IBR Petition

IBR Definition Petition_final.pdf

FERC-725G, RD25-1-000, RD25-2-000, RD25-3-000; RM25-3 Mandatory Reliability Standards for the Bulk-Power System: PRC Rel Stds.

IBR Petition

OMB: 1902-0252

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UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
North American Electric Reliability
Corporation

)

Docket No. _________

)

PETITION OF THE NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION
FOR APPROVAL OF A NEW TERM “INVERTER-BASED RESOURCE” USED IN
NERC RELIABILITY STANDARDS

Lauren A. Perotti
Assistant General Counsel
Alain Rigaud
Associate Counsel
North American Electric Reliability Corporation
1401 H Street, N.W., Suite 410
Washington, D.C. 20005
(202) 400-3000
(202) 644-8099 – facsimile
[email protected]
[email protected]
Counsel for the North American Electric
Reliability Corporation

November 4, 2024

TABLE OF CONTENTS
NOTICES AND COMMUNICATIONS ............................................................................. 3
BACKGROUND .................................................................................................................. 3
Regulatory Framework .................................................................................................... 3
NERC Reliability Standards Development Procedure .................................................... 4
Glossary of Terms used in NERC Reliability Standards ................................................. 5
Procedural Development of the Proposed Inverter-Based Resource (IBR) Definition ... 6
JUSTIFICATION FOR APPROVAL .................................................................................. 9
EFFECTIVE DATE OF THE PROPOSED INVERTER-BASED RESOURCE (IBR)
DEFINITION ................................................................................................................................ 14
CONCLUSION .................................................................................................................. 15

Exhibit A
Exhibit B
Exhibit C
Exhibit D
Exhibit E
Exhibit F

Proposed Definition for Inclusion in the Glossary of Terms used in NERC
Reliability Standards
Implementation Plan
Technical Rationale
Order No. 672 Criteria
Summary of Development and Complete Record of Development
Standard Drafting Team Roster, Project 2020-06 Verifications of Models and
Data for Generators – IBR Definition

UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
North American Electric Reliability
Corporation

)

Docket No. ________

)

PETITION OF THE NORTH AMERICAN ELECTRIC RELIABILITY CORPORATION
FOR APPROVAL OF A NEW TERM “INVERTER-BASED RESOURCE” USED IN
NERC RELIABILITY STANDARDS
Pursuant to Section 215(d)(1) of the Federal Power Act (“FPA”) 1 and Section 39.5 2 of the
Federal Energy Regulatory Commission’s (“FERC” or “Commission”) regulations, the North
American Electric Reliability Corporation (“NERC”) 3 hereby submits for Commission approval a
new definition of the term Inverter-Based Resource (“IBR”), for inclusion in the Glossary of Terms
used in NERC Reliability Standards. 4
The proposed definition for inclusion in the NERC Glossary is:
•

Inverter-Based Resource: A plant/facility consisting of individual devices that are
capable of exporting Real Power through a power electronic interface(s) such as an
inverter or converter, and that are operated together as a single resource at a
common point of interconnection to the electric system. Examples include, but are
not limited to, plants/facilities with solar photovoltaic (PV), Type 3 and Type 4
wind, battery energy storage system (BESS), and fuel cell devices.

16 U.S.C. § 824o.

18 C.F.R. § 39.5 (2023).

The Commission certified NERC as the electric reliability organization (“ERO”) in accordance with Section
215 of the FPA on July 20, 2006. N. Am. Elec. Reliability Corp., 116 FERC ¶ 61,062 (2006), order on reh’g &
compliance, 117 FERC ¶ 61,126 (2006), aff’d sub nom. Alcoa, Inc. v. FERC, 564 F.3d 1342 (D.C. Cir. 2009).

The Glossary of Terms used in NERC Reliability Standards (“NERC Glossary” or “Glossary”) is available
on the NERC website at https://www.nerc.com/pa/Stand/Glossary%20of%20Terms/Glossary_of_Terms.pdf. Unless
otherwise indicated, all capitalized terms used in this petition shall have the meaning set forth in the NERC Glossary.
4

The proposed definition was developed through NERC’s Commission-approved standard
development process. NERC Board of Trustees adopted the proposed IBR definition on October
8, 2024.
NERC requests that the Commission approve the proposed IBR definition, as shown in
Exhibit A, as just, reasonable, not unduly discriminatory or preferential, and in the public interest.
NERC also requests that the Commission approve the proposed implementation plan (Exhibit B),
under which the proposed IBR definition would become effective on the first day of the first
calendar quarter following regulatory approval.
As required by Section 39.5(a) 5 of the Commission’s regulations, this petition presents the
technical basis and purpose of the proposed IBR definition, along with relevant background
(Sections II and III), a demonstration that the proposed IBR definition meets the criteria identified
by the Commission in Order No. 672 6 (Exhibit D), and a summary of the development history for
the proposed IBR definition (Exhibit E).

18 C.F.R. § 39.5(a).

The Commission specified in Order No. 672 certain general factors it would consider when assessing whether
a particular Reliability Standard is just and reasonable. Rules Concerning Certification of the Electric Reliability
Organization; and Procedures for the Establishment, Approval, and Enforcement of Electric Reliability Standards,
Order No. 672, 114 FERC ¶ 61,104, at P 262, 321-37 [hereinafter Order No. 672], order on reh’g, Order No. 672-A,
114 FERC ¶ 61,328 (2006).
6

NOTICES AND COMMUNICATIONS
Notices and communications with respect to this filing may be addressed to the following: 7
Lauren A. Perotti
Assistant General Counsel
Alain Rigaud
Associate Counsel
North American Electric Reliability
Corporation
1401 H Street NW
Suite 410
Washington, D.C. 20005
(202) 400-3000
(202) 644-8099 – facsimile
[email protected]
[email protected]

Soo Jin Kim
Vice President, Engineering and Standards
Jamie Calderon
Director, Standards Development
North American Electric Reliability
Corporation
3353 Peachtree Road, N.E.
Suite 600, North Tower
Atlanta, GA 30326
(404) 446-2560
(404) 446-2595 – facsimile
[email protected]
[email protected]

BACKGROUND
Regulatory Framework
By enacting the Energy Policy Act of 2005, 8 Congress entrusted the Commission with the
duties of approving and enforcing rules to ensure the reliability of the Bulk-Power System
(“BPS”), and with the duties of certifying an ERO that would be charged with developing and
enforcing mandatory Reliability Standards, subject to Commission approval. Section 215(b)(1) 9
of the FPA states that all users, owners, and operators of the BPS in the United States will be
subject to Commission-approved Reliability Standards. Section 215(d)(5) 10 of the FPA authorizes
the Commission to order the ERO to submit a new or modified Reliability Standard. Section

NERC requests waiver of 18 C.F.R. § 385.203(b) to permit the inclusion of more than two people on the
service list.

16 U.S.C. § 824o.

Id. § 824o(b)(1).

Id. § 824o(d)(5).

39.5(a) 11 of the Commission’s regulations requires the ERO to file with the Commission for its
approval each new Reliability Standard that the ERO proposes should become mandatory and
enforceable in the United States, and each modification to a Reliability Standard that the ERO
proposes should be made effective.
The Commission is vested with the regulatory responsibility to approve Reliability
Standards that protect the reliability of the BPS and to ensure that Reliability Standards are just,
reasonable, not unduly discriminatory or preferential, and in the public interest. Pursuant to
Section 215(d)(2) of the FPA 12 and Section 39.5(c) 13 of the Commission’s regulations, the
Commission will give due weight to the technical expertise of the ERO with respect to the content
of a Reliability Standard.
NERC Reliability Standards Development Procedure
NERC develops Reliability Standards and definitions of terms used in Reliability
Standards in accordance with Section 300 (Reliability Standards Development) of its Rules of
Procedure and the NERC Standard Processes Manual. 14 In its order certifying NERC as the
Commission’s ERO, the Commission found that NERC’s rules provide for reasonable notice and
opportunity for public comment, due process, openness, and a balance of interests in developing
Reliability Standards, 15 and thus satisfy several of the Commission’s approval criteria. 16 The
development process is open to any person or entity with a legitimate interest in the reliability of

18 C.F.R. § 39.5(a).

16 U.S.C. § 824o(d)(2).

18 C.F.R. § 39.5(c)(1).

The NERC Rules of Procedure, including Appendix 3A, NERC Standard Processes Manual, are available at
https://www.nerc.com/AboutNERC/Pages/Rules-of-Procedure.aspx.
14

N. Am. Elec. Reliability Corp., 116 FERC ¶ 61,062 at P 250 (2006).

Order No. 672, supra note 7, at PP 268, 270.

the BPS. NERC considers the comments of all stakeholders. Stakeholders must approve, and the
NERC Board of Trustees must adopt, a new or revised Reliability Standard or definition before
NERC submits the Reliability Standard or definition to the Commission for approval.
Glossary of Terms used in NERC Reliability Standards
NERC maintains a comprehensive, up-to-date document on its web site that reflects all
defined terms used in Reliability Standards that have been adopted by the NERC Board of
Trustees: the Glossary of Terms used in NERC Reliability Standards (“Glossary” or “NERC
Glossary”). The NERC Glossary reflects the status of Commission approval and effective dates
and contains links to the archive of the development of each definition. In Order No. 693 17
approving the first mandatory and enforceable Reliability Standards and defined terms, the
Commission highlighted the role the NERC Glossary plays in promoting a consistent and clear
understanding of terms used throughout the Reliability Standards:
The terms defined in the glossary have an important role in
establishing consistent understanding of the Reliability Standards
Requirements and implementation. The approval of the glossary
will provide continuity in application of the glossary definitions
industry-wide, and will eliminate multiple interpretations of the
same term or function, which may otherwise create
miscommunication and jeopardize Bulk-Power System reliability. 18
The Commission further stated, “The glossary should be updated through the Reliability
Standards development process whenever a new or revised Reliability Standard that includes a
new defined term is approved, or as needed to clarify compliance activities.” 19

Mandatory Reliability Standards for the Bulk-Power System, Order No. 693, 118 FERC ¶ 61,218 (2007)
[hereinafter Order No. 693].
18
Id. at P 1893.
17

Id.

Since the NERC Glossary was first approved in 2007, the Commission has approved new
defined terms and revisions to the definitions of existing terms developed through the standard
development process, as well as the retirement of previously effective terms and definitions. While
defined terms typically accompany the new or revised Reliability Standards that will use those
terms, NERC has on occasion proposed new or revised defined terms independent of a proposed
Reliability Standard. 20
Procedural Development of the Proposed Inverter-Based Resource (IBR)
Definition
NERC developed the proposed IBR definition through Project 2020-06 Verifications of
Models and Data for Generators. NERC initiated Project 2020-06 in 2021 to address a Standard
Authorization Request (“SAR”) submitted by the NERC Inverter-Based Resource Performance
Task Force (“IRPTF”). In 2020, the IRPTF published a white paper summarizing the results of its
review of NERC Reliability Standards. 21 The IRPTF undertook this review to determine if there
were opportunities to address gaps or otherwise improve the standards to assure reliability
considering the unprecedented growth of IBRs on the Bulk Power System. Among other things,
the IRPTF recommended revisions to MOD-026-1 and MOD-027-1 to address issues related to
model verification for IBRs. 22

See, e.g., Petition of NERC for Approval of Revised Definitions of Terms used in Reliability Standards,
Docket No. RD16-3-000 (Dec. 7, 2015); Petition of NERC for Approval of New, Revised, and Retired Definitions of
Terms used in Reliability Standards, Docket No. RD24-6-000 (March. 8, 2024).
20

IPRTF White Paper at 4.

On October 19, 2023, while work was underway on Project 2020-06, the Commission
issued Order No. 901. 23 In Order No. 901, the Commission directed NERC to develop new or
modified Reliability Standards addressing reliability concerns related to IBRs at “all stages of
interconnection, planning, and operations,” 24 and to develop new or revised Reliability Standards
addressing IBR reliability issues as follows:
•

IBR disturbance monitoring data sharing and post-event performance validation 25
and ride-through performance requirements 26 by November 4, 2024;

•

IBR data and model validation 27 by November 4, 2025; and

•

planning and operational studies 28 for IBRs by November 4, 2026.

The Commission also directed NERC to develop and submit a work plan to develop new
and revised Reliability Standards to address these issues in accordance with the specified
timeframes above. 29
On January 17, 2024, NERC submitted its Order No. 901 Work Plan 30 outlining a
comprehensive work plan with key milestones to address the directives by the deadlines set in
Order No. 901. The Order No. 901 Work Plan consists of four key milestones with associated dates
for completion, which are consistent with the Commission’s direction in Order No. 901. These
milestones are summarized below:

Reliability Standards to Address Inverter-Based Resources, Order No. 901, 185 FERC ¶ 61,042 (2023)
[hereinafter Order No. 901].

Id. at P 25.

See id. at PP 66-109 (discussing directives related to data sharing requirements).

See id. at PP 178-211 (discussing directives related to performance requirements).

See id. at PP 110-161 (discussing directives related to data and model validation requirements).

See id. at PP 162-177 (discussing directives related to planning and operational studies requirements).

See id. at P 222.

Informational Filing of the North American Electric Reliability Corporation Regarding the Development of
Reliability Standards Responsive to Order No. 901, Docket No. RM22-12-000 (Jan. 17, 2024) [hereinafter Order
No. 901 Work Plan].

•

Milestone 1: Submission of Order No. 901 Work Plan (completed: January 17,
2024)

•

Milestone 2: Development and filing of Reliability Standards to address
disturbance monitoring data sharing, IBR performance requirements, and postevent performance validation for registered IBRs (completion: November 4, 2024)

•

Milestone 3: Development and filing of Reliability Standards to address data
sharing and model validation for all IBRs (completion: November 4, 2025)

•

Milestone 4: Development and filing of Reliability Standards to address planning
and operational studies requirements for all IBRs (completion: November 4, 2026)

Within Milestone 2 of the workplan, NERC identified several active standards
development projects to address disturbance monitoring, performance-based ride-through
requirements, and post-event performance validation for registered IBRs. These projects are:
•

Project 2020-06 Verifications of Models and Data for Generators

•

Project 2021-04 Modifications to PRC-002-2 Disturbance Monitoring

•

Project 2020-02 Modifications to PRC-024 (Generator Ride-through); and

•

Project 2023-02 Analysis and Mitigation of BES Inverter-Based Resource
Performance Issues.

Relevant to this filing, NERC determined that, given the multiple standards development
projects underway to address the risks related to IBRs, a single drafting team should move forward
with a definition of IBR that would be leveraged by all other projects. NERC selected Project
2020-06 to coalesce development efforts for the definition and coordinate the proposed definition
with the other NERC projects addressing IBR issues.
NERC developed the proposed definition using NERC’s standard development process.
The proposed definition of IBR was developed in an open and fair manner and in accordance with
the Commission-approved development process for Reliability Standards and definitions of terms
used in Reliability Standards, which included multiple comment and ballot periods. The proposed
definition of was adopted by the NERC Board of Trustees on October 8, 2024. A summary of the

development history and the complete record of development is attached to this petition as Exhibit
E.
JUSTIFICATION FOR APPROVAL
The addition of IBR as a defined term within the NERC Glossary will establish a consistent
understanding of the meaning of the term across all NERC Reliability Standards going forward.
This term is used in the Order No. 901 Work Plan Milestone 2 Reliability Standards being
proposed in the projects listed in Section II(D), above, and will be used in other Reliability
Standards addressing IBR-related reliability risks. The addition of a single defined term to the
NERC Glossary would promote consistency, avoid confusion, and facilitate efficiency for drafting
teams addressing IBR issues.
As outlined above, NERC proposes the Commission approve the following definition of
IBR for inclusion in the NERC Glossary:
Inverter-Based Resource: A plant/facility consisting of individual devices that are
capable of exporting Real Power through a power electronic interface(s) such as an
inverter or converter, and that are operated together as a single resource at a
common point of interconnection to the electric system. Examples include, but are
not limited to, plants/facilities with solar photovoltaic (PV), Type 3 and Type 4
wind, battery energy storage system (BESS), and fuel cell devices.
In developing the proposed IBR definition, the drafting team referred to the IEEE 28002022 definition of inverter-based resource (IBR), 31 as well as definitions of the term reflected in

IEEE, Standard for Interconnection and Interoperability of Inverter-Based Resources (IBRs)
Interconnecting with Associated Transmission Electric Power Systems, IEEE 2800-2022 (2022),
https://standards.ieee.org/ieee/2800/10453/ (establishing uniform technical minimum requirements for the
interconnection, capability, and performance of IBRs for reliable integration onto the electric system).

both NERC 32 and Commission documents. 33 Inverter-based resources have commonly been
referred to as generating resources. Consistent with this common understanding, the proposed IBR
definition refers to a type of generation resource.
Under the proposed IBR definition, a resource (i.e., a plant or facility) would be considered
an IBR based on the technology it uses to export Real Power. The NERC Glossary defines Real
Power as “the portion of electricity that supplies energy to the Load.” For an IBR, the technology
consists of: (1) individual devices that are capable of exporting Real Power through a power
electronic interface(s) such as an inverter or converter; and (2) that are operated together as a single
resource at a common point of interconnection to the electric system.
The first part of the proposed definition refers to individual devices, such as turbines, solar
panels, batteries, or other devices, which are capable of exporting Real Power through a power
electronic interface. The phrase "power electronic interface" refers to the technology used to
convert the power that is generated by the devices to power that can be used on the electric system.
An inverter is a power electronic device that inverts DC power to AC sinusoidal power. A
converter is a power electronic device that performs inversion (i.e. inverts DC power to AC
sinusoidal power) or rectification (i.e. rectifies AC sinusoidal power to DC power). Generating
resources that do not have a “power electronic device” are not considered to be IBR, as their power

See, e.g., NERC, An Introduction to Inverter-Based Resources on the Bulk Power System (June 2023) at 3
(describing inverter-based resources as dispersed power-producing resources consisting of several components),
available at https://www.nerc.com/pa/Documents/2023_NERC_Guide_Inverter-Based-Resources.pdf. See also
NERC Rules of Procedure Appendix 2, Definitions used in the NERC Rules of Procedure (definitions of Generator
Owner and Generator Operator include owners and operators of certain “inverter based generating resources”
(emphasis added)
https://www.nerc.com/AboutNERC/RulesOfProcedure/Appendix%202%20eff%2020240627_signed.pdf.
32

See, e.g., Registration of Inverter Based Resources, 181 FERC ¶ 61,124 (2022) at note 1 (describing the
term IBR “to include all generating facilities that connect to the electric power system using power electronic
devices that change direct current (DC) power produced by a resource to alternating current (AC) power compatible
with distribution and transmission systems.”)

output is based on inherent qualities of the induction motor (Type 1), or they have a variable rotor
resistance (Type 2) that cannot dynamically control reactive power.
The inclusion of the phrase “capable of exporting Real Power” in the proposed IBR
definition is to clarify that IBRs are considered generating resources that provide Real Power to
load; loads connected to the electric system through power electronic devices are not generating
resources and are not to be considered IBRs. This would include, for example, resources that only
perform transmission functions, such as stand-alone flexible AC transmission systems (“FACTS”)
devices. These resources do not pose the same impact on the reliability of the Bulk-Power system
as IBR generation.
The second part of the definition refers to how the resource is connected to the electric
system. An IBR consists of individual devices (often many devices) that must be individually
modeled for accurate dynamic simulations and model quality analysis, but are operated by system
operators as a single, aggregated resource at a common point of interconnection to the electric
system. An IBR can be connected to any part of the transmission system, sub-transmission system,
or distribution system.
To illustrate, the proposed IBR definition includes several examples of IBRs that would
meet this definition, including plants/facilities with solar photovoltaic (PV), Type 3 and Type 4
wind, battery energy storage system (BESS), 34 and fuel cell devices. This list is not intended to be
exhaustive, nor is it intended to exclude from the definition resource types with IBR technological
characteristics that are developed in the future. Under the proposed IBR definition, IBRs may also

As explained in the Technical Rationale, battery energy storage systems (BESS) are considered IBRs
whether the device is operating in a charging, idle, or discharging mode. See Exhibit C Technical Rationale at 2.

include any hybrid combination of IBR resources such as PV and BESS, which includes portions
of a facility that have IBR resources like a BESS located at synchronous generation facility. 35
For clarity, the Technical Rationale includes examples of resources that would not be
considered IBRs under the proposed definition. Such examples include synchronous generators or
condensers, including gas and steam power plants. Other examples include stand-alone FACTS,
including static synchronous compensators (“STATCOM”) and static VAR compensators
(“SVC”) or voltage source converter high-voltage direct current (“VSC HVDC”) systems, unless
the VSC HVDC equipment is a dedicated point of connection for an IBR to the electric system.
The figure below shows an example diagram of an IBR. The IBR (red box) includes the
devices (blue boxes), collection system (green boxes), power plant controller(s) (not shown), and
reactive resources within the IBR plant. As noted above, If the IBR is connected to the electric
system via a dedicated voltage source converter high-voltage direct current (VSC HVDC) system,
the VSC HVDC system would be considered part of the IBR.

See Exhibit C Technical Rationale at 1. The Technical Rationale contains non-exhaustive lists of examples
of technologies that may be considered IBRs and that are not considered IBRs under the proposed IBR definition.

Figure 1: Example Diagram of an IBR
In developing the proposed IBR definition, the drafting team considered stakeholder
comments suggesting the definition contain other limiting factors not related to the technology
used, such defining IBR based on voltage connection level (kV) or facility capability level
(MW/MVA). 36 The drafting team considered these comments and determined that the proposed
IBR definition should describe only the technology used, and should not include factors that could
prescribe or limit the applicability of Reliability Standards using the definition. The determination
of which IBRs to include in a Reliability Standard would remain the responsibility of the drafting
team developing that standard. For example, the drafting team developing a standard applicable to
IBRs may specify that it applies to BES IBR Facilities or to both BES IBR Facilities and non-BES

See, e.g., Exhibit E Summary of Development and Complete Record of Development at item 22, February
22, 2024 Consideration of Comments, at 16 et seq. (responses to Question 1).

IBRs meeting the criteria for inclusion under the recently approved NERC Rules of Procedure
registry criteria. 37
As discussed in Exhibit D, the proposed IBR definition meets the Commission’s criteria
for approval in Order No. 672. It would improve clarity and advance reliability in the Reliability
Standards in which it is used. Commission approval of the proposed IBR definition would be just,
reasonable, not unduly discriminatory, and in the public interest. NERC respectfully requests that
the Commission approve the proposed IBR definition, to become effective in accordance with the
proposed implementation plan discussed in Section IV.
EFFECTIVE DATE OF THE PROPOSED INVERTER-BASED RESOURCE (IBR)
DEFINITION
NERC respectfully requests that the Commission approve the implementation plan
attached to this petition as Exhibit B. The proposed implementation plan provides that the
proposed IBR definition would become effective on the first day of the first calendar quarter after
applicable regulatory approval. Any proposed standards using this term would become effective
in accordance with their respective implementation plans.

Order Approving Revisions to North American Electric Reliability Corporation Rules of Procedure and
Requiring Compliance Filing, 187 FERC ¶ 61,196 (2024) (the Commission approved revisions to the Generator
Owner and Generator Operator functions in the Registry Criteria to include a new category, Category 2 Generator
Owner and Category 2 Generator Operator, that own or operate non-BES IBRs).

CONCLUSION
For the reasons set forth above, NERC respectfully requests that the Commission approve:
•

The proposed IBR definition, as shown in Exhibit A; and

•

The implementation plan included in Exhibit B.

Respectfully submitted,
/s/ Alain Rigaud
Lauren A. Perotti
Assistant General Counsel
Alain Rigaud
Associate Counsel
North American Electric Reliability Corporation
1401 H Street, N.W., Suite 410
Washington, D.C. 20005
(202) 400-3000
(202) 644-8099 – facsimile
[email protected]
[email protected]
Counsel for the North American Electric
Reliability Corporation
November 4, 2024

Exhibit A
Proposed Definition for Inclusion in the Glossary of Terms used in NERC Reliability Standards

RELIABILITY | RESILIENCE | SECURITY

Project 2020-06 Verifications of Models and Data for Generators – IBR Definition

Description of Current Draft
Completed Actions

Date

Standards Committee approved Standards Authorization Request (SAR)

September 24, 2020

SAR posted for comment

December 16, 2020 – January 14, 2021

45-day formal comment period with initial ballot

November 16, 2023 – January 9, 2024

45-day formal comment period with additional ballot

February 22 – April 8, 2024

Standards Committee approved Standards Authorization Request (SAR)

May 15, 2024

30-day formal comment period with additional ballot

July 12 – August 12, 2024

Anticipated Actions

Date

10-day final ballot

September 3 – September 12, 2024

NERC Board adoption

October 8-9, 2024

Project 2020-06 | Final Draft of IBR Definition
September 2024

Page 1 of 3

Project 2020-06 Verifications of Models and Data for Generators – IBR Definition

New or Modified Term(s) Used in NERC Reliability Standards

This section includes all new or modified terms used in the proposed standard that will be included in the
Glossary of Terms Used in NERC Reliability Standards upon applicable regulatory approval. The term proposed
below is intended to be used in MOD-026-2 and other inverter-based resource related standards.
Term(s):

Inverter-Based Resource (IBR): A plant/facility consisting of individual devices that are capable of exporting
Real Power through a power electronic interface(s) such as an inverter or converter, and that are operated
together as a single resource at a common point of interconnection to the electric system. Examples include,
but are not limited to, plants/facilities with solar photovoltaic (PV), Type 3 and Type 4 wind, battery energy
storage system (BESS), and fuel cell devices.

Project 2020-06 | Final Draft of IBR Definition
September 2024

Page 2 of 3

2020-06 Verifications of Models and Data for Generators – IBR Definition

Version History
Version
1

Date
TBD

Action

Change Tracking

New IBR Definition

Project 2020-06 | Final Draft of IBR Definition
September 2024

Page 3 of 3

Exhibit B
Implementation Plan

RELIABILITY | RESILIENCE | SECURITY

Implementation Plan

Project 2020-06 Verifications of Models and Data for Generators
Inverter-Based Resource Definition
Applicable Standard(s)
•

None

Requested Retirement(s)
•

None

Prerequisite Standard(s)

These standard(s) or definition must be approved before the Applicable Standard becomes effective:
•

None

Applicable Entities
•

None

New/Modified/Retired Terms in the NERC Glossary of Terms
•

Inverter-Based Resource (IBR)

Background

As multiple standards development projects are actively addressing risks related to inverter-based
generation, NERC evaluated the need for a single standards project to move forward with definitions that
would be leveraged by all other projects. Project 2020-06 was identified as the drafting team (DT) that would
coalesce development efforts for the definition and coordinate proposed definition with the other NERC
developers. The DT proposes the definition of IBR to be used in Reliability Standard MOD-026-2, as well as
other IBR related standards development projects.
General Considerations
Multiple standards in development will use the definition, and the proposed implementation time frame is
intended to reflect that any one of those standards may be the first to use the definition. Additionally, this
implementation plan only affects the date that this new definition will become an effective term in the NERC
Glossary of Terms. A separate implementation plan will be developed for MOD-026-2, including
requirements that use the proposed definition.

RELIABILITY | RESILIENCE | SECURITY

Effective Date

The effective date(s) for the proposed definition for Glossary of Terms are provided below.
Where approval by an applicable governmental authority is required, the proposed definition shall become
effective on the first day of the first calendar quarter after the applicable governmental authority’s order
approving the definition, or as otherwise provided for by the applicable governmental authority.
Where approval by an applicable governmental authority is not required, the proposed definition shall
become effective on the first day of the first calendar quarter after the date the definition are adopted by
the NERC Board of Trustees, or as otherwise provided for in that jurisdiction.

Implementation Plan for IBR Definition
Project 2020-06 Verifications of Models and Data for Generators | September 2024

Exhibit C
Technical Rationale

RELIABILITY | RESILIENCE | SECURITY

Technical Rationale

Project 2020-06 Verification of Models and Data for Generators
IBR Definition | August 2024
Inverter-based Resource Definition

The drafting team (DT) utilized the IEEE 2800-2022 definitions as an initial basis for the inverter-based
resource terms for the NERC Glossary of Terms and adjusted, as necessary. The DT acknowledges the
efforts of the P2800 Wind and Solar Plant Interconnection Performance Working Group and IEEE members
in developing those definitions. The DT also used recent FERC and NERC documents, which included
inverter-based resource related terms and descriptions, as the basis for the IBR definitions.
The IBR definition is intended to describe technologies that shall be considered IBR. An IBR is defined by
technology, thus voltage connection level (kV), facility capability level (MW/MVA), or other factors do not
impact the inclusion as an IBR. An IBR can be connected to any part the transmission system, subtransmission system, or distribution system. For Reliability Standards that use the IBR term, the
Applicability Section for that Reliability Standard(s) will specify which IBRs are applicable. Each of these
Reliability Standards, including the Applicability Section(s) will be balloted in accordance with the NERC
Rules of Procedure, and the Applicability Section. For example, an Applicability Section may specify that IBR
Facilities (BES), IBRs that are owned by a Generator Owner (Category 2), or IBRs that are operated by a
Generator Operator (Category 2), are considered applicable.
IBRs have commonly been referred to as “generating resources.” An IBR is not a HVDC system (except for a
high-voltage direct current (VSC HVDC) with a dedicated connection to an IBR, as this is part of the IBR
facility), stand-alone flexible ac transmission systems (FACTS) (e.g., static synchronous compensators
(STATCOM) and static VAR compensators (SVC)), or any resources that are not inverter-based, e.g., gas and
steam power plants with synchronous generators. A list of IBRs is provided in Table 1 below.
IBRs may include any hybrid combination of IBR types (e.g., BESS and solar PV). IBRs also include co-located
portions of a facility that are IBR technologies (e.g., a BESS, which is co-located at synchronous generation
facility), see table below.
Examples
IBR
•
•
•
•
•
•
•
•
•

Solar photovoltaic
Type 3 wind
Type 4 wind
Battery energy storage system (BESS)
Fuel cell(s)
Hybrid combination of IBRs
Portions of co-located facility that are IBR
VSC HVDC with dedicated connection to IBR
This is not an all-inclusive list.

Not an IBR
•
•
•
•
•
•
•

Stand-alone FACTS device (e.g., STATCOM or SVC)
Flywheels
Synchronous generator
Synchronous condenser
VSC HVDC
Line-Commutated Converters (LCC) HVDC
This is not an all-inclusive list.

RELIABILITY | RESILIENCE | SECURITY

An inverter is a power electronic device that inverts DC power to AC sinusoidal power. A rectifier is a power
electronic device that rectifies AC sinusoidal power to DC power. A converter is a power electronic device
that performs rectification and/or inversion.
Figure 1 shows an example diagram of an IBR. The IBR (red box) includes the devices (blue boxes), collection
system (green boxes), power plant controller(s) (not shown), and reactive resources within the IBR plant. If
the IBR is connected to the electric system via a dedicated voltage source converter high-voltage direct
current (VSC HVDC) system, the VSC HVDC system is part of the IBR.

Figure 1 Example diagram of an IBR depicting the IBR (red box), collector system
(green box), and devices (blue boxes).
The inclusion of ‘capable of exporting Real Power’ is to clarify that loads connected to the electric system via
power electronics are not IBRs. IBRs are capable of exporting Real Power and may also be capable of
providing Reactive Power. The DT contemplated adding the phrase “may also be capable of providing
Reactive Power” in the definition(s). However, the DT believed this may be misinterpreted that IBRs include
technologies such as FACTS devices or HVDC.
Battery energy storage systems (BESS) are considered IBRs whether the device is operating in a charging,
idle, or discharging mode. Within each Reliability Standard, a DT may draft operating mode-specific
Requirements, as needed.
The Project 2020-06 DT intends to use the Glossary Term of IBR for MOD-026-2. Additional standard
development projects and related standards that may use this defined term include:
•

Project 2020-02 Generator Ride-through (new PRC-029, modified PRC-024)

Technical Rationale for IBR Definition
2020-06 Verification of Models and Data for Generators | September 2024

•

Project 2021-01 Modifications to PRC-019 and MOD-025

•

Project 2021-04 Modifications to PRC-002 (new PRC-028)

•

Project 2022-04 EMT Modeling

•

Project 2023-01 EOP-004 IBR Event Reporting

•

Project 2023-02 Analysis and Mitigation of BES Inverter-Based Resource Performance Issues (new
PRC-030)

Distributed Energy Resources (DER) related projects that may or may not need to use IBR (if they end up
with their own definition)
•

Project 2022-02 Modifications to TPL-001 and MOD-032 (DER)

•

Project 2023-05 Modifications to FAC-001 and FAC-002 (DER)

•

Project 2023-08 MOD-031 Demand and Energy (DER)

Technical Rationale for IBR Definition
2020-06 Verification of Models and Data for Generators | September 2024

Exhibit D
Order No. 672 Criteria

RELIABILITY | RESILIENCE | SECURITY

EXHIBIT D
Order No. 672 Criteria
In Order No. 672, 1 the Commission identified a number of criteria it will use to analyze
Reliability Standards proposed for approval to ensure they are just, reasonable, not unduly
discriminatory or preferential, and in the public interest. The discussion below identifies these
factors and explains how the proposed new definition of Inverter-Based Resource (“IBR”) has met
or exceeded the criteria.
1.

Proposed Reliability Standards must be designed to achieve a specified reliability goal
and must contain a technically sound means to achieve that goal. 2
The proposed definition of IBR within the NERC Glossary will establish consistency and

common understanding of what an IBR is for all standards projects and Reliability Standards going
forward. The IBR definition is intended to describe technologies that shall be considered IBR.
The addition of a single defined term to the NERC Glossary would promote consistency, avoid
confusion, and facilitate efficiency for drafting teams addressing IBR issues.

Rules Concerning Certification of the Electric Reliability Organization; and Procedures for the
Establishment, Approval, and Enforcement of Electric Reliability Standards, Order No. 672, 114 FERC ¶ 61,104,
order on reh’g, Order No. 672-A, 114 FERC ¶ 61,328 (2006) [hereinafter Order No. 672].
2
See Order No. 672, supra note 1, at P 321 (“The proposed Reliability Standard must address a reliability
concern that falls within the requirements of section 215 of the FPA. That is, it must provide for the reliable operation
of Bulk-Power System facilities. It may not extend beyond reliable operation of such facilities or apply to other
facilities. Such facilities include all those necessary for operating an interconnected electric energy transmission
network, or any portion of that network, including control systems. The proposed Reliability Standard may apply to
any design of planned additions or modifications of such facilities that is necessary to provide for reliable operation.
It may also apply to Cybersecurity protection.”).
See Order No. 672, supra note 1, at P 324 (“The proposed Reliability Standard must be designed to achieve
a specified reliability goal and must contain a technically sound means to achieve this goal. Although any person may
propose a topic for a Reliability Standard to the ERO, in the ERO’s process, the specific proposed Reliability Standard
should be developed initially by persons within the electric power industry and community with a high level of
technical expertise and be based on sound technical and engineering criteria. It should be based on actual data and
lessons learned from past operating incidents, where appropriate. The process for ERO approval of a proposed
Reliability Standard should be fair and open to all interested persons.”).
1

The proposed definition of IBR is thus designed to achieve a specific reliability goal and
contain a technically sound means to achieve that goal.
2.

Proposed Reliability Standards must be applicable only to users, owners, and
operators of the bulk power system, and must be clear and unambiguous as to what
is required and who is required to comply. 3
The proposed definition of IBR is clear and unambiguous as to what is required and who

is required to comply and support clear and consistent application in the Reliability Standards in
which it is used, in accordance with Order No. 672. The proposed definition of IBR will help
clearly articulate the actions that applicable entities must take to comply with the standards.
3.

A proposed Reliability Standard must include clear and understandable
consequences and a range of penalties (monetary and/or non-monetary) for a
violation. 4
The proposed IBR definition will help support the clear and consistent application of

Reliability Standards in which it is used. No changes are proposed to those Reliability Standards;
thus, no changes are proposed to the approved Violation Severity Levels or Violation Risk Factors
for those Reliability Standards.
4.

A proposed Reliability Standard must identify clear and objective criteria or
measures for compliance, so that it can be enforced in a consistent and nonpreferential manner. 5
The proposed definition of IBR will help support the clear and consistent application of

Reliability Standards in which it is used. No changes are proposed to those Reliability Standards;
See Order No. 672, supra note 1, at P 322 (“The proposed Reliability Standard may impose a requirement on
any user, owner, or operator of such facilities, but not on others.”).
See Order No. 672, supra note 1, at P 325 (“The proposed Reliability Standard should be clear and
unambiguous regarding what is required and who is required to comply. Users, owners, and operators of the BulkPower System must know what they are required to do to maintain reliability.”).
4
See Order No. 672, supra note 1, at P 326 (“The possible consequences, including range of possible penalties,
for violating a proposed Reliability Standard should be clear and understandable by those who must comply.”).
5
See Order No. 672, supra note 1, at P 327 (“There should be a clear criterion or measure of whether an entity
is in compliance with a proposed Reliability Standard. It should contain or be accompanied by an objective measure
of compliance so that it can be enforced and so that enforcement can be applied in a consistent and non-preferential
manner.”).
3

thus, no changes are made to the measures 6 in those Reliability Standards that support each
requirement by clearly identifying what is required and how the requirement will be enforced.
5.

Proposed Reliability Standards should achieve a reliability goal effectively and
efficiently, but do not necessarily have to reflect “best practices” without regard to
implementation cost or historical regional infrastructure design. 7
The proposed definition of IBR achieves the reliability goals of Project 2020-06

Verifications of Models and Data for Generators effectively and efficiently in accordance with
Order No. 672. The proposed definition of IBR would establish consistency and common
understanding of what an IBR is for all standards projects and Reliability Standards going forward.
6.

Proposed Reliability Standards cannot be “lowest common denominator,” i.e., cannot
reflect a compromise that does not adequately protect Bulk-Power System reliability.
Proposed Reliability Standards can consider costs to implement for smaller entities,
but not at consequences of less than excellence in operating system reliability. 8

These measures help provide clarity regarding how the requirements would be enforced and help ensure
that the requirements would be enforced in a clear, consistent, and non-preferential manner and without prejudice to
any party.
7
See Order No. 672, supra note 1, at P 328 (“The proposed Reliability Standard does not necessarily have to
reflect the optimal method, or ‘best practice,’ for achieving its reliability goal without regard to implementation cost
or historical regional infrastructure design. It should however achieve its reliability goal effectively and efficiently.”).
8
See Order No. 672, supra note 1, at P 329 (“The proposed Reliability Standard must not simply reflect a
compromise in the ERO’s Reliability Standard development process based on the least effective North American
practice—the so-called ‘lowest common denominator’—if such practice does not adequately protect Bulk-Power
System reliability. Although the Commission will give due weight to the technical expertise of the ERO, we will not
hesitate to remand a proposed Reliability Standard if we are convinced it is not adequate to protect reliability.”).
See Order No. 672, supra note 1, at P 330 (“A proposed Reliability Standard may take into account the size
of the entity that must comply with the Reliability Standard and the cost to those entities of implementing the proposed
Reliability Standard. However, the ERO should not propose a ‘lowest common denominator’ Reliability Standard that
would achieve less than excellence in operating system reliability solely to protect against reasonable expenses for
supporting this vital national infrastructure. For example, a small owner or operator of the Bulk-Power System must
bear the cost of complying with each Reliability Standard that applies to it.”).
6

The proposed definition of IBR does not reflect a “lowest common denominator” approach.
The proposed definition of IBR will be used in Order No. 901 Work Plan Milestone 2 Reliability
Standards, as well as other standards development projects addressing IBR reliability concerns.
For Reliability Standards that use the IBR term, the Applicability Section for those Reliability
Standards would specify which IBRs are applicable. Each of these Reliability Standards, including
the Applicability Sections, will be balloted in accordance with the NERC Rules of Procedure, and
the Applicability Section.
7.

Proposed Reliability Standards must be designed to apply throughout North America
to the maximum extent achievable with a single Reliability Standard while not
favoring one geographic area or regional model. It should take into account regional
variations in the organization and corporate structures of transmission owners and
operators, variations in generation fuel type and ownership patterns, and regional
variations in market design if these affect the proposed Reliability Standard. 9
The proposed definition of IBR would continue to apply consistently throughout North

America and does not favor one geographic area or regional model.

See Order No. 672, supra note 1, at P 331 (“A proposed Reliability Standard should be designed to apply
throughout the interconnected North American Bulk-Power System, to the maximum extent this is achievable with a
single Reliability Standard. The proposed Reliability Standard should not be based on a single geographic or regional
model but should take into account geographic variations in grid characteristics, terrain, weather, and other such
factors; it should also take into account regional variations in the organizational and corporate structures of
transmission owners and operators, variations in generation fuel type and ownership patterns, and regional variations
in market design if these affect the proposed Reliability Standard.”).
9

Proposed Reliability Standards should cause no undue negative effect on competition
or restriction of the grid beyond any restriction necessary for reliability. 10
The proposed definition of IBR would have no undue negative effect on competition and

would not unreasonably restrict the available transmission capacity or limit the use of the BPS in
a preferential manner. The Reliability Standards in which the proposed definition of IBR is used
are unchanged and would continue to require the same performance by each of the applicable
entities.
9.

The implementation time for the proposed Reliability Standard is reasonable. 11
The proposed effective date for the proposed definition of IBR is just and reasonable and

appropriately balances the urgency in the need to implement the standard against the
reasonableness of the time allowed for those who must comply to develop necessary procedures
or other relevant capability. The proposed implementation plan provides that the proposed
definition of IBR would become effective on the first day of the first calendar quarter following
regulatory approval. This implementation timeline appropriately balances the urgency in the need
to implement the standards against the time allowed for those who must comply to develop
necessary procedures and other relevant capabilities. The proposed implementation plan is
attached as Exhibit B to this petition.

10
See Order No. 672, supra note 1, at P 332 (“As directed by section 215 of the FPA, the Commission itself
will give special attention to the effect of a proposed Reliability Standard on competition. The ERO should attempt to
develop a proposed Reliability Standard that has no undue negative effect on competition. Among other possible
considerations, a proposed Reliability Standard should not unreasonably restrict available transmission capability on
the Bulk-Power System beyond any restriction necessary for reliability and should not limit use of the Bulk-Power
System in an unduly preferential manner. It should not create an undue advantage for one competitor over another.”).
11
See Order No. 672, supra note 1, at P 333 (“In considering whether a proposed Reliability Standard is just
and reasonable, the Commission will consider also the timetable for implementation of the new requirements,
including how the proposal balances any urgency in the need to implement it against the reasonableness of the time
allowed for those who must comply to develop the necessary procedures, software, facilities, staffing or other relevant
capability.”).

10.

The Reliability Standard was developed in an open and fair manner and in
accordance with the Commission-approved Reliability Standard development
process. 12
The proposed definition of IBR was developed in accordance with NERC’s Commission-

approved processes for developing and approving Reliability Standards. Exhibit E includes a
summary of the development proceedings for the proposed definition of IBR, and details the
processes followed to develop the proposed definition of IBR. These processes included, among
other things, comment periods, pre-ballot review periods, and balloting periods. Additionally, all
meetings of the standard drafting team were properly noticed and open to the public.
11.

NERC must explain any balancing of vital public interests in the development of
proposed Reliability Standards. 13
NERC has identified no competing public interests regarding the request for approval of

the proposed definition of IBR. No comments were received that indicated that the proposed
definition of IBR conflicts with other vital public interests.
12.

Proposed Reliability Standards must consider any other appropriate factors. 14
No other negative factors relevant to whether the proposed definition of IBR is just and

reasonable were identified.

See Order No. 672, supra note 1, at P 334 (“Further, in considering whether a proposed Reliability Standard
meets the legal standard of review, we will entertain comments about whether the ERO implemented its Commissionapproved Reliability Standard development process for the development of the particular proposed Reliability
Standard in a proper manner, especially whether the process was open and fair. However, we caution that we will not
be sympathetic to arguments by interested parties that choose, for whatever reason, not to participate in the ERO’s
Reliability Standard development process if it is conducted in good faith in accordance with the procedures approved
by the Commission.”).
13
See Order No. 672, supra note 1, at P 335 (“Finally, we understand that at times development of a proposed
Reliability Standard may require that a particular reliability goal must be balanced against other vital public interests,
such as environmental, social and other goals. We expect the ERO to explain any such balancing in its application for
approval of a proposed Reliability Standard.”).
14
See Order No. 672, supra note 1, at P 323 (“In considering whether a proposed Reliability Standard is just
and reasonable, we will consider the following general factors, as well as other factors that are appropriate for the
particular Reliability Standard proposed.”).
12

Exhibit E
Summary of Development and Complete Record of Development

RELIABILITY | RESILIENCE | SECURITY

Summary of Development History
The following is a summary of the development record for the proposed definition of the
term Inverter-Based Resource (“IBR”), developed under Project 2020-06 Verifications of Models
and Data for Generators. Initially, Project 2020-06 proposed two defined terms: “Inverter-Based
Resource (IBR)” and “IBR Unit”. However, following two failed ballots of the term “IBR Unit”,
the drafting team revised the definition of “Inverter-Based Resource (IBR)” to discontinue use of
the embedded term “IBR Unit” and determined to move forward only with a proposed definition
of Inverter-Based Resource (IBR).
I.

Overview of the Drafting Team
When evaluating a proposed Reliability Standard (to include definitions used in Reliability

Standards), the Commission is expected to give “due weight” to the technical expertise of the
ERO. 1 The technical expertise of the ERO is derived from the drafting team selected to lead each
project in accordance with Section 4.3 of the NERC Standard Processes Manual. 2 For this project,
the drafting team consisted of industry experts, all with a diverse set of experiences. A roster of
the Project 2020-06 drafting team members is included in Exhibit E.
II.

Definition Development History
A. Project Initiation
In 2021, NERC initiated Project 2020-06 to address a Standard Authorization Request

(“SAR”) submitted by the NERC Inverter-Based Resource Performance Task Force (“IRPTF”).
In 2020, the IRPTF published a white paper summarizing the results of its review of NERC

Section 215(d)(2) of the Federal Power Act; 16 U.S.C. § 824(d)(2) (2018).

The NERC Standard Processes Manual is available at
https://www.nerc.com/AboutNERC/RulesOfProcedure/Appendix_3A_SPM_Clean_Mar2019.pdf.

Reliability Standards. 3 Among other things, the IRPTF recommended revisions to MOD-026-1
and MOD-027-1 to address issues related to model verification of IBRs.
B. Standard Authorization Request Development
On September 24, 2020, the Standards Committee accepted the Standards Authorization
Request proposing to clarify requirements related to IBRs and to require model verification
through a revision to NERC Reliability Standards MOD-026-1 and MOD-027-1, and authorized
posting the SAR for a 30-day informal comment period from December 16, 2020 through January
14, 2021, and the solicitation of SAR drafting team members. 4 On July 21, 2021, the Standards
Committee accepted the Project 2020-06 SARs – Verifications of Models and Data for Generators,
and Transmission-Connected Dynamic Reactive Resources. The Standards Committee authorized
drafting revisions to the Reliability Standards identified in the SARs and appointed the Project
2020-06 SAR Drafting Team as the Project 2020-06 Standard Drafting Team. 5
C.

Informal Comment Period

From September 18, 2023 through October 24, 2023, an early draft of the terms “InverterBased Resource (IBR)” and “Power Electronic Device (PED)” were posted for an informal

NERC IRPTF, IRPTF Review of NERC Reliability Standards White Paper (March 2020),
https://www.nerc.com/comm/PC/InverterBased%20Resource%20Performance%20Task%20Force%20IRPT/Review
_of_NERC_Reliability_Standards_White_Paper.pdf.
4
See NERC, Standards Committee September 24, 2020 Meeting Minutes at 3,
https://www.nerc.com/comm/SC/Agenda%20Highlights%20and%20Minutes/SC%20September%20Meeting%20Mi
nutes%20Approved%20November%2019,%202020.pdf.
5
See NERC, Standards Committee July 21, 2021 Meeting Minutes at 3,
https://www.nerc.com/comm/SC/Agenda%20Highlights%20and%20Minutes/SC_July_Meeting_Minutes_Approved
_September_23_%202021.pdf.
3

comment period. 6 The comments were reviewed and the definitions revised; the use of the term
“Power Electronic Device” was discontinued.
D. Issuance of Federal Energy Regulatory Commission Order No. 901
On October 19, 2023, the Commission issued Order No. 901 7 directing NERC to develop
new or modified Reliability Standards addressing reliability concerns related to IBRs. With the
issuance of Order 901, NERC determined that a single drafting team should move forward with a
definition of IBR. The Project 2020-06 drafting team was selected to lead this effort.
E. First Formal Posting – Comment Period and Initial Ballot
On November 15, 2023, the Standards Committee authorized the initial posting of the
proposed definitions for Inverter-Based Resource and IBR Unit and the associated Implementation
Plan for a 45-day formal comment period. 8 The initial posting took place from November 16, 2023
through January 9, 2024, with parallel initial ballots conducted during the last 12 days of the
comment period from December 29, 2023 through January 9, 2024. 9 The results for the initial
ballot are summarized below:
•

Proposed definition of Inverter-Based Resource (IBR) received 43.82 percent
approval, reaching quorum at 89.36 percent of the ballot pool. 10

•

Proposed definition of IBR Unit received 45.04 percent approval, reaching quorum
at 89.68 percent of the ballot pool. 11

6
7

See Exhibit D, Complete Record of Development at items 12,14.
Reliability Standards to Address Inverter-Based Resources, Order No. 901, 185 FERC ¶ 61,042 (2023).

See NERC, Standards Committee November 15, 2023 Meeting Minutes at 2,
https://www.nerc.com/comm/SC/Agenda%20Highlights%20and%20Minutes/SC%20November%20Minutes%20%20Approved%20December%2013,%202023.pdf.
9
See Exhibit D, Complete Record of Development at item 20.
10
Id. at item 25.
11
Id. at item 26.
8

•

Proposed IBR-related Definitions Implementation Plan received 58.52 percent
approval, reaching quorum at 88.93 percent of the ballot pool. 12

There were 73 sets of responses, including comments from approximately 179 different
individuals and approximately 113 companies, representing all 10 industry segments. 13
F. Second Formal Posting - Comment Period and Additional Ballot
The second draft of the proposed definitions of Inverter-Based Resource and IBR Unit and
the associated Implementation Plan were posted for a 47-day formal comment period from
February 22, 2024 through April 8, 2024, with a parallel additional ballot held from March 29,
2024 through April 8, 2024. 14 The results for the ballots are summarized below:
•

Proposed definition of Inverter-Based Resource (IBR) received 67.55 percent
approval, reaching quorum at 83.33 percent of the ballot pool. 15

•

Proposed definition of IBR Unit received 61.07 percent approval, reaching quorum
at 83.27 percent of the ballot pool. 16

•

Proposed IBR-related Definitions Implementation Plan received 70.04 percent
approval, reaching quorum at 83.21 percent of the ballot pool. 17

There were 49 sets of responses, including comments from approximately 144 different
individuals and approximately 102 companies, representing all 10 industry segments. 18 Following
this posting, the drafting team determined to discontinue the proposed definition of IBR Unit.

12
13
14
15
16
17
18

Id. at item 27.
Id. at items 21, 22.
Id. at item 33.
Id. at item 38.
Id. at item 39.
Id. at item 40.
Id. at items 34, 35.

G. Third Posting – Comment Period and Additional Ballot
The proposed definition of Inverter-Based Resource (IBR) and the associated
Implementation Plan were posted for a 32-day formal comment period from July 12, 2024 through
August 12, 2024, with a parallel additional ballot held from August 2, 2024 through August 12,
2024. 19 The results for the ballots are summarized below:
•

Proposed definition of Inverter-Based Resource received 91.57 percent approval,
reaching quorum at 85.46 percent of the ballot pool. 20

•

Proposed IBR-related Definitions Implementation Plan received 92.45 percent
approval, reaching quorum at 85 percent of the ballot pool. 21

There were 52 sets of responses, including comments from approximately 147 different
individuals and approximately 100 companies, representing all 10 industry segments. 22
H. Final Ballot
The proposed definition of Inverter-Based Resource (IBR) and the associated
Implementation Plan were posted for a 10-day final ballot period from September 3, 2024 through
September 12, 2024. 23 The final ballot for the proposed definition of Inverter-Based Resource
(IBR) reached quorum at 90.07 percent of the ballot pool, receiving support from 92.82 percent of
the voters. 24 The final ballot for the Implementation Plan reached quorum at 89.64 percent of the
ballot pool, receiving support from 96.66 percent of the voters. 25

19
20
21
22
23
24
25

Id. at item 53.
Id. at item 59.
Id. at item 60.
Id. at items 55, 56.
Id. at item 68.
Id. at item 69.
Id. at item 70.

I. Board of Trustees Adoption
The NERC Board of Trustees adopted the proposed definition of Inverter-Based Resource
(IBR) on October 8, 2024. 26

See NERC Board of Trustees October 8, 2024 Agenda Package, Agenda Item 2a (Project 2020-06
Verifications of Models and Data for Generators),
https://www.nerc.com/gov/bot/Agenda%20highlights%20and%20Mintues%202013/Board%20of%20Trustees%20
Open%20Meeting%20Agenda%20Package%20October%208%202024%20Attendees.pdf.

Complete Record of Development
(Items 43-46, pertaining to a Standard Authorization Request for this project to address later
FERC Order No. 901 milestones, are omitted from this filing.)

Home > Program Areas & Departments > Standards > Project 2020-06 Verifications of Models and Data for Generators

Project 2020-06 Verifications of Models and Data for Generators
Related Files
Status
The final ballot for the Inverter-Based Resource Glossary Term concluded 8 p.m. Eastern, Thursday, September 12, 2024. The voting results can be accessed via the links below. The definition and its implementation plan will be submitted to the Board of
Trustees for adoption and then filed with the appropriate regulatory authorities.
Background
The NERC Inverter-based Resource (IBR) Performance Task Force (IRPTF) undertook an effort to perform a comprehensive review of all NERC Reliability Standards to determine if there were any potential gaps or improvements. The IRPTF identified several issues as
part of this effort and documented its findings and recommendations in the “IRPTF Review of NERC Reliability Standards White Paper," which was approved in March 2020 by the Operating Committee and the Planning Committee (now part of the Reliability and
Security Technical Committee (RSTC)). Among the findings noted in the white paper, the IRPTF identified issues with MOD-026-1 and MOD-027-1 that should be addressed. The RSTC endorsed the SAR on June 10, 2020.
Consistent with the IRPTF recommendations, the scope of the proposed SAR includes revisions to NERC Reliability Standards MOD-026-1 and MOD-027-1. Standards MOD-026-1 and MOD-027- 1 require, among other things, Generator Owners to provide verified
dynamic models to their Transmission Planner for the purposes of power system planning studies. Both standards contain language that is specific to synchronous generators that is not applicable to IBRs. The IRPTF recommended revisions to clarify the applicable
requirements for synchronous generators and IBRs. As such, the SAR proposes revisions to MOD-026-1 and MOD-027-1 to clarify requirements related to IBRs and to require sufficient model verification to ensure accurate generator representation in dynamic
simulations. The Standards Committee accepted the SAR and authorized posting at its September 24, 2020 meeting.
Standard(s) Affected – MOD-026-1 Verification of Models and Data for Generator Excitation Control System or Plant Volt/Var Control Functions | MOD-027-1 Verification of Models and Data for Turbine/Governor and Load Control or Active Power/Frequency Control
Functions
Purpose/Industry Need
Project 2020-02 Transmission-connected Dynamic Reactive Resources SAR was posted from March 30 to May 13, 2020, and members of a SAR DT were solicited. However, Project 2020-02 was paused indefinitely, and a SAR DT was not appointed. Subsequently, a
second SAR involving similar standards, namely MOD-026 and MOD-027, was being drafted by the IRPTF and approved for posting in September 2020 by the Standards Committee. The Project 2020-06 Verifications of Models and Data for Generators SAR will be
posted for industry comment, and additional nominees with MOD-026/027 background will be sought. A single SAR DT will be charged with determining whether to combine the two projects and drafting a combined SAR.
See Project 2020-02 Transmission-connected Dynamic Reactive Resources for additional purpose statement.
Subscribe to this project's observer mailing list
Select "NERC Email Distribution Lists" from the "Service" drop-down menu and specify “Project 2020-06 Verifications of Models and Data for Generators” in the Description Box.

Draft

Actions

Dates

Results

Consideration of
Comments

Final Ballot
Inverter-Based Resource Glossary Term
(63) Clean
Implementation Plan
(64) Clean | (65) Redline

Final Ballot

Ballot Results

(68) Info

(69) IBR Definition

Vote

09/03/24 - 09/12/24

For informational purposes. These
documents will be presented to the
Board of Trustees

08/15/24

Supporting Materials
Technical Rationale
(66) Clean | (67) Redline

(61) Inverter-based (IBR) Definition
(62)Implementation Plan

Additional Ballots
Ballot Results

(58) Info

08/02/24 - 08/12/24 (updated)

(59) IBR Definition

Vote
Comment Period

(54) Info

07/12/24 - 08/12/24 (updated)

Submit Comments

Comment Period
(45) Info

05/23/24 - 06/26/24

Submit Comments
Drafting Team Nominations
Supporting Materials
(41) Unofficial Nomination Form (Word)
Draft 2
Inverter-based Resource Glossary Terms
(28) Clean | (29) Redline to Last Posted

Nomination Period
(42) Info

05/23/24 - 06/26/24

Submit Nominations
Additional Ballots

Ballot Results

03/29/24 - 04/08/24

(37) Info

(39) IBR Unit
(40) IBR-related Definitions
Implementation Plan

Vote

(30) Implementation Plan
Supporting Materials
(31) Unofficial Comment Form (Word)
(32) Technical Rationale

(38) Inverter-based Resource (IBR)

Comment Period
(33) Info

02/22/24 - 04/08/24

Submit Comments

Ballot Results
Draft 1
(17) Inverter-based Resource Glossary Terms
(18) Implementation Plan

(25) Inverter-Based Resource (IBR)

Initial Ballots

(24) Info (Updated 11/20/23)

12/29/23 - 01/09/24

Vote

Additional Materials

Join Ballot Pools

(19) Unofficial Comment Form
(Word)

Comment Period
(20) Info(Updated 11/20/23)

Submit Comments

IBR-related Definitions
(27) Implementation Plan

11/16/23 - 12/15/23

11/16/23 - 01/09/24

(12) Inverter-based Resource Glossary Terms
Additional Materials
(13) Unofficial Comment Form (Word)

Comment Period

Submit Comments

09/18/23 - 10/24/23

(16) Summary Response to
Comments

Accepted by the Standards Committee

Drafting Team Nominations
Supporting Materials
(6) Unofficial Nomination Form

07/21/21

Nomination Period
(7) Info

12/16/20 - 01/14/21

Submit Nominations

(Word)

Comment Period
(3) Info

Submit Comments

12/16/20 - 01/14/21

(4) Comments Received

(5) Summary Response to

Comments

Standard Authorization Request (SAR)
Complete and submit this form, with attachment(s)
to the NERC Help Desk. Upon entering the Captcha,
please type in your contact information, and attach
the SAR to your ticket. Once submitted, you will
receive a confirmation number which you can use
to track your request.

SAR Title:

Date Submitted:
SAR Requester

The North American Electric Reliability Corporation
(NERC) welcomes suggestions to improve the
reliability of the bulk power system through
improved Reliability Standards.

Requested information
MOD-026-1 Verification of Models and Data for Generator Excitation
Control System or Plant Volt/Var Control Functions, MOD-027-1
Verification of Models and Data for Turbine/Governor and Load Control
or Active Power/Frequency Control Functions
June 10, 2020

Allen Shriver, Chair
Jeffery Billo, Vice Chair
Organization: Inverter-Based Resource Performance Task Force (IRPTF)
Allen: 561-904-3234
[email protected]
Telephone:
Email:
Jeffery: 512-248-6334
[email protected]
SAR Type (Check as many as apply)
New Standard
Imminent Action/ Confidential Issue (SPM
Revision to Existing Standard
Section 10)
Add, Modify or Retire a Glossary Term
Variance development or revision
Withdraw/retire an Existing Standard
Other (Please specify)
Justification for this proposed standard development project (Check all that apply to help NERC
prioritize development)
Regulatory Initiation
NERC Standing Committee Identified
Emerging Risk (Reliability Issues Steering
Enhanced Periodic Review Initiated
Committee) Identified
Industry Stakeholder Identified
Reliability Standard Development Plan
Industry Need (What Bulk Electric System (BES) reliability benefit does the proposed project provide?):
The NERC Inverter-based Resource Performance Task Force (IRPTF) undertook an effort to perform a
comprehensive review of all NERC Reliability Standards to determine if there were any potential gaps or
improvements based on the work and findings of the IRPTF. The IRPTF identified several issues as part
of this effort and documented its findings and recommendations in a white paper. The “IRPTF Review
of NERC Reliability Standards White Paper” was approved by the Operating Committee and the Planning
Committee in March 2020. Among the findings noted in the white paper, the IRPTF identified issues
with MOD-026-1 and MOD-027-1 that should be addressed.
Name:

RELIABILITY | RESILIENCE | SECURITY

Requested information
MOD-026-1 and MOD-027-1 require, among other things, GOs to provide verified dynamic models to their
Transmission Planner (TP) for the purposes of power system planning studies. Both standards contain
language that is specific to synchronous generators and is not applicable to inverter-based resources
(IBRs). For example, sub-requirement 2.1.3 in MOD-026-1 states that each verification shall include
“model structure and data including, but not limited to reactance, time constants, saturation factors, total
rotational inertia…” The standards should be revised to clarify the applicable requirements for
synchronous generators and IBRs. For example, total rotational inertia should not be required for IBRs,
while voltage ride-through control settings should only be required of IBRs and not synchronous
generators.
Additionally, to some degree, all dynamic model parameters affect the response of a represented
resource in dynamic simulations performed by power engineers. Accurate model response is required
for the engineers to adequately study system conditions. Hence, it is crucial that all parameters in a model
be verified in some way. However, a significant number of parameters in the models are not verified in
the typical verification tests used to comply with MOD-026-1 and MOD-027-1. For example, the test
currently used to comply with MOD-026-1 does not verify the model parameters associated with voltage
control behavior during large disturbance conditions.
Purpose or Goal (How does this proposed project provide the reliability-related benefit described
above?):
This SAR proposes to revise MOD-026-1 and MOD-027-1 and/or create a new standard to clarify
requirements related to IBRs and to require sufficient model verification to ensure accurate generator
representation in dynamic simulations.
Project Scope (Define the parameters of the proposed project):
The proposed scope of this project is as follows:
a. Update requirement language to better reflect all types of generation resources and not just
synchronous resources.
b. Consider ways to require sufficient model verification to ensure accurate generator
representation in dynamic simulations of typical phenomena that would be studied by power
system engineers, including large disturbances.
Detailed Description (Describe the proposed deliverable(s) with sufficient detail for a drafting team to
execute the project. If you propose a new or substantially revised Reliability Standard or definition,
provide: (1) a technical justification 1 which includes a discussion of the reliability-related benefits of
developing a new or revised Reliability Standard or definition, and (2) a technical foundation document
(e.g., research paper) to guide development of the Standard or definition):
NERC MOD-026-1 focuses on verification of data for generator excitation control system or plant volt/var
control functions and MOD-027-1 focuses on verification of data for turbine-governor and load control or
active power-frequency control functions. Specifically, MOD-026-1 states in footnote 1 that the excitation
control system for aggregate generating plants (i.e., wind and solar PV) includes the volt/var control
system including the voltage regulator and reactive power control system controlling and coordinating
The NERC Rules of Procedure require a technical justification for new or substantially revised Reliability Standards. Please attach pertinent
information to this form before submittal to NERC.

Standard Authorization Request (SA R)

Requested information
plant voltage and associated reactive capable resources. This language is slightly ambiguous on whether
the verification activities include the inverter-level parameter values of the dynamic models. Various
testing engineers and entities have stated that they are uncertain as to whether the standard applies to
the plant-level parameters or the aggregate representation of the inverter-level settings.
Most commonly, verification test reports for inverter-based resources involve a small set of small
disturbance tests including, but not limited to, the following:
•

Capacitor switching test

•

Plant-level voltage or reactive power reference step test

•

Plant-level frequency reference step test

•

Plant-level frequency play-in or step test

These tests do not perturb the generating resource such that the parameter values that dictate the large
disturbance behavior of the resource are verified in any way. While some incorrect model parameters
may be identified during these tests, the tests do not verify that the parameters selected for the model
accurately capture the full dynamic behavior of the resource. This gives a false impression to TPs and PCs
that the full set of parameters are verified for use in planning studies.
This issue is one of the predominant reasons why ride-through operation modes such as momentary
cessation were able to persist and promulgate in IBRs without the knowledge of planners and system
operators until the Blue Cut Fire and Canyon 2 Fire events exposed them. The dynamic models did not
accurately represent this large disturbance behavior due to the model deficiency and because certain key
parameters that govern large disturbance response were incorrectly parameterized. However, many of
the same plants that entered momentary cessation mode during these events were able to provide
verification reports that demonstrated that the small disturbance behavior driven mainly by plant-level
control settings reasonably matched modeled performance in compliance with these standards.
Cost Impact Assessment, if known (Provide a paragraph describing the potential cost impacts associated
with the proposed project):
The SAR proposes to clarify and address gaps in the requirements in MOD-026-1 and MOD-027-1. The
cost impact is unknown.
Please describe any unique characteristics of the BES facilities that may be impacted by this proposed
standard development project (e.g., Dispersed Generation Resources):
The abovementioned reliability gap exists for both synchronous generators and IBRs. However, it is
potentially more severe for IBRs since their behavior is based more on programmable control functions
than for synchronous generators which have behavior that is based more on the physical characteristics
of the machine. Additionally, the IRPTF noted that it is not feasible to stage large disturbances for
verification purposes, so other methods for verification of model performance under large disturbance
conditions may need to be developed.
To assist the NERC Standards Committee in appointing a drafting team with the appropriate members,
please indicate to which Functional Entities the proposed standard(s) should apply (e.g., Transmission

Standard Authorization Request (SA R)

Requested information
Operator, Reliability Coordinator, etc. See the most recent version of the NERC Functional Model for
definitions):
Transmission Planner, Generator Owner, Planning Coordinator
Do you know of any consensus building activities 2 in connection with this SAR? If so, please provide any
recommendations or findings resulting from the consensus building activity.
This issue was captured in the “IRPTF Review of NERC Reliability Standards White Paper” which was
approved by the Operating Committee and the Planning Committee. Additionally, the issue was
discussed in the IRPTF-produced “Improvements to Interconnection Requirements for BPS-Connected
Inverter-Based Resources” reliability guideline.
Are there any related standards or SARs that should be assessed for impact as a result of this proposed
project? If so, which standard(s) or project number(s)?
N/A
Are there alternatives (e.g., guidelines, white paper, alerts, etc.) that have been considered or could
meet the objectives? If so, please list the alternatives.
The IRPTF did not identify any alternatives since there are gaps in the existing language for MOD-026-1
and MOD-027-1 that need to be resolved.
Reliability Principles
Does this proposed standard development project support at least one of the following Reliability
Principles (Reliability Interface Principles)? Please check all those that apply.
1. Interconnected bulk power systems shall be planned and operated in a coordinated manner
to perform reliably under normal and abnormal conditions as defined in the NERC Standards.
2. The frequency and voltage of interconnected bulk power systems shall be controlled within
defined limits through the balancing of real and reactive power supply and demand.
3. Information necessary for the planning and operation of interconnected bulk power systems
shall be made available to those entities responsible for planning and operating the systems
reliably.
4. Plans for emergency operation and system restoration of interconnected bulk power systems
shall be developed, coordinated, maintained and implemented.
5. Facilities for communication, monitoring and control shall be provided, used and maintained
for the reliability of interconnected bulk power systems.
6. Personnel responsible for planning and operating interconnected bulk power systems shall be
trained, qualified, and have the responsibility and authority to implement actions.
7. The security of the interconnected bulk power systems shall be assessed, monitored and
maintained on a wide area basis.
8. Bulk power systems shall be protected from malicious physical or cyber attacks.

Consensus building activities are occasionally conducted by NERC and/or project review teams. They typically are conducted to obtain
industry inputs prior to proposing any standard development project to revise, or develop a standard or definition.

Standard Authorization Request (SA R)

Market Interface Principles
Does the proposed standard development project comply with all of the following
Market Interface Principles?
1. A reliability standard shall not give any market participant an unfair competitive
advantage.
2. A reliability standard shall neither mandate nor prohibit any specific market
structure.
3. A reliability standard shall not preclude market solutions to achieving compliance
with that standard.
4. A reliability standard shall not require the public disclosure of commercially
sensitive information. All market participants shall have equal opportunity to
access commercially non-sensitive information that is required for compliance
with reliability standards.

Enter
(yes/no)
Yes
Yes
Yes
Yes

Identified Existing or Potential Regional or Interconnection Variances
Region(s)/
Explanation
Interconnection
None
N/A

For Use by NERC Only
SAR Status Tracking (Check off as appropriate).
Draft SAR reviewed by NERC Staff
Draft SAR presented to SC for acceptance
DRAFT SAR approved for posting by the SC

Final SAR endorsed by the SC
SAR assigned a Standards Project by NERC
SAR denied or proposed as Guidance
document

Version History
Version

Date

Owner

Change Tracking

June 3, 2013

August 29, 2014

Standards Information Staff

Updated template

January 18, 2017

Standards Information Staff

Revised

June 28, 2017

Standards Information Staff

Updated template

February 22, 2019

Standards Information Staff

Added instructions to submit via Help
Desk

February 25, 2020

Standards Information Staff

Updated template footer

Standard Authorization Request (SA R)

Revised

Unofficial Comment Form

Project 2020-06 Verification of Models and Data for Generators
Standard Authorization Request
Do not use this form for submitting comments. Use the Standards Balloting and Commenting System to
submit comments on the Project 2020-06 Verification of Models and Data for Generators Standard
Authorization Request by 8 p.m. Eastern, Thursday, January 14, 2021.
m. Eastern, Thursday, August 20, 2015
Additional information is available on the project page. If you have questions, contact Senior Standards
Developer, Chris Larson (via email), or at 404-446-9708.
Background

The NERC Inverter-based Resource (IBR) Performance Task Force (IRPTF) undertook an effort to perform a
comprehensive review of all NERC Reliability Standards to determine if there were any potential gaps or
improvements. The IRPTF identified several issues as part of this effort and documented its findings and
recommendations in the “IRPTF Review of NERC Reliability Standards White Paper,” which was approved
in March 2020 by the Operating Committee and the Planning Committee (now part of the Reliability and
Security Technical Committee (RSTC)). Among the findings noted in the white paper, the IRPTF identified
issues with MOD-026-1 and MOD-027-1 that should be addressed. The RSTC endorsed the SAR on June
10, 2020.
Consistent with the IRPTF recommendations, the scope of the proposed SAR includes revisions to NERC
Reliability Standards MOD-026-1 and MOD-027-1. Standards MOD-026-1 and MOD-027- 1 require, among
other things, Generator Owners to provide verified dynamic models to their Transmission Planner for the
purposes of power system planning studies. Both standards contain language that is specific to
synchronous generators that is not applicable to IBRs. The IRPTF recommended revisions to clarify the
applicable requirements for synchronous generators and IBRs. As such, the SAR proposes revisions to
MOD-026-1 and MOD-027-1 to clarify requirements related to IBRs and to require sufficient model
verification to ensure accurate generator representation in dynamic simulations. The Standards
Committee accepted the IRPTF SAR and authorized posting at its September 24, 2020 meeting.
Project 2020-02 Transmission-connected Dynamic Reactive Resources SAR was posted from March 30 to
May 13, 2020, and members of a SAR DT were solicited. However, Project 2020-02 was paused
indefinitely, and a SAR DT was not appointed. Subsequently, a second SAR involving similar standards,
namely MOD-026 and MOD-027, was being drafted by the IRPTF and approved for posting in September
2020 by the Standards Committee. The Project 2020-06 Verifications of Models and Data for Generators
SAR will be posted for industry comment, and additional nominees with MOD-026/027 background will be
sought. A single SAR DT will be charged with determining whether to combine the two projects and
drafting a combined SAR.

RELIABILITY | RESILIENCE | SECURITY

Questions

1. Do you agree with the proposed scope as described in the SAR? If you do not agree, or if you agree
but have comments or suggestions for the project scope please provide your recommendation and
explanation.
Yes
No
Comments:
2. In your opinion, should the project scopes of Project 2020-02 Transmission-connected Dynamic
Reactive Resources (MOD-026/027 portions only) and Project 2020-06 be combined under a single
project, with a single standard drafting team? Please explain.
Yes
No
Comments:
3. Provide any additional comments for the SAR drafting team to consider, if desired.
Comments:

Unofficial Comment Form | Project 2020-06 Verification of Models and Data for Generators
Standard Authorization Request | December 2020

Standards Announcement

Project 2020-06 Verifications of Models and Data for Generators
Standard Authorization Request
Informal Comment Period Open through January 14, 2021

Now Available

An informal comment period for the Project 2020-06 Verifications of Models and Data for Generators
Standard Authorization Request (SAR), is open through 8 p.m. Eastern, Thursday, January 14, 2021.
Commenting

Use the Standards Balloting and Commenting System (SBS) to submit comments. Contact Linda Jenkins
regarding issues using the SBS. An unofficial Word version of the comment form is posted on the project
page.
•

Contact NERC IT support directly at https://support.nerc.net/ (Monday – Friday, 8 a.m. - 5 p.m.
Eastern) for problems regarding accessing the SBS due to a forgotten password, incorrect
credential error messages, or system lock-out.

•

Passwords expire every 6 months and must be reset.

•

The SBS is not supported for use on mobile devices.

•

Please be mindful of ballot and comment period closing dates. We ask to allow at least 48
hours for NERC support staff to assist with inquiries. Therefore, it is recommended that users try
logging into their SBS accounts prior to the last day of a comment/ballot period.

Background

Project 2020-02 Transmission-connected Dynamic Reactive Resources SAR was posted from March 30 to
May 13, 2020, and members of a SAR DT were solicited. However, Project 2020-02 was paused
indefinitely, and a SAR DT was not appointed. Subsequently, a second SAR involving similar standards,
namely MOD-026 and MOD-027, was being drafted by the IRPTF and approved for posting in September
2020 by the Standards Committee. The Project 2020-06 Verifications of Models and Data for Generators
SAR will be posted for industry comment, and additional nominees with MOD-026/027 background will
be sought. A single SAR DT will be charged with determining whether to combine the two projects and
drafting a combined SAR.
Next Steps
The SAR drafting team will review all responses received during the comment period and determine the next
steps of the project.

RELIABILITY | RESILIENCE | SECURITY

For more information on the Standards Development Process, refer to the Standard Processes
Manual.
Subscribe to this project's observer mailing list by selecting "NERC Email Distribution Lists" from the
"Service" drop-down menu and specify “Project 2020-06 Verifications of Models and Data for Generators” in
the Description Box. For more information or assistance, contact Senior Standards Developer, Chris Larson
(via email) or at 404-446-9708
North American Electric Reliability Corporation
3353 Peachtree Rd, NE
Suite 600, North Tower
Atlanta, GA 30326
404-446-2560 | www.nerc.com

Standards Announcement | Project 2020-06 Verifications of Models and Data for Generators
December 16, 2020

Comment Report
Project Name:

2020-06 Verification of Models and Data for Generators | Standard Authorization Request

Comment Period Start Date:

12/16/2020

Comment Period End Date:

1/14/2021

Associated Ballots:

There were 35 sets of responses, including comments from approximately 112 different people from approximately 87 companies
representing 10 of the Industry Segments as shown in the table on the following pages.

Questions
1. Do you agree with the proposed scope as described in the SAR? If you do not agree, or if you agree but have comments or suggestions for
the project scope please provide your recommendation and explanation.
2. In your opinion, should the project scopes of Project 2020-02 Transmission-connected Dynamic Reactive Resources (MOD-026/027
portions only) and Project 2020-06 be combined under a single project, with a single standard drafting team? Please explain.
3. Provide any additional comments for the SAR drafting team to consider, if desired.

Organization
Name
MRO

Name

Dana Klem

Segment(s)

1,2,3,4,5,6

Region

MRO

Group
Name

Group Member
Name

MRO NSRF Joseph
DePoorter

Group
Group
Member
Member
Organization Segment(s)

Group
Member
Region

Madison Gas & 3,4,5,6
Electric

MRO

Larry Heckert

Alliant Energy 4

MRO

Michael
Brytowski

Great River
Energy

MRO

Jodi Jensen

Western Area 1,6
Power
Administration

MRO

Andy Crooks

SaskPower
Corporation

MRO

Bryan Sherrow Kansas City
1
Board of Public
Utilities

MRO

Bobbi Welch

Omaha Public 1,3,5,6
Power District

MRO

Jeremy Voll

Basin Electric 1
Power
Cooperative

MRO

Bobbi Welch

Midcontinent
ISO

MRO

1,3,5,6

Douglas Webb Kansas City
1,3,5,6
Power & Light

MRO

Fred Meyer

Algonquin
Power Co.

MRO

John Chang

Manitoba
Hydro

1,3,6

MRO

James Williams Southwest
Power Pool,
Inc.

MRO

Jamie Monette Minnesota
Power /
ALLETE

MRO

Jamison
Cawley

Nebraska
Public Power

1,3,5

MRO

Sing Tay

Oklahoma Gas 1,3,5,6
& Electric

MRO

Terry Harbour

MidAmerican
Energy

MRO

1,3

PJM
Elizabeth
Interconnection, Davis
L.L.C.

ISO/RTO
Council
(IRC)
Standards
Review
Committee
(SRC)

Troy Brumfield American
1
Transmission
Company

MRO

Mike Del Viscio PJM
2
Interconnection

Becky Davis

PJM
2
Interconnection

Gregory
Campoli

New York
Independent
System
Operator

NPCC

Charles Yeung Southwest
Power Pool,
Inc. (RTO)

MRO

Kathleen
Goodman

ISO-NE

NPCC

Helen Lainis

IESO

NPCC

Bobbi Welch

Midcontinent
ISO, Inc.

Jamie Johnson California ISO 2
Duke Energy

FirstEnergy FirstEnergy
Corporation

Southern
Company Southern
Company
Services, Inc.

Kim Thomas 1,3,5,6

FRCC,RF,SERC,Texas Duke Energy Laura Lee
Duke Energy
RE
Dale Goodwine Duke Energy

Mark Garza 1,3,4,5,6

Pamela
Hunter

1,3,5,6

FE Voter

SERC

Southern
Company

WECC

SERC

Greg Cecil

Duke Energy

Julie Severino

FirstEnergy FirstEnergy
Corporation

Aaron
Ghodooshim

FirstEnergy FirstEnergy
Corporation

Robert Loy

FirstEnergy FirstEnergy
Solutions

Ann Carey

FirstEnergy FirstEnergy
Solutions

Mark Garza

FirstEnergyFirstEnergy

Matt Carden

Southern
Company Southern
Company
Services, Inc.

SERC

Joel
Dembowski

Southern
Company -

SERC

Alabama
Power
Company

Northeast
Power
Coordinating
Council

Ruida Shu

1,2,3,4,5,6,7,8,9,10 NPCC

NPCC
Regional
Standards
Committee

Ron Carlsen

Southern
Company Southern
Company
Generation

SERC

Jim Howell

Southern
5
Company Southern
Company
Services, Inc. Gen

SERC

Guy V. Zito

Northeast
Power
Coordinating
Council

NPCC

Randy
MacDonald

New Brunswick 2
Power

NPCC

Glen Smith

Entergy
Services

NPCC

Alan Adamson New York
State
Reliability
Council

NPCC

David Burke

Orange &
Rockland
Utilities

NPCC

Michele
Tondalo

NPCC

Helen Lainis

IESO

NPCC

David Kiguel

Independent

NPCC

Paul
Malozewski

Hydro One
3
Networks, Inc.

NPCC

Nick Kowalczyk Orange and
Rockland

NPCC

Joel Charlebois AESI - Acumen 5
Engineered
Solutions
International
Inc.

NPCC

Mike Cooke

NPCC

Ontario Power 4
Generation,
Inc.

Salvatore
Spagnolo

New York
Power
Authority

NPCC

Shivaz Chopra New York
Power
Authority

NPCC

Deidre Altobell Con Ed Consolidated
Edison

NPCC

Dermot Smyth Con Ed Consolidated
Edison Co. of
New York

NPCC

Peter Yost

Con Ed Consolidated
Edison Co. of
New York

NPCC

Cristhian Godoy Con Ed Consolidated
Edison Co. of
New York

NPCC

Sean Bodkin

Dominion Dominion
Resources,
Inc.

NPCC

Nurul Abser

NB Power
Corporation

NPCC

Randy
MacDonald

NB Power
Corporation

NPCC

Michael
Ridolfino

Central
Hudson Gas
and Electric

NPCC

Vijay Puran

NYSPS

NPCC

ALAN
ADAMSON

New York
State
Reliability
Council

NPCC

Sean Cavote

PSEG - Public 1
Service
Electric and
Gas Co.

NPCC

Brian Robinson Utility Services 5

NPCC

Quintin Lee

Eversource
Energy

NPCC

Jim Grant

NYISO

NPCC

Southwest
Power Pool,
Inc. (RTO)

Shannon
Mickens

OGE Energy - Sing Tay
Oklahoma Gas
and Electric Co.

1,3,5,6

MRO,SPP RE

SPP RE

SPP RTO

OKGE

John Pearson

ISONE

NPCC

John Hastings

National Grid
USA

NPCC

Michael Jones

National Grid
USA

NPCC

Nicolas
Turcotte

Hydro-Qu?bec 1
TransEnergie

NPCC

Chantal Mazza Hydro-Quebec 2

NPCC

Shannon
Mickens

Southwest
Power Pool
Inc.

MRO

Sunny Raheem Southwest
Power Pool
Inc.

MRO

Doug Bowman Southwest
Power Pool
Inc.

MRO

Sing Tay

OGE Energy - 6
Oklahoma

MRO

Terri Pyle

OGE Energy - 1
Oklahoma Gas
and Electric
Co.

MRO

Donald
Hargrove

OGE Energy - 3
Oklahoma Gas
and Electric
Co.

MRO

Patrick Wells

OGE Energy - 5
Oklahoma Gas
and Electric
Co.

MRO

Document Name
Comment
AZPS generally agrees with the proposed scope of the SAR. However, the testing methodology needs to be based on standard industry practices. Also,
in some cases, modeling can be performed using information obtained from the generator owner without requiring a model verification test.
AZPS agrees with the SAR that reliability gaps are much less for synchronous generators which have behavior that is based more on the physical
characteristics of the machine. Therefore, AZPS does not support significant changes or more prescriptive requirements with regards to model
validation for synchronous generators.
Likes

Dislikes

Response

Matthew Nutsch - Seattle City Light - 1,3,4,5,6 - WECC
Answer

Document Name
Comment
No evidence is provided in the SAR or the referenced white papers that the existing method of model verification as required by MOD-026/027 is
insufficient for synchronous generators, yet the SAR proposes a significant time and cost increase on synchronous generator GOs to perform additional
verification.
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Richard Jackson - U.S. Bureau of Reclamation - 1,5
Answer
Document Name
Comment

Please see the response to question 2 regarding scope. Prior to proposing additional modifications, Reclamation recommends the SDT take additional
time to completely identify the scope of the Standard Authorization Request to account for future potential compliance issues. This will provide
economic relief for entities by minimizing the costs associated with the planning and adjustments required to achieve compliance with frequently
changing standard versions. NERC should foster a compliance environment that will allow entities to fully implement technical compliance with current
standards before moving to subsequent versions.
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Douglas Webb - Evergy - 1,3,5,6 - MRO
Answer

Document Name
Comment
Evergy incorporates by reference the Edison Electric Institute's response to Question 1.
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Jennie Wike - Tacoma Public Utilities (Tacoma, WA) - 1,3,4,5,6 - WECC
Answer

Document Name
Comment
Tacoma Power does not agree that changes to MOD-026 and MOD-027 are justified. The modeling standards are all encompassing and do not directly
address any specific type of asset. There are specific models for the various resources. If additional models are required to account for new resources
such as inverter-based, then new models should be developed to account for such resources. The intent of the proposed changes seem to be
focused on performance and should be addressed by other standards such as BAL or VAR standards.
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Daniel Gacek - Exelon - 1,3,5,6
Answer

Document Name
Comment
Exelon generally supports the SAR, however we agree with the concerns regarding the scope of the SAR as stated in the comments submitted by the
EEI. .
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Sing Tay - OGE Energy - Oklahoma Gas and Electric Co. - 1,3,5,6, Group Name OKGE
Answer

Document Name
Comment
OKGE agrees with the concerns as stated in the comments submitted by EEI.

