The Federal Energy Regulatory Commission (“FERC”) recently approved the North American Electric Reliability Corporation’s (“NERC”) request to expand registration and compliance requirements to inverter-based resources (“IBRs”) that meet or exceed 20 MVA and are interconnected at or above 60 kV. This will impact certain wind, solar, battery, and fuel cell facilities that were previously too small to be required to register with NERC.
Specifically, NERC has expanded the Generator Owner (“GO”) and Generator Operator (“GOP”) registration functions to include new subcategories, called Category 2 Generator Owners (“Category 2 GOs”) and Category 2 Generator Operators (“Category 2 GOPs”). As a result, a wide range of entities that own mid-sized IBRs that meet the following descriptions of a Category 2 GO or a Category 2 GOP will be required to register with NERC:
Category 2 GO: an entity that “owns and maintains non-[bulk electric system (“BES”)] inverter-based generating resources that either have or contribute to an aggregate nameplate capacity of greater than or equal to 20 MVA, connected through a system designed primarily for delivering such capacity to a common point of connection at a voltage greater than or equal to 60 kV”
Category 2 GOP: an entity that “operates non-BES inverter-based generating resources that either have or contribute to an aggregate nameplate capacity of greater than or equal to 20 MVA, connected through a system designed primarily for delivering such capacity to a common point of connection at a voltage greater than or equal to 60 kV”
The reference to “generating resources” includes battery storage facilities and fuel cells. Thus, IBRs that meet or exceed the 20 MVA capacity threshold and the 60 kV interconnection threshold will generally be required to register with NERC as a Category 2 GO and/or a Category 2 GOP. Whether an entity is required to register is a facility-specific technical determination.
As shown in the following milestones, NERC is currently conducting outreach to candidates for registration. Registration will take place between May 2025 and May 2026.
Image: NERC – IBR Registration Initiative Quick Reference Guide
For proactive compliance, renewable energy companies should consider the following action items:
- Analyze all currently operating projects that are not registered with NERC as a GO or GOP to determine if any will be required to register with NERC as a Category 2 GO or a Category 2 GOP.
- Analyze development-stage projects to determine if any will be required to register with NERC as a Category 2 GO or a Category 2 GOP. Prioritize this analysis for late-stage development projects.
- Contact a NERC compliance consultant or agent and make a plan for Category 2 GO/GOP registration and compliance obligations.
For further information about this compliance requirement, contact Sylvia Bartell or an attorney in Husch Blackwell’s Energy Regulation practice group.
Refer to NERC, 187 FERC ¶ 61,196 (2024) and Reliability Standards to Address Inverter-Based Resources, Order No. 901, 185 FERC ¶61,042 (2023).