The Federal Energy Regulatory Commission (FERC) has proposed new grid reliability standards to ensure grid reliability as the energy landscape shifts toward renewable energy resources. On December 19, 2024, under Docket No. RM25-3-000, FERC issued a Notice of Proposed Rulemaking (NOPR) targeting inverter-based resources (IBRs) such as solar photovoltaic systems, wind turbines, and battery storage facilities.
These changes present opportunities and challenges for renewable energy developers, operators, and stakeholders. Ingrid Bjorklund and Bray Dohrwardt from Avisen Legal have years of experience advising clients and are ready to help you navigate these evolving regulations proposed by FERC. From assisting with compliance audits to handling regulatory investigations and engaging in rulemaking processes, Ingrid and Bray offer the knowledge and insight your business needs to stay ahead.
What FERC’s NOPR Proposes
New Ride-Through Standards for Inverter-Based Resources
The proposed rule introduces a key requirement that IBR “ride through” frequency and voltage disturbances remain connected and operational to support grid stability. This addresses common failures, such as when IBR reduces output, momentarily ceases operations, or trips offline during grid events.
Updates to NERC Reliability Standards
FERC proposes updates to North American Electric Reliability Corporation (NERC) standards:
- PRC-024-4: Refines frequency and voltage protection standards for synchronous generators, Type 1 and Type 2 wind resources, and synchronous condensers, ensuring compatibility with modern grid demands.
- PRC-029-1: Establishes detailed ride-through performance requirements for IBRs, such as wind and solar facilities with advanced power electronics. This standard ensures IBRs inject current and perform frequency support during disturbances while restricting momentary cessation.
Exemptions for Legacy Inverter-Based Resources
Acknowledging hardware limitations in older IBRs, FERC proposes directing NERC to develop an exemption process for systems already operational by the new standards’ effective date and seeks to understand the volume of exemptions:
- Eligibility: Legacy IBRs must demonstrate that hardware constraints prevent compliance.
- Documentation: Generator owners must submit detailed reports on limitations to regional compliance authorities for review.
Data Transparency Through Informational Filings
FERC requires NERC to file two reports within 12 and 24 months after the conclusion of the 12-month exemption request period. These reports will evaluate:
- The total number of IBRs subject to the standards.
- Exemptions requested, granted, and denied.
- Impacts of exemptions on grid reliability.
Industry Input Sought
FERC invites public comments within 60 days of the NOPR’s publication in the Federal Register. Stakeholders can weigh in on ride-through requirements, the exemption process, and the long-term implications of these proposals.
Implications for Energy Developers and Operators
Operational Adjustments
IBR operators may need to upgrade control systems, modify operational protocols, or invest in new hardware to meet the stringent ride-through requirements.
Compliance Costs
Compliance with the new standards could require significant capital investment, particularly for facilities without advanced ride-through capabilities. The exemption process adds administrative complexity for legacy facilities.
Regulatory Risk
Non-compliance with these rules could result in penalties, reputational damage, or operational disruptions. Conversely, timely compliance can help avoid these risks and enhance your facilities’ grid value.
How Ingrid Bjorklund and Bray Dohrwardt Can Help
Ensure Compliance
Ingrid and Bray can assist in interpreting the new standards and developing strategies to meet FERC’s requirements, whether through system upgrades or procedural changes.
Manage Exemption Applications
If your IBR qualifies as a legacy facility, Ingrid and Bray will guide you through the exemption process, helping you document hardware limitations and submit the necessary reports to compliance authorities.
Represent Your Interests
FERC’s comment process is a vital opportunity to advocate for industry needs. Ingrid and Bray can help draft and submit detailed comments on your behalf, ensuring your voice is heard during the rulemaking process.
Plan Strategically
Whether planning facility upgrades, assessing future project impacts, or preparing for regulatory audits, Ingrid and Bray will provide strategic guidance to align your business goals with evolving regulatory expectations.
Why Act Now?
The energy landscape is rapidly evolving, and these proposed standards underscore the importance of proactive compliance. With 60 days to comment and tight timelines for implementation, now is the time to act.
Key Deadlines:
- Comment Period: Within 60 days of the NOPR’s publication in the Federal Register.
- Exemption Applications: Legacy IBR operators will have a limited 12-month window to submit exemption requests after the new standards take effect.
Take the Next Step with Ingrid Bjorklund and Bray Dohrwardt at Avisen Legal
At Avisen Legal, Ingrid and Bray are ready to provide the legal guidance your business needs to navigate these regulatory changes. With extensive experience in NERC compliance, regulatory investigations, and rulemaking, they are well-equipped to help you achieve compliance while protecting your bottom line.
Contact us today to schedule a consultation and discuss how Ingrid and Bray can help you confidently meet FERC’s new standards. Whether you need support in compliance, advocacy, or strategic planning, Avisen Legal is here to turn challenges into opportunities for growth.
Let Ingrid Bjorklund and Bray Dohrwardt guide your business through these transformative changes and ensure your success in the evolving energy market.