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Mark Gray - Edison Electric Institute - NA - Not Applicable - NA - Not Applicable
Answer

Document Name
Comment
EEI generally supports the proposed scope in principle but recommends that the scope reflect the gap(s) identified in the referenced white
papers. Additionally, if Project 2020-02 and Project 2020-06 are combined as described in question 2 (below), additional industry review and comment
will be necessary. Relative to the current SAR, we offer the following suggestions:
1. Project Scope language for Item a.: Develop requirements that provide Transmission Planning (TP) and Generator Owners (TO) needed
direction and latitude in specifying and delivering generating unit resource data that can be used for the development of dynamic models that
reflect resource performance regardless of the resource type.
2. Project Scope language for Item b: Develop requirements that provide Transmission Planners the flexibility to specify model parameters that
align with the resource types that are used in their dynamic simulations so that BES reliability under their purview can be accurately assessed.
3. Replace phrases such as “consider ways” in the SAR because such terms are open ended and not actionable.

4. Remove the phrase “all types” and provide Transmission Planners the ability to define the needed model parameters that align with the
resource types under their purview. This will ensure model parameters are based on good engineering judgement.
5. Replace the term “sufficient” because the term is too vague to provide needed direction and scope to the SDT.
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Thomas Foltz - AEP - 3,5,6
Answer

Yes

Document Name
Comment
AEP agrees in principle with the overall scope and direction of this proposed SAR. AEP also believes there is merit in developing new standard(s) rather
than modifying the existing MOD-026 and MOD-027 standards. The technological difference of IBRs as compared to synchronous generators is
obviously significant, and as alluded to in the draft SAR, the modeling information needed would be quite different as well. This difference is significant
enough that modifying MOD-026 and MOD-027 to accommodate new IBR obligations will result in overly complex versions of those two standards.
Therefore, AEP recommends that new standards be pursued for IBRs rather than modifying MOD-026 and MOD-027, though MOD-026/027 may need
to be modified to remove the present references to IBRs.
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Leonard Kula - Independent Electricity System Operator - 2
Answer

Yes

Document Name
Comment
N/A.
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Rachel Coyne - Texas Reliability Entity, Inc. - 10
Answer
Document Name

Yes

Comment
Yes
Texas RE agrees with the scope of the Project 2020-06 as described in the Standard Authorization Request (SAR). Texas RE notes that the SAR
states “the IRPTF noted that it is not feasible to stage large disturbances for verification purposes, so other methods for verification of model
performance under large disturbance conditions may need to be developed.” The Standard drafting team (SDT) could consider modifying the MOD-026
and MOD-027 testing requirements to include large disturbances, both inside and outside the GOs’ planning areas, in addition to the small disturbances
as is required currently.

As an alternative, the SDT should consider modifying MOD-033 as an alternative for large disturbance verification. MOD-033-1 only requires the
Planning Coordinator (PC) to perform one comparison of the performance of the PC’s portion of the existing system in a planning dynamic model to
actual system response once every 24 months, and allows the PC to select the dynamic local event for which the comparison is performed. The
standard could be modified to require comparisons for a defined subset of large disturbances, and require notification to the GO and GO model
parameter verification when the comparison identifies issues.

Texas RE encourages the drafting team to work with the IRPTF (now IRPWG) to develop methods for this type of test.
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Jamie Prater - Entergy - 5,6
Answer

Yes

Document Name
Comment
Entergy's primary comment would be to support this SAR. Most models for the Inverter-based Resources that we initially receive from the
Interconnection Customers use generic parameters. We can identify obvious errors with some modeling parameters; however, sufficient MOD-026/027
model verification is needed to ensure the models are parameterized such that they provide accurate dynamic responses for small and large
disturbances. As outlined in this SAR, the existing MOD-026/027 requirements do not allow for adequate verification of the IBR model particularly for
large disturbances. For improved clarity, Requirement 2 of MOD-026/027 should specifically mention data needs associated with frequency/voltage ride
through, momentary cessation, low/high voltage logic, and active/reactive power control settings although all parameters of acceptable models still need
to be verified and provided. Also, given that most inverter-based resources operate in plant-level control, to verify the appropriate plant level controller
parameters, multiple solar cells or wind turbines should be online during the test and specified as a requirement for MOD-026/027 verification.

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Dana Klem - MRO - 1,2,3,4,5,6 - MRO, Group Name MRO NSRF
Answer

Yes

Document Name
Comment
While the MRO NSRF understands the FERC and NERC concern that existing small disturbance testing does not adequately verify model parameters
to capture the full dynamic behavior of the generation resource, it has concerns on mandating the scope of large disturbance testing that includes:
1.
Testing of commercial and utility scale inverter-based systems should not mandate testing of individual inverters as this would be cost prohibitive
and inefficient which are contrary to good standards development. Testing at the individual inverter level should be explicitly excluded in the MOD-026 /
and MOD-027 applicability section similar to PRC-005.
2.
Staged voltage testing greater than nearby capacitor bank switching or voltage reference step testing for MOD-026 is problematic. Creating a
disturbance larger than nearby capacitor bank switching could induce a transmission system disturbance.
3.
Staged frequency testing beyond frequency reference step tests and outside of deadbands for MOD-027 is problematic and could induce a
transmission system disturbance. Only distribution / transmission system disturbances have capability to move interconnection level frequencies outside
of deadbands unless the inverter-based system is very small.
4.
The MRO NSRF agrees with the NERC IRPTF that it’s not feasible to stage large disturbances for verification purposes. Therefore, any
mandatory requirements of modifications should include alternatives such as operational recording of voltage and frequency responses due to nearby
system disturbances. Any large disturbance testing should not have the potential to cause damage to the generator or the transmission system.
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Andy Fuhrman - Minnkota Power Cooperative Inc. - 1 - MRO
Answer

Yes

Document Name
Comment
MPC supports comments submitted by the MRO NERC Standards Review Forum.
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Larry Heckert - Alliant Energy Corporation Services, Inc. - 4
Answer

Yes

Document Name
Comment
Alliant Energy supports the comments submitted by the MRO NSRF.
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Bobbi Welch - Midcontinent ISO, Inc. - 2
Answer

Yes

Document Name
Comment
MISO supports comments submitted by the ISO/RTO Council (IRC) Standards Review Committee (SRC). MISO agrees with requiring testing to verify
parameters to be used in modeling and agrees with ensuring all technologies are included. The concern is ensuring the proposed scope of such testing
is practical and does not introduce an undue testing burden that requires difficult field testing without the intended results. In addition, future test
windows should be conducted in a timelier manner than the required ten years for Generator Owners/Operators to initially implement and report on
these new tests.
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Jamie Monette - Allete - Minnesota Power, Inc. - 1
Answer

Yes

Document Name
Comment
Minnesota Power supports MRO’s NERC Standards Review Forum’s (NSRF) comments for this project.
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Carl Pineault - Hydro-Qu?bec Production - 1,5
Answer

Yes

Document Name

2020-06_Unofficial_Comment_Form_SAR_HQP_completed.docx

Comment
Please send comments attached.
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Christopher McKinnon - Eversource Energy - 1,3
Answer

Yes

Document Name
Comment
Eversource agrees with the SAR and adds that the Standards Committee should priortize this since there are several sizable IBR generation projects
planned for New England in the near future. Please see comments in question 3.
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Elizabeth Davis - PJM Interconnection, L.L.C. - 2 - RF, Group Name ISO/RTO Council (IRC) Standards Review Committee (SRC)
Answer

Yes

Document Name
Comment
The ISO/RTO Council (IRC) Standards Review Committee (SRC) agrees with requiring testing to verify parameters to be used in modeling and agrees
with ensuring all technologies are included. The concern is ensuring the proposed scope of such testing is practical and does not introduce an undue
testing burden that requires difficult field testing without the intended results. In addition, future test windows should be conducted in a timelier manner
than the required ten years for Generator Owners/Operators to initially implement and report on these new tests.
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Brandon Gleason - Electric Reliability Council of Texas, Inc. - 2
Answer
Document Name

Yes

Comment
None.
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Pamela Hunter - Southern Company - Southern Company Services, Inc. - 1,3,5,6 - SERC, Group Name Southern Company
Answer

Yes

Document Name
Comment
See comments in #3 below.
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Amber Parker - Unisource - Tucson Electric Power Co. - NA - Not Applicable - WECC
Answer

Yes

Document Name
Comment

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Response

Bruce Reimer - Manitoba Hydro - 1,3,5,6
Answer

Yes

Document Name
Comment

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Response

Mark Garza - FirstEnergy - FirstEnergy Corporation - 1,3,4,5,6, Group Name FE Voter
Answer

Yes

Document Name
Comment

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Response

Anthony Jablonski - ReliabilityFirst - 10
Answer

Yes

Document Name
Comment

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Response

Kjersti Drott - Tri-State G and T Association, Inc. - 1,3,5
Answer

Yes

Document Name
Comment

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Response

Anton Vu - Los Angeles Department of Water and Power - 1,3,5,6
Answer

Yes

Document Name
Comment

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Response

James Baldwin - Lower Colorado River Authority - 1,5
Answer

Yes

Document Name
Comment

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Response

Teresa Cantwell - Lower Colorado River Authority - 1,5
Answer

Yes

Document Name
Comment

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Response

Kim Thomas - Duke Energy - 1,3,5,6 - SERC,RF, Group Name Duke Energy
Answer

Yes

Document Name
Comment

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0
0

Response

Cain Braveheart - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

Yes

Document Name
Comment

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Response

Shannon Mickens - Southwest Power Pool, Inc. (RTO) - 2 - MRO, Group Name SPP RTO
Answer

Yes

Document Name
Comment

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Response

Ruida Shu - Northeast Power Coordinating Council - 1,2,3,4,5,6,7,8,9,10 - NPCC, Group Name NPCC Regional Standards Committee
Answer

Yes

Document Name
Comment

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Response

Constantin Chitescu - Ontario Power Generation Inc. - 5
Answer
Document Name

Yes

Comment

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2. In your opinion, should the project scopes of Project 2020-02 Transmission-connected Dynamic Reactive Resources (MOD-026/027
portions only) and Project 2020-06 be combined under a single project, with a single standard drafting team? Please explain.
Jennie Wike - Tacoma Public Utilities (Tacoma, WA) - 1,3,4,5,6 - WECC
Answer

Document Name
Comment
While Tacoma Power agrees that transmission connected Dynamic Reactive Resources that qualify as BES elements and meet the requirements of
MOD-026 and MOD-027 should be modeled, modifications to the existing MOD standards are not required. MOD-026 as currently written sufficiently
addresses Dynamic Reactive Resource response for various assets. MOD-027 does not have any implications to Dynamic “Reactive” Resources.
Tacoma Power recommends that these deficiencies should be addressed by performance standards and not modeling standards. Any changes based
on IBRs should also not be limited to “Reactive” capability since Real power capability is equally important to system reliability.
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Bobbi Welch - Midcontinent ISO, Inc. - 2
Answer

Document Name
Comment
MISO recommends Project 2020-02: Transmission Connected Resources and Project 2020-06: Verifications of Models and Data for Generators
be approved and tracked separately. While we support the SAR for Project 2020-02: Transmission Connected Resources, we would prioritize the
work of Project 2020-06: Verifications of Models and Data for Generators to clarify required tests for generators, particularly ride-through capability
of inverter-based resources, as a good first step prior to adding more equipment as that under Project 2020-02. In tying Project 2020-06 to Project
2020-02, we are concerned that adding Transmission Owners and a host of additional transmission equipment to the scope of MOD-026 and MOD-027,
currently not covered under the scope of these standards, may delay the specifications needed for generator testing. That said, we are supportive of the
same SDT working on both projects.
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Thomas Foltz - AEP - 3,5,6
Answer
Document Name

Comment
AEP recommends against combining the drafting teams of Project 2020-02 and 2020-06 for the efforts related to MOD-026 and MOD-027. While
combining these two projects may appear to make logical sense from a topical standpoint, there are a number of reasons why these efforts should
remain distinct: (1) the implementation plan of MOD-026 and MOD-027 is well-underway with obligations already being phased-in over time. Attempting
to merge a new implementation plan involving dynamic reactive device requirements into the same standards would result in confusion. (2) There is
technical merit in keeping the two projects and resulting standards separate because even though IBRs and dynamic reactive devices are both
electronic-based, they are different enough in function and configuration to justify their own distinct efforts and resulting standards. (3) Differing
Applicable Entities are involved: GOs in the case of IBRs, TOs in the case of dynamic reactive devices.
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Pamela Hunter - Southern Company - Southern Company Services, Inc. - 1,3,5,6 - SERC, Group Name Southern Company
Answer

Yes

Document Name
Comment
By combining the two projects into a single project and a single standard drafting team could eliminate potential conflict between the two
projects. Moreover, it should also improve the efficiency of the overall project.
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Constantin Chitescu - Ontario Power Generation Inc. - 5
Answer

Yes

Document Name
Comment
OPG supports the comments from NPCC Regional Standards Committee
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Response

Brandon Gleason - Electric Reliability Council of Texas, Inc. - 2

Answer

Yes

Document Name
Comment
ERCOT sees value in combining the projects, provided focus remains on model verification in the event the projects are combined.
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Elizabeth Davis - PJM Interconnection, L.L.C. - 2 - RF, Group Name ISO/RTO Council (IRC) Standards Review Committee (SRC)
Answer

Yes

Document Name
Comment
The IRC SRC agrees in combining the scope of both Project 2020-02 and 2020-06, under Project 2020-06. We request the SAR Drafting Team to
consider also combining MOD-026 and MOD-027 under one new dynamics Standard to allow for efficient and effective management of the
documentation and testing that meets the Standard Requirements, along with the Subject Matter Expert’s time / resources allocated to this Project work.
(Please note: MISO does not support the response to Question #2, thank you)

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Mark Gray - Edison Electric Institute - NA - Not Applicable - NA - Not Applicable
Answer

Yes

Document Name
Comment
EEI supports the concept of combining the MOD-026/027 portions of Project 2020-02 into Project 2020-06, noting that the scope of Project 2020-02
includes addressing “all varieties of transmission-connected dynamic reactive resources that are utilized in providing ERS in the BES” (see P20202-02
Scope). This change represents a significant expansion of the Project 2020-06, so the revised SAR will need to be resubmitted for Industry review and
comment.
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0
0

Response

Daniel Gacek - Exelon - 1,3,5,6
Answer

Yes

Document Name
Comment
Exelon concurs with the Question 2 comment submitted by the EEI.
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Ruida Shu - Northeast Power Coordinating Council - 1,2,3,4,5,6,7,8,9,10 - NPCC, Group Name NPCC Regional Standards Committee
Answer

Yes

Document Name
Comment
As both projects relate to the same standards, combining both projects would result in only one revision of MOD-026/027 standards. Each update of
MOD-026/027 standards generates a considerable amount of work for stakeholders.
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Shannon Mickens - Southwest Power Pool, Inc. (RTO) - 2 - MRO, Group Name SPP RTO
Answer

Yes

Document Name
Comment
The SPP RTO supports a single project for the standards. We feel this effort will promote consistency and efficiency due to their requirement similarities
in model verification.
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Response

Douglas Webb - Evergy - 1,3,5,6 - MRO
Answer

Yes

Document Name
Comment
Evergy incorporates by reference the Edison Electric Institute's response to Question 2.
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Response

Carl Pineault - Hydro-Qu?bec Production - 1,5
Answer

Yes

Document Name

2020-06_Unofficial_Comment_Form_SAR_HQP_completed.docx

Comment
Please find attached comments
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Response

Jamie Monette - Allete - Minnesota Power, Inc. - 1
Answer

Yes

Document Name
Comment
Minnesota Power supports MRO’s NERC Standards Review Forum’s (NSRF) comments for this project.
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Response

Larry Heckert - Alliant Energy Corporation Services, Inc. - 4

Answer

Yes

Document Name
Comment
No comments
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Response

Leonard Kula - Independent Electricity System Operator - 2
Answer

Yes

Document Name
Comment
N/A.
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Response

Richard Jackson - U.S. Bureau of Reclamation - 1,5
Answer

Yes

Document Name
Comment
To minimize churn among standard versions, Reclamation recommends the standard drafting team coordinate changes with other existing drafting
teams for related standards; specifically, MOD-025, MOD-032, PRC-019, PRC-024, Project 2017-07, and the Standards Efficiency Review Phase 2.
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Kjersti Drott - Tri-State G and T Association, Inc. - 1,3,5
Answer
Document Name

Yes

Comment
It is reasonable to combine the two projects under a single project to avoid redundant work.
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Response

Bruce Reimer - Manitoba Hydro - 1,3,5,6
Answer

Yes

Document Name
Comment
In MH there are Transmission-connected Dynamic Reactive Resources (Ponton and Birchtree SVC stations) and Generation owned synchronous
condenser machines, which all need to be modeled and validated for Transmission and Operations.
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Matthew Nutsch - Seattle City Light - 1,3,4,5,6 - WECC
Answer

Yes

Document Name
Comment
MOD-026 and MOD-027 have slight differences that complicate implementation in part because they were drafted by different teams. A single team to
oversee revisions to both standards is recommended to ensure consistency.
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Kelsi Rigby - APS - Arizona Public Service Co. - 1,3,5,6
Answer
Document Name
Comment

Yes

APS supports combining the MOD-026/027 portions of Projects 2020-02 into 2020-06 and forming a single drafting team for MOD-026/027. APZS
requests clarity that the Project 2020-02 drafting team will remain in place for MOD-025, PRC-019, and PRC-024 changes only.
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Sing Tay - OGE Energy - Oklahoma Gas and Electric Co. - 1,3,5,6, Group Name OKGE
Answer

Yes

Document Name
Comment

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Response

Christopher McKinnon - Eversource Energy - 1,3
Answer

Yes

Document Name
Comment

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Response

Andy Fuhrman - Minnkota Power Cooperative Inc. - 1 - MRO
Answer

Yes

Document Name
Comment

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0
0

Response

Dana Klem - MRO - 1,2,3,4,5,6 - MRO, Group Name MRO NSRF
Answer

Yes

Document Name
Comment

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Response

Cain Braveheart - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

Yes

Document Name
Comment

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Response

Kim Thomas - Duke Energy - 1,3,5,6 - SERC,RF, Group Name Duke Energy
Answer

Yes

Document Name
Comment

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Response

Teresa Cantwell - Lower Colorado River Authority - 1,5
Answer
Document Name

Yes

Comment

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Response

James Baldwin - Lower Colorado River Authority - 1,5
Answer

Yes

Document Name
Comment

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Response

Anton Vu - Los Angeles Department of Water and Power - 1,3,5,6
Answer

Yes

Document Name
Comment

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Response

Anthony Jablonski - ReliabilityFirst - 10
Answer

Yes

Document Name
Comment

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Response

Amber Parker - Unisource - Tucson Electric Power Co. - NA - Not Applicable - WECC
Answer

Yes

Document Name
Comment

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Response

Rachel Coyne - Texas Reliability Entity, Inc. - 10
Answer
Document Name
Comment
Texas RE does not have comments on this question.
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Mark Garza - FirstEnergy - FirstEnergy Corporation - 1,3,4,5,6, Group Name FE Voter
Answer
Document Name
Comment
FirstEnergy supports the path of either combined or separate; whatever is chosen should offer the most efficient and expeditious means of completing
this process.
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3. Provide any additional comments for the SAR drafting team to consider, if desired.
Kelsi Rigby - APS - Arizona Public Service Co. - 1,3,5,6
Answer
Document Name
Comment
AZPS generally agrees with the proposed scope of the SAR. However, the testing methodology needs to be based on standard industry practices.
Also, in some cases, modeling can be performed using information obtained from the generator owner without requiring a model verification test.
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Matthew Nutsch - Seattle City Light - 1,3,4,5,6 - WECC
Answer
Document Name
Comment
Seattle City Light feels that there is not enough information to be able to agree with what is being proposed for verifying how a generator will respond to
a large system disturbance. The following sentence from the SAR is concerning:
Additionally, the IRPTF noted that it is not feasible to stage large disturbances for verification purposes, so other methods for verification of model
performance under large disturbance conditions may need to be developed.
There is seemingly no consideration of what the cost of these verifcations tests will be. Seatlle would like to know what the proposed methods are for
this testing before agreeing with the SAR. That way potential cost of testing can be estimated. Testing generators is expensive and time consuming
and generally the operating staff don't like it when we test units near their limits. magine what their response would be if we said we wanted to simulate
a large system disturbance on this machine to see how it will behave.
Based on the current construciton of the SAR, Seattle feels that there has not been sufficient reason shown for additional testing on the synchornous
machines. The SAR notes that the problem exists for inverter based equipment during disturbances but does not speak to the same problems
occurring on synchronous equipment. This wholesale approach to the SAR seems to encumber synchronous units with testing that does not benefit
them and undue costs.
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Mark Garza - FirstEnergy - FirstEnergy Corporation - 1,3,4,5,6, Group Name FE Voter

Answer
Document Name
Comment
N/A
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Richard Jackson - U.S. Bureau of Reclamation - 1,5
Answer
Document Name
Comment
Reclamation recommends the SAR drafting team thoughtfully assess the cost impacts (Cost Impact Assessment, page 3) associated with this SAR to
effect changes in a cost-effective manner. The SAR proposes a significant increase in the scope of the affected standards, which will have a substantial
impact on affected entities and should not be taken without appropriate cost consideration.
Reclamation observes the Reliability Coordinator’s new BES reliability constraints for outages and generation operations (not accounting for ramp
testing or other generation system testing) and the new Energy Imbalance Market make testing generator resources in a dynamic model difficult without
impacting those constraints. NERC Standards are beginning to conflict with daily operations and the Registered Entities are caught in the middle.
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Leonard Kula - Independent Electricity System Operator - 2
Answer
Document Name
Comment
N/A.
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Kim Thomas - Duke Energy - 1,3,5,6 - SERC,RF, Group Name Duke Energy
Answer
Document Name
Comment
Consider reevaluating applicability of the Eastern Interconnection 100 MVA rating for generating units based on current and anticipated future influx of
IBR’s by considering a lower MVA threshold for NERC Standards MOD-026 and MOD-027.
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Cain Braveheart - Bonneville Power Administration - 1,3,5,6 - WECC
Answer
Document Name
Comment
After review of the Project 2020-06 SAR and its inclusion of IBR, BPA observed that our comments were not considered from the previous SAR
comment period for Project 2020-02, Transmission Connected Resources. BPA would like to reiterate our recommendation in our comments below, as
BPA believes revisiting the applicability threshold is needed to capture the renewable generation capability that is currently planned/projected to be
introduced to the Bulk Power System (BPS).
BPA is raising this concern and recommendation again, recognizing that once this SAR moves to the Standard Development phase, it will be difficult to
introduce the concept of capturing the small renewable generation influx on the BPS, as it may fall outside the scope of the SAR. BPA believes this
would bolster the reliability of the BPS by allowing for more accurate models that reflect a comprehensive data set.

BPA Comments from 5/13/20: Project 2020-02 - TCR SAR
BPA believes this is a timely and much needed effort to ensure transmission-connected reactive resources have validated dynamic models, and
appropriate system performance. The Western Interconnection is undergoing significant transformation with its generation mix. Many of the large coalfired and nuclear power plants have retired or are scheduled to retire. These generators are replaced with renewable plants, which are usually smaller
in size. The current 75 MW threshold represented 80% of generating capacity in the Western Interconnection in 2007. However, with the retirement of
large synchronous generators and addition of smaller renewable plants, the threshold is now lower. As such, BPA requests the drafting team to revisit
the applicability threshold in MOD-026/27 Reliability Standards for the Western Interconnection as additional scope to this SAR.
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Dana Klem - MRO - 1,2,3,4,5,6 - MRO, Group Name MRO NSRF

Answer
Document Name
Comment
1. Purpose or Goal: We are not supportive of providing the SDT with the option of “creating a new standard.”
2. Cost Impact Assessment: Suggest removing “The SAR proposes to clarify and address gaps in the requirements in MOD-026-1 and MOD-0271.” The statement does not provide insight to costs.
3. Project Scope (a): “…better reflect all types of generation resources and not just synchronous resources.”
4. The concern is that the language is without limitation. “All types” when the SAR attempting to address a specific, limited issue. Also, does “not
just synchronous” exclude potential synchronous resources or assumes the standards already address synchronous resources?
5. Project Scope (b): “Consider ways” is not actionable to revising a standard. Suggest language like, “Develop and incorporate methods to
recognize generator representation in dynamic simulations…”
6. Purpose or Goal and Project Scope: The word “sufficient” is vague in the context of the SAR.
To Illustrate. I may be driving down the street and my brake warning light comes on but still have “sufficient” power to stop.
Suggestion, or something along these lines: “…to IBRs and to require [Registered Entities to develop model verifications to represent generation in
dynamic simulations.]”
7. General Note: It looks as if language from the white paper was dumped into the SAR. That’s fine but white paper language does not necessarily
translate well to the purpose of the SAR—scoping the SDT.
Likes

Dislikes

Response

Andy Fuhrman - Minnkota Power Cooperative Inc. - 1 - MRO
Answer
Document Name
Comment
MPC supports comments submitted by the MRO NERC Standards Review Forum.
Likes

Dislikes

Response

Larry Heckert - Alliant Energy Corporation Services, Inc. - 4
Answer
Document Name
Comment

Alliant Energy supports the comments submitted by the MRO NSRF.
Likes

Dislikes

Response

Bobbi Welch - Midcontinent ISO, Inc. - 2
Answer
Document Name
Comment
MISO supports comments submitted by the ISO/RTO Council (IRC) Standards Review Committee (SRC) and agrees with the proposed language in the
SAR. In addition, we recommend the scope of the SAR be expanded to allow entities with a reliability need to request modeling data from GOs. We
believe this aligns with the White Paper’s intent to require the provision of GO data in support of accurate models.
Likes

Dislikes

Response

Jamie Monette - Allete - Minnesota Power, Inc. - 1
Answer
Document Name
Comment
Minnesota Power supports MRO’s NERC Standards Review Forum’s (NSRF) comments for this project.
Likes

Dislikes

Response

Douglas Webb - Evergy - 1,3,5,6 - MRO
Answer
Document Name
Comment

None.
Likes

Dislikes

Response

Shannon Mickens - Southwest Power Pool, Inc. (RTO) - 2 - MRO, Group Name SPP RTO
Answer
Document Name
Comment
The SPP RTO agrees with proposed language in the SAR. However, we recommend that the SAR’s scope includes language that requires GOs to
provide modeling data to entities that have a reliability need and make a request. We feel this recommendation would properly align with the White
Paper’s language suggesting these efforts would help produce quality models.
The propose scope language can be seen as follows:
Consider including language in both standards and/or new standard that would require the GO to make modeling information available to entities that
have a reliability related need and request the modeling data.
Likes

Dislikes

Response

Jennie Wike - Tacoma Public Utilities (Tacoma, WA) - 1,3,4,5,6 - WECC
Answer
Document Name
Comment
While Tacoma Power recognizes that there is room for improvement in the existing Standards that would improve system reliability for IBRs, the
modeling Standards are not the best means of correcting these deficiencies. Modeling is a means of predicting how BES elements will dynamically
respond to system disturbances but actual performance should be the metric used to determine true performance regardless of the resource type. This
should include the resources ability to quickly respond to system disturbances including voltage and frequency excursions.
Likes

Dislikes
Response

Christopher McKinnon - Eversource Energy - 1,3
Answer
Document Name
Comment
It is important to note that real-power producing IBR sites can include reactive-only inverter-based compensation as part of their design. Eversource
requests that the scope of this SAR include model verification of the models of these reactive-power-only IBRs (example: STATCOMs) as well as the
real-power-capable IBRs. The impact of a generating site on the performance of the transmission system is a result of the operation of both types of
IBRs. Additionally, other reactive-power-only resources such as synchronous condensers and SVCs should have requirements under these model
verification standards. Finally, NERC needs to define a new term - Resource Owners - since the term Generator Owners is commonly interpreted to
refer to the owners of watt-producing equipment whereas the MOD standards need to reflect model verification requirements for dynamic var-producing
equipment (synchronous condenders, SVCs, STATCOMs) also.
Likes

Dislikes

Response

Daniel Gacek - Exelon - 1,3,5,6
Answer
Document Name
Comment
The scope of Item b. should allow the drafting team to consider an exemption from the R2.1.1 model verification testing for generation resource types
that cannot perform the required tests or can only safely perform tests that are of no practical value.
Likes

Dislikes

Response

Elizabeth Davis - PJM Interconnection, L.L.C. - 2 - RF, Group Name ISO/RTO Council (IRC) Standards Review Committee (SRC)
Answer
Document Name
Comment
The IRC SRC agrees with proposed language in the SAR. However, we recommend that the SAR’s scope includes language that requires GOs to
provide modeling data to entities that have a reliability need and make a request. We feel this recommendation would properly align with the White
Paper’s language suggesting these efforts would help produce quality models.
Likes
Dislikes

0
0

Response

Brandon Gleason - Electric Reliability Council of Texas, Inc. - 2
Answer
Document Name
Comment
None.
Likes

Dislikes

Response

Pamela Hunter - Southern Company - Southern Company Services, Inc. - 1,3,5,6 - SERC, Group Name Southern Company
Answer
Document Name
Comment
a) The indication of the ability of IBR facilities to ride through voltage and frequency excursions (large disturbances) is required to be communicated to
TPs via recent changes to PRC-024 and does not need to be separately addressed in MOD-026 & MOD-027.
b) Performance of the field testing required to obtain a generating plant response to large system disturbance cannot be done. This inability raises
concerns that GOs may be forced to perform multiple, iterative model parameter estimations for each facility each time that a system disturbance
causes a facility to perform differently from the existing model.
c) Overlap in the dynamic characteristics listed in the requirements of MOD-032 with the requirements of MOD-026 and MOD-027 exist. Some
consideration of eliminating the duplicative requirements should be done.
d) the transmission system interconnection requirements and interconnection agreements can be the sufficient and adequate governing regulation for
transmission planning groups to obtain necessary modeling information.

Likes

Dislikes
Response

Project 2020-06 & 2020-02

Summary Response to SAR Comments | June 2021

Introduction

The Standard Authorization Request (SAR) drafting team thanks all who provided comments during the
informal comment period. All comments received were reviewed and the identified common themes are
addressed below. Some comments have been reserved for consideration during the standard drafting
phase of the project. As the standard drafting phase begins, the financial impact question and risk will be
considered.
Industry raised concern of the practicality for validation of large-signal response testing for Inverter
Based Resources (IBR) if required within the standard.
The existing MOD-026/027 Standards do not explicitly require model verification using large-signal
disturbance tests. In the revised standard(s), the SDT will consider reasonable testing including alternate
means of model verification.
Given the change of generation mix (increase of IBRs) since the MOD-026/027 effective date, the
current 75MVA/100MVA thresholds for applicability is too high.
The SAR Detailed Description has added language to include a review of the Applicability sections.
Besides MOD-026/027, revisions to MOD-032 or MOD-033 could also be made to improve dynamic
model verification and model accuracy.
The SAR focuses on revisions to MOD-026/027 to include IBR model verification and clarify any important
differences from synchronous resources. Though MOD-032/033 are related, the SAR DT believes the
improvements can be achieved by revising MOD-026/027.
Questions/concerns about implementation plan(s) for MOD-026/027 R2 considering the ongoing
phased approach.
The SDT will propose a reasonable implementation plan inclusive of IBRs and dynamic reactive resources
that is considerate of current phased implementation MOD-026/027.
Revisions to MOD-026/027 are not necessary.
The Industry Need and Detailed Description sections articulate the need for revisions to MOD-026/027,
especially considering the increased usage of both IBR’s and transmission-connected reactive resources.
Consider adding requirement language to MOD-026/027 that a Registered Entity with a reliability
related need (such as a PC) can request model information from a GO, and the GO be obligated to
provide the information.
MOD-026/027 requires the GO to provide the TP verified modeling information. In addition, MOD-032
prescribes the Planning Coordinator (PC) & associated TPs to jointly develop dynamic modeling data

RELIABILITY | RESILIENCE | SECURITY

requirements and reporting procedures for the PC’s planning area, which can then be requested of the
GO. Therefore, the SAR DT does not see a need to expand the obligations of the GO.
It is unclear whether MOD-026/027 are applicable to EMT models.
The SDT will review and determine if revisions to MOD-026/027 are needed to clarify language related to
EMT models.
(2020-02) There is needed definition or clarification of what is considered a transmission-connected
dynamic reactive resource (TCDRR).
The revised standard language and/or applicability will make clear what is meant by a transmissionconnected dynamic reactive resource and applicable MVA thresholds. The SAR allows the SDT to add,
modify or retire Glossary Terms.
(2020-02) Majority of comments advocate the combination of scopes for Projects 2020-02 and 2020-06
under a single drafting team for the sake of efficiency and consistency.
Project 2020-06 SAR DT intends to maintain and address the scope outlined in two separate SAR’s for
revisions to MOD-026 and MOD-027. Revisions to the remaining standards MOD-025, PRC-019, and PRC024 will be addressed by other drafting teams.

Resources
Project 2020-06 Verifications of Models and Data for Generators
•

MOD-026-1 and MOD-027-1 SAR

•

Industry Comments

Project 2020-02 Transmission-connected Reactive Dynamic Resources
•

TCR SAR (MOD-026, MOD-027, MOD-025, PRC-019, PRC-024)

•

Industry Comments

Project 2020-06 Verifications of Models and Data for Generators
Summary of Comments | May 2021

Unofficial Nomination Form

Project 2020-06 Verification of Models and Data for Generators
Standard Authorization Request Drafting Team
Do not use this form for submitting nominations. Use the electronic form to submit nominations for
Project 2020-06 Verification of Models and Data for Generators Standard Authorization Request (SAR)
drafting team members by 8 p.m. Eastern, Thursday, January 14, 2021. This unofficial version is provided
to assist nominees in compiling the information necessary to submit the electronic form.
Additional information is available on the project page. If you have questions, contact Senior Standards
Developer, Chris Larson (via email), or at 404-446-9708.
By submitting a nomination form, you are indicating your willingness and agreement to actively
participate in face-to-face meetings and conference calls.
Previous drafting or review team experience is beneficial, but not required. A brief description of the
desired qualifications, expected commitment, and other pertinent information is included below.
Background

RELIABILITY | RESILIENCE | SECURITY

namely MOD-026 and MOD-027, was being drafted by the IRPTF and approved for posting in September
2020 by the Standards Committee. The Project 2020-06 Verifications of Models and Data for Generators
SAR will be posted for industry comment, and additional nominees with MOD-026/027 background will be
sought. A single SAR DT will be charged with determining whether to combine the two projects and
drafting a combined SAR.
Standard(s) affected: MOD-026, MOD-027

Drafting Team activities include participation in technical conferences, stakeholder communications
and outreach events, periodic drafting team meetings and conference calls. Approximately one faceto-face meeting per quarter can be expected (on average three full working days each meeting) with
conference calls scheduled as needed to meet the agreed-upon timeline the drafting team sets forth.
NERC is seeking individuals who possess experience in the following areas:
•

Developing and verifying models involving Inverter Based Resources (IBR) and synchronous
generators used in long-term planning assessments

•

Understanding the large disturbance behavior of IBRs, modelling parameters associated with
voltage control behavior during large disturbance conditions, and the associated verification
methods and practices for IBRs

•

Developing and verifying dynamic models used in long-term planning assessments, specifically
for transmission-connected reactive resources*

•

Modeling and studying transmission-connected reactive devices during interconnection
studies or long-term planning assessments

•

Performing equipment capability testing for transmission-connected reactive devices and
rotating machines

•

Understanding the large disturbance behavior of transmission-connected reactive devices,
particularly the power electronic controls that govern the performance of these devices during
abnormal grid conditions

* Transmission-connected reactive resources generally refers to FACTS (Flexible AC Transmission
System) devices such as Static Var Compensators (SVCs) and Static Synchronous Compensator
(STATCOMs) as well as other power-electronic devices that fall in this category such as HVDC circuits
and synchronous condensers.
Name:
Organization:
Address:

Unofficial Nomination Form
Project 2020-06 Verification of Models and Data for Generators | December 2020

Telephone:
Email:
Please briefly describe your experience and qualifications to serve on the requested SAR Drafting
Team (Bio):

If you are currently a member of any NERC drafting team, please list each team here:
Not currently on any active SAR or standard drafting team.
Currently a member of the following SAR or standard drafting team(s):
If you previously worked on any NERC drafting team please identify the team(s):
No prior NERC SAR or standard drafting team.
Prior experience on the following team(s):
Acknowledgement that the nominee has read and understands both the NERC Participant Conduct
Policy and the Standard Drafting Team Scope documents, available on NERC Standards Resources.
Yes, the nominee has read and understands these documents.
Select each NERC Region in which you have experience relevant to the Project for which you are
volunteering:
MRO
NPCC
RF

SERC
Texas RE
WECC

NA – Not Applicable

Unofficial Nomination Form
Project 2020-06 Verification of Models and Data for Generators | December 2020

8 — Small Electricity End Users
9 — Federal, State, and Provincial Regulatory or other Government Entities
10 — Regional Reliability Organizations and Regional Entities
NA – Not Applicable

Unofficial Nomination Form
Project 2020-06 Verification of Models and Data for Generators | December 2020

Select each Function 1 in which you have current or prior expertise:
Balancing Authority
Compliance Enforcement Authority
Distribution Provider
Generator Operator
Generator Owner
Interchange Authority
Load-serving Entity
Market Operator
Planning Coordinator

Transmission Operator
Transmission Owner
Transmission Planner
Transmission Service Provider
Purchasing-selling Entity
Reliability Coordinator
Reliability Assurer
Resource Planner

Provide the names and contact information for two references who could attest to your technical
qualifications and your ability to work well in a group:
Name:

Telephone:

Organization:

Email:

Name:

Telephone:

Organization:

Email:

Provide the name and contact information of your immediate supervisor or a member of your
management who can confirm your organization’s willingness to support your active participation.

Name:

Telephone:

Title:

Email:

These functions are defined in the NERC Functional Model, which is available on the NERC web site.

Unofficial Nomination Form
Project 2020-06 Verification of Models and Data for Generators | December 2020

Standards Announcement

Project 2020-06 Verifications of Models and Data for Generators
Nomination Period Open through January 14, 2021
Now Available

Nominations are being sought for SAR drafting team members through 8 p.m. Eastern, Thursday,
January 14, 2021.
Use the electronic form to submit a nomination. Contact Linda Jenkins regarding issues using the
electronic form. An unofficial Word version of the nomination form is posted on the Standard
Drafting Team Vacancies page and the project page.
By submitting a nomination form, you are indicating your willingness and agreement to actively
participate in face-to-face meetings and conference calls. The time commitment for this project is
expected to be one face-to-face meetings per quarter (on average two full working days each
meeting) with conference calls scheduled as needed to meet the agreed upon timeline the team sets
forth. Face-to-face meetings will be conducted only when CDC health guidelines permit. Team
members may also have side projects, either individually or by sub-group, to present for discussion
and review. Lastly, an important component of the team effort is outreach. Members of the team
will be expected to conduct industry outreach during the development process to support a
successful ballot.
Previous drafting team experience is beneficial but not required. See the project page and nomination
form for additional information.
Background

The Standards Committee is expected to appoint members to the Project 2020-06 SAR drafting team in
March 2021. Nominees will be notified shortly after they have been appointed.

RELIABILITY | RESILIENCE | SECURITY

Standards Announcement | Project 2020-06 Verifications of Models and Data for Generators
December 16, 2020

SAR Title:

The North American Electric Reliability Corporation
(NERC) welcomes suggestions to improve the
reliability of the bulk power system through
improved Reliability Standards.

Date Submitted:
SAR Requester
Name:
Brad Marszalkowski (chair)
Organization: Project 2020-06 SAR Drafting Team; original SAR submitted by IRPTF (06/10/2020)
Telephone:
413-535-4050
Email:
[email protected]
SAR Type (Check as many as apply)
New Standard
Imminent Action/ Confidential Issue (SPM
Revision to Existing Standard
Section 10)
Add, Modify or Retire a Glossary Term
Variance development or revision
Withdraw/retire an Existing Standard
Other (Please specify)
Justification for this proposed standard development project (Check all that apply to help NERC
prioritize development)
Regulatory Initiation
NERC Standing Committee Identified
Emerging Risk (Reliability Issues Steering
Enhanced Periodic Review Initiated
Committee) Identified
Industry Stakeholder Identified
Reliability Standard Development Plan
Industry Need (What Bulk Electric System (BES) reliability benefit does the proposed project provide?):
The NERC Inverter-based Resource Performance Task Force (IRPTF) undertook an effort to perform a
comprehensive review of all NERC Reliability Standards to determine if there were any potential gaps or
improvements based on the work and findings of the IRPTF. The IRPTF identified several issues as part
of this effort and documented its findings and recommendations in a white paper. The IRPTF Review of
NERC Reliability Standards White Paper was approved by the Operating Committee and the Planning
Committee in March 2020. Among the findings noted in the white paper, the IRPTF identified issues
with MOD-026-1 and MOD-027-1 that should be addressed.
MOD-026-1 and MOD-027-1 require, among other things, GOs to provide verified dynamic models to their
Transmission Planner (TP) for the purposes of power system planning studies. Both standards contain
language that is specific to synchronous generators and is not applicable to inverter-based resources

RELIABILITY | RESILIENCE | SECURITY

Requested information
(IBRs). For example, sub-requirement 2.1.3 in MOD-026-1 states that each verification shall include
“model structure and data including, but not limited to reactance, time constants, saturation factors, total
rotational inertia…” The standards should be revised to clarify the applicable requirements for
synchronous generators and IBRs. For example, total rotational inertia should not be required for IBRs,
while voltage ride-through control settings should only be required of IBRs and not synchronous
generators.
Additionally, to some degree, all dynamic model parameters affect the response of a represented
resource in dynamic simulations performed by power engineers. Accurate model response is required for
the engineers to adequately study system conditions. Hence, it is crucial that all parameters in a model
be verified in some way. However, a significant number of parameters in the models are not verified in
the typical verification tests used to comply with MOD-026-1 and MOD-027-1.
Purpose or Goal (How does this proposed project provide the reliability-related benefit described
above?):
This SAR proposes to revise MOD-026-1 and MOD-027-1 and/or create a new standard to clarify
requirements related to IBRs and to require sufficient model verification to ensure accurate generator
representation in dynamic simulations.
Project Scope (Define the parameters of the proposed project):
a. Revise or develop requirements that provide Generator Owners (GO) needed direction to provide
verified generating unit and/or generating plant resource models that can be used that reflect
resource performance regardless of the resource type.
b. Revise or develop requirements that provide Transmission Planners (TP) latitude and flexibility to
specify the usability criteria of models submitted by the GO.
Detailed Description (Describe the proposed deliverable(s) with sufficient detail for a drafting team to
execute the project. If you propose a new or substantially revised Reliability Standard or definition,
provide: (1) a technical justification 1 which includes a discussion of the reliability-related benefits of
developing a new or revised Reliability Standard or definition, and (2) a technical foundation document
(e.g., research paper) to guide development of the Standard or definition):
The SDT will address the following deliverables:
1) Review, and if necessary, update MOD-026/027 to be inclusive of IBRs with focus on the following:
a) Applicability section(s)
b) Similar to R2.1, identify what the Responsible Entity (GO) should provide for verifications plantlevel and inverter-level model parameters, to include but not limited to documentation,
equipment information, model structure and data, and compensation settings
c) Other sections of MOD-026/027 pertinent to verification of models including periodicity
2) Review, and if necessary, update MOD-026/027 to clarify language for model verification of all
resources types, including synchronous, IBRs, or any combination thereof.
3) Review, and if necessary, update requirement language to improve accuracy and usability of models.
4) In the alternative, develop a new MOD reliability standard that addresses the above.
The NERC Rules of Procedure require a technical justification for new or substantially revised Reliability Standards. Please attach pertinent
information to this form before submittal to NERC.
1

Standard Authorization Request (SAR)

Requested information
NERC MOD-026-1 focuses on verification of data for generator excitation control system or plant volt/var
control functions, and MOD-027-1 focuses on verification of data for turbine-governor and load control
or active power-frequency control functions. Specifically, MOD-026-1 states in footnote 1 that the
excitation control system for aggregate generating plants (i.e., wind and solar PV) includes the volt/var
control system including the voltage regulator and reactive power control system controlling and
coordinating plant voltage and associated reactive capable resources. This language is slightly ambiguous
on whether the verification activities include the inverter-level parameter values of the dynamic models.
Various testing engineers and entities have stated that they are uncertain as to whether the standard
applies to the plant-level parameters or the aggregate representation of the inverter-level settings.
Most commonly, verification test reports for inverter-based resources involve a small set of small
disturbance tests including, but not limited to, the following:
•

Capacitor switching test

•

Plant-level voltage or reactive power reference step test

•

Plant-level frequency reference step test

•

Plant-level frequency play-in or step test

Standard Authorization Request (SAR)

Requested information
than for synchronous generators which have behavior that is based more on the physical characteristics
of the machine. Additionally, the IRPTF noted that it is not feasible to stage large disturbances for
verification purposes, so other methods for verification of model performance under large disturbance
conditions may need to be developed.
To assist the NERC Standards Committee in appointing a drafting team with the appropriate members,
please indicate to which Functional Entities the proposed standard(s) should apply (e.g., Transmission
Operator, Reliability Coordinator, etc. See the most recent version of the NERC Functional Model for
definitions):
Transmission Planner, Generator Owner, Planning Coordinator
Do you know of any consensus building activities 2 in connection with this SAR? If so, please provide any
recommendations or findings resulting from the consensus building activity.
This issue was captured in the IRPTF Review of NERC Reliability Standards White Paper which was
approved by the Operating Committee and the Planning Committee. Additionally, the issue was
discussed in the IRPTF-produced “Improvements to Interconnection Requirements for BPS-Connected
Inverter-Based Resources” reliability guideline.
Are there any related standards or SARs that should be assessed for impact as a result of this proposed
project? If so, which standard(s) or project number(s)?
Yes, Project 2020-02 Transmission-connected Dynamic Reactive Resources may have overlapping scope.
Are there alternatives (e.g., guidelines, white paper, alerts, etc.) that have been considered or could
meet the objectives? If so, please list the alternatives.
The IRPTF did not identify any alternatives since there are gaps in the existing language for MOD-026-1
and MOD-027-1 that need to be resolved.
Reliability Principles
Does this proposed standard development project support at least one of the following Reliability
Principles (Reliability Interface Principles)? Please check all those that apply.
1. Interconnected bulk power systems shall be planned and operated in a coordinated manner
to perform reliably under normal and abnormal conditions as defined in the NERC Standards.
2. The frequency and voltage of interconnected bulk power systems shall be controlled within
defined limits through the balancing of real and reactive power supply and demand.
3. Information necessary for the planning and operation of interconnected bulk power systems
shall be made available to those entities responsible for planning and operating the systems
reliably.
4. Plans for emergency operation and system restoration of interconnected bulk power systems
shall be developed, coordinated, maintained and implemented.
5. Facilities for communication, monitoring and control shall be provided, used and maintained
for the reliability of interconnected bulk power systems.
6. Personnel responsible for planning and operating interconnected bulk power systems shall be
trained, qualified, and have the responsibility and authority to implement actions.
Consensus building activities are occasionally conducted by NERC and/or project review teams. They typically are conducted to obtain
industry inputs prior to proposing any standard development project to revise, or develop a standard or definition.

Standard Authorization Request (SAR)

Reliability Principles
7. The security of the interconnected bulk power systems shall be assessed, monitored and
maintained on a wide area basis.
8. Bulk power systems shall be protected from malicious physical or cyber attacks.
Market Interface Principles
Does the proposed standard development project comply with all of the following
Market Interface Principles?
1. A reliability standard shall not give any market participant an unfair competitive
advantage.
2. A reliability standard shall neither mandate nor prohibit any specific market
structure.
3. A reliability standard shall not preclude market solutions to achieving compliance
with that standard.
4. A reliability standard shall not require the public disclosure of commercially
sensitive information. All market participants shall have equal opportunity to
access commercially non-sensitive information that is required for compliance
with reliability standards.

Enter
(yes/no)
Yes
Yes
Yes
Yes

Identified Existing or Potential Regional or Interconnection Variances
Region(s)/
Explanation
Interconnection
None
N/A

For Use by NERC Only
SAR Status Tracking (Check off as appropriate).
Draft SAR reviewed by NERC Staff
Draft SAR presented to SC for acceptance
DRAFT SAR approved for posting by the SC

Final SAR endorsed by the SC
SAR assigned a Standards Project by NERC
SAR denied or proposed as Guidance document

Version History
Version

Date

Owner

Change Tracking

June 3, 2013

August 29, 2014

Standards Information Staff

Updated template

January 18, 2017

Standards Information Staff

Revised

Standard Authorization Request (SAR)

Revised

June 28, 2017

Standards Information Staff

Updated template

February 22, 2019

Standards Information Staff

Added instructions to submit via Help
Desk

February 25, 2020

Standards Information Staff

Updated template footer

Standard Authorization Request (SAR)

SAR Title:

The North American Electric Reliability Corporation
(NERC) welcomes suggestions to improve the
reliability of the bulk power system through
improved Reliability Standards.

RELIABILITY | RESILIENCE | SECURITY

Requested information
(IBRs). For example, sub-requirement 2.1.3 in MOD-026-1 states that each verification shall include
“model structure and data including, but not limited to reactance, time constants, saturation factors, total
rotational inertia…” The standards should be revised to clarify the applicable requirements for
synchronous generators and IBRs. For example, total rotational inertia should not be required for IBRs,
while voltage ride-through control settings should only be required of IBRs and not synchronous
generators.
Additionally, to some degree, all dynamic model parameters affect the response of a represented
resource in dynamic simulations performed by power engineers. Accurate model response is required for
the engineers to adequately study system conditions. Hence, it is crucial that all parameters in a model
be verified in some way. However, a significant number of parameters in the models are not verified in
the typical verification tests used to comply with MOD-026-1 and MOD-027-1. For example, the test
currently used to comply with MOD-026-1 does not verify the model parameters associated with voltage
control behavior during large disturbance conditions.
Purpose or Goal (How does this proposed project provide the reliability-related benefit described
above?):
This SAR proposes to revise MOD-026-1 and MOD-027-1 and/or create a new standard to clarify
requirements related to IBRs and to require sufficient model verification to ensure accurate generator
representation in dynamic simulations.
Project Scope (Define the parameters of the proposed project):
The proposed scope of this project is as follows:
a. Update requirement language to better reflect all types of generation resources and not just
synchronous resources.
b. Consider ways to require sufficient model verification to ensure accurate generator representation
in dynamic simulations of typical phenomena that would be studied by power system engineers,
including large disturbances.
a. Revise or develop requirements that provide Generator Owners (GO) needed direction to provide
verified generating unit and/or generating plant resource models that can be used that reflect
resource performance regardless of the resource type.
b. Revise or develop requirements that provide Transmission Planners (TP) latitude and flexibility to
specify the usability criteria of models submitted by the GO.
Detailed Description (Describe the proposed deliverable(s) with sufficient detail for a drafting team to
execute the project. If you propose a new or substantially revised Reliability Standard or definition,
provide: (1) a technical justification 1 which includes a discussion of the reliability-related benefits of
developing a new or revised Reliability Standard or definition, and (2) a technical foundation document
(e.g., research paper) to guide development of the Standard or definition):
The SDT will address the following deliverables:
1) Review, and if necessary, update MOD-026/027 to be inclusive of IBRs with focus on the following:
a) Applicability section(s)
The NERC Rules of Procedure require a technical justification for new or substantially revised Reliability Standards. Please attach pertinent
information to this form before submittal to NERC.
1

Standard Authorization Request (SAR)

Requested information
b) Similar to R2.1, identify what the Responsible Entity (GO) should provide for verifications plantlevel and inverter-level model parameters, to include but not limited to documentation,
equipment information, model structure and data, and compensation settings
c) Other sections of MOD-026/027 pertinent to verification of models including periodicity
2) Review, and if necessary, update MOD-026/027 to clarify language for model verification of all
resources types, including synchronous, IBRs, or any combination thereof.
3) Review, and if necessary, update requirement language to improve accuracy and usability of models.
4) In the alternative, develop a new MOD reliability standard that addresses the above.
NERC MOD-026-1 focuses on verification of data for generator excitation control system or plant volt/var
control functions, and MOD-027-1 focuses on verification of data for turbine-governor and load control
or active power-frequency control functions. Specifically, MOD-026-1 states in footnote 1 that the
excitation control system for aggregate generating plants (i.e., wind and solar PV) includes the volt/var
control system including the voltage regulator and reactive power control system controlling and
coordinating plant voltage and associated reactive capable resources. This language is slightly ambiguous
on whether the verification activities include the inverter-level parameter values of the dynamic models.
Various testing engineers and entities have stated that they are uncertain as to whether the standard
applies to the plant-level parameters or the aggregate representation of the inverter-level settings.
Most commonly, verification test reports for inverter-based resources involve a small set of small
disturbance tests including, but not limited to, the following:
•

Capacitor switching test

•

Plant-level voltage or reactive power reference step test

•

Plant-level frequency reference step test

•

Plant-level frequency play-in or step test

Standard Authorization Request (SAR)

Requested information
Cost Impact Assessment, if known (Provide a paragraph describing the potential cost impacts associated
with the proposed project):
The SAR proposes to clarify and address gaps in the requirements in MOD-026-1 and MOD-027-1. The
cost impact is unknown.
Please describe any unique characteristics of the BES facilities that may be impacted by this proposed
standard development project (e.g., Dispersed Generation Resources):
The abovementioned reliability gap exists for both synchronous generators and IBRs. However, it is
potentially more severe for IBRs since their behavior is based more on programmable control functions
than for synchronous generators which have behavior that is based more on the physical characteristics
of the machine. Additionally, the IRPTF noted that it is not feasible to stage large disturbances for
verification purposes, so other methods for verification of model performance under large disturbance
conditions may need to be developed.
To assist the NERC Standards Committee in appointing a drafting team with the appropriate members,
please indicate to which Functional Entities the proposed standard(s) should apply (e.g., Transmission
Operator, Reliability Coordinator, etc. See the most recent version of the NERC Functional Model for
definitions):
Transmission Planner, Generator Owner, Planning Coordinator
Do you know of any consensus building activities 2 in connection with this SAR? If so, please provide any
recommendations or findings resulting from the consensus building activity.
This issue was captured in the IRPTF Review of NERC Reliability Standards White Paper which was
approved by the Operating Committee and the Planning Committee. Additionally, the issue was
discussed in the IRPTF-produced “Improvements to Interconnection Requirements for BPS-Connected
Inverter-Based Resources” reliability guideline.
Are there any related standards or SARs that should be assessed for impact as a result of this proposed
project? If so, which standard(s) or project number(s)?
Yes, Project 2020-02 Transmission-connected Dynamic Reactive Resources may have overlapping scope.
Are there alternatives (e.g., guidelines, white paper, alerts, etc.) that have been considered or could
meet the objectives? If so, please list the alternatives.
The IRPTF did not identify any alternatives since there are gaps in the existing language for MOD-026-1
and MOD-027-1 that need to be resolved.
Reliability Principles
Does this proposed standard development project support at least one of the following Reliability
Principles (Reliability Interface Principles)? Please check all those that apply.
1. Interconnected bulk power systems shall be planned and operated in a coordinated manner
to perform reliably under normal and abnormal conditions as defined in the NERC Standards.
2. The frequency and voltage of interconnected bulk power systems shall be controlled within
defined limits through the balancing of real and reactive power supply and demand.

Standard Authorization Request (SAR)

3.
4.
5.
6.
7.
8.

Reliability Principles
Information necessary for the planning and operation of interconnected bulk power systems
shall be made available to those entities responsible for planning and operating the systems
reliably.
Plans for emergency operation and system restoration of interconnected bulk power systems
shall be developed, coordinated, maintained and implemented.
Facilities for communication, monitoring and control shall be provided, used and maintained
for the reliability of interconnected bulk power systems.
Personnel responsible for planning and operating interconnected bulk power systems shall be
trained, qualified, and have the responsibility and authority to implement actions.
The security of the interconnected bulk power systems shall be assessed, monitored and
maintained on a wide area basis.
Bulk power systems shall be protected from malicious physical or cyber attacks.

Enter
(yes/no)
Yes
Yes
Yes
Yes

Identified Existing or Potential Regional or Interconnection Variances
Region(s)/
Explanation
Interconnection
None
N/A

For Use by NERC Only
SAR Status Tracking (Check off as appropriate).
Draft SAR reviewed by NERC Staff
Draft SAR presented to SC for acceptance
DRAFT SAR approved for posting by the SC

Standard Authorization Request (SAR)

Final SAR endorsed by the SC
SAR assigned a Standards Project by NERC
SAR denied or proposed as Guidance document

Version History
Version

Date

Owner

Change Tracking

June 3, 2013

August 29, 2014

Standards Information Staff

Updated template

January 18, 2017

Standards Information Staff

Revised

June 28, 2017

Standards Information Staff

Updated template

February 22, 2019

Standards Information Staff

Added instructions to submit via Help
Desk

February 25, 2020

Standards Information Staff

Updated template footer

Standard Authorization Request (SAR)

Revised

Standard Authorization Request (SAR)
Complete and please email this form, with
Complete
and please
email this form, with
attachment(s)
to: [email protected]
attachment(s) to: [email protected]

SAR Title:

The North American Electric Reliability Corporation (NERC)
welcomes suggestions to improve the reliability of the bulk
power system through improved Reliability Standards.

Requested information
Applicability revisions for transmission connected dynamic reactive
resources
May 21, 2021

Date Submitted:
SAR Requester
Name:
Brad Marszalkowski (chair)
Organization: Project 2020-06 SAR Drafting Team; original submitted by Hari Singh (SAMS)
Telephone:
413-535-4050
Email:
[email protected]
SAR Type (Check as many as apply)
New Standard
Imminent Action/ Confidential Issue (SPM
Revision to Existing Standard
Section 10)
Add, Modify or Retire a Glossary Term
Variance development or revision
Withdraw/retire an Existing Standard
Other (Please specify)
Justification for this proposed standard development project (Check all that apply to help NERC
prioritize development)
Regulatory Initiation
NERC Standing Committee Identified
Emerging Risk (Reliability Issues Steering
Enhanced Periodic Review Initiated
Committee) Identified
Industry Stakeholder Identified
Reliability Standard Development Plan
Industry Need (What Bulk Electric System (BES) reliability benefit does the proposed project provide?):
Dynamic reactive resources used to provide Essential Reliability Services (ERS) in the BES include
generation resources (rotating machine and inverter-based) as well as transmission connected dynamic
reactive resources (power-electronics based). Existing reliability standards for verifying the capability,
modeling and performance of dynamic reactive resources are only applicable to Facilities comprising
generation resources. Augmenting the applicability of these standards to include (non-generation)
transmission-connected reactive resources – both rotating machine (i.e. synchronous condenser) and
power-electronics based – will enhance the BES reliability by ensuring that the capability, models and
performance is verified and validated for all varieties of dynamic reactive resources utilized in providing
ERS in the BES.
Purpose or Goal (How does this proposed project provide the reliability-related benefit described
above?):
Augment the “Applicability – Facilities” and “Applicability-Functional Entities” sections in MOD-026 and
MOD-027 reliability standards to address (non-generation) transmission-connected dynamic reactive

Requested information
resources – both rotating machine (i.e. synchronous condenser) and power-electronics based. Also
modify Requirements (including applicable attachments) as needed to ensure they continue to address
the additional Facilities. As needed, also define new Glossary Terms for all or some of the transmissionconnected dynamic reactive devices noted in the SAMS white-paper “Transmission Connected Dynamic
Reactive Resources – Assessment of Applicability in Reliability Standards”.
Project Scope (Define the parameters of the proposed project):
Revise the “Applicability – Facilities” section, “Applicability – Functional Entities” section, and
Requirements (including applicable attachments) as needed in MOD-026 and MOD-027 reliability
standards to comprehensively address all varieties of transmission-connected dynamic reactive
resources that are utilized in providing ERS in the BES.
Detailed Description (Describe the proposed deliverable(s) with sufficient detail for a drafting team to
execute the project. If you propose a new or substantially revised Reliability Standard or definition,
provide: (1) a technical justification 1which includes a discussion of the reliability-related benefits of
developing a new or revised Reliability Standard or definition, and (2) a technical foundation document
(e.g. research paper) to guide development of the Standard or definition):
The “Applicability – Facilities” and “Applicability-Functional Entities” sections in MOD-026 and MOD-027
reliability standards will be revised to address (non-generation) transmission-connected dynamic
reactive resources (TCDRR) based on the recommendations summarized in Table 1 of the SAMS whitepaper “Transmission Connected Dynamic Reactive Resources – Assessment of Applicability in Reliability
Standards”. The white-paper also provides the technical justifications for the recommended revisions
and the associated reliability benefits.
The SDT will address the following deliverables:
1. Review, and if necessary, update MOD-026/027 to be inclusive of TCDRR with focus on the
following:
a. Applicability section(s)
b. Similar to R2.1, identify what the Responsible Entity (TO) should provide for verifications
to include but not limited to documentation, equipment information, model structure and
data, and compensation settings
c. Other sections of MOD-026/027 pertinent to verification of models including periodicity
2. Review, and if necessary, update MOD-026/027 to clarify language for model verification of TCDRR
3. As needed, also define new Glossary Terms for TCDRR or related terms
4. In the alternative, develop a new MOD reliability standard that addresses the above.
Cost Impact Assessment, if known (Provide a paragraph describing the potential cost impacts associated
with the proposed project):
Please describe any unique characteristics of the BES facilities that may be impacted by this proposed
standard development project (e.g. Dispersed Generation Resources):
The NERC Rules of Procedure require a technical justification for new or substantially revised Reliability Standards. Please attach pertinent
information to this form before submittal to NERC.
1

Standard Authorization Request (SAR)

Requested information
Power-electronics based transmission-connected reactive resources – also known as FACTS (Flexible AC
Transmission System) devices – such as: Static Var Compensator (SVC), Static Synchronous Compensator
(STATCOM), HVDC Links (LCC or VSC).
To assist the NERC Standards Committee in appointing a drafting team with the appropriate members,
please indicate to which Functional Entities the proposed standard(s) should apply (e.g. Transmission
Operator, Reliability Coordinator, etc. See the most recent version of the NERC Functional Model for
definitions):
Transmission Owners in addition to the existing Functional Entities
Do you know of any consensus building activities 2 in connection with this SAR? If so, please provide any
recommendations or findings resulting from the consensus building activity.
“Transmission Connected Dynamic Reactive Resources – Assessment of Applicability in Reliability
Standards” white-paper approved by SAMS members.
Are there any related standards or SARs that should be assessed for impact as a result of this proposed
project? If so which standard(s) or project number(s)?
PRC-019 SAR requested by SPCS and PRC-024 SAR requested by IRPTF
Are there alternatives (e.g. guidelines, white paper, alerts, etc.) that have been considered or could
meet the objectives? If so, please list the alternatives.
No viable alternatives were found by SAMS.
Reliability Principles
Does this proposed standard development project support at least one of the following Reliability
Principles (Reliability Interface Principles)? Please check all those that apply.
1. Interconnected bulk power systems shall be planned and operated in a coordinated manner
to perform reliably under normal and abnormal conditions as defined in the NERC Standards.
2. The frequency and voltage of interconnected bulk power systems shall be controlled within
defined limits through the balancing of real and reactive power supply and demand.
3. Information necessary for the planning and operation of interconnected bulk power systems
shall be made available to those entities responsible for planning and operating the systems
reliably.
4. Plans for emergency operation and system restoration of interconnected bulk power systems
shall be developed, coordinated, maintained and implemented.
5. Facilities for communication, monitoring and control shall be provided, used and maintained
for the reliability of interconnected bulk power systems.
6. Personnel responsible for planning and operating interconnected bulk power systems shall be
trained, qualified, and have the responsibility and authority to implement actions.
7. The security of the interconnected bulk power systems shall be assessed, monitored and
maintained on a wide area basis.
8. Bulk power systems shall be protected from malicious physical or cyber attacks.
Consensus building activities are occasionally conducted by NERC and/or project review teams. They typically are conducted to obtain
industry inputs prior to proposing any standard development project to revise, or develop a standard or definition.

Standard Authorization Request (SAR)

Enter
(yes/no)
Yes
Yes
Yes
Yes

Identified Existing or Potential Regional or Interconnection Variances
Region(s)/
Explanation
Interconnection
e.g. NPCC

For Use by NERC Only
SAR Status Tracking (Check off as appropriate)
Draft SAR reviewed by NERC Staff
Draft SAR presented to SC for acceptance
DRAFT SAR approved for posting by the SC

Final SAR endorsed by the SC
SAR assigned a Standards Project by NERC
SAR denied or proposed as Guidance
document

Version History
Version

Date

Owner

Change Tracking

June 3, 2013

August 29, 2014

Standards Information Staff

Updated template

January 18, 2017

Standards Information Staff

Revised

June 28, 2017

Standards Information Staff

Updated template

Standard Authorization Request (SAR)

Revised

Standard Authorization Request (SAR)
Complete and please email this form, with
Complete
and please
email this form, with
attachment(s)
to: [email protected]
attachment(s) to: [email protected]

SAR Title:

The North American Electric Reliability Corporation (NERC)
welcomes suggestions to improve the reliability of the bulk
power system through improved Reliability Standards.

Requested information
Applicability revisions for transmission connected dynamic reactive
resources
May 21, 2021

Date Submitted:
SAR Requester
Name:
Brad Marszalkowski (chair)
Organization: Project 2020-06 SAR Drafting Team; original submitted by Hari Singh (SAMS)
Telephone:
413-535-4050
Email:
[email protected]
SAR Type (Check as many as apply)
New Standard
Imminent Action/ Confidential Issue (SPM
Revision to Existing Standard
Section 10)
Add, Modify or Retire a Glossary Term
Variance development or revision
Withdraw/retire an Existing Standard
Other (Please specify)
Justification for this proposed standard development project (Check all that apply to help NERC
prioritize development)
Regulatory Initiation
NERC Standing Committee Identified
Emerging Risk (Reliability Issues Steering
Enhanced Periodic Review Initiated
Committee) Identified
Industry Stakeholder Identified
Reliability Standard Development Plan
Industry Need (What Bulk Electric System (BES) reliability benefit does the proposed project provide?):
Dynamic reactive resources used to provide Essential Reliability Services (ERS) in the BES include
generation resources (rotating machine and inverter-based) as well as transmission connected dynamic
reactive resources (power-electronics based). Existing reliability standards for verifying the capability,
modeling and performance of dynamic reactive resources are only applicable to Facilities comprising
generation resources. Augmenting the applicability of these standards to include (non-generation)
transmission-connected reactive resources – both rotating machine (i.e. synchronous condenser) and
power-electronics based – will enhance the BES reliability by ensuring that the capability, models and
performance is verified and validated for all varieties of dynamic reactive resources utilized in providing
ERS in the BES.
Purpose or Goal (How does this proposed project provide the reliability-related benefit described
above?):
Augment the “Applicability – Facilities” and “Applicability-Functional Entities” sections in MOD-025,
MOD-026, MOD-027, PRC-019 and PRC-024 reliability standards to address (non-generation)

Requested information
transmission-connected dynamic reactive resources – both rotating machine (i.e. synchronous
condenser) and power-electronics based. Also modify Requirements (including applicable attachments)
as needed to ensure they continue to address the additional Facilities. As needed, also define new
Glossary Terms for all or some of the transmission-connected dynamic reactive devices noted in the
SAMS white-paper “Transmission Connected Dynamic Reactive Resources – Assessment of Applicability
in Reliability Standards”.
Project Scope (Define the parameters of the proposed project):
Revise the “Applicability – Facilities” section, “Applicability – Functional Entities” section, and
Requirements (including applicable attachments) as needed in MOD-025, MOD-026, MOD-027, PRC-019
and PRC-024 reliability standards to comprehensively address all varieties of transmission-connected
dynamic reactive resources that are utilized in providing ERS in the BES.
Detailed Description (Describe the proposed deliverable(s) with sufficient detail for a drafting team to
execute the project. If you propose a new or substantially revised Reliability Standard or definition,
provide: (1) a technical justification 1which includes a discussion of the reliability-related benefits of
developing a new or revised Reliability Standard or definition, and (2) a technical foundation document
(e.g. research paper) to guide development of the Standard or definition):
The “Applicability – Facilities” and “Applicability-Functional Entities” sections in MOD-025, MOD-026,
MOD-027, PRC-019 and PRC-024 reliability standards will be revised to address (non-generation)
transmission-connected dynamic reactive resources (TCDRR) based on the recommendations
summarized in Table 1 of the SAMS white-paper “Transmission Connected Dynamic Reactive Resources
– Assessment of Applicability in Reliability Standards”. The white-paper also provides the technical
justifications for the recommended revisions and the associated reliability benefits.
The SDT will address the following deliverables:
1. Review, and if necessary, update MOD-026/027 to be inclusive of TCDRR with focus on the
following:
a. Applicability section(s)
b. Similar to R2.1, identify what the Responsible Entity (TO) should provide for verifications
to include but not limited to documentation, equipment information, model structure and
data, and compensation settings
c. Other sections of MOD-026/027 pertinent to verification of models including periodicity
2. Review, and if necessary, update MOD-026/027 to clarify language for model verification of TCDRR
3. As needed, also define new Glossary Terms for all or some of the TCDRR or related terms. noted
as items 1.a – 1.j in the Additional Considerations section of the SAMS white-paper.
4. In the alternative, develop a new MOD reliability standard that addresses the above.
Cost Impact Assessment, if known (Provide a paragraph describing the potential cost impacts associated
with the proposed project):

The NERC Rules of Procedure require a technical justification for new or substantially revised Reliability Standards. Please attach pertinent
information to this form before submittal to NERC.
1

Standard Authorization Request (SAR)

Requested information
Please describe any unique characteristics of the BES facilities that may be impacted by this proposed
standard development project (e.g. Dispersed Generation Resources):
Power-electronics based transmission-connected reactive resources – also known as FACTS (Flexible AC
Transmission System) devices – such as: Static Var Compensator (SVC), Static Synchronous Compensator
(STATCOM), HVDC Links (LCC or VSC).
To assist the NERC Standards Committee in appointing a drafting team with the appropriate members,
please indicate to which Functional Entities the proposed standard(s) should apply (e.g. Transmission
Operator, Reliability Coordinator, etc. See the most recent version of the NERC Functional Model for
definitions):
Transmission Owners in addition to the existing Functional Entities
Do you know of any consensus building activities 2 in connection with this SAR? If so, please provide any
recommendations or findings resulting from the consensus building activity.
“Transmission Connected Dynamic Reactive Resources – Assessment of Applicability in Reliability
Standards” white-paper approved by SAMS members.
Are there any related standards or SARs that should be assessed for impact as a result of this proposed
project? If so which standard(s) or project number(s)?
PRC-019 SAR requested by SPCS and PRC-024 SAR requested by IRPTF
Are there alternatives (e.g. guidelines, white paper, alerts, etc.) that have been considered or could
meet the objectives? If so, please list the alternatives.
No viable alternatives were found by SAMS.
Reliability Principles
Does this proposed standard development project support at least one of the following Reliability
Principles (Reliability Interface Principles)? Please check all those that apply.
1. Interconnected bulk power systems shall be planned and operated in a coordinated manner
to perform reliably under normal and abnormal conditions as defined in the NERC Standards.
2. The frequency and voltage of interconnected bulk power systems shall be controlled within
defined limits through the balancing of real and reactive power supply and demand.
3. Information necessary for the planning and operation of interconnected bulk power systems
shall be made available to those entities responsible for planning and operating the systems
reliably.
4. Plans for emergency operation and system restoration of interconnected bulk power systems
shall be developed, coordinated, maintained and implemented.
5. Facilities for communication, monitoring and control shall be provided, used and maintained
for the reliability of interconnected bulk power systems.
6. Personnel responsible for planning and operating interconnected bulk power systems shall be
trained, qualified, and have the responsibility and authority to implement actions.
7. The security of the interconnected bulk power systems shall be assessed, monitored and
maintained on a wide area basis.
Consensus building activities are occasionally conducted by NERC and/or project review teams. They typically are conducted to obtain
industry inputs prior to proposing any standard development project to revise, or develop a standard or definition.

Standard Authorization Request (SAR)

Reliability Principles
8. Bulk power systems shall be protected from malicious physical or cyber attacks.
Market Interface Principles
Does the proposed standard development project comply with all of the following
Market Interface Principles?
1. A reliability standard shall not give any market participant an unfair competitive
advantage.
2. A reliability standard shall neither mandate nor prohibit any specific market
structure.
3. A reliability standard shall not preclude market solutions to achieving compliance
with that standard.
4. A reliability standard shall not require the public disclosure of commercially
sensitive information. All market participants shall have equal opportunity to
access commercially non-sensitive information that is required for compliance
with reliability standards.

Enter
(yes/no)
Yes
Yes
Yes
Yes

Identified Existing or Potential Regional or Interconnection Variances
Region(s)/
Explanation
Interconnection
e.g. NPCC

For Use by NERC Only
SAR Status Tracking (Check off as appropriate)
Draft SAR reviewed by NERC Staff
Draft SAR presented to SC for acceptance
DRAFT SAR approved for posting by the SC

Final SAR endorsed by the SC
SAR assigned a Standards Project by NERC
SAR denied or proposed as Guidance
document

Version History
Version

Date

Owner

Change Tracking

June 3, 2013

August 29, 2014

Standards Information Staff

Updated template

January 18, 2017

Standards Information Staff

Revised

June 28, 2017

Standards Information Staff

Updated template

Standard Authorization Request (SAR)

Revised

MOD-026-2 – Verification of Dynamic Models and Data for BES Connected Facilities

New or Modified Term(s) Used in NERC Reliability Standards
Background:

This section includes all new or modified terms used in the proposed standard that will be
included in the Glossary of Terms Used in NERC Reliability Standards upon applicable regulatory
approval. The terms proposed below are intended to be used in MOD-026-2 and other inverterbased resource related standards.
Term(s):

Power Electronic Device (PED): Any device connected to the ac power system through a power
electronic interface that generates or transmits active power or reactive power, or absorbs
active power for the purposes of re-injecting it at a later time. This term excludes any load.
Inverter-Based Resource (IBR): Any source of electric power consisting of one or more Power
Electronic Devices (PEDs), that operates as a single resource, supplies primarily active power,
and connects to the Bulk Power System. An IBR plant/facility includes the Power Electronic
Devices, and the equipment designed primarily for delivering the power to a common point of
connection (e.g. step-up transformers, collector system(s), main power transformer(s), and
power plant controller(s)).
Technical Rationale and Considerations:
•

A Power Electronic Device is inclusive of multiple technologies that use a power electronic
interface, and is not limited to generators. Power Electronic Device examples include type 3
wind generators, type 4 wind generators, solar photovoltaic inverters, battery energy
storage inverters, variable-speed pumped hydro inverter, high-voltage direct current
(HVDC) converters, static synchronous compensators (STATCOM), static VAR compensators
(SVC), and other inverter/converter connected FACTS devices, as these technologies are
also connected to the grid via a power electronic interface.

•

Inverter-Based Resource examples include type 3 wind, type 4 wind, solar photovoltaic,
battery energy storage, and variable-speed pumped hydro. There is a desire by the SDT to
maintain a precedent that IBRs are considered “generating resources”, so the IBR term
includes the phrase “primarily supplies active power”. Therefore, an HVDC system or a
transmission-connected FACTS device (STATCOM, SVC, etc.) would not be considered an
IBR.

•

NERC Glossary terms apply to use in NERC Reliability Standards. NERC has a different focus
than IEEE. "Power Electronic Device" was chosen as an alternative to the IEEE term "IBR
unit" to differentiate the two terms.

•

There is a need to distinguish between the individual “device” and the “resource/facility” as
a whole, in order to allow the requirement language to be applied at device level or facility
level. Hence, the two definitions for PED and IBR. The phrase “IBR plant/facility" refers to a
facility in the common meaning.

•

Battery energy storage system (BESS) will be considered as a PED/IBR independent of
whether or not the device is operating in the charging or discharging mode.

Draft 4 of MOD-026-2
September 2023

Page 1 of 1

Unofficial Comment Form

Project 2020-06 Verification of Models and Data for Generators
Do not use this form for submitting comments. Use the Standards Balloting and Commenting System
(SBS) to submit comments on MOD-026-2 – inverter-based resource related Glossary Terms by 8 p.m.
Eastern, Tuesday, October 24, 2023.
m. Eastern, Thursday, August 20, 2015

Additional information is available on the project page. If you have questions, contact Senior Standards
Developer, Chris Larson (via email), or at 404-446-9708.
Background

The NERC Inverter-based Resource (IBR) Performance Task Force (IRPTF) performed a comprehensive
review of all NERC Reliability Standards to identify any potential gaps and/or improvements. The IRPTF
discovered several issues as part of this effort and documented its findings and recommendations in the
IRPTF Review of NERC Reliability Standards White Paper, which was approved in March 2020 by the
Operating Committee and the Planning Committee (now part of the Reliability and Security Technical
Committee (RSTC)). Among the findings noted in the white paper, the IRPTF identified issues with MOD026-1 and MOD-027-1 that should be addressed. The RSTC endorsed the standard authorization request
(SAR) June 10, 2020.
The Standards Committee accepted two revised SARs at its July 21, 2021 meeting. The scope of the Project
2020-06 SARs includes the potential to add, modify, or retire a Glossary Terms for NERC Reliability
Standards. The Project 2020-06 standard drafting team proposes two new terms as part of this informal
comment period.
Please provide your responses to the questions listed below, along with any detailed comments.
Questions

1. Do you support the definition for Power Electronic Device (PED) as proposed, or with nonsubstantive changes? If you do not support the definition as proposed, please explain the changes
that, if made, would result in your support.
Yes
No
Comments:
2. Do you support the definition for Inverter-Based Resource (IBR) as proposed, or with nonsubstantive changes? If you do not support the definition as proposed, please explain the changes
that, if made, would result in your support.
Yes
No
Comments:
3. Provide any additional comments for the SDT to consider, if desired.
Comments:

RELIABILITY | RESILIENCE | SECURITY

Standards Announcement

Project 2020-06 Verifications of Models and Data for Generators
Additional Information
Informal Comment Period Open through October 24, 2023
Now Available

Project 2020-06 Verifications of Models and Data for Generators is developing new definitions for IBR
that will be leveraged by other IBR-related drafting teams. An informal comment period for these
inverter-based resource Glossary Terms is open through 8 p.m. Eastern, Tuesday, October 24, 2023.
Commenting

Use the Standards Balloting and Commenting System (SBS) to submit comments. An unofficial Word
version of the comment form is posted on the project page.
•

•

Passwords expire every 6 months and must be reset.

•

The SBS is not supported for use on mobile devices.

•

Please be mindful of ballot and comment period closing dates. We ask to allow at least 48 hours
for NERC support staff to assist with inquiries. Therefore, it is recommended that users try logging
into their SBS accounts prior to the last day of a comment/ballot period.

Next Steps

The Project 2020-06 drafting team will review all responses received during the comment period. Other
IBR-related drafting teams will be provided additional information and modifications to the definitions, if
any.
For more information on the Reliability Standards development process, refer to the Standard Processes
Manual.
For more information or assistance, contact Senior Standards Developer, Chris Larson (via email) or at 404446-9708. Subscribe to this project's observer mailing list by selecting "NERC Email Distribution Lists" from
the "Service" drop-down menu and specify “Project 2020-06 Verifications of Models and Data for
Generators Observer List” in the Description Box.
North American Electric Reliability Corporation
3353 Peachtree Rd, NE
Suite 600, North Tower
Atlanta, GA 30326
404-446-2560 | www.nerc.com

RELIABILITY | RESILIENCE | SECURITY

Comment Report
Project Name:

2020-06 Verifications of Models and Data for Generators | Inverter-based, resource-related Glossary Terms

Comment Period Start Date:

9/18/2023

Comment Period End Date:

10/24/2023

Associated Ballots:

There were 39 sets of responses, including comments from approximately 101 different people from approximately 67 companies
representing 8 of the Industry Segments as shown in the table on the following pages.

Questions
1. Do you support the definition for Power Electronic Device (PED) as proposed, or with non-substantive changes? If you do not support the
definition as proposed, please explain the changes that, if made, would result in your support.
2. Do you support the definition for Inverter-Based Resource (IBR) as proposed, or with non-substantive changes? If you do not support the
definition as proposed, please explain the changes that, if made, would result in your support.
3. Provide any additional comments for the SDT to consider, if desired.

Organization
Name

Name

BC Hydro and Adrian
Power
Andreoiu
Authority

DTE Energy - Adrian
Detroit Edison Raducea
Company

WEC Energy
Group, Inc.

Segment(s)

1,3,5

Region

WECC

3,5

1,3,4,5,6

BC Hydro

WEC Energy
Group

WECC

Tacoma
Power

Group
Member
Organization

Group
Group Member
Member
Region
Segment(s)

Hootan Jarollahi BC Hydro and 3
Power
Authority

WECC

Helen Hamilton
Harding

BC Hydro and 5
Power
Authority

WECC

Adrian Andreoiu

BC Hydro and 1
Power
Authority

WECC

DTE Energy - 3
Detroit Edison
Company

Adrian Raducea

DTE Energy - 5
Detroit Edison

patricia ireland

DTE Energy

Christine Kane

WEC Energy
Group

Matthew Beilfuss WEC Energy
Group, Inc.

Clarice Zellmer

WEC Energy
Group, Inc.

David Boeshaar

WEC Energy
Group, Inc.

Jennie Wike

Tacoma
1,3,4,5,6
Public Utilities

WECC

John Merrell

Tacoma
1
Public Utilities
(Tacoma, WA)

WECC

John Nierenberg Tacoma
3
Public Utilities
(Tacoma, WA)

WECC

Hien Ho

Tacoma
4
Public Utilities
(Tacoma, WA)

WECC

Terry Gifford

Tacoma
6
Public Utilities
(Tacoma, WA)

WECC

Ozan Ferrin

Tacoma
5
Public Utilities
(Tacoma, WA)

WECC

DTE Energy - Karie Barczak
DTE Electric

Christine Kane 3,4,5,6

Tacoma
Jennie Wike
Public Utilities
(Tacoma, WA)

Group Name Group Member
Name

ACES Power
Marketing

Jodirah Green 1,3,4,5,6

MRO,RF,SERC,Texas ACES
Bob Soloman
RE,WECC
Collaborators

Kris Carper

MRO

Kendra
Buesgens

1,2,3,4,5,6

MRO

MRO NSRF

Hoosier
Energy
Electric
Cooperative

Arizona
1
Electric Power
Cooperative,
Inc.

WECC

Jason Procuniar Buckeye
Power, Inc.

1,4

Jolly Hayden

East Texas
Electric
Cooperative,
Inc.

NA - Not
Applicable

Texas RE

Amber Skillern

East Kentucky 1
Power
Cooperative

SERC

Scott Brame

North Carolina 3,4,5
Electric
Membership
Corporation

SERC

Bobbi Welch

Midcontinent
ISO, Inc.

MRO

Christopher Bills City of
3,5
Independence
Power & Light

MRO

Fred Meyer

Algonquin
Power Co.

MRO

Jamie Monette

Allete Minnesota
Power, Inc.

MRO

Larry Heckert

Alliant Energy 4
Corporation
Services, Inc.

MRO

Marc Gomez

Southwestern 1
Power
Administration

MRO

Bryan Sherrow

Kansas City
1
Board Of
Public Utilities

MRO

Terry Harbour

MidAmerican
Energy

1,3

MRO

Jamison Cawley Nebraska
Public Power

1,3,5

MRO

Seth Shoemaker Muscatine
Power &

1,3,5,6

MRO

Water

FirstEnergy FirstEnergy
Corporation

Mark Garza

1,3,4,5,6

FE Voter

Michael
Brytowski

Great River
Energy

Shonda McCain

Omaha Public 6
Power District

MRO

George Brown

Acciona
Energy North
America

MRO

Jaimin Patel

Saskatchewan 1
Power
Corporation

MRO

1,3,5,6

MRO,RF,SERC,Texas Southern
RE,WECC
Company

MRO

Kimberly Bentley Western Area 1,6
Power
Administration

MRO

Jay Sethi

Manitoba
Hydro

1,3,5,6

MRO

Michael Ayotte

ITC Holdings

MRO

Julie Severino

FirstEnergy FirstEnergy
Corporation

Aaron
Ghodooshim

FirstEnergy FirstEnergy
Corporation

Robert Loy

FirstEnergy FirstEnergy
Solutions

Mark Garza

FirstEnergyFirstEnergy

1,3,4,5,6

Stacey Sheehan FirstEnergy FirstEnergy
Corporation
Southern
Pamela
Company Frazier
Southern
Company
Services, Inc.

1,3,5,6

Matt Carden

Southern
1
Company Southern
Company
Services, Inc.

SERC

Joel Dembowski Southern
Company Alabama
Power
Company

SERC

Jim Howell, Jr.

