E-1: Final Rule
I will just speak to E-1 on the agenda today. I want to thank the team as well: Nicole, Eugene, and the rest of the team who worked really hard right up to the last minute on this rule. Thank you for that.
The Chairman describes what the rule is going to do. It directs NERC to establish standards to allow grid operators to better model and plan for how inverter-based resources operate. I think it is also important that Chairman Phillips mentioned that integrating IBRs—generation with built-in computers—provides an exciting opportunity for dynamic response and for increased operational flexibility. My understanding through NERC and through staff is that most of the IBRs on our grid will be able to meet any performance requirement that NERC might put forward with simple software upgrades. That said, there is an increasingly small percentage of older IBRs that may not be able to update their software to comply. The rule we are passing today directs NERC to consider exceptions for these older IBRs. I hope to see such exceptions, as doing so will allow these older resources to continue to provide value to customers without compromising system reliability.
Similarly, today’s order directs NERC to consider, but does not mandate, data sharing requirements from transmission owners to the IBR generation owners. The record in the proceeding indicates that generator owners require data to support the support the modeling and performance requirements that we are now directing NERC to create. I understand that in some cases procedures do exist for access to this data, but to me, if our goal is to ensure that these resources can perform as expected, I would have preferred to require information sharing. Not only from IBR resources to transmission operators, but also in reverse. I hope that NERC will mandate such sharing in its standards development process. I think it is kind out tough to make people bake a cake without giving them the recipe.
As I said when we proposed this rule, today’s order is exactly the kind of action the Commission should be taking. We all agree on that. We are a technology-neutral regulator, and our responsibility is to facilitate what is happening on the grid using the lessons we have learned to safely integrate IBR resources or any kind of resources. I am happy to hand this over to NERC and look forward to what they will bring back to us on this front. Thanks again.