RM22-12 Non-Substantive Change Justification

Final Rule for RM22-12 725_Non-Substantive Change Justification.docx

FERC-725, Final Rule in Docket No. RM22-12-000, No Material or Nonsubstantive Change to Certification of Electric Reliability Organization; Procedures for Electric Reliability Standards

RM22-12 Non-Substantive Change Justification

OMB: 1902-0225

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FERC-725 (OMB Control No. 1902-0225)

Docket No. RM22-12, issued 10/19/2023 and published on 10/30/2023

RIN:1902-AG07


Justification for Non-Material or Non-Substantive Change

to the FERC-725 “Certification of Electric Reliability Standards; Procedures for Electric Reliability Standards”,

Docket No.

RM22-12 (Registration of Inverter Based Resources)


In this order, Docket RD22-12 issued on October 5, 2022,1 the Federal Energy Regulatory Commission (Commission or FERC) The information collection affected by this order is FERC–725, “Certification of Electric Reliability Organization; Procedures for Electric Reliability Standards” (OMB Control Number 1902-0225). The information collection requirements in the RM22-12 are covered by and included in, the existing OMB-approved FERC-725.


NERC is directed to fulfill the following in RD22-12:



NERC to submit new or modified Reliability Standards that address specific matters pertaining to the impacts of IBRs on the reliable operation of the Bulk-Power System are covered by, and already included in, the existing OMB-approved information collection FERC-725 (Certification of Electric Reliability Organization; Procedures for Electric Reliability Standards; OMB Control No. 1902-0225), under Reliability Standards Development.

In this final rule, we direct NERC to develop new or modify the currently effective Reliability Standards to address these issues and, when these Reliability Standards are submitted to the Commission for approval, to explain in the accompanying petition how the issues are addressed in the proposed new or modified Reliability Standards.  NERC may propose to develop new or modified Reliability Standards that address our concerns in an equally efficient and effective manner; however, NERC’s proposal should explain how the new or modified Reliability Standards address the Commission’s concerns discussed in this final rule. The Federal Energy Regulatory Commission (Commission) is directing the North American Electric Reliability Corporation (NERC), the Commission-certified Electric Reliability Organization, to develop new or modified Reliability Standards that address reliability gaps related to inverter-based resources in the following areas: data sharing; model validation; planning and operational studies; and performance requirements. The Commission is also directing NERC to submit to the Commission an informational filing within 90 days of the issuance of this final rule that includes a detailed, comprehensive standards development plan providing that all new or modified Reliability Standards necessary to address the inverter-based resource-related reliability gaps identified in this final rule be submitted to the Commission by November 4, 2026.




The FERC-725 contains the following information collection elements.


The requirement for NERC to develop, revise, or update Reliability Standards is already covered by the FERC-725 information collection (Certification of Electric Reliability Organization; Procedures for Electric Reliability Standards).2


The OMB-approved FERC-725 information collection includes the burden, reporting and record-keeping requirements associated with:


  • Reliability Standards Development;

  • Reliability Assessments;

  • Self-Assessment and ERO Application;

  • Reliability Compliance;

  • Stakeholder Survey; and

  • Other Reporting.


Accordingly, the Commission considers this as a non-material or non-substantive change to the currently approved FERC-725 information collection.

2 Any Reliability Standards submitted by NERC for Commission approval in compliance with Docket No. RM22-12 would be considered by the Commission in future proceedings.

File Typeapplication/vnd.openxmlformats-officedocument.wordprocessingml.document
File Titlenon-substantive or no material justification
AuthorCamilla Ryan
File Modified0000-00-00
File Created2023-12-21

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