SERC

Southern
Company Southern
Company
Generation

Southwest
Power Pool,
Inc. (RTO)

Western
Electricity
Coordinating
Council

Shannon
Mickens

Steven
Rueckert

MRO,SPP RE,WECC SPP RTO

WECC

Ron Carlsen

Southern
Company Southern
Company
Generation

SERC

Leslie Burke

Southern
Company Southern
Company
Generation

SERC

Shannon
Mickens

Southwest
Power Pool
Inc.

MRO

Eddie Watson

Southwest
Power Pool
Inc.

MRO

Jim Williams

Southwest
Power Pool
Inc

MRO

Jeff McDiarmid

Southwest
Power Pool
Inc.

MRO

Dee Edmondson Southwest
Power Pool
Inc.

MRO

Eric Sullivan

Southwest
Power Pool
Inc.

MRO

Brandon
Hentschel

Southwest
Power Pool
Inc.

MRO

Mia Wilson

Southwest
Power Pool
Inc.

MRO

Doug Bowman

Southwest
Power Pool
Inc.

MRO

Mason Favazza

Southwest
Power Pool
Inc.

MRO

Zach Sabey

Southwest
Power Pool
Inc.

MRO

Steve Rueckert

WECC

Phil O'Donnell

WECC

1. Do you support the definition for Power Electronic Device (PED) as proposed, or with non-substantive changes? If you do not support the
definition as proposed, please explain the changes that, if made, would result in your support.
Anderson Hoke - National Renewable Energy Laboratory - NA - Not Applicable - NA - Not Applicable
Answer

Document Name
Comment
It is confusing to define a term PED that excludes loads because increasingly many loads are power electronic devices. Instead, I’d suggest leveraging
the definition of “IBR unit” from IEEE 2800, which has nearly the same meaning as PED. The IBR unit definition could be amended by NERC to include
STATCOMs etc. if desired.
Likes

Dislikes

Response
Randall Buswell - VELCO -Vermont Electric Power Company, Inc. - 1
Answer

Document Name
Comment
The most confusing item is the use of “power electronic interface” in the PED definition because inverters are describes as a PED in the technical
rationale. If an inverter is a PED, what is the power electronic interface? The PED definition could be clarified by inserting “, such as an inverter”, after
“power electronic interface”. In addition, we would suggest removing inverters from the technical rationale. If we misunderstood the intent, please
explain what is meant by electronic interface.
Likes

Dislikes

Response
Ben Hammer - Western Area Power Administration - 1,6
Answer

Document Name
Comment
NERC Glossary of term utilizes "Real Power" but not "active power", "Reactive Power" not "reactive power" and "Load" not "load".

Suggest modification of PED definition to:
Power Electronic Device (PED): Any device connected to the ac power system through a power electronic interface that generates or transmits Real
Power or Reactive Power, or absorbs Real Power for the purposes of re-injecting it at a later time. This term excludes any Load.
Likes

Dislikes

Associated Electric Cooperative, Inc., 3, Bennett Todd
0

Response
Kendra Buesgens - MRO - 1,2,3,4,5,6 - MRO, Group Name MRO NSRF
Answer

Document Name
Comment
The MRO NSRF does not support creating the term Power Electronic Device. The term adds minimal value or clarity on its own. In principle, it’s a term
created for use in defining another term. In practice it almost completely overlaps with the proposed definition of IBR. The MRO NSRF suggests
combining power electronic device definition with the definition of inverter-based resource.
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Response
Srikanth Chennupati - Entergy - 1,3,5,7 - SERC
Answer

Document Name
Comment
Entergy agrees with NAGF comments. The NAGF has identified the following comments for consideration regarding the proposed Power Electronic
Device (PED) definition:
1. The term “power electronic interface” needs to be clarified as there are multiple definitions of this term.
2. The last sentence “This term excludes any load” needs to be clarified or deleted. A battery energy storage or pumped hydro device are modeled
as a load when in the charging/pumping operational modes. Such devices should not be excluded from the PED definition.
Likes

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Response
Adrian Andreoiu - BC Hydro and Power Authority - 1,3,5, Group Name BC Hydro

Answer

Document Name
Comment
BC Hydro appreciates the drafting team's efforts and the opportunity to comment, and offers the following.
The term “power electronic device” is widely used in the power and energy industry to refer to semiconductor devices (e.g., IGBT, Thyristor, MOSFET,
BJT, etc.) that are used in power electronic circuits and systems. This term has also been occasionally used to refer to power electronic converters
(e.g., inverters, rectifiers, choppers, etc.) that are composed of multiple semiconductor devices. The proposed definition now appears to extend this
term to also include other components of a single unit of an Inverter-Based Resource (IBR) along with a range of other devices, including HVDC
converters and FACTS devices. As such, it can lead to significant confusion.
The proposed definition states that a “Power Electronic Device” is “[any] device connected to the ac power system through a power electronic
interface…”. The confusion lies in the fact that the “power electronic interface”, which has been referred to in this definition, is itself recognized by the
industry as a power electronic device(s) or composed of power electronic devices.
The Standard Drafting Team may consider alternative terms such as IBR Unit (IBRU), Inverter-Based Device (IBD), or Power-Electronic-Interfaced
Device (PEID).
IBRU has been historically used to refer to the devices that are intended to fall into the scope of the definition. Therefore, its consistent use is not
expected to create confusion. IBD, on the other hand, does not appear to have been used extensively in the past. Therefore, it can be defined as a new
NERC Glossary Term, which will also minimize confusion.
It is recognized that certain FACTS devices are not inverter-based (such as SVC and TCSC). However, BC Hydro is of the opinion that such FACTS
devices are better addressed separately, rather than being lumped with the inverter-based devices in a single definition.
Alternatively, PEID can be used to cover all devices that have been intended to fall under the scope of the proposed definition. Although longer, this
term has the advantage of clarity, because the key term in the definition, i.e., “power electronic interface”, has been retained in the name, thereby
avoiding confusion and misinterpretation.
Likes

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Response
Duane Franke - Manitoba Hydro - 1,3,5,6 - MRO
Answer

Document Name
Comment
Please reference the IEEE definition of IBR and IBR units in the technical rationale.
Likes

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Response

George E Brown - Pattern Operators LP - 5
Answer

Document Name
Comment
Pattern Energy does not believe a standalone glossary term for “power electronic device is required. Please see response to question three. Thank
you.
Likes

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Response
Christine Kane - WEC Energy Group, Inc. - 3,4,5,6, Group Name WEC Energy Group
Answer

Document Name
Comment
WEC Energy Group supports the comments of the NAGF.
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Response
Israel Perez - Salt River Project - 1,3,5,6 - WECC
Answer

Document Name
Comment
SRP does not support the addition of this term to the standard. This new term defines IBR’s being introduced directly into a standard which previously
did not have IBR applicability. SRP strongly feels Inverter Based Resources should have separate standards.
Likes

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Response

Nikki Carson-Marquis - Minnkota Power Cooperative Inc. - 1 - MRO
Answer

Document Name
Comment
Minnkota Power Cooperative recognizes the need to distinguish individual IBR “devices” and the “resource/facility” with a term similar to IEEE’s “IBR
unit”. However, Minnkota opposes the proposed definition of PED, as well as the title of this term “Power Electronic Device”.
The proposed definition for PED is much too broad, as there are many different types of devices that use power electronics, not all of which are relevant
to generation resources. The proposed definition should also include more detail for determining which devices that have power electronics are PEDs
and which devices do not have PEDs. While the SDT’s technical rationale provides some clarification as to which types of devices are considered PED,
this level of detail is missing from the proposed definition.
Additionally, Minnkota opposes the proposed title of “Power Electronic Device”. This term is already in broad use within industry, and industry usage of
this term is not limited to IBR. The title of the proposed term should be more specific to IBR, perhaps “IBR Device”, “Inverter Based Device (IBD)”, or
even IEEE’s “IBR Unit”. While Minnkota acknowledges the SDT’s reasoning that IEEE is a different entity with a different focus, Minnkota believes
IEEE’s “IBR Unit” term more clearly indicates that this term is limited to devices used within an IBR context than the proposed PED term, and the SDT
should reconsider using the “IBR Unit” term. If, in the SDT’s view, IEEE’s definition of “IBR Unit” conflicts with the purpose of “PED”, it should be
explained in more detail.

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Response
Adrian Raducea - DTE Energy - Detroit Edison Company - 3,5, Group Name DTE Energy - DTE Electric
Answer

Document Name
Comment
No, definition is too much overlap to IBR definition.
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Response
Chantal Mazza - Hydro-Quebec (HQ) - 1 - NPCC
Answer

Document Name
Comment
The definition of PED mentions that it “generates or transmits both active and reactive power” while the definition for IBR mentions that it “supplies
primarily active power”. As mentioned, an HVDC or FACTS device is excluded from the term IBR, but is considered a PED. Therefore, the definition of
IBR should mention that it is a type of PED and not a collection of PED. This modification doesn’t exclude the possibility to have multiple PED together
to form a single bigger resource.
Power Electronic Device (PED): Any device incorporating a power electronic interface for connection to the ac power system that generates or transmits
active power or reactive power or absorbs active power for the purposes of re-injecting it later. This term excludes any load.
The most confusing item is the use of “power electronic interface” in the PED definition because inverters are describing as a PED in the technical
rationale. If an inverter is a PED, what is the power electronic interface? The PED definition could be clarified by inserting “, such as an inverter”, after
“power electronic interface”. In addition, we would suggest removing inverters from the technical rationale. If we misunderstood the intent, please
explain what is meant by electronic interface.

Likes

Dislikes

Response
Pamela Frazier - Southern Company - Southern Company Services, Inc. - 1,3,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name Southern
Company
Answer

Document Name
Comment
There is no clear definition of power electronic interface in provided technical rationale. Loads can also be defined as PEDs i.e., BESS during charging
mode. The last sentence of the proposed definition should be removed.
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Response
Wayne Sipperly - North American Generator Forum - 5 - MRO,WECC,Texas RE,NPCC,SERC,RF
Answer
Document Name
Comment

The NAGF has identified the following comments for consideration regarding the proposed Power Electronic Device (PED) definition:
a)

The term “power electronic interface” needs to be clarified as there are multiple definitions of this term.

b) The last sentence “This term excludes any load” needs to be clarified or deleted. A battery energy storage or pumped hydro device are modeled as
a load when in the charging/pumping operational modes. Such devices should not be excluded from the PED definition.
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Response
Junji Yamaguchi - Hydro-Quebec (HQ) - 1,5
Answer

Document Name
Comment
The definition of PED mentions that it “generates or transmits both active and reactive power” while the definition for IBR mentions that it “supplies
primarily active power”. As mentioned, an HVDC or FACTS device is excluded from the term IBR, but is considered a PED. Therefore, the definition of
IBR should mention that it is a type of PED and not a collection of PED. This modification doesn’t exclude the possibility to have multiple PED together
to form a single bigger resource.
Power Electronic Device (PED): Any device incorporating a power electronic interface for connection to the ac power system that generates or transmits
active power or reactive power or absorbs active power for the purposes of re-injecting it later. This term excludes any load.s
The most confusing item is the use of “power electronic interface” in the PED definition because inverters are describing as a PED in the technical
rationale. If an inverter is a PED, what is the power electronic interface? The PED definition could be clarified by inserting “, such as an inverter”, after
“power electronic interface”. In addition, we would suggest removing inverters from the technical rationale. If we misunderstood the intent, please
explain what is meant by electronic interface.
Likes

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Response
Kimberly Turco - Constellation - 5,6
Answer

Document Name
Comment
Constellation supports NAGF comments.
Kimberly Turco on behalf of Constellation Segments 5 and 6

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Response
Hillary Creurer - Allete - Minnesota Power, Inc. - 1
Answer

Document Name
Comment
Minnesota Power supports MRO’s NERC Standards Review Forum’s (NSRF) comments.
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Response
Alison MacKellar - Constellation - 5,6
Answer

Document Name
Comment
Constellation supports NAGF comments.
Alison Mackellar on behalf of Constellation Segments 5 and 6
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Response
Charles Yeung - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC
Answer

Document Name
Comment
There is no explanation of what purpose the term PED is intended to serve within MOD-026-2 and possibly other standards. Without understanding the
concern the term is intended to address, it is unclear whether there is a need for this to be a defined term. Rather than use this defined term in the IBR
definition, using “power electronic interface” is sufficient to complete the IBR definition.

If the PED term is retained, the ISO RTO Council Standards Review Committee (SRC) recommends that the definition be clarified to address the
identified ambiguities to ensure that there are no gaps in what the defined terms cover. In addition we do not agree with the phrase “This term excludes
any load” in the definition. Though we agree that “PED” does not include traditional load, stating this in the definition can be confusing because BESS in
a charging state needs to be modeled as load. We recommend leaving that phrase out of the definition and instead discussing this topic in the Technical
Rationale & Considerations. The proposed definition of PED already states that the device generates or transmits electric energy and therefore cannot
be a traditional load. Further, it is not good practice to use exclusionary language in a definition. It would be preferred that more descriptive words be
added to more clearly eliminate load as PED.

It is also unclear why the SDT used the undefined terms “active power” and “reactive power” in the proposed definition instead of using the existing
NERC glossary terms Real Power and Reactive Power. Using undefined terms when suitable defined terms already exist may result in ambiguity and
make the definition less effective; the SRC therefore recommends the use of existing defined terms. If the SDT intends “active power” and “reactive
power” to mean something different from Real Power and Reactive Power, the SRC recommends that the SDT use different terms and clarify the
intended meaning. The proposed definition also lacks clarity regarding whether a combination of multiple pieces of modular equipment of the same type
would be considered a single PED or an aggregation of PEDs.
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Kennedy Meier - Electric Reliability Council of Texas, Inc. - 2
Answer

Document Name
Comment
ERCOT joins the comments submitted by the ISO/RTO Council (IRC) Standards Review Committee (SRC) and adopts them as its own.
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Response
Shannon Mickens - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC, Group Name SPP RTO
Answer

Document Name
Comment
SPP has a concern that the term Power Electronic Device (PED) does not have a true definition implemented in the IEEE 2800 Standard. For the
record, the term was only found once in the document (on page 134) to where there was no definition associated, but only a description. At this point, it
is not clear on what the drafting team is suggesting in reference to the relationship of the PED and the IBR. We recommend that the drafting team

provide clarity around their expectations for the PED term and how it aligns with the IBR from a NERC Reliability Standard perspective.
Furthermore, we recommend that the IRPTF coordinates with the IEEE 2800 drafting team and ensure that this proposed term is included in the IEEE
Standard to promote consistency with the proposed Glossary of Terms definition.
Moreover, we recommend that the IRTPF coordinates with NERC legal to ensure that the proposed definition is included in the NERC Rules of
Procedures (RoP) Appendix 2A to ensure proper alignment with the other two documents.
Additionally, we recommend that the proposed term not be capitalized at the point. This current action will create confusion for the industry on the
current status of the term. For clarity, a defined term is only capitalized when it has officially been added to the NERC Glossary of Terms.
Finally, we recommend that the IRPTF create educational opportunities for industry to understand the relationship and purpose of the IEEE Standards
and how they align with the NERC Standards to help support the reliability needs of the grid. From our perspective, there’s no situational awareness
around the alignment of the documents.
Likes

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Response
C. A. Campbell - LS Power Development, LLC - 5
Answer

Document Name
Comment
LS Power Development agress with the comments submitted by the North American Generator Forum (NAGF).
Likes

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Response
Andy Thomas - Duke Energy - 1,3,5,6 - SERC,RF
Answer

Yes

Document Name
Comment
None.
Likes

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Response

Shengen Chen - RLC Engineering - NA - Not Applicable - NPCC
Answer

Yes

Document Name
Comment
This definition will cover broader devices that using power eletronic.
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Mark Garza - FirstEnergy - FirstEnergy Corporation - 1,3,4,5,6, Group Name FE Voter
Answer

Yes

Document Name
Comment
FirstEnergy supports EEI’s comments which state:
EEI does not oppose the proposed new term “Power Electronic Device” (PED). While we do not oppose the proposed new term, we offer the following
edits in boldface for consideration:
Power Electronic Device (PED): Any device incorporating a power electronic interface for connection to the Bulk Power System that generates or
transmits active power or reactive power or absorbs active power for the purposes of re-injecting it at a later time.
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Response
Mark Gray - Edison Electric Institute - NA - Not Applicable - NA - Not Applicable
Answer

Yes

Document Name
Comment
EEI does not oppose the proposed new term “Power Electronic Device” (PED). While we do not oppose the proposed new term, we offer the following
edits in boldface for consideration:
Power Electronic Device (PED): Any device incorporating a power electronic interface for connection to the Bulk Power System that generates or

transmits active power or reactive power or absorbs active power for the purposes of re-injecting it at a later time.
Likes

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Response
Daniela Atanasovski - APS - Arizona Public Service Co. - 1,3,5,6
Answer

Yes

Document Name
Comment
AZPS does not oppose the proposed new term “Power Electronic Device” (PED). While we do not oppose the proposed new term, we support the
following edits submitted by EEI on behalf of their members.
Power Electronic Device (PED): Any device connected to the ac power system through incorporating a power electronic interface for connection
to the Bulk Power System that generates or transmits active power or reactive power or absorbs active power for the purposes of re-injecting it at a
later time.
Likes

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Response
Anna Todd - Southern Indiana Gas and Electric Co. - 3,5,6 - RF
Answer

Yes

Document Name
Comment
N/A
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Response
Thomas Foltz - AEP - 3,5,6
Answer
Document Name
Comment

Yes

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Response
Steven Rueckert - Western Electricity Coordinating Council - 10, Group Name WECC
Answer

Yes

Document Name
Comment
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Response
Cain Braveheart - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

Yes

Document Name
Comment
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Response
Rachel Coyne - Texas Reliability Entity, Inc. - 10
Answer

Yes

Document Name
Comment
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Response

Diana Aguas - CenterPoint Energy Houston Electric, LLC - 1 - Texas RE
Answer

Yes

Document Name
Comment
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Response
Jennie Wike - Tacoma Public Utilities (Tacoma, WA) - 1,3,4,5,6 - WECC, Group Name Tacoma Power
Answer

Yes

Document Name
Comment
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Response
Jodirah Green - ACES Power Marketing - 1,3,4,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name ACES Collaborators
Answer

Yes

Document Name
Comment
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Response
Gail Elliott - International Transmission Company Holdings Corporation - NA - Not Applicable - MRO,RF
Answer
Document Name
Comment

No response received from Subject Matter Experts
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2. Do you support the definition for Inverter-Based Resource (IBR) as proposed, or with non-substantive changes? If you do not support the
definition as proposed, please explain the changes that, if made, would result in your support.
C. A. Campbell - LS Power Development, LLC - 5
Answer

Document Name
Comment
LS Power Development agress with the comments submitted by the North American Generator Forum (NAGF).
Likes

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Shannon Mickens - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC, Group Name SPP RTO
Answer

Document Name
Comment
SPP has concerns when it comes to the proposed IBR definition. One of our concerns pertain to the IEEE definition and the proposed Glossary
definition not having similar language.
Moreover, we have a concern on the how these definitions align with the FERC definition as well as what the Technical Rationale states that the
glossary of terms and IEEE definitions “has different focus.” We recommend that the IRPTF provide clarity on how this different focus doesn’t create
reliability concerns when it comes to the coordination of the IEEE and NERC Standards.
Again, we recommend that the IRPTF coordinates with the IEEE 2800 drafting team and ensure that this proposed term aligns with the IEEE Standard
to promote consistency with the NERC Glossary of Terms.
Furthermore, we recommend that the IRTPF coordinates with NERC legal to ensure that the proposed definition is included in the NERC Rules of
Procedures (RoP) Appendix 2A to ensure proper alignment with the other documents.
Also, we recommend that the IRPTF coordinates with the PRC-024 drafting team to ensure that the new performance based standard clearly
addresses how an IBR is defined, while, addressing the need of the IBR performance during a system disturbance.
Finally, we recommend that the IRPTF create educational opportunities for industry to understand the relationship and purpose of the IEEE standards
and how they align with the NERC Standards to help support the reliability needs of the grid. From our perspective, there’s no situational awareness
around the alignment of the documents.
Likes

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Kennedy Meier - Electric Reliability Council of Texas, Inc. - 2
Answer

Document Name
Comment
ERCOT joins the comments submitted by the IRC SRC and adopts them as its own.
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Charles Yeung - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC
Answer

Document Name
Comment
The SRC recommends that the drafting team leverage definitions from IEEE 2800 as much as possible instead of creating new definitions. The IEEE
2800 definitions of IBR Unit and IBR Plant are particularly useful, and the SDT should strongly consider defining these terms using the IEEE 2800
definitions, modified as necessary to align with the structure of NERC Reliability Standards. The SRC recognizes that the IEEE definitions may not be a
perfect fit for the NERC Reliability Standards, but the SRC believes that the concepts that the IEEE definitions capture will be useful for delineating
which Reliability Standard requirements apply to individual units (such as some of the requirements proposed in PRC-028-1) and which requirements
apply to IBR Plants as a whole. Therefore, the SRC believes that using the IEEE 2800 definitions as the NERC definitions as much as possible would
result in clearer definitions and minimize potential gaps in coverage.
Due to the emergence of inverter-based distributed energy resources connected to distribution systems, a general understanding of the term IBR has
arisen in industry that encompasses resources that do not connect to the Bulk-Power System (BPS). Including a reference to BPS connectivity in the
NERC definition for IBR may cause confusion, since the term “IBRs” is commonly used to refer to any DC-based energy devices regardless of whether
they connect to the BPS or to the distribution system. To avoid this potential confusion, the SRC recommends that the definition for the term not include
any references to the BPS. Reliability Standards can refer to “IBRs connected to the BPS” in order to avoid exceeding NERC’s authority without using a
nonstandard, confusing definition of the term IBR.
It is also confusing to state an IBR “operates as a single resource.” We support the need to distinguish this capability however, the term as written can
be misinterpreted to mean that the definition is not applicable when an IBR is designed to operate in aggregate (instead of as a single resource) through
a collector configuration such as what is identified in the I4 BES Inclusion. Instead, better wording to define the combination of PED(s) (or power
electronic interfaces”) to form a single IBR would be “taken together constitutes a single resource.” It is also unclear why the IBR definition is limited to
devices primarily supplying active power when the PED definition includes resources providing active or reactive power.

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Jodirah Green - ACES Power Marketing - 1,3,4,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name ACES Collaborators
Answer

Document Name
Comment
We applaud the efforts of the SDT to develop a definition for IBRs. We believe this is a welcome improvement that will add clarity to multiple Reliability
Standards. We believe the initial draft of the proposed IBR definition is a valiant attempt to define a broad range of various technologies; however, we
have concerns with the last bullet point of the Technical Rationale section which states:
“Battery energy storage system (BESS) will be considered as a PED/IBR independent of whether or not the device is operating in the charging or
discharging mode.”
This statement seems to contradict the caveat added in the IBR definition “supplies primarily active power”. A BESS system by its very nature will likely
be supplying active power <=50% of the time that it is in operation. To wit, charging rates may be less than discharge rates, thereby causing the BESS
to be absorbing active power over a longer time frame than it is supplying active power. Considering this, how would a BESS be considered to be
primarily supplying active power? We feel that additional clarification is needed to specifically address BESSs.

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Alison MacKellar - Constellation - 5,6
Answer

Document Name
Comment
The definition expands the definition of qualified units required under NERC standards.
Alison Mackellar on behalf of Constellation Segments 5 and 6
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Hillary Creurer - Allete - Minnesota Power, Inc. - 1

Answer

Document Name
Comment
Minnesota Power supports MRO’s NERC Standards Review Forum’s (NSRF) comments.
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Kimberly Turco - Constellation - 5,6
Answer

Document Name
Comment
The definition expands the definition of qualified units required under NERC standards.

Kimberly Turco on behalf of Constellation Segments 5 and 6
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Junji Yamaguchi - Hydro-Quebec (HQ) - 1,5
Answer

Document Name
Comment
The definition on its own does not exclude HVDC systems. It may be a good idea to add a specific exclusion like the PED definition. For example, add:
“This term excludes HVDC systems”. Alternatively, starting the definition with “Any electric power resource” could make it clearer that we are not simply
referring to a device that transmits electric power.
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Wayne Sipperly - North American Generator Forum - 5 - MRO,WECC,Texas RE,NPCC,SERC,RF
Answer

Document Name
Comment
The NAGF has identified the following comments for consideration regarding the proposed Inverter-Based Resource (IBR) definition:
a) Remove the term “Bulk Power System” and replace with “electrical system”. The NAGF is concerned that using the BPS term in the proposed
definition will not apply to Distributed Energy Resources (DER). The NAGF notes that an IBR is an IBR regardless of the level of the interconnection. It
is important that NERC develop DER and IBR definitions that work together and do not cause conflict/confusion.
b) Additional information is needed to understand how the IBR definition will impact the devices/facilities under the new GO/GOP-IBR registration
categories.
c)
Consider adding the following language to the proposed IBR definition: “An IBR plant/facility includes the Power Electronic Devices, and the
equipment designed primarily for delivering the power to a common point of connection (e.g. step-up transformers, collector system(s), main power
transformer(s), and power plant controller(s)). “
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Pamela Frazier - Southern Company - Southern Company Services, Inc. - 1,3,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name Southern
Company
Answer

Document Name
Comment
IBR definition, as proposed, excludes other than BPS systems that IBR are currently connected to i.e., DER. We suggest using “electrical system” in
place of “Bulk Power System”.
The reactive power production capability of inverter based resources is just as important as the real power production, so the phrase “supplies primarily
active power” is inaccurate.
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Chantal Mazza - Hydro-Quebec (HQ) - 1 - NPCC
Answer
Document Name

Comment
The definition on its own does not exclude HVDC systems. It may be a good idea to add a specific exclusion like the PED definition. For example, add:
“This term excludes HVDC systems”. Alternatively, starting the definition with “Any electric power resource” could make it clearer that we are not simply
referring to a device that transmits electric power.

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Adrian Raducea - DTE Energy - Detroit Edison Company - 3,5, Group Name DTE Energy - DTE Electric
Answer

Document Name
Comment
No, there is too much overlap to PED definition.
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Nikki Carson-Marquis - Minnkota Power Cooperative Inc. - 1 - MRO
Answer

Document Name
Comment
Minnkota Power supports the MRO New Standard Review Forum (NSRF) and ACES comments. Minnkota believes formally defining “Inverter-Based
Resource (IBR)” is the correct path forward and thanks the SDT for their efforts on the initial proposed definition.
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Israel Perez - Salt River Project - 1,3,5,6 - WECC
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Christine Kane - WEC Energy Group, Inc. - 3,4,5,6, Group Name WEC Energy Group
Answer

Document Name
Comment
WEC Energy Group supports the comments of the NAGF.
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George E Brown - Pattern Operators LP - 5
Answer

Document Name
Comment
Please see response to question three. Thank you.
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Duane Franke - Manitoba Hydro - 1,3,5,6 - MRO
Answer
Document Name
Comment

1. IBR should be independent of whether it is connected to the Bulk Power System or not. 2. In IEEE defined IBR, the IBR with the dedicated VSCHVDC all belongs to IBR. I am not sure whether it is the same for the NERC-defined IBR. Please clarify.
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Kendra Buesgens - MRO - 1,2,3,4,5,6 - MRO, Group Name MRO NSRF
Answer

Document Name
Comment
The MRO NSRF does not agree with the Inverter-Based Resource (IBR) definition. Resource is not well defined or constrained, which isn’t typically an
issue when the term is used in other locations, but here, it could lead to overlap between IBR and IBR facility/plant. “Connects to the BPS” shouldn’t be
included in the definition, as a device being connected (or not) to the BPS doesn’t actually change what it is, and things not connected to the BPS aren’t
subject to standards anyways. The phrase “supplies primarily active power” is also not well defined and probably not even needed. The last sentence
shouldn’t even be considered for inclusion as part of the definition for IBR, as it doesn’t define IBR in any way, it just stipulates what may be considered
an IBR plant/facility, something like this would be best placed in technical rationale or its own definition.
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Ben Hammer - Western Area Power Administration - 1,6
Answer

Document Name
Comment
NERC Glossary of term utilizes "Real Power" but not "active power".
Suggest modification of PED definition to:
Inverter-Based Resource (IBR): Any source of electric power consisting of one or more Power Electronic Devices (PEDs), that operates as a single
resource, supplies primarily Real Power, and connects to the Bulk Power System. An IBR plant/facility includes the Power Electronic Devices, and the
equipment designed primarily for delivering the power to a common point of connection (e.g. step-up transformers, collector system(s), main power
transformer(s), and power plant controller(s)).
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0

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Anderson Hoke - National Renewable Energy Laboratory - NA - Not Applicable - NA - Not Applicable
Answer

Document Name
Comment
Generally the definition is good. But why define IBR to include only BPS-connected plants? A distribution- or subtransmission-connected IBR is still an
IBR. Instead, just leave BPS out of the definition of IBR, but clarify in the main document which IBRs the requirements you are writing apply to. (For
example you could say in the main document that the requirements apply to BPS-connected IBRs, if that is the intent.)
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Diana Aguas - CenterPoint Energy Houston Electric, LLC - 1 - Texas RE
Answer

Yes

Document Name
Comment
We recognize that some older IBR units may not have the capability to provide reactive power. Nevertheless, CEHE would like to include the
revision below to the IBR definition for completeness. CEHE proposes the following revision to the IBR definition for consideration:
Any source of electric power consisting of one or more Power Electronic Devices (PEDs), that operates as a single resource, supplies primarily active
power, provides reactive power to support system voltage if capable and connects to the Bulk Power System. An IBR plant/facility includes the
Power Electronic Devices, and the equipment designed primarily for delivering the power to a common point of connection (e.g., step-up transformers,
collector system(s), main power transformer(s), and power plant controller(s)).

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Anna Todd - Southern Indiana Gas and Electric Co. - 3,5,6 - RF
Answer
Document Name
Comment

Yes

N/A
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Daniela Atanasovski - APS - Arizona Public Service Co. - 1,3,5,6
Answer

Yes

Document Name
Comment
While AZPS does not oppose the proposed definition of IBR, we do support the proposed changes submitted by EEI on behalf of their members. The
last sentence of the proposed definition seems to add a definition within a definition. If there is a belief that IBR plant/Facility needs to be defined, an
additional definition should be developed. We also suggest adding reactive power to the definition. All of our suggested changes are in boldface
below:
Inverter-Based Resource (IBR): Any source of electric power consisting of one or more Power Electronic Devices (PEDs), that operates as a single
resource, supplies primarily active power, and connects to the Bulk Power System. (Strikethrough/remove- An IBR plant/facility includes the Power
Electronic Devices, and the equipment designed primarily for delivering the power to a common point of connection (e.g. step-up
transformers, collector system(s), main power transformer(s), and power plant controller(s)).)
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Mark Gray - Edison Electric Institute - NA - Not Applicable - NA - Not Applicable
Answer

Yes

Document Name
Comment
While EEI does not oppose the proposed definition of IBR, we do suggest some changes. The last sentence of the proposed definition seems to add a
definition within a definition. If there is a belief that IBR plant/Facility needs to be defined, an additional definition should be developed. Suggest
deleting the last sentence, see below:
Inverter-Based Resource (IBR): Any source of electric power consisting of one or more Power Electronic Devices (PEDs), that operates as a single
resource, supplies primarily active power, and connects to the Bulk Power System.
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0

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Mark Garza - FirstEnergy - FirstEnergy Corporation - 1,3,4,5,6, Group Name FE Voter
Answer

Yes

Document Name
Comment
While EEI does not oppose the proposed definition of IBR, we do suggest some changes. The last sentence of the proposed definition seems to add a
definition within a definition. If there is a belief that IBR plant/Facility needs to be defined, an additional definition should be developed. We also suggest
adding reactive power to the definition.
Inverter-Based Resource (IBR): Any source of electric power consisting of one or more Power Electronic Devices (PEDs), that operates as a single
resource, supplies primarily active power, and connects to the Bulk Power System.
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Srikanth Chennupati - Entergy - 1,3,5,7 - SERC
Answer

Yes

Document Name
Comment
Entergy agrees with NAGF. NAGF has identified the following comments for consideration regarding the proposed Inverter- Based Resource (IBR)
definition:
a) Remove the term “Bulk Power System” and replace with “electrical system”. The NAGF is concerned that using the BPS term in the proposed
definition will not apply to Distributed Energy Resources (DER). The NAGF notes that an IBR is an IBR regardless of the level of the interconnection. It
is important that NERC develop DER and IBR definitions that work together and do not cause conflict/confusion.
b) Additional information is needed to understand how the IBR definition will impact the devices/facilities under the new GO/GOP-IBR registration
categories.
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Andy Thomas - Duke Energy - 1,3,5,6 - SERC,RF
Answer

Yes

Document Name
Comment
None.
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Randall Buswell - VELCO -Vermont Electric Power Company, Inc. - 1
Answer

Yes

Document Name
Comment
The definition on its own does not exclude HVDC systems. It may be a good idea to add a specific exclusion similar to the PED definition. For
example, add: “This term excludes HVDC systems”. Alternatively, starting the definition with “Any electric power resource” could make it clearer that we
are not simply referring to a device that transmits electric power.
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Jennie Wike - Tacoma Public Utilities (Tacoma, WA) - 1,3,4,5,6 - WECC, Group Name Tacoma Power
Answer

Yes

Document Name
Comment
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Cain Braveheart - Bonneville Power Administration - 1,3,5,6 - WECC
Answer
Document Name
Comment

Yes

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Shengen Chen - RLC Engineering - NA - Not Applicable - NPCC
Answer

Yes

Document Name
Comment
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Adrian Andreoiu - BC Hydro and Power Authority - 1,3,5, Group Name BC Hydro
Answer

Yes

Document Name
Comment
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Steven Rueckert - Western Electricity Coordinating Council - 10, Group Name WECC
Answer

Yes

Document Name
Comment
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Thomas Foltz - AEP - 3,5,6
Answer

Yes

Document Name
Comment
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Gail Elliott - International Transmission Company Holdings Corporation - NA - Not Applicable - MRO,RF
Answer
Document Name
Comment
No response received from Subject Matter Experts
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Rachel Coyne - Texas Reliability Entity, Inc. - 10
Answer
Document Name
Comment
Texas RE agrees with having a definition of Inverter-Based Resource (IBR) appreciates the drafting team’s efforts to write a definition. Texas RE is
concerned, however, with the phrases “primarily active power” and “collector system(s)” and recommends they be clarified.

In using the phrase “primary active power” in the definition, it may imply that supplying reactive power from these IBRs are less important or
nonessential. Additionally, using the phrase “collector system(s)” should be clarified to read “portions of the collector system(s) per the BES definition”.
In the BES Reference Document, there is a discussion about the common point of interconnection and the document indicates not all the collector
system(s) are part of the BES.

Texas RE recommends the IBR definition be revised to the following:

Inverter-Based Resource (IBR): Any source of electric power consisting of one or more Power Electronic Devices (PEDs), that operates as a single
resource, supplies active and reactive power simultaneously, and connects to the Bulk Power System. An IBR plant/facility includes the Power
Electronic Devices, and the equipment designed primarily for delivering the power to a common point of connection (e.g. step-up transformers, portions
of collector system(s) per the BES definition, main power transformer(s), and power plant controller(s)).

Lastly, Texas RE cautions drafting teams on being consistent with the IBR term. There have been drafts that use the term “IBR unit” rather than IBR,
which is not defined. Texas RE recommends being consistent in the use of the term IBR across all applicable standards.
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3. Provide any additional comments for the SDT to consider, if desired.
Steven Rueckert - Western Electricity Coordinating Council - 10, Group Name WECC
Answer
Document Name
Comment
None.
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Andy Thomas - Duke Energy - 1,3,5,6 - SERC,RF
Answer
Document Name
Comment

Please consider expanding the term “primarily” for the IBR term listed under the Technical Rationale and Considerations section that reads: …supplies “primarily” active power, and co
the statement that it can also provide reactive power.

Reference: MOD-026-2 – Verification of Dynamic Models and Data for BES Connected Facilities, Draft 4 of MOD-026-2, September 2023, Page 1 of 1, New or Modified Term(s) Used
Standards
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Kendra Buesgens - MRO - 1,2,3,4,5,6 - MRO, Group Name MRO NSRF
Answer
Document Name
Comment

The MRO NSRF thanks the SDT for their efforts in defining inverter-based resource and is the proper way to proceed. SDT needs to consider other defined terms for inclusion in this
Power, Reactive Power, Bulk Electrical System, et cetera. Using undefined versions of the aforementioned defined terms will lead to misinterpretation.
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Kacie Fischer - Oncor Electric Delivery - 1 - Texas RE
Answer
Document Name
Comment
Oncor believes it may be helpful if the following examples were moved out of the “Rationale and Technical Consideration” section and into the “Terms” section:
•
•

The device examples from bullet points 1 and 2.
The BESS clarification from bullet point 5. BESS acts like a load when it is charging, and the PED definition states “[t]his term excludes any load.” The BESS statement helps
of whether it is a PED in the charging state. It would also make more sense that BESS be in one category regardless of its operation modes.

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Srikanth Chennupati - Entergy - 1,3,5,7 - SERC
Answer
Document Name
Comment
Technical Rational and Considerations Section:
a) Recommend to include co-located hybrid IBR devices/facilities in the discussion to clarify whether the proposed PED and IBR definitions apply to such technologies.
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George E Brown - Pattern Operators LP - 5
Answer
Document Name
Comment
Pattern Energy would like to thank the Standards Drafting Team for their efforts to define inverter-based resource.

Inverter based resource (IBR) needs to be defined on its own and in a general manner, exclusive of either generation or transmission. This will allow the IBR term to capture all types

equipment. Then when it is necessary to have specific regulations/requirements for IBRs, the regulations/requirements could further narrow the scope to which particular types of IBR
regulations/requirements are applicable to using the Bulk Electrical System definition.
•

Proposed definition:

Inverter Based Resource (IBR): Refer generally to Bulk Power System (BPS) connected facilities that have a power electronic device that converts direct current (dc) electricity to alte
electricity between the ac grid and the source of electricity and vice versa. IBRs include but are not limited to type 3 and 4 wind turbine generators, solar photovoltaic inverters, and b
resources, as well as high voltage direct current circuits and flexible alternating current transmission system devices like static synchronous compensators and static volt-ampere reac

•

Application of the IBR term in regulations/requirements examples, not all inclusive:
o Aggregate Plant Level:

“IBRs identified through Inclusion I2 or I4 of the Bulk Electrical System definition at an aggregate plant/facility level, shall…”

•

Individual Unit Level:

“Individual IBR generating units of dispersed power producing resources identified through Inclusion I4 of the Bulk Electrical System definition, shall…”

Referenced Documents:
2023_NERC_Guide_Inverter-Based-Resources.pdf
NERC_IBR_QuickReferenceGuideMarch2023.pdf
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Christine Kane - WEC Energy Group, Inc. - 3,4,5,6, Group Name WEC Energy Group
Answer
Document Name
Comment
WEC Energy Group supports the comments of the NAGF.
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Xiaoyu Wang - Enel Green Power - NA - Not Applicable - NA - Not Applicable
Answer
Document Name
Comment
Please the SDT consider providing further clarifications on the PED definition.

Generally speaking, the team is to use this term to include a broader range of power electronics technology than IBRs, mainly to cover the FACTS such as StatCom, SVC, etc. This in
conveyed by the PED definition and its Technical Rationales.

However, in the IBR term definition, it reads that 'An IBR plant/facility includes the Power Electronic Devices, and the equipment designed primarily for delivering the power to a comm
(e.g. step-up transformers, collector system(s), main power transformer(s), and power plant controller(s)).' Sounds like here it refers PED to the inverter unit/device/equipment vs. othe
equipment/components within the IBR plant, such as transformers and collector systems.
It will be beneficial to clarify the actual scope of PED for future use.
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Shengen Chen - RLC Engineering - NA - Not Applicable - NPCC
Answer
Document Name
Comment
Maybe also consider some langueges that describing the software come with PED and IBR could also control/impact the performance of PED and IBR.
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Israel Perez - Salt River Project - 1,3,5,6 - WECC
Answer
Document Name
Comment

SRP does not support the addition of these new terms to the standard. These new terms are specific to IBR’s. SRP strongly feels Inverter Based Resources should have separate sta

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Nikki Carson-Marquis - Minnkota Power Cooperative Inc. - 1 - MRO
Answer
Document Name
Comment
Minnkota Power Cooperative appreciates the opportunity to comment.
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Mark Garza - FirstEnergy - FirstEnergy Corporation - 1,3,4,5,6, Group Name FE Voter
Answer
Document Name
Comment
N/A
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Adrian Raducea - DTE Energy - Detroit Edison Company - 3,5, Group Name DTE Energy - DTE Electric
Answer
Document Name
Comment
None
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0
0

Response
Chantal Mazza - Hydro-Quebec (HQ) - 1 - NPCC
Answer
Document Name
Comment
An IBR doesn't have to be connected to the Bulk Power System to be an IBR. This is the case for IBR on the distribution grid or on isolated grid.
Within MOD-026 please keep distinction between LCC HVDC vs. VSC HVDC.

We have concerns with the proposed IBR definition and the existing BES definition, in particular the I4 inclusion with refers to “Dispersed power producing resources” (DPPR) and is v
proposed IBR definition. Our understanding is that an IBR is automatically considered a DDPR, but the opposite is possibly not the case? Are there 2 distinct types of facilities, IBR (n
(BES)? We encourage the SDT to ensure consistent use of these terms when referring to an installation

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Pamela Frazier - Southern Company - Southern Company Services, Inc. - 1,3,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name Southern Company
Answer
Document Name
Comment

Consider adding the following language to the proposed IBR definition: “An IBR plant/facility includes the Power Electronic Devices, and the equipment designed primarily for deliverin
common point of connection (e.g. step-up transformers, collector system(s), main power transformer(s), and power plant controller(s))."

HVDC systems and transmission-connected FACTS devices (STATCOMs and SVCs, etc) are power electronic devices. Simply saying they are not in the IBR definition is not a valid
disassociation from the definition. If those device types are not intended or planned to be part of the development of future reliability standards, then the exclusion from applicability s
the standard, not in the development of a definition that doesn’t satisfy common sense.
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Daniela Atanasovski - APS - Arizona Public Service Co. - 1,3,5,6
Answer

Document Name
Comment
None
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Wayne Sipperly - North American Generator Forum - 5 - MRO,WECC,Texas RE,NPCC,SERC,RF
Answer
Document Name
Comment
Technical Rational and Considerations Section:
a) Recommend to include co-located hybrid IBR devices/facilities in the discussion to clarify whether the proposed PED and IBR definitions apply to such technologies. Please see
Guide for reference that NERC published back in 2021:

https://www.nerc.com/pa/comp/RegistrationReferenceDocsDL/CMEP%20Practice%20Guide%20%20Application%20of%20the%20BES%20Definition%20to%20BESS%20and%20H
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Anna Todd - Southern Indiana Gas and Electric Co. - 3,5,6 - RF
Answer
Document Name
Comment
N/A
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Junji Yamaguchi - Hydro-Quebec (HQ) - 1,5

Answer
Document Name
Comment
An IBR doesn't have to be connected to the Bulk Power System to be an IBR. This is the case for IBR on the distribution grid or on isolated grid.
Within MOD-026 please keep distinction between LCC HVDC vs. VSC HVDC.

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Kimberly Turco - Constellation - 5,6
Answer
Document Name
Comment
Constellation has no additional comments.

Kimberly Turco on behalf of Constellation Segments 5 and 6
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Hillary Creurer - Allete - Minnesota Power, Inc. - 1
Answer
Document Name
Comment
Minnesota Power supports MRO’s NERC Standards Review Forum’s (NSRF) comments.
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Alison MacKellar - Constellation - 5,6
Answer
Document Name
Comment
Constellation has no additional comments.
Alison Mackellar on behalf of Constellation Segments 5 and 6
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Jodirah Green - ACES Power Marketing - 1,3,4,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name ACES Collaborators
Answer
Document Name
Comment
Thank you for the opportunity to comment.
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Charles Yeung - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC
Answer
Document Name
Comment

The headers for R4, R5, and R6 in the posted draft 3 of MOD-026-2 infer they are applicable to IBRs by stating “Inverter Based Resources.” However, these three requirements also
does not meet the “IBR” definition, e.g. - FACTS, VSC HVDC, and LCC HVDC. The headers should be changed to remove “Inverter Based Resources” or removed in their entirety to

In addition the second bullet of the section “Technical Rationale and Considerations” states that the presence of the phrase “primarily supplies active power” in the IBR definition is the
systems would not be considered IBRs. The SRC agrees that HVDC systems should not be considered IBRs, but believes the stated reason is not correct. The SDT’s desire for the IB

limited to generating resources or sources of electric power would be a more accurate basis for excluding HVDC systems from the universe of IBRs.

It is necessary for the standard to distinguish between unit level and plant level requirements for commissioning purposes, since most facilities perform commissioning tests as interm
as building blocks leading up to the final end-to-end testing. This would help make available IBR test information prior to the commercial operation date. Finally, in the fourth bullet of t
is unclear what requirements are being proposed at the device level. In particular, with respect to model verification and validation, it is unclear what need exists for device-level NER
of plant-level requirements.

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Kennedy Meier - Electric Reliability Council of Texas, Inc. - 2
Answer
Document Name
Comment
ERCOT joins the comments submitted by the IRC SRC and adopts them as its own.

Additionally, the definitions and associated technical guidance should account for HVDC systems and their associated inverters, all of which may be considered PEDs. An HVDC syst
multiple smaller HVDC ties that include multiple inverters. Offshore wind farms may also employ a VSC HVDC transmission system to transfer power from the wind turbine PEDs to t
interconnection, potentially with different owners. Finally, ERCOT recommends that the SDT coordinate with the Project No. 2023-01 SDT, which has also been considering the appr
defining the term IBR.

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Gail Elliott - International Transmission Company Holdings Corporation - NA - Not Applicable - MRO,RF
Answer
Document Name
Comment
No response received from Subject Matter Experts
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0

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Shannon Mickens - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC, Group Name SPP RTO
Answer
Document Name
Comment
N/A
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C. A. Campbell - LS Power Development, LLC - 5
Answer
Document Name
Comment
LS Power Development agress with the comments submitted by the North American Generator Forum (NAGF).
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Consideration of Comments

Project 2020-06 Verification of Models and Data for Generators
IBR Definitions | Posted September 18 – October 24, 2023
Comments Received Summary

There were 39 sets of responses, including comments from approximately 101 different people from
approximately 67 companies representing 8 of the Industry Segments.
All comments submitted can be reviewed in their original format on the project page. If you feel that
your comment has been overlooked, please let us know immediately. Our goal is to give every
comment serious consideration in this process. If you feel there has been an error or omission, contact
Director, Standards Development Latrice Harkness (via email) or at (404) 858-8088.
Consideration of Comments

The Project 2020-06 drafting team (DT) thanks all of industry for your time and comments. The DT
identified themes from the informal comment period for the two terms (Inverter-Based Resource and
Power Electronic Device) to guide the overall revisions to the definitions and revised the inverter-based
resource (IBR)-related definitions based on the comments received. Due to the similar nature of
multiple comments received during the initial ballot and comment period, the DT chose to respond to
comments in summary format as described in Section 4.12 of the Standard Processes Manual.
Industry Comment Themes

•

The definitions should be more similar or aligned with the IEEE definitions for “IBR and IBR unit,”
since these definitions are well established.

•

The Power Electronic Device (PED) term is too broad. A PED can mean almost anything power
electronic based device/technology, such as an IGBT, computers, or other power electronic
based devices. Commenters also recommended using a different term to replace PED, such as
IBR Unit or Inverter-Based Device.

•

There needs to be a distinction between the definitions for PED and IBR. There is too much
overlap between the two terms.

•

The description of power electronic interface would be clearer if followed by the phrase “such
as an inverter/converter.”

•

The definition for IBR should not include “connected to the Bulk Power System.” An IBR is an IBR
regardless of where it is connected to the electrical power system, (e.g., transmission,
distribution, BES, BPS, etc.). Other commenters felt that the IBR definition should include
specific mention of connection to the Bulk Power System or transmission system.

•

The definitions should make it clearer which types of technologies are considered IBR.

RELIABILITY | RESILIENCE | SECURITY

•

The definitions should use other defined terms when possible, such as Real Power instead of
active power.

New Definitions

The DT proposes the two definitions below based on industry comment themes and team discussions.
Additional information can be found in the initial ballot documentation posted on the project page.
Inverter-Based Resource (IBR): A source (or sink in the case of a charging battery energy storage
system (BESS)) of electric power that is connected to the electric power system (transmission, subtransmission, or distribution system), and that consists of one or more IBR Unit(s) operated as a single
resource at a common point of interconnection. IBRs include solar photovoltaic (PV), Type 3 and Type 4
wind, BESS, and fuel cell.
IBR Unit: An individual device, or a grouping of multiple devices, that uses a power electronic
interface(s), such as an inverter or converter, capable of exporting Real Power from a primary energy
source or energy storage system, and that connect together at a single point on the collector system.

Response to Comments for Draft 1 of MOD-026-2
Project 2020-06 Verifications of Models and Data for Generators | November 2023

Inverter-Based Resource Definitions

Description of Current Draft

This is the first draft of the proposed Glossary Terms posted for a formal comment period and initial
ballot.
Completed Actions

Date

Standards Committee approved Standards Authorization Request (SAR)

September 24, 2020

SAR posted for comment

December 16, 2020 – January
14, 2021

Anticipated Actions

Date

45-day formal comment period with initial ballot

November 16, 2023 – January 4,
2024

10-day final ballot

January 2024

NERC Board adoption

February 2024

Project 2020-06 Verifications of Models and Data for Generators
Initial Draft of IBR Definitions | November 2023

Page 1 of 4

Inverter-Based Resource Definitions

New or Modified Term(s) Used in NERC Reliability Standards
Background:

This section includes all new or modified terms used in the proposed standard that will be included in
the Glossary of Terms Used in NERC Reliability Standards upon applicable regulatory approval. The terms
proposed below are intended to be used in MOD-026-2 and other inverter-based resource related
standards.
Term(s):

Inverter-Based Resource (IBR): A source (or sink in the case of a charging battery energy storage system
(BESS)) of electric power that is connected to the electric power system (transmission, sub-transmission,
or distribution system), and that consists of one or more IBR Unit(s) operated as a single resource at a
common point of interconnection. IBRs include solar photovoltaic (PV), Type 3 and Type 4 wind, BESS,
and fuel cell.
IBR Unit: An individual device, or a grouping of multiple devices, that uses a power electronic
interface(s), such as an inverter or converter, capable of exporting Real Power from a primary energy
source or energy storage system, and that connect together at a single point on the collector system.

Project 2020-06 Verifications of Models and Data for Generators
Initial Draft of IBR Definitions | November 2023

Page 2 of 4

Inverter-Based Resource Definitions

Background
•

The drafting team (DT) utilized the IEEE 2800-2022 definitions as an initial basis for the IBR terms
for the NERC Glossary of Terms and adjusted, as necessary. The DT acknowledges the efforts of
the P2800 Wind and Solar Plant Interconnection Performance Working Group and IEEE members
in developing those definitions.

•

The IBR and IBR Unit definitions are intended to describe the technology and which types of
technologies are considered IBR. An IBR is not defined by where it is connected or the size of the
IBR. Therefore, the definitions do not define the applicability for Reliability Standards, voltage
connection level, or facility capability level (MW/MVA). The applicability of IBR will be defined in
the Applicability section of the respective Reliability Standards. Additionally, this is the DT’s
reasoning to include the phrase “connected to the electric power system (transmission, subtransmission, or distribution system),” while excluding specific voltage connection and MW
values within the IBR definition.

•

There is a need to distinguish between the individual “IBR unit or device” and the “IBR
plant/facility” as a whole, so that standards or requirements can be written for each, as
necessary. Hence, the two definitions for IBR Unit and IBR.

•

The term IBR is synonymous with the term “IBR plant/facility.” An IBR includes the IBR Units, and
the equipment designed primarily for delivering the power to a common point of
interconnection (e.g., step-up transformers, collector system(s), main power transformer(s),
power plant controller(s), reactive resources within the IBR plant, and a voltage source converter
high-voltage direct current (VSC HVDC) system with a dedicated connection to the IBR).

•

IBRs have traditionally been considered “generating resources.” An IBR is not a HVDC system
(except for a VSC HVDC with a dedicated connection to an IBR), flexible ac transmission systems
(FACTS) (e.g., static synchronous compensators (STATCOM) and static VAR compensators (SVC)),
or any resources that are not inverter-based, e.g., gas and steam power plants with synchronous
generators. The DT’s intent with the phrase "IBRs include" is to articulate a specific list of IBRs.
Therefore, other technologies not listed would not be considered an IBR.

•

A hybrid IBR (e.g., BESS and solar PV) or collocated portions of a facility that are IBR (e.g., a BESS
at synchronous generation facility) are considered an IBR.

•

IBRs are capable of exporting Real Power and may also be capable of providing Reactive Power.

•

Battery energy storage systems (BESS) are considered an IBR unit or IBR independent of whether
the device is operating in a charging, idle, or discharging mode.

•

The Project 2020-06 DT intends to use the Glossary Terms of IBR Unit and IBR for MOD-026-2.
Additional standards development projects and related standards that may use these defined
terms include:
o Project 2020-02 Generator Ride-through (new PRC-029, modified PRC-024)
o Project 2021-01 Modifications to PRC-019 and MOD-025
o Project 2021-04 Modifications to PRC-002 (new PRC-028)

Project 2020-06 Verifications of Models and Data for Generators
Initial Draft of IBR Definitions | November 2023

Page 3 of 4

Inverter-Based Resource Definitions

o Project 2022-04 EMT Modeling
o Project 2023-01 EOP-004 IBR Event Reporting
o Project 2023-02 Performance of IBRs (new PRC-030)
•

Distributed Energy Resources (DER) related projects that may or may not need to use IBR/IBR
Unit if they end up with their own definition)
o Project 2022-02 Modifications to TPL-001 and MOD-032 (DER)
o Project 2023-05 FAC-001/FAC-002 DER
o Project 2023-08 MOD-031 Demand and Energy (DER)

Project 2020-06 Verifications of Models and Data for Generators
Initial Draft of IBR Definitions | November 2023

Page 4 of 4

Implementation Plan

Project 2020-06 Verifications of Models and Data for Generators
Inverter-Based Resource Definitions
Applicable Standard(s)
•

None

Requested Retirement(s)
•

None

Prerequisite Standard(s)

These standard(s) or definitions must be approved before the Applicable Standard becomes
effective:
•

None

Applicable Entities
•

None

New/Modified/Retired Terms in the NERC Glossary of Terms
•

Inverter-Based Resource (IBR)

•

IBR Unit

Background

As multiple standards development projects are actively addressing risks related to inverter-based
generation, NERC evaluated the need for a single standards project to move forward with
definitions that would be leveraged by all other projects. Project 2020-06 was identified as the
Drafting Team (DT) that would coalesce development efforts for these definitions and coordinate
proposed definitions with the other NERC developers. The Drafting Team proposes the two
definitions of IBR and IBR Unit to be used in Reliability Standard MOD-026-2, as well as other IBRrelated standards development projects.
General Considerations
Multiple standards in development will use the definition(s), and the proposed implementation
timeframe is intended to reflect that any one of those standards may be the first to use one or more
of the definitions. Additionally, this implementation plan only affects the date that these new
definitions will become effective terms in the NERC Glossary of Terms. A separate implementation
plan will be developed for MOD-026-2, including requirements that use these proposed definitions.

RELIABILITY | RESILIENCE | SECURITY

Effective Date

The effective date(s) for the proposed definitions for Glossary of Terms are provided below.
Where approval by an applicable governmental authority is required, the proposed definitions shall
become effective on the first day of the first calendar quarter after the applicable governmental
authority’s order approving the definitions, or as otherwise provided for by the applicable
governmental authority.
Where approval by an applicable governmental authority is not required, the proposed definitions
shall become effective on the first day of the first calendar quarter after the date the definitions are
adopted by the NERC Board of Trustees, or as otherwise provided for in that jurisdiction.

Implementation Plan for IBR-related Definitions
Project 2020-06 Verifications of Models and Data for Generators | November 2023

Unofficial Comment Form

Project 2020-06 Verification of Models and Data for Generators
Inverter-based Resource Definitions
Do not use this form for submitting comments. Use the Standards Balloting and Commenting System
(SBS) to submit comments on Inverter-based Resource (IBR) Glossary Terms by 8 p.m. Eastern, Tuesday,
January 9, 2024.
m. Eastern, Thursday, August 20, 2015

Additional information is available on the project page. If you have questions, contact Senior Standards
Developer, Chris Larson (via email), or at 404-446-9708.
Background

The NERC IBR Performance Task Force (IRPTF) performed a comprehensive review of all NERC Reliability
Standards to identify any potential gaps and/or improvements. The IRPTF discovered several issues as part
of this effort and documented its findings and recommendations in the IRPTF Review of NERC Reliability
Standards White Paper, which was approved in March 2020 by the Operating Committee and the Planning
Committee (now part of the Reliability and Security Technical Committee (RSTC)). Among the findings
noted in the white paper, the IRPTF identified issues with MOD-026-1 and MOD-027-1 that should be
addressed. The RSTC endorsed the standard authorization request (SAR) June 10, 2020.
The Standards Committee accepted two revised SARs at its July 21, 2021 meeting. The scope of the SARs
include the potential to add, modify, or retire a Glossary Terms for NERC Reliability Standards. The Project
2020-06 drafting team proposes two new terms as part of this formal comment and initial ballot period.
Please provide your responses to the questions listed below, along with any detailed comments.
Questions

1. Do you support the definition for IBR as proposed, or with non-substantive changes? If you do not
support the definition as proposed, please explain the changes that, if made, would result in your
support.
Yes
No
Comments:
2. Do you support the definition for IBR Unit as proposed, or with non-substantive changes? If you do
not support the definition as proposed, please explain the changes that, if made, would result in
your support.
Yes
No
Comments:
3. Provide any additional comments for the DT to consider, if desired.
Comments:

RELIABILITY | RESILIENCE | SECURITY

UPDATED
Standards Announcement

Project 2020-06 Verifications of Models and Data for Generators
Inverter-based Resource Glossary Terms
Formal Comment Period Open through January 9, 2024
Ballot Pools Forming through December 15, 2023
Now Available

A formal comment period for Inverter-based Resource Glossary Terms is open through 8 p.m. Eastern,
Tuesday, January 9, 2024.
Commenting

Use the Standards Balloting and Commenting System (SBS) to submit comments. An unofficial Word
version of the comment form is posted on the project page.
Reminder Regarding Corporate RBB Memberships

Under the NERC Rules of Procedure, each entity and its affiliates are collectively permitted one voting
membership per Registered Ballot Body Segment. Each entity that undergoes a change in corporate
structure (such as a merger or acquisition) that results in the entity or affiliated entities having more
than the one permitted representative in a particular Segment must withdraw the duplicate
membership(s) prior to joining new ballot pools or voting on anything as part of an existing ballot pool.
Contact [email protected] to assist with the removal of any duplicate registrations.
Ballot Pools

Ballot pools are being formed through 8 p.m. Eastern, Friday, December 15, 2023. Registered Ballot
Body members can join the ballot pools here.
•

•

Passwords expire every 6 months and must be reset.

•

The SBS is not supported for use on mobile devices.

•

Please be mindful of ballot and comment period closing dates. We ask to allow at least 48 hours
for NERC support staff to assist with inquiries. Therefore, it is recommended that users try logging
into their SBS accounts prior to the last day of a comment/ballot period.

RELIABILITY | RESILIENCE | SECURITY

Next Steps

Initial ballots will be conducted December 29, 2023 – January 9, 2024.
For more information on the Reliability Standards development process, refer to the Standard Processes
Manual.
For more information or assistance, contact Senior Standards Developer, Chris Larson (via email) or at 404446-9708. Subscribe to this project's observer mailing list by selecting "NERC Email Distribution Lists" from
the "Service" drop-down menu and specify “Project 2020-06 Verifications of Models and Data for
Generators Observer List” in the Description Box.
North American Electric Reliability Corporation
3353 Peachtree Rd, NE
Suite 600, North Tower
Atlanta, GA 30326
404-446-2560 | www.nerc.com

Standards Announcement | Project 2020-06 Verification of Data and Models for Generators
Inverter-Based Resource Glossary Terms | November 2023

Comment Report
Project Name:

2020-06 Verifications of Models and Data for Generators | Draft 1 of IBR Definitions

Comment Period Start Date:

11/16/2023

Comment Period End Date:

1/9/2024

Associated Ballots:

2020-06 Verifications of Models and Data for Generators IBR Unit IN 1 DEF
2020-06 Verifications of Models and Data for Generators IBR-related Definitions | Implementation Plan IN 1 OT
2020-06 Verifications of Models and Data for Generators Inverter-Based Resource (IBR) IN 1 DEF

Questions
1. Do you support the definition for IBR as proposed, or with non-substantive changes? If you do not support the definition as proposed,
please explain the changes that, if made, would result in your support.
2. Do you support the definition for IBR Unit as proposed, or with non-substantive changes? If you do not support the definition as proposed,
please explain the changes that, if made, would result in your support.
3. Provide any additional comments for the DT to consider, if desired.

Organization
Name

Name

BC Hydro and Adrian
Power
Andreoiu
Authority

MRO

Anna
Martinson

Segment(s)

1,2,3,4,5,6

Region

WECC

MRO

Group Name Group Member
Name
BC Hydro

MRO Group

Group
Group
Member
Member
Organization Segment(s)

Group
Member
Region

Hootan Jarollahi BC Hydro and 3
Power
Authority

WECC

Helen Hamilton BC Hydro and 5
Harding
Power
Authority

WECC

Adrian Andreoiu BC Hydro and 1
Power
Authority

WECC

Shonda McCain Omaha Public 1,3,5,6
Power District
(OPPD)

MRO

Michael
Brytowski

Great River
Energy

1,3,5,6

MRO

Jamison
Cawley

Nebraska
Public Power
District

1,3,5

MRO

Jay Sethi

Manitoba
Hydro (MH)

1,3,5,6

MRO

Husam AlHadidi

Manitoba
1,3,5,6
Hydro
(System
Preformance)

MRO

Kimberly
Bentley

Western Area 1,6
Power
Adminstration

MRO

Jaimin Patal

Saskatchewan 1
Power
Coporation
(SPC)

MRO

Angela Wheat

Southwestern 1
Power
Administration

MRO

George Brown

Pattern
Operators LP

MRO

Larry Heckert

Alliant Energy 4
(ALTE)

MRO

Terry Harbour

MidAmerican
Energy
Company
(MEC)

MRO

1,3

Southwest
Power Pool,
Inc. (RTO)

WEC Energy
Group, Inc.

Charles
Yeung

Christine
Kane

Southern
Colby
Company Galloway
Southern
Company
Services, Inc.

1,3,5,6

MRO,SPP RE,WECC SRC 2023

WEC Energy
Group

MRO,RF,SERC,Texas Southern
RE,WECC
Company

Dane Rogers

Oklahoma
Gas and
Electric
(OG&E)

1,3,5,6

MRO

Seth
Shoemaker

Muscatine
Power &
Water

1,3,5,6

MRO

Bobbi Welch

Midcontinent
ISO, Inc.

MRO

Michael Ayotte

ITC Holdings

MRO

Andrew Coffelt

Board of
1,3,5,6
Public UtilitiesKansas (BPU)

MRO

Charles Yeung

SPP

MRO

Ali Miremadi

CAISO

WECC

Helen Lainis

IESO

NPCC

Bobbi Welch

Midcontinent
ISO, Inc.

MRO

Greg Campoli

NYISO

NPCC

Elizabeth Davis PJM

Kennedy Meier Electric
Reliability
Council of
Texas, Inc.

Texas RE

Christine Kane

WEC Energy
Group

Matthew
Beilfuss

WEC Energy
Group, Inc.

Clarice Zellmer WEC Energy
Group, Inc.

David Boeshaar WEC Energy
Group, Inc.

Matt Carden

Southern
1
Company Southern
Company
Services, Inc.

SERC

Joel
Dembowski

Southern
Company Alabama
Power
Company

SERC

Ron Carlsen

Southern

SERC

Company Southern
Company
Generation

Public Utility
District No. 1
of Chelan
County

Diane E
Landry

ACES Power Jodirah
Marketing
Green

1,3,4,5,6

CHPD

Leslie Burke

Southern
Company Southern
Company
Generation

SERC

Joyce Gundry

Public Utility
District No. 1
of Chelan
County

WECC

Anne
Kronshage

Public Utility
District No. 1
of Chelan
County

WECC

Rebecca Zahler Public Utility
District No. 1
of Chelan
County

WECC

MRO,RF,SERC,Texas ACES
Bob Soloman
RE,WECC
Collaborators

Hoosier
Energy
Electric
Cooperative

Kris Carper

Arizona
1
Electric Power
Cooperative,
Inc.

WECC

Scott Brame

North Carolina 3,4,5
Electric
Membership
Corporation

SERC

Jason Procuniar Buckeye
Power, Inc.

Kevin Lyons

Central Iowa
Power
Cooperative

MRO

Amber Skillern

East Kentucky 1
Power
Cooperative

SERC

Nick Fogleman Prairie Power, 1,3
Inc.

SERC

Kylee Kropp

Sunflower
1
Electric Power
Corporation

MRO

Austin Towne

Western

Texas RE

1,5

Farmers
Electric
Cooperative
Eversource
Energy

FirstEnergy FirstEnergy
Corporation

Michael
Johnson

Northeast
Power
Coordinating
Council

Joshua
London

Mark Garza

Michael
Johnson

Ruida Shu

Eversource

FE Voter

WECC

1,2,3,4,5,6,7,8,9,10 NPCC

PG&E All
Segments

NPCC RSC

Joshua London Eversource
Energy

NPCC

Vicki O'Leary

Eversource
Energy

NPCC

Julie Severino

FirstEnergy FirstEnergy
Corporation

Aaron
Ghodooshim

FirstEnergy FirstEnergy
Corporation

Robert Loy

FirstEnergy FirstEnergy
Solutions

Mark Garza

FirstEnergyFirstEnergy

1,3,4,5,6

Stacey
Sheehan

FirstEnergy FirstEnergy
Corporation

Marco Rios

Pacific Gas
and Electric
Company

WECC

Sandra Ellis

Pacific Gas
and Electric
Company

WECC

Frank Lee

Pacific Gas
and Electric
Company

WECC

Gerry Dunbar

Northeast
Power
Coordinating
Council

NPCC

Alain Mukama

Hydro One
1
Networks, Inc.

NPCC

Deidre Altobell

Con Edison

NPCC

Jeffrey Streifling NB Power
Corporation

NPCC

Michele
Tondalo

United
Illuminating
Co.

NPCC

Stephanie
Ullah-Mazzuca

Orange and
Rockland

NPCC

Michael

Central

NPCC

Ridolfino

Hudson Gas &
Electric Corp.

Randy Buswell

Vermont
1
Electric Power
Company

NPCC

James Grant

NYISO

NPCC

John Pearson

ISO New
England, Inc.

NPCC

Harishkumar
Subramani
Vijay Kumar

Independent
Electricity
System
Operator

NPCC

Randy
MacDonald

New
Brunswick
Power
Corporation

NPCC

Dermot Smyth

Con Ed 1
Consolidated
Edison Co. of
New York

NPCC

David Burke

Orange and
Rockland

NPCC

Peter Yost

Con Ed 3
Consolidated
Edison Co. of
New York

NPCC

Salvatore
Spagnolo

New York
Power
Authority

NPCC

Sean Bodkin

Dominion Dominion
Resources,
Inc.

NPCC

David Kwan

Ontario Power 4
Generation

NPCC

Silvia Mitchell

NextEra
1
Energy Florida Power
and Light Co.

NPCC

Glen Smith

Entergy
Services

NPCC

Sean Cavote

PSEG

NPCC

Tracy MacNicoll Utility Services 5

NPCC

Jason Chandler Con Edison

Elevate
Energy
Consulting

Dominion Dominion
Resources,
Inc.

Shannon
Mickens

Ryan Quint

NA - Not
Applicable

Sean Bodkin 6

Shannon
Mickens

NA - Not Applicable

Elevate
Energy
Consulting

Dominion

MRO,SPP RE,WECC SPP RTO

Shivaz Chopra

New York
Power
Authority

NPCC

Vijay Puran

New York
6
State
Department of
Public Service

NPCC

ALAN
ADAMSON

New York
State
Reliability
Council

NPCC

David Kiguel

Independent

NPCC

Joel Charlebois AESI

NPCC

Joshua London Eversource
Energy

NPCC

Ryan Quint

Elevate
Energy
Consulting

NA - Not
Applicable

N/A

NA - Not
Applicable

Connie Lowe

Dominion Dominion
Resources,
Inc.

NA - Not
Applicable

Lou Oberski

Dominion Dominion
Resources,
Inc.

NA - Not
Applicable

Larry Nash

Dominion 1
Dominion
Virginia Power

NA - Not
Applicable

Rachel Snead

Dominion Dominion
Resources,
Inc.

NA - Not
Applicable

Shannon
Mickens

Southwest
Power Pool
Inc.

MRO

Mia Wilson

Southwest
Power Pool
Inc.

MRO

Josh Phillips

Southwest
Power Pool
Inc.

MRO

Darian Richards Southwest
Power Pool

MRO

Inc
Jim William

Stephen
Whaite

Western
Electricity
Coordinating
Council

Steven
Rueckert

Tim Kelley

WECC

Southwest
Power Pool
Inc.

MRO

Mason Favazza Southwest
Power Pool
Inc.

MRO

Scott Jordan

Southwest
Power Pool
Inc.

MRO

Will Tootle

Southwest
Power Pool
Inc.

MRO

Zach Sabey

Southwest
Power Pool
Inc.

MRO

ReliabilityFirst Lindsey
ReliabilityFirst 10
Ballot Body
Mannion
Member and Stephen Whaite ReliabilityFirst 10
Proxies

WECC

SMUD and
BANC

Steve Rueckert WECC

WECC

Phil O'Donnell

WECC

Nicole Looney

Sacramento
Municipal
Utility District

WECC

Charles Norton Sacramento
Municipal
Utility District

WECC

Wei Shao

Sacramento
Municipal
Utility District

WECC

Foung Mua

Sacramento
Municipal
Utility District

WECC

Nicole Goi

Sacramento
Municipal
Utility District

WECC

Kevin Smith

Balancing
Authority of
Northern
California

WECC

Document Name
Comment
The Inverter Based Resource proposed definition includes distribution. GADS and other regional (ISO/RTO) definitions support BPS (transmission and
sub-transmission) and purposely leave out distribution systems (distributed energy resources (DERs)). We recommend also having this delineation to
help industry terms align. Thus, DER should have its own definition and a MW delineation or facility descriptions as part of its definition. We believe
having MW delineation may help approval odds of both definitions. This may also help with the inclusions and exclusions of IBRs and DERs for
upcoming standards.
Further we recommend that BESS Resource should be excluded from this definition, and should be its own definition. Separating these items out may
help the inclusion and exclusion of certain units/facilities. We also recommend that converter unit resources should be its own definition. Reasoning for
breaking these resources out as their own definition, makes it easier to include, exclude, delineate and detail requirements for each kind of resource
within upcoming standards. Example: EMT modeling requirements, event reporting, and performances should differ between IBRs, BESS Resources
and Converter Based Resources.
Also, many companies (GOs) are seperating out their PV Plant as one legal entity and their BESS as another legal entity. With this in mind, making
seperate definitions also helps these companies.
Likes

Dislikes

Response
Duane Franke - Manitoba Hydro - 1,3,5,6 - MRO
Answer

Document Name
Comment
·
Item 4 in the background of the IBR definition documents indicates that the IBR is synonymous with the term “IBR plant/facility”, where a step-up
transformer, collector systems, main power transformers, power plant controllers, etc., all belong to the IBR. However, these details are not mentioned
in the IBR definition. Therefore, it is recommended to include these details in the IBR definition to clarify the definition.
·
The isolated IBR, regardless of their energy resource, interconnecting via a dedicated VSC-HVDC transmission facility should be included in the
IBR definition.
Likes
Dislikes

0
0

Response
Sean Bodkin - Dominion - Dominion Resources, Inc. - 6, Group Name Dominion
Answer

Document Name
Comment
The proposed defintion conflicts with the BES definition and also appears to be an attempt to expand NERC jurisidction into the distribution system. The
definition is expansive and goes beyond a defintoin of what an Inverter Based Resource is technically. Dominion Energy recommends that NERC use
the FERC definition of IBR: IBRs include solar photovoltaic, wind, fuel cell, and battery storage resources powering electronic devices that change
direct current power produced by these resources to alternating current power to be transmitted on the BPS. The FERC definition clearly communicates
that only resources that are intending to move power across the BPS are a jurisdictional IBR and does not conflict with the existing and approved BES
definition.
Dominion Energy also supports EEI comments.
Likes

Dislikes

Response
Ryan Quint - Elevate Energy Consulting - NA - Not Applicable - NA - Not Applicable, Group Name Elevate Energy Consulting
Answer

Document Name
Comment
The drafting team has presented a good draft definition of IBR but the proposed definition includes some technical issues that could create challenges,
inconsistencies, and applicability challenges when used in the NERC Reliability Standards. These issues should be further vetted and considered by the
drafting team for the next iteration. Potential issues include:
1. The parenthetical “(transmission, sub-transmission, or distribution system)” encapsulates all IBRs connected to the power grid which is a good
approach to create a generic definition that can then be further specified for applicability to requirements. However, the phrase could also be
removed and the meaning would remain the same. So therefore, it may not be necessary to add that level of specificity to the Glossary Term
knowing that further clarification would be needed for applicability in the Standards.
o IBRs connected to the distribution system are classified as distributed energy resources (DERs) and would need a separate definition to
classify them as such for any DER-related standards modifications.
2. The list of IBR technologies at the end of the definition is confusing in that it is unclear whether this list is inclusive or exclusive. As written, one
cannot clearly determine whether the list defines the types of resources that are considered IBRs or if they are simply examples. There are
other types of IBRs such as FACTS devices (STATCOMs, SVCs, etc.) and HVDC circuits that are not included in this list. Therefore, as written,
the definition will cause a significant amount of confusion and require significant clarifying language in every standard where used.
3. The ERO Enterprise CMEP Practice Guide: Application of the Bulk Electric System Definition to Battery Energy Storage Systems and Hybrid
Resources Version 1 clarifies that BESS applicability is irrespective of charging and discharging. This is relevant to these definitions in that the
proposed IBR definition states “A source (or sink in the case of a charging BESS)” but it is unclear what value the parenthetical addition brings
to the definition. A BESS is a source of electric power when discharging and therefore could be classified accordingly without the additional
language. The drafting team should consider this when developing the definition given the past precedence set with the Practice Guide.

Similarly, if the team decides to keep it, it could be integrated into the definition so there are less parentheticals throughout.
The following are supported in the definition:
1. The use of “electric power system” is likely a suitable term in that it is generic enough for a definition such as this. Again, without the additional
text that appears to be unnecessary, as described above.
A more fundamental definition such as the following may be just as useful for reference in NERC Standards: “A source of electric power connected to
the electric power system that consists of one or more IBR Unit(s) operated as a single resource at a common point of connection.
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Mark Garza - FirstEnergy - FirstEnergy Corporation - 4, Group Name FE Voter
Answer

Document Name
Comment
FirstEnergy supports EEI’s comments which state:
EEI appreciates the efforts to develop the proposed IBR definition, however, we do not support the definition as currently written
Our concerns include the specificity in the technology types covered in the proposed definition, noting that NERC definitions should be technology
agnostic. Also, as written the definition seems to cast an overly broad net relative to the size and voltage class for the IBR resources yielding
insufficient regulatory clarity necessary for entities to apply the definition in any meaningful way. While the definition is not intended to identify specific
resource applicability, it still should be clear enough to provide a regulatory floor as it relates to NERC Reliability Standards.
To address these concerns, either the IEEE definition of IBRs, as defined in IEEE 2800-2022 (IEEE Standard for Interconnection and Interoperability of
Inverter-Based Resources (IBRs) Interconnecting with Associated Transmission Electric Power Systems, See Section 3, page 31) or the informal
definition of IBRs as proposed by the FERC Commission on Nov. 17, 2023 should be leveraged.
Finally, consideration should be given to defining DERs separately noting these resources, while also inverter based, represent a specific class of IBRs
that are directly connected to the distribution system and in many cases serve a very different purpose outside of supporting the reliability of the Bulk
Power System.
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PG&E does not support the definition of an IBR as written because it is too narrow to only define the listed 5 items as IBR technologies. There are
other generation types that use IBR technologies that produce MWs such as Flywheels, Tidal flows, etc… that if left out, will result in future ambiguity.
PG&E's recommendation is to either list other generation methods by name or the Drafting Team (DT) should include in the requirement text “and
other” to ensure emerging generation or technologies are not excluded to avoid future modifications to the definition.
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Ruchi Shah - AES - AES Corporation - 5
Answer

Document Name
Comment
AES Clean Energy supports NAGF’s comments and NAGF’s proposed definition for IBR.
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Andy Thomas - DTE Energy - 1,3,5,6 - SERC,RF
Answer

Document Name
Comment
Duke Energy provides the following guidance: Delete proposed NERC IBR definition and substitute the IEEE 2800 “IBR Plant” definition. The
IEEE2800 definition is well vetted within the industry and serves the NERC intended purpose for this application. Note: The proposed NERC IBR
definition fits the IBR Plant definition from IEEE 2800.
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Anna Martinson - MRO - 1,2,3,4,5,6 - MRO, Group Name MRO Group
Answer

Document Name
Comment
MRO NSRF does not support the definition as written due to the following concerns:
The phrase “that is connected to the electric power system (transmission, sub-transmission, or distribution)” needs to be removed. Language
is unnecessary.
The sentence “IBRs include solar photovoltaic (PV), Type 3 and Type 4 wind, BESS, and fuel cell.” should be deleted. When possible, language
used in standards and definitions should be technology neutral.
The broadness of the definition generates ambiguity and will create difficultly in the application for NERC compliance. While identifying specific
resource applicability isn't the aim, the definition should provide a clear regulatory framework as a baseline for adherence to NERC Reliability
Standards.
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Lincoln Electric System, 5, Millard Brittany
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Response
Casey Perry - PNM Resources - 1,3 - WECC,Texas RE
Answer

Document Name
Comment
PNM and TNMP supports EEI comments but also provide recommended modification of the IBR definition.
Inverter Based Resource: A source of electric power that is connected to the and consists of one or more IBR Unit(s) operated as a single resource at
common point of interconnection. IBRs include but are not limited to solar photovoltaic (PV), Type 3 and Type 4 wind BESS, and fuel cell.
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Srikanth Chennupati - Entergy - Entergy Services, Inc. - 1,3,5,7 - SERC
Answer

facilities. Distribution connected facilities should be called DER in alignment with other NERC Posted guidelines.
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Sheila Suurmeier - Black Hills Corporation - 5
Answer

Document Name
Comment
Black Hills Corporation supports NAGF and EEI Comments.
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Micah Runner - Black Hills Corporation - 1
Answer

Document Name
Comment
Black Hills Corporation supports NAGF and EEI comments.
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Carly Miller - Carly Miller On Behalf of: Josh Combs, Black Hills Corporation, 5, 1, 3, 6; - Carly Miller
Answer

Document Name
Comment
Black Hills Corporation supports NAGF and EEI comments.
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Rachel Schuldt - Rachel Schuldt On Behalf of: Rachel Schuldt, Black Hills Corporation, 5, 1, 3, 6; - Black Hills Corporation - 6
Answer

Document Name
Comment
Black Hills Corporation supports NAGF and EEI comments.
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Jennifer Neville - Western Area Power Administration - 6
Answer

Document Name
Comment
•
•
•

Remove the phrase “that is connected to the electric power system (transmission, sub-transmission, or distribution)” as it is
unnecessary language.
Delete the sentence “IBRs include solar photovoltaic (PV), Type 3 and Type 4 wind, BESS, and fuel cell.” because the language is not
technology neutral.
The definition should provide a clarity for regulatory pruposes, currently the broadness of the definition generates ambiguity and will create
difficultly in the application for NERC compliance.

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Tracy MacNicoll - Utility Services, Inc. - 4
Answer

Document Name
Comment
"(transmission, sub-transmission, or distribution system)" is unnecessary for the definition. This clarification would be made in the Applicability or
Facilities section of a standard.

The last sentence should have "may include". If it is only those 4 generating types, the rest of the definition wouldn't be necessary.
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James Keele - Entergy - 3
Answer

Document Name
Comment
Entergy recommends The Inverter Based Resource(IBR) definition should clearly state that this definition should apply to only transmission connected
facilities. Distribution connected facilities should be called DER in alignment with other NERC Posted guidelines.
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Dennis Chastain - Tennessee Valley Authority - 1,3,5,6 - SERC
Answer

Document Name
Comment
The first sentence of the proposed definition includes the phrase “(or sink in the case of a charging battery energy storage system (BESS)” which limits
the applicability of an IBR to just BESS. Energy storage systems that could use IBRs are not limited to BESS - they could be used in other energy
storage technologies such as compressed gas, gravity based, etc. Also, using the word “or” limits the IBR to one or the other, when it could be both.
Suggest changing “or” to “and/or” and removing the word “battery” and “(BESS)” such that it reads “ “(and/or sink when used in conjunction with an
energy storage system)”. Also, change “BESS” to “energy storage system” in the last sentence.
The last sentence of the proposed definition includes the phrase “IBRs include solar photovoltaic (PV)… This seems to indicate that IBRs are PVs, etc.,
when they actually only support them. Suggest changing the sentence to read “IBRs are typically used with solar photovoltaic (PV), Type 3 and Type 4
wind, energy storage, and fuel cells.”
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Zahid Qayyum - New York Power Authority - 5
Answer

Document Name
Comment
NYPA reviewed the proposed IBR definition and suggests a revision. Given the dynamic nature of IBR technology, it’s advisable not to specify certain
types as the sole IBRs; instead, they could be cited as examples.
The term “IBR Unit” causes confusion as it says every inverter is a unit in the current definition, and NYPA recommends adopting an alternative term in
alignment with other NERC standards.
Additionally, it’s essential to explicitly include hybrid plants in the IBR definition, as the current background section lacks clarity on the designated IBR
portion. Besides, NYPA also recommends using Inverter Based Unit(s) instead of IBR Units (s) in the following sentence as it intends to explain IBR
itself:

“…and that consists of one or more IBR Unit(s) operated as a single resource at a common point of interconnection…”
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Ben Hammer - Western Area Power Administration - 1
Answer

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Donna Wood - Tri-State G and T Association, Inc. - 1
Answer

Document Name
Comment
Either delete the sentence “IBRs include solar photovoltaic (PV), Type 3 and Type 4 wind, BESS, and fuel cell.” all together or add "may include". .
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Marty Hostler - Northern California Power Agency - 4
Answer

Document Name
Comment
BES needs to be included in the Definition.
We already have experience with regulators making up their own interpretation when "BES" is not included. For example, in CIP-002-5.1a IRC 2.11
Auditors claim since BES is not before the word generation, GOP's must include non-BES generation in their Control Center assessments. Even
though a GOP can not possibly perform a GOP functional obligation for a non-BES generator, as it has no NERC functional obligations.
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Lauren Giordano - Lauren Giordano On Behalf of: Dennis Sismaet, Northern California Power Agency, 4, 6, 3, 5; Jeremy Lawson, Northern
California Power Agency, 4, 6, 3, 5; Marty Hostler, Northern California Power Agency, 4, 6, 3, 5; - Lauren Giordano
Answer

Document Name
Comment
BES needs to be included in the Definition. We already have experience with regulators making up their own interpretation when "BES" in not included.
For example, in CIP-002-5.1A IRC 2.11 Auditors claim since BES is not before the word generation, GOP's must include non-BES generation in their
Control Center assessments. Even though a GOP cannot possibly perform a GOP functional obligation for a non-BES generator as it has no NERC
functional obligations
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0
0

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Michael Whitney - Northern California Power Agency - 3,4,5,6
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Christine Kane - WEC Energy Group, Inc. - 3, Group Name WEC Energy Group
Answer

Document Name
Comment
WEC Energy Group supports the comments of the NAGF, the MRO NSRF and EEI.
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Stephen Stafford - Stephen Stafford On Behalf of: Greg Davis, Georgia Transmission Corporation, 1; - Stephen Stafford
Answer

Document Name
Comment
Remove the reference for sink in the IBR definition. A sink (load) is not a resource. Consider referring to a discharging battery energy storage system
(BESS).
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Jennifer Bray - Arizona Electric Power Cooperative, Inc. - 1
Answer

Document Name
Comment
AEPC signed on to ACES comments:
It is ACES’ viewpoint that the proposed definitions are a welcome step towards better defining what is inherently a somewhat nebulous concept. While
we can appreciate the approach taken by the Drafting Team, we believe further refinement is necessary. We would like to specifically emphasize our
agreement with the 3ʳᵈ bullet point of the “Background” section. We believe that it is imperative that the industry adopt specific definitions to distinguish
between an individual “IBR unit” and the “IBR plant/facility as a whole” thereby allowing each SDT the flexibility to draft each individual standard or
requirement with the correct scope for each. While we agree that creating distinct definitions is the correct method to clearly define these resource
types, it is our interpretation that the currently proposed IBR definition does not align with this stated approach. It is our opinion that the first sentence of
the IBR definition is redundant to the IBR unit definition and should be struck.
Furthermore, we do not believe that the IBR definition should be limited by a specific listing of technologies as is done in the last sentence of the
definition. The last sentence of the 6ᵗʰ bullet point in the background section states:
•

“The DT’s intent with the phrase "IBRs include" is to articulate a specific list of IBRs. Therefore, other technologies not listed would not be
considered an IBR.”

It is our perspective that if a specific list of applicable technologies is required to clearly define this term, then the rest of the definition is moot and can
be eliminated. In other words, rather than providing a definition and an all-inclusive list of applicable technologies, why not simply provide an allinclusive list? We believe this approach needlessly limits the IBR definition to current technologies in common use and does not allow enough flexibility
for future technological growth nor changes in industry trends.
It is our recommendation that the IBR definition be modified as follows:
•
•

“One or more IBR Unit(s), operated as a single resource at a common point of interconnection, connected to the electric power system
(transmission, sub-transmission, or distribution system).
IBRs may include, but are not limited to, any combination of one or more of the following installation types: solar photovoltaic (PV), wind turbine,
battery energy storage system, and fuel cell.”

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Tammy Porter - Tammy Porter On Behalf of: Byron Booker, Oncor Electric Delivery, 1; - Tammy Porter
Answer

Document Name
Comment
We are in agreement with other comments that, although the applicability section of MOD-026-2 limits resources set by the NERC I4 BES definition, the
proposed IBR definition needs to clearly state that it aligns with the NERC I4 BES definition. The current definition may imply that each IBR, ranging
from roof top solar to large dispatchable units, would fall under future NERC standards whose applicability does not explicitly include the NERC I4 BES
definition. It would be a costly undertaking for a larger utility to include all connected IBR units outside the I4 BES definition. In short, the applicability
scope of MOD-026-2 is directed toward NERC’s I4 BES definition, and the IBR definition need to reflect this boundary as well. Also, to better
incorporate the industry recommendation to use other defined terms when possible, such as Real Power, we recommend replacing “electric power” to
“Real Power.”
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Alan Kloster - Alan Kloster On Behalf of: Jeremy Harris, Evergy, 3, 5, 1, 6; Kevin Frick, Evergy, 3, 5, 1, 6; Marcus Moor, Evergy, 3, 5, 1, 6;
Tiffany Lake, Evergy, 3, 5, 1, 6; - Alan Kloster
Answer

Document Name
Comment
Evergy supports and incorporates by reference the comments of the Edison Electric Institute (EEI), MRO NSRF and the NAGF reasons for not
supporting the proposed definition for question #1. Evergy also humbly submits the following proposed definition for the drafting teams consideration:
Inverter-Based Resource - A generating resource or an energy storage system that relies on power electronic interfaces (inverters, converters, etc.) to
deliver electric power to a common point of interconnection.
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Wayne Sipperly - North American Generator Forum - 5 - MRO,WECC,Texas RE,NPCC,SERC,RF
Answer

Document Name
Comment
The NAGF does not support the proposed IBR definition draft #1 for the following reasons:
a. It is unclear if the proposed IBR definition draft #1 would make a three (3) unit IBR generating plant a single Inverter-Based Resource or multiple
Inverter-Based Resources. A 2x1 synchronous combined cycle gas plant has three generating units that can be controlled separately. Inverter-based
resources may also be structured and controlled as distinct units behind a common point of interconnection. When this occurs, these separately

controlled groups of inverters are considered generating units within a single plant.
b.

Recommend removing the parenthetical narrative “(transmission, sub-transmission, and distribution system).

c.
Recommend deleting the last sentence of the proposed IBR definition draft #1. It appears that any type of inverter not listed is excluded. While at
this time the list may be complete, there will be different types of inverter resources in the future that are applicable under the IBR definition.
The NAGF recommends the following alternative definition for IBR:
Inverter-Based Resource (IBR): A source (or sink in the case of a charging battery energy storage system (BESS)) of electric power that consists of
one or more IBR Unit(s) at a common point of interconnection.
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Selene Willis - Edison International - Southern California Edison Company - 5
Answer

Document Name
Comment
“See comments submitted by the Edison Electric Institute”
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Kenya Streeter - Edison International - Southern California Edison Company - 1,3,5,6
Answer

Document Name
Comment
See comments submitted by the Edison Electric Institute
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Daniela Atanasovski - APS - Arizona Public Service Co. - 1

Answer

Document Name
Comment
AZPS supports the following comments that were submitted by EEI on behalf of its members:
EEI appreciates the efforts to develop the proposed IBR definition, however, we do not support the definition as currently written. Our concerns include
the specificity in the technology types covered in the proposed definition, noting that NERC definitions should be technology agnostic. Also, as written
the definition seems to cast an overly broad net relative to the size and voltage class for the IBR resources yielding insufficient regulatory clarity
necessary for entities to apply the definition in any meaningful way. While the definition is not intended to identify specific resource applicability, it still
should be clear enough to provide a regulatory floor as it relates to NERC Reliability Standards.
To address these concerns, either the IEEE definition of IBRs, as defined in IEEE 2800-2022 (IEEE Standard for Interconnection and Interoperability of
Inverter-Based Resources (IBRs) Interconnecting with Associated Transmission Electric Power Systems, See Section 3, page 31) or the informal
definition of IBRs as proposed by the FERC Commission on Nov. 17, 2023 should be leveraged.
EEI further notes that the Project 2022-02 SDT has already attempted to define DERs separately within that project and while these resources are also
inverter based, they represent a specific class of IBRs that are directly connected to the distribution system and in many cases serve a very different
purpose outside of supporting the reliability of the Bulk Power System and therefore should be defined separately.
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Mark Gray - Edison Electric Institute - NA - Not Applicable - NA - Not Applicable
Answer

Document Name
Comment
EEI appreciates the efforts to develop the proposed IBR definition, however, we do not support the definition as currently written. Our concerns include
the specificity in the technology types covered in the proposed definition, noting that NERC definitions should be technology agnostic. Also, as written
the definition seems to cast an overly broad net relative to the size and voltage class for the IBR resources yielding insufficient regulatory clarity
necessary for entities to apply the definition in any meaningful way. While the definition is not intended to identify specific resource applicability, it still
should be clear enough to provide a regulatory floor as it relates to NERC Reliability Standards.
To address these concerns, either the IEEE definition of IBRs, as defined in IEEE 2800-2022 (IEEE Standard for Interconnection and Interoperability of
Inverter-Based Resources (IBRs) Interconnecting with Associated Transmission Electric Power Systems, See Section 3, page 31) or the informal
definition of IBRs as proposed by the FERC Commission on Nov. 17, 2023 should be leveraged.
EEI further notes that the Project 2022-02 SDT attempted to define DERs separately within that project. While these resources are also inverter based,
they represent a specific class of IBRs that are directly connected to the distribution system and in many cases serve a different purpose outside of
supporting the reliability of the Bulk Power System and therefore should be defined separately.
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0
0

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Dwanique Spiller - Berkshire Hathaway - NV Energy - 5
Answer

Document Name
Comment
The phrase “that is connected to the electric power system (transmission, sub-transmission, or distribution)” needs to be removed. Language
is unnecessary.

The sentence “IBRs include solar photovoltaic (PV), Type 3 and Type 4 wind, BESS, and fuel cell.” Should be deleted. When possible, language
used in standards and definitions should be technology neutral. If a resource would otherwise meet the criteria for being classified as an IBR, the
specific device type should not be taken into consideration as a means of exclusion. Any resource that meets the inclusion criteria of Bulk Electric
System should be subject to the appropriate reliability standards, regardless of specific device type. This is important for ensuring that standards and
associated language have the necessary flexibility to adapt to future technology and changing resource mixes. Additionally, while the Standard Drafting
Team’s intent in this being a closed list is stated in the Technical Rationale, the writing of this sentence does not clearly convey that intent, as “includes”
has been interpreted to be both limiting and non-limiting in various jurisdictions.
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Gail Elliott - Gail Elliott On Behalf of: Michael Moltane, International Transmission Company Holdings Corporation, 1; - Gail Elliott
Answer

Document Name
Comment
ITC supports the comments provided by MRO NSRF
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Rachel Coyne - Texas Reliability Entity, Inc. - 10
Answer
Document Name
Comment

According to the background section, the IBR definition should not designate the location of the resource connection. The verbiage of the definition,
however, indicates that it is connected to the electric power system (transmission, sub-transmission, or distribution). Texas RE recommends removing
the reference to transmission, sub-transmission, and distribution.
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Steven Rueckert - Western Electricity Coordinating Council - 10, Group Name WECC
Answer

Document Name
Comment
WECC suggests that the drafting team attempt to not include one-off technology-based language within the definition (i.e., “sink” phrase). Essentially,
batteries, in order to charge and discharge, have bi-directional converters (AC to DC when charging and DC to AC when discharging.) Using “IBR” as
part of the definition of IBR even as a descriptor of the unit type is somewhat circular. The phrase “operated as a single resource at a common point of
interconnection” may be troublesome as there are configurations where devices connect to separate systems and then those systems make multiple
connections (both to sub-transmission and in some cases transmission level voltages.) There should not be a loophole for compliance built into a
definition (if a company puts two connections to separate parts of a station there will be the discussion about applicability of the definition.) Additionally,
if there are multiple owners with multiple strings of IBRS but collect to a single GSU and a single point of interconnection, there could be confusion
regarding joint-owned and responsibilities OR there could be the argument that it is not a single resource and does not meet the definition. WECC
suggests the following definition:” Inverter-Based Resource (IBR)- A dispersed power producing resource that uses equipment explicitly for the
transformation of current flow from DC to AC, AC to DC, or some combination thereof including, but not limited to, solar photovoltaic (PV), Type 3 wind,
Type 4 wind, battery energy storage system (BESS) and fuel cell technologies or combinations of said technologies.”
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Shannon Mickens - Shannon Mickens On Behalf of: Joshua Phillips, Southwest Power Pool, Inc. (RTO), 2; - Shannon Mickens, Group Name
SPP RTO
Answer
Document Name
Comment

SPP has a concern that the proposed definition for Inverter-Based Resource (IBR) creates confusion on how to identify the resource as well as define
the responsibility. The initial draft for IBRs focused around the inclusion of the Power Electronic Device (PED) while the recent version includes
language pertaining to a source/sink. From our perspective, the latest version (including source/sink) doesn’t create a clear and concise picture defining
the definition. Moreover, those terms are more associated with Transmission Service Request (TSR) that allows a utility to allocate physical capacity in
the form of transmission service rights (TSRs) for the transmission of electric power.
SPP recommends that the drafting team considers removing the terms “source and sink” from the proposed definition and replaced them with language
that aligns with their purpose (proposed language shown below).
From our perspective, the proposed IBR definition doesn’t include language showing what a facility/plant is and the difference in reference to an IBR
unit (device) as noted in the rationale language.
Inverter-Based Resource (IBR): A generation (plant) (or load (storage facility) in the case of a charging battery energy storage system (BESS)) of
electric power that is connected to the electric power system (transmission, sub-transmission, or distribution system), and that consists of one or more
IBR Unit(s) operated as a single resource at a common point of interconnection. IBRs include solar photovoltaic (PV), Type 3 and Type 4 wind, BESS,
and fuel cell.
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Jodirah Green - ACES Power Marketing - 1,3,4,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name ACES Collaborators
Answer

Document Name
Comment
Comments: It is ACES’ viewpoint that the proposed deﬁnitions are a welcome step towards better deﬁning what is inherently a somewhat nebulous
concept. While we can appreciate the approach taken by the Drafting Team, we believe further reﬁnement is necessary.
We would like to speciﬁcally emphasize our agreement with the 3ʳᵈ bullet point of the “Background” section. We believe that it is imperative that the
industry adopt speciﬁc deﬁnitions to distinguish between an individual “IBR unit” and the “IBR plant/facility as a whole” thereby allowing each SDT the
ﬂexibility to draft each individual standard or requirement with the correct scope for each.
While we agree that creating distinct deﬁnitions is the correct method to clearly deﬁne these resource types, it is our interpretation that the currently
proposed IBR deﬁnition does not align with this stated approach. It is our opinion that the ﬁrst sentence of the IBR deﬁnition is
redundant to the IBR unit deﬁnition and should be struck.
Furthermore, we do not believe that the IBR deﬁnition should be limited by a speciﬁc listing of technologies as is done in the last sentence of the
deﬁnition. The last sentence of the 6ᵗʰ bullet point in the background section states:
“The DT’s intent with the phrase "IBRs include" is to ariculate a speciﬁc list of IBRs. Therefore, other technologies not listed would not be considered an
IBR.”
It is our perspective that if a speciﬁc list of applicable technologies is required to clearly deﬁne thisterm, then the rest of the deﬁnition is moot and can
be eliminated. In other words, rather than providing a deﬁnition and an all-inclusive list of applicable technologies, why not simply provide an allinclusive list? We believe this approach needlessly limits the IBR deﬁnition to current technologies in common use and does not allow enough ﬂexibility

for future technological growthnor changes in industry trends.
It is our recommendation that the IBR deﬁnition be modiﬁed as follows:
“One or more IBR Unit(s), operated as a single resource at a common point of interconnection, connected to the electric power system (transmission,
sub-transmission, or distribution system).
IBRs may include, but are not limited to, any combination of one or more of the following installation types: solar photovoltaic (PV), wind turbine, battery
energy storage system, and fuel cell.”

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LaTroy Brumfield - American Transmission Company, LLC - 1
Answer

Document Name
Comment
ATC mostly agrees with the MRO NSRF‘s comment on this matter.

ATC agrees with the MRO NSRF that the phrase “that is connected to the electric power system (transmission, sub-transmission, or
distribution)” should be removed as the highlighted language is unnecessary.

ATC also agrees with the MRO NSRF that the sentence “IBRs include solar photovoltaic (PV), Type 3 and Type 4 wind, BESS, and fuel cell.”

should be deleted. When possible, language used in standards and definitions should be technology neutral.
However, ATC believes that the IBR definition should not explicitly include applicability considerations within the definition itself, but that should be left
within the Applicability section of each standard. ATC does not believe the IBR definition should reference the BES definition as even the BES definition
may shift and change to accommodate the new IBR-GO and IBR-GOP thresholds being considered. This may have unintended consequences for the
IBR definition down the line.
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Charles Yeung - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC, Group Name SRC 2023
Answer

Document Name
Comment
The ISO RTO Council (IRC) Standards Review Committee (SRC) believes the definition does not fully align with the intent described in the background
material provided with the definition. Specifically, the proposed definition does not appear to fully include “the equipment designed primarily for
delivering the power to a common point of interconnection . . . .” Additionally, it seems to be unnecessary for the definition to include a BESS-specific
parenthetical since the proposed definition of IBR Unit already addresses energy storage systems. Additionally, new technologies may emerge that
include devices that are not capable of storing energy in batteries, but are capable of functioning as both a source and a sink of electric power, and it
would be inappropriate for the definition to exclude these devices if they otherwise meet the definition of an IBR. We also believe it is unnecessary for
the proposed IBR definition to reference specific fuel sources such as solar photovoltaic and wind. The type of fuel used is not the defining characteristic
of IBRs, and the definition should not be limited to currently known fuel types and configurations.
Finally, it is unnecessary to specify that the IBR interconnection point is transmission, sub-transmission and distribution. The applicability of the IBR
requirements is defined by the BES definition and distribution level applicability through the NERC Rules of Procedure. Any changes to applicability
would require a change in the term if these are included. Consequently, the BESS-specific parenthetical should be removed from the definition of IBR
and the definition be further revised to read as follows:
Inverter-Based Resource (IBR): A source of electric power that is connected to the electric power system, and that consists of one or more IBR Unit(s)
operated as a single resource at a common point of interconnection. An IBR consists of the IBR Unit(s), and the equipment designed primarily for
delivering the power to a common point of interconnection (e.g., step-up transformers, collector system(s), main power transformer(s),
power plant controller(s), reactive resources within the IBR plant, and a voltage source converter high-voltage direct current (VSC HVDC)
system with a dedicated connection to the IBR). A Battery Energy Storage System (BESS) operating in charging mode, acting as a sink of
electrical energy, is considered an IBR.
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Elizabeth Davis - Elizabeth Davis On Behalf of: Thomas Foster, PJM Interconnection, L.L.C., 2; - Elizabeth Davis
Answer

Document Name
Comment
Please reference IRC SRC comments. Thank you.
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Kennedy Meier - Electric Reliability Council of Texas, Inc. - 2
Answer

Document Name
Comment
ERCOT joins the comments submitted by the ISO/RTO Council (IRC) Standards Review Committee (SRC) and adopts them as its own.
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Robert Blackney - Edison International - Southern California Edison Company - 1
Answer

Document Name
Comment
See comments submitted by the Edison Electric Institute (EEI).
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Response
Patricia Lynch - NRG - NRG Energy, Inc. - 5
Answer
Document Name
Comment

NRG is in support of the NAGF comments concerning the proposed definiton of IBR as:
a.
It is unclear if the proposed IBR definition draft #1 would make a three (3) unit IBR generating plant a single Inverter-Based Resource or multiple
Inverter-Based Resources. A 2x1 synchronous combined cycle gas plant has three generating units that can be controlled separately. Inverter-based
resources may also be structured and controlled as distinct units behind a common point of interconnection. When this occurs, these separately
controlled groups of inverters are considered generating units within a single plant.
b. Recommend deleting the last sentence of the proposed IBR definition draft #1. It appears that any type of inverter not listed is excluded. While at this
time the list may be complete, there will be different types of inverter resources in the future that are applicable under the IBR definition.
As proposed by NAGF, an alternate definition for IBR can include the following:
Inverter-Based Resource (IBR): A source (or sink in the case of a charging battery energy storage system (BESS)) of electric power that consists of
one or more IBR Unit(s) at a common point of interconnection.
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Thomas Foltz - AEP - 5
Answer

Yes

Document Name
Comment
While AEP does not object to the definition as proposed, we would like to suggest the drafting team to consider revising it as follows: IBR Unit: An
individual device, or a grouping of multiple devices, that uses a power electronic interface(s), such as an inverter or converter, capable of exporting Real
Power from a primary energy source or energy storage system, and that *functionally integrate* at a *delivery* point on the collector system.
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Adrian Andreoiu - BC Hydro and Power Authority - 1, Group Name BC Hydro
Answer

Yes

Document Name
Comment
BC Hydro requests that SDT clarify whether the last sentence, which only appears to serve as examples, is intended to convey any additional material
criteria to the application of the proposed definition.
Using the “connected to electric power system” in the definition appears to further qualify IBRs; however, as “electric power system” is not a defined

term, this wording may only result in unnecessary applicability interpretations.
BC Hydro suggests that the applicability to specific reliability standards be kept outside the IBR definition (such as within the Facility section of
Standards), or further define the criteria that would make an inverter-based resource an IBR for the purpose of the NERC standards applicability.
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Alison MacKellar - Constellation - 5
Answer

Yes

Document Name
Comment
Constellation has no additional comments.
Alison Mackellar on behalf of Constellation Segments 5 and 6.
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Kimberly Turco - Constellation - 6
Answer

Yes

Document Name
Comment
Constellation has no additional comments

Kimberly Turco on behald of Constellation Segments 5 and 6
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Anna Todd - Southern Indiana Gas and Electric Co. - 3,5,6 - RF
Answer

Yes

Document Name
Comment
N/A
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Daniel Gacek - Exelon - 1
Answer

Yes

Document Name
Comment
While Exelon supports the proposed definition, we support the questions presented in the EEI comments.
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Response
Colby Galloway - Southern Company - Southern Company Services, Inc. - 1,3,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name Southern
Company
Answer

Yes

Document Name
Comment
Southern Company suggests that additional clarification could be provided to further indicate that this definition is intended to apply to an entire facility
or electric power producing plant.
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Joshua London - Eversource Energy - 1, Group Name Eversource
Answer
Document Name

Yes

Comment
The sentence “IBRs include solar photovoltaic (PV), Type 3 and Type 4 wind, BESS, and fuel cell.” should be deleted or edited to say “Examples
of IBRs include”. Definitions should not require the statement of specific technologies for an individual to understand that those technologies fall under
the definition as doing so may lead a reader to believe only those specific technologies are in-scope. If you want to provide examples, then it should be
stated that way.
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Ruida Shu - Northeast Power Coordinating Council - 1,2,3,4,5,6,7,8,9,10 - NPCC, Group Name NPCC RSC
Answer

Yes

Document Name
Comment
NPCC RSC supports the definition for IBR as proposed.
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Response
Russell Jones - Invenergy LLC - 5
Answer

Yes

Document Name
Comment
Invenergy supports the spirit of the definition proposed and does not offer any substantive changes. We do, however, have concerns about the
application of this definition to various reliability standards going forward. More specifically, Invenergy believes the drafting team should consider how
this broad definition will be applied in specific Reliability Standard requirements to different roles (transmission, sub-transmission, distribution) and
different technologies (PV, Type 3 and Type 4 wind, BESS, and fuel cell) where nuance may be required to account for technological limitations or
differences.
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Response
Colin Chilcoat - Invenergy LLC - 6

Answer

Yes

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Response
Kinte Whitehead - Exelon - 1,3
Answer

Yes

Document Name
Comment
While Exelon supports the proposed definition, we support the question presented in the EEI comments.
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Response
Constantin Chitescu - Ontario Power Generation Inc. - 5
Answer

Yes

Document Name
Comment
OPG supports NPCC Regional Standards Committee’s comments.
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Response
Diane E Landry - Public Utility District No. 1 of Chelan County - 1, Group Name CHPD

Answer

Yes

Document Name
Comment
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Response
Cain Braveheart - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

Yes

Document Name
Comment
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Response
Mike Magruder - Avista - Avista Corporation - 1
Answer

Yes

Document Name
Comment
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Response
Mohamad Elhusseini - DTE Energy - Detroit Edison Company - 3,5
Answer

Yes

Document Name
Comment
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Response
Stephen Whaite - Stephen Whaite On Behalf of: Lindsey Mannion, ReliabilityFirst , 10; - Stephen Whaite, Group Name ReliabilityFirst Ballot
Body Member and Proxies
Answer

Yes

Document Name
Comment
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Yes

Document Name
Comment
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Response
Jesus Sammy Alcaraz - Imperial Irrigation District - 1
Answer

Yes

Document Name
Comment
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Response
Diana Aguas - CenterPoint Energy Houston Electric, LLC - 1 - Texas RE

Answer

Yes

Document Name
Comment
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Response
Tim Kelley - Tim Kelley On Behalf of: Charles Norton, Sacramento Municipal Utility District, 3, 6, 4, 1, 5; Foung Mua, Sacramento Municipal
Utility District, 3, 6, 4, 1, 5; Kevin Smith, Balancing Authority of Northern California, 1; Nicole Looney, Sacramento Municipal Utility District, 3,
6, 4, 1, 5; Ryder Couch, Sacramento Municipal Utility District, 3, 6, 4, 1, 5; Wei Shao, Sacramento Municipal Utility District, 3, 6, 4, 1, 5; - Tim
Kelley, Group Name SMUD and BANC
Answer

Yes

Document Name
Comment
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Response
Teresa Krabe - Lower Colorado River Authority - 5
Answer

Yes

Document Name
Comment
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Response
Matt Lewis - Lower Colorado River Authority - 1,5
Answer
Document Name
Comment

Yes

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Response
Nikki Carson-Marquis - Nikki Carson-Marquis On Behalf of: Theresa Allard, Minnkota Power Cooperative Inc., 1; - Nikki Carson-Marquis
Answer
Document Name
Comment
No. Minnkota Power Cooperative supports comments by ACES and the MRO New Standard Review Forum (NSRF). MPC believes the IBR definition
should be technology-neutral and should avoid listing examples within the final definition.
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Document Name
Comment
NRG is in support of the NAGF comments that has been submitted regarding this proposed definiton:
The NAGF does not support the proposed IBR Unit definition draft #1 for the following reasons:
a.
Utilizing the term IBR Unit to refer to a single inverter within the generating plant will cause significant confusion at the plant level. Unless any
instruction provided to the plant is written, then it will not be clear if the term IBR Unit is the defined term used by NERC or if it is intended to mean the
generating unit (Unit 1, 2 or 3), IBR unit. This level of potential confusion is unacceptable resulting in an unacceptable risk of the BES being
misoperated. The word “unit” has long been associated with a distinct operating segment of a plant. For this reason, the NAGF does not support the use
of the term unit to mean anything less than the dispatchable grouping of inverters.
The NAGF recommends the following alternative definition for IBR Unit:
IBR Unit: All or part of an Inverter-Based Resource that is operated as a single resource. An IBR Unit may consist of one or more IBR Devices.
In addition, the NAGF recommends the creation of the definition for IBR Device:
IBR Device: An individual device, or a grouping of multiple devices, (including equipment connected to the DC terminal of the inverter) that includes
power electronic interface(s), such as an inverter or converter, capable of exporting Real Power from a primary energy source or energy storage
system, and that connects at a single point on the collector system.

These proposed alternative definitions will enable applicable NERC standards to be clear when a protection device or modeling information is needed at
the device or unit level without causing confusion. While normally the use of the IEEE definition would be supported, in this case it is likely to cause
more problems and uncertainty for the industry.
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Response
Robert Blackney - Edison International - Southern California Edison Company - 1
Answer

Document Name
Comment
See comments submitted by the Edison Electric Institute (EEI).

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Response
Kennedy Meier - Electric Reliability Council of Texas, Inc. - 2
Answer

Document Name
Comment
ERCOT joins the comments submitted by the IRC SRC and adopts them as its own.
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Response
Elizabeth Davis - Elizabeth Davis On Behalf of: Thomas Foster, PJM Interconnection, L.L.C., 2; - Elizabeth Davis
Answer

Document Name
Comment
Please reference IRC SRC comments. Thank you.
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Response
Charles Yeung - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC, Group Name SRC 2023
Answer

primary energy source or energy storage system or a grouping of multiple devices, that uses a power electronic interface(s), such as an inverter
or converter, capable of exporting Real Power from a primary energy source or energy storage system and delivering that power at a
common point.
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Response
LaTroy Brumfield - American Transmission Company, LLC - 1
Answer

Document Name
Comment
ATC supports the comments of the MRO NSRF indicating that two separate definitions are not needed, and the use of the term facility or plant can be
used to differentiate between the IBR and the IBR facility.
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Jodirah Green - ACES Power Marketing - 1,3,4,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name ACES Collaborators
Answer

Document Name
Comment
Similar to our interpretation of the IBR deﬁnition, as stated above, we believe the currently proposed IBR Unit deﬁnition contains superﬂuous language
that overlaps the proposed IBR deﬁnition and should be modiﬁed. It is our opinion that the IBR unit deﬁnition should utilize a
standalone technologically agnostic approach. Therefore, we are in favor of removing all references to multiple devices within this single unit deﬁnition.
We recommend that the IBR Unit deﬁnition be modiﬁed as follows:
“An individual device that uses a power electronic interface(s), such as an inverter or converter, that is capable of exporting Real Power from a primary
energy source or energy storage system.”

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Response

Shannon Mickens - Shannon Mickens On Behalf of: Joshua Phillips, Southwest Power Pool, Inc. (RTO), 2; - Shannon Mickens, Group Name
SPP RTO
Answer

Document Name
Comment
SPP has a concern in reference to the proposed definition for the IBR Unit. We understand that the drafting team used definitions from the IEEE 1547
and 2800 Standards to structure the proposed definition. However, there is the concern that the drafting team has not created enough rationale
language defining the components of an actual IBR device. In our evaluation, we noticed that the IBR definition in the IEEE 2800 Standard mentions
that an IBR Device is “a collector system or supplemental”. From our perspective, there will need to be some clarity placed around the definition of an
IBR device.
With that said, SPP recommends that the drafting team considers creating a definition for the term “IBR Device” as well as provide a list of those types
of elements to help ensure there is a clear and concise distinction of an IBR Unit and IBR Device.
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Steven Rueckert - Western Electricity Coordinating Council - 10, Group Name WECC
Answer

Document Name
Comment
The definitions does not address Reactive Power. The phrase “that connect together at a single point on the collector system” may be troublesome as
there are configurations where devices connect to separate systems and then those systems make multiple connections (both to sub-transmission and
in some cases transmission level voltages.) As indicated in our response to question 1, there should not be a loophole for compliance built into a
definition. In the December 5 presentation, if there are two owners of the two sets of IBR Units, are there two IBRs or one IBR that is co-owned/jointlyowned? “IBR” in the presentation provided December 5, slide 10 appears to indicate the inverter banks and the power source are part of the BES but
slide 7 only calls out the inverters as an IBR Unit. The SDT needs to clarify if the primary energy source is part of the IBR Unit (thus part of the BES) to
help ensure consistency by industry when used in a Standard. For instance- are freeze protection measures only for the inverter or the inverter and the
primary energy source? Slide 8 clearly reveals more details than the definition of IBR states and does not support the BES definition clearly.
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Rachel Coyne - Texas Reliability Entity, Inc. - 10
Answer

IBR Unit: An individual device, or a grouping of multiple devices, that uses a power electronic interface(s), such as an inverter or converter, capable of
exporting Real Power and capable of providing dynamic Reactive Power support from a primary energy source or energy storage system, and that
connect together at a single point on a collector system.
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Response
Gail Elliott - Gail Elliott On Behalf of: Michael Moltane, International Transmission Company Holdings Corporation, 1; - Gail Elliott
Answer

Document Name
Comment
ITC supports the comments provided by MRO NSRF
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Response
Dwanique Spiller - Berkshire Hathaway - NV Energy - 5
Answer

Document Name
Comment
There should not be two separate definitions. IBR should be defined to address the resource itself. The term facility{C}[1] can be included when
necessary to refer to a group of IBRs and the equipment associated with the group. This is the how Standards and associated language address
synchronous resources and is easily understood and applied.

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Response
Mark Gray - Edison Electric Institute - NA - Not Applicable - NA - Not Applicable
Answer

Document Name
Comment
We do not support the proposed definition for IBR unit. Given the linkage between IBR and IBR Unit, we cannot support this definition until the core IBR
definition is resolved.
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Daniela Atanasovski - APS - Arizona Public Service Co. - 1
Answer

Document Name
Comment
AZPS supports the following comments that were submitted by EEI on behalf of its members:
We do not support the proposed definition for IBR unit. Given the linkage between IBR and IBR Unit, we cannot support this definition until the core IBR
definition is resolved.
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Response
Kenya Streeter - Edison International - Southern California Edison Company - 1,3,5,6
Answer

Document Name
Comment
See comments submitted by the Edison Electric Institute
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Response
Selene Willis - Edison International - Southern California Edison Company - 5
Answer

Document Name
Comment
“See comments submitted by the Edison Electric Institute”
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Response
Wayne Sipperly - North American Generator Forum - 5 - MRO,WECC,Texas RE,NPCC,SERC,RF
Answer

Document Name
Comment
The NAGF does not support the proposed IBR Unit definition draft #1 for the following reasons:
a. Utilizing the term IBR Unit to refer to a single inverter within the generating plant will cause significant confusion at the plant level. Unless any
instruction provided to the plant is written, then it will not be clear if the term IBR Unit is the defined term used by NERC or if it is intended to mean the
generating unit (Unit 1, 2 or 3), IBR unit. This level of potential confusion is unacceptable resulting in an unacceptable risk of the BES being
misoperated. The word “unit” has long been associated with a distinct operating segment of a plant. For this reason, the NAGF does not support the use
of the term unit to mean anything less than the dispatchable grouping of inverters.
The NAGF recommends the following alternative definition for IBR Unit:
IBR Unit: All or part of an Inverter-Based Resource that is operated as a single resource. An IBR Unit may consist of one or more IBR Devices.
In addition, the NAGF recommends the creation of the definition for IBR Device:
IBR Device: An individual device, or a grouping of multiple devices, (including equipment connected to the DC terminal of the inverter) that includes
power electronic interface(s), such as an inverter or converter, capable of exporting Real Power from a primary energy source or energy storage
system, and that connects at a single point on the collector system.
These proposed alternative definitions will enable applicable NERC standards to be clear when a protection device or modeling information is needed at
the device or unit level without causing confusion. While normally the use of the IEEE definition would be supported, in this case it is likely to cause
more problems and uncertainty for the industry.
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Document Name
Comment
Evergy supports and incorporates by reference the comments of the Edison Electric Institute (EEI), MRO NSRF and the NAGF for question #2.
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Tammy Porter - Tammy Porter On Behalf of: Byron Booker, Oncor Electric Delivery, 1; - Tammy Porter
Answer

Document Name
Comment
Again we echo our previous comment in the IBR definition, chiefly that the NERC I4 BES definition needs to be explicitly stated or reflected in this
definition. The labor and cost of the compliance effort would not serve the customer well if we needed to incorporate all connected IBR units outside of
the I4 definition.
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Response
Jennifer Bray - Arizona Electric Power Cooperative, Inc. - 1
Answer

Document Name
Comment
AEPC signed on to ACES comments:
Similar to our interpretation of the IBR definition, as stated above, we believe the currently proposed IBR Unit definition contains superfluous language
that overlaps the proposed IBR definition and should be modified. It is our opinion that the IBR unit definition should
utilize a standalone technologically agnostic approach. Therefore, we are in favor of removing all references to multiple devices within this single unit

definition. We recommend that the IBR Unit definition be modified as follows:
•

“An individual device that uses a power electronic interface(s), such as an inverter or converter, that is capable of exporting Real Power from a
primary energy source or energy storage system.”

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Response
Stephen Stafford - Stephen Stafford On Behalf of: Greg Davis, Georgia Transmission Corporation, 1; - Stephen Stafford
Answer

Document Name
Comment
The IBR Unit definition lacks clarity in the last part of the definition. GTC recommends rewording this part of the definition as follows: “An individual
device, or a grouping of multiple devices, that uses a power electronic interface(s), such as an inverter or converter, capable of exporting Real Power
from a primary energy source or energy storage system, and that are electrically connected on a collector system.”
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Response
Christine Kane - WEC Energy Group, Inc. - 3, Group Name WEC Energy Group
Answer

Document Name
Comment
WEC Energy Group supports the comments of the NAGF, the MRO NSRF and EEI.
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Response
Michael Whitney - Northern California Power Agency - 3,4,5,6
Answer
Document Name

Comment
See response to question 1. BES needs to be included here too. Connected to a BES collector.

Likes

Dislikes

Document Name
Comment
See response to question 1. BES needs to be included here too. Connected to a BES collector.
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Response
Marty Hostler - Northern California Power Agency - 4
Answer

Document Name
Comment
See response to question 1. BES needs to be included here too. Connect to a BES collector.
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Response
Anna Todd - Southern Indiana Gas and Electric Co. - 3,5,6 - RF
Answer
Document Name
Comment

SIGE recommends adding Reactive Power language to the proposed definition.
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Response
Ben Hammer - Western Area Power Administration - 1
Answer

Document Name
Comment
There should not be two separate definitions. IBR should be defined to address the resource itself. The term F(f)acility(1) can be included when
necessary to refer to a group of IBRs and the equipment associated with the group. This is the how Standards and associated language address
synchronous resources and is easily understood and applied. Additionally, the use of the term unit adds potential additional confusion based on the
understanding and usage of the term for synchronous generation.
1: Facility as defined in the NERC Glossary of Terms, “A set of electrical equipment that operates as a single Bulk Electric System Element (e.g., a line,
a generator, a shunt compensator, transformer, etc.)”
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Dennis Chastain - Tennessee Valley Authority - 1,3,5,6 - SERC
Answer

Document Name
Comment
The proposed definition includes the phrase “capable of exporting Real Power”. They can also “import” power when used as a sink for energy storage
systems. They are also not limited to “Real Power” as they can also produce “Reactive Power” such as synthetic inertia.
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Response
James Keele - Entergy - 3
Answer

Document Name
Comment
Entergy recommend changing IBR Unit definition to the following.

IBR Unit: An individual device, or a grouping of multiple devices, that uses a power electronic interface(s), such as an inverter or converter, capable of
exporting Real Power from a primary energy source or energy storage system, and that connect together at the collector substation.
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Response
Jennifer Neville - Western Area Power Administration - 6
Answer

Document Name
Comment
There should not be two separate definitions. IBR should be defined to address the resource itself.
The NERC defined term "Facility" can be included when necessary to refer to a group of IBRs and the equipment associated with the group.
Additionally, the use of the term unit adds potential additional confusion based on the understanding and usage of the term for synchronous generation.
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Rachel Schuldt - Rachel Schuldt On Behalf of: Rachel Schuldt, Black Hills Corporation, 5, 1, 3, 6; - Black Hills Corporation - 6
Answer

Document Name
Comment
Black Hills Corporation supports NAGF and EEI comments.
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Response

Carly Miller - Carly Miller On Behalf of: Josh Combs, Black Hills Corporation, 5, 1, 3, 6; - Carly Miller
Answer

Document Name
Comment
Black Hills Corporation supports NAGF and EEI comments.
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Response
Micah Runner - Black Hills Corporation - 1
Answer

Document Name
Comment
Black Hills Corporation supports NAGF and EEI comments.
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Response
Sheila Suurmeier - Black Hills Corporation - 5
Answer

Document Name
Comment
Black Hills Corporation supports NAGF and EEI comments.
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Response
Srikanth Chennupati - Entergy - Entergy Services, Inc. - 1,3,5,7 - SERC
Answer

Document Name
Comment
Entergy recommend changing IBR Unit definition to the following.

Dislikes

Response
Casey Perry - PNM Resources - 1,3 - WECC,Texas RE
Answer

Document Name
Comment
PNM and TNMP supports EEI comments but also provide specific recommended changes to the IBR definition.
IBR Unit: Device(s) that uses a power electronic interface(s), such as an inverter or converter, capable or exporting Real Power from a primary energy
source or energy storage system, and that connect at a single point on the collector system.
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Anna Martinson - MRO - 1,2,3,4,5,6 - MRO, Group Name MRO Group
Answer

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Lincoln Electric System, 5, Millard Brittany
0

Response
Andy Thomas - DTE Energy - 1,3,5,6 - SERC,RF
Answer

Document Name
Comment
Duke Energy provides the following guidance: Delete the proposed NERC IBR Unit definition and substitute the IEEE 2800 “IBR Unit” definition. The
IEEE2800 definition is well vetted within the industry and serves the NERC intended purpose for this application.
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Response
Ruchi Shah - AES - AES Corporation - 5
Answer

Document Name
Comment
AES Clean Energy supports NAGF’s comments, and NAGF’s proposed definition for IBR Unit as well as creation of a new term called IBR Device.
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Response
Mark Garza - FirstEnergy - FirstEnergy Corporation - 4, Group Name FE Voter
Answer

Document Name
Comment
We do not support the proposed definition for IBR unit. Given the linkage between IBR and IBR Unit, we cannot support this definition until the core IBR
definition is resolved.

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Response
Ryan Quint - Elevate Energy Consulting - NA - Not Applicable - NA - Not Applicable, Group Name Elevate Energy Consulting
Answer

Document Name
Comment
The drafting team has presented a good draft definition of IBR Unit but the proposed definition includes some technical issues that could create
challenges, inconsistencies, and applicability challenges when used in the NERC Reliability Standards. These issues should be further vetted and
considered by the drafting team for the next iteration. Potential issues include:
1. The proposed term uses “Real Power”, which significantly restricts the use of the IBR definition above. In the proposed term, IBR Unit must
export Real Power whereas the proposed IBR definition as a whole is defined as “electric power” (no specification of Real Power or Reactive
Power). Therefore, this definition as proposed precludes STATCOMs, SVCs, and HVDC circuits from being considered IBRs in NERC
standards. This will require significant clarifying language to address within every standard where these types of inverter-based devices and
technologies should be considered. As NERC has initiated projects to more directly pull in these resources to applicable standards, it would be
a significant misstep to not include them in the IBR definition.
o Note that this broader term for IBR has been used for over 7 years by NERC and is described clearly in the NERC IBR Risk Mitigation
Strategy (https://www.nerc.com/comm/Documents/NERC_IBR_Strategy.pdf). Risks posed to the BPS related to IBRs are across all
resource types, not just generating resources. Stability studies conducted by NERC and stakeholders following the Blue Cut Fire and
Canyon 2 Fire disturbances highlighted that momentary cessation of solar PV IBRs would then cause unexpected and unwanted
blocking on a major HVDC circuit in the Western Interconnection, which would subsequently cause instability, uncontrolled separation,
and cascading. Ensuring reliable performance, accurate modeling, and sufficiently detailed studies of all these devices and resources is
critical to reliable operation of the BPS.
o Similarly, the phrase “from a primary energy source or energy storage system” can add some confusion as well, as it has nothing to do
with the IBR Unit itself. For example, STATCOMs, SVCs, and HVDC then do not meet this definition (or only implicitly, at best), which
relates to the added confusion above.
2. The proposed definition states “that connect together at a single point on the collector system,” implying that the common connection must be
on the collector system for all IBR Units. This is often not the case, such as with wind collector systems aggregating at the substation. Minor
issue, but one that should possibly be clarified in future revision. The SDT could consider something like “that connect to single point(s) of
connection through a collector system.”
A definition such as the following may be more appropriate: “An individual device or a grouping of multiple devices that uses a power electronic
interface(s), such as an inverter or converter.”
Likes

Dislikes

Response
Sean Bodkin - Dominion - Dominion Resources, Inc. - 6, Group Name Dominion
Answer

Document Name
Comment
Please see previous comment.
Likes

Dislikes

Response
Kristina Marriott - Miller Bros. Solar, LLC - 5 - MRO,WECC,Texas RE
Answer

Document Name
Comment
The DT specifically mentions the differences between inverter and converter within the Background of the proposed definition. We recommend that
these "definitions" be included as part of the overall unit definition. Furthermore, converter should be its own definition. This may help the inclusion and
exclusion of such units for specific standards.
"An inverter is a power electronic device that inverts DC power to AC sinusoidal power. A rectifier is a power electronic device that rectifies AC
sinusoidal power to DC power. A converter is a power electronic device that performs rectification and/or inversion. "
Since a battery energy storage system may have both, we recommend a detailed definition of BESS unit. We do understand the initial mindset of the
DT, separating these out may make it easier for future standards (Modeling, Protection studies, Performance, CIP, Maintenance, etc).
Likes

Dislikes

Response
Constantin Chitescu - Ontario Power Generation Inc. - 5
Answer

Yes

Document Name
Comment
OPG supports NPCC Regional Standards Committee’s comments.
Likes

Dislikes
Response

Ruida Shu - Northeast Power Coordinating Council - 1,2,3,4,5,6,7,8,9,10 - NPCC, Group Name NPCC RSC
Answer

Yes

Document Name
Comment
NPCC RSC supports the definition for IBR Unit as proposed.
Likes

Dislikes

Response
Colby Galloway - Southern Company - Southern Company Services, Inc. - 1,3,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name Southern
Company
Answer

Yes

Document Name
Comment
Southern Company understands that the IBR Unit definition is essentially addressing the power conversion device at most typical DC-to-AC type and
AC-DC-AC type electric generating stations. Southern Company respectfully requests that additional examples be provided to further clarify the
various configurations that typically exist at IBR facilities, including AC-DC-DC converters, solar plant string inverters, individual inverter modules,
groups of modules, etc., and to, in each case, identify which parts are to be considered the IBR Unit or IBR Units. Further, Southern Company believes
that this is essential based on the probable use of these definitions as seen in the use of IBR Unit in MOD-026-2 Draft 3 (Jun 2022).
Likes

Dislikes

Response
Kimberly Turco - Constellation - 6
Answer

Yes

Document Name
Comment
Constellation has no additional comments

Kimberly Turco on behald of Constellation Segments 5 and 6

Likes

Dislikes

Response
Alison MacKellar - Constellation - 5
Answer

Yes

Document Name
Comment
Constellation has no additional comments.
Alison Mackellar on behalf of Constellation Segments 5 and 6.
Likes

Dislikes

Yes

Document Name
Comment
PG&E supports the IBR Unit definition.
Likes

Dislikes

Response
Duane Franke - Manitoba Hydro - 1,3,5,6 - MRO
Answer

Yes

Document Name
Comment
The IEEE definition says may include unit transformer in the IBR unit definition. There may be some confusion when the other equipment
(ex.transformer) is to be included; at the IBR unit level or IBR plant/facility level?

Likes

Dislikes

Response
Kinte Whitehead - Exelon - 1,3
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Colin Chilcoat - Invenergy LLC - 6
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Russell Jones - Invenergy LLC - 5
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Matt Lewis - Lower Colorado River Authority - 1,5

Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Teresa Krabe - Lower Colorado River Authority - 5
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Joshua London - Eversource Energy - 1, Group Name Eversource
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Daniel Gacek - Exelon - 1
Answer

Yes

Document Name
Comment
Likes

Dislikes

Yes

Document Name
Comment
Likes

Dislikes

Response
Diana Aguas - CenterPoint Energy Houston Electric, LLC - 1 - Texas RE
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Donna Wood - Tri-State G and T Association, Inc. - 1
Answer

Yes

Document Name
Comment
Likes

Dislikes
Response

Tracy MacNicoll - Utility Services, Inc. - 4
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Jesus Sammy Alcaraz - Imperial Irrigation District - 1
Answer

Yes

Document Name
Comment
Likes

Dislikes

Yes

Document Name
Comment
Likes

Dislikes

Response
Stephen Whaite - Stephen Whaite On Behalf of: Lindsey Mannion, ReliabilityFirst , 10; - Stephen Whaite, Group Name ReliabilityFirst Ballot
Body Member and Proxies
Answer
Document Name
Comment

Yes

Likes

Dislikes

Response
Mohamad Elhusseini - DTE Energy - Detroit Edison Company - 3,5
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Adrian Andreoiu - BC Hydro and Power Authority - 1, Group Name BC Hydro
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Mike Magruder - Avista - Avista Corporation - 1
Answer

Yes

Document Name
Comment
Likes

Dislikes
Response

Cain Braveheart - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Diane E Landry - Public Utility District No. 1 of Chelan County - 1, Group Name CHPD
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thomas Foltz - AEP - 5
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Nikki Carson-Marquis - Nikki Carson-Marquis On Behalf of: Theresa Allard, Minnkota Power Cooperative Inc., 1; - Nikki Carson-Marquis
Answer
Document Name
Comment

No. Minnkota Power Cooperative supports the reasoning provided in the ACES comments.
Likes

Dislikes
Response

3. Provide any additional comments for the DT to consider, if desired.
Duane Franke - Manitoba Hydro - 1,3,5,6 - MRO
Answer
Document Name
Comment
·
The IBR definition states that an IBR can be connected to the transmission, sub-transmission, and distribution systems. However, the last bullet
of the background in the IBR definition documents says that DER-related projects may or may not need to use the same definition of IBR/IBR units. It is
suggested that NERC collaborate with different departments to use the same definition and to reduce confusion.
·
What about the IBR unit and IBR plant auxiliary equipment? Does it belong to the IBR and IBR units? More clarity is required to the IBR/IBR unit
definition regarding auxiliary equipment.
·
It is not clear how the terms IBR & IBR Unit fit in with the term dispersed power producing resource. If an IBR is also a dispersed power producing
resource, what term is MOD 26-2 going to use? IBRs or the BES inclusion term using dispersed power producing (generating) resource.
Likes

Dislikes

Response
Diane E Landry - Public Utility District No. 1 of Chelan County - 1, Group Name CHPD
Answer
Document Name
Comment
Further clarification requested regarding whether the definition is for IBRs applied to the BES, or for all categories of IBRs. MOD-026 currently limits
scope to BES under ‘Applicability’ of the MOD-026 standard. However, since the new term is defined apart from the MOD-026 standard, it is
recommended that BES applicability be included in the definition, so the application of the term is consistent with MOD-026 units, should the term be
used elsewhere. The concern is that the term could be used beyond the scope of units defined under MOD-026 if this BES is not clarified; for example,
a 1 MW PV unit connected to a distribution system would fall under the scope of the proposed definition, although it is neither BES nor in-scope under
MOD-026.
Likes

Dislikes

Response
Ryan Quint - Elevate Energy Consulting - NA - Not Applicable - NA - Not Applicable, Group Name Elevate Energy Consulting
Answer

Document Name
Comment
1. The definitions are leveraging IEEE 2800-2022 as a reference; however, there are notable differences between definitions. Most importantly,
IEEE 2800-2022 is careful in its consideration of supplemental IBR, defined as “any equipment within an IBR plant, which may or may not be
inverter-based…” These could include capacitor banks, STATCOMs, harmonic filters, protection systems, plant-level controllers, etc., which
should all be considered as part of the overall IBR facility. If the resource (or part of the resource) is deemed “IBR”, then all applicable
components that support that resource (such as those listed above) should be considered part of the IBR.
2. The drafting team should consider how these definitions will apply to hybrid/co-located resources. Some consideration and clarifications, if
needed, could be useful as the terms get used in NERC Reliability Standards. Growth of hybrid resources across the BPS will make this a
notable issue moving forward, so careful consideration of this topic now will be most effective.
Likes

Dislikes

Response
Mark Garza - FirstEnergy - FirstEnergy Corporation - 4, Group Name FE Voter
Answer
Document Name
Comment
None.
Likes

Dislikes

Response
Michael Johnson - Michael Johnson On Behalf of: Frank Lee, Pacific Gas and Electric Company, 3, 1, 5; Marco Rios, Pacific Gas and Electric
Company, 3, 1, 5; Sandra Ellis, Pacific Gas and Electric Company, 3, 1, 5; - Michael Johnson, Group Name PG&E All Segments
Answer
Document Name
Comment
PG&E thanks the Drafting Team's effort in creating an IBR definition that can be used throughout the industry for other current and future standards
development work.
Likes

Dislikes
Response

Ruchi Shah - AES - AES Corporation - 5
Answer
Document Name
Comment
AES Clean Energy recommends most of the Background section (except the last two main bullets) of the IBR Definition document be included in a
separate document (such as a technical rationale or implementation guidance).
Likes

Dislikes

Response
Andy Thomas - DTE Energy - 1,3,5,6 - SERC,RF
Answer
Document Name
Comment
None.
Likes

Dislikes

Response
Anna Martinson - MRO - 1,2,3,4,5,6 - MRO, Group Name MRO Group
Answer
Document Name
Comment
IBR: A single generating unit of generating Facility as identified through Inclusion I2 or I4 of the BES Definition that utilizes a power electronic interface
to convert its self-generated(1) DC electricity to AC electricity for the primary purpose of supplying power to the Bulk Power System.
1: This includes DC electricity that is discharged from devices such as batteries and fuel cells.
Likes

Dislikes
Response

Lincoln Electric System, 5, Millard Brittany
0

Casey Perry - PNM Resources - 1,3 - WECC,Texas RE
Answer
Document Name
Comment
Request SDT to provide a full list of specific IBR devices that will be covered under this definition.
Likes

Dislikes

Response
Srikanth Chennupati - Entergy - Entergy Services, Inc. - 1,3,5,7 - SERC
Answer
Document Name
Comment
Clarify how these IBR and IBR Unit definitions will interact with other projects proposed definitions for DERs.
Likes

Dislikes

Response
Israel Perez - Israel Perez On Behalf of: Mathew Weber, Salt River Project, 3, 1, 6, 5; Sarah Blankenship, Salt River Project, 3, 1, 6, 5; Thomas
Johnson, Salt River Project, 3, 1, 6, 5; Timothy Singh, Salt River Project, 3, 1, 6, 5; - Israel Perez
Answer
Document Name
Comment
SRP does not support the addition or modification of this term and simply adding it to Reliability Standards that previously did not have IBR applicability.
SRP strongly feels IBRs should have separate standards.
Likes

Dislikes

Response
Sheila Suurmeier - Black Hills Corporation - 5

Answer
Document Name
Comment
Black Hills Corporation supports NAGF comments.
Likes

Dislikes

Response
Micah Runner - Black Hills Corporation - 1
Answer
Document Name
Comment
Black Hills Corporation supports NAGF comments.
Likes

Dislikes

Response
Carly Miller - Carly Miller On Behalf of: Josh Combs, Black Hills Corporation, 5, 1, 3, 6; - Carly Miller
Answer
Document Name
Comment
Black Hills Corporation supports NAGF comments.
Likes

Dislikes

Response
Rachel Schuldt - Rachel Schuldt On Behalf of: Rachel Schuldt, Black Hills Corporation, 5, 1, 3, 6; - Black Hills Corporation - 6
Answer
Document Name

Comment
Black Hills Corporation supports NAGF comments.
Likes

Dislikes

Response
Alison MacKellar - Constellation - 5
Answer
Document Name
Comment
Constellation has no additional comments.
Alison Mackellar on behalf of Constellation Segments 5 and 6.
Likes

Dislikes

Response
Jennifer Neville - Western Area Power Administration - 6
Answer
Document Name
Comment
Suggested IBR definition: A single generating unit of generating facility as identified through Inclusion I2 or I4 of the BES Definition that utilizes a
power electronic interface to convert its self-generated(1) DC electricity to AC electricity for the primary purpose of supplying power to the Bulk Power
System.
(1): This includes DC electricity that is discharged from devices such as batteries and fuel cells.
Likes

Dislikes

Response
Kimberly Turco - Constellation - 6
Answer

Document Name
Comment
Constellation has no additional comments

Kimberly Turco on behald of Constellation Segments 5 and 6
Likes

Dislikes

Response
James Keele - Entergy - 3
Answer
Document Name
Comment
Clarify how these IBR and IBR Unit definitions will interact with other projects proposed definitions for DERs.
Likes

Dislikes

Response
Ben Hammer - Western Area Power Administration - 1
Answer
Document Name
Comment
IBR: A single generating unit of generating Facility as identified through Inclusion I2 or I4 of the BES Definition that utilizes a power electronic interface
to convert its self-generated(1) DC electricity to AC electricity for the primary purpose of supplying power to the Bulk Power System.
1: This includes DC electricity that is discharged from devices such as batteries and fuel cells.
Likes

Dislikes
Response

Donna Wood - Tri-State G and T Association, Inc. - 1
Answer
Document Name
Comment
NA
Likes

Dislikes

Response
Nikki Carson-Marquis - Nikki Carson-Marquis On Behalf of: Theresa Allard, Minnkota Power Cooperative Inc., 1; - Nikki Carson-Marquis
Answer
Document Name
Comment
Minnkota Power Cooperative appreciates the SDT's efforts to define impactful terms. MPC recommends distinguishing "IBR" and
"IBR Unit" terms from those of the same name in IEEE 2800-2022 to avoid conflating the two entities' similar terminology.
Likes

Dislikes

Response
Anna Todd - Southern Indiana Gas and Electric Co. - 3,5,6 - RF
Answer
Document Name
Comment
N/A
Likes

Dislikes

Response
Marty Hostler - Northern California Power Agency - 4
Answer

Document Name
Comment
None.
Likes

Dislikes

Response
Michael Whitney - Northern California Power Agency - 3,4,5,6
Answer
Document Name
Comment
No
Likes

Dislikes

Response
Christine Kane - WEC Energy Group, Inc. - 3, Group Name WEC Energy Group
Answer
Document Name
Comment
No additional comments
Likes

Dislikes

Response
Jennifer Bray - Arizona Electric Power Cooperative, Inc. - 1
Answer
Document Name
Comment

AEPC signed on to ACES comments:
We at ACES appreciate the effort put forth by the Drafting Team in developing these proposed definitions. We especially appreciate the fact that the
Drafting Team used an industry standard source (IEEE 2800-2022) as a starting point for their efforts. While we do not completely
agree with the exact language as currently proposed, we do agree with the overall premise utilized by the Drafting team.
Thank you for the opportunity to comment.

Likes

Dislikes

Response
Wayne Sipperly - North American Generator Forum - 5 - MRO,WECC,Texas RE,NPCC,SERC,RF
Answer
Document Name
Comment
The NAGF provides the following additional comments for consideration:
a.

The proposed Inverter-Based Resources (IBR) Definitions – Background section

i. General – this section provides supporting information that is critical to understanding the IBR Definitions and therefore should be memorialized in a
technical rational or similar document.
ii. Bullet # 7 – the entire collocated synchronous generation and BESS facility should not be considered an IBR; only the IBR portion of the facility (i.e.
the BESS) should be considered IBR. Recommend revising the language to clarify.
Likes

Dislikes

Response
Selene Willis - Edison International - Southern California Edison Company - 5
Answer
Document Name
Comment
“See comments submitted by the Edison Electric Institute”
Likes

Dislikes

Response
Romel Aquino - Edison International - Southern California Edison Company - 3
Answer
Document Name
Comment
See comments submitted by the Edison Electric Institute
Likes

Dislikes

Response
Kenya Streeter - Edison International - Southern California Edison Company - 1,3,5,6
Answer
Document Name
Comment
See comments submitted by the Edison Electric Institute
Likes

Dislikes

Response
Daniela Atanasovski - APS - Arizona Public Service Co. - 1
Answer
Document Name
Comment
None
Likes

Dislikes
Response

Gail Elliott - Gail Elliott On Behalf of: Michael Moltane, International Transmission Company Holdings Corporation, 1; - Gail Elliott
Answer
Document Name
Comment
ITC supports the comments provided by MRO NSRF
Likes

Dislikes

Response
Colby Galloway - Southern Company - Southern Company Services, Inc. - 1,3,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name Southern
Company
Answer
Document Name
Comment
None
Likes

Dislikes

Response
Joshua London - Eversource Energy - 1, Group Name Eversource
Answer
Document Name
Comment
There appears to be confusing circular logic with calling the second definition IBR Unit. By shortening to “IBR” you are stating it is previously defined,
but the definition of Inverter-Based Resource relies upon the definition of “IBR Unit”. Change “IBR Unit” to “Inverter-Based Resource Unit.
Likes

Dislikes
Response

Teresa Krabe - Lower Colorado River Authority - 5
Answer
Document Name
Comment
IBRs do not have an electromagnetic link to grid power which can extract stored inertial energy.
Likes

Dislikes

Response
Matt Lewis - Lower Colorado River Authority - 1,5
Answer
Document Name
Comment
IBRs do not have an electromagnetic link to grid power which can extract stored inertial energy.
Likes

Dislikes

Response
Steven Rueckert - Western Electricity Coordinating Council - 10, Group Name WECC
Answer
Document Name
Comment
WECC appreciates the efforts and understands the difficulties in proposing definitions. WECC can support the defintionsif Implementation Guidance or
Definition Guidance (like the BES Reference Guide) with drawings that clearly depict the difference between an IBR and an IBR Unit as well as BES
relationship to eachare developed. This will get industry on the same page and the ERO Enterprise on the same page. Do not allow other uses such
as IBR plant or IBR Facility or hybrid IBR within the Implementation Guidance or any Standard. If there needs to be additional descriptors add it to the
definition—consistency in terminology will make applicability easier for everyone.
In slide 14 of the Dec 5 presentation, the example 6.3 verbiage appears to reflect IBR aspects and IBR Unit aspects but uses “Facility” for IBR. Are the
“enabled protective and limiting functions” directly tripping the IRB Unit(s) or IBR (versus Facility)? Or an IBR Facility?
Likes
Dislikes

0
0

Response
Shannon Mickens - Shannon Mickens On Behalf of: Joshua Phillips, Southwest Power Pool, Inc. (RTO), 2; - Shannon Mickens, Group Name
SPP RTO
Answer
Document Name
Comment
SPP recommends that the drafting team reference the IEEE 1547-2018 Standard in the background details since there are terms from that standard
has been included in the proposed definitions (for example electric power system (eps) and Energy storage system (ess).
Additionally, SPP recommends that the drafting team consider to coordinate with NERC staff to implement the definitions into the Rules of Procedures
(RoP) to ensure proper alignment with the proposed efforts associated with the Glossary of Terms.

Likes

Dislikes

Response
Russell Jones - Invenergy LLC - 5
Answer
Document Name
Comment
Invenergy supports the spirit of the definition proposed and does not offer any substantive changes. We do, however, have concerns about the
application of this definition to various reliability standards going forward. More specifically, Invenergy believes the drafting team should consider how
this broad definition will be applied in specific Reliability Standard requirements to different roles (transmission, sub-transmission, distribution) and
different technologies (PV, Type 3 and Type 4 wind, BESS, and fuel cell) where nuance may be required to account for technological limitations or
differences.
Likes

Dislikes

Response
Jodirah Green - ACES Power Marketing - 1,3,4,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name ACES Collaborators
Answer
Document Name
Comment

We at ACES appreciate the eﬀort put forth by the Drafting Team in developing these proposed deﬁnitions. We especially appreciate the fact that the
Drafting Team used an industry standard source (IEEE 2800-2022) as a starting point for their eﬀorts. While we do not completely
agree with the exact language as currently proposed, we do agree with the overall premise utilized by the Drafting team.
Thank you for the opportunity to comment.

Likes

Dislikes

Response
LaTroy Brumfield - American Transmission Company, LLC - 1
Answer
Document Name
Comment
Below is a consideration for an updated definition of IBR.
IBR: A single generating unit or generating Facility that utilizes a power electronic interface to convert its self-generated(1) DC electricity to AC
electricity for the primary purpose of supplying power to the Bulk Power System.
1: This includes DC electricity that is discharged from devices such as batteries and fuel cells. Self-generated also implies that FACTs devices that
simply convert power do not apply to this definition.
Likes

Dislikes

Response
Charles Yeung - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC, Group Name SRC 2023
Answer
Document Name
Comment
The SRC notes the inconsistent use of “electric power system” and “electric system” throughout various definitions in the NERC Glossary and
recommends NERC give some thought to standardizing this language in the future.

Likes

Dislikes

Response
Elizabeth Davis - Elizabeth Davis On Behalf of: Thomas Foster, PJM Interconnection, L.L.C., 2; - Elizabeth Davis
Answer
Document Name
Comment
PJM recommends the following concise axioms in managing future updates:
1)

All IBRs are comprised of one or more IBR Units.

An IBR unit is a generator that employs inverter(s) to create power.

To be an IBR unit, the DC side must be able to generate power onto the AC side past the POI.

An IBR unit may also consume power, but to be an IBR unit, axiom 3 must be met.

IBRs are the combination of IBR units, conversion (inverter), and AC equipment up to a POI.

Likes

Dislikes

Response
Kennedy Meier - Electric Reliability Council of Texas, Inc. - 2
Answer
Document Name
Comment
ERCOT joins the comments submitted by the IRC SRC and adopts them as its own.
Likes

Dislikes

Response
Constantin Chitescu - Ontario Power Generation Inc. - 5
Answer

Document Name
Comment
OPG supports NPCC Regional Standards Committee’s comments.
Likes

Dislikes
Response

Consideration of Comments
Project Name:

2020-06 Verifications of Models and Data for Generators | Draft 1 of IBR Definitions

Comment Period Start Date: 11/16/2023
Comment Period End Date: 1/9/2024
Associated Ballot(s):

2020-06 Verifications of Models and Data for Generators IBR Unit IN 1 DEF
2020-06 Verifications of Models and Data for Generators IBR-related Definitions |
Implementation Plan IN 1 OT
2020-06 Verifications of Models and Data for Generators Inverter-Based Resource (IBR) IN 1 DEF

There were 73 sets of responses, including comments from approximately 179 different people from approximately 113
companies representing 10 of the Industry Segments as shown in the table on the following pages.
All comments submitted can be reviewed in their original format on the project page.
If you feel that your comment has been overlooked, let us know immediately. Our goal is to give every comment serious consideration in
this process. If you feel there has been an error or omission, contact Director, Standards Development Latrice Harkness (via email) or at
(404) 858-8088.

RELIABILITY | RESILIENCE | SECURITY

Questions
1. Do you support the definition for IBR as proposed, or with non-substantive changes? If you do not support the definition as
proposed, please explain the changes that, if made, would result in your support.
2. Do you support the definition for IBR Unit as proposed, or with non-substantive changes? If you do not support the definition as
proposed, please explain the changes that, if made, would result in your support.
3. Provide any additional comments for the DT to consider, if desired.
The Industry Segments are:

1 — Transmission Owners
2 — RTOs, ISOs
3 — Load-serving Entities
4 — Transmission-dependent Utilities
5 — Electric Generators
6 — Electricity Brokers, Aggregators, and Marketers
7 — Large Electricity End Users
8 — Small Electricity End Users
9 — Federal, State, Provincial Regulatory or other Government Entities
10 — Regional Reliability Organizations, Regional Entities

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Organization
Name
BC Hydro
and Power
Authority

MRO

Name
Adrian
Andreoiu

Anna
Martinson

Segment(s)
1

1,2,3,4,5,6

Region
WECC

MRO

Group Name
BC Hydro

MRO Group

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Group
Member
Name

Group
Group
Member
Member
Organization Segment(s)

Group
Member
Region

Hootan
Jarollahi

BC Hydro and 3
Power
Authority

WECC

Helen
Hamilton
Harding

BC Hydro and 5
Power
Authority

WECC

Adrian
Andreoiu

BC Hydro and 1
Power
Authority

WECC

Shonda
McCain

Omaha Public 1,3,5,6
Power District
(OPPD)

MRO

Michael
Brytowski

Great River
Energy

1,3,5,6

MRO

Jamison
Cawley

Nebraska
Public Power
District

1,3,5

MRO

Jay Sethi

Manitoba
Hydro (MH)

1,3,5,6

MRO

Husam AlHadidi

Manitoba
1,3,5,6
Hydro (System
Preformance)

MRO

Organization
Name

Name

Segment(s)

Region

Group Name

Group
Member
Name

Group
Member
Region

Kimberly
Bentley

Western Area 1,6
Power
Adminstration

MRO

Jaimin Patal

Saskatchewan 1
Power
Coporation
(SPC)

MRO

Angela Wheat Southwestern 1
Power
Administration

MRO

George Brown Pattern
Operators LP

MRO

Alliant Energy 4
(ALTE)

MRO

Larry Heckert

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Group
Group
Member
Member
Organization Segment(s)

Terry Harbour MidAmerican 1,3
Energy
Company
(MEC)

MRO

Dane Rogers

Oklahoma Gas 1,3,5,6
and Electric
(OG&E)

MRO

Seth
Shoemaker

Muscatine
Power &
Water

MRO

1,3,5,6

Organization
Name

Name

Southwest Charles
Power Pool, Yeung
Inc. (RTO)

WEC Energy Christine
Group, Inc. Kane

Segment(s)

Region

Group Name

MRO,SPP RE,WECC SRC 2023

WEC Energy
Group

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Group
Member
Name

Group
Group
Member
Member
Organization Segment(s)

Group
Member
Region

Bobbi Welch

Midcontinent 2
ISO, Inc.

MRO

Michael
Ayotte

ITC Holdings

MRO

Andrew
Coffelt

Board of
Public
UtilitiesKansas (BPU)

1,3,5,6

MRO

Charles Yeung SPP

MRO

Ali Miremadi

CAISO

WECC

Helen Lainis

IESO

NPCC

Bobbi Welch

Midcontinent 2
ISO, Inc.

MRO

Greg Campoli NYISO

NPCC

Elizabeth Davis PJM

Kennedy
Meier

Texas RE

Christine Kane WEC Energy
Group

Matthew
Beilfuss

Electric
Reliability
Council of
Texas, Inc.

WEC Energy
Group, Inc.

Organization
Name

Name

Southern
Colby
Company - Galloway
Southern
Company
Services, Inc.

Segment(s)

1,3,5,6

Region

Group Name

MRO,RF,SERC,Texas Southern
RE,WECC
Company

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Group
Member
Name

Group
Group
Member
Member
Organization Segment(s)

Group
Member
Region

Clarice Zellmer WEC Energy
Group, Inc.

David
Boeshaar

WEC Energy
Group, Inc.

Matt Carden

Southern
Company Southern
Company
Services, Inc.

SERC

Joel
Dembowski

Southern
Company Alabama
Power
Company

SERC

Ron Carlsen

Southern
Company Southern
Company
Generation

SERC

Leslie Burke

Southern
Company Southern
Company
Generation

SERC

Organization
Name

Name

Public Utility Diane E
District No. 1 Landry
of Chelan
County

ACES Power Jodirah
Marketing
Green

Segment(s)
1

1,3,4,5,6

Region

Group Name
CHPD

Group
Member
Name

Group
Member
Region

Joyce Gundry

Public Utility
District No. 1
of Chelan
County

WECC

Anne
Kronshage

Public Utility
District No. 1
of Chelan
County

WECC

Rebecca
Zahler

Public Utility
District No. 1
of Chelan
County

WECC

Hoosier
Energy
Electric
Cooperative

MRO,RF,SERC,Texas ACES
Bob Soloman
RE,WECC
Collaborators

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Group
Group
Member
Member
Organization Segment(s)

Kris Carper

Arizona
1
Electric Power
Cooperative,
Inc.

WECC

Scott Brame

North Carolina 3,4,5
Electric
Membership
Corporation

SERC

Organization
Name

Eversource
Energy

Name

Joshua
London

Segment(s)

FirstEnergy - Mark Garza 4
FirstEnergy
Corporation

Region

Group Name

Eversource

FE Voter

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Group
Member
Name

Group
Group
Member
Member
Organization Segment(s)

Group
Member
Region

Jason
Procuniar

Buckeye
Power, Inc.

Kevin Lyons

Central Iowa
Power
Cooperative

MRO

Amber Skillern East Kentucky 1
Power
Cooperative

SERC

Nick Fogleman Prairie Power, 1,3
Inc.

SERC

Kylee Kropp

MRO

Sunflower
1
Electric Power
Corporation

Austin Towne Western
Farmers
Electric
Cooperative

1,5

Texas RE

Joshua London Eversource
Energy

NPCC

Vicki O'Leary

NPCC

Eversource
Energy

Julie Severino FirstEnergy FirstEnergy
Corporation

Organization
Name

Michael
Johnson

Name

Michael
Johnson

Northeast
Ruida Shu
Power
Coordinating
Council

Segment(s)

Region

WECC

1,2,3,4,5,6,7,8,9,10 NPCC

Group Name

PG&E All
Segments

NPCC RSC

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Group
Member
Name

Group
Group
Member
Member
Organization Segment(s)

Group
Member
Region

Aaron
Ghodooshim

FirstEnergy FirstEnergy
Corporation

Robert Loy

FirstEnergy FirstEnergy
Solutions

Mark Garza

FirstEnergyFirstEnergy

1,3,4,5,6

Stacey
Sheehan

FirstEnergy FirstEnergy
Corporation

Marco Rios

Pacific Gas
and Electric
Company

WECC

Sandra Ellis

Pacific Gas
and Electric
Company

WECC

Frank Lee

Pacific Gas
and Electric
Company

WECC

NPCC

Gerry Dunbar Northeast
Power
Coordinating
Council

Organization
Name

Name

Segment(s)

Region

Group Name

Group
Member
Name

Group
Member
Region

Alain Mukama Hydro One
1
Networks, Inc.

NPCC

Deidre Altobell Con Edison

NPCC

Jeffrey
Streifling

NB Power
Corporation

NPCC

Michele
Tondalo

United
Illuminating
Co.

NPCC

Stephanie
Orange and
Ullah-Mazzuca Rockland

NPCC

Central
1
Hudson Gas &
Electric Corp.

NPCC

Randy Buswell Vermont
1
Electric Power
Company

NPCC

James Grant

NYISO

NPCC

John Pearson

ISO New
England, Inc.

NPCC

Harishkumar
Subramani
Vijay Kumar

Independent
Electricity
System
Operator

NPCC

Michael
Ridolfino

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Group
Group
Member
Member
Organization Segment(s)

Organization
Name

Name

Segment(s)

Region

Group Name

Group
Member
Name
Randy
MacDonald

Group
Group
Member
Member
Organization Segment(s)
New
Brunswick
Power
Corporation

NPCC

Dermot Smyth Con Ed Consolidated
Edison Co. of
New York

NPCC

David Burke

Orange and
Rockland

NPCC

Peter Yost

Con Ed Consolidated
Edison Co. of
New York

NPCC

Salvatore
Spagnolo

New York
Power
Authority

NPCC

Sean Bodkin

Dominion Dominion
Resources,
Inc.

NPCC

David Kwan

Ontario Power 4
Generation

NPCC

Silvia Mitchell NextEra
Energy Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Group
Member
Region

NPCC

Organization
Name

Name

Segment(s)

Region

Group Name

Group
Member
Name

Group
Group
Member
Member
Organization Segment(s)

Group
Member
Region

Florida Power
and Light Co.
Glen Smith

Entergy
Services

NPCC

Sean Cavote

PSEG

NPCC

Utility Services 5

NPCC

Jason Chandler Con Edison
Tracy
MacNicoll

Shivaz Chopra New York
Power
Authority

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

NPCC

Vijay Puran

New York
6
State
Department of
Public Service

NPCC

ALAN
ADAMSON

New York
State
Reliability
Council

NPCC

David Kiguel

Independent

NPCC

Joel Charlebois AESI

NPCC

Joshua London Eversource
Energy

NPCC

Organization
Name

Name

Segment(s)

Elevate
Energy
Consulting

Ryan Quint NA - Not
Applicable

Dominion Dominion
Resources,
Inc.

Sean Bodkin 6

Shannon
Mickens

Region

Group Name

NA - Not Applicable Elevate
Energy
Consulting
Dominion

MRO,SPP RE,WECC SPP RTO

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Group
Member
Name

Group
Group
Member
Member
Organization Segment(s)

Group
Member
Region

Ryan Quint

Elevate Energy
Consulting

NA - Not
Applicable

N/A

NA - Not
Applicable

Connie Lowe

Dominion Dominion
Resources,
Inc.

NA - Not
Applicable

Lou Oberski

Dominion Dominion
Resources,
Inc.

NA - Not
Applicable

Larry Nash

Dominion 1
Dominion
Virginia Power

NA - Not
Applicable

Rachel Snead

Dominion Dominion
Resources,
Inc.

NA - Not
Applicable

Shannon
Mickens

Southwest
Power Pool
Inc.

MRO

Mia Wilson

Southwest
Power Pool
Inc.

MRO

Organization
Name

Stephen
Whaite

Name

Stephen
Whaite

Segment(s)

Region

Group Name

ReliabilityFirst
Ballot Body
Member and
Proxies

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Group
Member
Name

Group
Group
Member
Member
Organization Segment(s)

Group
Member
Region

Josh Phillips

Southwest
Power Pool
Inc.

MRO

Darian
Richards

Southwest
2
Power Pool Inc

MRO

Jim William

Southwest
Power Pool
Inc.

MRO

Mason
Favazza

Southwest
Power Pool
Inc.

MRO

Scott Jordan

Southwest
Power Pool
Inc.

MRO

Will Tootle

Southwest
Power Pool
Inc.

MRO

Zach Sabey

Southwest
Power Pool
Inc.

MRO

Lindsey
Mannion

ReliabilityFirst 10

Stephen
Whaite

ReliabilityFirst 10

Organization
Name

Name

Western
Steven
Electricity
Rueckert
Coordinating
Council
Tim Kelley

Tim Kelley

Segment(s)

Region

Group Name
WECC

WECC

SMUD and
BANC

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Group
Member
Name

Group
Group
Member
Member
Organization Segment(s)

Group
Member
Region

Steve Rueckert WECC

WECC

Phil O'Donnell WECC

WECC

Nicole Looney Sacramento
3
Municipal
Utility District

WECC

Charles Norton Sacramento
6
Municipal
Utility District

WECC

Wei Shao

Sacramento
1
Municipal
Utility District

WECC

Foung Mua

Sacramento
4
Municipal
Utility District

WECC

Nicole Goi

Sacramento
5
Municipal
Utility District

WECC

Kevin Smith

Balancing
Authority of
Northern
California

WECC

Document Name
Comment
The Inverter Based Resource proposed definition includes distribution. GADS and other regional (ISO/RTO) definitions support BPS
(transmission and sub-transmission) and purposely leave out distribution systems (distributed energy resources (DERs)). We recommend
also having this delineation to help industry terms align. Thus, DER should have its own definition and a MW delineation or facility
descriptions as part of its definition. We believe having MW delineation may help approval odds of both definitions. This may also help
with the inclusions and exclusions of IBRs and DERs for upcoming standards.
Further we recommend that BESS Resource should be excluded from this definition, and should be its own definition. Separating these
items out may help the inclusion and exclusion of certain units/facilities. We also recommend that converter unit resources should be its
own definition. Reasoning for breaking these resources out as their own definition, makes it easier to include, exclude, delineate and
detail requirements for each kind of resource within upcoming standards. Example: EMT modeling requirements, event reporting, and
performances should differ between IBRs, BESS Resources and Converter Based Resources.
Also, many companies (GOs) are separating out their PV Plant as one legal entity and their BESS as another legal entity. With this in mind,
making separate definitions also helps these companies.
Likes

Dislikes

Response
1. This parenthetical has been removed, and further discussion about this topic is included in the technical rationale.
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

2. A table has been added to the technical rationale, and the list of technologies has been removed from the definition.
3. The language has been updated, but in general the SDT believes a BESS is an IBR whether it is charging or discharging. Reliability
Standards drafting teams will have the responsibility of deciding whether requirements apply in both modes or not. Additionally, the
DT wanted to define as few terms as possible. The commenter is welcome to submit a SAR in the future to address their concern.
4. Thank you for the comment. The DT has chosen to keep the BESS as part of the IBR definition.
5.
Duane Franke - Manitoba Hydro - 1,3,5,6 - MRO
Answer

Document Name
Comment
·
Item 4 in the background of the IBR definition documents indicates that the IBR is synonymous with the term “IBR plant/facility”,
where a step-up transformer, collector systems, main power transformers, power plant controllers, etc., all belong to the IBR. However,
these details are not mentioned in the IBR definition. Therefore, it is recommended to include these details in the IBR definition to clarify
the definition.
·
The isolated IBR, regardless of their energy resource, interconnecting via a dedicated VSC-HVDC transmission facility should be
included in the IBR definition.
Likes

Dislikes

Response
Please see the Technical Rationale.
This is included under the definition and the technical rationale explains this more thoroughly.
Sean Bodkin - Dominion - Dominion Resources, Inc. - 6, Group Name Dominion

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Answer

Document Name
Comment
The proposed defintion conflicts with the BES definition and also appears to be an attempt to expand NERC jurisidction into the
distribution system. The definition is expansive and goes beyond a defintoin of what an Inverter Based Resource is technically. Dominion
Energy recommends that NERC use the FERC definition of IBR: IBRs include solar photovoltaic, wind, fuel cell, and battery storage
resources powering electronic devices that change direct current power produced by these resources to alternating current power to be
transmitted on the BPS. The FERC definition clearly communicates that only resources that are intending to move power across the BPS
are a jurisdictional IBR and does not conflict with the existing and approved BES definition.
Dominion Energy also supports EEI comments.
Likes

Dislikes

Response
The updated definition stays silent on the applicability. In general, the SDT believes an IBR is an IBR regardless of the voltage class it is
connected to or the size. This is further described in the technical rationale.
Ryan Quint - Elevate Energy Consulting - NA - Not Applicable - NA - Not Applicable, Group Name Elevate Energy Consulting
Answer

Document Name
Comment

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

The drafting team has presented a good draft definition of IBR but the proposed definition includes some technical issues that could
create challenges, inconsistencies, and applicability challenges when used in the NERC Reliability Standards. These issues should be
further vetted and considered by the drafting team for the next iteration. Potential issues include:
1. The parenthetical “(transmission, sub-transmission, or distribution system)” encapsulates all IBRs connected to the power grid

which is a good approach to create a generic definition that can then be further specified for applicability to requirements.
However, the phrase could also be removed and the meaning would remain the same. So therefore, it may not be necessary to
add that level of specificity to the Glossary Term knowing that further clarification would be needed for applicability in the
Standards.
o IBRs connected to the distribution system are classified as distributed energy resources (DERs) and would need a separate
definition to classify them as such for any DER-related standards modifications.
2. The list of IBR technologies at the end of the definition is confusing in that it is unclear whether this list is inclusive or exclusive. As
written, one cannot clearly determine whether the list defines the types of resources that are considered IBRs or if they are simply
examples. There are other types of IBRs such as FACTS devices (STATCOMs, SVCs, etc.) and HVDC circuits that are not included in
this list. Therefore, as written, the definition will cause a significant amount of confusion and require significant clarifying language
in every standard where used.
3. The ERO Enterprise CMEP Practice Guide: Application of the Bulk Electric System Definition to Battery Energy Storage Systems and
Hybrid Resources Version 1 clarifies that BESS applicability is irrespective of charging and discharging. This is relevant to these
definitions in that the proposed IBR definition states “A source (or sink in the case of a charging BESS)” but it is unclear what value
the parenthetical addition brings to the definition. A BESS is a source of electric power when discharging and therefore could be
classified accordingly without the additional language. The drafting team should consider this when developing the definition
given the past precedence set with the Practice Guide. Similarly, if the team decides to keep it, it could be integrated into the
definition so there are less parentheticals throughout.
The following are supported in the definition:
1. The use of “electric power system” is likely a suitable term in that it is generic enough for a definition such as this. Again, without

the additional text that appears to be unnecessary, as described above.

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

A more fundamental definition such as the following may be just as useful for reference in NERC Standards: “A source of electric power
connected to the electric power system that consists of one or more IBR Unit(s) operated as a single resource at a common point of
connection.
Likes

Dislikes

Response
1. This parenthetical has been removed, and further discussion about this topic is included in the technical rationale.
2. A table has been added to the technical rationale, and the list of technologies has been removed from the definition.
3. The language has been updated, but in general the SDT believes a BESS is an IBR whether it is charging or discharging. Reliability
Standards drafting teams will have the responsibility of deciding whether requirements apply in both modes or not.
4. Language has been removed.
Mark Garza - FirstEnergy - FirstEnergy Corporation - 4, Group Name FE Voter
Answer

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

To address these concerns, either the IEEE definition of IBRs, as defined in IEEE 2800-2022 (IEEE Standard for Interconnection and
Interoperability of Inverter-Based Resources (IBRs) Interconnecting with Associated Transmission Electric Power Systems, See Section 3,
page 31) or the informal definition of IBRs as proposed by the FERC Commission on Nov. 17, 2023 should be leveraged.
Finally, consideration should be given to defining DERs separately noting these resources, while also inverter based, represent a specific
class of IBRs that are directly connected to the distribution system and in many cases serve a very different purpose outside of supporting
the reliability of the Bulk Power System.
Likes

Dislikes

Response
The updated definition stays silent on the applicability. In general, the SDT believes an IBR is an IBR regardless of the voltage class it is
connected to or the size. This is further described in the technical rationale.
Michael Johnson - Michael Johnson On Behalf of: Frank Lee, Pacific Gas and Electric Company, 3, 1, 5; Marco Rios, Pacific Gas and
Electric Company, 3, 1, 5; Sandra Ellis, Pacific Gas and Electric Company, 3, 1, 5; - Michael Johnson, Group Name PG&E All Segments
Answer

Document Name
Comment
PG&E does not support the definition of an IBR as written because it is too narrow to only define the listed 5 items as IBR
technologies. There are other generation types that use IBR technologies that produce MWs such as Flywheels, Tidal flows, etc… that if
left out, will result in future ambiguity. PG&E's recommendation is to either list other generation methods by name or the Drafting Team
(DT) should include in the requirement text “and other” to ensure emerging generation or technologies are not excluded to avoid future
modifications to the definition.
Likes
Dislikes

0
0

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Response
A table has been added to the technical rationale to help further clarify
Ruchi Shah - AES - AES Corporation - 5
Answer

Document Name
Comment
AES Clean Energy supports NAGF’s comments and NAGF’s proposed definition for IBR.
Likes

Dislikes

Response
Please see NAGF response.
Andy Thomas - DTE Energy - 1,3,5,6 - SERC,RF
Answer

Document Name
Comment
Duke Energy provides the following guidance: Delete proposed NERC IBR definition and substitute the IEEE 2800 “IBR Plant”
definition. The IEEE2800 definition is well vetted within the industry and serves the NERC intended purpose for this application. Note:
The proposed NERC IBR definition fits the IBR Plant definition from IEEE 2800.
Likes
Dislikes

0
0

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Response
The IEEE 2800 definition was used in this NERC definition, there is effectively no difference between them.
Anna Martinson - MRO - 1,2,3,4,5,6 - MRO, Group Name MRO Group
Answer

Document Name
Comment
MRO NSRF does not support the definition as written due to the following concerns:
The phrase “that is connected to the electric power system (transmission, sub-transmission, or distribution)” needs to be
removed. Language is unnecessary.
The sentence “IBRs include solar photovoltaic (PV), Type 3 and Type 4 wind, BESS, and fuel cell.” should be deleted. When possible,
language used in standards and definitions should be technology neutral.
The broadness of the definition generates ambiguity and will create difficultly in the application for NERC compliance. While identifying
specific resource applicability isn't the aim, the definition should provide a clear regulatory framework as a baseline for adherence to
NERC Reliability Standards.
Likes

Dislikes

Lincoln Electric System, 5, Millard Brittany
0

Response
The last sentence of the IBR definition was updated, and additional information provided in the Technical Rationale.

Casey Perry - PNM Resources - 1,3 - WECC,Texas RE

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Answer

Document Name
Comment
PNM and TNMP supports EEI comments but also provide recommended modification of the IBR definition.
Inverter Based Resource: A source of electric power that is connected to the and consists of one or more IBR Unit(s) operated as a single
resource at common point of interconnection. IBRs include but are not limited to solar photovoltaic (PV), Type 3 and Type 4 wind BESS,
and fuel cell.
Likes

Dislikes

Response
See EEI response.
Srikanth Chennupati - Entergy - Entergy Services, Inc. - 1,3,5,7 - SERC
Answer

Document Name
Comment
The definition of IBR is very vague.
Entergy recommends The Inverter Based Resource(IBR) definition should clearly state that this definition should apply to only
transmission connected facilities. Distribution connected facilities should be called DER in alignment with other NERC Posted guidelines.
Likes

Dislikes

Response
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

The updated definition stays silent on the applicability. In general, the SDT believes an IBR is an IBR regardless of the voltage class it is
connected to or the size. This is further described in the technical rationale.
Sheila Suurmeier - Black Hills Corporation - 5
Answer

Document Name
Comment
Black Hills Corporation supports NAGF and EEI Comments.
Likes

Dislikes

Response
See NAGF and EEI responses.
Micah Runner - Black Hills Corporation - 1
Answer

Document Name
Comment
Black Hills Corporation supports NAGF and EEI comments.
Likes

Dislikes

Response

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

See NAGF and EEI responses.
Carly Miller - Carly Miller On Behalf of: Josh Combs, Black Hills Corporation, 5, 1, 3, 6; - Carly Miller
Answer

Document Name
Comment
Black Hills Corporation supports NAGF and EEI comments.
Likes

Dislikes

Response
See NAGF and EEI responses.
Rachel Schuldt - Rachel Schuldt On Behalf of: Rachel Schuldt, Black Hills Corporation, 5, 1, 3, 6; - Black Hills Corporation - 6
Answer

Document Name
Comment
Black Hills Corporation supports NAGF and EEI comments.
Likes

Dislikes

Response
See NAGF and EEI responses.

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Jennifer Neville - Western Area Power Administration - 6
Answer

Document Name
Comment
•
•
•

Remove the phrase “that is connected to the electric power system (transmission, sub-transmission, or distribution)” as it is
unnecessary language.
Delete the sentence “IBRs include solar photovoltaic (PV), Type 3 and Type 4 wind, BESS, and fuel cell.” because the language is
not technology neutral.
The definition should provide a clarity for regulatory pruposes, currently the broadness of the definition generates ambiguity and
will create difficultly in the application for NERC compliance.

Likes

Dislikes

Response
•
•
•

Has been removed from the definition and clarified in the technical rationale.
Has been removed from the definition and clarified in the technical rationale.
The base definition can be further clarified in each NERC reliability standard by that SDT. IBR is ambiguous as it covers many
differing fuel sources.

Tracy MacNicoll - Utility Services, Inc. - 4
Answer

Document Name
Comment
"(transmission, sub-transmission, or distribution system)" is unnecessary for the definition. This clarification would be made in the
Applicability or Facilities section of a standard.

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

The last sentence should have "may include". If it is only those 4 generating types, the rest of the definition wouldn't be necessary.
Likes

Dislikes

Response
•
•

Has been removed from the definition and further clarified in the technical rationale
Has been added to say may include but not limited to, and was moved to the technical rationale

James Keele - Entergy - 3
Answer

Document Name
Comment
Entergy recommends The Inverter Based Resource(IBR) definition should clearly state that this definition should apply to only
transmission connected facilities. Distribution connected facilities should be called DER in alignment with other NERC Posted guidelines.
Likes

Dislikes

Document Name
Comment
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

The first sentence of the proposed definition includes the phrase “(or sink in the case of a charging battery energy storage system (BESS)”
which limits the applicability of an IBR to just BESS. Energy storage systems that could use IBRs are not limited to BESS - they could be
used in other energy storage technologies such as compressed gas, gravity based, etc. Also, using the word “or” limits the IBR to one or
the other, when it could be both. Suggest changing “or” to “and/or” and removing the word “battery” and “(BESS)” such that it reads “
“(and/or sink when used in conjunction with an energy storage system)”. Also, change “BESS” to “energy storage system” in the last
sentence.
The last sentence of the proposed definition includes the phrase “IBRs include solar photovoltaic (PV)… This seems to indicate that IBRs
are PVs, etc., when they actually only support them. Suggest changing the sentence to read “IBRs are typically used with solar
photovoltaic (PV), Type 3 and Type 4 wind, energy storage, and fuel cells.”
Likes

Dislikes

Response
Removed this language and moved it to the technical rationale to further clarify. The new language says may include but is not limited to.
Has been removed from the definition and moved to the technical rationale.
Zahid Qayyum - New York Power Authority - 5
Answer

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Additionally, it’s essential to explicitly include hybrid plants in the IBR definition, as the current background section lacks clarity on the
designated IBR portion. Besides, NYPA also recommends using Inverter Based Unit(s) instead of IBR Units (s) in the following sentence as
it intends to explain IBR itself:
“…and that consists of one or more IBR Unit(s) operated as a single resource at a common point of interconnection…”
Likes

Dislikes

Response
1. SDT agrees and has moved this to the technical rationale with examples
2. This is the intent, every inverter is an IBR unit, the resource or IBR as a whole is comprised of those units. This aligns with the IEEE
2800 definition.
3. The definition does not exclude Hybrid IBRs, no change is needed here.
Ben Hammer - Western Area Power Administration - 1
Answer

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Likes

Dislikes

Response
•
•
•

Has been removed from the definition and clarified in the technical rationale
Has been removed from the definition and clarified in the technical rationale
The base definition can be further clarified in each NERC reliability standard by that SDT. IBR is ambiguous as it covers many
differing fuel sources.

Donna Wood - Tri-State G and T Association, Inc. - 1
Answer

Document Name
Comment
Either delete the sentence “IBRs include solar photovoltaic (PV), Type 3 and Type 4 wind, BESS, and fuel cell.” all together or add "may
include". .
Likes

Dislikes

Response
Has been removed, and added “may include but not limited to” language in the technical rationale.
Marty Hostler - Northern California Power Agency - 4
Answer

Document Name
Comment

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

BES needs to be included in the Definition.
We already have experience with regulators making up their own interpretation when "BES" is not included. For example, in CIP-002-5.1a
IRC 2.11 Auditors claim since BES is not before the word generation, GOP's must include non-BES generation in their Control Center
assessments. Even though a GOP can not possibly perform a GOP functional obligation for a non-BES generator, as it has no NERC
functional obligations.
Likes

Dislikes

Response
The updated definition stays silent on the applicability. In general, the SDT believes an IBR is an IBR regardless of the voltage class it is
connected to or the size. This is further described in the technical rationale.
Lauren Giordano - Lauren Giordano On Behalf of: Dennis Sismaet, Northern California Power Agency, 4, 6, 3, 5; Jeremy Lawson,
Northern California Power Agency, 4, 6, 3, 5; Marty Hostler, Northern California Power Agency, 4, 6, 3, 5; - Lauren Giordano
Answer

Document Name
Comment
BES needs to be included in the Definition. We already have experience with regulators making up their own interpretation when "BES" in
not included. For example, in CIP-002-5.1A IRC 2.11 Auditors claim since BES is not before the word generation, GOP's must include nonBES generation in their Control Center assessments. Even though a GOP cannot possibly perform a GOP functional obligation for a nonBES generator as it has no NERC functional obligations
Likes

Dislikes

Response

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

The updated definition stays silent on the applicability. In general, the SDT believes an IBR is an IBR regardless of the voltage class it is
connected to or the size. This is further described in the technical rationale.
Michael Whitney - Northern California Power Agency - 3,4,5,6
Answer

Document Name
Comment
BES needs to be included in the Definition. We already have experience with regulators making up their own interpretation when "BES" in
not included. For example, in CIP-002-5.1A IRC 2.11 Auditors claim since BES is not before the word generation, GOP's must include nonBES generation in their Control Center assessments. Even though a GOP cannot possibly perform a GOP functional obligation for a nonBES generator as it has no NERC functional obligations.
Marty Hostler, Northern California Power Agency, 4, 1/8/2024
Likes

Dislikes

Document Name
Comment
WEC Energy Group supports the comments of the NAGF, the MRO NSRF and EEI.

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Likes

Dislikes

Response
See EEI, NAGF, and MRO NSRF Comments.
Stephen Stafford - Stephen Stafford On Behalf of: Greg Davis, Georgia Transmission Corporation, 1; - Stephen Stafford
Answer

Document Name
Comment
Remove the reference for sink in the IBR definition. A sink (load) is not a resource. Consider referring to a discharging battery energy
storage system (BESS).
Likes

Dislikes

Response
Language removed and clarified within the technical rationale.
Jennifer Bray - Arizona Electric Power Cooperative, Inc. - 1
Answer

Document Name
Comment
AEPC signed on to ACES comments:

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

It is ACES’ viewpoint that the proposed definitions are a welcome step towards better defining what is inherently a somewhat nebulous
concept. While we can appreciate the approach taken by the Drafting Team, we believe further refinement is necessary. We would like to
specifically emphasize our agreement with the 3ʳᵈ bullet point of the “Background” section. We believe that it is imperative that the
industry adopt specific definitions to distinguish between an individual “IBR unit” and the “IBR plant/facility as a whole” thereby allowing
each SDT the flexibility to draft each individual standard or requirement with the correct scope for each. While we agree that creating
distinct definitions is the correct method to clearly define these resource types, it is our interpretation that the currently proposed IBR
definition does not align with this stated approach. It is our opinion that the first sentence of the IBR definition is redundant to the IBR
unit definition and should be struck.
Furthermore, we do not believe that the IBR definition should be limited by a specific listing of technologies as is done in the last sentence
of the definition. The last sentence of the 6ᵗʰ bullet point in the background section states:
•

“The DT’s intent with the phrase "IBRs include" is to articulate a specific list of IBRs. Therefore, other technologies not listed would
not be considered an IBR.”

It is our perspective that if a specific list of applicable technologies is required to clearly define this term, then the rest of the definition is
moot and can be eliminated. In other words, rather than providing a definition and an all-inclusive list of applicable technologies, why not
simply provide an all-inclusive list? We believe this approach needlessly limits the IBR definition to current technologies in common use
and does not allow enough flexibility for future technological growth nor changes in industry trends.
It is our recommendation that the IBR definition be modified as follows:
•

“One or more IBR Unit(s), operated as a single resource at a common point of interconnection, connected to the electric power
system (transmission, sub-transmission, or distribution system).

•

IBRs may include, but are not limited to, any combination of one or more of the following installation types: solar photovoltaic
(PV), wind turbine, battery energy storage system, and fuel cell.”

Likes

Dislikes

Response
SDT Agrees and language has been modified with clarification added to the technical rationale.

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

List has been removed from the language and added to the technical rationale with “may include but not limited to” language.
Tammy Porter - Tammy Porter On Behalf of: Byron Booker, Oncor Electric Delivery, 1; - Tammy Porter
Answer

Document Name
Comment
We are in agreement with other comments that, although the applicability section of MOD-026-2 limits resources set by the NERC I4 BES
definition, the proposed IBR definition needs to clearly state that it aligns with the NERC I4 BES definition. The current definition may
imply that each IBR, ranging from roof top solar to large dispatchable units, would fall under future NERC standards whose applicability
does not explicitly include the NERC I4 BES definition. It would be a costly undertaking for a larger utility to include all connected IBR units
outside the I4 BES definition. In short, the applicability scope of MOD-026-2 is directed toward NERC’s I4 BES definition, and the IBR
definition need to reflect this boundary as well. Also, to better incorporate the industry recommendation to use other defined terms
when possible, such as Real Power, we recommend replacing “electric power” to “Real Power.”
Likes

Dislikes

Response
The updated definition stays silent on the applicability. In general, the SDT believes an IBR is an IBR regardless of the voltage class it is
connected to or the size. This is further described in the technical rationale.
Alan Kloster - Alan Kloster On Behalf of: Jeremy Harris, Evergy, 3, 5, 1, 6; Kevin Frick, Evergy, 3, 5, 1, 6; Marcus Moor, Evergy, 3, 5, 1, 6;
Tiffany Lake, Evergy, 3, 5, 1, 6; - Alan Kloster
Answer

Document Name
Comment
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Evergy supports and incorporates by reference the comments of the Edison Electric Institute (EEI), MRO NSRF and the NAGF reasons for
not supporting the proposed definition for question #1. Evergy also humbly submits the following proposed definition for the drafting
teams consideration:
Inverter-Based Resource - A generating resource or an energy storage system that relies on power electronic interfaces (inverters,
converters, etc.) to deliver electric power to a common point of interconnection.
Likes

Dislikes

Response
Please see EEI, NAGF, and MRO-NSRF comments.
Wayne Sipperly - North American Generator Forum - 5 - MRO,WECC,Texas RE,NPCC,SERC,RF
Answer

Document Name
Comment
The NAGF does not support the proposed IBR definition draft #1 for the following reasons:
a. It is unclear if the proposed IBR definition draft #1 would make a three (3) unit IBR generating plant a single Inverter-Based Resource
or multiple Inverter-Based Resources. A 2x1 synchronous combined cycle gas plant has three generating units that can be controlled
separately. Inverter-based resources may also be structured and controlled as distinct units behind a common point of interconnection.
When this occurs, these separately controlled groups of inverters are considered generating units within a single plant.
b.

Recommend removing the parenthetical narrative “(transmission, sub-transmission, and distribution system).

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

c. Recommend deleting the last sentence of the proposed IBR definition draft #1. It appears that any type of inverter not listed is
excluded. While at this time the list may be complete, there will be different types of inverter resources in the future that are applicable
under the IBR definition.
The NAGF recommends the following alternative definition for IBR:
Inverter-Based Resource (IBR): A source (or sink in the case of a charging battery energy storage system (BESS)) of electric power that
consists of one or more IBR Unit(s) at a common point of interconnection.
Likes

Dislikes

Response
a. IBR Definition would include these projects dependent on how they were operated. Either they would be separate IBR’s or one
whole IBR. It would depend on the circumstance, but the definition would cover it in either case.
b. Language removed from the definition, and further clarified in the technical rationale.
c. SDT Agrees and has moved this list to the technical rationale with “May include but not limited to” language.
Selene Willis - Edison International - Southern California Edison Company - 5
Answer

Document Name
Comment
“See comments submitted by the Edison Electric Institute”
Likes

Dislikes

Response
Please see response to EEI.
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Kenya Streeter - Edison International - Southern California Edison Company - 1,3,5,6
Answer

Document Name
Comment
See comments submitted by the Edison Electric Institute
Likes

Dislikes

Response
Please see response to EEI comments.
Daniela Atanasovski - APS - Arizona Public Service Co. - 1
Answer

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

To address these concerns, either the IEEE definition of IBRs, as defined in IEEE 2800-2022 (IEEE Standard for Interconnection and
Interoperability of Inverter-Based Resources (IBRs) Interconnecting with Associated Transmission Electric Power Systems, See Section 3,
page 31) or the informal definition of IBRs as proposed by the FERC Commission on Nov. 17, 2023 should be leveraged.
EEI further notes that the Project 2022-02 SDT has already attempted to define DERs separately within that project and while these
resources are also inverter based, they represent a specific class of IBRs that are directly connected to the distribution system and in
many cases serve a very different purpose outside of supporting the reliability of the Bulk Power System and therefore should be defined
separately.
Likes

Dislikes

Response
Please see response to EEI comments.
Mark Gray - Edison Electric Institute - NA - Not Applicable - NA - Not Applicable
Answer

Document Name
Comment
EEI appreciates the efforts to develop the proposed IBR definition, however, we do not support the definition as currently written. Our
concerns include the specificity in the technology types covered in the proposed definition, noting that NERC definitions should be
technology agnostic. Also, as written the definition seems to cast an overly broad net relative to the size and voltage class for the IBR
resources yielding insufficient regulatory clarity necessary for entities to apply the definition in any meaningful way. While the definition
is not intended to identify specific resource applicability, it still should be clear enough to provide a regulatory floor as it relates to NERC
Reliability Standards.
To address these concerns, either the IEEE definition of IBRs, as defined in IEEE 2800-2022 (IEEE Standard for Interconnection and
Interoperability of Inverter-Based Resources (IBRs) Interconnecting with Associated Transmission Electric Power Systems, See Section 3,
page 31) or the informal definition of IBRs as proposed by the FERC Commission on Nov. 17, 2023 should be leveraged.

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

EEI further notes that the Project 2022-02 SDT attempted to define DERs separately within that project. While these resources are also
inverter based, they represent a specific class of IBRs that are directly connected to the distribution system and in many cases serve a
different purpose outside of supporting the reliability of the Bulk Power System and therefore should be defined separately.
Likes

Dislikes

Response
Please see the first part of the Technical Rationale. This is the approach used by the DT in the IBR and IBR Unit definitions.
The IBR definition is written in such a way that an IBR is defined based on its technology and not its voltage connection level or size
(MVA). This is stated in the Technical Rationale. Additionally, a DER can include IBR technologies plus other generators that are not
inverter-based.

Dwanique Spiller - Berkshire Hathaway - NV Energy - 5
Answer

Document Name
Comment
The phrase “that is connected to the electric power system (transmission, sub-transmission, or distribution)” needs to be
removed. Language is unnecessary.
The sentence “IBRs include solar photovoltaic (PV), Type 3 and Type 4 wind, BESS, and fuel cell.” Should be deleted. When possible,
language used in standards and definitions should be technology neutral. If a resource would otherwise meet the criteria for being
classified as an IBR, the specific device type should not be taken into consideration as a means of exclusion. Any resource that meets the
inclusion criteria of Bulk Electric System should be subject to the appropriate reliability standards, regardless of specific device type. This
is important for ensuring that standards and associated language have the necessary flexibility to adapt to future technology and
changing resource mixes. Additionally, while the Standard Drafting Team’s intent in this being a closed list is stated in the Technical

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Rationale, the writing of this sentence does not clearly convey that intent, as “includes” has been interpreted to be both limiting and nonlimiting in various jurisdictions.
Likes

Dislikes

Response
•
•

Has been removed, and language added to the technical rationale to clarify.
Has been removed, and language added to the technical rationale to clarify.

Gail Elliott - Gail Elliott On Behalf of: Michael Moltane, International Transmission Company Holdings Corporation, 1; - Gail Elliott
Answer

Document Name
Comment
ITC supports the comments provided by MRO NSRF
Likes

Dislikes

Response
Please see MRO NSRF comments.
Rachel Coyne - Texas Reliability Entity, Inc. - 10
Answer

Document Name
Comment

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Texas RE is concerned that the proposed definition of IBR Unit does not account for Reactive Power capabilities required to maintain BPS
reliability. Since, all Inverter-based Resources (IBR) shall be capable of providing dynamic reactive power support to the grid to maintain
voltage stability, Texas RE recommends the definition of IBR Unit be revised to include Reactive Power capabilities required to maintain
BPS reliability.
According to the background section, the IBR definition should not designate the location of the resource connection. The verbiage of the
definition, however, indicates that it is connected to the electric power system (transmission, sub-transmission, or distribution). Texas RE
recommends removing the reference to transmission, sub-transmission, and distribution.
Likes

Dislikes

Response
SDT does not specifically include reactive power in order to remove any confusion about whether or not FACTS devices would be
included. The IBR definition is meant to only apply to generation type resources.
Steven Rueckert - Western Electricity Coordinating Council - 10, Group Name WECC
Answer

Document Name
Comment
WECC suggests that the drafting team attempt to not include one-off technology-based language within the definition (i.e., “sink”
phrase). Essentially, batteries, in order to charge and discharge, have bi-directional converters (AC to DC when charging and DC to AC
when discharging.) Using “IBR” as part of the definition of IBR even as a descriptor of the unit type is somewhat circular. The phrase
“operated as a single resource at a common point of interconnection” may be troublesome as there are configurations where devices
connect to separate systems and then those systems make multiple connections (both to sub-transmission and in some cases
transmission level voltages.) There should not be a loophole for compliance built into a definition (if a company puts two connections to
separate parts of a station there will be the discussion about applicability of the definition.) Additionally, if there are multiple owners
with multiple strings of IBRS but collect to a single GSU and a single point of interconnection, there could be confusion regarding jointConsideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

owned and responsibilities OR there could be the argument that it is not a single resource and does not meet the definition. WECC
suggests the following definition:”
Inverter-Based Resource (IBR)- A dispersed power producing resource that uses equipment explicitly for the transformation of current
flow from DC to AC, AC to DC, or some combination thereof including, but not limited to, solar photovoltaic (PV), Type 3 wind, Type 4
wind, battery energy storage system (BESS) and fuel cell technologies or combinations of said technologies.”
Likes

Dislikes

Response
Language has been removed and clarification has been added to the technical rational about BESS, voltage class, and other applicability
concerns.
Shannon Mickens - Shannon Mickens On Behalf of: Joshua Phillips, Southwest Power Pool, Inc. (RTO), 2; - Shannon Mickens, Group
Name SPP RTO
Answer

Document Name
Comment
SPP has a concern that the proposed definition for Inverter-Based Resource (IBR) creates confusion on how to identify the resource as
well as define the responsibility. The initial draft for IBRs focused around the inclusion of the Power Electronic Device (PED) while the
recent version includes language pertaining to a source/sink. From our perspective, the latest version (including source/sink) doesn’t
create a clear and concise picture defining the definition. Moreover, those terms are more associated with Transmission Service Request
(TSR) that allows a utility to allocate physical capacity in the form of transmission service rights (TSRs) for the transmission of electric
power.
SPP recommends that the drafting team considers removing the terms “source and sink” from the proposed definition and replaced them
with language that aligns with their purpose (proposed language shown below).

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

From our perspective, the proposed IBR definition doesn’t include language showing what a facility/plant is and the difference in
reference to an IBR unit (device) as noted in the rationale language.
Inverter-Based Resource (IBR): A generation (plant) (or load (storage facility) in the case of a charging battery energy storage system
(BESS)) of electric power that is connected to the electric power system (transmission, sub-transmission, or distribution system), and that
consists of one or more IBR Unit(s) operated as a single resource at a common point of interconnection. IBRs include solar photovoltaic
(PV), Type 3 and Type 4 wind, BESS, and fuel cell.
Likes

Dislikes

Response
The SDT agrees and this language has been removed from the definition and added to the technical rationale with further clarification
Jodirah Green - ACES Power Marketing - 1,3,4,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name ACES Collaborators
Answer

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Furthermore, we do not believe that the IBR deﬁnition should be limited by a speciﬁc listing of technologies as is done in the last sentence
of the deﬁnition. The last sentence of the 6ᵗʰ bullet point in the background section states:
“The DT’s intent with the phrase "IBRs include" is to ariculate a speciﬁc list of IBRs. Therefore, other technologies not listed would not be
considered an IBR.”
It is our perspective that if a speciﬁc list of applicable technologies is required to clearly deﬁne this term, then the rest of the deﬁnition is
moot and can be eliminated. In other words, rather than providing a deﬁnition and an all-inclusive list of applicable technologies, why not
simply provide an all-inclusive list? We believe this approach needlessly limits the IBR deﬁnition to current technologies in common use
and does not allow enough ﬂexibility for future technological growthnor changes in industry trends.
It is our recommendation that the IBR deﬁnition be modiﬁed as follows:
“One or more IBR Unit(s), operated as a single resource at a common point of interconnection, connected to the electric power system
(transmission, sub-transmission, or distribution system).
IBRs may include, but are not limited to, any combination of one or more of the following installation types: solar photovoltaic (PV), wind
turbine, battery energy storage system, and fuel cell.”
Likes

Dislikes

Response
IBRs include, but are not limited to, any combination of one or more of the following: solar photovoltaic (PV), wind turbine (Type 3&4),
battery energy storage system, and fuel cell.”
LaTroy Brumfield - American Transmission Company, LLC - 1
Answer

Document Name
Comment

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

ATC mostly agrees with the MRO NSRF‘s comment on this matter.
ATC agrees with the MRO NSRF that the phrase “that is connected to the electric power system (transmission, sub-transmission, or
distribution)” should be removed as the highlighted language is unnecessary.
ATC also agrees with the MRO NSRF that the sentence “IBRs include solar photovoltaic (PV), Type 3 and Type 4 wind, BESS, and fuel
cell.” should be deleted. When possible, language used in standards and definitions should be technology neutral.
However, ATC believes that the IBR definition should not explicitly include applicability considerations within the definition itself, but that
should be left within the Applicability section of each standard. ATC does not believe the IBR definition should reference the BES
definition as even the BES definition may shift and change to accommodate the new IBR-GO and IBR-GOP thresholds being
considered. This may have unintended consequences for the IBR definition down the line.
Likes

Dislikes

Response
Please see MRO-NSRF Comments.
Charles Yeung - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC, Group Name SRC 2023
Answer

otherwise meet the definition of an IBR. We also believe it is unnecessary for the proposed IBR definition to reference specific fuel
sources such as solar photovoltaic and wind. The type of fuel used is not the defining characteristic of IBRs, and the definition should not
be limited to currently known fuel types and configurations.
Finally, it is unnecessary to specify that the IBR interconnection point is transmission, sub-transmission and distribution. The applicability
of the IBR requirements is defined by the BES definition and distribution level applicability through the NERC Rules of Procedure. Any
changes to applicability would require a change in the term if these are included. Consequently, the BESS-specific parenthetical should be
removed from the definition of IBR and the definition be further revised to read as follows:
Inverter-Based Resource (IBR): A source of electric power that is connected to the electric power system, and that consists of one or
more IBR Unit(s) operated as a single resource at a common point of interconnection. An IBR consists of the IBR Unit(s), and the
equipment designed primarily for delivering the power to a common point of interconnection (e.g., step-up transformers, collector
system(s), main power transformer(s), power plant controller(s), reactive resources within the IBR plant, and a voltage source converter
high-voltage direct current (VSC HVDC) system with a dedicated connection to the IBR). A Battery Energy Storage System (BESS) operating
in charging mode, acting as a sink of electrical energy, is considered an IBR.
Likes

Dislikes

Response
•
•
•

Language has been added to the technical rationale to further clarify that this equipment is part of the IBR.
Language was removed and clarification in the technical rational has been added.
The updated definition stays silent on the applicability. In general, the SDT believes an IBR is an IBR regardless of the voltage class
it is connected to or the size. This is further described in the technical rationale.

Elizabeth Davis - Elizabeth Davis On Behalf of: Thomas Foster, PJM Interconnection, L.L.C., 2; - Elizabeth Davis
Answer

Document Name
Comment

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Please reference IRC SRC comments. Thank you.
Likes

Dislikes

Response
Please see IRC-SRC response.
Kennedy Meier - Electric Reliability Council of Texas, Inc. - 2
Answer

Document Name
Comment
ERCOT joins the comments submitted by the ISO/RTO Council (IRC) Standards Review Committee (SRC) and adopts them as its own.
Likes

Dislikes

Response
Please see IRC-SRC response.
Robert Blackney - Edison International - Southern California Edison Company - 1
Answer

Document Name
Comment
See comments submitted by the Edison Electric Institute (EEI).

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Likes

Dislikes

Response
Please see EEI response.
Patricia Lynch - NRG - NRG Energy, Inc. - 5
Answer

Document Name
Comment
NRG is in support of the NAGF comments concerning the proposed definition of IBR as:
a. It is unclear if the proposed IBR definition draft #1 would make a three (3) unit IBR generating plant a single Inverter-Based Resource
or multiple Inverter-Based Resources. A 2x1 synchronous combined cycle gas plant has three generating units that can be controlled
separately. Inverter-based resources may also be structured and controlled as distinct units behind a common point of interconnection.
When this occurs, these separately controlled groups of inverters are considered generating units within a single plant.
b. Recommend deleting the last sentence of the proposed IBR definition draft #1. It appears that any type of inverter not listed is excluded.
While at this time the list may be complete, there will be different types of inverter resources in the future that are applicable under the
IBR definition.
As proposed by NAGF, an alternate definition for IBR can include the following:
Inverter-Based Resource (IBR): A source (or sink in the case of a charging battery energy storage system (BESS)) of electric power that
consists of one or more IBR Unit(s) at a common point of interconnection.
Likes

Dislikes

Response
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

a. IBR Definition would include these projects dependent on how they were operated. Either they would be separate IBR’s or one
whole IBR. It would depend on the circumstance, but the definition would cover it in either case.
b. Language removed ,and added to the technical rational with further clarification
Thomas Foltz - AEP - 5
Answer

Yes

Document Name
Comment
While AEP does not object to the definition as proposed, we would like to suggest the drafting team to consider revising it as follows: IBR
Unit: An individual device, or a grouping of multiple devices, that uses a power electronic interface(s), such as an inverter or converter,
capable of exporting Real Power from a primary energy source or energy storage system, and that *functionally integrate* at a *delivery*
point on the collector system.
Likes

Dislikes

Response
Adrian Andreoiu - BC Hydro and Power Authority - 1, Group Name BC Hydro
Answer

Yes

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Using the “connected to electric power system” in the definition appears to further qualify IBRs; however, as “electric power system” is
not a defined term, this wording may only result in unnecessary applicability interpretations.
BC Hydro suggests that the applicability to specific reliability standards be kept outside the IBR definition (such as within the Facility
section of Standards), or further define the criteria that would make an inverter-based resource an IBR for the purpose of the NERC
standards applicability.
Likes

Dislikes

Response
Change made. A clarifying phrase “but not limited to” was added.
A list of example IBRs were added to the Technical Rationale.
Alison MacKellar - Constellation - 5
Answer

Yes

Document Name
Comment
Constellation has no additional comments.
Alison Mackellar on behalf of Constellation Segments 5 and 6.
Likes

Dislikes

Response
Kimberly Turco - Constellation - 6
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Answer

Yes

Document Name
Comment
Constellation has no additional comments
Kimberly Turco on behald of Constellation Segments 5 and 6
Likes

Dislikes

Response
Anna Todd - Southern Indiana Gas and Electric Co. - 3,5,6 - RF
Answer

Yes

Document Name
Comment
N/A
Likes

Dislikes

Response
Daniel Gacek - Exelon - 1
Answer

Yes

Document Name
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Comment
While Exelon supports the proposed definition, we support the questions presented in the EEI comments.
Likes

Dislikes

Response
Thank you for the support and please see response to EEI comments.
Colby Galloway - Southern Company - Southern Company Services, Inc. - 1,3,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name Southern
Company
Answer

Yes

Document Name
Comment
Southern Company suggests that additional clarification could be provided to further indicate that this definition is intended to apply to
an entire facility or electric power producing plant.
Likes

Dislikes

Response
See updated Technical Rationale.
Joshua London - Eversource Energy - 1, Group Name Eversource
Answer

Yes

Document Name
Comment

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

The sentence “IBRs include solar photovoltaic (PV), Type 3 and Type 4 wind, BESS, and fuel cell.” should be deleted or edited to say
“Examples of IBRs include”. Definitions should not require the statement of specific technologies for an individual to understand that
those technologies fall under the definition as doing so may lead a reader to believe only those specific technologies are in-scope. If you
want to provide examples, then it should be stated that way.
Likes

Dislikes

Response
Definition is updated. See Table in Technical Rationale.
Ruida Shu - Northeast Power Coordinating Council - 1,2,3,4,5,6,7,8,9,10 - NPCC, Group Name NPCC RSC
Answer

Yes

Document Name
Comment
NPCC RSC supports the definition for IBR as proposed.
Likes

Dislikes

Response
Russell Jones - Invenergy LLC - 5
Answer

Yes

Document Name
Comment

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Invenergy supports the spirit of the definition proposed and does not offer any substantive changes. We do, however, have concerns
about the application of this definition to various reliability standards going forward. More specifically, Invenergy believes the drafting
team should consider how this broad definition will be applied in specific Reliability Standard requirements to different roles
(transmission, sub-transmission, distribution) and different technologies (PV, Type 3 and Type 4 wind, BESS, and fuel cell) where nuance
may be required to account for technological limitations or differences.
Likes

Dislikes

Response
Colin Chilcoat - Invenergy LLC - 6
Answer

Yes

Document Name
Comment
Invenergy supports the spirit of the definition proposed and does not offer any substantive changes. We do, however, have concerns
about the application of this definition to various reliability standards going forward. More specifically, Invenergy believes the drafting
team should consider how this broad definition will be applied in specific Reliability Standard requirements to different roles
(transmission, sub-transmission, distribution) and different technologies (PV, Type 3 and Type 4 wind, BESS, and fuel cell) where nuance
may be required to account for technological limitations or differences.
Likes

Dislikes

Response
If there are nuances that need to be addressed for each standard or technology, then those need to be made in the respective standard.
Additionally, more Technical Rationale and Implementation Guidance can be created in the future as industry and the ERO learn more
about the application and implementation of the terms.
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Kinte Whitehead - Exelon - 1,3
Answer

Yes

Document Name
Comment
While Exelon supports the proposed definition, we support the question presented in the EEI comments.
Likes

Dislikes

Response
Please see response to EEI comments.
Constantin Chitescu - Ontario Power Generation Inc. - 5
Answer

Yes

Document Name
Comment
OPG supports NPCC Regional Standards Committee’s comments.
Likes

Dislikes

Response
Diane E Landry - Public Utility District No. 1 of Chelan County - 1, Group Name CHPD
Answer

Yes

Document Name

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Comment
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Response
Cain Braveheart - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Mike Magruder - Avista - Avista Corporation - 1
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Mohamad Elhusseini - DTE Energy - Detroit Edison Company - 3,5
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Stephen Whaite - Stephen Whaite On Behalf of: Lindsey Mannion, ReliabilityFirst , 10; - Stephen Whaite, Group Name ReliabilityFirst
Ballot Body Member and Proxies
Answer

Yes

Document Name
Comment
Likes

Dislikes

Yes

Document Name
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Comment
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Response
Jesus Sammy Alcaraz - Imperial Irrigation District - 1
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Diana Aguas - CenterPoint Energy Houston Electric, LLC - 1 - Texas RE
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Tim Kelley - Tim Kelley On Behalf of: Charles Norton, Sacramento Municipal Utility District, 3, 6, 4, 1, 5; Foung Mua, Sacramento
Municipal Utility District, 3, 6, 4, 1, 5; Kevin Smith, Balancing Authority of Northern California, 1; Nicole Looney, Sacramento Municipal
Utility District, 3, 6, 4, 1, 5; Ryder Couch, Sacramento Municipal Utility District, 3, 6, 4, 1, 5; Wei Shao, Sacramento Municipal Utility
District, 3, 6, 4, 1, 5; - Tim Kelley, Group Name SMUD and BANC
Answer

Yes

Document Name
Comment
Likes

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Response
Teresa Krabe - Lower Colorado River Authority - 5
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Matt Lewis - Lower Colorado River Authority - 1,5
Answer

Yes

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Document Name
Comment
Likes

Dislikes

Response
Nikki Carson-Marquis - Nikki Carson-Marquis On Behalf of: Theresa Allard, Minnkota Power Cooperative Inc., 1; - Nikki Carson-Marquis
Answer
Document Name
Comment
No. Minnkota Power Cooperative supports comments by ACES and the MRO New Standard Review Forum (NSRF). MPC believes the IBR
definition should be technology-neutral and should avoid listing examples within the final definition.
Likes

Dislikes

Response
Please see response to ACES and MRO NSRF comments.

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Patricia Lynch - NRG - NRG Energy, Inc. – 5
Answer

Document Name
Comment
NRG is in support of the NAGF comments that has been submitted regarding this proposed definition:
The NAGF does not support the proposed IBR Unit definition draft #1 for the following reasons:
a. Utilizing the term IBR Unit to refer to a single inverter within the generating plant will cause significant confusion at the plant level.
Unless any instruction provided to the plant is written, then it will not be clear if the term IBR Unit is the defined term used by NERC or if it
is intended to mean the generating unit (Unit 1, 2 or 3), IBR unit. This level of potential confusion is unacceptable resulting in an
unacceptable risk of the BES being misoperated. The word “unit” has long been associated with a distinct operating segment of a plant.
For this reason, the NAGF does not support the use of the term unit to mean anything less than the dispatchable grouping of inverters.
The NAGF recommends the following alternative definition for IBR Unit:
IBR Unit: All or part of an Inverter-Based Resource that is operated as a single resource. An IBR Unit may consist of one or more IBR
Devices.
In addition, the NAGF recommends the creation of the definition for IBR Device:
IBR Device: An individual device, or a grouping of multiple devices, (including equipment connected to the DC terminal of the inverter) that
includes power electronic interface(s), such as an inverter or converter, capable of exporting Real Power from a primary energy source or
energy storage system, and that connects at a single point on the collector system.
These proposed alternative definitions will enable applicable NERC standards to be clear when a protection device or modeling
information is needed at the device or unit level without causing confusion. While normally the use of the IEEE definition would be
supported, in this case it is likely to cause more problems and uncertainty for the industry.
Likes
Dislikes

0
0

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Response:
While the definition of IBR Unit is aligned with the IEEE 2800 definition, it will only apply to NERC standards. It is further not a term that
needs to be used between Transmission Operators and IBR plant personnel. The proposed IBR Unit definition is necessary if standard
requirements need to be applied at the individual inverter level instead of the plant/facility as a whole. The definition of IBR Device given
above cannot be distinguished from the proposed definition of IBR Unit.
Robert Blackney - Edison International - Southern California Edison Company – 1
Answer

Document Name
Comment
See comments submitted by the Edison Electric Institute (EEI).
Likes

Dislikes

Response:
Please see the SDT’s reply to EEI comments.
Kennedy Meier - Electric Reliability Council of Texas, Inc. – 2
Answer

Document Name
Comment
ERCOT joins the comments submitted by the IRC SRC and adopts them as its own.
Likes
Dislikes

0
0

Response:
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Please see the SDT’s reply to IRC SRC comments.
Elizabeth Davis - Elizabeth Davis On Behalf of: Thomas Foster, PJM Interconnection, L.L.C., 2; - Elizabeth Davis
Answer

Document Name
Comment
Please reference IRC SRC comments. Thank you.
Likes

Dislikes

Response:
Please see the SDT’s reply to IRC SRC comments.
Charles Yeung - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC, Group Name SRC 2023
Answer

Document Name
Comment
The IRC SRC believes that the definition should be revised to clarify that the phrase “and that connect together at a single point on the
collector system” is only intended to apply to “a grouping of multiple devices” and not to “an individual device.”
The definition should be revised to read as follows:
IBR Unit: An individual device that uses a power electronic interface(s), such as an inverter or converter, capable of exporting Real Power
from a primary energy source or energy storage system or a grouping of multiple devices, that uses a power electronic interface(s), such
as an inverter or converter, capable of exporting Real Power from a primary energy source or energy storage system and delivering
that power at a common point.
Likes

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Dislikes

Response:
The IBR Unit definition has been expanded to better distinguish between individual inverter devices and groupings of inverter devices
according to the comment.
LaTroy Brumfield - American Transmission Company, LLC - 1
Answer

Document Name
Comment
ATC supports the comments of the MRO NSRF indicating that two separate definitions are not needed, and the use of the term facility or
plant can be used to differentiate between the IBR and the IBR facility.
Likes

Dislikes

Response:
Please see the SDT’s reply to MRO NSRF comments.
Jodirah Green - ACES Power Marketing - 1,3,4,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name ACES Collaborators
Answer

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

unit deﬁnition.
We recommend that the IBR Unit deﬁnition be modiﬁed as follows:
“An individual device that uses a power electronic interface(s), such as an inverter or converter, that is capable of exporting Real Power
from a primary energy source or energy storage system.”
Likes

Dislikes

Response:
No change. Examples of groupings of inverter devices that should each be understood as an IBR Unit as distinct from an IBR plant/facility
have been added to the technical rationale.
Shannon Mickens - Shannon Mickens On Behalf of: Joshua Phillips, Southwest Power Pool, Inc. (RTO), 2; - Shannon Mickens, Group
Name SPP RTO
Answer

Document Name
Comment
SPP has a concern in reference to the proposed definition for the IBR Unit. We understand that the drafting team used definitions from
the IEEE 1547 and 2800 Standards to structure the proposed definition. However, there is the concern that the drafting team has not
created enough rationale language defining the components of an actual IBR device. In our evaluation, we noticed that the IBR definition
in the IEEE 2800 Standard mentions that an IBR Device is “a collector system or supplemental”. From our perspective, there will need to
be some clarity placed around the definition of an IBR device.
With that said, SPP recommends that the drafting team considers creating a definition for the term “IBR Device” as well as provide a list
of those types of elements to help ensure there is a clear and concise distinction of an IBR Unit and IBR Device.
Likes
Dislikes

0
0

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Response:
The SDT is not defining an IBR device because it would only end up being synonymous with IBR Unit for any usage in NERC standards.
Examples of groupings of inverter devices that should each be understood as an IBR Unit as distinct from an IBR plant/facility have been
added to the technical rationale to help clarify.
Steven Rueckert - Western Electricity Coordinating Council - 10, Group Name WECC
Answer

Document Name
Comment
The definitions does not address Reactive Power. The phrase “that connect together at a single point on the collector system” may be
troublesome as there are configurations where devices connect to separate systems and then those systems make multiple connections
(both to sub-transmission and in some cases transmission level voltages.) As indicated in our response to question 1, there should not be
a loophole for compliance built into a definition. In the December 5 presentation, if there are two owners of the two sets of IBR Units, are
there two IBRs or one IBR that is co-owned/jointly-owned? “IBR” in the presentation provided December 5, slide 10 appears to indicate
the inverter banks and the power source are part of the BES but slide 7 only calls out the inverters as an IBR Unit. The SDT needs to clarify
if the primary energy source is part of the IBR Unit (thus part of the BES) to help ensure consistency by industry when used in a
Standard. For instance- are freeze protection measures only for the inverter or the inverter and the primary energy source? Slide 8
clearly reveals more details than the definition of IBR states and does not support the BES definition clearly.
Likes

Dislikes

Response:
Reactive power is not a defining characteristic of either an IBR or IBR Unit so it does not need to be stipulated in the definitions. An IBR
may or may not be capable of producing reactive power. As stated in the technical rationale, IBR and IBR Unit are defined by technology
type and not by ownership or what system they may be connected to or whether they may be considered BES or not.
Rachel Coyne - Texas Reliability Entity, Inc. – 10
Answer

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Document Name
Comment
Texas RE is concerned the current verbiage of IBR Unit does not include the capabilities for absorbing or delivering reactive power which
is essential for electric system operations. Texas RE recommends the following verbiage:
IBR Unit: An individual device, or a grouping of multiple devices, that uses a power electronic interface(s), such as an inverter or
converter, capable of exporting Real Power and capable of providing dynamic Reactive Power support from a primary energy source or
energy storage system, and that connect together at a single point on a collector system.
Likes

Dislikes

Response:
Essential as it may be, reactive power is not a defining characteristic of either IBR or IBR Unit so it does not need to be stipulated in the
definitions. There may be IBR Units not capable of providing reactive power that should still be classified as IBR Units if other stipulations
are met.
Gail Elliott - Gail Elliott On Behalf of: Michael Moltane, International Transmission Company Holdings Corporation, 1; - Gail Elliott
Answer

Document Name
Comment
ITC supports the comments provided by MRO NSRF
Likes
Dislikes

0
0

Response:
Please see the SDT’s reply to MRO NSRF comments.

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Dwanique Spiller - Berkshire Hathaway - NV Energy – 5
Answer

Document Name
Comment
There should not be two separate definitions. IBR should be defined to address the resource itself. The term facility{C}[1] can be
included when necessary to refer to a group of IBRs and the equipment associated with the group. This is the how Standards and
associated language address synchronous resources and is easily understood and applied.
Likes

Dislikes

0
0

Response:
Please see the SDT’s reply to EEI’s comment under Q1.

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Daniela Atanasovski - APS - Arizona Public Service Co. – 1
Answer

Dislikes

Response:
Please see the SDT’s reply to EEI comments.
Kenya Streeter - Edison International - Southern California Edison Company - 1,3,5,6
Answer

Document Name
Comment
See comments submitted by the Edison Electric Institute
Likes
Dislikes

0
0

Response:
Please see the SDT’s reply to EEI comments.
Selene Willis - Edison International - Southern California Edison Company - 5

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Answer

Document Name
Comment
“See comments submitted by the Edison Electric Institute”
Likes

Dislikes

Response:
Please see the SDT’s reply to EEI comments.
Wayne Sipperly - North American Generator Forum - 5 - MRO,WECC,Texas RE,NPCC,SERC,RF
Answer

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

In addition, the NAGF recommends the creation of the definition for IBR Device:
IBR Device: An individual device, or a grouping of multiple devices, (including equipment connected to the DC terminal of the inverter)
that includes power electronic interface(s), such as an inverter or converter, capable of exporting Real Power from a primary energy
source or energy storage system, and that connects at a single point on the collector system.
These proposed alternative definitions will enable applicable NERC standards to be clear when a protection device or modeling
information is needed at the device or unit level without causing confusion. While normally the use of the IEEE definition would be
supported, in this case it is likely to cause more problems and uncertainty for the industry.
Likes

Dislikes

Response:
While the definition of IBR Unit is aligned with the IEEE 2800 definition, it will only apply to NERC standards. It is further not a term that
needs to be used between Transmission Operators and IBR plant personnel. The proposed IBR Unit definition is necessary if standard
requirements need to be applied at the individual inverter level instead of the plant/facility as a whole. The definition of IBR Device given
above cannot be distinguished from the proposed definition of IBR Unit.
Alan Kloster - Alan Kloster On Behalf of: Jeremy Harris, Evergy, 3, 5, 1, 6; Kevin Frick, Evergy, 3, 5, 1, 6; Marcus Moor, Evergy, 3, 5, 1, 6;
Tiffany Lake, Evergy, 3, 5, 1, 6; - Alan Kloster
Answer

Document Name
Comment
Evergy supports and incorporates by reference the comments of the Edison Electric Institute (EEI), MRO NSRF and the NAGF for question
#2.
Likes
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0
0

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Response:
Please see the SDT’s reply to these comments.
Tammy Porter - Tammy Porter On Behalf of: Byron Booker, Oncor Electric Delivery, 1; - Tammy Porter
Answer

Document Name
Comment
Again we echo our previous comment in the IBR definition, chiefly that the NERC I4 BES definition needs to be explicitly stated or
reflected in this definition. The labor and cost of the compliance effort would not serve the customer well if we needed to incorporate all
connected IBR units outside of the I4 definition.
Likes

Dislikes

Response:
The applicability sections of NERC standards identify which IBRs and which IBR Units are subject to the standard. As stated in the technical
rationale, IBR and IBR Unit are defined by technology type and not by whether they may be considered BES or not. The Glossary should
not limit the applicability which may need to be extended beyond BES in some standards.
Jennifer Bray - Arizona Electric Power Cooperative, Inc. – 1
Answer

Document Name
Comment
AEPC signed on to ACES comments:
Similar to our interpretation of the IBR definition, as stated above, we believe the currently proposed IBR Unit definition contains
superfluous language that overlaps the proposed IBR definition and should be modified. It is our opinion that the IBR unit definition
should
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

utilize a standalone technologically agnostic approach. Therefore, we are in favor of removing all references to multiple devices within
this single unit definition. We recommend that the IBR Unit definition be modified as follows:
•

“An individual device that uses a power electronic interface(s), such as an inverter or converter, that is capable of exporting Real
Power from a primary energy source or energy storage system.”

Likes

Dislikes

Response:
No change. Examples of groupings of inverter devices that should each be understood as an IBR Unit as distinct from an IBR plant/facility
have been added to the technical rationale.
Stephen Stafford - Stephen Stafford On Behalf of: Greg Davis, Georgia Transmission Corporation, 1; - Stephen Stafford
Answer

Document Name
Comment
The IBR Unit definition lacks clarity in the last part of the definition. GTC recommends rewording this part of the definition as follows: “An
individual device, or a grouping of multiple devices, that uses a power electronic interface(s), such as an inverter or converter, capable of
exporting Real Power from a primary energy source or energy storage system, and that are electrically connected on a collector system.”
Likes

Dislikes

Response:
No change. A single point on the collector system is already stipulated in the proposed definition.
Christine Kane - WEC Energy Group, Inc. - 3, Group Name WEC Energy Group
Answer

Document Name
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Comment
WEC Energy Group supports the comments of the NAGF, the MRO NSRF and EEI.
Likes

Dislikes

Response:
Please see the SDT’s replies to these comments.
Michael Whitney - Northern California Power Agency - 3,4,5,6
Answer

Document Name
Comment
See response to question 1. BES needs to be included here too. Connected to a BES collector.
Likes

Dislikes

Response:
A glossary definition should not limit applicability of a standard. The applicability section of each standard should establish if the standard
is limited to BES elements or not.
Lauren Giordano - Lauren Giordano On Behalf of: Dennis Sismaet, Northern California Power Agency, 4, 6, 3, 5; Jeremy Lawson,
Northern California Power Agency, 4, 6, 3, 5; Marty Hostler, Northern California Power Agency, 4, 6, 3, 5; - Lauren Giordano
Answer

Document Name
Comment

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

See response to question 1. BES needs to be included here too. Connected to a BES collector.
Likes

Dislikes

Document Name
Comment
See response to question 1. BES needs to be included here too. Connect to a BES collector.
Likes

Dislikes

Document Name
Comment
SIGE recommends adding Reactive Power language to the proposed definition.

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Likes

Dislikes

Response:
Reactive power is not a defining characteristic of either IBR or IBR Unit, so it does not need to be stipulated in the definitions. An IBR that
does not produce or absorb reactive power can still be an IBR.
Ben Hammer - Western Area Power Administration – 1
Answer

Document Name
Comment
There should not be two separate definitions. IBR should be defined to address the resource itself. The term F(f)acility(1) can be included
when necessary to refer to a group of IBRs and the equipment associated with the group. This is the how Standards and associated
language address synchronous resources and is easily understood and applied. Additionally, the use of the term unit adds potential
additional confusion based on the understanding and usage of the term for synchronous generation.
1: Facility as defined in the NERC Glossary of Terms, “A set of electrical equipment that operates as a single Bulk Electric System Element
(e.g., a line, a generator, a shunt compensator, transformer, etc.)”
Likes

Dislikes

Response:
The proposed definitions are both necessary because NERC standard requirements may need to be applied at both the individual inverter
level and the plant/facility as a whole. The SDT does not see there would be any confusion with the term “unit” as it is applied to
synchronous generation as long as the IBR piece is not missing.
Dennis Chastain - Tennessee Valley Authority - 1,3,5,6 – SERC
Answer

Document Name
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Comment
The proposed definition includes the phrase “capable of exporting Real Power”. They can also “import” power when used as a sink for
energy storage systems. They are also not limited to “Real Power” as they can also produce “Reactive Power” such as synthetic inertia.
Likes

Dislikes

Response:
Both points are true and explained in the technical rationale accompanying the proposed definitions.
James Keele - Entergy – 3
Answer

Document Name
Comment
Entergy recommend changing IBR Unit definition to the following.
IBR Unit: An individual device, or a grouping of multiple devices, that uses a power electronic interface(s), such as an inverter or
converter, capable of exporting Real Power from a primary energy source or energy storage system, and that connect together at the
collector substation.
Likes

Dislikes

Response:
No change. The proposed IBR Unit definition stipulates connections to the collector system but not to the collector substation. Changing
this to “collector substation” would make the proposed IBR Unit definition confused with the collector system itself.
Jennifer Neville - Western Area Power Administration – 6
Answer

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Document Name
Comment
There should not be two separate definitions. IBR should be defined to address the resource itself.
The NERC defined term "Facility" can be included when necessary to refer to a group of IBRs and the equipment associated with the
group. Additionally, the use of the term unit adds potential additional confusion based on the understanding and usage of the term for
synchronous generation.
Likes

Dislikes

Response:
The proposed definitions are both necessary because NERC standard requirements may need to be applied at both the individual inverter
level and the plant/facility as a whole.
Rachel Schuldt - Rachel Schuldt On Behalf of: Rachel Schuldt, Black Hills Corporation, 5, 1, 3, 6; - Black Hills Corporation – 6
Answer

Document Name
Comment
Black Hills Corporation supports NAGF and EEI comments.
Likes

Dislikes

Response:
Please see the SDT’s reply to these comments.
Carly Miller - Carly Miller On Behalf of: Josh Combs, Black Hills Corporation, 5, 1, 3, 6; - Carly Miller
Answer

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Document Name
Comment
Black Hills Corporation supports NAGF and EEI comments.
Likes

Dislikes

Response:
Please see the SDT’s reply to these comments.
Micah Runner - Black Hills Corporation – 1
Answer

Document Name
Comment
Black Hills Corporation supports NAGF and EEI comments.
Likes

Dislikes

Response:
Please see the SDT’s reply to these comments.
Sheila Suurmeier - Black Hills Corporation – 5
Answer

Document Name
Comment

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Black Hills Corporation supports NAGF and EEI comments.
Likes

Dislikes

Response:
Please see the SDT’s reply to these comments.
Srikanth Chennupati - Entergy - Entergy Services, Inc. - 1,3,5,7 – SERC
Answer

Dislikes

Response:
No change. The proposed IBR Unit definition stipulates connections to the collector system but not to the collector substation. Changing
this to “collector substation” would make the proposed IBR Unit definition confused with the collector system itself.
Casey Perry - PNM Resources - 1,3 - WECC, Texas RE
Answer

Document Name
Comment
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

PNM and TNMP supports EEI comments but also provide specific recommended changes to the IBR definition.
IBR Unit: Device(s) that uses a power electronic interface(s), such as an inverter or converter, capable or exporting Real Power from a
primary energy source or energy storage system, and that connect at a single point on the collector system.
Likes

Dislikes

Response:
Please see the SDT’s reply to EEI comments.
Anna Martinson - MRO - 1,2,3,4,5,6 - MRO, Group Name MRO Group
Answer

Document Name
Comment
There should not be two separate definitions. IBR should be defined to address the resource itself. The term F(f)acility(1) can be included
when necessary to refer to a group of IBRs and the equipment associated with the group. This is the how Standards and associated
language address synchronous resources and is easily understood and applied. Additionally, the use of the term unit adds potential
additional confusion based on the understanding and usage of the term for synchronous generation.
1: Facility as defined in the NERC Glossary of Terms, “A set of electrical equipment that operates as a single Bulk Electric System Element
(e.g., a line, a generator, a shunt compensator, transformer, etc.)”
Likes
Dislikes

Lincoln Electric System, 5, Millard Brittany
0

Response:

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

The proposed definitions are both necessary because NERC standard requirements may need to be applied at both the individual inverter
level and the plant/facility as a whole. The SDT does not see there would be any confusion with the term “unit” as it is applied to
synchronous generation as long as the IBR piece is not missing.
Andy Thomas - DTE Energy - 1,3,5,6 - SERC,RF
Answer

Document Name
Comment
Duke Energy provides the following guidance: Delete the proposed NERC IBR Unit definition and substitute the IEEE 2800 “IBR Unit”
definition. The IEEE2800 definition is well vetted within the industry and serves the NERC intended purpose for this application.
Likes

Dislikes

Response:
No change. The proposed IBR Unit definition is essentially the same as the 2800 definition but with added clarification to stipulate
exporting of Real power, association with an energy storage system, and attachment to the collector system of an IBR plant/facility.
Ruchi Shah - AES - AES Corporation – 5
Answer

Document Name
Comment
AES Clean Energy supports NAGF’s comments, and NAGF’s proposed definition for IBR Unit as well as creation of a new term called IBR
Device.
Likes
Dislikes

0
0

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Response:
Please see the SDT’s reply to NAGF comments.
Mark Garza - FirstEnergy - FirstEnergy Corporation - 4, Group Name FE Voter
Answer

Dislikes

Response:
Please see the SDT’s reply to EEI comments.
Ryan Quint - Elevate Energy Consulting - NA - Not Applicable - NA - Not Applicable, Group Name Elevate Energy Consulting
Answer

Unit must export Real Power whereas the proposed IBR definition as a whole is defined as “electric power” (no specification of
Real Power or Reactive Power). Therefore, this definition as proposed precludes STATCOMs, SVCs, and HVDC circuits from being
considered IBRs in NERC standards. This will require significant clarifying language to address within every standard where these

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Draft 1 of IBR Definitions | February 22, 2024

types of inverter-based devices and technologies should be considered. As NERC has initiated projects to more directly pull in
these resources to applicable standards, it would be a significant misstep to not include them in the IBR definition.
o Note that this broader term for IBR has been used for over 7 years by NERC and is described clearly in the NERC IBR Risk
Mitigation Strategy (https://www.nerc.com/comm/Documents/NERC_IBR_Strategy.pdf). Risks posed to the BPS related to
IBRs are across all resource types, not just generating resources. Stability studies conducted by NERC and stakeholders
following the Blue Cut Fire and Canyon 2 Fire disturbances highlighted that momentary cessation of solar PV IBRs would
then cause unexpected and unwanted blocking on a major HVDC circuit in the Western Interconnection, which would
subsequently cause instability, uncontrolled separation, and cascading. Ensuring reliable performance, accurate modeling,
and sufficiently detailed studies of all these devices and resources is critical to reliable operation of the BPS.
o Similarly, the phrase “from a primary energy source or energy storage system” can add some confusion as well, as it has
nothing to do with the IBR Unit itself. For example, STATCOMs, SVCs, and HVDC then do not meet this definition (or only
implicitly, at best), which relates to the added confusion above.
2. The proposed definition states “that connect together at a single point on the collector system,” implying that the common
connection must be on the collector system for all IBR Units. This is often not the case, such as with wind collector systems
aggregating at the substation. Minor issue, but one that should possibly be clarified in future revision. The SDT could consider
something like “that connect to single point(s) of connection through a collector system.”
A definition such as the following may be more appropriate: “An individual device or a grouping of multiple devices that uses a power
electronic interface(s), such as an inverter or converter.”
Likes
Dislikes

0
0

Response:
FACTS devices and HVDC systems are deliberately excluded from both proposed definitions. If they are applicable in any standard, the
standard may and should refer to them as FACTS and HVDC. The SDT believes that the general usage of the term IBR is directed to Real
Power producing (or absorbing in the case of batteries) devices and did not want to depart from this understood use. As for the single
point on the collector system, standards may need to apply requirements at inverter terminals instead of the POI or POM. The intent of
the proposed IBR Unit definition is to facilitate such requirements. The technical rationale explains in more detail with examples how the
definition is intended to be applied.
Sean Bodkin - Dominion - Dominion Resources, Inc. - 6, Group Name Dominion
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Answer

Document Name
Comment
Please see previous comment.
Likes

Dislikes

Response
N/A
Kristina Marriott - Miller Bros. Solar, LLC - 5 - MRO,WECC,Texas RE
Answer

Document Name
Comment
The DT specifically mentions the differences between inverter and converter within the Background of the proposed definition. We
recommend that these "definitions" be included as part of the overall unit definition. Furthermore, converter should be its own
definition. This may help the inclusion and exclusion of such units for specific standards.
"An inverter is a power electronic device that inverts DC power to AC sinusoidal power. A rectifier is a power electronic device that
rectifies AC sinusoidal power to DC power. A converter is a power electronic device that performs rectification and/or inversion. "
Since a battery energy storage system may have both, we recommend a detailed definition of BESS unit. We do understand the initial
mindset of the DT, separating these out may make it easier for future standards (Modeling, Protection studies, Performance, CIP,
Maintenance, etc).
Likes
Dislikes

0
0

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Response:
The SDT does not believe it is necessary to define the terms inverter, converter, and rectifier in the NERC glossary. There should be no
confusion about these terms but just in case there is some uncertainty, the technical rationale has these quoted statements. Regarding
the battery comment, if a battery needs to have requirements in a standard distinct from other IBRs, it may be referred to as a battery or
BESS. The SDT is attempting to fulfill its charge with as few additions to the glossary as possible.
Constantin Chitescu - Ontario Power Generation Inc. – 5
Answer

Yes

Document Name
Comment
OPG supports NPCC Regional Standards Committee’s comments.
Likes

Dislikes

Response:
Please see the SDT’s reply to NPCC comments.
Ruida Shu - Northeast Power Coordinating Council - 1,2,3,4,5,6,7,8,9,10 - NPCC, Group Name NPCC RSC
Answer

Yes

Document Name
Comment
NPCC RSC supports the definition for IBR Unit as proposed.
Likes
Dislikes

0
0

Response:
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Thank you.
Colby Galloway - Southern Company - Southern Company Services, Inc. - 1,3,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name Southern
Company
Answer

Yes

Document Name
Comment
Southern Company understands that the IBR Unit definition is essentially addressing the power conversion device at most typical DC-toAC type and AC-DC-AC type electric generating stations. Southern Company respectfully requests that additional examples be provided
to further clarify the various configurations that typically exist at IBR facilities, including AC-DC-DC converters, solar plant string inverters,
individual inverter modules, groups of modules, etc., and to, in each case, identify which parts are to be considered the IBR Unit or IBR
Units. Further, Southern Company believes that this is essential based on the probable use of these definitions as seen in the use of IBR
Unit in MOD-026-2 Draft 3 (Jun 2022).
Likes

Dislikes

Response:
Examples have been added to the technical rationale.
Kimberly Turco - Constellation – 6
Answer

Yes

Document Name
Comment
Constellation has no additional comments
Kimberly Turco on behald of Constellation Segments 5 and 6

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Likes

Dislikes

Response
Thank you.
Alison MacKellar - Constellation – 5
Answer

Yes

Document Name
Comment
Constellation has no additional comments.
Alison Mackellar on behalf of Constellation Segments 5 and 6.
Likes

Dislikes

Response
Thank you.
Michael Johnson - Michael Johnson On Behalf of: Frank Lee, Pacific Gas and Electric Company, 3, 1, 5; Marco Rios, Pacific Gas and
Electric Company, 3, 1, 5; Sandra Ellis, Pacific Gas and Electric Company, 3, 1, 5; - Michael Johnson, Group Name PG&E All Segments
Answer

Yes

Document Name
Comment
PG&E supports the IBR Unit definition.
Likes

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Dislikes

Response:
Thank you.
Duane Franke - Manitoba Hydro - 1,3,5,6 – MRO
Answer

Yes

Document Name
Comment
The IEEE definition says may include unit transformer in the IBR unit definition. There may be some confusion when the other equipment
(ex. transformer) is to be included; at the IBR unit level or IBR plant/facility level?
Likes

Dislikes

Response
Some examples of IBR Units have been added to the technical rationale. It is understood and explained that a GSU transformer stepping
up from inverter level voltage to the collector system voltage may be considered a component of an IBR unit.
Kinte Whitehead - Exelon - 1,3
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Colin Chilcoat - Invenergy LLC - 6
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Russell Jones - Invenergy LLC - 5
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Matt Lewis - Lower Colorado River Authority - 1,5
Answer

Yes

Document Name
Comment

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Likes

Dislikes

Response
Teresa Krabe - Lower Colorado River Authority - 5
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Joshua London - Eversource Energy - 1, Group Name Eversource
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Daniel Gacek - Exelon - 1

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Tim Kelley - Tim Kelley On Behalf of: Charles Norton, Sacramento Municipal Utility District, 3, 6, 4, 1, 5; Foung Mua, Sacramento
Municipal Utility District, 3, 6, 4, 1, 5; Kevin Smith, Balancing Authority of Northern California, 1; Nicole Looney, Sacramento Municipal
Utility District, 3, 6, 4, 1, 5; Ryder Couch, Sacramento Municipal Utility District, 3, 6, 4, 1, 5; Wei Shao, Sacramento Municipal Utility
District, 3, 6, 4, 1, 5; - Tim Kelley, Group Name SMUD and BANC
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Diana Aguas - CenterPoint Energy Houston Electric, LLC - 1 - Texas RE
Answer

Yes

Document Name
Comment
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Likes

Dislikes

Response
Donna Wood - Tri-State G and T Association, Inc. - 1
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Tracy MacNicoll - Utility Services, Inc. - 4
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Jesus Sammy Alcaraz - Imperial Irrigation District - 1
Answer

Yes

Document Name
Comment
Likes

Dislikes

Yes

Document Name
Comment
Likes

Dislikes

Response
Stephen Whaite - Stephen Whaite On Behalf of: Lindsey Mannion, ReliabilityFirst , 10; - Stephen Whaite, Group Name ReliabilityFirst
Ballot Body Member and Proxies
Answer

Yes

Document Name
Comment
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Likes

Dislikes

Response
Mohamad Elhusseini - DTE Energy - Detroit Edison Company - 3,5
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Adrian Andreoiu - BC Hydro and Power Authority - 1, Group Name BC Hydro
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Mike Magruder - Avista - Avista Corporation - 1
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Cain Braveheart - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Diane E Landry - Public Utility District No. 1 of Chelan County - 1, Group Name CHPD
Answer

Yes

Document Name
Comment

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

Likes

Dislikes

Response
Thomas Foltz - AEP – 5
Answer

Yes

Document Name
Comment
Likes

Dislikes

0
0

Response:
Please see the SDT’s reply to ACES comments.

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100

3. Provide any additional comments for the DT to consider, if desired.
Duane Franke - Manitoba Hydro - 1,3,5,6 – MRO
Answer
Document Name
Comment
·
The IBR definition states that an IBR can be connected to the transmission, sub-transmission, and distribution systems. However,
the last bullet of the background in the IBR definition documents says that DER-related projects may or may not need to use the same
definition of IBR/IBR units. It is suggested that NERC collaborate with different departments to use the same definition and to reduce
confusion.
·
What about the IBR unit and IBR plant auxiliary equipment? Does it belong to the IBR and IBR units? More clarity is required to the
IBR/IBR unit definition regarding auxiliary equipment.
·
It is not clear how the terms IBR & IBR Unit fit in with the term dispersed power producing resource. If an IBR is also a dispersed
power producing resource, what term is MOD 26-2 going to use? IBRs or the BES inclusion term using dispersed power producing
(generating) resource.
Likes

Dislikes

Response
The SDT maintains that an IBR is defined according to technology and is not defined by where it is connected or its size. The NERC
Glossary must not define applicability because different standards may need wider or more restrictive applicability depending on their
objectives. The applicability section of each standard is where BES or non-BES IBR applicability should be established and MOD-026
should not be setting the scope for other standards that may need to use the terms.
Diane E Landry - Public Utility District No. 1 of Chelan County - 1, Group Name CHPD

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101

Answer
Document Name
Comment
Further clarification requested regarding whether the definition is for IBRs applied to the BES, or for all categories of IBRs. MOD-026
currently limits scope to BES under ‘Applicability’ of the MOD-026 standard. However, since the new term is defined apart from the MOD026 standard, it is recommended that BES applicability be included in the definition, so the application of the term is consistent with
MOD-026 units, should the term be used elsewhere. The concern is that the term could be used beyond the scope of units defined under
MOD-026 if this BES is not clarified; for example, a 1 MW PV unit connected to a distribution system would fall under the scope of the
proposed definition, although it is neither BES nor in-scope under MOD-026.
Likes

Dislikes

Response
The SDT maintains that an IBR is defined according to technology and is not defined by where it is connected or its size. The NERC
Glossary must not define applicability because different standards may need wider or more restrictive applicability depending on their
objectives. The applicability section of each standard is where BES or non-BES IBR applicability should be established and MOD-026
should not be setting the scope for other standards that may need to use the terms.
Ryan Quint - Elevate Energy Consulting - NA - Not Applicable - NA - Not Applicable, Group Name Elevate Energy Consulting
Answer
Document Name
Comment
1. The definitions are leveraging IEEE 2800-2022 as a reference; however, there are notable differences between definitions. Most

importantly, IEEE 2800-2022 is careful in its consideration of supplemental IBR, defined as “any equipment within an IBR plant,
which may or may not be inverter-based…” These could include capacitor banks, STATCOMs, harmonic filters, protection systems,
plant-level controllers, etc., which should all be considered as part of the overall IBR facility. If the resource (or part of the

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102

resource) is deemed “IBR”, then all applicable components that support that resource (such as those listed above) should be
considered part of the IBR.
2. The drafting team should consider how these definitions will apply to hybrid/co-located resources. Some consideration and
clarifications, if needed, could be useful as the terms get used in NERC Reliability Standards. Growth of hybrid resources across the
BPS will make this a notable issue moving forward, so careful consideration of this topic now will be most effective.
Likes

Dislikes

Response
Any auxiliary equipment at the collector station behind the interface to the transmission system, including all the mentioned items, is part
of the IBR plant/facility. The SDT has included this clarification in the technical rationale.
Mark Garza - FirstEnergy - FirstEnergy Corporation - 4, Group Name FE Voter
Answer
Document Name
Comment
None.
Likes

Dislikes

Response
Michael Johnson - Michael Johnson On Behalf of: Frank Lee, Pacific Gas and Electric Company, 3, 1, 5; Marco Rios, Pacific Gas and
Electric Company, 3, 1, 5; Sandra Ellis, Pacific Gas and Electric Company, 3, 1, 5; - Michael Johnson, Group Name PG&E All Segments
Answer
Document Name
Comment
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103

PG&E thanks the Drafting Team's effort in creating an IBR definition that can be used throughout the industry for other current and future
standards development work.
Likes

Dislikes

Response:
Thank you.
Ruchi Shah - AES - AES Corporation – 5
Answer
Document Name
Comment
AES Clean Energy recommends most of the Background section (except the last two main bullets) of the IBR Definition document be
included in a separate document (such as a technical rationale or implementation guidance).
Likes

Dislikes

Response:
Thak you
Andy Thomas - DTE Energy - 1,3,5,6 - SERC,RF
Answer
Document Name
Comment
None.

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104

Likes

Dislikes

Response
Anna Martinson - MRO - 1,2,3,4,5,6 - MRO, Group Name MRO Group
Answer
Document Name
Comment
IBR: A single generating unit of generating Facility as identified through Inclusion I2 or I4 of the BES Definition that utilizes a power
electronic interface to convert its self-generated(1) DC electricity to AC electricity for the primary purpose of supplying power to the Bulk
Power System.
1: This includes DC electricity that is discharged from devices such as batteries and fuel cells.
Likes

Dislikes

Lincoln Electric System, 5, Millard Brittany
0

Response
Thank you for this suggestion but the SDT will stick with its proposal as revised based on feedback from other commenters.
Casey Perry - PNM Resources - 1,3 - WECC,Texas RE
Answer
Document Name
Comment
Request SDT to provide a full list of specific IBR devices that will be covered under this definition.

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105

Likes

Dislikes

Response
The common forms of IBRs are listed in a non-exclusive list within the proposed definition. The SDT does not want to exclude any future
technologies unknown at present that could qualify as IBRs.
Srikanth Chennupati - Entergy - Entergy Services, Inc. - 1,3,5,7 – SERC
Answer
Document Name
Comment
Clarify how these IBR and IBR Unit definitions will interact with other projects proposed definitions for DERs.
Likes

Dislikes

Response
The SDT maintains that an IBR is defined according to technology and is not defined by where it is connected or its size. Therefore, DERs
that are also IBRs should be considered a subset of IBRs.
Israel Perez - Israel Perez On Behalf of: Mathew Weber, Salt River Project, 3, 1, 6, 5; Sarah Blankenship, Salt River Project, 3, 1, 6, 5;
Thomas Johnson, Salt River Project, 3, 1, 6, 5; Timothy Singh, Salt River Project, 3, 1, 6, 5; - Israel Perez
Answer
Document Name
Comment
SRP does not support the addition or modification of this term and simply adding it to Reliability Standards that previously did not have
IBR applicability. SRP strongly feels IBRs should have separate standards.

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Likes

Dislikes

Response
Whether there should be separate standards for IBRs or whether IBRs applicability may be inserted into standards that presently do no
pertain to IBRs is a matter to be determined by each relevant SAR and/or SDT.
Sheila Suurmeier - Black Hills Corporation – 5
Answer
Document Name
Comment
Black Hills Corporation supports NAGF comments.
Likes

Dislikes

Response
Please see the SDT’s reply to NAGF comments.
Micah Runner - Black Hills Corporation – 1
Answer
Document Name
Comment
Black Hills Corporation supports NAGF comments.
Likes
Dislikes

0
0

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107

Response
Please see the SDT’s reply to NAGF comments.
Carly Miller - Carly Miller On Behalf of: Josh Combs, Black Hills Corporation, 5, 1, 3, 6; - Carly Miller
Answer
Document Name
Comment
Black Hills Corporation supports NAGF comments.
Likes

Dislikes

Response
Please see the SDT’s reply to NAGF comments.
Rachel Schuldt - Rachel Schuldt On Behalf of: Rachel Schuldt, Black Hills Corporation, 5, 1, 3, 6; - Black Hills Corporation - 6
Answer
Document Name
Comment
Black Hills Corporation supports NAGF comments.
Likes

Dislikes

Response
Please see the SDT’s reply to NAGF comments.
Alison MacKellar - Constellation – 5

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108

Answer
Document Name
Comment
Constellation has no additional comments.
Alison Mackellar on behalf of Constellation Segments 5 and 6.
Likes

Dislikes

Response
Jennifer Neville - Western Area Power Administration – 6
Answer
Document Name
Comment
Suggested IBR definition: A single generating unit of generating facility as identified through Inclusion I2 or I4 of the BES Definition that
utilizes a power electronic interface to convert its self-generated(1) DC electricity to AC electricity for the primary purpose of supplying
power to the Bulk Power System.
(1): This includes DC electricity that is discharged from devices such as batteries and fuel cells.
Likes

Dislikes

Response
Thank you for this suggestion but the SDT will stick with its proposal as revised based on feedback from other commenters.

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109

Kimberly Turco - Constellation – 6
Answer
Document Name
Comment
Constellation has no additional comments
Kimberly Turco on behald of Constellation Segments 5 and 6
Likes

Dislikes

Response
James Keele - Entergy – 3
Answer
Document Name
Comment
Clarify how these IBR and IBR Unit definitions will interact with other projects proposed definitions for DERs.
Likes
Dislikes

0
0

Response:
The SDT maintains that an IBR is defined according to technology and is not defined by where it is connected or its size. Therefore, DERs
that are also IBRs should be considered a subset of IBRs.
Ben Hammer - Western Area Power Administration – 1

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110

Answer
Document Name
Comment
IBR: A single generating unit of generating Facility as identified through Inclusion I2 or I4 of the BES Definition that utilizes a power
electronic interface to convert its self-generated(1) DC electricity to AC electricity for the primary purpose of supplying power to the Bulk
Power System.
1: This includes DC electricity that is discharged from devices such as batteries and fuel cells.
Likes

Dislikes

Response
Thank you for this suggestion but the SDT will stick with its proposal as revised based on feedback from other commenters.
Donna Wood - Tri-State G and T Association, Inc. – 1
Answer
Document Name
Comment
NA
Likes

Dislikes

Response
Nikki Carson-Marquis - Nikki Carson-Marquis On Behalf of: Theresa Allard, Minnkota Power Cooperative Inc., 1; - Nikki Carson-Marquis

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Answer
Document Name
Comment
Minnkota Power Cooperative appreciates the SDT's efforts to define impactful terms. MPC recommends distinguishing "IBR" and
"IBR Unit" terms from those of the same name in IEEE 2800-2022 to avoid conflating the two entities' similar terminology.
Likes

Dislikes

Response:
No change. The proposed NERC glossary IBR definition deviates slightly from the 2800 definition in that the proposed NERC glossary
definition is not limited to transmission interconnections but also encompasses DERs. The proposed IBR Unit definition is essentially the
same as the 2800 definition but with added clarification to stipulate exporting of Real Power, association with an energy storage system,
and attachment to the collector system of an IBR plant/facility.
Anna Todd - Southern Indiana Gas and Electric Co. - 3,5,6 – RF
Answer
Document Name
Comment
N/A
Likes

Dislikes

Response
Marty Hostler - Northern California Power Agency – 4

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112

Answer
Document Name
Comment
None.
Likes

Dislikes

Response
Michael Whitney - Northern California Power Agency - 3,4,5,6
Answer
Document Name
Comment
No
Likes

Dislikes

Response
Christine Kane - WEC Energy Group, Inc. - 3, Group Name WEC Energy Group
Answer
Document Name
Comment

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113

No additional comments
Likes

Dislikes

Response
Jennifer Bray - Arizona Electric Power Cooperative, Inc. – 1
Answer
Document Name
Comment
AEPC signed on to ACES comments:
We at ACES appreciate the effort put forth by the Drafting Team in developing these proposed definitions. We especially appreciate the
fact that the Drafting Team used an industry standard source (IEEE 2800-2022) as a starting point for their efforts. While we do not
completely
agree with the exact language as currently proposed, we do agree with the overall premise utilized by the Drafting team.
Thank you for the opportunity to comment.
Likes

Dislikes

Response:
Thank you for your comment.
Wayne Sipperly - North American Generator Forum - 5 - MRO,WECC,Texas RE,NPCC,SERC,RF
Answer

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

114

Document Name
Comment
The NAGF provides the following additional comments for consideration:
a.

The proposed Inverter-Based Resources (IBR) Definitions – Background section

i. General – this section provides supporting information that is critical to understanding the IBR Definitions and therefore should be
memorialized in a technical rational or similar document.
ii. Bullet # 7 – the entire collocated synchronous generation and BESS facility should not be considered an IBR; only the IBR portion of the
facility (i.e. the BESS) should be considered IBR. Recommend revising the language to clarify.
Likes

Dislikes

Response
Language updated in the Technical Rationale.
Selene Willis - Edison International - Southern California Edison Company – 5
Answer
Document Name
Comment
“See comments submitted by the Edison Electric Institute”
Likes
Dislikes

0
0

Response:

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

115

Please see the SDT’s reply to EEI comments.
Romel Aquino - Edison International - Southern California Edison Company – 3
Answer
Document Name
Comment
See comments submitted by the Edison Electric Institute
Likes

Dislikes

Response:
Please see the SDT’s reply to EEI comments.
Kenya Streeter - Edison International - Southern California Edison Company - 1,3,5,6
Answer
Document Name
Comment
See comments submitted by the Edison Electric Institute
Likes

Dislikes

Response:
Please see the SDT’s reply to EEI comments.
Daniela Atanasovski - APS - Arizona Public Service Co. – 1
Answer

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

116

Document Name
Comment
None
Likes

Dislikes

Response
Gail Elliott - Gail Elliott On Behalf of: Michael Moltane, International Transmission Company Holdings Corporation, 1; - Gail Elliott
Answer
Document Name
Comment
ITC supports the comments provided by MRO NSRF
Likes

Dislikes

Response:
Please see the SDT’s reply to NAGF comments.
Colby Galloway - Southern Company - Southern Company Services, Inc. - 1,3,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name Southern
Company
Answer
Document Name
Comment

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

117

None
Likes

Dislikes

Response
Joshua London - Eversource Energy - 1, Group Name Eversource
Answer
Document Name
Comment
There appears to be confusing circular logic with calling the second definition IBR Unit. By shortening to “IBR” you are stating it is
previously defined, but the definition of Inverter-Based Resource relies upon the definition of “IBR Unit”. Change “IBR Unit” to “InverterBased Resource Unit.
Likes

Dislikes

Response:
Thank you for this suggestion. Revised to Inverter-Based Resource Unit (IBR Unit).
Teresa Krabe - Lower Colorado River Authority – 5
Answer
Document Name
Comment
IBRs do not have an electromagnetic link to grid power which can extract stored inertial energy.

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

118

Likes

Dislikes

Response:
This is true.
Matt Lewis - Lower Colorado River Authority - 1,5
Answer
Document Name
Comment
IBRs do not have an electromagnetic link to grid power which can extract stored inertial energy.
Likes

Dislikes

Response:
This is true.
Steven Rueckert - Western Electricity Coordinating Council - 10, Group Name WECC
Answer
Document Name
Comment
WECC appreciates the efforts and understands the difficulties in proposing definitions. WECC can support the definitions if the
Implementation Guidance or Definition Guidance (like the BES Reference Guide) with drawings that clearly depict the difference between
an IBR and an IBR Unit as well as BES relationship to each are developed. This will get industry on the same page and the ERO Enterprise
on the same page. Do not allow other uses such as IBR plant or IBR Facility or hybrid IBR within the Implementation Guidance or any

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

119

Standard. If there needs to be additional descriptors add it to the definition—consistency in terminology will make applicability easier for
everyone.
In slide 14 of the Dec 5 presentation, the example 6.3 verbiage appears to reflect IBR aspects and IBR Unit aspects but uses “Facility” for
IBR. Are the “enabled protective and limiting functions” directly tripping the IRB Unit(s) or IBR (versus Facility)? Or an IBR Facility?
Likes

Dislikes

Response:
Examples of IBR Units have been added to the technical rationale.
In answer to the December 5 presentation slide question; a single or multiple IBR Units can trip or the entire IBR (facility/plant) can trip
based on the enabled protective and limiting functions.
Shannon Mickens - Shannon Mickens On Behalf of: Joshua Phillips, Southwest Power Pool, Inc. (RTO), 2; - Shannon Mickens, Group
Name SPP RTO
Answer
Document Name
Comment
SPP recommends that the drafting team reference the IEEE 1547-2018 Standard in the background details since there are terms from that
standard has been included in the proposed definitions (for example electric power system (eps) and Energy storage system (ess).
Additionally, SPP recommends that the drafting team consider coordinating with NERC staff to implement the definitions into the Rules of
Procedures (RoP) to ensure proper alignment with the proposed efforts associated with the Glossary of Terms.
Likes
Dislikes

0
0

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

120

Response:
The SDT does not see a need to reference the above mentioned terms in the IEEE 1547 standard. The SDT has been charged with
proposing NERC glossary definitions only. NERC may choose to update the ROP.
Russell Jones - Invenergy LLC – 5
Answer
Document Name
Comment
Invenergy supports the spirit of the definition proposed and does not offer any substantive changes. We do, however, have concerns
about the application of this definition to various reliability standards going forward. More specifically, Invenergy believes the drafting
team should consider how this broad definition will be applied in specific Reliability Standard requirements to different roles
(transmission, sub-transmission, distribution) and different technologies (PV, Type 3 and Type 4 wind, BESS, and fuel cell) where nuance
may be required to account for technological limitations or differences.
Likes

Dislikes

Response:
The applicability section of each standard will establish the scope of its applicability to various IBR connection locations, sizing, and IBR
types as necessary for each standard.
Jodirah Green - ACES Power Marketing - 1,3,4,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name ACES Collaborators
Answer
Document Name
Comment

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

121

We at ACES appreciate the eﬀort put forth by the Drafting Team in developing these proposed deﬁnitions. We especially appreciate the
fact that the Drafting Team used an industry standard source (IEEE 2800-2022) as a starting point for their eﬀorts. While we do not
completely agree with the exact language as currently proposed, we do agree with the overall premise utilized by the Drafting team.
Thank you for the opportunity to comment.
Likes

Dislikes

Response:
Thank you for your comment.
LaTroy Brumfield - American Transmission Company, LLC - 1
Answer
Document Name
Comment
Below is a consideration for an updated definition of IBR.
IBR: A single generating unit or generating Facility that utilizes a power electronic interface to convert its self-generated(1) DC electricity
to AC electricity for the primary purpose of supplying power to the Bulk Power System.
1: This includes DC electricity that is discharged from devices such as batteries and fuel cells. Self-generated also implies that FACTs
devices that simply convert power do not apply to this definition.
Likes
Dislikes

0
0

Response:
Thank you for this suggestion but the SDT will stick with its proposal as revised based on feedback from other commenters.

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

122

Charles Yeung - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC, Group Name SRC 2023
Answer
Document Name
Comment
The SRC notes the inconsistent use of “electric power system” and “electric system” throughout various definitions in the NERC Glossary
and recommends NERC give some thought to standardizing this language in the future.
Likes

Dislikes

Response:
For all practical purposes, the terms are synonymous.
Elizabeth Davis - Elizabeth Davis On Behalf of: Thomas Foster, PJM Interconnection, L.L.C., 2; - Elizabeth Davis
Answer
Document Name
Comment
PJM recommends the following concise axioms in managing future updates:
1) All IBRs are comprised of one or more IBR Units.
2) An IBR unit is a generator that employs inverter(s) to create power.
3) To be an IBR unit, the DC side must be able to generate power onto the AC side past the POI.
4) An IBR unit may also consume power, but to be an IBR unit, axiom 3 must be met.
5) IBRs are the combination of IBR units, conversion (inverter), and AC equipment up to a POI.

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

123

Likes

Dislikes

Response:
Thank you for your comment.
Kennedy Meier - Electric Reliability Council of Texas, Inc. - 2
Answer
Document Name
Comment
ERCOT joins the comments submitted by the IRC SRC and adopts them as its own.
Likes

Dislikes

Response:
Please see the SDT’s reply to IRC SRC comments.
Constantin Chitescu - Ontario Power Generation Inc. – 5
Answer
Document Name
Comment
OPG supports NPCC Regional Standards Committee’s comments.
Likes
Dislikes

0
0

Response:

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

124

Please see the SDT’s reply to NPCC comments.

End of Report

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 1 of IBR Definitions | February 22, 2024

125

Public

Reminder
Standards Announcement

Project 2020-06 Verifications of Models and Data for Generators
Inverter-based Resource Glossary Terms
Initial Ballots Open through January 9, 2024
Now Available

The initial ballots for Inverter-based Resource Glossary Terms are open through 8 p.m. Eastern,
Tuesday, January 9, 2024.
Reminder Regarding Corporate RBB Memberships

Under the NERC Rules of Procedure, each entity and its affiliates is collectively permitted one voting
membership per Registered Ballot Body Segment. Each entity that undergoes a change in corporate
structure (such as a merger or acquisition) that results in the entity or affiliated entities having more
than the one permitted representative in a particular Segment must withdraw the duplicate
membership(s) prior to joining new ballot pools or voting on anything as part of an existing ballot
pool. Contact [email protected] to assist with the removal of any duplicate registrations.
Balloting

Members of the ballot pools associated with this project can log in and submit their votes by accessing
the Standards Balloting and Commenting System (SBS) here.
•

Contact NERC IT support directly at https://support.nerc.net/ (Monday – Friday, 8 a.m. - 5
p.m. Eastern) for problems regarding accessing the SBS due to a forgotten password,
incorrect credential error messages, or system lock-out.

•

Passwords expire every 6 months and must be reset.

•

The SBS is not supported for use on mobile devices.

•

Next Steps

The ballot results will be announced and posted on the project page. The drafting team will review all
responses received during the comment period and determine the next steps of the project.

Public

RELIABILITY | RESILIENCE | SECURITY

Public

For information on the Standards Development Process, refer to the Standard Processes Manual.
For more information or assistance, contact Senior Standards Developer, Chris Larson (via email) or at
404-446-9708. Subscribe to this project's observer mailing list by selecting "NERC Email Distribution Lists"
from the "Service" drop-down menu and specify “Project 2020-06 Verifications of Models and Data for
Generators Observer List” in the Description Box.

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3353 Peachtree Rd, NE
Suite 600, North Tower
Atlanta, GA 30326
404-446-2560 | www.nerc.com

Public

Standards Announcement | Project 2020-06 Ballot Open Reminder
Inverter-based Resource Glossary Terms | December 29, 2023

UPDATED
Standards Announcement

A formal comment period for Inverter-based Resource Glossary Terms is open through 8 p.m. Eastern,
Tuesday, January 9, 2024.
Commenting

Use the Standards Balloting and Commenting System (SBS) to submit comments. An unofficial Word
version of the comment form is posted on the project page.
Reminder Regarding Corporate RBB Memberships

Ballot pools are being formed through 8 p.m. Eastern, Friday, December 15, 2023. Registered Ballot
Body members can join the ballot pools here.
•

•

Passwords expire every 6 months and must be reset.

•

The SBS is not supported for use on mobile devices.

•

Please be mindful of ballot and comment period closing dates. We ask to allow at least 48 hours
for NERC support staff to assist with inquiries. Therefore, it is recommended that users try logging
into their SBS accounts prior to the last day of a comment/ballot period.

RELIABILITY | RESILIENCE | SECURITY

Next Steps

Standards Announcement | Project 2020-06 Verification of Data and Models for Generators
Inverter-Based Resource Glossary Terms | November 2023

NERC Balloting Tool (/)

Dashboard (/)

Users

Ballots

Comment Forms

BALLOT RESULTS
Comment: View Comment Results (/CommentResults/Index/310)
Ballot Name: 2020-06 Verifications of Models and Data for Generators Inverter-Based Resource (IBR) IN 1 DEF
Voting Start Date: 12/29/2023 12:01:00 AM
Voting End Date: 1/9/2024 8:00:00 PM
Ballot Type: DEF
Ballot Activity: IN
Ballot Series: 1
Total # Votes: 252
Total Ballot Pool: 282
Quorum: 89.36
Quorum Established Date: 1/9/2024 3:20:53 PM
Weighted Segment Value: 43.82
Ballot
Pool

Segment
Weight

Affirmative
Votes

Affirmative
Fraction

Negative Votes w/
Comment

Negative Fraction
w/ Comment

Negative Votes w/o
Comment

Abstain

No
Vote

Segment:
1

0.382

0.618

Segment:
2

0.7

0.3

0.4

Segment:
3

0.362

0.638

Segment:
4

0.385

0.615

Segment:
5

0.456

0.544

Segment:
6

0.432

0.568

Segment:
7

Segment:
8

Segment:
9

Segment:
10

0.5

0.4

0.1

Totals:

282

6.2

2.717

129

3.483

Segment

BALLOT POOL MEMBERS
Show

All

Segment

entries
Organization

1
AEP - AEP Service Corporation
© 2024 - NERC Ver 4.2.1.0 Machine Name: ATLVPEROWEB02

Search:
Voter
Dennis Sauriol

Designated Proxy

Ballot
Affirmative

NERC Memo
N/A

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Allete - Minnesota Power, Inc.

Hillary Creurer

None

N/A

Ameren - Ameren Services

Tamara Evey

None

N/A

American Transmission Company, LLC

LaTroy Brumfield

Negative

Comments
Submitted

APS - Arizona Public Service Co.

Daniela Atanasovski

Negative

Comments
Submitted

Arizona Electric Power Cooperative, Inc.

Jennifer Bray

Negative

Comments
Submitted

Arkansas Electric Cooperative Corporation

Emily Corley

Abstain

N/A

Associated Electric Cooperative, Inc.

Mark Riley

Affirmative

N/A

Austin Energy

Thomas Standifur

Affirmative

N/A

Avista - Avista Corporation

Mike Magruder

Affirmative

N/A

Balancing Authority of Northern California

Kevin Smith

Affirmative

N/A

BC Hydro and Power Authority

Adrian Andreoiu

Affirmative

N/A

Berkshire Hathaway Energy - MidAmerican Energy
Co.

Terry Harbour

Negative

Comments
Submitted

Black Hills Corporation

Micah Runner

Negative

Comments
Submitted

CenterPoint Energy Houston Electric, LLC

Daniela Hammons

Affirmative

N/A

City Utilities of Springfield, Missouri

Michael Bowman

Negative

Third-Party
Comments

Con Ed - Consolidated Edison Co. of New York

Dermot Smyth

Negative

Third-Party
Comments

Dairyland Power Cooperative

Karrie Schuldt

Abstain

N/A

Dominion - Dominion Virginia Power

Elizabeth Weber

Negative

Comments
Submitted

Duke Energy

Katherine Street

Negative

Comments
Submitted

Edison International - Southern California Edison
Company

Robert Blackney

Negative

Comments
Submitted

Entergy

Brian Lindsey

Negative

Comments
Submitted

Evergy

Kevin Frick

Negative

Comments
Submitted

Eversource Energy

Joshua London

Affirmative

N/A

Exelon

Daniel Gacek

Negative

Comments
Submitted

FirstEnergy - FirstEnergy Corporation

Theresa Ciancio

Negative

Comments
Submitted

Georgia Transmission Corporation

Greg Davis

Negative

Comments
Submitted

Glencoe Light and Power Commission

Terry Volkmann

Negative

Third-Party
Comments

Hydro One Networks, Inc.

Alain Mukama

Abstain

N/A

Affirmative

N/A

1
Hydro-Quebec (HQ)
© 2024 - NERC Ver 4.2.1.0 Machine Name: ATLVPEROWEB02

Nicolas Turcotte

Tim Kelley

Alan Kloster

Stephen Stafford

Ijad Dewan

Segment

Organization

Voter

IDACORP - Idaho Power Company

Sean Steffensen

Imperial Irrigation District

Jesus Sammy Alcaraz

International Transmission Company Holdings
Corporation

Michael Moltane

JEA

Designated Proxy

Ballot

NERC Memo

None

N/A

Denise Sanchez

Affirmative

N/A

Gail Elliott

Negative

Comments
Submitted

Joseph McClung

Affirmative

N/A

Lakeland Electric

Larry Watt

Affirmative

N/A

Lincoln Electric System

Josh Johnson

Negative

Comments
Submitted

Long Island Power Authority

Isidoro Behar

Abstain

N/A

Los Angeles Department of Water and Power

faranak sarbaz

None

N/A

LS Power Transmission, LLC

Jennifer Richardson

Affirmative

N/A

Manitoba Hydro

Nazra Gladu

Jay Sethi

Negative

Comments
Submitted

Minnkota Power Cooperative Inc.

Theresa Allard

Nikki Carson-Marquis

Negative

Comments
Submitted

Muscatine Power and Water

Andrew Kurriger

Negative

Third-Party
Comments

National Grid USA

Michael Jones

Negative

Third-Party
Comments

NB Power Corporation

Jeffrey Streifling

Abstain

N/A

Nebraska Public Power District

Jamison Cawley

Negative

Third-Party
Comments

NextEra Energy - Florida Power and Light Co.

Silvia Mitchell

Abstain

N/A

NiSource - Northern Indiana Public Service Co.

Alison Nickells

Affirmative

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Terri Pyle

Negative

Third-Party
Comments

Omaha Public Power District

Doug Peterchuck

Negative

Third-Party
Comments

Oncor Electric Delivery

Byron Booker

Negative

Comments
Submitted

OTP - Otter Tail Power Company

Charles Wicklund

Negative

Third-Party
Comments

Pacific Gas and Electric Company

Marco Rios

Negative

Comments
Submitted

Pedernales Electric Cooperative, Inc.

Bradley Collard

None

N/A

Platte River Power Authority

Marissa Archie

Abstain

N/A

PNM Resources - Public Service Company of New
Mexico

Lynn Goldstein

Negative

Comments
Submitted

Portland General Electric Co.

Brooke Jockin

None

N/A

PPL Electric Utilities Corporation

Michelle McCartney
Longo

Affirmative

N/A

PSEG - Public Service Electric and Gas Co.

Karen Arnold

Negative

Third-Party
Comments

Public Utility District No. 1 of Chelan County

Diane E Landry

Affirmative

N/A

Alyssia Rhoads

Affirmative

N/A

Tammy Porter

Michael Johnson

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Sacramento Municipal Utility District

Wei Shao

Tim Kelley

Affirmative

N/A

Salt River Project

Sarah Blankenship

Israel Perez

Affirmative

N/A

Santee Cooper

Chris Wagner

None

N/A

SaskPower

Wayne Guttormson

Abstain

N/A

Sempra - San Diego Gas and Electric

Mohamed Derbas

Affirmative

N/A

Southern Company - Southern Company Services,
Inc.

Matt Carden

Affirmative

N/A

Sunflower Electric Power Corporation

Paul Mehlhaff

Negative

Third-Party
Comments

Tacoma Public Utilities (Tacoma, WA)

John Merrell

Abstain

N/A

Tallahassee Electric (City of Tallahassee, FL)

Scott Langston

Abstain

N/A

Tennessee Valley Authority

David Plumb

Negative

Comments
Submitted

Tri-State G and T Association, Inc.

Donna Wood

Negative

Comments
Submitted

U.S. Bureau of Reclamation

Richard Jackson

Abstain

N/A

Western Area Power Administration

Ben Hammer

Negative

Comments
Submitted

Xcel Energy, Inc.

Eric Barry

None

N/A

California ISO

Darcy O'Connell

Abstain

N/A

Electric Reliability Council of Texas, Inc.

Kennedy Meier

Negative

Comments
Submitted

Independent Electricity System Operator

Helen Lainis

Affirmative

N/A

ISO New England, Inc.

John Pearson

Affirmative

N/A

Midcontinent ISO, Inc.

Bobbi Welch

Negative

Third-Party
Comments

New York Independent System Operator

Gregory Campoli

Affirmative

N/A

PJM Interconnection, L.L.C.

Thomas Foster

Elizabeth Davis

Negative

Third-Party
Comments

Southwest Power Pool, Inc. (RTO)

Joshua Phillips

Shannon Mickens

Negative

Comments
Submitted

AEP

Kent Feliks

Affirmative

N/A

Ameren - Ameren Services

David Jendras Sr

None

N/A

APS - Arizona Public Service Co.

Jessica Lopez

Negative

Comments
Submitted

Arkansas Electric Cooperative Corporation

Ayslynn Mcavoy

Abstain

N/A

Avista - Avista Corporation

Robert Follini

Affirmative

N/A

BC Hydro and Power Authority

Ming Jiang

Affirmative

N/A

Berkshire Hathaway Energy - MidAmerican Energy
Co.

Joseph Amato

Negative

Comments
Submitted

Black Hills Corporation

Josh Combs

Carly Miller

Negative

Comments
Submitted

Carl Spaetzel

Ryan Strom

Negative

Third-Party
Comments

3
Buckeye Power, Inc.
© 2024 - NERC Ver 4.2.1.0 Machine Name: ATLVPEROWEB02

Jennie Wike

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

CMS Energy - Consumers Energy Company

Karl Blaszkowski

None

N/A

Colorado Springs Utilities

Hillary Dobson

Affirmative

N/A

Con Ed - Consolidated Edison Co. of New York

Peter Yost

Negative

Third-Party
Comments

Dominion - Dominion Virginia Power

Bill Garvey

Negative

Comments
Submitted

DTE Energy - Detroit Edison Company

Marvin Johnson

Affirmative

N/A

Duke Energy - Florida Power Corporation

Marcelo Pesantez

Negative

Comments
Submitted

Edison International - Southern California Edison
Company

Romel Aquino

Negative

Comments
Submitted

Entergy

James Keele

Negative

Comments
Submitted

Evergy

Marcus Moor

Negative

Comments
Submitted

Eversource Energy

Vicki O'Leary

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Aaron Ghodooshim

Negative

Comments
Submitted

Georgia System Operations Corporation

Scott McGough

Negative

Third-Party
Comments

Great River Energy

Michael Brytowski

Negative

Third-Party
Comments

Imperial Irrigation District

George Kirschner

Affirmative

N/A

JEA

Marilyn Williams

Affirmative

N/A

Lakeland Electric

Steven Marshall

Affirmative

N/A

Lincoln Electric System

Sam Christensen

Negative

Comments
Submitted

Los Angeles Department of Water and Power

Fausto Serratos

None

N/A

Manitoba Hydro

Mike Smith

Negative

Comments
Submitted

MGE Energy - Madison Gas and Electric Co.

Benjamin Widder

Negative

Third-Party
Comments

Muscatine Power and Water

Seth Shoemaker

Negative

Third-Party
Comments

National Grid USA

Brian Shanahan

Negative

Third-Party
Comments

Nebraska Public Power District

Tony Eddleman

Negative

Third-Party
Comments

New York Power Authority

David Rivera

Negative

Comments
Submitted

NextEra Energy - Florida Power and Light Co.

Karen Demos

Abstain

N/A

NiSource - Northern Indiana Public Service Co.

Steven Taddeucci

Affirmative

N/A

North Carolina Electric Membership Corporation

Chris Dimisa

Scott Brame

Negative

Third-Party
Comments

Ocala Utility Services

Neville Bowen

LaKenya Vannorman

None

N/A

Alan Kloster

Denise Sanchez

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

OGE Energy - Oklahoma Gas and Electric Co.

Donald Hargrove

Negative

Third-Party
Comments

Old Dominion Electric Coop.

William Pezalla

None

N/A

Omaha Public Power District

David Heins

Negative

Third-Party
Comments

OTP - Otter Tail Power Company

Wendi Olson

Negative

Third-Party
Comments

Pacific Gas and Electric Company

Sandra Ellis

Negative

Comments
Submitted

PNM Resources - Public Service Company of New
Mexico

Amy Wesselkamper

Negative

Comments
Submitted

PPL - Louisville Gas and Electric Co.

James Frank

None

N/A

PSEG - Public Service Electric and Gas Co.

Christopher Murphy

Negative

Third-Party
Comments

Public Utility District No. 1 of Chelan County

Joyce Gundry

Affirmative

N/A

Sacramento Municipal Utility District

Nicole Looney

Tim Kelley

Affirmative

N/A

Salt River Project

Mathew Weber

Israel Perez

Affirmative

N/A

Santee Cooper

Vicky Budreau

None

N/A

Sempra - San Diego Gas and Electric

Bryan Bennett

Affirmative

N/A

Snohomish County PUD No. 1

Holly Chaney

Affirmative

N/A

Southern Company - Alabama Power Company

Joel Dembowski

Affirmative

N/A

Southern Indiana Gas and Electric Co.

Ryan Snyder

Affirmative

N/A

Tennessee Valley Authority

Ian Grant

Negative

Comments
Submitted

Tri-State G and T Association, Inc.

Ryan Walter

Negative

Comments
Submitted

WEC Energy Group, Inc.

Christine Kane

Negative

Comments
Submitted

Xcel Energy, Inc.

Nicholas Friebel

None

N/A

Alliant Energy Corporation Services, Inc.

Larry Heckert

Negative

Third-Party
Comments

Austin Energy

Tony Hua

Affirmative

N/A

Buckeye Power, Inc.

Jason Procuniar

Negative

Third-Party
Comments

CMS Energy - Consumers Energy Company

Aric Root

Affirmative

N/A

DTE Energy

Patricia Ireland

Affirmative

N/A

Electricities of North Carolina

Marcus Freeman

Abstain

N/A

FirstEnergy - FirstEnergy Corporation

Mark Garza

Negative

Comments
Submitted

Georgia System Operations Corporation

Katrina Lyons

Negative

Third-Party
Comments

Illinois Municipal Electric Agency

Mary Ann Todd

Abstain

N/A

North Carolina Electric Membership Corporation

Richard McCall

Negative

Third-Party
Comments

Michael Johnson

Ryan Strom

Scott Brame

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Northern California Power Agency

Marty Hostler

Negative

Comments
Submitted

Public Utility District No. 1 of Snohomish County

John D. Martinsen

Affirmative

N/A

Public Utility District No. 2 of Grant County,
Washington

Karla Weaver

Abstain

N/A

Sacramento Municipal Utility District

Foung Mua

Tim Kelley

Affirmative

N/A

Tacoma Public Utilities (Tacoma, WA)

Hien Ho

Jennie Wike

Abstain

N/A

Utility Services, Inc.

Tracy MacNicoll

Negative

Comments
Submitted

WEC Energy Group, Inc.

Matthew Beilfuss

Negative

Comments
Submitted

AEP

Thomas Foltz

Affirmative

N/A

AES - AES Corporation

Ruchi Shah

Negative

Comments
Submitted

Ameren - Ameren Missouri

Sam Dwyer

None

N/A

APS - Arizona Public Service Co.

Andrew Smith

Negative

Comments
Submitted

Associated Electric Cooperative, Inc.

Chuck Booth

Affirmative

N/A

Austin Energy

Michael Dillard

Affirmative

N/A

Avista - Avista Corporation

Glen Farmer

Affirmative

N/A

Basin Electric Power Cooperative

Amanda Wangler

None

N/A

BC Hydro and Power Authority

Helen Hamilton Harding

Affirmative

N/A

Berkshire Hathaway - NV Energy

Dwanique Spiller

Negative

Comments
Submitted

Black Hills Corporation

Sheila Suurmeier

Negative

Comments
Submitted

Bonneville Power Administration

Christopher Siewert

Affirmative

N/A

Buckeye Power, Inc.

Kevin Zemanek

Negative

Third-Party
Comments

CMS Energy - Consumers Energy Company

David Greyerbiehl

Affirmative

N/A

Colorado Springs Utilities

Jeffrey Icke

Affirmative

N/A

Con Ed - Consolidated Edison Co. of New York

Helen Wang

Negative

Third-Party
Comments

Constellation

Alison MacKellar

Affirmative

N/A

Dairyland Power Cooperative

Tommy Drea

Negative

Third-Party
Comments

Decatur Energy Center LLC

Megan Melham

Negative

Third-Party
Comments

Duke Energy

Dale Goodwine

Negative

Comments
Submitted

Edison International - Southern California Edison
Company

Selene Willis

Negative

Comments
Submitted

Enel Green Power

Natalie Johnson

Abstain

N/A

Gail Golden

Negative

Comments
Submitted

5
Entergy - Entergy Services, Inc.
© 2024 - NERC Ver 4.2.1.0 Machine Name: ATLVPEROWEB02

Ryan Strom

Segment

Organization

Voter

Evergy

Jeremy Harris

FirstEnergy - FirstEnergy Corporation

Designated Proxy

NERC Memo

Negative

Comments
Submitted

Matthew Augustin

Negative

Comments
Submitted

Great River Energy

Jacalynn Bentz

Negative

Third-Party
Comments

Greybeard Compliance Services, LLC

Mike Gabriel

Negative

Third-Party
Comments

Hydro-Quebec (HQ)

Junji Yamaguchi

Affirmative

N/A

Imperial Irrigation District

Tino Zaragoza

Affirmative

N/A

Invenergy LLC

Rhonda Jones

Affirmative

N/A

JEA

John Babik

Affirmative

N/A

Lincoln Electric System

Brittany Millard

Negative

Third-Party
Comments

Los Angeles Department of Water and Power

Robert Kerrigan

None

N/A

Lower Colorado River Authority

Teresa Krabe

Affirmative

N/A

LS Power Development, LLC

C. A. Campbell

Affirmative

N/A

National Grid USA

Robin Berry

Negative

Third-Party
Comments

NB Power Corporation - New Brunswick Power
Transmission Corporation

Fon Hiew

Abstain

N/A

Nebraska Public Power District

Ronald Bender

Negative

Third-Party
Comments

New York Power Authority

Zahid Qayyum

Negative

Comments
Submitted

NextEra Energy

Richard Vendetti

Abstain

N/A

NiSource - Northern Indiana Public Service Co.

Kathryn Tackett

Affirmative

N/A

North Carolina Electric Membership Corporation

Reid Cashion

Negative

Third-Party
Comments

Northern California Power Agency

Jeremy Lawson

Negative

Comments
Submitted

NRG - NRG Energy, Inc.

Patricia Lynch

Negative

Comments
Submitted

OGE Energy - Oklahoma Gas and Electric Co.

Patrick Wells

Negative

Third-Party
Comments

Omaha Public Power District

Kayleigh Wilkerson

Negative

Third-Party
Comments

Ontario Power Generation Inc.

Constantin Chitescu

Affirmative

N/A

OTP - Otter Tail Power Company

Stacy Wahlund

Negative

Third-Party
Comments

Pacific Gas and Electric Company

Frank Lee

Negative

Comments
Submitted

Pattern Operators LP

George E Brown

Negative

Third-Party
Comments

Platte River Power Authority

Jon Osell

None

N/A

Ryan Olson

None

N/A

Alan Kloster

Ballot

Denise Sanchez

Scott Brame

Michael Johnson

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

PSEG Nuclear LLC

Tim Kucey

Negative

Third-Party
Comments

Public Utility District No. 1 of Chelan County

Rebecca Zahler

Affirmative

N/A

Public Utility District No. 1 of Snohomish County

Becky Burden

Affirmative

N/A

Public Utility District No. 2 of Grant County,
Washington

Nikkee Hebdon

None

N/A

Sacramento Municipal Utility District

Ryder Couch

Tim Kelley

Affirmative

N/A

Salt River Project

Thomas Johnson

Israel Perez

Affirmative

N/A

Santee Cooper

Carey Salisbury

None

N/A

Seminole Electric Cooperative, Inc.

Melanie Wong

Abstain

N/A

Sempra - San Diego Gas and Electric

Jennifer Wright

Affirmative

N/A

Southern Company - Southern Company
Generation

Leslie Burke

Affirmative

N/A

Southern Indiana Gas and Electric Co.

Larry Rogers

Affirmative

N/A

Tacoma Public Utilities (Tacoma, WA)

Ozan Ferrin

Abstain

N/A

Talen Generation, LLC

Donald Lock

Affirmative

N/A

Tennessee Valley Authority

Darren Boehm

Negative

Comments
Submitted

TransAlta Corporation

Ashley Scheelar

Abstain

N/A

Tri-State G and T Association, Inc.

Sergio Banuelos

Negative

Comments
Submitted

U.S. Bureau of Reclamation

Wendy Kalidass

Abstain

N/A

Vistra Energy

Daniel Roethemeyer

Affirmative

N/A

WEC Energy Group, Inc.

Clarice Zellmer

Negative

Comments
Submitted

Xcel Energy, Inc.

Gerry Huitt

None

N/A

AEP

Mathew Miller

Affirmative

N/A

Ameren - Ameren Services

Robert Quinlivan

None

N/A

APS - Arizona Public Service Co.

Marcus Bortman

Negative

Comments
Submitted

Arkansas Electric Cooperative Corporation

Bruce Walkup

Abstain

N/A

Austin Energy

Imane Mrini

Affirmative

N/A

Black Hills Corporation

Rachel Schuldt

Negative

Comments
Submitted

Bonneville Power Administration

Tanner Brier

Affirmative

N/A

Cleco Corporation

Robert Hirchak

Negative

Third-Party
Comments

Con Ed - Consolidated Edison Co. of New York

Jason Chandler

Negative

Third-Party
Comments

Constellation

Kimberly Turco

Affirmative

N/A

CPower

Aaron Breidenbaugh

Negative

Third-Party
Comments

Jennie Wike

David Vickers

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Dominion - Dominion Resources, Inc.

Sean Bodkin

Negative

Comments
Submitted

Duke Energy

John Sturgeon

Negative

Comments
Submitted

Entergy

Julie Hall

Negative

Comments
Submitted

Evergy

Tiffany Lake

Negative

Comments
Submitted

FirstEnergy - FirstEnergy Corporation

Stacey Sheehan

Negative

Comments
Submitted

Imperial Irrigation District

Diana Torres

Affirmative

N/A

Invenergy LLC

Colin Chilcoat

Affirmative

N/A

Lakeland Electric

Paul Shipps

Affirmative

N/A

Lincoln Electric System

Eric Ruskamp

Negative

Comments
Submitted

Los Angeles Department of Water and Power

Anton Vu

Abstain

N/A

Manitoba Hydro

Kelly Bertholet

Negative

Comments
Submitted

Muscatine Power and Water

Nicholas Burns

Negative

Third-Party
Comments

New York Power Authority

Shelly Dineen

Negative

Comments
Submitted

NextEra Energy - Florida Power and Light Co.

Justin Welty

Abstain

N/A

NiSource - Northern Indiana Public Service Co.

Joseph OBrien

Affirmative

N/A

Northern California Power Agency

Dennis Sismaet

Negative

Comments
Submitted

OGE Energy - Oklahoma Gas and Electric Co.

Ashley F Stringer

Negative

Third-Party
Comments

Omaha Public Power District

Shonda McCain

Negative

Third-Party
Comments

Platte River Power Authority

Sabrina Martz

Abstain

N/A

Portland General Electric Co.

Stefanie Burke

None

N/A

Powerex Corporation

Raj Hundal

Affirmative

N/A

PPL - Louisville Gas and Electric Co.

Linn Oelker

Affirmative

N/A

PSEG - PSEG Energy Resources and Trade LLC

Laura Wu

Negative

Third-Party
Comments

Public Utility District No. 1 of Chelan County

Anne Kronshage

Affirmative

N/A

Sacramento Municipal Utility District

Charles Norton

Tim Kelley

Affirmative

N/A

Salt River Project

Timothy Singh

Israel Perez

Affirmative

N/A

Santee Cooper

Marty Watson

None

N/A

Seminole Electric Cooperative, Inc.

Bret Galbraith

None

N/A

Snohomish County PUD No. 1

John Liang

Affirmative

N/A

Ron Carlsen

Affirmative

N/A

Southern Company - Southern Company
Generation
© 2024 - NERC Ver 4.2.1.0 Machine Name: ATLVPEROWEB02

Alan Kloster

Denise Sanchez

Segment

Organization

Voter

Southern Indiana Gas and Electric Co.

Kati Barr

Tacoma Public Utilities (Tacoma, WA)

Terry Gifford

Tennessee Valley Authority

Designated Proxy

Ballot

NERC Memo

Affirmative

N/A

Abstain

N/A

Armando Rodriguez

Negative

Comments
Submitted

WEC Energy Group, Inc.

David Boeshaar

Negative

Comments
Submitted

Western Area Power Administration

Jennifer Neville

Negative

Comments
Submitted

Xcel Energy, Inc.

Steve Szablya

None

N/A

Midwest Reliability Organization

Mark Flanary

Affirmative

N/A

New York State Reliability Council

Wesley Yeomans

None

N/A

Northeast Power Coordinating Council

Gerry Dunbar

Abstain

N/A

ReliabilityFirst

Lindsey Mannion

Affirmative

N/A

SERC Reliability Corporation

Dave Krueger

Affirmative

N/A

Texas Reliability Entity, Inc.

Rachel Coyne

Negative

Comments
Submitted

Western Electricity Coordinating Council

Steven Rueckert

Affirmative

N/A

Jennie Wike

Previous
Showing 1 to 282 of 282 entries

NERC Balloting Tool (/)

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Users

Ballots

Comment Forms

BALLOT RESULTS
Comment: View Comment Results (/CommentResults/Index/310)
Ballot Name: 2020-06 Verifications of Models and Data for Generators IBR Unit IN 1 DEF
Voting Start Date: 12/29/2023 12:01:00 AM
Voting End Date: 1/9/2024 8:00:00 PM
Ballot Type: DEF
Ballot Activity: IN
Ballot Series: 1
Total # Votes: 252
Total Ballot Pool: 281
Quorum: 89.68
Quorum Established Date: 1/9/2024 3:20:45 PM
Weighted Segment Value: 45.04
Ballot
Pool

Segment
Weight

Affirmative
Votes

Affirmative
Fraction

Negative Votes w/
Comment

Negative Fraction
w/ Comment

Negative Votes w/o
Comment

Abstain

No
Vote

Segment:
1

0.407

0.593

Segment:
2

0.7

0.3

0.4

Segment:
3

0.362

0.638

Segment:
4

0.462

0.538

Segment:
5

0.456

0.544

Segment:
6

0.405

0.595

Segment:
7

Segment:
8

Segment:
9

Segment:
10

0.5

0.4

0.1

Totals:

281

6.2

2.792

127

3.408

Segment

BALLOT POOL MEMBERS
Show

All

Segment

entries
Organization

1
AEP - AEP Service Corporation
© 2024 - NERC Ver 4.2.1.0 Machine Name: ATLVPEROWEB02

Search:
Voter
Dennis Sauriol

Designated Proxy

Ballot
Affirmative

NERC Memo
N/A

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Allete - Minnesota Power, Inc.

Hillary Creurer

None

N/A

Ameren - Ameren Services

Tamara Evey

None

N/A

American Transmission Company, LLC

LaTroy Brumfield

Negative

Comments
Submitted

APS - Arizona Public Service Co.

Daniela Atanasovski

Negative

Comments
Submitted

Arizona Electric Power Cooperative, Inc.

Jennifer Bray

Negative

Comments
Submitted

Arkansas Electric Cooperative Corporation

Emily Corley

Abstain

N/A

Associated Electric Cooperative, Inc.

Mark Riley

Affirmative

N/A

Austin Energy

Thomas Standifur

Affirmative

N/A

Avista - Avista Corporation

Mike Magruder

Affirmative

N/A

Balancing Authority of Northern California

Kevin Smith

Affirmative

N/A

BC Hydro and Power Authority

Adrian Andreoiu

Affirmative

N/A

Berkshire Hathaway Energy - MidAmerican Energy
Co.

Terry Harbour

Negative

Comments
Submitted

Black Hills Corporation

Micah Runner

Negative

Comments
Submitted

CenterPoint Energy Houston Electric, LLC

Daniela Hammons

Abstain

N/A

City Utilities of Springfield, Missouri

Michael Bowman

Negative

Third-Party
Comments

Con Ed - Consolidated Edison Co. of New York

Dermot Smyth

Negative

Third-Party
Comments

Dairyland Power Cooperative

Karrie Schuldt

Abstain

N/A

Dominion - Dominion Virginia Power

Elizabeth Weber

Negative

Comments
Submitted

Duke Energy

Katherine Street

Negative

Comments
Submitted

Edison International - Southern California Edison
Company

Robert Blackney

Negative

Comments
Submitted

Entergy

Brian Lindsey

Affirmative

N/A

Evergy

Kevin Frick

Negative

Comments
Submitted

Eversource Energy

Joshua London

Affirmative

N/A

Exelon

Daniel Gacek

Negative

Comments
Submitted

FirstEnergy - FirstEnergy Corporation

Theresa Ciancio

Negative

Comments
Submitted

Georgia Transmission Corporation

Greg Davis

Negative

Comments
Submitted

Glencoe Light and Power Commission

Terry Volkmann

Negative

Third-Party
Comments

Hydro One Networks, Inc.

Alain Mukama

Abstain

N/A

Hydro-Quebec (HQ)

Nicolas Turcotte

Affirmative

N/A

Sean Steffensen

None

N/A

Tim Kelley

Alan Kloster

Stephen Stafford

Ijad Dewan

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Imperial Irrigation District

Jesus Sammy Alcaraz

Denise Sanchez

Affirmative

N/A

International Transmission Company Holdings
Corporation

Michael Moltane

Gail Elliott

Negative

Comments
Submitted

JEA

Joseph McClung

Affirmative

N/A

Lakeland Electric

Larry Watt

Affirmative

N/A

Lincoln Electric System

Josh Johnson

Negative

Comments
Submitted

Long Island Power Authority

Isidoro Behar

Abstain

N/A

Los Angeles Department of Water and Power

faranak sarbaz

None

N/A

LS Power Transmission, LLC

Jennifer Richardson

Affirmative

N/A

Manitoba Hydro

Nazra Gladu

Jay Sethi

Negative

Comments
Submitted

Minnkota Power Cooperative Inc.

Theresa Allard

Nikki Carson-Marquis

Negative

Comments
Submitted

Muscatine Power and Water

Andrew Kurriger

Negative

Third-Party
Comments

National Grid USA

Michael Jones

Negative

Third-Party
Comments

NB Power Corporation

Jeffrey Streifling

Abstain

N/A

Nebraska Public Power District

Jamison Cawley

Negative

Third-Party
Comments

NextEra Energy - Florida Power and Light Co.

Silvia Mitchell

Abstain

N/A

NiSource - Northern Indiana Public Service Co.

Alison Nickells

Affirmative

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Terri Pyle

Negative

Third-Party
Comments

Omaha Public Power District

Doug Peterchuck

Negative

Third-Party
Comments

Oncor Electric Delivery

Byron Booker

Negative

Comments
Submitted

OTP - Otter Tail Power Company

Charles Wicklund

Negative

Third-Party
Comments

Pacific Gas and Electric Company

Marco Rios

Negative

Comments
Submitted

Pedernales Electric Cooperative, Inc.

Bradley Collard

None

N/A

Platte River Power Authority

Marissa Archie

Abstain

N/A

PNM Resources - Public Service Company of New
Mexico

Lynn Goldstein

Negative

Comments
Submitted

Portland General Electric Co.

Brooke Jockin

None

N/A

PPL Electric Utilities Corporation

Michelle McCartney
Longo

Affirmative

N/A

PSEG - Public Service Electric and Gas Co.

Karen Arnold

Negative

Third-Party
Comments

Public Utility District No. 1 of Chelan County

Diane E Landry

Affirmative

N/A

Public Utility District No. 1 of Snohomish County

Alyssia Rhoads

Affirmative

N/A

Affirmative

N/A

Wei Shao

Tammy Porter

Michael Johnson

Tim Kelley

Segment

Organization

Voter

Salt River Project

Sarah Blankenship

Santee Cooper

Designated Proxy

NERC Memo

Affirmative

N/A

Chris Wagner

None

N/A

SaskPower

Wayne Guttormson

Abstain

N/A

Sempra - San Diego Gas and Electric

Mohamed Derbas

Affirmative

N/A

Southern Company - Southern Company Services,
Inc.

Matt Carden

Affirmative

N/A

Sunflower Electric Power Corporation

Paul Mehlhaff

Negative

Third-Party
Comments

Tacoma Public Utilities (Tacoma, WA)

John Merrell

Abstain

N/A

Tallahassee Electric (City of Tallahassee, FL)

Scott Langston

Abstain

N/A

Tennessee Valley Authority

David Plumb

Negative

Comments
Submitted

Tri-State G and T Association, Inc.

Donna Wood

Affirmative

N/A

U.S. Bureau of Reclamation

Richard Jackson

Abstain

N/A

Western Area Power Administration

Ben Hammer

Negative

Comments
Submitted

Xcel Energy, Inc.

Eric Barry

None

N/A

California ISO

Darcy O'Connell

Abstain

N/A

Electric Reliability Council of Texas, Inc.

Kennedy Meier

Negative

Comments
Submitted

Independent Electricity System Operator

Helen Lainis

Affirmative

N/A

ISO New England, Inc.

John Pearson

Affirmative

N/A

Midcontinent ISO, Inc.

Bobbi Welch

Negative

Third-Party
Comments

New York Independent System Operator

Gregory Campoli

Affirmative

N/A

PJM Interconnection, L.L.C.

Thomas Foster

Elizabeth Davis

Negative

Third-Party
Comments

Southwest Power Pool, Inc. (RTO)

Joshua Phillips

Shannon Mickens

Negative

Comments
Submitted

AEP

Kent Feliks

Affirmative

N/A

Ameren - Ameren Services

David Jendras Sr

None

N/A

APS - Arizona Public Service Co.

Jessica Lopez

Negative

Comments
Submitted

Arkansas Electric Cooperative Corporation

Ayslynn Mcavoy

Abstain

N/A

Avista - Avista Corporation

Robert Follini

Affirmative

N/A

BC Hydro and Power Authority

Ming Jiang

Affirmative

N/A

Berkshire Hathaway Energy - MidAmerican Energy
Co.

Joseph Amato

Negative

Comments
Submitted

Black Hills Corporation

Josh Combs

Carly Miller

Negative

Comments
Submitted

Buckeye Power, Inc.

Carl Spaetzel

Ryan Strom

Negative

Third-Party
Comments

None

N/A

3
CMS Energy - Consumers Energy Company
© 2024 - NERC Ver 4.2.1.0 Machine Name: ATLVPEROWEB02

Karl Blaszkowski

Israel Perez

Ballot

Jennie Wike

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Colorado Springs Utilities

Hillary Dobson

Affirmative

N/A

Con Ed - Consolidated Edison Co. of New York

Peter Yost

Negative

Third-Party
Comments

Dominion - Dominion Virginia Power

Bill Garvey

Negative

Comments
Submitted

DTE Energy - Detroit Edison Company

Marvin Johnson

Affirmative

N/A

Duke Energy - Florida Power Corporation

Marcelo Pesantez

Negative

Comments
Submitted

Edison International - Southern California Edison
Company

Romel Aquino

Negative

Comments
Submitted

Entergy

James Keele

Negative

Comments
Submitted

Evergy

Marcus Moor

Negative

Comments
Submitted

Eversource Energy

Vicki O'Leary

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Aaron Ghodooshim

Negative

Comments
Submitted

Georgia System Operations Corporation

Scott McGough

Negative

Third-Party
Comments

Great River Energy

Michael Brytowski

Negative

Third-Party
Comments

Imperial Irrigation District

George Kirschner

Affirmative

N/A

JEA

Marilyn Williams

Affirmative

N/A

Lakeland Electric

Steven Marshall

Affirmative

N/A

Lincoln Electric System

Sam Christensen

Negative

Comments
Submitted

Los Angeles Department of Water and Power

Fausto Serratos

None

N/A

Manitoba Hydro

Mike Smith

Negative

Comments
Submitted

MGE Energy - Madison Gas and Electric Co.

Benjamin Widder

Negative

Third-Party
Comments

Muscatine Power and Water

Seth Shoemaker

Negative

Third-Party
Comments

National Grid USA

Brian Shanahan

Negative

Third-Party
Comments

Nebraska Public Power District

Tony Eddleman

Negative

Third-Party
Comments

New York Power Authority

David Rivera

Negative

Comments
Submitted

NextEra Energy - Florida Power and Light Co.

Karen Demos

Abstain

N/A

NiSource - Northern Indiana Public Service Co.

Steven Taddeucci

Affirmative

N/A

North Carolina Electric Membership Corporation

Chris Dimisa

Scott Brame

Negative

Third-Party
Comments

Ocala Utility Services

Neville Bowen

LaKenya Vannorman

None

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Donald Hargrove

Negative

Third-Party
Comments

Alan Kloster

Denise Sanchez

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Old Dominion Electric Coop.

William Pezalla

None

N/A

Omaha Public Power District

David Heins

Negative

Third-Party
Comments

OTP - Otter Tail Power Company

Wendi Olson

Negative

Third-Party
Comments

Pacific Gas and Electric Company

Sandra Ellis

Negative

Comments
Submitted

PNM Resources - Public Service Company of New
Mexico

Amy Wesselkamper

Negative

Comments
Submitted

PPL - Louisville Gas and Electric Co.

James Frank

None

N/A

PSEG - Public Service Electric and Gas Co.

Christopher Murphy

Negative

Third-Party
Comments

Public Utility District No. 1 of Chelan County

Joyce Gundry

Affirmative

N/A

Sacramento Municipal Utility District

Nicole Looney

Tim Kelley

Affirmative

N/A

Salt River Project

Mathew Weber

Israel Perez

Affirmative

N/A

Santee Cooper

Vicky Budreau

None

N/A

Sempra - San Diego Gas and Electric

Bryan Bennett

Affirmative

N/A

Snohomish County PUD No. 1

Holly Chaney

Affirmative

N/A

Southern Company - Alabama Power Company

Joel Dembowski

Affirmative

N/A

Southern Indiana Gas and Electric Co.

Ryan Snyder

Negative

Comments
Submitted

Tennessee Valley Authority

Ian Grant

Negative

Comments
Submitted

Tri-State G and T Association, Inc.

Ryan Walter

Affirmative

N/A

WEC Energy Group, Inc.

Christine Kane

Negative

Comments
Submitted

Xcel Energy, Inc.

Nicholas Friebel

None

N/A

Alliant Energy Corporation Services, Inc.

Larry Heckert

Negative

Third-Party
Comments

Austin Energy

Tony Hua

Affirmative

N/A

Buckeye Power, Inc.

Jason Procuniar

Negative

Third-Party
Comments

CMS Energy - Consumers Energy Company

Aric Root

Affirmative

N/A

DTE Energy

Patricia Ireland

Affirmative

N/A

Electricities of North Carolina

Marcus Freeman

Abstain

N/A

FirstEnergy - FirstEnergy Corporation

Mark Garza

Negative

Comments
Submitted

Georgia System Operations Corporation

Katrina Lyons

Negative

Third-Party
Comments

Illinois Municipal Electric Agency

Mary Ann Todd

Abstain

N/A

North Carolina Electric Membership Corporation

Richard McCall

Negative

Third-Party
Comments

Northern California Power Agency

Marty Hostler

Negative

Comments
Submitted

Michael Johnson

Ryan Strom

Scott Brame

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Public Utility District No. 1 of Snohomish County

John D. Martinsen

Affirmative

N/A

Public Utility District No. 2 of Grant County,
Washington

Karla Weaver

Abstain

N/A

Sacramento Municipal Utility District

Foung Mua

Tim Kelley

Affirmative

N/A

Tacoma Public Utilities (Tacoma, WA)

Hien Ho

Jennie Wike

Abstain

N/A

Utility Services, Inc.

Tracy MacNicoll

Affirmative

N/A

WEC Energy Group, Inc.

Matthew Beilfuss

Negative

Comments
Submitted

AEP

Thomas Foltz

Affirmative

N/A

AES - AES Corporation

Ruchi Shah

Negative

Comments
Submitted

Ameren - Ameren Missouri

Sam Dwyer

None

N/A

APS - Arizona Public Service Co.

Andrew Smith

Negative

Comments
Submitted

Associated Electric Cooperative, Inc.

Chuck Booth

Affirmative

N/A

Austin Energy

Michael Dillard

Affirmative

N/A

Avista - Avista Corporation

Glen Farmer

Affirmative

N/A

Basin Electric Power Cooperative

Amanda Wangler

None

N/A

BC Hydro and Power Authority

Helen Hamilton Harding

Affirmative

N/A

Berkshire Hathaway - NV Energy

Dwanique Spiller

Negative

Comments
Submitted

Black Hills Corporation

Sheila Suurmeier

Negative

Comments
Submitted

Bonneville Power Administration

Christopher Siewert

Affirmative

N/A

Buckeye Power, Inc.

Kevin Zemanek

Negative

Third-Party
Comments

CMS Energy - Consumers Energy Company

David Greyerbiehl

Affirmative

N/A

Colorado Springs Utilities

Jeffrey Icke

Affirmative

N/A

Con Ed - Consolidated Edison Co. of New York

Helen Wang

Negative

Third-Party
Comments

Constellation

Alison MacKellar

Affirmative

N/A

Dairyland Power Cooperative

Tommy Drea

Negative

Third-Party
Comments

Decatur Energy Center LLC

Megan Melham

Negative

Third-Party
Comments

Duke Energy

Dale Goodwine

Negative

Comments
Submitted

Edison International - Southern California Edison
Company

Selene Willis

Negative

Comments
Submitted

Enel Green Power

Natalie Johnson

Abstain

N/A

Entergy - Entergy Services, Inc.

Gail Golden

Negative

Comments
Submitted

Evergy

Jeremy Harris

Negative

Comments
Submitted

Ryan Strom

Alan Kloster

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

FirstEnergy - FirstEnergy Corporation

Matthew Augustin

Negative

Comments
Submitted

Great River Energy

Jacalynn Bentz

Negative

Third-Party
Comments

Greybeard Compliance Services, LLC

Mike Gabriel

Negative

Third-Party
Comments

Hydro-Quebec (HQ)

Junji Yamaguchi

Affirmative

N/A

Imperial Irrigation District

Tino Zaragoza

Affirmative

N/A

Invenergy LLC

Rhonda Jones

Affirmative

N/A

JEA

John Babik

Affirmative

N/A

Lincoln Electric System

Brittany Millard

Negative

Third-Party
Comments

Los Angeles Department of Water and Power

Robert Kerrigan

None

N/A

Lower Colorado River Authority

Teresa Krabe

Affirmative

N/A

LS Power Development, LLC

C. A. Campbell

Affirmative

N/A

National Grid USA

Robin Berry

Negative

Third-Party
Comments

NB Power Corporation - New Brunswick Power
Transmission Corporation

Fon Hiew

Abstain

N/A

Nebraska Public Power District

Ronald Bender

Negative

Third-Party
Comments

New York Power Authority

Zahid Qayyum

Negative

Comments
Submitted

NextEra Energy

Richard Vendetti

Abstain

N/A

NiSource - Northern Indiana Public Service Co.

Kathryn Tackett

Affirmative

N/A

North Carolina Electric Membership Corporation

Reid Cashion

Negative

Third-Party
Comments

Northern California Power Agency

Jeremy Lawson

Negative

Comments
Submitted

NRG - NRG Energy, Inc.

Patricia Lynch

Negative

Comments
Submitted

OGE Energy - Oklahoma Gas and Electric Co.

Patrick Wells

Negative

Third-Party
Comments

Omaha Public Power District

Kayleigh Wilkerson

Negative

Third-Party
Comments

Ontario Power Generation Inc.

Constantin Chitescu

Affirmative

N/A

OTP - Otter Tail Power Company

Stacy Wahlund

Negative

Third-Party
Comments

Pacific Gas and Electric Company

Frank Lee

Negative

Comments
Submitted

Pattern Operators LP

George E Brown

Negative

Third-Party
Comments

Platte River Power Authority

Jon Osell

None

N/A

Portland General Electric Co.

Ryan Olson

None

N/A

Tim Kucey

Negative

Third-Party
Comments

5
PSEG Nuclear LLC
© 2024 - NERC Ver 4.2.1.0 Machine Name: ATLVPEROWEB02

Denise Sanchez

Scott Brame

Michael Johnson

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Public Utility District No. 1 of Chelan County

Rebecca Zahler

Affirmative

N/A

Public Utility District No. 1 of Snohomish County

Becky Burden

Affirmative

N/A

Public Utility District No. 2 of Grant County,
Washington

Nikkee Hebdon

None

N/A

Sacramento Municipal Utility District

Ryder Couch

Tim Kelley

Affirmative

N/A

Salt River Project

Thomas Johnson

Israel Perez

Affirmative

N/A

Santee Cooper

Carey Salisbury

None

N/A

Seminole Electric Cooperative, Inc.

Melanie Wong

Abstain

N/A

Sempra - San Diego Gas and Electric

Jennifer Wright

Affirmative

N/A

Southern Company - Southern Company
Generation

Leslie Burke

Affirmative

N/A

Southern Indiana Gas and Electric Co.

Larry Rogers

Negative

Comments
Submitted

Tacoma Public Utilities (Tacoma, WA)

Ozan Ferrin

Abstain

N/A

Talen Generation, LLC

Donald Lock

Affirmative

N/A

Tennessee Valley Authority

Darren Boehm

Negative

Comments
Submitted

TransAlta Corporation

Ashley Scheelar

Abstain

N/A

Tri-State G and T Association, Inc.

Sergio Banuelos

Affirmative

N/A

U.S. Bureau of Reclamation

Wendy Kalidass

Abstain

N/A

Vistra Energy

Daniel Roethemeyer

Affirmative

N/A

WEC Energy Group, Inc.

Clarice Zellmer

Negative

Comments
Submitted

Xcel Energy, Inc.

Gerry Huitt

None

N/A

AEP

Mathew Miller

Affirmative

N/A

Ameren - Ameren Services

Robert Quinlivan

None

N/A

APS - Arizona Public Service Co.

Marcus Bortman

Negative

Comments
Submitted

Arkansas Electric Cooperative Corporation

Bruce Walkup

Abstain

N/A

Austin Energy

Imane Mrini

Affirmative

N/A

Black Hills Corporation

Rachel Schuldt

Negative

Comments
Submitted

Bonneville Power Administration

Tanner Brier

Affirmative

N/A

Cleco Corporation

Robert Hirchak

Negative

Third-Party
Comments

Con Ed - Consolidated Edison Co. of New York

Jason Chandler

Negative

Third-Party
Comments

Constellation

Kimberly Turco

Affirmative

N/A

CPower

Aaron Breidenbaugh

Negative

Third-Party
Comments

Dominion - Dominion Resources, Inc.

Sean Bodkin

Negative

Comments
Submitted

Jennie Wike

David Vickers

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Duke Energy

John Sturgeon

Negative

Comments
Submitted

Entergy

Julie Hall

Negative

Comments
Submitted

Evergy

Tiffany Lake

Negative

Comments
Submitted

FirstEnergy - FirstEnergy Corporation

Stacey Sheehan

Negative

Comments
Submitted

Imperial Irrigation District

Diana Torres

Affirmative

N/A

Invenergy LLC

Colin Chilcoat

Affirmative

N/A

Lakeland Electric

Paul Shipps

Affirmative

N/A

Lincoln Electric System

Eric Ruskamp

Negative

Comments
Submitted

Los Angeles Department of Water and Power

Anton Vu

Abstain

N/A

Manitoba Hydro

Kelly Bertholet

Negative

Comments
Submitted

Muscatine Power and Water

Nicholas Burns

Negative

Third-Party
Comments

New York Power Authority

Shelly Dineen

Negative

Comments
Submitted

NextEra Energy - Florida Power and Light Co.

Justin Welty

Abstain

N/A

NiSource - Northern Indiana Public Service Co.

Joseph OBrien

Affirmative

N/A

Northern California Power Agency

Dennis Sismaet

Negative

Comments
Submitted

OGE Energy - Oklahoma Gas and Electric Co.

Ashley F Stringer

Negative

Third-Party
Comments

Omaha Public Power District

Shonda McCain

Negative

Third-Party
Comments

Platte River Power Authority

Sabrina Martz

Abstain

N/A

Portland General Electric Co.

Stefanie Burke

None

N/A

Powerex Corporation

Raj Hundal

Affirmative

N/A

PPL - Louisville Gas and Electric Co.

Linn Oelker

Affirmative

N/A

PSEG - PSEG Energy Resources and Trade LLC

Laura Wu

Negative

Third-Party
Comments

Public Utility District No. 1 of Chelan County

Anne Kronshage

Affirmative

N/A

Sacramento Municipal Utility District

Charles Norton

Tim Kelley

Affirmative

N/A

Salt River Project

Timothy Singh

Israel Perez

Affirmative

N/A

Santee Cooper

Marty Watson

None

N/A

Seminole Electric Cooperative, Inc.

Bret Galbraith

None

N/A

Snohomish County PUD No. 1

John Liang

Affirmative

N/A

Southern Company - Southern Company
Generation

Ron Carlsen

Affirmative

N/A

Southern Indiana Gas and Electric Co.

Kati Barr

Negative

Comments
Submitted

Alan Kloster

Denise Sanchez

Segment

Organization

Voter

Tacoma Public Utilities (Tacoma, WA)

Terry Gifford

Tennessee Valley Authority

Designated Proxy
Jennie Wike

Ballot

NERC Memo

Abstain

N/A

Armando Rodriguez

Negative

Comments
Submitted

WEC Energy Group, Inc.

David Boeshaar

Negative

Comments
Submitted

Western Area Power Administration

Jennifer Neville

Negative

Comments
Submitted

Xcel Energy, Inc.

Steve Szablya

None

N/A

Midwest Reliability Organization

Mark Flanary

Affirmative

N/A

Northeast Power Coordinating Council

Gerry Dunbar

Abstain

N/A

ReliabilityFirst

Lindsey Mannion

Affirmative

N/A

SERC Reliability Corporation

Dave Krueger

Affirmative

N/A

Texas Reliability Entity, Inc.

Rachel Coyne

Negative

Comments
Submitted

Western Electricity Coordinating Council

Steven Rueckert

Affirmative

N/A
Previous

Showing 1 to 281 of 281 entries

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Comment Forms

BALLOT RESULTS
Comment: View Comment Results (/CommentResults/Index/310)
Ballot Name: 2020-06 Verifications of Models and Data for Generators IBR-related Definitions | Implementation Plan IN 1 OT
Voting Start Date: 12/29/2023 12:01:00 AM
Voting End Date: 1/9/2024 8:00:00 PM
Ballot Type: OT
Ballot Activity: IN
Ballot Series: 1
Total # Votes: 249
Total Ballot Pool: 280
Quorum: 88.93
Quorum Established Date: 1/9/2024 3:21:51 PM
Weighted Segment Value: 58.52
Ballot
Pool

Segment
Weight

Affirmative
Votes

Affirmative
Fraction

Negative Votes w/
Comment

Negative Fraction
w/ Comment

Negative Votes w/o
Comment

Abstain

No
Vote

Segment:
1

0.463

0.537

Segment:
2

0.6

0.5

0.1

Segment:
3

0.467

0.533

Segment:
4

0.615

0.385

Segment:
5

0.537

0.463

Segment:
6

0.529

0.471

Segment:
7

Segment:
8

Segment:
9

Segment:
10

0.4

Totals:

280

110

3.511

100

2.489

Segment

BALLOT POOL MEMBERS
Show

All

Segment

entries
Organization

1
AEP - AEP Service Corporation
© 2024 - NERC Ver 4.2.1.0 Machine Name: ATLVPEROWEB02

Search:
Voter
Dennis Sauriol

Designated Proxy

Ballot
Affirmative

NERC Memo
N/A

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Allete - Minnesota Power, Inc.

Hillary Creurer

None

N/A

Ameren - Ameren Services

Tamara Evey

None

N/A

American Transmission Company, LLC

LaTroy Brumfield

Negative

Comments
Submitted

APS - Arizona Public Service Co.

Daniela Atanasovski

Negative

Comments
Submitted

Arizona Electric Power Cooperative, Inc.

Jennifer Bray

Negative

Comments
Submitted

Arkansas Electric Cooperative Corporation

Emily Corley

Abstain

N/A

Associated Electric Cooperative, Inc.

Mark Riley

Affirmative

N/A

Austin Energy

Thomas Standifur

Affirmative

N/A

Avista - Avista Corporation

Mike Magruder

Affirmative

N/A

Balancing Authority of Northern California

Kevin Smith

Affirmative

N/A

BC Hydro and Power Authority

Adrian Andreoiu

Abstain

N/A

Berkshire Hathaway Energy - MidAmerican Energy
Co.

Terry Harbour

Negative

Comments
Submitted

Black Hills Corporation

Micah Runner

Negative

Comments
Submitted

CenterPoint Energy Houston Electric, LLC

Daniela Hammons

Affirmative

N/A

City Utilities of Springfield, Missouri

Michael Bowman

Negative

Third-Party
Comments

Con Ed - Consolidated Edison Co. of New York

Dermot Smyth

Negative

Third-Party
Comments

Dairyland Power Cooperative

Karrie Schuldt

Abstain

N/A

Dominion - Dominion Virginia Power

Elizabeth Weber

Negative

Comments
Submitted

Duke Energy

Katherine Street

Negative

Comments
Submitted

Edison International - Southern California Edison
Company

Robert Blackney

Negative

Comments
Submitted

Entergy

Brian Lindsey

Affirmative

N/A

Evergy

Kevin Frick

Negative

Comments
Submitted

Eversource Energy

Joshua London

Affirmative

N/A

Exelon

Daniel Gacek

Negative

Comments
Submitted

FirstEnergy - FirstEnergy Corporation

Theresa Ciancio

Affirmative

N/A

Georgia Transmission Corporation

Greg Davis

Affirmative

N/A

Glencoe Light and Power Commission

Terry Volkmann

Negative

Third-Party
Comments

Hydro One Networks, Inc.

Alain Mukama

Abstain

N/A

Hydro-Quebec (HQ)

Nicolas Turcotte

Affirmative

N/A

IDACORP - Idaho Power Company

Sean Steffensen

None

N/A

Affirmative

N/A

Jesus Sammy Alcaraz

Tim Kelley

Alan Kloster

Stephen Stafford

Ijad Dewan

Denise Sanchez

Segment

Organization

Voter

International Transmission Company Holdings
Corporation

Michael Moltane

JEA

Designated Proxy

NERC Memo

Negative

Comments
Submitted

Joseph McClung

Affirmative

N/A

Lakeland Electric

Larry Watt

Affirmative

N/A

Lincoln Electric System

Josh Johnson

Negative

Comments
Submitted

Long Island Power Authority

Isidoro Behar

Abstain

N/A

Los Angeles Department of Water and Power

faranak sarbaz

None

N/A

LS Power Transmission, LLC

Jennifer Richardson

Affirmative

N/A

Manitoba Hydro

Nazra Gladu

Jay Sethi

Negative

Comments
Submitted

Minnkota Power Cooperative Inc.

Theresa Allard

Nikki Carson-Marquis

Negative

Comments
Submitted

Muscatine Power and Water

Andrew Kurriger

Negative

Third-Party
Comments

National Grid USA

Michael Jones

Negative

Third-Party
Comments

NB Power Corporation

Jeffrey Streifling

Abstain

N/A

Nebraska Public Power District

Jamison Cawley

Negative

Third-Party
Comments

NextEra Energy - Florida Power and Light Co.

Silvia Mitchell

Abstain

N/A

NiSource - Northern Indiana Public Service Co.

Alison Nickells

Affirmative

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Terri Pyle

Negative

Third-Party
Comments

Omaha Public Power District

Doug Peterchuck

Negative

Third-Party
Comments

Oncor Electric Delivery

Byron Booker

Negative

Comments
Submitted

OTP - Otter Tail Power Company

Charles Wicklund

Negative

Third-Party
Comments

Pacific Gas and Electric Company

Marco Rios

Negative

Comments
Submitted

Pedernales Electric Cooperative, Inc.

Bradley Collard

None

N/A

Platte River Power Authority

Marissa Archie

Abstain

N/A

PNM Resources - Public Service Company of New
Mexico

Lynn Goldstein

Negative

Comments
Submitted

Portland General Electric Co.

Brooke Jockin

None

N/A

PPL Electric Utilities Corporation

Michelle McCartney
Longo

Affirmative

N/A

PSEG - Public Service Electric and Gas Co.

Karen Arnold

Negative

Third-Party
Comments

Public Utility District No. 1 of Chelan County

Diane E Landry

Affirmative

N/A

Public Utility District No. 1 of Snohomish County

Alyssia Rhoads

Affirmative

N/A

Sacramento Municipal Utility District

Wei Shao

Tim Kelley

Affirmative

N/A

Sarah Blankenship

Israel Perez

Affirmative

N/A

Gail Elliott

Ballot

Tammy Porter

Michael Johnson

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Santee Cooper

Chris Wagner

None

N/A

SaskPower

Wayne Guttormson

Abstain

N/A

Sempra - San Diego Gas and Electric

Mohamed Derbas

Affirmative

N/A

Southern Company - Southern Company Services,
Inc.

Matt Carden

Affirmative

N/A

Sunflower Electric Power Corporation

Paul Mehlhaff

Negative

Third-Party
Comments

Tacoma Public Utilities (Tacoma, WA)

John Merrell

Abstain

N/A

Tallahassee Electric (City of Tallahassee, FL)

Scott Langston

Abstain

N/A

Tennessee Valley Authority

David Plumb

Affirmative

N/A

Tri-State G and T Association, Inc.

Donna Wood

Affirmative

N/A

U.S. Bureau of Reclamation

Richard Jackson

Abstain

N/A

Western Area Power Administration

Ben Hammer

Negative

Comments
Submitted

Xcel Energy, Inc.

Eric Barry

None

N/A

California ISO

Darcy O'Connell

Abstain

N/A

Electric Reliability Council of Texas, Inc.

Kennedy Meier

Affirmative

N/A

Independent Electricity System Operator

Helen Lainis

Affirmative

N/A

ISO New England, Inc.

John Pearson

Affirmative

N/A

Midcontinent ISO, Inc.

Bobbi Welch

Affirmative

N/A

New York Independent System Operator

Gregory Campoli

Affirmative

N/A

PJM Interconnection, L.L.C.

Thomas Foster

Elizabeth Davis

Abstain

N/A

Southwest Power Pool, Inc. (RTO)

Joshua Phillips

Shannon Mickens

Negative

Comments
Submitted

AEP

Kent Feliks

Affirmative

N/A

Ameren - Ameren Services

David Jendras Sr

None

N/A

APS - Arizona Public Service Co.

Jessica Lopez

Negative

Comments
Submitted

Arkansas Electric Cooperative Corporation

Ayslynn Mcavoy

Abstain

N/A

Avista - Avista Corporation

Robert Follini

Affirmative

N/A

BC Hydro and Power Authority

Ming Jiang

Abstain

N/A

Berkshire Hathaway Energy - MidAmerican Energy
Co.

Joseph Amato

Negative

Comments
Submitted

Black Hills Corporation

Josh Combs

Carly Miller

Negative

Comments
Submitted

Buckeye Power, Inc.

Carl Spaetzel

Ryan Strom

Negative

Third-Party
Comments

CMS Energy - Consumers Energy Company

Karl Blaszkowski

None

N/A

Colorado Springs Utilities

Hillary Dobson

Affirmative

N/A

Con Ed - Consolidated Edison Co. of New York

Peter Yost

Negative

Third-Party
Comments

Jennie Wike

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Dominion - Dominion Virginia Power

Bill Garvey

Negative

Comments
Submitted

DTE Energy - Detroit Edison Company

Marvin Johnson

Affirmative

N/A

Duke Energy - Florida Power Corporation

Marcelo Pesantez

Negative

Comments
Submitted

Edison International - Southern California Edison
Company

Romel Aquino

Negative

Comments
Submitted

Entergy

James Keele

Affirmative

N/A

Evergy

Marcus Moor

Negative

Comments
Submitted

Eversource Energy

Vicki O'Leary

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Aaron Ghodooshim

Affirmative

N/A

Georgia System Operations Corporation

Scott McGough

Affirmative

N/A

Great River Energy

Michael Brytowski

Negative

Third-Party
Comments

Imperial Irrigation District

George Kirschner

Affirmative

N/A

JEA

Marilyn Williams

Affirmative

N/A

Lakeland Electric

Steven Marshall

Affirmative

N/A

Lincoln Electric System

Sam Christensen

Negative

Comments
Submitted

Los Angeles Department of Water and Power

Fausto Serratos

None

N/A

Manitoba Hydro

Mike Smith

Negative

Comments
Submitted

MGE Energy - Madison Gas and Electric Co.

Benjamin Widder

Negative

Third-Party
Comments

Muscatine Power and Water

Seth Shoemaker

Negative

Third-Party
Comments

National Grid USA

Brian Shanahan

Negative

Third-Party
Comments

Nebraska Public Power District

Tony Eddleman

Negative

Third-Party
Comments

New York Power Authority

David Rivera

Negative

Comments
Submitted

NextEra Energy - Florida Power and Light Co.

Karen Demos

Abstain

N/A

NiSource - Northern Indiana Public Service Co.

Steven Taddeucci

Affirmative

N/A

North Carolina Electric Membership Corporation

Chris Dimisa

Scott Brame

Negative

Third-Party
Comments

Ocala Utility Services

Neville Bowen

LaKenya Vannorman

None

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Donald Hargrove

Negative

Third-Party
Comments

Old Dominion Electric Coop.

William Pezalla

None

N/A

Omaha Public Power District

David Heins

Negative

Third-Party
Comments

OTP - Otter Tail Power Company

Wendi Olson

Negative

Third-Party
Comments

Alan Kloster

Denise Sanchez

Segment

Organization

Voter

Pacific Gas and Electric Company

Sandra Ellis

PNM Resources - Public Service Company of New
Mexico

Designated Proxy

NERC Memo

Negative

Comments
Submitted

Amy Wesselkamper

Negative

Comments
Submitted

PPL - Louisville Gas and Electric Co.

James Frank

None

N/A

PSEG - Public Service Electric and Gas Co.

Christopher Murphy

Abstain

N/A

Public Utility District No. 1 of Chelan County

Joyce Gundry

Affirmative

N/A

Sacramento Municipal Utility District

Nicole Looney

Tim Kelley

Affirmative

N/A

Salt River Project

Mathew Weber

Israel Perez

Affirmative

N/A

Santee Cooper

Vicky Budreau

None

N/A

Sempra - San Diego Gas and Electric

Bryan Bennett

Affirmative

N/A

Snohomish County PUD No. 1

Holly Chaney

Affirmative

N/A

Southern Company - Alabama Power Company

Joel Dembowski

Affirmative

N/A

Southern Indiana Gas and Electric Co.

Ryan Snyder

Affirmative

N/A

Tennessee Valley Authority

Ian Grant

Affirmative

N/A

Tri-State G and T Association, Inc.

Ryan Walter

Affirmative

N/A

WEC Energy Group, Inc.

Christine Kane

Negative

Comments
Submitted

Xcel Energy, Inc.

Nicholas Friebel

None

N/A

Alliant Energy Corporation Services, Inc.

Larry Heckert

Negative

Third-Party
Comments

Austin Energy

Tony Hua

Affirmative

N/A

Buckeye Power, Inc.

Jason Procuniar

Negative

Third-Party
Comments

CMS Energy - Consumers Energy Company

Aric Root

Affirmative

N/A

DTE Energy

Patricia Ireland

Affirmative

N/A

Electricities of North Carolina

Marcus Freeman

Abstain

N/A

FirstEnergy - FirstEnergy Corporation

Mark Garza

Affirmative

N/A

Georgia System Operations Corporation

Katrina Lyons

Affirmative

N/A

Illinois Municipal Electric Agency

Mary Ann Todd

Abstain

N/A

North Carolina Electric Membership Corporation

Richard McCall

Negative

Third-Party
Comments

Northern California Power Agency

Marty Hostler

Negative

Comments
Submitted

Public Utility District No. 1 of Snohomish County

John D. Martinsen

Affirmative

N/A

Public Utility District No. 2 of Grant County,
Washington

Karla Weaver

Abstain

N/A

Sacramento Municipal Utility District

Foung Mua

Tim Kelley

Affirmative

N/A

Tacoma Public Utilities (Tacoma, WA)

Hien Ho

Jennie Wike

Abstain

N/A

Utility Services, Inc.

Tracy MacNicoll

Affirmative

N/A

Matthew Beilfuss

Negative

Comments
Submitted

4
WEC Energy Group, Inc.
© 2024 - NERC Ver 4.2.1.0 Machine Name: ATLVPEROWEB02

Michael Johnson

Ballot

Ryan Strom

Scott Brame

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

AEP

Thomas Foltz

Affirmative

N/A

AES - AES Corporation

Ruchi Shah

Affirmative

N/A

Ameren - Ameren Missouri

Sam Dwyer

None

N/A

APS - Arizona Public Service Co.

Andrew Smith

Negative

Comments
Submitted

Associated Electric Cooperative, Inc.

Chuck Booth

Affirmative

N/A

Austin Energy

Michael Dillard

Affirmative

N/A

Avista - Avista Corporation

Glen Farmer

Affirmative

N/A

Basin Electric Power Cooperative

Amanda Wangler

None

N/A

BC Hydro and Power Authority

Helen Hamilton Harding

Abstain

N/A

Berkshire Hathaway - NV Energy

Dwanique Spiller

Negative

Comments
Submitted

Black Hills Corporation

Sheila Suurmeier

Negative

Comments
Submitted

Bonneville Power Administration

Christopher Siewert

Affirmative

N/A

Buckeye Power, Inc.

Kevin Zemanek

Negative

Third-Party
Comments

CMS Energy - Consumers Energy Company

David Greyerbiehl

Affirmative

N/A

Colorado Springs Utilities

Jeffrey Icke

Affirmative

N/A

Con Ed - Consolidated Edison Co. of New York

Helen Wang

Negative

Third-Party
Comments

Constellation

Alison MacKellar

Affirmative

N/A

Dairyland Power Cooperative

Tommy Drea

Negative

Third-Party
Comments

Decatur Energy Center LLC

Megan Melham

Negative

Third-Party
Comments

Duke Energy

Dale Goodwine

Negative

Comments
Submitted

Edison International - Southern California Edison
Company

Selene Willis

Negative

Comments
Submitted

Enel Green Power

Natalie Johnson

Abstain

N/A

Entergy - Entergy Services, Inc.

Gail Golden

Affirmative

N/A

Evergy

Jeremy Harris

Negative

Comments
Submitted

FirstEnergy - FirstEnergy Corporation

Matthew Augustin

Affirmative

N/A

Great River Energy

Jacalynn Bentz

Negative

Third-Party
Comments

Greybeard Compliance Services, LLC

Mike Gabriel

Negative

Third-Party
Comments

Hydro-Quebec (HQ)

Junji Yamaguchi

Affirmative

N/A

Imperial Irrigation District

Tino Zaragoza

Affirmative

N/A

Invenergy LLC

Rhonda Jones

Affirmative

N/A

John Babik

Affirmative

N/A

5
JEA
© 2024 - NERC Ver 4.2.1.0 Machine Name: ATLVPEROWEB02

Ryan Strom

Alan Kloster

Denise Sanchez

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Lincoln Electric System

Brittany Millard

Negative

Third-Party
Comments

Los Angeles Department of Water and Power

Robert Kerrigan

None

N/A

Lower Colorado River Authority

Teresa Krabe

Affirmative

N/A

LS Power Development, LLC

C. A. Campbell

Affirmative

N/A

National Grid USA

Robin Berry

Negative

Third-Party
Comments

NB Power Corporation - New Brunswick Power
Transmission Corporation

Fon Hiew

Abstain

N/A

Nebraska Public Power District

Ronald Bender

Negative

Third-Party
Comments

New York Power Authority

Zahid Qayyum

Negative

Comments
Submitted

NextEra Energy

Richard Vendetti

Abstain

N/A

NiSource - Northern Indiana Public Service Co.

Kathryn Tackett

Affirmative

N/A

North Carolina Electric Membership Corporation

Reid Cashion

Negative

Third-Party
Comments

Northern California Power Agency

Jeremy Lawson

Negative

Comments
Submitted

NRG - NRG Energy, Inc.

Patricia Lynch

Negative

Comments
Submitted

OGE Energy - Oklahoma Gas and Electric Co.

Patrick Wells

Negative

Third-Party
Comments

Omaha Public Power District

Kayleigh Wilkerson

Negative

Third-Party
Comments

Ontario Power Generation Inc.

Constantin Chitescu

Affirmative

N/A

OTP - Otter Tail Power Company

Stacy Wahlund

Negative

Third-Party
Comments

Pacific Gas and Electric Company

Frank Lee

Negative

Comments
Submitted

Pattern Operators LP

George E Brown

Negative

Third-Party
Comments

Platte River Power Authority

Jon Osell

None

N/A

Portland General Electric Co.

Ryan Olson

None

N/A

PSEG Nuclear LLC

Tim Kucey

Abstain

N/A

Public Utility District No. 1 of Chelan County

Rebecca Zahler

Affirmative

N/A

Public Utility District No. 1 of Snohomish County

Becky Burden

Affirmative

N/A

Public Utility District No. 2 of Grant County,
Washington

Nikkee Hebdon

None

N/A

Sacramento Municipal Utility District

Ryder Couch

Tim Kelley

Affirmative

N/A

Salt River Project

Thomas Johnson

Israel Perez

Affirmative

N/A

Santee Cooper

Carey Salisbury

None

N/A

Seminole Electric Cooperative, Inc.

Melanie Wong

Abstain

N/A

Jennifer Wright

Affirmative

N/A

5
Sempra - San Diego Gas and Electric
© 2024 - NERC Ver 4.2.1.0 Machine Name: ATLVPEROWEB02

Scott Brame

Michael Johnson

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Southern Company - Southern Company
Generation

Leslie Burke

Affirmative

N/A

Southern Indiana Gas and Electric Co.

Larry Rogers

Affirmative

N/A

Tacoma Public Utilities (Tacoma, WA)

Ozan Ferrin

Abstain

N/A

Talen Generation, LLC

Donald Lock

None

N/A

Tennessee Valley Authority

Darren Boehm

Affirmative

N/A

TransAlta Corporation

Ashley Scheelar

Abstain

N/A

Tri-State G and T Association, Inc.

Sergio Banuelos

Affirmative

N/A

U.S. Bureau of Reclamation

Wendy Kalidass

Abstain

N/A

Vistra Energy

Daniel Roethemeyer

Affirmative

N/A

WEC Energy Group, Inc.

Clarice Zellmer

Negative

Comments
Submitted

Xcel Energy, Inc.

Gerry Huitt

None

N/A

AEP

Mathew Miller

Affirmative

N/A

Ameren - Ameren Services

Robert Quinlivan

None

N/A

APS - Arizona Public Service Co.

Marcus Bortman

Negative

Comments
Submitted

Arkansas Electric Cooperative Corporation

Bruce Walkup

Abstain

N/A

Austin Energy

Imane Mrini

Affirmative

N/A

Black Hills Corporation

Rachel Schuldt

Negative

Comments
Submitted

Bonneville Power Administration

Tanner Brier

Affirmative

N/A

Con Ed - Consolidated Edison Co. of New York

Jason Chandler

Negative

Third-Party
Comments

Constellation

Kimberly Turco

Affirmative

N/A

CPower

Aaron Breidenbaugh

Negative

Third-Party
Comments

Dominion - Dominion Resources, Inc.

Sean Bodkin

Negative

Comments
Submitted

Duke Energy

John Sturgeon

Negative

Comments
Submitted

Entergy

Julie Hall

Affirmative

N/A

Evergy

Tiffany Lake

Negative

Comments
Submitted

FirstEnergy - FirstEnergy Corporation

Stacey Sheehan

Affirmative

N/A

Imperial Irrigation District

Diana Torres

Affirmative

N/A

Invenergy LLC

Colin Chilcoat

Affirmative

N/A

Lakeland Electric

Paul Shipps

Affirmative

N/A

Lincoln Electric System

Eric Ruskamp

Negative

Comments
Submitted

Los Angeles Department of Water and Power

Anton Vu

Abstain

N/A

Kelly Bertholet

Negative

Comments
Submitted

6
Manitoba Hydro
© 2024 - NERC Ver 4.2.1.0 Machine Name: ATLVPEROWEB02

Jennie Wike

David Vickers

Alan Kloster

Denise Sanchez

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Muscatine Power and Water

Nicholas Burns

Negative

Third-Party
Comments

New York Power Authority

Shelly Dineen

Negative

Comments
Submitted

NextEra Energy - Florida Power and Light Co.

Justin Welty

Abstain

N/A

NiSource - Northern Indiana Public Service Co.

Joseph OBrien

Affirmative

N/A

Northern California Power Agency

Dennis Sismaet

Negative

Comments
Submitted

OGE Energy - Oklahoma Gas and Electric Co.

Ashley F Stringer

Negative

Third-Party
Comments

Omaha Public Power District

Shonda McCain

Negative

Third-Party
Comments

Platte River Power Authority

Sabrina Martz

Abstain

N/A

Portland General Electric Co.

Stefanie Burke

None

N/A

Powerex Corporation

Raj Hundal

Abstain

N/A

PPL - Louisville Gas and Electric Co.

Linn Oelker

Affirmative

N/A

PSEG - PSEG Energy Resources and Trade LLC

Laura Wu

Abstain

N/A

Public Utility District No. 1 of Chelan County

Anne Kronshage

Affirmative

N/A

Sacramento Municipal Utility District

Charles Norton

Tim Kelley

Affirmative

N/A

Salt River Project

Timothy Singh

Israel Perez

Affirmative

N/A

Santee Cooper

Marty Watson

None

N/A

Seminole Electric Cooperative, Inc.

Bret Galbraith

None

N/A

Snohomish County PUD No. 1

John Liang

Affirmative

N/A

Southern Company - Southern Company
Generation

Ron Carlsen

Affirmative

N/A

Southern Indiana Gas and Electric Co.

Kati Barr

Affirmative

N/A

Tacoma Public Utilities (Tacoma, WA)

Terry Gifford

None

N/A

Tennessee Valley Authority

Armando Rodriguez

Affirmative

N/A

WEC Energy Group, Inc.

David Boeshaar

Negative

Comments
Submitted

Western Area Power Administration

Jennifer Neville

Negative

Comments
Submitted

Xcel Energy, Inc.

Steve Szablya

None

N/A

Midwest Reliability Organization

Mark Flanary

Affirmative

N/A

Northeast Power Coordinating Council

Gerry Dunbar

Abstain

N/A

ReliabilityFirst

Lindsey Mannion

Affirmative

N/A

SERC Reliability Corporation

Dave Krueger

Affirmative

N/A

Texas Reliability Entity, Inc.

Rachel Coyne

Affirmative

N/A

Western Electricity Coordinating Council

Steven Rueckert

Abstain

N/A

Jennie Wike

Previous
Showing 1 to 280 of 280 entries
© 2024 - NERC Ver 4.2.1.0 Machine Name: ATLVPEROWEB02

Description of Current Draft

This is the second draft of the proposed Glossary Terms posted for a 45-day formal comment period and
additional ballot.
Completed Actions

Date

Standards Committee approved Standards Authorization Request (SAR)

September 24, 2020

SAR posted for comment

December 16, 2020 – January
14, 2021

45-day formal comment period with initial ballot

November 16, 2023 – January 9,
2024

Anticipated Actions

Date

45-day formal comment period with additional ballot

February 22 – April 8, 2024

10-day final ballot

April 2024

NERC Board adoption

May 2024

Draft 2 of IBR Definitions
Project 2020-06 Verifications of Models and Data for Generators | February 2024

Page 1 of 2

New or Modified Term(s) Used in NERC Reliability Standards
Background:

This section includes all new or modified terms used in the proposed standard that will be included in
the Glossary of Terms Used in NERC Reliability Standards upon applicable regulatory approval. The terms
proposed below are intended to be used in MOD-026-2 and other inverter-based resource related
standards.
Term(s):

Inverter-Based Resource (IBR): A plant/facility that is connected to the electric system, consisting of one
or more IBR Unit(s) operated as a single resource at a common point of interconnection. IBRs include,
but are not limited to, solar photovoltaic (PV), Type 3 and Type 4 wind, battery energy storage system
(BESS), and fuel cell.
Inverter-Based Resource Unit (IBR Unit): An individual device that uses a power electronic interface,
such as an inverter or converter, capable of exporting Real Power from a primary energy source or
energy storage system, and that connects at a single point on the collector system; or a grouping of
multiple devices that uses a power electronic interface(s), such as an inverter or converter, capable of
exporting Real Power from a primary energy source or energy storage system, and that connect
together at a single point on the collector system.

Draft 2 of IBR Definitions
Project 2020-06 Verifications of Models and Data for Generators | February 2024

Page 2 of 2

Description of Current Draft

This is the second draft of the proposed Glossary Terms posted for a 45-day formal comment period and
additional ballot.
Completed Actions

Date

Standards Committee approved Standards Authorization Request (SAR)

September 24, 2020

SAR posted for comment

December 16, 2020 – January
14, 2021

45-day formal comment period with initial ballot

November 16, 2023 – January 9,
2024

Anticipated Actions

Date

45-day formal comment period with additional ballot

February 22 – April 8, 2024

10-day final ballot

April 2024

NERC Board adoption

May 2024

Project 2020-06 Verifications of Models and Data for Generators
Second Draft of IBR Definitions | February 2024

Page 1 of 4

New or Modified Term(s) Used in NERC Reliability Standards
Background:

This section includes all new or modified terms used in the proposed standard that will be
included in the Glossary of Terms Used in NERC Reliability Standards upon applicable regulatory
approval. The terms proposed below are intended to be used in MOD-026-2 and other inverter-based
resource related standards.
Term(s):

Inverter-Based Resource (IBR): A source (or sink in the case of a charging battery energy storage system
(BESS)) of electric powerplant/facility that is connected to the electric power system (transmission, subtransmission, or distribution system), and that consists, consisting of one or more IBR Unit(s) operated
as a single resource at a common point of interconnection. IBRs include, but are not limited to, solar
photovoltaic (PV), Type 3 and Type 4 wind, battery energy storage system (BESS), and fuel cell.
IBR UnitInverter-Based Resource Unit (IBR Unit): An individual device, that uses a power electronic
interface, such as an inverter or converter, capable of exporting Real Power from a primary energy
source or energy storage system, and that connects at a single point on the collector system; or a
grouping of multiple devices, that uses a power electronic interface(s), such as an inverter or converter,
capable of exporting Real Power from a primary energy source or energy storage system, and that
connect together at a single point on the collector system.

Project 2020-06 Verifications of Models and Data for Generators
Second Draft of IBR Definitions | February 2024

Page 2 of 4

Background
• The drafting team (DT) utilized the IEEE 2800-2022 definitions as an initial basis for the inverter-

based resource terms for the NERC Glossary of Terms and adjusted as necessary. The DT
acknowledges the efforts of the P2800 Wind and Solar Plant Interconnection Performance
Working Group and IEEE members in developing those definitions.

• The IBR and IBR Unit definitions are intended to describe the technology and which types of

technologies are considered IBR. An IBR is not defined by where it is connected or the size of the
IBR. Therefore, the definitions do not define the applicability for Reliability Standards, voltage
connection level, or facility capability level (MW/MVA). The applicability of IBR will be defined in
the Applicability section of the respective Reliability Standards. Additionally, this is the DT’s
reasoning to include the phrase “connected to the electric power system (transmission, subtransmission, or distribution system)”, while excluding specific voltage connection and MW
values within the IBR definition.

• There is a need to distinguish between the individual “IBR unit or device” and the “IBR

plant/facility” as a whole, so that standards or requirements can be written for each as
necessary. Hence, the two definitions for IBR Unit and IBR.

• The term IBR is synonymous with the term “IBR plant/facility.” An IBR includes the IBR Units, and

the equipment designed primarily for delivering the power to a common point of
interconnection (e.g. step-up transformers, collector system(s), main power transformer(s),
power plant controller(s), reactive resources within the IBR plant, and a voltage source converter
high-voltage direct current (VSC HVDC) system with a dedicated connection to the IBR).

• An inverter is a power electronic device that inverts DC power to AC sinusoidal power. A rectifier is

a power electronic device that rectifies AC sinusoidal power to DC power. A converter is a power
electronic device that performs rectification and/or inversion.

• IBRs have traditionally been considered “generating resources.” An IBR is not a HVDC system

(except for a VSC HVDC with a dedicated connection to an IBR), flexible ac transmission systems
(FACTS) (e.g. static synchronous compensators (STATCOM) and static VAR compensators (SVC)),
or any resources that are not inverter-based, e.g., gas and steam power plants with synchronous
generators. The DT’s intent with the phrase "IBRs include" is to articulate a specific list of IBRs.
Therefore, other technologies not listed would not be considered an IBR.

• A hybrid IBR (e.g. BESS and solar PV) or collocated portions of a facility that are IBR (e.g. a BESS at

synchronous generation facility) are considered an IBR.

• IBRs are capable of exporting Real Power and may also be capable of providing Reactive Power.
• Battery energy storage systems (BESS) are considered an IBR unit or IBR independent of whether

the device is operating in a charging, idle, or discharging mode.

• The Project 2020-06 DT intends to use the Glossary Terms of IBR Unit and IBR for MOD-026-2.

Additional standards development projects and related standards that may use these defined
terms include:
o Project 2020-02 Generator Ride-through (new PRC-029, modified PRC-024)
o Project 2021-01 Modifications to PRC-019 and MOD-025
o Project 2021-04 Modifications to PRC-002 (new PRC-028)

Project 2020-06 Verifications of Models and Data for Generators
Second Draft of IBR Definitions | February 2024

Page 3 of 4

o Project 2022-04 EMT Modeling
o Project 2023-01 EOP-004 IBR Event Reporting
o Project 2023-02 Performance of IBRs (new PRC-030)
• Distributed Energy Resources (DER) related projects that may or may not need to use IBR/IBR Unit

if they end up with their own definition)

o Project 2022-02 Modifications to TPL-001 and MOD-032 (DER)
o Project 2023-05 FAC-001/FAC-002 DER
o Project 2023-08 MOD-031 Demand and Energy (DER)

Project 2020-06 Verifications of Models and Data for Generators
Second Draft of IBR Definitions | February 2024

Page 4 of 4

Implementation Plan

Project 2020-06 Verifications of Models and Data for Generators
Inverter-Based Resource Definitions
Applicable Standard(s)
•

None

Requested Retirement(s)
•

None

Prerequisite Standard(s)

These standard(s) or definitions must be approved before the Applicable Standard becomes effective:
•

None

Applicable Entities
•

None

New/Modified/Retired Terms in the NERC Glossary of Terms
•

Inverter-Based Resource (IBR)

•

IBR Unit

Background

As multiple standards development projects are actively addressing risks related to inverter-based
generation, NERC evaluated the need for a single standards project to move forward with definitions that
would be leveraged by all other projects. Project 2020-06 was identified as the drafting team (DT) that would
coalesce development efforts for these definitions and coordinate proposed definitions with the other NERC
developers. The DT proposes the two definitions of IBR and IBR Unit to be used in Reliability Standard MOD026-2, as well as other IBR- related standards development projects.
General Considerations
Multiple standards in development will use the definition(s), and the proposed implementation timeframe is
intended to reflect that any one of those standards may be the first to use one or more of the definitions.
Additionally, this implementation plan only affects the date that these new definitions will become effective
terms in the NERC Glossary of Terms. A separate implementation plan will be developed for MOD-026-2,
including requirements that use these proposed definitions.

Effective Date

The effective date(s) for the proposed definitions for Glossary of Terms are provided below.
Where approval by an applicable governmental authority is required, the proposed definitions shall become
effective on the first day of the first calendar quarter after the applicable governmental authority’s order
approving the definitions, or as otherwise provided for by the applicable governmental authority.
Where approval by an applicable governmental authority is not required, the proposed definitions shall
become effective on the first day of the first calendar quarter after the date the definitions are adopted by
the NERC Board of Trustees, or as otherwise provided for in that jurisdiction.

Implementation Plan for IBR-related Definitions
Project 2020-06 Verifications of Models and Data for Generators | February 2024

Unofficial Comment Form

Project 2020-06 Verification of Models and Data for Generators
Inverter-based Resource-related Definitions
Do not use this form for submitting comments. Use the Standards Balloting and Commenting System
(SBS) to submit comments on MOD-026-2 – Inverter-Based Resource (IBR) related Glossary Terms by 8
p.m. Eastern, Monday, April 8, 2024.
m. Eastern, Thursday, August 20, 2015

Additional information is available on the project page. If you have questions, contact Senior Standards
Developer, Chris Larson (via email), or at 470-599-3851.
Background

The NERC IBR Performance Task Force (IRPTF) performed a comprehensive review of all NERC Reliability
Standards to identify any potential gaps and/or improvements. The IRPTF discovered several issues as part
of this effort and documented its findings and recommendations in the IRPTF Review of NERC Reliability
Standards White Paper, which was approved in March 2020 by the Operating Committee and the Planning
Committee (now part of the Reliability and Security Technical Committee (RSTC)). Among the findings
noted in the white paper, the IRPTF identified issues with MOD-026-1 and MOD-027-1 that should be
addressed by a project. The RSTC endorsed the standard authorization request (SAR) June 10, 2020.
The Standards Committee accepted two revised SARs at its July 21, 2021 meeting. The scope of the project
includes the potential to add, modify, or retire Glossary Terms for NERC Reliability Standards. The Project
2020-06 drafting team (DT) proposes two new terms as part of this formal comment and initial ballot
period.
Please provide your responses to the questions listed below, along with any detailed comments.
Questions

1. Do you support the definition for Inverter-Base Resource (IBR) as proposed, or with non-substantive
changes? If you do not support the definition as proposed, please explain the changes that, if made,
would result in your support.
Yes
No
Comments:
2. Do you support the definition for IBR Unit as proposed, or with non-substantive changes? If you do
not support the definition as proposed, please explain the changes that, if made, would result in
your support.
Yes
No
Comments:

RELIABILITY | RESILIENCE | SECURITY

3. As discussed in the Technical Rationale, the proposed definitions would define the scope of
equipment, but would not define the scope of IBR units subject to mandatory compliance with
Reliability Standards. Each standard would define the applicable units subject to compliance with
that standard. An example to include both BES and non-BES IBRs is as follows:
Section 4. Applicability:
4.1 Functional Entities: Generator Owner, Generator Operator
4.1 Facilities: (1) BES Inverter-Based Resources; and (2) Non-BES Inverter Based Resources
(IBRs) that 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.
Please provide any suggested revisions you feel would improve the readability of this example.
Comments:
4. Provide any additional comments for the DT to consider, if desired.
Comments:

Unofficial Comment Form | MOD-026-2
Project 2020-06 Verification of Models and Data for Generators | February 2024

1
2
3
4
5
6
7
8
9

Technical Rationale

Project 2020-06 Verifications of Models and Data for Generators
Inverter-based Resource Definitions
1. The drafting team (DT) utilized the IEEE 2800-2022 definitions as an initial basis for the inverterbased resource terms for the NERC Glossary of Terms and adjusted as necessary. The DT
acknowledges the efforts of the P2800 Wind and Solar Plant Interconnection Performance
Working Group and IEEE members in developing those definitions. The DT also used recent FERC
and NERC documents, which included inverter-based resource related terms and descriptions, as
the basis for the IBR definitions.

10
11
12
13
14
15
16
17
18
19
20
21

2. The IBR and IBR Unit definitions are intended to describe technologies that shall be considered
IBR and to distinguish between a unit and resource. An IBR is defined by technology, thus voltage
connection level (kV), facility capability level (MW/MVA), or other factors do not impact the
inclusion as an IBR. An IBR can be connected to any part the transmission system, subtransmission system, or distribution system. For a Reliability Standard(s) that use either the IBR
or IBR Unit terms, the Applicability Section for that Reliability Standard(s) will specify which IBRs
are applicable. Each of these Reliability Standards, including the Applicability Section(s) will be
balloted in accordance with the NERC Rules of Procedure, and the Applicability Section. For
example, an Applicability Section may specify that IBR Facilities (BES), IBRs that are owned by a
Generator Owner meeting the new registry criteria for sub-BES resources, or IBRs that are
operated by a Generator Operator meeting the new registry criteria for sub-BES resources, are
considered applicable.

22
23
24
25
26
27

3. IBRs have commonly been referred to as “generating resources.” An IBR is not a HVDC system
(except for a VSC HVDC with a dedicated connection to an IBR, as this is part of the IBR facility),
stand-alone flexible ac transmission systems (FACTS) (e.g., static synchronous compensators
(STATCOM) and static VAR compensators (SVC)), or any resources that are not inverter-based,
e.g., gas and steam power plants with synchronous generators. A list of IBRs is provided in Table
1 below.

4. IBRs may include any hybrid combination of IBR types (e.g., BESS and solar PV), see Table 1.

29
30

5. IBRs also include co-located portions of a facility that are IBR technologies (e.g., a BESS, which is
co-located at synchronous generation facility), see Table 1.

RELIABILITY | RESILIENCE | SECURITY

31
32

6. Examples of IBRs include:
IBRs
•
•
•
•
•
•
•
•
•

33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53

Solar photovoltaic
Type 3 wind
Type 4 wind
Battery energy storage system
(BESS)
Fuel cell(s)
Hybrid combination of IBRs
Portions of co-located facility that
are IBR
VSC HVDC with dedicated
connection to IBR
This is not an all-inclusive list.

Not an IBR
•
•
•
•
•
•
•

Stand-alone FACTS device (e.g.,
STATCOM or SVC)
Flywheels
Synchronous generator
Synchronous condenser
VSC HVDC
LCC HVDC
This is not an all-inclusive list.

Table 1: Inverter-Based Resource (IBR) examples

7. When drafting Reliability Standards and Requirements for IBR, an IBR unit and IBR plant/facility
must be distinguishable from one another. Examples from current Reliability Standards usage
include the following:
•

MOD-026, MOD-027: An IBR model that has been tested makes up a crucial element of
the IBR plant/facility model. Thus, the new standard includes IBR Unit conditions for that
testing. Many of the IBR Unit level parameters cannot be validated with plant/facility
validation, staged testing.

•

PRC-019: Changes made to IBR Unit control system firmware or settings changes may be
subject to updating protection coordination, as would an IBR plant/facility power plant
controller firmware or settings changes.

•

PRC-028: Disturbance monitoring at IBR Unit levels may be necessary for disturbance
recording.

•

PRC-029: Each Generator Owner or Transmission Owner of an applicable IBR shall ensure
that each facility remains electrically connected and continues to exchange current in
accordance with the no-trip zones and Operation Regions as specified in
Attachment 1 unless needed to clear a fault.

8. An inverter is a power electronic device that inverts DC power to AC sinusoidal power. A rectifier
is a power electronic device that rectifies AC sinusoidal power to DC power. A converter is a
power electronic device that performs rectification and/or inversion.

Technical Ra�onale for IBR-related Deﬁni�ons
Project 2020-06 Veriﬁca�ons of Models and Data for Generators | February 2024

54
55
56
57
58
59

9. Figure 2.1 shows an example diagram of an IBR. The IBR (red box) includes the IBR Units (blue
boxes), collection system (green boxes), power plant controller(s) (not shown), and reactive
resources within the IBR plant. If the IBR is connected to the electric system via a dedicated
voltage source converter high-voltage direct current (VSC HVDC) system, the VSC HVDC system is
part of the IBR.

IBR

collector system

IBR Unit
Transformer

IBR Unit
#5

IBR Unit
#4

IBR Unit
#3

IBR Unit
#2

IBR Unit
#1

Main IBR
Transformer

electric
system

61
62
63
64

POI

IBR Unit
# 10

IBR Unit
#9

IBR Unit
#8

IBR Unit
#7

IBR Unit
#6

IBR Unit
# 15

IBR Unit
# 14

IBR Unit
# 13

IBR Unit
# 12

IBR Unit
# 11

Figure 2.1 Example diagram of an IBR depicting the IBR (red box), collector system (green box), and
IBR Units (blue boxes)

10. Examples of common IBR Unit configurations are shown in Figures 2.2 and Figure 2.3.
IBR Unit
Transformer

IBR Unit
Transformer

AC Bus

...
DC input

66
67

Reactive
Device

DC input

DC Bus
DC input

...
inverter
module

DC input DC input

DC input

Figure 2.2. Example configurations of full converter-based IBR Units

Technical Ra�onale for IBR-related Deﬁni�ons
Project 2020-06 Veriﬁca�ons of Models and Data for Generators | February 2024

IBR Unit
DFIG

IBR Unit
Transformer

69
70

Figure 2.3. Type III wind IBR Unit example

71
72
73
74
75

11. The inclusion of ‘capable of exporting Real Power’ is to clarify that loads connected to the electric
system via power electronics are not IBRs. IBRs are capable of exporting Real Power and may also
be capable of providing Reactive Power. The DT contemplated adding the phrase “may also be
capable of providing Reactive Power” in the definition(s). However, the DT believed this may be
misinterpreted that IBRs include technologies such as FACTS devices or HVDC.

76
77
78

12. Battery energy storage systems (BESS) are considered IBRs whether the device is operating in a
charging, idle, or discharging mode. Within each Reliability Standard, a DT may draft operating
mode-specific Requirements, as needed.

79
80
81

13. The Project 2020-06 DT intends to use the Glossary Terms of IBR Unit and IBR for MOD-026-2.
Additional standards development projects and related standards that may use these defined
terms include:

•

Project 2020-02 Generator Ride-through (new PRC-029, modified PRC-024)

•

Project 2021-01 Modifications to PRC-019 and MOD-025

•

Project 2021-04 Modifications to PRC-002 (new PRC-028)

•

Project 2022-04 EMT Modeling

•

Project 2023-01 EOP-004 IBR Event Reporting

•

Project 2023-02 Performance of IBRs (new PRC-030)

88
89

14. Distributed Energy Resources (DER) related projects that may or may not need to use IBR/IBR
Unit if they end up with their own definition)

•

Project 2022-02 Modifications to TPL-001 and MOD-032 (DER)

•

Project 2023-05 FAC-001/FAC-002 DER

•

Project 2023-08 MOD-031 Demand and Energy (DER)

93
94

Technical Ra�onale for IBR-related Deﬁni�ons
Project 2020-06 Veriﬁca�ons of Models and Data for Generators | February 2024

Standards Announcement

Project 2020-06 Verifications of Models and Data for Generators
Inverter-based Resource Glossary Terms
Formal Comment Period Open through April 8, 2024
Now Available

A formal comment period for Inverter-based Resource Glossary Terms is open through 8 p.m.
Eastern, Monday, April 8, 2024.
The standard drafting team’s considerations of the responses received from the previous comment
period are reflected in this draft of the definitions.
Reminder Regarding Corporate RBB Memberships

Under the NERC Rules of Procedure, each entity and its affiliates is collectively permitted one voting
membership per Registered Ballot Body Segment. Each entity that undergoes a change in corporate
structure (such as a merger or acquisition) that results in the entity or affiliated entities having more than
the one permitted representative in a particular Segment must withdraw the duplicate membership(s)
prior to joining new ballot pools or voting on anything as part of an existing ballot pool. Contact
[email protected] to assist with the removal of any duplicate registrations.
Commenting

Use the Standards Balloting and Commenting System (SBS) to submit comments. An unofficial Word
version of the comment form is posted on the project page.
•

Contact NERC IT support directly at https://support.nerc.net/ (Monday – Friday, 8 a.m. - 5
p.m. Eastern) for problems regarding accessing the SBS due to a forgotten password,
incorrect credential error messages, or system lock-out.

•

Passwords expire every 6 months and must be reset.

•

The SBS is not supported for use on mobile devices.

•

Next Steps

Additional ballots will be conducted March 29 – April 8, 2024.

RELIABILITY | RESILIENCE | SECURITY

For information on the Standards Development Process, refer to the Standard Processes Manual.
For more information or assistance, contact Senior Standards Developer, Chris Larson (via email) or at 404446-9708. Subscribe to this project's observer mailing list by selecting "NERC Email Distribution Lists" from
the "Service" drop-down menu and specify “Project 2020-06 Verifications of Models and Data for
Generators Observer List” in the Description Box.

North American Electric Reliability Corporation
3353 Peachtree Rd, NE
Suite 600, North Tower
Atlanta, GA 30326
404-446-2560 | www.nerc.com

Standards Announcement | Project 2020-06 Verification of Data and Models for Generators
Inverter-Based Resource Glossary Terms | February 2024

Comment Report
Project Name:

2020-06 Verifications of Models and Data for Generators | Draft 2 of IBR Definitions

Comment Period Start Date:

2/22/2024

Comment Period End Date:

4/8/2024

Associated Ballots:

2020-06 Verifications of Models and Data for Generators IBR Unit AB 2 DEF
2020-06 Verifications of Models and Data for Generators IBR-related Definitions | Implementation Plan AB 2 OT
2020-06 Verifications of Models and Data for Generators Inverter-Based Resource (IBR) AB 2 DEF

Questions
1. Do you support the definition for Inverter-based Resource (IBR) as proposed, or with non-substantive changes? If you do not support the
definition as proposed, please explain the changes that, if made, would result in your support.
2. Do you support the definition for IBR Unit as proposed, or with non-substantive changes? If you do not support the definition as proposed,
please explain the changes that, if made, would result in your support.
3. As discussed in the Technical Rationale, the proposed definitions would define the scope of equipment, but would not define the scope of
IBR units subject to mandatory compliance with Reliability Standards. Each standard would define the applicable units subject to compliance
with that standard. An example to include both BES and non-BES IBRs is as follows:
Section 4. Applicability:
4.1 Functional Entities: Generator Owner, Generator Operator
4.1 Facilities: (1) BES Inverter-Based Resources; and (2) Non-BES Inverter Based Resources (IBRs) that 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.
Provide any suggested revisions you feel would improve the readability of this example.

4. Provide any additional comments for the DT to consider, if desired.

Organization
Name

Name

BC Hydro and Adrian
Power
Andreoiu
Authority

MRO

Anna
Martinson

Segment(s)

1,2,3,4,5,6

Region

WECC

MRO

Group Name Group Member
Name
BC Hydro

MRO Group

Group
Group
Member
Member
Organization Segment(s)

Group
Member
Region

Hootan Jarollahi BC Hydro and 3
Power
Authority

WECC

Helen Hamilton BC Hydro and 5
Harding
Power
Authority

WECC

Adrian Andreoiu BC Hydro and 1
Power
Authority

WECC

Shonda McCain Omaha Public 1,3,5,6
Power District
(OPPD)

MRO

Michael
Brytowski

1,3,5,6

MRO

Jamison Cawley Nebraska
Public Power
District

1,3,5

MRO

Jay Sethi

Manitoba
Hydro (MH)

1,3,5,6

MRO

Husam AlHadidi

Manitoba
1,3,5,6
Hydro
(System
Preformance)

MRO

Kimberly
Bentley

Western Area 1,6
Power
Adminstration

MRO

Jaimin Patal

Saskatchewan 1
Power
Coporation
(SPC)

MRO

George Brown

Pattern
Operators LP

MRO

Larry Heckert

Alliant Energy 4
(ALTE)

MRO

Terry Harbour

MidAmerican
Energy
Company
(MEC)

1,3

MRO

Dane Rogers

Oklahoma
Gas and
Electric
(OG&E)

1,3,5,6

MRO

Great River
Energy

Southwest
Power Pool,
Inc. (RTO)

WEC Energy
Group, Inc.

Charles
Yeung

Christine
Kane

MRO,SPP RE,WECC SRC 2023

Seth
Shoemaker

Muscatine
Power &
Water

1,3,5,6

MRO

Michael Ayotte

ITC Holdings

MRO

Andrew Coffelt

Board of
1,3,5,6
Public UtilitiesKansas (BPU)

MRO

Peter Brown

Invenergy

MRO

Angela Wheat

Southwestern 1
Power
Administration

MRO

Bobbi Welch

Midcontinent
ISO, Inc.

MRO

Charles Yeung

SPP

MRO

Ali Miremadi

CAISO

WECC

Helen Lainis

IESO

NPCC

Bobbi Welch

Midcontinent
ISO, Inc.

MRO

Greg Campoli

NYISO

NPCC

Elizabeth Davis PJM

Kennedy Meier Electric
Reliability
Council of
Texas, Inc.

Texas RE

WEC Energy
Group

WEC Energy
Group, Inc.

Clarice Zellmer WEC Energy
Group, Inc.

David Boeshaar WEC Energy
Group, Inc.

WEC Energy Christine Kane
Group
Matthew
Beilfuss

Southern
Colby
Company Galloway
Southern
Company
Services, Inc.

1,3,5,6

MRO,RF,SERC,Texas Southern
RE,WECC
Company

Matt Carden

5,6

Southern
1
Company Southern
Company
Services, Inc.

SERC

Joel Dembowski Southern
Company Alabama
Power
Company

SERC

Ron Carlsen

SERC

Southern

Company Southern
Company
Generation
Leslie Burke

ACES Power Jodirah
Marketing
Green

FirstEnergy FirstEnergy
Corporation

Michael

Mark Garza

Michael

1,3,4,5,6

MRO,RF,SERC,Texas ACES
Bob Soloman
RE,WECC
Collaborators

FE Voter

WECC

PG&E All

Southern
Company Southern
Company
Generation

SERC

Hoosier
Energy
Electric
Cooperative

Kris Carper

Arizona
2
Electric Power
Cooperative,
Inc.

WECC

Bill Pezalla

Old Dominion 3,4
Electric
Cooperative

SERC

Jason Procuniar Buckeye
Power, Inc.

Jolly Hayden

East Texas
Electric
Cooperative,
Inc.

NA - Not
Applicable

Texas RE

Nick Fogleman

Prairie Power, 1,3
Inc.

SERC

Kylee Kropp

Sunflower
1
Electric Power
Corporation

MRO

Julie Severino

FirstEnergy FirstEnergy
Corporation

Aaron
Ghodooshim

FirstEnergy FirstEnergy
Corporation

Robert Loy

FirstEnergy FirstEnergy
Solutions

Mark Garza

FirstEnergyFirstEnergy

1,3,4,5,6

Stacey
Sheehan

FirstEnergy FirstEnergy
Corporation

Marco Rios

Pacific Gas

WECC

Johnson

Black Hills
Corporation

Northeast
Power
Coordinating
Council

Johnson

Rachel
Schuldt

Ruida Shu

Segments

1,2,3,4,5,6,7,8,9,10 NPCC

and Electric
Company
Sandra Ellis

Pacific Gas
and Electric
Company

WECC

Tyler Brun

Pacific Gas
and Electric
Company

WECC

Black Hills
Corporation

WECC

Black Hills
Corporation

WECC

Rachel Schuldt Black Hills
Corporation

WECC

Carly Miller

Black Hills
Corporation

WECC

Sheila
Suurmeier

Black Hills
Corporation

WECC

Gerry Dunbar

Northeast
Power
Coordinating
Council

NPCC

Alain Mukama

Hydro One
1
Networks, Inc.

NPCC

Deidre Altobell

Con Edison

NPCC

Jeffrey Streifling NB Power
Corporation

NPCC

Michele
Tondalo

United
Illuminating
Co.

NPCC

Stephanie
Ullah-Mazzuca

Orange and
Rockland

NPCC

Michael
Ridolfino

Central
1
Hudson Gas &
Electric Corp.

NPCC

Randy Buswell

Vermont
1
Electric Power
Company

NPCC

James Grant

NYISO

NPCC

John Pearson

ISO New
England, Inc.

NPCC

Harishkumar
Independent
Subramani Vijay Electricity
Kumar
System

NPCC

Black Hills
Micah Runner
Corporation All Segments Josh Combs

NPCC RSC

Operator
Randy
MacDonald

New
Brunswick
Power
Corporation

NPCC

Dermot Smyth

Con Ed 1
Consolidated
Edison Co. of
New York

NPCC

David Burke

Orange and
Rockland

NPCC

Peter Yost

Con Ed 3
Consolidated
Edison Co. of
New York

NPCC

Salvatore
Spagnolo

New York
Power
Authority

NPCC

Sean Bodkin

Dominion Dominion
Resources,
Inc.

NPCC

David Kwan

Ontario Power 4
Generation

NPCC

Silvia Mitchell

NextEra
1
Energy Florida Power
and Light Co.

NPCC

Glen Smith

Entergy
Services

NPCC

Sean Cavote

PSEG

NPCC

Tracy MacNicoll Utility Services 5

NPCC

Shivaz Chopra

New York
Power
Authority

NPCC

Vijay Puran

New York
6
State
Department of
Public Service

NPCC

ALAN
ADAMSON

New York
State
Reliability
Council

NPCC

Jason Chandler Con Edison

David Kiguel

Elevate
Energy
Consulting

Dominion Dominion
Resources,
Inc.

Ryan Quint

NA - Not
Applicable

NA - Not Applicable

Sean Bodkin 6

Western
Electricity
Coordinating
Council

Steven
Rueckert

Tim Kelley

Elevate
Energy
Consulting

WECC

NPCC

Joel Charlebois AESI

NPCC

Joshua London Eversource
Energy

NPCC

Ryan Quint

Elevate
Energy
Consulting

NA - Not
Applicable

N/A

NA - Not
Applicable

Connie Lowe

Dominion Dominion
Resources,
Inc.

NA - Not
Applicable

Lou Oberski

Dominion Dominion
Resources,
Inc.

NA - Not
Applicable

Larry Nash

Dominion 1
Dominion
Virginia Power

NA - Not
Applicable

Rachel Snead

Dominion Dominion
Resources,
Inc.

NA - Not
Applicable

WECC Entity Steve Rueckert WECC
Monitoring
Phil O'Donnell WECC

WECC

SMUD and
BANC

Sacramento
Municipal
Utility District

WECC

Charles Norton Sacramento
Municipal
Utility District

WECC

Wei Shao

Sacramento
Municipal
Utility District

WECC

Foung Mua

Sacramento
Municipal
Utility District

WECC

Nicole Goi

Sacramento
Municipal
Utility District

WECC

Kevin Smith

Balancing
Authority of
Northern

WECC

Dominion

Independent

Nicole Looney

California

1. Do you support the definition for Inverter-based Resource (IBR) as proposed, or with non-substantive changes? If you do not support the
definition as proposed, please explain the changes that, if made, would result in your support.
Duane Franke - Manitoba Hydro - 1,3,5,6 - MRO
Answer

Document Name
Comment
- The off-shore IBR connected via VSC-HVDC should be included in the IBR definition list of examples.
- We have concerns about the term ‘not limited to’ in the definition, which may create some confusion about what could be considered as IBR, such as a
STATCOM with limited active power capability to support the system inertia or system reliability, that should not belong to the IBR, even it meets the
IBR definition. We proposed adding the exclusion terms in the definition, which may state that an inverter-based plant with limited active power
capability is not part of the IBR definition.
- Any FACT device connected to the IBR plant to support the IBR operation should be included in the IBR auxiliary equipment and be part of the IBR
definition.
Likes

Dislikes

Response
Sean Bodkin - Dominion - Dominion Resources, Inc. - 6, Group Name Dominion
Answer

Document Name
Comment
Dominion Energy does not agree with the proposed efintion and offers the folloowing alternative:
Inverter Based Resources (IBR): IBRs include all NERC registered generating facilities directly connected to the Bulk Power System at 60kV and
above using power electronic devices that change direct current (DC) power produced by a resource to alternating current (AC).
Likes

Dislikes

Response
Kristina Marriott - Miller Bros. Solar, LLC - 5 - MRO,WECC,Texas RE
Answer

Document Name
Comment
MBS supports the direction the SDT has taken. However, we believe that the sentence providing examples should be deleted.
This sentence is not necessary, and may cause ambiguity on what other technologies may or may not qualify. MBS would support the definition if the
examples were left out.
Likes

Dislikes

Response
Rachel Schuldt - Black Hills Corporation - 6, Group Name Black Hills Corporation - All Segments
Answer

Document Name
Comment
Black Hills Corporation believes that only the Inverter-Based Resource (IBR) definition is needed. Consider revision of the definition as follows:
“Generating unit that consists of an individual device or a grouping of multiple devices that:
•
•
•

use a power electronic interface, such as an inverter or converter,
can export Real Power from a primary energy source or energy storage system,
and are connected through a system designed primarily for delivering Real Power to a common point of interconnection to Transmission.”

Likes

Dislikes

Response
Jennifer Bray - Arizona Electric Power Cooperative, Inc. - 1
Answer

Document Name
Comment
AEPC has signed on to ACES comments:
We at ACES applaud the SDT for the work that has been put into developing these definitions. We are greatly encouraged by the SDT’s willingness to
heed industry feedback and implement changes to the IBR definition. It is the opinion of ACES that the currently proposed IBR
definition, while overall very good, would benefit from a few minor changes.
It is our opinion that the addition of the phrase “plant/facility” within the definition potentially introduces more confusion than it eliminates. As this term is
not explicitly defined, it allows for a considerable amount of interpretation by the industry. It is our opinion that the term facility

should instead be included within the defined term itself (i.e., Inverter-Based Resource Facility) in order to be more consistent with other uses of this
phrase within the NERC Glossary of Terms.
Lastly, we believe that the last sentence of the definition wherein a list of example technologies is provided should be struck. It is our perspective that
this list is superfluous and unnecessary. While we appreciate the intent of the SDT in providing said list, we believe this level of granularity is best
provided via the Reliability Standards themselves as stated in Section 2 of the Technical Rationale (e.g., “…the Applicability Section for that Reliability
Standard(s) will specify which IBRs are applicable.”). If it is the intention of the SDT to specifically exclude certain resource types, then we suggest
either providing an explicit list of excluded resource types or modifying the definition in
such a manner so as to not include these resource types in the first place. Thus, it is our recommendation that the IBR definition be renamed to IBR
Facility and modified as follows:
•

Inverter-Based Resource (IBR) Facility: One or more IBR Unit(s), and any associated Element(s) required for the operation thereof,
connected to the electric system and operated as a single resource at a common point of interconnection.

Likes

Dislikes

Document Name
Comment
SRP does not support the addition or modification of this term to the standard. This new term defines IBR’s being introduced directly into a standard
which previously did not have IBR applicability. SRP strongly feels Inverter Based Resources should have separate standards.
Likes

Dislikes

Response
Srikanth Chennupati - Entergy - Entergy Services, Inc. - 1,3,5,6 - SERC
Answer

Document Name
Comment
•
•

Entergy believes that this Inverter-Based Resource (IBR) definition and IBR Unit definition should be combined into to a single definition.
Proposed definition is “A facility that is connected to the electric system, consisting of one or more devices using a power electronic interface
(such as an inverter or converter) and capable of exporting Real Power and acting as a single resource at a common point of interconnection.

IBRs include but are not limited to, solar photovoltaic (PV), Type 3 and Type 4 wind, battery energy storage system (BESS), and fuel cell.”
Likes

Dislikes

Response
Anna Martinson - MRO - 1,2,3,4,5,6 - MRO, Group Name MRO Group
Answer

Document Name
Comment
Defining Inverter-Based Resource (IBR) at an aggregate level and at individual level, having two definitions, is unnecessary and inconsistent with
existing defined terms. An IBR is a piece of electrical equipment and therefore the definition should stay consistent with defining it as a piece of
electrical equipment. Resource is not a defined term and can be used to define either an individual unit or aggregate set of units, please see Blackstart
Resource definition. Further, defined terms already exist, such as Facility, that can be utilized to clearly articulate that IBR term is intended to be used
at an aggregate level in certain contexts. Additionally, undefined terms such as facility or plant can be used, as currently done in existing standards,
when a defined term is not adequate. For example, IBR generating Facility or facility would refer to the aggregate level, whereas IBR individual
generating unit would refer to a single wind turbine generator or photovoltaic inverter.

The MRO NSRF proposes the following:
Inverter-Based Resource (IBR):
A generating unit(s) that consists of an individual device(s) that uses a power electronic interface, such as an inverter or converter, capable of exporting
Real Power from a primary energy source or energy storage system, and that are connected through a system designed primarily for delivering Real
Power to a common point of interconnection to Transmission.

Likes

Dislikes

Lincoln Electric System, 5, Millard Brittany
0

Response
Andy Thomas - Duke Energy - 1,3,5,6 - SERC,RF
Answer

will also reduce confusion within other standards. Additionally, the modeling standard should recognize that modeling may need to be split by inverter
model and/or resource type but recombined as a unit based on how the devices are controlled (e.g., PV and BESS inverters need different models, but
may be operated together to regulate voltage). The fact that the devices must be modeled differently does not mean that each type of inverter must be
defined as a unit.

Definition #1
Inverter-Based Resource Plant/Facility (IBR Plant/Facility): A plant/facility connected to the electric system that consist of one or more IBR Unit(s) at
a common point of interconnection. IBRs types include, but are not limited to, solar photovoltaic (PV), Type 3 and Type 4 wind, battery energy storage
system (BESS), and fuel cell.
Justification: With regard to the removal of “Operated as a single resource”, this phrase implied that each unit must be combined to operate as a
single resource. Generally, multiple units at a plant are controlled individually.

Definition #2
Inverter-Based Resource Unit (IBR Unit): A single or group of devices that are operated and controlled together as a single resource (entity). The unit
utilizes a power electronic interface, such as inverters or converters, capable of exporting Power from a primary energy source or energy storage
system.
Justification: The phrase “Single point on the collector system” was removed because that the implied condition could result in multiple interpretations.
The SDT was possibly assuming that the IEEE Point of Connection term is equivalent to the phrase “single point on the collector system” but are not
equivalent in several cases.
Definition: Unit - An electricity generator and related equipment essential to the electricity generator’s operation, which together function as a single
entity. (Source: Generating Unit Definition: 414 Samples | Law Insider)

Definition #3
Inverter-Based Resource Device (IBR Device): An individual device, such as an inverter or converter, capable of exporting Power from a primary
energy source or energy storage system.
Justification: This additional term was added because the NERC use of the term Unit does not align well with IEEE IBR Unit. The IEEE definition of an
IBR unit is directed towards a component, or device. It can be a single inverter, a central inverter unit, or a group of inverters tested by a NRTL to
function together. The NERC definition of a Unit appears more focused on a collection of individual devices designed and constructed to function
together, but not designed as a single package.
Likes

Dislikes

Response
Christine Kane - WEC Energy Group, Inc. - 3, Group Name WEC Energy Group
Answer
Document Name

Comment
WEC Energy Group supports the comments of the MRO NSRF.
Likes

Dislikes

Response
Dennis Chastain - Tennessee Valley Authority - 1,3,5,6 - SERC
Answer

Document Name
Comment
The Draft 2 "IBR" definition states that it’s a plant/facility consisting of one or more IBR Unit(s). The definition of “consisting” is “composed or made up
of”. As such, the definition is basically stating that an IBR is made up of IBR Unit(s). This is not correct as the updated definition of an IBR Unit is that
it’s a “device” and not a “plant/facility”. As such, suggest changing the words “consisting of” to “using” such that the definition would then read:
“A plant/facility that is connected to the electric system using one or more IBR Unit(s) operated as a single resource at a common point of
interconnection. IBRs include, but are not limited to, solar photovoltaic (PV), Type 3 and Type 4 wind, battery energy storage system (BESS), and fuel
cell.”
Likes

Dislikes

Response
Donna Wood - Tri-State G and T Association, Inc. - 1
Answer

Document Name
Comment
Tri-State Generation and Transmission supports the comments of the MRO NSRF.
Likes

Dislikes

Response
Carver Powers - Utility Services, Inc. - 4
Answer

Document Name
Comment
The proposed definition first states that an IBR is a plant/facility but the last sentence state that an “IBR includes” and then lists a type of technology
(solar photovoltaic) and elements that include inverters to convert power from DC to AC (Type 3 and Type 4) and elements that require separate
devices (battery energy storage system, fuel cell). With the proposed definition, it is unclear whether an IBR is an Element or a plant/facility.
Suggest moving the concepts detailed in the second sentence to the IBR Unit definition for clarity of the undefined term “power source” used in that
definition.
Both “plant” and “facility” are not defined. The term facility is often confused with the NERC defined term “Facility”. CIP-002 R1 uses the undefined term
“asset” and then lists the applicable assets. Suggest replacing the term “facility” with “asset”.
The term “electric system” is undefined. It seems that the intent is to allow the IBR definition to apply to more than the BES or BPS but any two
electrical devices connected together could be an “electric system”. Suggest referencing that the IBR is used to convert power that is exported from the
plant/facility.
Recommend clarifying “Type 3 and Type 4 wind” by including “turbine” after wind in the proposed IBR definition.
“Solar photovoltaic” is a type of technology or method to generate electricity and not a device. A plant may have ancillary devices such as lights and
cameras, that use solar photovoltaic cells to charge their batteries. These ancillary devices should not be IBRs.
The NERC glossary does not define acronyms within definition for a different term. Both PV and BESS acronyms should not be included in the
definition of IBR.
Suggest the following:
“Inverter-Based Resource (IBR): A plant/asset that uses one or more IBR Unit(s) for the conversion of power for export from the plant/asset and
operated as a single resource at a common point of interconnection.”
Likes

Dislikes

Response
Megan Melham - Decatur Energy Center LLC - 5
Answer

Document Name
Comment
Capital Power supports the NAGF comments for the IBR definition as below:
The NAGF believes that only the Inverter-Based Resource (IBR) definition is needed and should be revised as follows:
“A generating unit(s) that consists of one or more individual device(s) that uses a power electronic interface, such as an inverter or converter, capable of
exporting Real Power from a primary energy source or energy storage system, and that are connected through a system designed primarily for
delivering Real Power to a common point of interconnection to Transmission.”

Likes

Dislikes

Response
Dwanique Spiller - Berkshire Hathaway - NV Energy - 5
Answer

NV Energy proposes the following:

Inverter-Based Resource (IBR):
A generating unit(s) that consists of an individual device(s) that uses a power electronic interface, such as an inverter or converter, capable of exporting
Real Power from a primary energy source or energy storage system, and that are connected through a system designed primarily for delivering Real
Power to a common point of interconnection to Transmission.
Likes

Dislikes

Response
Wayne Sipperly - North American Generator Forum - 5 - MRO,WECC,Texas RE,NPCC,SERC,RF
Answer

exporting Real Power from a primary energy source or energy storage system, and that are connected through a system designed primarily for
delivering Real Power to a common point of interconnection to Transmission.”
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Comment
We believe the SDT needs to explain or clarify what "the electric system" is and how an IBR relates to the Bulk Electric System.
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Jodirah Green - ACES Power Marketing - 1,3,4,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name ACES Collaborators
Answer

Document Name
Comment
We at ACES applaud the SDT for the work that has been put into developing these definitions. We are greatly encouraged by the SDT’s willingness to
heed industry feedback and implement changes to the IBR definition. It is the opinion of ACES that the currently proposed IBR definition, while overall
very good, would benefit from a few minor changes.
It is our opinion that the addition of the phrase “plant/facility” within the definition potentially introduces more confusion than it eliminates. As this term is
not explicitly defined, it allows for a considerable amount of interpretation by the industry. It is our opinion that the term facility should instead be
included within the defined term itself (i.e., Inverter-Based Resource Facility) in order to be more consistent with other uses of this phrase within the
NERC Glossary of Terms.
Lastly, we believe that the last sentence of the definition wherein a list of example technologies is provided should be struck. It is our perspective that
this list is superfluous and unnecessary. While we appreciate the intent of the SDT in providing said list, we believe this level of granularity is best
provided via the Reliability Standards themselves as stated in Section 2 of the Technical Rationale (e.g., “…the Applicability Section for that Reliability
Standard(s) will specify which IBRs are applicable.”). If it is the intention of the SDT to specifically exclude certain resource types, then we suggest
either providing an explicit list of excluded resource types or modifying the definition in such a manner so as to not include these resource types in the
first place.
Thus, it is our recommendation that the IBR definition be renamed to IBR Facility and modified as follows:

Inverter-Based Resource (IBR) Facility: One or more IBR Unit(s), and any associated Element(s) required for the operation thereof, connected to the
electric system and operated as a single resource at a common point of interconnection.
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Joshua Phillips - Southwest Power Pool, Inc. (RTO) - 2
Answer

Document Name
Comment
SPP requests the drafting team consider that some large loads may also use power electronic interfaces which may also encounter Sub Synchronous
Resonance issues. SPP encourages the drafting team to consider if such loads should be considered in the IBR definitions due to these similarities.
While they do not inject real power into the grid, they do pull real power from the grid and the impacts of these types of loads tripping off can have
impacts to reliability.
Large loads can be considered resources when utilized as demand response, though requirements may need to be considered beyond a resource
definition. To the extent these would not be covered by the definition proposed, we request consideration of including such clarifications in the definition.
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Ryan Quint - Elevate Energy Consulting - NA - Not Applicable - NA - Not Applicable, Group Name Elevate Energy Consulting
Answer

Yes

Document Name
Comment
We support the definition; however, the term "plant/facility" is a bit vague and unclear which could add confusion for entitites trying to be in compliance
when using this term.
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Teresa Krabe - Lower Colorado River Authority - 5
Answer

Yes

Document Name
Comment
LCRA supports the proposed IBR definition with the current Glossary of Terms. However, depending on how “point of interconnection” is defined, or if it
is added to the Glossary of Terms, the IBR definition could become invalid since there may be multiple generation facilities behind a common GSU or
Transmission Owner equipment which are operated independently and not “as a single resource.”
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Matt Lewis - Lower Colorado River Authority - 1,5
Answer

Yes

Document Name
Comment
LCRA TSC supports the proposed IBR definition with the current Glossary of Terms. However, depending on how “point of interconnection” is defined,
or if it is added to the Glossary of Terms, the IBR definition could become invalid since there may be multiple generation facilities behind a common
GSU or Transmission Owner equipment which are operated independently and not “as a single resource.”
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Adrian Andreoiu - BC Hydro and Power Authority - 1, Group Name BC Hydro
Answer

Yes

Document Name
Comment
BC Hydro appreciates the drafting team’s efforts and the opportunity to comment.
Given the comprehensive treatment in the Technical Rationale, the second sentence in the proposed IBR definition is not required. BC Hydro suggests
that the IBR definition can be simplified as follows:
IBR – a plant including an individual IBR Unit or multiple IBR Units operated as a single resource connected to the electric system at a common point of
connection.
As well, BC Hydro sees a potential conflict between IBR as defined here and the recent updates to the NERC Rules of Procedure to the Generator
Owner and Operator definitions.
In the current draft of the NERC Rules of Procedure – Appendix 2 Definitions used in the Rules of Procedure and Appendix 5B Statement of

Compliance Registry Criteria (Revision 8), the Category 2 Generator Owner entity is defined as “owns and maintains non-BES inverter based
generating resources (emphasis added) 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 GO)”.
BC Hydro appreciates the discussion at item #3 in the Technical Rationale. However, depending on the interpretation of “generating resources”, owners
of certain IBR types such as battery energy storage systems (BESS) may not be registered as a GO for these facilities. This would create a potential
discrepancy between definitions which may create a gap in the intended scope of applicability for MOD-026-2 and potentially other reliability standards,
i.e., entities that would be included under the applicability section of the standard wouldn’t be part of the MRS Program as they may not be registered if
they don’t meet the GO definition.
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Yes

Document Name
Comment
PG&E supports the IBR definition.
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Response
Daniela Atanasovski - APS - Arizona Public Service Co. - 1
Answer

Yes

Document Name
Comment
None
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Gail Elliott - Gail Elliott On Behalf of: Michael Moltane, International Transmission Company Holdings Corporation, 1; - Gail Elliott

Answer

Yes

Document Name
Comment
A White Paper authored by either the drafting team or NERC staff identifying those devices considered within the scope of the definition and those
outside of the Inverter-Based Resource (IBR) definition would be helpful going forward, if maintained by NERC staff.
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Mark Garza - FirstEnergy - FirstEnergy Corporation - 4, Group Name FE Voter
Answer

Yes

Document Name
Comment
None.
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Steven Rueckert - Western Electricity Coordinating Council - 10, Group Name WECC Entity Monitoring
Answer

Yes

Document Name
Comment
WECC supports the definition and voted affirmative. However, we do have some questions that the SDT can hopefully address. How broad does the
SDT consider the “common point of interconnection”? Is it one lead line to one station? Multiple lead lines to multiple transformers within a station?
The industry responds to regulatory oversight (e.g., such as building plants at 74 MVA) and could respond to this definition in a similar manner by
building a second point of interconnection. The risk would still be there but may remain unregulated. Provided technical rational supports avoiding
confusion when applying Requirement language but may need to be enhanced to meet the reliability concerns of two (or more) points of
interconnection. WECC agrees with bullet 7 in the Technical Rationale and each SDT using the defined terms needs to ensure clarity. Does the
definition fully support all variants of hybrid plants? Care needs to be taken as more hybrid plants are being integrated. If the term “IBR” is used for a
MOD Standard and represents a hybrid plant, how does a single model of the “IBR” represent the response? Granted, each part of the hybrid plant
would be separate IBR Units which may dictate how Standards utilize the terms.
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0

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Mark Gray - Edison Electric Institute - NA - Not Applicable - NA - Not Applicable
Answer

Yes

Document Name
Comment
EEI has no objections to the IBR definition as proposed.
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Amy Wilke - American Transmission Company, LLC - 1
Answer

Yes

Document Name
Comment
The language itself may be acceptable, but changes should be made to the technical rationale to explain where an IBR ends. If POI or where the
facility is "connected to the electric power system" is the preferred term, this must be reconciled with other standards where IBR is intended to be used.
Other standards are contemplating using the POM or high side of the main power transformer as the location where IBR performance is measured.
NERC Proposed Definition - Inverter-Based Resource (IBR): A plant/facility that is connected to the electric system consisting of one or more IBR
Unit(s) operated as a single resource at a common point of interconnection. IBRs include, but are not limited to, solar photovoltaic (PV), Type 3 and
Type 4 wind, battery energy storage system (BESS), and fuel cell.
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Thomas Foltz - AEP - 5
Answer

Yes

Document Name
Comment
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0
0

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Pirouz Honarmand - Pirouz Honarmand On Behalf of: Helen Lainis, Independent Electricity System Operator, 2; - Pirouz Honarmand
Answer

Yes

Document Name
Comment
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Mohamad Elhusseini - DTE Energy - Detroit Edison Company - 3,5
Answer

Yes

Document Name
Comment
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Response
Casey Perry - PNM Resources - 1,3 - WECC,Texas RE
Answer

Yes

Document Name
Comment
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Response
Cain Braveheart - Bonneville Power Administration - 1,3,5,6 - WECC
Answer
Document Name

Yes

Comment
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Response
Dave Krueger - SERC Reliability Corporation - 10
Answer

Yes

Document Name
Comment
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Response
David Jendras Sr - Ameren - Ameren Services - 3
Answer

Yes

Document Name
Comment
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Response
Chantal Mazza - Chantal Mazza On Behalf of: Nicolas Turcotte, Hydro-Quebec (HQ), 1, 5; - Chantal Mazza
Answer

Yes

Document Name
Comment
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Response

Junji Yamaguchi - Hydro-Quebec (HQ) - 5
Answer

Yes

Document Name
Comment
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Response
Colby Galloway - Southern Company - Southern Company Services, Inc. - 1,3,5,6 - SERC, Group Name Southern Company
Answer

Yes

Document Name
Comment
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Response
Ruida Shu - Northeast Power Coordinating Council - 1,2,3,4,5,6,7,8,9,10 - NPCC, Group Name NPCC RSC
Answer

Yes

Document Name
Comment
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Response
Diana Aguas - CenterPoint Energy Houston Electric, LLC - 1 - Texas RE
Answer
Document Name
Comment

Yes

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Response
Leslie Hamby - Southern Indiana Gas and Electric Co. - 3,5,6 - RF
Answer

Yes

Document Name
Comment
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Response
Kinte Whitehead - Exelon - 1,3
Answer

Yes

Document Name
Comment
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Response
Mike Magruder - Avista - Avista Corporation - 1
Answer

Yes

Document Name
Comment
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Response

Charles Yeung - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC, Group Name SRC 2023
Answer

Yes

Document Name
Comment
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Response
Kennedy Meier - Electric Reliability Council of Texas, Inc. - 2
Answer

Yes

Document Name
Comment
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Yes

Document Name
Comment
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Marty Hostler - Northern California Power Agency - 4
Answer
Document Name

Comment
1. NO. We believe the SDT needs to explain or clarify what "the electric system" is and how an IBR relates to the Bulk Electric System.
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2. Do you support the definition for IBR Unit as proposed, or with non-substantive changes? If you do not support the definition as proposed,
please explain the changes that, if made, would result in your support.
Tim Kelley - Tim Kelley On Behalf of: Charles Norton, Sacramento Municipal Utility District, 3, 6, 4, 1, 5; Foung Mua, Sacramento Municipal
Utility District, 3, 6, 4, 1, 5; Kevin Smith, Balancing Authority of Northern California, 1; Nicole Looney, Sacramento Municipal Utility District, 3,
6, 4, 1, 5; Ryder Couch, Sacramento Municipal Utility District, 3, 6, 4, 1, 5; Wei Shao, Sacramento Municipal Utility District, 3, 6, 4, 1, 5; - Tim
Kelley, Group Name SMUD and BANC
Answer

Document Name
Comment
SMUD supports the creation of a definition for “IBR Unit” since it is highly likely that drafting teams for other NERC Standards Projects related to
inverter-based resources will need the flexibility to draft requirements that apply specifically to the power electronic interface equipment, and not to the
entire inverter-based resource facility.
The proposed definition for IBR Unit is excessively complicated. We recommend the drafting team consider the following changes to the proposed
definition:
“An individual device, or grouping of multiple devices, that uses a power electronic interface, such as an inverter or converter, capable of exporting
Real Power and of providing Reactive Power support from a primary energy source or energy storage system, and that connects at a single point on
a collector system.”
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Amy Wilke - American Transmission Company, LLC - 1
Answer

Document Name
Comment
Additional clarity should be provided to this definition. There is some confusion right now without more context of the technical rationale document
included in the standard itself. As stated right now, an IBR unit can be an individual device or multiple devices and while the Technical Rationale
examples and pictures make it fairly clear, more clarity in the definition language would be helpful. Perhaps stating that an IBR unit is one that connects
together behind the same generator step up transformer (IBR Unit transformer). Edits are also provided below.
NERC Proposed Definition - Inverter-Based Resource unit (IBR Unit): An individual device that uses a power electronic Interface, such as an inverter or
converter, capable of exporting Real Power from a primary energy source or energy storage system, and that connects at a single point on the collector
system: or a grouping of multiple devices that uses a power electronic interface(s), such as an inverter or converter, capable of exporting Real Power
from a primary energy source or energy storage system, and that connect together at a single point on the collector system.
ATC Proposed edit - Inverter-Based Resource Unit (IBR Unit): An individual device or grouping of multiple devices that uses a power electronic
interface, such as an inverter or converter, capable of exporting Real Power from a primary energy source or energy storage system, and that connects

behind the same IBR Unit step up transformer.
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Joshua Phillips - Southwest Power Pool, Inc. (RTO) - 2
Answer

Document Name
Comment
SPP has a concern that the proposed definition potentially places a limit only holding an account for Real Power instead of Reactive Power.
We recommend that the drafting team replace the term “Real Power” with power, that aligns with the BES definition for generation (inclusion).
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Jodirah Green - ACES Power Marketing - 1,3,4,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name ACES Collaborators
Answer

Document Name
Comment
We believe the currently proposed IBR Unit definition contains language that overlaps the proposed IBR (a.k.a. IBR Facility) definition and should be
modified. It is our opinion that the definition of an IBR Unit should utilize a standalone, technologically agnostic, approach that is consistent with
language already utilized elsewhere in the NERC Glossary of Terms.
Furthermore, it is the opinion of ACES that the reference to “a grouping of multiple devices” is confusing. We believe that the intent of the SDT was to
encompass all possible configurations of IBR Units; however, we do not believe the current language meets said intent succinctly enough. Moreover,
there are no other definitions that attempt to define generating units with such a level of specificity. For instance, there are no definitions within the
NERC Glossary of Terms that attempt to define the many various configurations of a combined cycle unit (e.g., 1x1, 2x1, 3x2, 4x1, etc.). Hence, in this
instance, we believe that less is more.
Therefore, it is our recommendation that the IBR Unit definition be modified as follows:
Inverter-Based Resource (IBR) Unit: An individual generating resource capable of exporting Real Power that uses a power electronic interface, such
as an inverter or rectifier, and connects at a single point to a system designed primarily for delivering such Real Power to a common point of
interconnection.
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Document Name
Comment
If the SDT is going to use the proposed definition the language "single point on the collector system" should be revised to "single point on a collector
system bus that meets the BES definition."
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Wayne Sipperly - North American Generator Forum - 5 - MRO,WECC,Texas RE,NPCC,SERC,RF
Answer

Document Name
Comment
The NAGF recommends that having an IBR unit definition is unnecessary. Please see the response to Question #1. In addition, the NAGF points out
that the SDT has said there is no need to define “collector system” as everyone understands what that term means. The SDT is also attempting to use a
term that industry understands and uses, “unit”, to mean something much different than how the term is currently used in the operations arena of the
industry. This is unacceptable as it will likely lead to significant confusion and misunderstanding in the implementation of the standards.
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Leslie Hamby - Southern Indiana Gas and Electric Co. - 3,5,6 - RF
Answer

Document Name
Comment
Renewable generation must at some point cover Reactive Power if we are moving towards all renewable generation in the future. Due to this, Southern
Indiana Gas & Electric, Company recommends adding “Reactive Power” to the definition.

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Dwanique Spiller - Berkshire Hathaway - NV Energy - 5
Answer

Document Name
Comment
See Question 1.
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Carver Powers - Utility Services, Inc. - 4
Answer

Document Name
Comment
Suggest changing the term name from IBR Unit to Inverter Based Unit (IBU) for clarity in the proposed IBR definition.
The proposed definition is structured in a way that make it difficult to understand. The following is the definition using the NERC style guide… in part.
1) An individual device that uses a power electronic interface, such as an inverter or converter, capable of exporting Real Power from a primary energy
source or energy storage system, and
2) that connects at a single point on the collector system;
or
1) A grouping of multiple devices that uses a power electronic interface(s), such as an inverter or converter, capable of exporting Real Power from a
primary energy source or energy storage system, and
2) that connect together at a single point on the collector system.
Based on this interpretation of the proposed definition, the following definition would mean the same but be simpler to understand. This modified
definition also includes the list of primary energy sources and BESS from the IBR definition
“An individual device or grouping of devices that:
1) use a power electronic interface, such as an inverter or converter, capable of exporting Real Power from a primary energy source or energy storage

system (e.g. solar photovoltaic devices, Type 3 and Type 4 wind turbines, battery energy storage systems, and fuel cells) and
2) connect at a single point on a collector system;”
It could also be structured this way:
“An individual device or grouping of devices that utilize a power electronic interface, such as an inverter or converter, capable of exporting Real Power
from a primary energy source or energy storage system (e.g., solar photovoltaic devices, Type 3 and Type 4 wind turbines, battery energy storage
systems, and fuel cells) and connecting at a single point on a collector system.”
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Donna Wood - Tri-State G and T Association, Inc. - 1
Answer

Document Name
Comment
Tri-State Generation and Transmission supports the comments of the MRO NSRF.
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Dennis Chastain - Tennessee Valley Authority - 1,3,5,6 - SERC
Answer

Document Name
Comment
The Draft 2 "IBR Unit" definition states that it’s a device that uses a power electronic interface. The IBR Unit doesn’t use the interface, it is the
interface. As such, suggest changing the words “that uses” to “consisting of” such that the definition would now read:
“An individual device consisting of a power electronic interface, such as an inverter or converter, capable of exporting Real Power from a primary
energy source or energy storage system, and that connects at a single point on the collector system; or a grouping of multiple devices consisting of
power electronic interface(s), such as inverters or converters, capable of exporting Real Power from a primary energy source or energy storage system,
and that connect together at a single point on the collector system.”
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Christine Kane - WEC Energy Group, Inc. - 3, Group Name WEC Energy Group
Answer

Document Name
Comment
WEC Energy Group supports the comments of the MRO NSRF.
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Andy Thomas - Duke Energy - 1,3,5,6 - SERC,RF
Answer

Document Name
Comment
See Question #1 Response.
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Anna Martinson - MRO - 1,2,3,4,5,6 - MRO, Group Name MRO Group
Answer

Document Name
Comment
See Question 1.

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0

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Srikanth Chennupati - Entergy - Entergy Services, Inc. - 1,3,5,6 - SERC
Answer

Document Name
Comment
Entergy believes that having an IBR Unit definition is unnecessary. Entergy is concerned that the potential level of granularity in the IBR Unit definition
makes compliance overly burdensome due to the need to perform compliance activities on a device-by-device basis. An IBR facility can have hundreds
of individual IBR Units as it is currently defined. Where standard requirements need to be applied at the inverter level, then the individual standards
should state that.
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Jennifer Bray - Arizona Electric Power Cooperative, Inc. - 1
Answer

consistent with language already utilized elsewhere in the NERC Glossary of Terms.
Furthermore, it is the opinion of ACES that the reference to “a grouping of multiple devices” is confusing. We believe that the intent of the SDT was to
encompass all possible configurations of IBR Units; however, we do not believe the current language meets said intent succinctly enough.
Moreover, there are no other definitions that attempt to define generating units with such a level of specificity. For instance, there are no definitions
within the NERC Glossary of Terms that attempt to define the many various configurations of a combined cycle unit (e.g., 1x1, 2x1, 3x2, 4x1, etc.).
Hence, in this instance, we believe that less is more.
Therefore, it is our recommendation that the IBR Unit definition be modified as follows:
•

Inverter-Based Resource (IBR) Unit: An individual generating resource capable of exporting Real Power that uses a power electronic
interface, such as an inverter or rectifier, and connects at a single point to a system designed primarily for delivering such Real Power to a
common point of interconnection.

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Rachel Schuldt - Black Hills Corporation - 6, Group Name Black Hills Corporation - All Segments
Answer

Document Name
Comment
Black Hills Corporation does not believe a definition for “IBR Unit” is necessary if the “IBR” definition from Question 1 is revised as mentioned. The use
of the term “unit” may conflict with other industry uses of the term. If necessary to define to an individual level, then consider use of the term “element”
or “device” in place of “unit.”
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Adrian Andreoiu - BC Hydro and Power Authority - 1, Group Name BC Hydro
Answer

single device will not have multiple connection points to a single system.
It is also not clear why the IBR Unit definition needs to be dependent on “the collector system”, which is not a defined term. As the IBR definition already
specifies the requirement of “a common point of interconnection”, we posit that would be sufficient to define the IBR.
BC Hydro suggests that the collector system concept is not necessary to define the IBR Unit: the examples provided in the Technical Rationale (Figures
2.1, 2.2, and 2.3 on pages 3-4) seem to indicate that it is the single AC bus that determines the interface between an IBR Unit and the electric power
system. However, if the “collector system” is to be deemed a critical component for defining an IBR Unit, BC Hydro suggests that this be defined as a
NERC Glossary Term instead of relying on a common understanding in the power industry.
During the SDT webinar’s Q&A session clarifications were provided to the effect that an Electric Vehicle (EV) can be deemed an IBR Unit if
bidirectional, i.e., injecting power into the grid, not just charging. Arguably, the collector system concept may be different in such scenarios.
BC Hydro suggests that the simplified definitions proposed below do not miss any critical element to fully define the IBR facilities.
IBR Unit – an individual device or a grouping of multiple devices that can export Real Power from a primary energy source or energy storage system via
a power electronics interface.
IBR – a plant including an individual IBR Unit or multiple IBR Units operated as a single resource connected to the electric power system at a common
point of connection.
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Kristina Marriott - Miller Bros. Solar, LLC - 5 - MRO,WECC,Texas RE
Answer

Document Name
Comment
MBS aligns with the previous submission responses made by the NAGF, and feels that the SDT did not address this concern nor provide clarity:
Utilizing the term IBR Unit to refer to a single inverter within the generating plant will cause significant confusion at the plant level. Unless any instruction
provided to the plant is written, then it will not be clear if the term IBR Unit is the defined term used by NERC or if it is intended to mean the generating
unit (Unit 1, 2 or 3), IBR unit. This level of potential confusion is unacceptable resulting in an unacceptable risk of the BES being mis operated. The
word “unit” has long been associated with a distinct operating segment of a plant. For this reason, the NAGF does not support the use of the term unit to
mean anything less than the dispatchable grouping of inverters.

MBS further supports TRE previous response:
...the current verbiage of IBR Unit does not include the capabilities for absorbing or delivering reactive power which is essential for electric system
operations.
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Sean Bodkin - Dominion - Dominion Resources, Inc. - 6, Group Name Dominion
Answer

Document Name
Comment
Dominion Energy is if the opinion that this defintion should be simplifed similiar to the proposed IBR defintion in Q1.
Inverter-Based Resource Unit (IBR Unit): An individual inverter device or a grouping of multiple inverters connected together operating functionally
as a single unit, and directly connected at a single point of interconnection to the Bulk Power System at 60kV and above.
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Ryan Quint - Elevate Energy Consulting - NA - Not Applicable - NA - Not Applicable, Group Name Elevate Energy Consulting
Answer

Document Name
Comment
The definition appears to be overcomplicated and unnecessarily confusing. It is unclear why the definition could not simply state: "An individual device,
or a grouping of multiple devices, that uses a power electronic interface(s), such as an inverter or converter, capable of exporting Real Power from a
primary energy source or energy storage system, and that connects at a single point on the collector system."
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Mark Gray - Edison Electric Institute - NA - Not Applicable - NA - Not Applicable
Answer

Yes

Document Name
Comment
EEI has no objections to the IBR Unit definition as proposed.
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Response
Steven Rueckert - Western Electricity Coordinating Council - 10, Group Name WECC Entity Monitoring
Answer

Yes

Document Name
Comment
WECC has no issue with the definition, but urges that care needs to be taken when using the term in Requirements. WECC appreciated the approach
taken by the SDT to distinguish the two terms.
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Mark Garza - FirstEnergy - FirstEnergy Corporation - 4, Group Name FE Voter
Answer

Yes

Document Name
Comment
No comment.
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Colby Galloway - Southern Company - Southern Company Services, Inc. - 1,3,5,6 - SERC, Group Name Southern Company
Answer

Yes

Document Name
Comment
See the suggestion to change IBR Unit to IBR Device in Q4 below. It is suggested that the SDT carefully consider the use of the word "unit" to refer to
both the power conversion element when unit is capitalized versus using unit to refer to the entire facility when not capitalized.
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0
0

Response
Junji Yamaguchi - Hydro-Quebec (HQ) - 5
Answer

Yes

Document Name
Comment
Another remark would be that while reading the overall definitions, it doesn’t seem clear that E-statcoms are not included in the scope of the term IBR
Unit. Perhaps a distinction between STATCOMs and E-STATCOMS should be added to the Technical Rationale depending on the energy that can be
stored or the storage technology used (supercaps-short duration vs batteries- long duration). Without this distinction, there exists a risk that a storage
system could be identified as a E-STATCOM and thus avoid certain requirements.
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Chantal Mazza - Chantal Mazza On Behalf of: Nicolas Turcotte, Hydro-Quebec (HQ), 1, 5; - Chantal Mazza
Answer

Yes

Document Name
Comment
While reading the overall definitions, it doesn’t seem clear that E-statcoms are not included in the scope of the term IBR Unit. Perhaps a distinction
between STATCOMs and E-STATCOMS should be added to the Technical Rationale depending on the energy that can be stored or the storage
technology used (supercaps-short duration vs batteries- long duration). Without this distinction, there exists a risk that a storage system could be
identified as a E-STATCOM and thus avoid certain requirements.
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Dave Krueger - SERC Reliability Corporation - 10
Answer

Yes

Document Name
Comment
On behalf of the SERC Generator Working Group:

Suggest changing the word "unit" to "asset" to avoid confusion with the historical meaning of unit
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Daniela Atanasovski - APS - Arizona Public Service Co. - 1
Answer

Yes

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Comment
None
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Yes

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PG&E supports the IBR Unit definition.
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Kennedy Meier - Electric Reliability Council of Texas, Inc. - 2
Answer

Yes

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Comment
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Charles Yeung - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC, Group Name SRC 2023
Answer

Yes

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Comment
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Mike Magruder - Avista - Avista Corporation - 1
Answer

Yes

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Comment
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Kinte Whitehead - Exelon - 1,3
Answer

Yes

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Comment
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Diana Aguas - CenterPoint Energy Houston Electric, LLC - 1 - Texas RE
Answer

Yes

Document Name
Comment
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Ruida Shu - Northeast Power Coordinating Council - 1,2,3,4,5,6,7,8,9,10 - NPCC, Group Name NPCC RSC
Answer

Yes

Document Name
Comment
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David Jendras Sr - Ameren - Ameren Services - 3
Answer

Yes

Document Name
Comment
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Cain Braveheart - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

Yes

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Comment
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0
0

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Casey Perry - PNM Resources - 1,3 - WECC,Texas RE
Answer

Yes

Document Name
Comment
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Matt Lewis - Lower Colorado River Authority - 1,5
Answer

Yes

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Comment
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Teresa Krabe - Lower Colorado River Authority - 5
Answer

Yes

Document Name
Comment
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Mohamad Elhusseini - DTE Energy - Detroit Edison Company - 3,5
Answer
Document Name

Yes

Comment
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Pirouz Honarmand - Pirouz Honarmand On Behalf of: Helen Lainis, Independent Electricity System Operator, 2; - Pirouz Honarmand
Answer

Yes

Document Name
Comment
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Duane Franke - Manitoba Hydro - 1,3,5,6 - MRO
Answer

Yes

Document Name
Comment
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Thomas Foltz - AEP - 5
Answer

Yes

Document Name
Comment
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Marty Hostler - Northern California Power Agency - 4
Answer
Document Name
Comment
1. No. If the SDT is going to use the proposed definition the language "single point on the collector system" should be revised to "single point on a
collector system bus that meets the BES definition."
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Megan Melham - Decatur Energy Center LLC - 5
Answer
Document Name
Comment
Capital Power supports the NAGF comments for the IBR Unit definition as below:
The NAGF recommends that having an IBR unit definition is unnecessary. Please see the response to Question #1. In addition, the NAGF points out
that the SDT has said there is no need to define “collector system” as everyone understands what that term means. The SDT is also attempting to use a
term that industry understands and uses, “unit”, to mean something much different than how the term is currently used in the operations arena of the
industry. This is unacceptable as it will likely lead to significant confusion and misunderstanding in the implementation of the standards.
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3. As discussed in the Technical Rationale, the proposed definitions would define the scope of equipment, but would not define the scope of
IBR units subject to mandatory compliance with Reliability Standards. Each standard would define the applicable units subject to compliance
with that standard. An example to include both BES and non-BES IBRs is as follows:
Section 4. Applicability:
4.1 Functional Entities: Generator Owner, Generator Operator
4.1 Facilities: (1) BES Inverter-Based Resources; and (2) Non-BES Inverter Based Resources (IBRs) that 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.
Provide any suggested revisions you feel would improve the readability of this example.

Sean Bodkin - Dominion - Dominion Resources, Inc. - 6, Group Name Dominion
Answer

Document Name
Comment
The BES definition should govern applicability and individual standards should not be conflicting with an approved defintoin.
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Srikanth Chennupati - Entergy - Entergy Services, Inc. - 1,3,5,6 - SERC
Answer

Document Name
Comment
None
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Andy Thomas - Duke Energy - 1,3,5,6 - SERC,RF
Answer

Document Name
Comment
The 60 kV voltage threshold value will limit the application of resources. Please consider reducing the voltage value to 40 kV.
Additionally, the NERC Glossary of Terms “Bulk Electric System” definition I2A for synchronous machines uses the phrase: “a) Gross individual
nameplate rating ‘greater’ than 20 MVA”; suggest changing 20 MVA language to “4.1 Facilities: (1) BES Inverter-Based Resources; and (2) Non-BES
Inverter Based Resources (IBRs) that that either have or contribute to an aggregate nameplate capacity of ‘greater' than 20 MVA,” to consolidate
language and reduce confusion with the implied 20 MVA value.
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Carver Powers - Utility Services, Inc. - 4
Answer

Document Name
Comment
Recommend that the proposed language for Section 4.1 Facilities, part 2 align with the pending GO/GOP NERC Glossary of Terms revisions and the
pending compliance registry definitions.
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Megan Melham - Decatur Energy Center LLC - 5
Answer

Document Name
Comment
Capital Power supports the NAGF comments as below:
The NAGF recommends that the proposed language for Section 4.1 Facilities, part 2 align with the pending GO/GOP NERC Glossary of Terms
revisions.
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Marty Hostler - Northern California Power Agency - 4
Answer

Document Name
Comment
No. Should not say 60 KV. Industry, NERC, and FERC agreed a long time ago on 100 KV.
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Wayne Sipperly - North American Generator Forum - 5 - MRO,WECC,Texas RE,NPCC,SERC,RF
Answer

Document Name
Comment
The NAGF recommends that the proposed language for Section 4.1 Facilities, part 2 align with the pending GO/GOP NERC Glossary of Terms
revisions.
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Lauren Giordano - Lauren Giordano On Behalf of: Dennis Sismaet, Northern California Power Agency, 4, 6, 3, 5; Jeremy Lawson, Northern
California Power Agency, 4, 6, 3, 5; Marty Hostler, Northern California Power Agency, 4, 6, 3, 5; - Lauren Giordano
Answer

Document Name
Comment
Should not say 60 KV. Industry, NERC, and FERC agreed a long time ago on 100 KV.
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Joshua Phillips - Southwest Power Pool, Inc. (RTO) - 2
Answer

Document Name
Comment
SPP has concern that the approach of each standard defining the applicable units may create conflicting issues amongst various standards. This oneoff concept (not being defined in the glossary of terms or Rules of Procedure RoP) could cause confusion and will not have a solid reference outside of
the actual language located in the standard. For example, if a standard is retired that uses this concept, it could create a gap in the IBR process and
may require the reopening of various standards.
Our concerns include the current BES definition properly aligning among this drafting team and drafting team efforts that are focused on the InverterBased Resource (IBR). The current definition does not take into consideration the IBR characteristics and impacts.
With that said, SPP recommends that the drafting team ensure the definitions of what is included and excluded within the BES definitions for proper
alignment with other NERC standards in reference to the new technology and its impact on the reliability of the grid.
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The format proposed by the Standard Drafting Team (SDT) is a good way to define applicability within each Standard, however, we feel that the
language proposed in NERC Standards Project 2021-04 Modifications to PRC-002 - Phase II, PRC-028-1 draft #2, is even better. This language is
formatted as follows:
“4.1. Functional Entities:
4.1.1. Generator Owner that owns equipment as identified in section 4.2 [emphasis added]
4.1.2. Generator Operator that operates equipment as identified in section 4.2 [emphasis added]
4.2. Facilities: The Elements associated with (1) BES Inverter-Based Resources; and (2) Non-BES Inverter-Based 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.”
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Ryan Quint - Elevate Energy Consulting - NA - Not Applicable - NA - Not Applicable, Group Name Elevate Energy Consulting
Answer

Yes

Document Name
Comment
Slight editorial changes such as :
1) There are two "4.1" in Section 4, which is in error we believe.
2) The acronym "(IBR)" should be on the first use of the term, not the second.
3) It states "that that" after the current use of (IBR) presently.
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Yes

PG&E has no suggested revisions that could improve the readability of the Applicability except for making “Facility” 4.2 and not 4.1.
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Donna Wood - Tri-State G and T Association, Inc. - 1
Answer

Yes

Document Name
Comment
Tri-State Generation and Transmission supports the comments of the MRO NSRF.
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David Jendras Sr - Ameren - Ameren Services - 3
Answer

Yes

Document Name
Comment
Ameren would like an example of how they use IBR unit in a compliance definition, for example in PRC-029 for a plant where you have mixed types of
IBR units.
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Dwanique Spiller - Berkshire Hathaway - NV Energy - 5
Answer

Yes

Document Name
Comment
NV Energy agrees that the applicability section and/or actual requirements should define the scope of equipment included/excluded whether it be a

Category 1 GO/GOP or Category 2 GO/GOP, as Defined in the proposed NERC ROP.
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Mark Garza - FirstEnergy - FirstEnergy Corporation - 4, Group Name FE Voter
Answer

Yes

Document Name
Comment
No Comments.
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Pirouz Honarmand - Pirouz Honarmand On Behalf of: Helen Lainis, Independent Electricity System Operator, 2; - Pirouz Honarmand
Answer

Yes

Document Name
Comment
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Mohamad Elhusseini - DTE Energy - Detroit Edison Company - 3,5
Answer

Yes

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Comment
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Kristina Marriott - Miller Bros. Solar, LLC - 5 - MRO,WECC,Texas RE
Answer

Yes

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Comment
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Teresa Krabe - Lower Colorado River Authority - 5
Answer

Yes

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Comment
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Casey Perry - PNM Resources - 1,3 - WECC,Texas RE
Answer

Yes

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Comment
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Dave Krueger - SERC Reliability Corporation - 10
Answer
Document Name
Comment

Yes

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Ruida Shu - Northeast Power Coordinating Council - 1,2,3,4,5,6,7,8,9,10 - NPCC, Group Name NPCC RSC
Answer

Yes

Document Name
Comment
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Adrian Andreoiu - BC Hydro and Power Authority - 1, Group Name BC Hydro
Answer
Document Name
Comment
BC Hydro sees a potential conflict between IBR as defined here and the recent updates to the NERC Rules of Procedure to the Generator Owner and
Operator definitions.
In the current draft of the NERC Rules of Procedure – Appendix 2 Definitions used in the Rules of Procedure and Appendix 5B Statement of
Compliance Registry Criteria (Revision 8), the Category 2 Generator Owner entity is defined as “owns and maintains non-BES inverter based
generating resources (emphasis added) 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 GO)”.
BC Hydro appreciates the discussion at item #3 in the Technical Rationale. However, depending on the interpretation of “generating resources”, owners
of certain IBR types such as battery energy storage systems (BESS) or Electric Vehicles may not be registered as a GO for these facilities. This would
create a potential discrepancy between definitions which may create a gap in the intended scope of applicability for MOD-026-2 and potentially other
reliability standards, i.e., entities that would be included under the applicability section of the standard wouldn’t be part of the MRS Program as they may
not be registered if they don’t meet the GO definition.
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Rachel Schuldt - Black Hills Corporation - 6, Group Name Black Hills Corporation - All Segments
Answer
Document Name
Comment
Black Hills Corporation recommends that the proposed language for “Section 4.1. Facilities” be updated to align with the pending GO & GOP definition
revisions in the NERC Rules of Procedure.
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Daniela Atanasovski - APS - Arizona Public Service Co. - 1
Answer
Document Name
Comment
None
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Jennifer Bray - Arizona Electric Power Cooperative, Inc. - 1
Answer
Document Name
Comment
AEPC has signed on to ACES comments:
We recommend modifying Section 4.1 Functional Entities to specifically reference the new Category 1 GO/GOP and Category 2 GO/GOP definitions.

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Anna Martinson - MRO - 1,2,3,4,5,6 - MRO, Group Name MRO Group
Answer
Document Name
Comment
MRO NSRF agrees that the applicability section and/or actual requirements should define the scope of equipment included/excluded whether it be a
Category 1 GO/GOP or Category 2 GO/GOP, as Defined in the proposed NERC ROP.
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Lincoln Electric System, 5, Millard Brittany
0

Response
Christine Kane - WEC Energy Group, Inc. - 3, Group Name WEC Energy Group
Answer
Document Name
Comment
WEC Energy Group supports the comments of the MRO NSRF.
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Dennis Chastain - Tennessee Valley Authority - 1,3,5,6 - SERC
Answer
Document Name
Comment
The IBR definition states that they have a common point of interconnection. As such, it doesn’t need to be stated again so 4.1 could state:
4.1 Facilities: (1) BES Inverter-Based Resources; and (2) Non-BES Inverter Based Resources (IBRs) 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 at a voltage greater
than or equal to 60 kV.
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0
0

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Colby Galloway - Southern Company - Southern Company Services, Inc. - 1,3,5,6 - SERC, Group Name Southern Company
Answer
Document Name
Comment

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Steven Rueckert - Western Electricity Coordinating Council - 10, Group Name WECC Entity Monitoring
Answer
Document Name
Comment
It appears that there was not a question above that can be answered Yes or NO, so WECC did not respond. However we do have the folloing thoughts.
Note- ALL SDTs needs to be clear in the usage of proposed terms- In the example question, the phrases “IBR unit” and “applicable units” are used. As
esoteric as that is, the question clearly demonstrates that the current and future SDTs using the terms should do so carefully and deliberately. Defined
terms are critical and using additional descriptors (especially the same term) can lead to various interpretations/thoughts by all entities. Is there any
reason why “IBR” is not shown after item 1 phrase? Is there a distinction trying to be made by use or non-use of the hyphen in IBR terms within item 1
and 2? The use of “connection” versus “interconnection”
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Mark Gray - Edison Electric Institute - NA - Not Applicable - NA - Not Applicable
Answer
Document Name
Comment
EEI has no suggested modifications regarding the readability of the example applicability language.
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Charles Yeung - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC, Group Name SRC 2023
Answer
Document Name
Comment
Paragraph 2 in the posted technical rationale is clear enough without this example. At this point, adding an example may just cause more confusion
becuase the approach for expanding the registration to include these (currently non-BES) facilities has not been finalized. The example may make
sense if NERC continues with its current approach of expanding GO/GOP registration criteria, but if NERC were to return to the originally proposed
approach of creating new registration categories the specification of facilities in this example would be redundant.
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Jodirah Green - ACES Power Marketing - 1,3,4,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name ACES Collaborators
Answer
Document Name
Comment
We recommend modifying Section 4.1 Functional Entities to specifically reference the new Category 1 GO/GOP and Category 2 GO/GOP definitions.
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Kennedy Meier - Electric Reliability Council of Texas, Inc. - 2
Answer
Document Name
Comment
ERCOT joins the comments submitted by the ISO/RTO Council (IRC) Standards Review Committee (SRC) for this response and adopts them as its
own.
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Amy Wilke - American Transmission Company, LLC - 1
Answer
Document Name
Comment
No comments.
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4. Provide any additional comments for the DT to consider, if desired.
Amy Wilke - American Transmission Company, LLC - 1
Answer
Document Name
Comment
The standard should operate as a stand-a-lone document. The standard should address the who, what, when, where and sometimes how (not always).
The Tech Rationale is only “why” a requirement is in the standard. References to the Tech Rationale can be misleading in that it is not part of the
standard.
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Kennedy Meier - Electric Reliability Council of Texas, Inc. - 2
Answer
Document Name
Comment
ERCOT joins the comments submitted by the IRC SRC for this response and adopts them as its own.
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Joshua Phillips - Southwest Power Pool, Inc. (RTO) - 2
Answer
Document Name
Comment
If determined that load should be included, SPP recommends the Standard Drafting Team consider concurrently undertaking the necessary process to
have the SAR(s) revised to allow for more broadly applicable Glossary of Terms definitions while continuing to develop this definition.
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0
0

Response
Jodirah Green - ACES Power Marketing - 1,3,4,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name ACES Collaborators
Answer
Document Name
Comment
Thank you for the opportunity to comment.
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Charles Yeung - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC, Group Name SRC 2023
Answer
Document Name
Comment
1.
Line 89 in the Technical Rationale currently states: “Unit if they end up with their own definition).” The SRC recommends that line 89 be changed
to: “Unit definitions:”
2.
The SRC does not believe Inclusion of the statement “IBRs include, but are not limited to, solar photovoltaic (PV), Type 3 and Type 4 wind,
battery energy storage system (BESS), and fuel cell” in the IBR definition is necessary and therefore recommends that it be deleted. If the SDT
determines there is a benefit to keeping this list of examples, the SRC suggests that the list be changed to read: “IBRs include, but are not limited to,
solar photovoltaic (PV) Facilities, Type 3 and Type 4 wind Facilities, battery energy storage system (BESS) Facilities, and fuel cell Facilities.” Listing
only “solar photovoltaic (PV)” is somewhat ambiguous, as it could be understood refer to just the PV panel or to an IBR Unit (which may or may not be
an IBR according to the proposed definition).
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Steven Rueckert - Western Electricity Coordinating Council - 10, Group Name WECC Entity Monitoring
Answer
Document Name
Comment
WECC appreciates the efforts of the SDT to ensure clarity in the definitions and use of the definitions moving forward to help ensure reliable planning

and operation of the BPS.
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Wayne Sipperly - North American Generator Forum - 5 - MRO,WECC,Texas RE,NPCC,SERC,RF
Answer
Document Name
Comment
The NAGF provides the following additional comments for consideration:
a. The NAGF is concerned with the use of the term “unit” in the proposed IBR Unit definition as it seems to conflict with the way industry currently
uses the term. Recommend that Drafting Team consider replacing with the term with “element” or “device” in the event the Drafting Team continues to
support the need for two definitions.
b.

The NAGF recommends that the proposed IBR Unit definition be revised as follows:

“An individual device or a grouping of multiple devices, that uses a power electronic interface, such as an inverter or converter, capable of exporting
Real Power from a primary energy source or energy storage system, and that connects at a single point on the collector system.”
c.
Technical Rationale – the document currently references the terms “IBR”, “IBR Unit”, and “IBR plant/facility”. Recommend that the document
references align with the IBR Glossary of Terms definitions to eliminate possible confusion.
d.

The NAGF notes that there are two SARs that form the basis for this project:

Modifications to MOD-026 and MOD-027

ii.

Applicability revisions for transmission connected dynamic reactive resources

The scope of these SARs does not appear to provide the SDT with the latitude to modify the NERC Glossary of Terms for IBRs. The MOD-026/027
SAR does not have the box checked for “Add, Modify or Retire a Glossary Term”. While the transmission connected dynamic reactive resources SAR
does have such box selected, it limits such changes to “also define new Glossary Terms for TCDRR or related terms”. Therefore, the NAGF requests
that the Drafting Team revisit the SARs accordingly to ensure that the Drafting Team is not overstepping their intended scope.
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Mark Garza - FirstEnergy - FirstEnergy Corporation - 4, Group Name FE Voter
Answer
Document Name

Comment
FirstEnergy requests as the drafting team moves forward with this endeavor that they ensure the applicability is maintained across all standards that
relate to this topic.
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Dwanique Spiller - Berkshire Hathaway - NV Energy - 5
Answer
Document Name
Comment
Upon review of the SARs under which this Standard Drafting Team is operating, NV Energy is of the opinion that the creation of a new glossary of terms
definition such as “Inverter Based Resource” is not currently within scope for the Standard Drafting Team. NV Energy would suggest that the Standard
Drafting Team concurrently undertake the necessary process to have the SAR(s) revised to allow for the creation of broadly applicable Glossary of
Terms definitions, while also continuing to develop this definition to allow for further improvements to the reliability of the Bulk Power System while
adhering to the rules for standard development as prescribed by the Standard Processes Manual.

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Ruida Shu - Northeast Power Coordinating Council - 1,2,3,4,5,6,7,8,9,10 - NPCC, Group Name NPCC RSC
Answer
Document Name
Comment
NPCC RSC supports the IBR and IBR unit definition.
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Colby Galloway - Southern Company - Southern Company Services, Inc. - 1,3,5,6 - SERC, Group Name Southern Company

Answer
Document Name
Comment
First, there are concerns with the use of "Unit" in the IBR Unit definition due to the current and historical use of the term "Unit" with respect to
generating plants. Often, that term has been and is used to represent the entire facility, not specifically the AC power producing component. Consider
changing "IBR Unit" to "IBR Device" to resolve this concern and confusion. Note this possible confusion even exists within the Comment item #3 above
where the difference between Unit and unit is very significant.
Second, the SDT should consider the compatibility of the proposed IBR definition, as depicted in Figure 2.1 of the Technical Rational with the existing
BES definition, I4 inclusion. The definition does not include the collection system (below 75MVA) in the scope of the parts of a facility.
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Marty Hostler - Northern California Power Agency - 4
Answer
Document Name
Comment
None.
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Response
Megan Melham - Decatur Energy Center LLC - 5
Answer
Document Name
Comment
Capital Power supports the NAGF comments as below:
The NAGF provides the following additional comments for consideration:
a. The NAGF is concerned with the use of the term “unit” in the proposed IBR Unit definition as it seems to conflict with the way industry currently uses
the term. Recommend that Drafting Team consider replacing with the term with “element” or “device” in the event the Drafting Team continues to
support the need for two definitions.

b. The NAGF recommends that the proposed IBR Unit definition be revised as follows:
“An individual device or a grouping of multiple devices, that uses a power electronic interface, such as an inverter or converter, capable of exporting
Real Power from a primary energy source or energy storage system, and that connects at a single point on the collector system.”
c. Technical Rationale – the document currently references the terms “IBR”, “IBR Unit”, and “IBR plant/facility”. Recommend that the document
references align with the IBR Glossary of Terms definitions to eliminate possible confusion.
d. The NAGF notes that there are two SARs that form the basis for this project:
i. Modifications to MOD-026 and MOD-027
ii. Applicability revisions for transmission connected dynamic reactive resources
The scope of these SARs does not appear to provide the SDT with the latitude to modify the NERC Glossary of Terms for IBRs. The MOD-026/027
SAR does not have the box checked for “Add, Modify or Retire a Glossary Term”. While the transmission connected dynamic reactive resources SAR
does have such box selected, it limits such changes to “also define new Glossary Terms for TCDRR or related terms”. Therefore, the NAGF requests
that the Drafting Team revisit the SARs accordingly to ensure that the Drafting Team is not overstepping their intended scope.
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Donna Wood - Tri-State G and T Association, Inc. - 1
Answer
Document Name
Comment
NA
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Dennis Chastain - Tennessee Valley Authority - 1,3,5,6 - SERC
Answer
Document Name
Comment
There is a need to ensure the IBR definition is sufficiently clear to determine if pumped storage facilities (particularly new variable speed pumped
storage technologies that act similar to IBRs) might be considered as an applicable generator, so that when applying standards and requirements to
these facilities, it is clear as to which applies. Does every plant need to be classified as a synchronous generator or an IBR? If so, pumped storage
facilities, for example, could be considered to act like bulk energy system synchronous machines due to charging and discharging modes, while at the

same time ride-thru capabilities may not seamlessly apply.
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Christine Kane - WEC Energy Group, Inc. - 3, Group Name WEC Energy Group
Answer
Document Name
Comment
WEC Energy Group supports the comments of the MRO NSRF.
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Response
Andy Thomas - Duke Energy - 1,3,5,6 - SERC,RF
Answer
Document Name
Comment
None.
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Response
Srikanth Chennupati - Entergy - Entergy Services, Inc. - 1,3,5,6 - SERC
Answer
Document Name
Comment
none
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Response
Anna Martinson - MRO - 1,2,3,4,5,6 - MRO, Group Name MRO Group
Answer
Document Name

Project 2020-06 MRO NSRF IBR Definition 20240403 Final.docx

Comment
Upon review of the SARs under which this Standard Drafting Team is operating, MRO NSRF is of the opinion that the creation of a new glossary of
terms definition such as “Inverter Based Resource” is not currently within scope for the Standard Drafting Team. MRO NSRF would suggest that the
Standard Drafting Team concurrently undertake the necessary process to have the SAR(s) revised to allow for the creation of broadly applicable
Glossary of Terms definitions, while also continuing to develop this definition to allow for further improvements to the reliability of the Bulk Power
System while adhering to the rules for standard development as prescribed by the Standard Processes Manual.
See attachment!
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Israel Perez - Israel Perez On Behalf of: Mathew Weber, Salt River Project, 3, 1, 6, 5; Sarah Blankenship, Salt River Project, 3, 1, 6, 5; Thomas
Johnson, Salt River Project, 3, 1, 6, 5; Timothy Singh, Salt River Project, 3, 1, 6, 5; - Israel Perez
Answer
Document Name
Comment
SRP does not support the addition or modification of this term to the standard. This new term defines IBR’s being introduced directly into a standard
which previously did not have IBR applicability. SRP strongly feels Inverter Based Resources should have separate standards.
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Jennifer Bray - Arizona Electric Power Cooperative, Inc. - 1
Answer
Document Name
Comment

Thank you for the opportunity to comment.
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Response
Daniela Atanasovski - APS - Arizona Public Service Co. - 1
Answer
Document Name
Comment
None
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Response
Rachel Schuldt - Black Hills Corporation - 6, Group Name Black Hills Corporation - All Segments
Answer
Document Name
Comment
Black Hills Corporation agrees with comments provided by NAGF, EEI and other industry peer groups.
Likes

Dislikes

Response
Michael Johnson - Michael Johnson On Behalf of: Marco Rios, Pacific Gas and Electric Company, 3, 1, 5; Sandra Ellis, Pacific Gas and
Electric Company, 3, 1, 5; Tyler Brun, Pacific Gas and Electric Company, 3, 1, 5; - Michael Johnson, Group Name PG&E All Segments
Answer
Document Name
Comment
PG&E has no further comments for the DT, but does wish to thank the DT for listening to the industry in making the current modifications in a difficult

and contentious process.
Likes

Dislikes

Response
Teresa Krabe - Lower Colorado River Authority - 5
Answer
Document Name
Comment
None.
Likes

Dislikes

Response
Kristina Marriott - Miller Bros. Solar, LLC - 5 - MRO,WECC,Texas RE
Answer
Document Name
Comment
Great Job, this is not an easy task!
Likes

Dislikes
Response

Consideration of Comments
Project Name:

2020-06 Verifications of Models and Data for Generators | Draft 2 of IBR Definitions

Comment Period Start Date:

2/22/2024

Comment Period End Date:

4/8/2024

Associated Ballot(s):

There were 49 sets of responses, including comments from approximately 144 different people from approximately 102 companies
representing 10 of the Industry Segments as shown in the table on the following pages.
All comments submitted can be reviewed in their original format on the project page.
If you feel that your comment has been overlooked, let us know immediately. Our goal is to give every comment serious consideration in this
process. If you feel there has been an error or omission, contact Manager of Standards Information, Nasheema Santos (via email) or at (404) 4462564.

RELIABILITY | RESILIENCE | SECURITY

Questions
1. Do you support the definition for Inverter-based Resource (IBR) as proposed, or with non-substantive changes? If you do not support the
definition as proposed, please explain the changes that, if made, would result in your support.
2. Do you support the definition for IBR Unit as proposed, or with non-substantive changes? If you do not support the definition as proposed,
please explain the changes that, if made, would result in your support.
3. As discussed in the Technical Rationale, the proposed definitions would define the scope of equipment, but would not define the scope of IBR
units subject to mandatory compliance with Reliability Standards. Each standard would define the applicable units subject to compliance with that
standard. An example to include both BES and non-BES IBRs is as follows:
Section 4. Applicability:
4.1 Functional Entities: Generator Owner, Generator Operator
4.1 Facilities: (1) BES Inverter-Based Resources; and (2) Non-BES Inverter Based Resources (IBRs) that 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.
Provide any suggested revisions you feel would improve the readability of this example.
4. Provide any additional comments for the DT to consider, if desired.

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

The Industry Segments are:

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Organization
Name

Name

BC Hydro and Adrian
Power
Andreoiu
Authority

MRO

Anna
Martinson

Segment(s)

1,2,3,4,5,6

Region

WECC

MRO

Group Name

BC Hydro

Group
Member
Name

Group
Member
Region

Hootan
Jarollahi

BC Hydro and 3
Power
Authority

WECC

Helen
Hamilton
Harding

BC Hydro and 5
Power
Authority

WECC

Adrian
Andreoiu

BC Hydro and 1
Power
Authority

WECC

Omaha Public 1,3,5,6
Power District
(OPPD)

MRO

Michael
Brytowski

Great River
Energy

1,3,5,6

MRO

Jamison
Cawley

Nebraska
Public Power
District

1,3,5

MRO

Jay Sethi

Manitoba
Hydro (MH)

1,3,5,6

MRO

Husam AlHadidi

Manitoba
1,3,5,6
Hydro (System
Preformance)

MRO

Kimberly
Bentley

Western Area 1,6
Power
Adminstration

MRO

MRO Group Shonda
McCain

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Group
Group
Member
Member
Organization Segment(s)

Organization
Name

Name

Segment(s)

Region

Group Name

Group
Member
Name

Jaimin Patal

Group
Group
Member
Member
Organization Segment(s)

Saskatchewan 1
Power
Coporation
(SPC)

George Brown Pattern
Operators LP

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Group
Member
Region

MRO

Larry Heckert Alliant Energy 4
(ALTE)

MRO

Terry Harbour MidAmerican 1,3
Energy
Company
(MEC)

MRO

Dane Rogers

Oklahoma Gas 1,3,5,6
and Electric
(OG&E)

MRO

Seth
Shoemaker

Muscatine
Power &
Water

1,3,5,6

MRO

Michael
Ayotte

ITC Holdings

MRO

Andrew
Coffelt

Board of
Public
UtilitiesKansas (BPU)

1,3,5,6

MRO

Peter Brown

Invenergy

5,6

MRO

Organization
Name

Southwest
Power Pool,
Inc. (RTO)

WEC Energy
Group, Inc.

Name

Charles
Yeung

Christine
Kane

Segment(s)

Region

Group Name

MRO,SPP RE,WECC SRC 2023

Group
Member
Name

Group
Group
Member
Member
Organization Segment(s)

Angela Wheat Southwestern 1
Power
Administration

MRO

Bobbi Welch

MRO

Midcontinent 2
ISO, Inc.

Charles Yeung SPP

MRO

Ali Miremadi

CAISO

WECC

Helen Lainis

IESO

NPCC

Bobbi Welch

Midcontinent 2
ISO, Inc.

MRO

Greg Campoli NYISO

NPCC

Elizabeth
Davis

PJM

Kennedy
Meier

Electric
Reliability
Council of
Texas, Inc.

Texas RE

WEC Energy
Group, Inc.

Clarice Zellmer WEC Energy
Group, Inc.

David
Boeshaar

WEC Energy Christine Kane WEC Energy
Group
Group
Matthew
Beilfuss

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Group
Member
Region

WEC Energy
Group, Inc.

Organization
Name

Name

Southern
Colby
Company Galloway
Southern
Company
Services, Inc.

ACES Power
Marketing

Jodirah
Green

Segment(s)

1,3,5,6

1,3,4,5,6

Region

Group Name

MRO,RF,SERC,Texas Southern
RE,WECC
Company

Group
Member
Name

Group
Member
Region

Matt Carden

Southern
Company Southern
Company
Services, Inc.

SERC

Joel
Dembowski

Southern
Company Alabama
Power
Company

SERC

Ron Carlsen

Southern
Company Southern
Company
Generation

SERC

Leslie Burke

Southern
Company Southern
Company
Generation

SERC

Hoosier
Energy
Electric
Cooperative

MRO,RF,SERC,Texas ACES
Bob Soloman
RE,WECC
Collaborators

Kris Carper

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Group
Group
Member
Member
Organization Segment(s)

Arizona
2
Electric Power
Cooperative,
Inc.

WECC

Organization
Name

Name

FirstEnergy - Mark Garza 4
FirstEnergy
Corporation

Segment(s)

Region

Group Name

FE Voter

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Group
Member
Name

Group
Group
Member
Member
Organization Segment(s)

Group
Member
Region

Bill Pezalla

Old Dominion 3,4
Electric
Cooperative

SERC

Jason
Procuniar

Buckeye
Power, Inc.

Jolly Hayden

East Texas
Electric
Cooperative,
Inc.

NA - Not
Applicable

Texas RE

Nick Fogleman Prairie Power, 1,3
Inc.

SERC

Kylee Kropp

MRO

Sunflower
1
Electric Power
Corporation

Julie Severino FirstEnergy FirstEnergy
Corporation

Aaron
Ghodooshim

FirstEnergy FirstEnergy
Corporation

Robert Loy

FirstEnergy FirstEnergy
Solutions

Mark Garza

FirstEnergyFirstEnergy

1,3,4,5,6

Organization
Name

Michael
Johnson

Black Hills
Corporation

Name

Segment(s)

Michael
Johnson

Rachel
Schuldt

Northeast
Ruida Shu
Power
Coordinating
Council

Region

WECC

1,2,3,4,5,6,7,8,9,10 NPCC

Group Name

Group
Member
Name

Group
Group
Member
Member
Organization Segment(s)

Group
Member
Region

Stacey
Sheehan

FirstEnergy FirstEnergy
Corporation

Marco Rios

Pacific Gas
and Electric
Company

WECC

Sandra Ellis

Pacific Gas
and Electric
Company

WECC

Tyler Brun

Pacific Gas
and Electric
Company

WECC

Black Hills
Micah Runner Black Hills
Corporation Corporation
All Segments Josh Combs
Black Hills
Corporation

WECC

Rachel Schuldt Black Hills
Corporation

WECC

Carly Miller

Black Hills
Corporation

WECC

Sheila
Suurmeier

Black Hills
Corporation

WECC

NPCC

PG&E All
Segments

NPCC RSC

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Gerry Dunbar Northeast
Power
Coordinating
Council

Organization
Name

Name

Segment(s)

Region

Group Name

Group
Member
Name

Group
Member
Region

Alain Mukama Hydro One
1
Networks, Inc.

NPCC

Deidre
Altobell

Con Edison

NPCC

Jeffrey
Streifling

NB Power
Corporation

NPCC

Michele
Tondalo

United
Illuminating
Co.

NPCC

Stephanie
Orange and
Ullah-Mazzuca Rockland

NPCC

Central
1
Hudson Gas &
Electric Corp.

NPCC

Randy Buswell Vermont
1
Electric Power
Company

NPCC

James Grant

NPCC

John Pearson ISO New
England, Inc.

NPCC

Harishkumar
Subramani
Vijay Kumar

Independent
Electricity
System
Operator

NPCC

Randy
MacDonald

New
Brunswick

NPCC

Michael
Ridolfino

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Group
Group
Member
Member
Organization Segment(s)

NYISO

Organization
Name

Name

Segment(s)

Region

Group Name

Group
Member
Name

Group
Group
Member
Member
Organization Segment(s)

Group
Member
Region

Power
Corporation

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Dermot Smyth Con Ed Consolidated
Edison Co. of
New York

NPCC

David Burke

Orange and
Rockland

NPCC

Peter Yost

Con Ed Consolidated
Edison Co. of
New York

NPCC

Salvatore
Spagnolo

New York
Power
Authority

NPCC

Sean Bodkin

Dominion Dominion
Resources,
Inc.

NPCC

David Kwan

Ontario Power 4
Generation

NPCC

Silvia Mitchell NextEra
1
Energy Florida Power
and Light Co.

NPCC

Glen Smith

NPCC

Entergy
Services

Organization
Name

Name

Segment(s)

Region

Group Name

Group
Member
Name

Group
Group
Member
Member
Organization Segment(s)

Sean Cavote

PSEG

NPCC

Jason
Chandler

Con Edison

NPCC

Tracy
MacNicoll

Utility Services 5

NPCC

Shivaz Chopra New York
Power
Authority

NPCC

Vijay Puran

New York
6
State
Department of
Public Service

NPCC

ALAN
ADAMSON

New York
State
Reliability
Council

NPCC

David Kiguel

Independent

NPCC

Joel
Charlebois

AESI

NPCC

Joshua London Eversource
Energy
Elevate
Energy
Consulting

Ryan Quint NA - Not
Applicable

NA - Not Applicable Elevate
Energy
Consulting

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Group
Member
Region

Ryan Quint

Elevate Energy
Consulting

NA - Not
Applicable

N/A

NA - Not
Applicable

Organization
Name

Dominion Dominion
Resources,
Inc.

Name

Segment(s)

Region

Sean Bodkin 6

Group Name

Dominion

Group
Member
Name

Group
Group
Member
Member
Organization Segment(s)

Connie Lowe

Dominion Dominion
Resources,
Inc.

NA - Not
Applicable

Lou Oberski

Dominion Dominion
Resources,
Inc.

NA - Not
Applicable

Larry Nash

Dominion 1
Dominion
Virginia Power

NA - Not
Applicable

Rachel Snead Dominion Dominion
Resources,
Inc.
Western
Steven
Electricity
Rueckert
Coordinating
Council
Tim Kelley

Tim Kelley

NA - Not
Applicable

WECC

Phil O'Donnell WECC

WECC

WECC Entity Steve
Monitoring Rueckert

WECC

SMUD and
BANC

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Group
Member
Region

Nicole Looney Sacramento
3
Municipal
Utility District

WECC

Charles
Norton

WECC

Sacramento
6
Municipal
Utility District

Organization
Name

Name

Segment(s)

Region

Group Name

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Group
Member
Name

Group
Group
Member
Member
Organization Segment(s)

Group
Member
Region

Wei Shao

Sacramento
1
Municipal
Utility District

WECC

Foung Mua

Sacramento
4
Municipal
Utility District

WECC

Nicole Goi

Sacramento
5
Municipal
Utility District

WECC

Kevin Smith

Balancing
Authority of
Northern
California

WECC

1. Do you support the definition for Inverter-based Resource (IBR) as proposed, or with non-substantive changes? If you do not support
the definition as proposed, please explain the changes that, if made, would result in your support.
Duane Franke - Manitoba Hydro - 1,3,5,6 - MRO
Answer

Document Name
Comment
- The off-shore IBR connected via VSC-HVDC should be included in the IBR definition list of examples.
- We have concerns about the term ‘not limited to’ in the definition, which may create some confusion about what could be considered as
IBR, such as a STATCOM with limited active power capability to support the system inertia or system reliability, that should not belong to
the IBR, even it meets the IBR definition. We proposed adding the exclusion terms in the definition, which may state that an inverter-based
plant with limited active power capability is not part of the IBR definition.
- Any FACT device connected to the IBR plant to support the IBR operation should be included in the IBR auxiliary equipment and be part of
the IBR definition.
Likes

Dislikes

Response
Thank you for the comment, this comment will be passed along to the drafting team (DT) for consideration when drafting the next draft
of the IBR definition. The DT will consider not carrying the IBR Unit term for the next ballot.
Sean Bodkin - Dominion - Dominion Resources, Inc. - 6, Group Name Dominion
Answer

Document Name
Comment
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Dominion Energy does not agree with the proposed definition and offers the following alternative:
Inverter Based Resources (IBR): IBRs include all NERC registered generating facilities directly connected to the Bulk Power System at 60kV
and above using power electronic devices that change direct current (DC) power produced by a resource to alternating current (AC).
Likes

Dislikes

Response
It is the DT's intent that IBR can apply to any voltage class and are not inherently linked to NERC registration. Newly proposed NERC
registration types specifically call those out as non-registered IBRs.
Kristina Marriott - Miller Bros. Solar, LLC - 5 - MRO,WECC,Texas RE
Answer

Dislikes

Response
Thank you for the comment, the DT has addressed the listed examples from FERC Order No.901, in which examples have proven to pose
risks to the transmission system reliability as documented by ERO disturbance reports. It was not the DT intent to exclude any types of
inverter-based resources.
Rachel Schuldt - Black Hills Corporation - 6, Group Name Black Hills Corporation - All Segments
Answer

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Document Name
Comment
Black Hills Corporation believes that only the Inverter-Based Resource (IBR) definition is needed. Consider revision of the definition as
follows:
“Generating unit that consists of an individual device or a grouping of multiple devices that:
•
•
•

Likes

Dislikes

Response
Thank you for the comment, the DT has re-considered the use of IBR Unit and is no longer proposing it as a definition in the new ballot.
Jennifer Bray - Arizona Electric Power Cooperative, Inc. - 1
Answer

Document Name
Comment
AEPC has signed on to ACES comments:
We at ACES applaud the SDT for the work that has been put into developing these definitions. We are greatly encouraged by the SDT’s
willingness to heed industry feedback and implement changes to the IBR definition. It is the opinion of ACES that the currently proposed
IBR
definition, while overall very good, would benefit from a few minor changes.
It is our opinion that the addition of the phrase “plant/facility” within the definition potentially introduces more confusion than it
eliminates. As this term is not explicitly defined, it allows for a considerable amount of interpretation by the industry. It is our opinion that
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

the term facility
should instead be included within the defined term itself (i.e., Inverter-Based Resource Facility) in order to be more consistent with other
uses of this phrase within the NERC Glossary of Terms.
Lastly, we believe that the last sentence of the definition wherein a list of example technologies is provided should be struck. It is our
perspective that this list is superfluous and unnecessary. While we appreciate the intent of the SDT in providing said list, we believe this
level of granularity is best provided via the Reliability Standards themselves as stated in Section 2 of the Technical Rationale (e.g., “…the
Applicability Section for that Reliability Standard(s) will specify which IBRs are applicable.”). If it is the intention of the SDT to specifically
exclude certain resource types, then we suggest either providing an explicit list of excluded resource types or modifying the definition in
such a manner so as to not include these resource types in the first place. Thus, it is our recommendation that the IBR definition be
renamed to IBR Facility and modified as follows:
•

Likes

Dislikes

Response
Thank you for the comment, the DT has considered the use plant/facility but maintains that an IBR is meant to be synonymous with the
topology of a plant and facility. The DT has addressed the listed examples from FERC Order no.901 and which examples have proven to
pose risks to the transmission system reliability as documented by ERO disturbance reports. It was not the DT intent to exclude any types
of inverter-based resources.
Israel Perez - Israel Perez On Behalf of: Mathew Weber, Salt River Project, 3, 1, 6, 5; Sarah Blankenship, Salt River Project, 3, 1, 6, 5;
Thomas Johnson, Salt River Project, 3, 1, 6, 5; Timothy Singh, Salt River Project, 3, 1, 6, 5; - Israel Perez
Answer

Document Name
Comment
SRP does not support the addition or modification of this term to the standard. This new term defines IBR’s being introduced directly into
a standard which previously did not have IBR applicability. SRP strongly feels Inverter Based Resources should have separate standards.
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Likes

Dislikes

Response
The original SAR of the Project 2020-06 requires the explicit consideration of IBR in MOD-026 and MOD-027. In addition, as of the current
effective version of MOD-026 and MOD-027 these currently apply to IBR.
Srikanth Chennupati - Entergy - Entergy Services, Inc. - 1,3,5,6 - SERC
Answer

Document Name
Comment
•
•

Entergy believes that this Inverter-Based Resource (IBR) definition and IBR Unit definition should be combined into to a single
definition.
Proposed definition is “A facility that is connected to the electric system, consisting of one or more devices using a power
electronic interface (such as an inverter or converter) and capable of exporting Real Power and acting as a single resource at a
common point of interconnection. IBRs include but are not limited to, solar photovoltaic (PV), Type 3 and Type 4 wind, battery
energy storage system (BESS), and fuel cell.”

Likes

Dislikes

Response
Thank you for the comment, the DT has re-considered the use of IBR Unit and is no longer proposing it as a definition in the new ballot.
Anna Martinson - MRO - 1,2,3,4,5,6 - MRO, Group Name MRO Group
Answer

aggregate set of units, please see Blackstart Resource definition. Further, defined terms already exist, such as Facility, that can be utilized
to clearly articulate that IBR term is intended to be used at an aggregate level in certain contexts. Additionally, undefined terms such as
facility or plant can be used, as currently done in existing standards, when a defined term is not adequate. For example, IBR generating
Facility or facility would refer to the aggregate level, whereas IBR individual generating unit would refer to a single wind turbine generator
or photovoltaic inverter.
The MRO NSRF proposes the following:
Inverter-Based Resource (IBR):
A generating unit(s) that consists of an individual device(s) that uses a power electronic interface, such as an inverter or converter,
capable of exporting Real Power from a primary energy source or energy storage system, and that are connected through a system
designed primarily for delivering Real Power to a common point of interconnection to Transmission.
Likes

Dislikes

Lincoln Electric System, 5, Millard Brittany
0

Response
Thank you for the comment, this comment will be passed along to the DT for consideration for the next draft of the IBR definition. The
team will consider no IBR Unit term for the next ballot.
Andy Thomas - Duke Energy - 1,3,5,6 - SERC,RF
Answer

Document Name
Comment
Duke Energy proposes the following three (3) IBR building-block related definitions. Dividing the NERC definitions into 3 definitions, helps
align the terms with current NERC usage of the terms for non-IBR generators and with other industry IBR standards. Unit is normally
understood as a combination of related equipment which together functions as a single entity for the industry and GADS reported data.
This proposed matching of terms will also reduce confusion within other standards. Additionally, the modeling standard should recognize
that modeling may need to be split by inverter model and/or resource type but recombined as a unit based on how the devices are

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

controlled (e.g., PV and BESS inverters need different models, but may be operated together to regulate voltage). The fact that the
devices must be modeled differently does not mean that each type of inverter must be defined as a unit.
Definition #1
Inverter-Based Resource Plant/Facility (IBR Plant/Facility): A plant/facility connected to the electric system that consist of one or more
IBR Unit(s) at a common point of interconnection. IBRs types include, but are not limited to, solar photovoltaic (PV), Type 3 and Type 4
wind, battery energy storage system (BESS), and fuel cell.
Justification: With regard to the removal of “Operated as a single resource”, this phrase implied that each unit must be combined to
operate as a single resource. Generally, multiple units at a plant are controlled individually.
Definition #2
Inverter-Based Resource Unit (IBR Unit): A single or group of devices that are operated and controlled together as a single resource
(entity). The unit utilizes a power electronic interface, such as inverters or converters, capable of exporting Power from a primary energy
source or energy storage system.
Justification: The phrase “Single point on the collector system” was removed because that the implied condition could result in multiple
interpretations. The SDT was possibly assuming that the IEEE Point of Connection term is equivalent to the phrase “single point on the
collector system” but are not equivalent in several cases.
Definition: Unit - An electricity generator and related equipment essential to the electricity generator’s operation, which together
function as a single entity. (Source: Generating Unit Definition: 414 Samples | Law Insider)
Definition #3
Inverter-Based Resource Device (IBR Device): An individual device, such as an inverter or converter, capable of exporting Power from a
primary energy source or energy storage system.
Justification: This additional term was added because the NERC use of the term Unit does not align well with IEEE IBR Unit. The IEEE
definition of an IBR unit is directed towards a component, or device. It can be a single inverter, a central inverter unit, or a group of
inverters tested by a NRTL to function together. The NERC definition of a Unit appears more focused on a collection of individual devices
designed and constructed to function together, but not designed as a single package.

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Likes

Dislikes

Response
Thank you for the comment, this comment will be passed along to the DT for consideration for the next draft of a singular IBR definition.
The team decided to re ballot IBR as a single definition instead multiple.
Christine Kane - WEC Energy Group, Inc. - 3, Group Name WEC Energy Group
Answer

Document Name
Comment
WEC Energy Group supports the comments of the MRO NSRF.
Likes

Dislikes

Response
Thank you for the comment, please see the response MRO NSRF.
Dennis Chastain - Tennessee Valley Authority - 1,3,5,6 - SERC
Answer

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

“A plant/facility that is connected to the electric system using one or more IBR Unit(s) operated as a single resource at a common point of
interconnection. IBRs include, but are not limited to, solar photovoltaic (PV), Type 3 and Type 4 wind, battery energy storage system
(BESS), and fuel cell.”
Likes

Dislikes

Response
Thank you for the comment, the DT has decided to remove IBR Unit and only ballot the term IBR. The team has updated IBR to not
include IBR Unit within the new definition.
Donna Wood - Tri-State G and T Association, Inc. - 1
Answer

Document Name
Comment
Tri-State Generation and Transmission supports the comments of the MRO NSRF.
Likes

Dislikes

Response
Thank you for the comment, please see the response to MRO NSRF’s comment.
Carver Powers - Utility Services, Inc. - 4
Answer

that require separate devices (battery energy storage system, fuel cell). With the proposed definition, it is unclear whether an IBR is an
Element or a plant/facility.
Suggest moving the concepts detailed in the second sentence to the IBR Unit definition for clarity of the undefined term “power source”
used in that definition.
Both “plant” and “facility” are not defined. The term facility is often confused with the NERC defined term “Facility”. CIP-002 R1 uses the
undefined term “asset” and then lists the applicable assets. Suggest replacing the term “facility” with “asset”.
The term “electric system” is undefined. It seems that the intent is to allow the IBR definition to apply to more than the BES or BPS but
any two electrical devices connected together could be an “electric system”. Suggest referencing that the IBR is used to convert power
that is exported from the plant/facility.
Recommend clarifying “Type 3 and Type 4 wind” by including “turbine” after wind in the proposed IBR definition.
“Solar photovoltaic” is a type of technology or method to generate electricity and not a device. A plant may have ancillary devices such
as lights and cameras, that use solar photovoltaic cells to charge their batteries. These ancillary devices should not be IBRs.
The NERC glossary does not define acronyms within definition for a different term. Both PV and BESS acronyms should not be included in
the definition of IBR.
Suggest the following:
“Inverter-Based Resource (IBR): A plant/asset that uses one or more IBR Unit(s) for the conversion of power for export from the
plant/asset and operated as a single resource at a common point of interconnection.”
Likes

Dislikes

Response
The IBR definition states that the IBR is a plant/facility comprised of those individual technology types. This is as opposed to a
synchronous resource that is comprised of synchronous generators.
IBR Unit Definition has been removed and will not be balloted this next balloting period.
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

It was the DT’s intent to use lowercase plant/facility in order to keep it separate from the NERC defined term Facility.
It was the DT’s intent that IBR can refer to any voltage class system, as long as it is a plant/facility that is made up of one or more
individual devices that export power to an AC electric system using power electronic devices.
The DT agrees with this final point.
Megan Melham - Decatur Energy Center LLC - 5
Answer

Document Name
Comment
Capital Power supports the NAGF comments for the IBR definition as below:
The NAGF believes that only the Inverter-Based Resource (IBR) definition is needed and should be revised as follows:
“A generating unit(s) that consists of one or more individual device(s) that uses a power electronic interface, such as an inverter or
converter, capable of exporting Real Power from a primary energy source or energy storage system, and that are connected through a
system designed primarily for delivering Real Power to a common point of interconnection to Transmission.”
Likes

Dislikes

Response
Thank you for the comment, the DT has re-considered the use of IBR Unit and is no longer proposing it as a definition in the new ballot.
Dwanique Spiller - Berkshire Hathaway - NV Energy - 5
Answer

defining it as a piece of electrical equipment. Resource is not a defined term and can be used to define either an individual unit or
aggregate set of units, please see Blackstart Resource definition. Further, defined terms already exist, such as Facility, that can be utilized
to clearly articulate that IBR term is intended to be used at an aggregate level in certain contexts. Additionally, undefined terms such as
facility or plant can be used, as currently done in existing standards, when a defined term is not adequate. For example, IBR generating
Facility or facility would refer to the aggregate level, whereas IBR individual generating unit would refer to a single wind turbine generator
or photovoltaic inverter.
NV Energy proposes the following:
Inverter-Based Resource (IBR):
A generating unit(s) that consists of an individual device(s) that uses a power electronic interface, such as an inverter or converter,
capable of exporting Real Power from a primary energy source or energy storage system, and that are connected through a system
designed primarily for delivering Real Power to a common point of interconnection to Transmission.
Likes

Dislikes

Response
Thank you for the comment, this will be passed along to the DT for consideration in the next draft of the terms. The DT also will not be
moving forward with the IBR Unit term in the next ballot.
Wayne Sipperly - North American Generator Forum - 5 - MRO,WECC,Texas RE,NPCC,SERC,RF
Answer

Document Name
Comment
The NAGF believes that only the Inverter-Based Resource (IBR) definition is needed and should be revised as follows:
“A generating unit(s) that consists of one or more individual device(s) that uses a power electronic interface, such as an inverter or
converter, capable of exporting Real Power from a primary energy source or energy storage system, and that are connected through a
system designed primarily for delivering Real Power to a common point of interconnection to Transmission.”
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Likes

Dislikes

Response
Thank you for the comment, the DT has re-considered the use of IBR Unit and is no longer proposing it as a definition in the new ballot.
Lauren Giordano - Lauren Giordano On Behalf of: Dennis Sismaet, Northern California Power Agency, 4, 6, 3, 5; Jeremy Lawson,
Northern California Power Agency, 4, 6, 3, 5; Marty Hostler, Northern California Power Agency, 4, 6, 3, 5; - Lauren Giordano
Answer

Document Name
Comment
We believe the SDT needs to explain or clarify what "the electric system" is and how an IBR relates to the Bulk Electric System.
Likes

Dislikes

Response
IBR does not specifically relate to the BPS or BES as defined by NERC. IBRs can be located on any voltage class system.
Jodirah Green - ACES Power Marketing - 1,3,4,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name ACES Collaborators
Answer

the term facility should instead be included within the defined term itself (i.e., Inverter-Based Resource Facility) in order to be more
consistent with other uses of this phrase within the NERC Glossary of Terms.
Lastly, we believe that the last sentence of the definition wherein a list of example technologies is provided should be struck. It is our
perspective that this list is superfluous and unnecessary. While we appreciate the intent of the SDT in providing said list, we believe this
level of granularity is best provided via the Reliability Standards themselves as stated in Section 2 of the Technical Rationale (e.g., “…the
Applicability Section for that Reliability Standard(s) will specify which IBRs are applicable.”). If it is the intention of the SDT to specifically
exclude certain resource types, then we suggest either providing an explicit list of excluded resource types or modifying the definition in
such a manner so as to not include these resource types in the first place.
Thus, it is our recommendation that the IBR definition be renamed to IBR Facility and modified as follows:
Inverter-Based Resource (IBR) Facility: One or more IBR Unit(s), and any associated Element(s) required for the operation thereof,
connected to the electric system and operated as a single resource at a common point of interconnection.
Likes

Dislikes

Response
Thank you for the comment, the DT has considered the use plant/facility but maintains that an IBR is meant to be synonymous with the
topology of a plant and facility.
The DT has addressed the listed examples from FERC Order no.901 and which examples have proven to pose risks to the transmission
system reliability as documented by ERO disturbance reports.
It was not the DT intent to exclude any types of inverter-based resources.
Joshua Phillips - Southwest Power Pool, Inc. (RTO) - 2
Answer

due to these similarities. While they do not inject real power into the grid, they do pull real power from the grid and the impacts of these
types of loads tripping off can have impacts to reliability.
Large loads can be considered resources when utilized as demand response, though requirements may need to be considered beyond a
resource definition. To the extent these would not be covered by the definition proposed, we request consideration of including such
clarifications in the definition.
Likes

Dislikes

Response
The DT did consider large power electronic loads, however decided to remain in line with industry consensus in that IBR are limited to
those resources able to inject power into the EPS, as evidenced by NERC IRPS and IEEE 2800. If SPP has this concern the DT would
recommend the commenter to look into submitting a SAR on this concern.
Ryan Quint - Elevate Energy Consulting - NA - Not Applicable - NA - Not Applicable, Group Name Elevate Energy Consulting
Answer

Yes

Dislikes

Response
Thank you for the comment, please refer to ACES comment response.
Teresa Krabe - Lower Colorado River Authority - 5
Answer

Yes

Document Name
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Comment
LCRA supports the proposed IBR definition with the current Glossary of Terms. However, depending on how “point of interconnection” is
defined, or if it is added to the Glossary of Terms, the IBR definition could become invalid since there may be multiple generation facilities
behind a common GSU or Transmission Owner equipment which are operated independently and not “as a single resource.”
Likes

Dislikes

Response
Thank you for the comment.
Matt Lewis - Lower Colorado River Authority - 1,5
Answer

Yes

Document Name
Comment
LCRA TSC supports the proposed IBR definition with the current Glossary of Terms. However, depending on how “point of
interconnection” is defined, or if it is added to the Glossary of Terms, the IBR definition could become invalid since there may be multiple
generation facilities behind a common GSU or Transmission Owner equipment which are operated independently and not “as a single
resource.”
Likes

Dislikes

Response
Thank you for the comment.
Adrian Andreoiu - BC Hydro and Power Authority - 1, Group Name BC Hydro
Answer

Yes

Document Name
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Comment
BC Hydro appreciates the drafting team’s efforts and the opportunity to comment.
Given the comprehensive treatment in the Technical Rationale, the second sentence in the proposed IBR definition is not required. BC
Hydro suggests that the IBR definition can be simplified as follows:
IBR – a plant including an individual IBR Unit or multiple IBR Units operated as a single resource connected to the electric system at a
common point of connection.
As well, BC Hydro sees a potential conflict between IBR as defined here and the recent updates to the NERC Rules of Procedure to the
Generator Owner and Operator definitions.
In the current draft of the NERC Rules of Procedure – Appendix 2 Definitions used in the Rules of Procedure and Appendix 5B Statement
of Compliance Registry Criteria (Revision 8), the Category 2 Generator Owner entity is defined as “owns and maintains non-BES inverter
based generating resources (emphasis added) 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 GO)”.
BC Hydro appreciates the discussion at item #3 in the Technical Rationale. However, depending on the interpretation of “generating
resources”, owners of certain IBR types such as battery energy storage systems (BESS) may not be registered as a GO for these facilities.
This would create a potential discrepancy between definitions which may create a gap in the intended scope of applicability for MOD026-2 and potentially other reliability standards, i.e., entities that would be included under the applicability section of the standard
wouldn’t be part of the MRS Program as they may not be registered if they don’t meet the GO definition.
Likes

Dislikes

Response
Thank you for the comment, these comments will be passed along to the DT for consideration.
Michael Johnson - Michael Johnson On Behalf of: Marco Rios, Pacific Gas and Electric Company, 3, 1, 5; Sandra Ellis, Pacific Gas and
Electric Company, 3, 1, 5; Tyler Brun, Pacific Gas and Electric Company, 3, 1, 5; - Michael Johnson, Group Name PG&E All Segments
Answer

Yes

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Document Name
Comment
PG&E supports the IBR definition.
Likes

Dislikes

Response
Thank you for the support.
Daniela Atanasovski - APS - Arizona Public Service Co. - 1
Answer

Yes

Document Name
Comment
None
Likes

Dislikes

Response
Thank you for the comment.
Gail Elliott - Gail Elliott On Behalf of: Michael Moltane, International Transmission Company Holdings Corporation, 1; - Gail Elliott
Answer

Yes

Document Name
Comment

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

A White Paper authored by either the drafting team or NERC staff identifying those devices considered within the scope of the definition
and those outside of the Inverter-Based Resource (IBR) definition would be helpful going forward, if maintained by NERC staff.
Likes

Dislikes

Response
Thank you for the comment, this idea will be passed along to DT for further consideration.
Mark Garza - FirstEnergy - FirstEnergy Corporation - 4, Group Name FE Voter
Answer

Yes

Document Name
Comment
None.
Likes

Dislikes

Response
Thank you for the support.
Steven Rueckert - Western Electricity Coordinating Council - 10, Group Name WECC Entity Monitoring
Answer

Yes

unregulated. Provided technical rational supports avoiding confusion when applying Requirement language but may need to
be enhanced to meet the reliability concerns of two (or more) points of interconnection. WECC agrees with bullet 7 in the Technical
Rationale and each SDT using the defined terms needs to ensure clarity. Does the definition fully support all variants of hybrid
plants? Care needs to be taken as more hybrid plants are being integrated. If the term “IBR” is used for a MOD Standard and represents
a hybrid plant, how does a single model of the “IBR” represent the response? Granted, each part of the hybrid plant would be separate
IBR Units which may dictate how Standards utilize the terms.
Likes

Dislikes

Response
1. It can be either one lead or multiple leads that all connect to the same POI. There can also be multiple POI's. The main idea is that they
are all being controlled together to run as a single resource.
2. Yes, the definition does consider hybrid resources and is discussed in the TR.
3. In that case there would need to be multiple models that work together to model the response of the plant.
Mark Gray - Edison Electric Institute - NA - Not Applicable - NA - Not Applicable
Answer

Yes

Document Name
Comment
EEI has no objections to the IBR definition as proposed.
Likes

Dislikes

Response
Thank you for the support.
Amy Wilke - American Transmission Company, LLC - 1
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Answer

Yes

Document Name
Comment
The language itself may be acceptable, but changes should be made to the technical rationale to explain where an IBR ends. If POI or
where the facility is "connected to the electric power system" is the preferred term, this must be reconciled with other standards where
IBR is intended to be used. Other standards are contemplating using the POM or high side of the main power transformer as the location
where IBR performance is measured.
NERC Proposed Definition - Inverter-Based Resource (IBR): A plant/facility that is connected to the electric system consisting of one or
more IBR Unit(s) operated as a single resource at a common point of interconnection. IBRs include, but are not limited to, solar
photovoltaic (PV), Type 3 and Type 4 wind, battery energy storage system (BESS), and fuel cell.
Likes

Dislikes

Response
Thank you for the comment, this comment will be passed along to the DT for consideration for the next draft of the IBR definition
Thomas Foltz - AEP - 5
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the support.
Pirouz Honarmand - Pirouz Honarmand On Behalf of: Helen Lainis, Independent Electricity System Operator, 2; - Pirouz Honarmand
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the support.
Mohamad Elhusseini - DTE Energy - Detroit Edison Company - 3,5
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the support.
Casey Perry - PNM Resources - 1,3 - WECC,Texas RE
Answer

Yes

Document Name
Comment
Likes
Dislikes

0
0

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Response
Thank you for the support.
Cain Braveheart - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the support.
Dave Krueger - SERC Reliability Corporation - 10
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the support.
David Jendras Sr - Ameren - Ameren Services - 3
Answer

Yes

Document Name
Comment
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Likes

Dislikes

Response
Thank you for the support.
Chantal Mazza - Chantal Mazza On Behalf of: Nicolas Turcotte, Hydro-Quebec (HQ), 1, 5; - Chantal Mazza
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the support.
Junji Yamaguchi - Hydro-Quebec (HQ) - 5
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
The DT thanks you for your support.
Colby Galloway - Southern Company - Southern Company Services, Inc. - 1,3,5,6 - SERC, Group Name Southern Company
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
The Drafting Team thanks you for your support.
Ruida Shu - Northeast Power Coordinating Council - 1,2,3,4,5,6,7,8,9,10 - NPCC, Group Name NPCC RSC
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
The DT thanks you for your support.
Diana Aguas - CenterPoint Energy Houston Electric, LLC - 1 - Texas RE
Answer

Yes

Document Name
Comment
Likes
Dislikes

0
0

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Response
The Drafting Team thanks you for your support.
Leslie Hamby - Southern Indiana Gas and Electric Co. - 3,5,6 - RF
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
The DT thanks you for your support.
Kinte Whitehead - Exelon - 1,3
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
The DT thanks you for your support.
Mike Magruder - Avista - Avista Corporation - 1
Answer

Yes

Document Name
Comment
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Likes

Dislikes

Response
The DT thanks you for your support.
Charles Yeung - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC, Group Name SRC 2023
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
The DT thanks you for your support.
Kennedy Meier - Electric Reliability Council of Texas, Inc. - 2
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
The DT thanks you for your support.
Tim Kelley - Tim Kelley On Behalf of: Charles Norton, Sacramento Municipal Utility District, 3, 6, 4, 1, 5; Foung Mua, Sacramento
Municipal Utility District, 3, 6, 4, 1, 5; Kevin Smith, Balancing Authority of Northern California, 1; Nicole Looney, Sacramento Municipal
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Utility District, 3, 6, 4, 1, 5; Ryder Couch, Sacramento Municipal Utility District, 3, 6, 4, 1, 5; Wei Shao, Sacramento Municipal Utility
District, 3, 6, 4, 1, 5; - Tim Kelley, Group Name SMUD and BANC
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
The DT thanks you for your support.
Marty Hostler - Northern California Power Agency - 4
Answer
Document Name
Comment
1. NO. We believe the SDT needs to explain or clarify what "the electric system" is and how an IBR relates to the Bulk Electric System.

Likes

Dislikes

Response
Thank you for the comment, we will be sure that this is passed along to the DT.

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

2. Do you support the definition for IBR Unit as proposed, or with non-substantive changes? If you do not support the definition as
proposed, please explain the changes that, if made, would result in your support.
Tim Kelley - Tim Kelley On Behalf of: Charles Norton, Sacramento Municipal Utility District, 3, 6, 4, 1, 5; Foung Mua, Sacramento
Municipal Utility District, 3, 6, 4, 1, 5; Kevin Smith, Balancing Authority of Northern California, 1; Nicole Looney, Sacramento Municipal
Utility District, 3, 6, 4, 1, 5; Ryder Couch, Sacramento Municipal Utility District, 3, 6, 4, 1, 5; Wei Shao, Sacramento Municipal Utility
District, 3, 6, 4, 1, 5; - Tim Kelley, Group Name SMUD and BANC
Answer

Document Name
Comment
SMUD supports the creation of a definition for “IBR Unit” since it is highly likely that drafting teams for other NERC Standards Projects
related to inverter-based resources will need the flexibility to draft requirements that apply specifically to the power electronic interface
equipment, and not to the entire inverter-based resource facility.
The proposed definition for IBR Unit is excessively complicated. We recommend the drafting team consider the following changes to the
proposed definition:
“An individual device, or grouping of multiple devices, that uses a power electronic interface, such as an inverter or converter, capable of
exporting Real Power and of providing Reactive Power support from a primary energy source or energy storage system, and that
connects at a single point on a collector system.”
Likes

Dislikes

Response
Thank you for the comment. The DT decides to remove the separate definition for "IBR Unit" based on the industrial comments.
The "IBR" definition is revised to include the description of individual devices. Examples of IBR are listed.
Amy Wilke - American Transmission Company, LLC - 1
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Answer

Document Name
Comment
Additional clarity should be provided to this definition. There is some confusion right now without more context of the technical
rationale document included in the standard itself. As stated right now, an IBR unit can be an individual device or multiple devices and
while the Technical Rationale examples and pictures make it fairly clear, more clarity in the definition language would be helpful. Perhaps
stating that an IBR unit is one that connects together behind the same generator step up transformer (IBR Unit transformer). Edits are
also provided below.
NERC Proposed Definition - Inverter-Based Resource unit (IBR Unit): An individual device that uses a power electronic Interface, such as
an inverter or converter, capable of exporting Real Power from a primary energy source or energy storage system, and that connects at a
single point on the collector system: or a grouping of multiple devices that uses a power electronic interface(s), such as an inverter or
converter, capable of exporting Real Power from a primary energy source or energy storage system, and that connect together at a single
point on the collector system.
ATC Proposed edit - Inverter-Based Resource Unit (IBR Unit): An individual device or grouping of multiple devices that uses a power
electronic interface, such as an inverter or converter, capable of exporting Real Power from a primary energy source or energy storage
system, and that connects behind the same IBR Unit step up transformer.
Likes

Dislikes

Document Name
Comment
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

SPP has a concern that the proposed definition potentially places a limit only holding an account for Real Power instead of Reactive
Power.
We recommend that the drafting team replace the term “Real Power” with power, that aligns with the BES definition for generation
(inclusion).
Likes

Dislikes

Response
Thank you for the comment, this will be passed along to the DT for consideration when drafting the new IBR definition.
Jodirah Green - ACES Power Marketing - 1,3,4,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name ACES Collaborators
Answer

Document Name
Comment
We believe the currently proposed IBR Unit definition contains language that overlaps the proposed IBR (a.k.a. IBR Facility) definition and
should be modified. It is our opinion that the definition of an IBR Unit should utilize a standalone, technologically agnostic, approach that
is consistent with language already utilized elsewhere in the NERC Glossary of Terms.
Furthermore, it is the opinion of ACES that the reference to “a grouping of multiple devices” is confusing. We believe that the intent of
the SDT was to encompass all possible configurations of IBR Units; however, we do not believe the current language meets said intent
succinctly enough. Moreover, there are no other definitions that attempt to define generating units with such a level of specificity. For
instance, there are no definitions within the NERC Glossary of Terms that attempt to define the many various configurations of a
combined cycle unit (e.g., 1x1, 2x1, 3x2, 4x1, etc.). Hence, in this instance, we believe that less is more.
Therefore, it is our recommendation that the IBR Unit definition be modified as follows:
Inverter-Based Resource (IBR) Unit: An individual generating resource capable of exporting Real Power that uses a power electronic
interface, such as an inverter or rectifier, and connects at a single point to a system designed primarily for delivering such Real Power to a
common point of interconnection.
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Likes

Dislikes

Response
Thank you for the comment. The DT decides to remove the separate definition for "IBR Unit" based on the industrial comments.
The "IBR" definition is revised to include the description of individual devices. Examples of IBRs are listed.
Lauren Giordano - Lauren Giordano On Behalf of: Dennis Sismaet, Northern California Power Agency, 4, 6, 3, 5; Jeremy Lawson,
Northern California Power Agency, 4, 6, 3, 5; Marty Hostler, Northern California Power Agency, 4, 6, 3, 5; - Lauren Giordano
Answer

Document Name
Comment
If the SDT is going to use the proposed definition the language "single point on the collector system" should be revised to "single point on
a collector system bus that meets the BES definition."
Likes

Dislikes

Response
Thank you for the comment. The DT decides to remove the separate definition for "IBR Unit" based on the industrial comments.
The "IBR" definition is revised to include the description of individual devices. Examples of IBRs are listed.
Wayne Sipperly - North American Generator Forum - 5 - MRO,WECC,Texas RE,NPCC,SERC,RF
Answer

Document Name
Comment

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

The NAGF recommends that having an IBR unit definition is unnecessary. Please see the response to Question #1. In addition, the NAGF
points out that the SDT has said there is no need to define “collector system” as everyone understands what that term means. The SDT is
also attempting to use a term that industry understands and uses, “unit”, to mean something much different than how the term is
currently used in the operations arena of the industry. This is unacceptable as it will likely lead to significant confusion and
misunderstanding in the implementation of the standards.
Likes

Dislikes

Document Name
Comment
Renewable generation must at some point cover Reactive Power if we are moving towards all renewable generation in the future. Due to
this, Southern Indiana Gas & Electric, Company recommends adding “Reactive Power” to the definition.
Likes

Dislikes

Response
Thank you for the comment, the DT will take this into consideration when drafting the new version of the definition for IBR.
Dwanique Spiller - Berkshire Hathaway - NV Energy - 5
Answer

Document Name
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Comment
See Question 1.
Likes

Dislikes

Document Name
Comment
Suggest changing the term name from IBR Unit to Inverter Based Unit (IBU) for clarity in the proposed IBR definition.
The proposed definition is structured in a way that make it difficult to understand. The following is the definition using the NERC style
guide… in part.
1) An individual device that uses a power electronic interface, such as an inverter or converter, capable of exporting Real Power from a
primary energy source or energy storage system, and
2) that connects at a single point on the collector system;
or
1) A grouping of multiple devices that uses a power electronic interface(s), such as an inverter or converter, capable of exporting Real
Power from a primary energy source or energy storage system, and
2) that connect together at a single point on the collector system.
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Based on this interpretation of the proposed definition, the following definition would mean the same but be simpler to understand. This
modified definition also includes the list of primary energy sources and BESS from the IBR definition
“An individual device or grouping of devices that:
1) use a power electronic interface, such as an inverter or converter, capable of exporting Real Power from a primary energy source or
energy storage system (e.g. solar photovoltaic devices, Type 3 and Type 4 wind turbines, battery energy storage systems, and fuel cells)
and
2) connect at a single point on a collector system;”
It could also be structured this way:
“An individual device or grouping of devices that utilize a power electronic interface, such as an inverter or converter, capable of
exporting Real Power from a primary energy source or energy storage system (e.g., solar photovoltaic devices, Type 3 and Type 4 wind
turbines, battery energy storage systems, and fuel cells) and connecting at a single point on a collector system.”
Likes

Dislikes

Response
Thank you for the comment, The DT decides to remove the separate definition for "IBR Unit" based on the industry comments.
The "IBR" definition is revised to include the description of individual devices. Examples of IBRs are listed.
Donna Wood - Tri-State G and T Association, Inc. - 1
Answer

Document Name
Comment
Tri-State Generation and Transmission supports the comments of the MRO NSRF.
Likes

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Dislikes

Response
Thank you for the comment, please see the response to MRO NSRF’s comment.
Dennis Chastain - Tennessee Valley Authority - 1,3,5,6 - SERC
Answer

Document Name
Comment
The Draft 2 "IBR Unit" definition states that it’s a device that uses a power electronic interface. The IBR Unit doesn’t use the interface, it
is the interface. As such, suggest changing the words “that uses” to “consisting of” such that the definition would now read:
“An individual device consisting of a power electronic interface, such as an inverter or converter, capable of exporting Real Power from a
primary energy source or energy storage system, and that connects at a single point on the collector system; or a grouping of multiple
devices consisting of power electronic interface(s), such as inverters or converters, capable of exporting Real Power from a primary
energy source or energy storage system, and that connect together at a single point on the collector system.”
Likes

Dislikes

Response
Thank you for the comment. The DT decides to remove the separate definition for "IBR Unit" based on the industrial comments. Thank
you for the suggestion and will be noted if the team decides to reconsider IBR Unit.
Christine Kane - WEC Energy Group, Inc. - 3, Group Name WEC Energy Group
Answer

Document Name
Comment

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

WEC Energy Group supports the comments of the MRO NSRF.
Likes

Dislikes

Response
Thank you for the comment, please refer to the response to MRO NSRF’s comment.
Andy Thomas - Duke Energy - 1,3,5,6 - SERC,RF
Answer

Document Name
Comment
See Question #1 Response.
Likes

Dislikes

Response
Thank you for the comment.
Anna Martinson - MRO - 1,2,3,4,5,6 - MRO, Group Name MRO Group
Answer

Document Name
Comment
See Question 1.
Likes
Dislikes

0
0

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Response
Thank you for the comment.
Srikanth Chennupati - Entergy - Entergy Services, Inc. - 1,3,5,6 - SERC
Answer

Document Name
Comment
Entergy believes that having an IBR Unit definition is unnecessary. Entergy is concerned that the potential level of granularity in the IBR
Unit definition makes compliance overly burdensome due to the need to perform compliance activities on a device-by-device basis. An
IBR facility can have hundreds of individual IBR Units as it is currently defined. Where standard requirements need to be applied at the
inverter level, then the individual standards should state that.
Likes

Dislikes

Response
Thank you for the comment. The DT decides to remove the separate definition for "IBR Unit" based on the industry comments.
Israel Perez - Israel Perez On Behalf of: Mathew Weber, Salt River Project, 3, 1, 6, 5; Sarah Blankenship, Salt River Project, 3, 1, 6, 5;
Thomas Johnson, Salt River Project, 3, 1, 6, 5; Timothy Singh, Salt River Project, 3, 1, 6, 5; - Israel Perez
Answer

Document Name
Comment
SRP does not support the addition or modification of this term to the standard. This new term defines IBR’s being introduced directly into
a standard which previously did not have IBR applicability. SRP strongly feels Inverter Based Resources should have separate standards.
Likes
Dislikes

0
0

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Response
Thank you for the comments and opinions.
Jennifer Bray - Arizona Electric Power Cooperative, Inc. - 1
Answer

Document Name
Comment
AEPC has signed on to ACES comments:
We believe the currently proposed IBR Unit definition contains language that overlap the proposed IBR (a.k.a. IBR Facility) definition and
should be modified. It is our opinion that the definition of an IBR Unit should utilize a standalone, technologically agnostic, approach that
is
consistent with language already utilized elsewhere in the NERC Glossary of Terms.
Furthermore, it is the opinion of ACES that the reference to “a grouping of multiple devices” is confusing. We believe that the intent of
the SDT was to encompass all possible configurations of IBR Units; however, we do not believe the current language meets said intent
succinctly enough.
Moreover, there are no other definitions that attempt to define generating units with such a level of specificity. For instance, there are no
definitions within the NERC Glossary of Terms that attempt to define the many various configurations of a combined cycle unit (e.g., 1x1,
2x1, 3x2, 4x1, etc.). Hence, in this instance, we believe that less is more.
Therefore, it is our recommendation that the IBR Unit definition be modified as follows:
•

Inverter-Based Resource (IBR) Unit: An individual generating resource capable of exporting Real Power that uses a power
electronic interface, such as an inverter or rectifier, and connects at a single point to a system designed primarily for delivering
such Real Power to a common point of interconnection.

Likes

Dislikes

Response
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Thank you for the comment. The DT decides to remove the separate definition for "IBR Unit" based on the industry comments. This is
noted for the future if IBR Unit is being reconsidered.
Rachel Schuldt - Black Hills Corporation - 6, Group Name Black Hills Corporation - All Segments
Answer

Document Name
Comment
Black Hills Corporation does not believe a definition for “IBR Unit” is necessary if the “IBR” definition from Question 1 is revised as
mentioned. The use of the term “unit” may conflict with other industry uses of the term. If necessary to define to an individual level, then
consider use of the term “element” or “device” in place of “unit.”
Likes

Dislikes

Response
Thank you for the comment.
Adrian Andreoiu - BC Hydro and Power Authority - 1, Group Name BC Hydro
Answer

Document Name
Comment
Per the latest revision, the IBR Unit definition references ‘an individual device … that connects at a single point on the collector
system’. BC Hydro appreciates the clarification provided during the SDT webinar that this addition was to correct grammar. However, it
does not seem to add value as a single device will not have multiple connection points to a single system.
It is also not clear why the IBR Unit definition needs to be dependent on “the collector system”, which is not a defined term. As the IBR
definition already specifies the requirement of “a common point of interconnection”, we posit that would be sufficient to define the IBR.

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

BC Hydro suggests that the collector system concept is not necessary to define the IBR Unit: the examples provided in the Technical
Rationale (Figures 2.1, 2.2, and 2.3 on pages 3-4) seem to indicate that it is the single AC bus that determines the interface between an
IBR Unit and the electric power system. However, if the “collector system” is to be deemed a critical component for defining an IBR Unit,
BC Hydro suggests that this be defined as a NERC Glossary Term instead of relying on a common understanding in the power industry.
During the SDT webinar’s Q&A session clarifications were provided to the effect that an Electric Vehicle (EV) can be deemed an IBR Unit if
bidirectional, i.e., injecting power into the grid, not just charging. Arguably, the collector system concept may be different in such
scenarios.
BC Hydro suggests that the simplified definitions proposed below do not miss any critical element to fully define the IBR facilities.
IBR Unit – an individual device or a grouping of multiple devices that can export Real Power from a primary energy source or energy
storage system via a power electronics interface.
IBR – a plant including an individual IBR Unit or multiple IBR Units operated as a single resource connected to the electric power system at
a common point of connection.
Likes

Dislikes

Response
Thank you for the comment, these will be considered when drafting the new IBR definition. The IBR Unit term will not be balloted this
next posting.
Kristina Marriott - Miller Bros. Solar, LLC - 5 - MRO,WECC,Texas RE
Answer

Document Name
Comment
MBS aligns with the previous submission responses made by the NAGF, and feels that the SDT did not address this concern nor provide
clarity:

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Utilizing the term IBR Unit to refer to a single inverter within the generating plant will cause significant confusion at the plant level. Unless
any instruction provided to the plant is written, then it will not be clear if the term IBR Unit is the defined term used by NERC or if it is
intended to mean the generating unit (Unit 1, 2 or 3), IBR unit. This level of potential confusion is unacceptable resulting in an
unacceptable risk of the BES being mis operated. The word “unit” has long been associated with a distinct operating segment of a plant.
For this reason, the NAGF does not support the use of the term unit to mean anything less than the dispatchable grouping of inverters.
MBS further supports TRE previous response:
...the current verbiage of IBR Unit does not include the capabilities for absorbing or delivering reactive power which is essential for
electric system operations.
Likes

Dislikes

Response
Thank you for the comment. The DT decides to remove the separate definition for "IBR Unit" based on the industry comments.
The "IBR" definition is revised to include the description of individual devices. Examples of IBRs are listed.
Sean Bodkin - Dominion - Dominion Resources, Inc. - 6, Group Name Dominion
Answer

Document Name
Comment
Dominion Energy is if the opinion that this defintion should be simplifed similiar to the proposed IBR defintion in Q1.
Inverter-Based Resource Unit (IBR Unit): An individual inverter device or a grouping of multiple inverters connected together operating
functionally as a single unit, and directly connected at a single point of interconnection to the Bulk Power System at 60kV and above.
Likes

Dislikes

Response
Thank you for the comments and the suggestion.
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Ryan Quint - Elevate Energy Consulting - NA - Not Applicable - NA - Not Applicable, Group Name Elevate Energy Consulting
Answer

Document Name
Comment
The definition appears to be overcomplicated and unnecessarily confusing. It is unclear why the definition could not simply state: "An
individual device, or a grouping of multiple devices, that uses a power electronic interface(s), such as an inverter or converter, capable of
exporting Real Power from a primary energy source or energy storage system, and that connects at a single point on the collector
system."
Likes

Dislikes

Response
Thank you for the feedback and input.
Mark Gray - Edison Electric Institute - NA - Not Applicable - NA - Not Applicable
Answer

Yes

Document Name
Comment
EEI has no objections to the IBR Unit definition as proposed.
Likes

Dislikes

Response
Thank you for the support.
Steven Rueckert - Western Electricity Coordinating Council - 10, Group Name WECC Entity Monitoring
Answer

Yes

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Document Name
Comment
WECC has no issue with the definition, but urges that care needs to be taken when using the term in Requirements. WECC appreciated
the approach taken by the SDT to distinguish the two terms.
Likes

Dislikes

Response
Thank you for the support.
Mark Garza - FirstEnergy - FirstEnergy Corporation - 4, Group Name FE Voter
Answer

Yes

Document Name
Comment
No comment.
Likes

Dislikes

Response
Thank you for the support.
Colby Galloway - Southern Company - Southern Company Services, Inc. - 1,3,5,6 - SERC, Group Name Southern Company
Answer

Yes

Document Name
Comment

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

See the suggestion to change IBR Unit to IBR Device in Q4 below. It is suggested that the SDT carefully consider the use of the word
"unit" to refer to both the power conversion element when unit is capitalized versus using unit to refer to the entire facility when not
capitalized.
Likes

Dislikes

Yes

Document Name
Comment
Another remark would be that while reading the overall definitions, it doesn’t seem clear that E-statcoms are not included in the scope of
the term IBR Unit. Perhaps a distinction between STATCOMs and E-STATCOMS should be added to the Technical Rationale depending on
the energy that can be stored or the storage technology used (supercaps-short duration vs batteries- long duration). Without this
distinction, there exists a risk that a storage system could be identified as a E-STATCOM and thus avoid certain requirements.
Likes

Dislikes

Response
Thank you for the comment, the IBR Unit will not be posted in the new ballot period.
Chantal Mazza - Chantal Mazza On Behalf of: Nicolas Turcotte, Hydro-Quebec (HQ), 1, 5; - Chantal Mazza
Answer

Yes

Document Name
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Comment
While reading the overall definitions, it doesn’t seem clear that E-statcoms are not included in the scope of the term IBR Unit. Perhaps a
distinction between STATCOMs and E-STATCOMS should be added to the Technical Rationale depending on the energy that can be stored
or the storage technology used (supercaps-short duration vs batteries- long duration). Without this distinction, there exists a risk that a
storage system could be identified as a E-STATCOM and thus avoid certain requirements.
Likes

Dislikes

Response
Thank you for the comment. The DT decides to remove the separate definition for "IBR Unit" based on the industry comments. The "IBR"
definition is revised to include the description of individual devices. Examples of IBRs are listed.
Dave Krueger - SERC Reliability Corporation - 10
Answer

Yes

Document Name
Comment
On behalf of the SERC Generator Working Group:
Suggest changing the word "unit" to "asset" to avoid confusion with the historical meaning of unit
Likes

Dislikes

Response
Thank you for the comments and suggestions.
Daniela Atanasovski - APS - Arizona Public Service Co. - 1
Answer

Yes

Document Name
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Comment
None
Likes

Dislikes

Response
Thank you for the support.
Michael Johnson - Michael Johnson On Behalf of: Marco Rios, Pacific Gas and Electric Company, 3, 1, 5; Sandra Ellis, Pacific Gas and
Electric Company, 3, 1, 5; Tyler Brun, Pacific Gas and Electric Company, 3, 1, 5; - Michael Johnson, Group Name PG&E All Segments
Answer

Yes

Document Name
Comment
PG&E supports the IBR Unit definition.
Likes

Dislikes

Response
Thank you for the comment.
Kennedy Meier - Electric Reliability Council of Texas, Inc. - 2
Answer

Yes

Document Name
Comment
Likes
Dislikes

0
0

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Response
Thank you for the support.
Charles Yeung - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC, Group Name SRC 2023
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the support.
Mike Magruder - Avista - Avista Corporation - 1
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the support.
Kinte Whitehead - Exelon - 1,3
Answer

Yes

Document Name
Comment
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Likes

Dislikes

Response
Thank you for the support.
Diana Aguas - CenterPoint Energy Houston Electric, LLC - 1 - Texas RE
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the support.
Ruida Shu - Northeast Power Coordinating Council - 1,2,3,4,5,6,7,8,9,10 - NPCC, Group Name NPCC RSC
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the support.
David Jendras Sr - Ameren - Ameren Services - 3
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the support.
Cain Braveheart - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the support.
Casey Perry - PNM Resources - 1,3 - WECC,Texas RE
Answer

Yes

Document Name
Comment
Likes
Dislikes

0
0

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Response
Thank you for the support.
Matt Lewis - Lower Colorado River Authority - 1,5
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the support.
Teresa Krabe - Lower Colorado River Authority - 5
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the support.
Mohamad Elhusseini - DTE Energy - Detroit Edison Company - 3,5
Answer

Yes

Document Name
Comment
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Likes

Dislikes

Response
Thank you for the support.
Pirouz Honarmand - Pirouz Honarmand On Behalf of: Helen Lainis, Independent Electricity System Operator, 2; - Pirouz Honarmand
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the support.
Duane Franke - Manitoba Hydro - 1,3,5,6 - MRO
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the support.
Thomas Foltz - AEP - 5
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the support.
Marty Hostler - Northern California Power Agency - 4
Answer
Document Name
Comment
1. No. If the SDT is going to use the proposed definition the language "single point on the collector system" should be revised to

"single point on a collector system bus that meets the BES definition."

Likes

Dislikes

Response
Thank you for the comments and suggestions.
Megan Melham - Decatur Energy Center LLC - 5
Answer
Document Name
Comment
Capital Power supports the NAGF comments for the IBR Unit definition as below:

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Dislikes

Response
Thank you for the comment, please refer to the response to NAGF’s comment.

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

3. As discussed in the Technical Rationale, the proposed definitions would define the scope of equipment, but would not define the
scope of IBR units subject to mandatory compliance with Reliability Standards. Each standard would define the applicable units subject
to compliance with that standard. An example to include both BES and non-BES IBRs is as follows:
Section 4. Applicability:
4.1 Functional Entities: Generator Owner, Generator Operator
4.1 Facilities: (1) BES Inverter-Based Resources; and (2) Non-BES Inverter Based Resources (IBRs) that 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.
Provide any suggested revisions you feel would improve the readability of this example.
Sean Bodkin - Dominion - Dominion Resources, Inc. - 6, Group Name Dominion
Answer

Document Name
Comment
The BES definition should govern applicability and individual standards should not be conflicting with an approved definition.
Likes

Dislikes

Response
Thank you for the comment.
Israel Perez - Israel Perez On Behalf of: Mathew Weber, Salt River Project, 3, 1, 6, 5; Sarah Blankenship, Salt River Project, 3, 1, 6, 5;
Thomas Johnson, Salt River Project, 3, 1, 6, 5; Timothy Singh, Salt River Project, 3, 1, 6, 5; - Israel Perez
Answer

Document Name
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Comment
SRP does not support the addition or modification of this term to the standard. This new term defines IBR’s being introduced directly into
a standard which previously did not have IBR applicability. SRP strongly feels Inverter Based Resources should have separate standards. In
addition, 4.1 Facilities definition has redundant "that" in its description.
Likes

Dislikes

Response
Thank you for the comment, this comment will be passed along to the DT for consideration when drafting.
Srikanth Chennupati - Entergy - Entergy Services, Inc. - 1,3,5,6 - SERC
Answer

Document Name
Comment
None
Likes

Dislikes

Response
Thank you for the comment.
Andy Thomas - Duke Energy - 1,3,5,6 - SERC,RF
Answer

Document Name
Comment
The 60 kV voltage threshold value will limit the application of resources. Please consider reducing the voltage value to 40 kV.
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Additionally, the NERC Glossary of Terms “Bulk Electric System” definition I2A for synchronous machines uses the phrase: “a) Gross
individual nameplate rating ‘greater’ than 20 MVA”; suggest changing 20 MVA language to “4.1 Facilities: (1) BES Inverter-Based
Resources; and (2) Non-BES Inverter Based Resources (IBRs) that that either have or contribute to an aggregate nameplate capacity of
‘greater' than 20 MVA,” to consolidate language and reduce confusion with the implied 20 MVA value.
Likes

Dislikes

Response
Thank you for the feedback, the DT and NERC will take these into consideration.
Carver Powers - Utility Services, Inc. - 4
Answer

Document Name
Comment
Recommend that the proposed language for Section 4.1 Facilities, part 2 align with the pending GO/GOP NERC Glossary of Terms
revisions and the pending compliance registry definitions.
Likes

Dislikes

Response
Thank you for the comment, the comment will be passed along for consideration.
Megan Melham - Decatur Energy Center LLC - 5
Answer

Document Name
Comment
Capital Power supports the NAGF comments as below:
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

The NAGF recommends that the proposed language for Section 4.1 Facilities, part 2 align with the pending GO/GOP NERC Glossary of
Terms revisions.
Likes

Dislikes

Response
Thank you for the comment, this will be passed along to the DT be taken into consideration.
Marty Hostler - Northern California Power Agency - 4
Answer

Document Name
Comment
No. Should not say 60 KV. Industry, NERC, and FERC agreed a long time ago on 100 KV.
Likes

Dislikes

Response
Thank you for the comment, this will be passed along for consideration.
Wayne Sipperly - North American Generator Forum - 5 - MRO,WECC,Texas RE,NPCC,SERC,RF
Answer

Document Name
Comment
The NAGF recommends that the proposed language for Section 4.1 Facilities, part 2 align with the pending GO/GOP NERC Glossary of
Terms revisions.
Likes

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Dislikes

Response
Thank you for the comment and for the recommendation. This will be passed along for consideration.
Lauren Giordano - Lauren Giordano On Behalf of: Dennis Sismaet, Northern California Power Agency, 4, 6, 3, 5; Jeremy Lawson,
Northern California Power Agency, 4, 6, 3, 5; Marty Hostler, Northern California Power Agency, 4, 6, 3, 5; - Lauren Giordano
Answer

Document Name
Comment
Should not say 60 KV. Industry, NERC, and FERC agreed a long time ago on 100 KV.
Likes

Dislikes

Response
Thank you for the comment, this will be passed along for consideration.
Joshua Phillips - Southwest Power Pool, Inc. (RTO) - 2
Answer

Document Name
Comment
SPP has concern that the approach of each standard defining the applicable units may create conflicting issues amongst various
standards. This one-off concept (not being defined in the glossary of terms or Rules of Procedure RoP) could cause confusion and will not
have a solid reference outside of the actual language located in the standard. For example, if a standard is retired that uses this concept,
it could create a gap in the IBR process and may require the reopening of various standards.
Our concerns include the current BES definition properly aligning among this drafting team and drafting team efforts that are focused on
the Inverter-Based Resource (IBR). The current definition does not take into consideration the IBR characteristics and impacts.

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

With that said, SPP recommends that the drafting team ensure the definitions of what is included and excluded within the BES definitions
for proper alignment with other NERC standards in reference to the new technology and its impact on the reliability of the grid.
Likes

Dislikes

Response
Thank you for the comment, this will be passed along for consideration for the next ballot. The DT will consider the removal of the term,
"IBR UNIT" for next ballot
Tim Kelley - Tim Kelley On Behalf of: Charles Norton, Sacramento Municipal Utility District, 3, 6, 4, 1, 5; Foung Mua, Sacramento
Municipal Utility District, 3, 6, 4, 1, 5; Kevin Smith, Balancing Authority of Northern California, 1; Nicole Looney, Sacramento Municipal
Utility District, 3, 6, 4, 1, 5; Ryder Couch, Sacramento Municipal Utility District, 3, 6, 4, 1, 5; Wei Shao, Sacramento Municipal Utility
District, 3, 6, 4, 1, 5; - Tim Kelley, Group Name SMUD and BANC
Answer

Document Name
Comment
The format proposed by the Standard Drafting Team (SDT) is a good way to define applicability within each Standard, however, we feel
that the language proposed in NERC Standards Project 2021-04 Modifications to PRC-002 - Phase II, PRC-028-1 draft #2, is even
better. This language is formatted as follows:
“4.1. Functional Entities:
4.1.1. Generator Owner that owns equipment as identified in section 4.2 [emphasis added]
4.1.2. Generator Operator that operates equipment as identified in section 4.2 [emphasis added]
4.2. Facilities: The Elements associated with (1) BES Inverter-Based Resources; and (2) Non-BES Inverter-Based 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.”
Likes

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Dislikes

Response
Thank you for the comment, this will be passed along to the DT for consideration.
Ryan Quint - Elevate Energy Consulting - NA - Not Applicable - NA - Not Applicable, Group Name Elevate Energy Consulting
Answer

Yes

Dislikes

Response
Thank you for the support, and this comment will be passed along and taken into consideration.
Michael Johnson - Michael Johnson On Behalf of: Marco Rios, Pacific Gas and Electric Company, 3, 1, 5; Sandra Ellis, Pacific Gas and
Electric Company, 3, 1, 5; Tyler Brun, Pacific Gas and Electric Company, 3, 1, 5; - Michael Johnson, Group Name PG&E All Segments
Answer

Yes

Document Name
Comment
PG&E has no suggested revisions that could improve the readability of the Applicability except for making “Facility” 4.2 and not 4.1.
Likes

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Dislikes

Response
Thank you for the comments and support.
Donna Wood - Tri-State G and T Association, Inc. - 1
Answer

Yes

Document Name
Comment
Tri-State Generation and Transmission supports the comments of the MRO NSRF.
Likes

Dislikes

Response
Please see the response to MRO NSRF’s comment.
David Jendras Sr - Ameren - Ameren Services - 3
Answer

Yes

Document Name
Comment
Ameren would like an example of how they use IBR unit in a compliance definition, for example in PRC-029 for a plant where you have
mixed types of IBR units.
Likes

Dislikes

Response
Thank you for commenting, the use of IBR Unit was used in PRC-028. IBR Unit will not be balloted this additional ballot.
Dwanique Spiller - Berkshire Hathaway - NV Energy - 5
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Answer

Yes

Document Name
Comment
NV Energy agrees that the applicability section and/or actual requirements should define the scope of equipment included/excluded
whether it be a Category 1 GO/GOP or Category 2 GO/GOP, as Defined in the proposed NERC ROP.
Likes

Dislikes

Response
Thank you for the comment, the DT has made changes to better clarify applicability. This suggestion will be passed along for
consideration.
Mark Garza - FirstEnergy - FirstEnergy Corporation - 4, Group Name FE Voter
Answer

Yes

Document Name
Comment
No Comments.
Likes

Dislikes

Response
Thank you for the support.
Pirouz Honarmand - Pirouz Honarmand On Behalf of: Helen Lainis, Independent Electricity System Operator, 2; - Pirouz Honarmand
Answer

Yes

Document Name
Comment
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Likes

Dislikes

Response
Thank you for the support.
Mohamad Elhusseini - DTE Energy - Detroit Edison Company - 3,5
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the support.
Kristina Marriott - Miller Bros. Solar, LLC - 5 - MRO,WECC,Texas RE
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the support.
Teresa Krabe - Lower Colorado River Authority - 5
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the support.
Casey Perry - PNM Resources - 1,3 - WECC,Texas RE
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the support.
Dave Krueger - SERC Reliability Corporation - 10
Answer

Yes

Document Name
Comment
Likes
Dislikes

0
0

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Response
Thank you for the support.
Ruida Shu - Northeast Power Coordinating Council - 1,2,3,4,5,6,7,8,9,10 - NPCC, Group Name NPCC RSC
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the support.
Adrian Andreoiu - BC Hydro and Power Authority - 1, Group Name BC Hydro
Answer
Document Name
Comment
BC Hydro sees a potential conflict between IBR as defined here and the recent updates to the NERC Rules of Procedure to the Generator
Owner and Operator definitions.
In the current draft of the NERC Rules of Procedure – Appendix 2 Definitions used in the Rules of Procedure and Appendix 5B Statement
of Compliance Registry Criteria (Revision 8), the Category 2 Generator Owner entity is defined as “owns and maintains non-BES inverter
based generating resources (emphasis added) 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 GO)”.
BC Hydro appreciates the discussion at item #3 in the Technical Rationale. However, depending on the interpretation of “generating
resources”, owners of certain IBR types such as battery energy storage systems (BESS) or Electric Vehicles may not be registered as a GO
for these facilities. This would create a potential discrepancy between definitions which may create a gap in the intended scope of
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

applicability for MOD-026-2 and potentially other reliability standards, i.e., entities that would be included under the applicability section
of the standard wouldn’t be part of the MRS Program as they may not be registered if they don’t meet the GO definition.
Likes

Dislikes

Response
Thank you for the feedback, the DT and NERC will take these into consideration when updating definition, and TR.
Rachel Schuldt - Black Hills Corporation - 6, Group Name Black Hills Corporation - All Segments
Answer
Document Name
Comment
Black Hills Corporation recommends that the proposed language for “Section 4.1. Facilities” be updated to align with the pending GO &
GOP definition revisions in the NERC Rules of Procedure.
Likes

Dislikes

Response
Thank you for the support, the DT will take this into consideration.
Daniela Atanasovski - APS - Arizona Public Service Co. - 1
Answer
Document Name
Comment
None
Likes

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Dislikes

Response
Thank you for the comment.
Jennifer Bray - Arizona Electric Power Cooperative, Inc. - 1
Answer
Document Name
Comment
AEPC has signed on to ACES comments:
We recommend modifying Section 4.1 Functional Entities to specifically reference the new Category 1 GO/GOP and Category 2 GO/GOP
definitions.
Likes

Dislikes

Response
Thank you for the support, the DT will take this into consideration.
Anna Martinson - MRO - 1,2,3,4,5,6 - MRO, Group Name MRO Group
Answer
Document Name
Comment
MRO NSRF agrees that the applicability section and/or actual requirements should define the scope of equipment included/excluded
whether it be a Category 1 GO/GOP or Category 2 GO/GOP, as Defined in the proposed NERC ROP.
Likes
Dislikes

Lincoln Electric System, 5, Millard Brittany
0

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Response
Thank you for the comment, the DT will take this into consideration.
Christine Kane - WEC Energy Group, Inc. - 3, Group Name WEC Energy Group
Answer
Document Name
Comment
WEC Energy Group supports the comments of the MRO NSRF.
Likes

Dislikes

Response
Thank you for the comment, please refer to the response to MRO NSRF’s comment.
Dennis Chastain - Tennessee Valley Authority - 1,3,5,6 - SERC
Answer
Document Name
Comment
The IBR definition states that they have a common point of interconnection. As such, it doesn’t need to be stated again so 4.1 could
state:
4.1 Facilities: (1) BES Inverter-Based Resources; and (2) Non-BES Inverter Based Resources (IBRs) 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 at a voltage greater than or equal to 60 kV.
Likes

Dislikes

Response
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Thank you for the suggestion, the DT will take this back for consideration.
Colby Galloway - Southern Company - Southern Company Services, Inc. - 1,3,5,6 - SERC, Group Name Southern Company
Answer
Document Name
Comment

Likes

Dislikes

Response
Thank you for the comment.
Steven Rueckert - Western Electricity Coordinating Council - 10, Group Name WECC Entity Monitoring
Answer
Document Name
Comment
It appears that there was not a question above that can be answered Yes or NO, so WECC did not respond. However we do have the
folloing thoughts.
Note- ALL SDTs needs to be clear in the usage of proposed terms- In the example question, the phrases “IBR unit” and “applicable units”
are used. As esoteric as that is, the question clearly demonstrates that the current and future SDTs using the terms should do so carefully
and deliberately. Defined terms are critical and using additional descriptors (especially the same term) can lead to various
interpretations/thoughts by all entities. Is there any reason why “IBR” is not shown after item 1 phrase? Is there a distinction trying to be
made by use or non-use of the hyphen in IBR terms within item 1 and 2? The use of “connection” versus “interconnection”
Likes
Dislikes

0
0

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Response
Thank you for the comment, the team will review the usage of these terms for the future posting. Thank you for the comment and
insight, these comments will be passed along, and necessary changes will be considered and made.
Mark Gray - Edison Electric Institute - NA - Not Applicable - NA - Not Applicable
Answer
Document Name
Comment
EEI has no suggested modifications regarding the readability of the example applicability language.
Likes

Dislikes

Response
Thank you for the comment.
Charles Yeung - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC, Group Name SRC 2023
Answer
Document Name
Comment
Paragraph 2 in the posted technical rationale is clear enough without this example. At this point, adding an example may just cause more
confusion becuase the approach for expanding the registration to include these (currently non-BES) facilities has not been finalized. The
example may make sense if NERC continues with its current approach of expanding GO/GOP registration criteria, but if NERC were to
return to the originally proposed approach of creating new registration categories the specification of facilities in this example would be
redundant.
Likes
Dislikes

0
0

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Response
Thank you for the comment and clarifications for the next ballot.
Jodirah Green - ACES Power Marketing - 1,3,4,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name ACES Collaborators
Answer
Document Name
Comment
We recommend modifying Section 4.1 Functional Entities to specifically reference the new Category 1 GO/GOP and Category 2 GO/GOP
definitions.
Likes

Dislikes

Response
Thank you for the comment and insight, these comments will be passed along, and necessary changes will be considered and made.
Kennedy Meier - Electric Reliability Council of Texas, Inc. - 2
Answer
Document Name
Comment
ERCOT joins the comments submitted by the ISO/RTO Council (IRC) Standards Review Committee (SRC) for this response and adopts them
as its own.
Likes

Dislikes

Response
Thank you for the comment, please refer to the response to the IRC SRC’s comment.
Amy Wilke - American Transmission Company, LLC - 1
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Answer
Document Name
Comment
No comments.
Likes

Dislikes

Response
Thank you for the comment.

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

4. Provide any additional comments for the DT to consider, if desired.
Amy Wilke - American Transmission Company, LLC - 1
Answer
Document Name
Comment
The standard should operate as a stand-alone document. The standard should address the who, what, when, where and sometimes how
(not always). The Tech Rationale is only “why” a requirement is in the standard. References to the Tech Rationale can be misleading in
that it is not part of the standard.
Likes

Dislikes

Response
Thank you for the comment and this interpretation. The technical rationale was attempting to provide an explanation for the choices and
decision the DT made to lead to the balloted version.
Kennedy Meier - Electric Reliability Council of Texas, Inc. - 2
Answer
Document Name
Comment
ERCOT joins the comments submitted by the IRC SRC for this response and adopts them as its own.
Likes

Dislikes

Response
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Thank you for the comment, please see the response to IRC SRC comment.
Joshua Phillips - Southwest Power Pool, Inc. (RTO) - 2
Answer
Document Name
Comment
If determined that load should be included, SPP recommends the Standard Drafting Team consider concurrently undertaking the
necessary process to have the SAR(s) revised to allow for more broadly applicable Glossary of Terms definitions while continuing to
develop this definition.
Likes

Dislikes

Response
Thank you for the comment.
Jodirah Green - ACES Power Marketing - 1,3,4,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name ACES Collaborators
Answer
Document Name
Comment
Thank you for the opportunity to comment.
Likes

Dislikes

Response
Thank you for the comment.
Charles Yeung - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC, Group Name SRC 2023
Answer
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Document Name
Comment
1.
Line 89 in the Technical Rationale currently states: “Unit if they end up with their own definition).” The SRC recommends that line
89 be changed to: “Unit definitions:”
2.
The SRC does not believe Inclusion of the statement “IBRs include, but are not limited to, solar photovoltaic (PV), Type 3 and Type
4 wind, battery energy storage system (BESS), and fuel cell” in the IBR definition is necessary and therefore recommends that it be
deleted. If the SDT determines there is a benefit to keeping this list of examples, the SRC suggests that the list be changed to read: “IBRs
include, but are not limited to, solar photovoltaic (PV) Facilities, Type 3 and Type 4 wind Facilities, battery energy storage system (BESS)
Facilities, and fuel cell Facilities.” Listing only “solar photovoltaic (PV)” is somewhat ambiguous, as it could be understood refer to just the
PV panel or to an IBR Unit (which may or may not be an IBR according to the proposed definition).
Likes

Dislikes

Response
Thank you for the comments, and the first recommendation. To answer the second comment, thank you for the insight the DT has
adjusted the wording in the definition to better reflect the inclusive change.
Steven Rueckert - Western Electricity Coordinating Council - 10, Group Name WECC Entity Monitoring
Answer
Document Name
Comment
WECC appreciates the efforts of the SDT to ensure clarity in the definitions and use of the definitions moving forward to help ensure
reliable planning and operation of the BPS.
Likes

Dislikes

Response
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Thank you for support and the response.
Wayne Sipperly - North American Generator Forum - 5 - MRO,WECC,Texas RE,NPCC,SERC,RF
Answer
Document Name
Comment
The NAGF provides the following additional comments for consideration:
a. The NAGF is concerned with the use of the term “unit” in the proposed IBR Unit definition as it seems to conflict with the way industry
currently uses the term. Recommend that Drafting Team consider replacing with the term with “element” or “device” in the event the
Drafting Team continues to support the need for two definitions.
b.

The NAGF recommends that the proposed IBR Unit definition be revised as follows:

“An individual device or a grouping of multiple devices, that uses a power electronic interface, such as an inverter or converter, capable of
exporting Real Power from a primary energy source or energy storage system, and that connects at a single point on the collector system.”
c. Technical Rationale – the document currently references the terms “IBR”, “IBR Unit”, and “IBR plant/facility”. Recommend that the
document references align with the IBR Glossary of Terms definitions to eliminate possible confusion.
d.

The NAGF notes that there are two SARs that form the basis for this project:

Modifications to MOD-026 and MOD-027

ii.

Applicability revisions for transmission connected dynamic reactive resources

The scope of these SARs does not appear to provide the SDT with the latitude to modify the NERC Glossary of Terms for IBRs. The MOD026/027 SAR does not have the box checked for “Add, Modify or Retire a Glossary Term”. While the transmission connected dynamic
reactive resources SAR does have such box selected, it limits such changes to “also define new Glossary Terms for TCDRR or related terms”.
Therefore, the NAGF requests that the Drafting Team revisit the SARs accordingly to ensure that the Drafting Team is not overstepping
their intended scope.
Likes

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Dislikes

Response
Thank you for the comment, the DT has removed the IBR Unit in this posting. The two standards referenced are upcoming projects that
will be revised under milestone 3 under the FERC order, and the team is going to consider not overstepping going forward with IBR in
these standards.
Mark Garza - FirstEnergy - FirstEnergy Corporation - 4, Group Name FE Voter
Answer
Document Name
Comment
FirstEnergy requests as the drafting team moves forward with this endeavor that they ensure the applicability is maintained across all
standards that relate to this topic.
Likes

Dislikes

Response
Thank you for the support.
Dwanique Spiller - Berkshire Hathaway - NV Energy - 5
Answer
Document Name
Comment
Upon review of the SARs under which this Standard Drafting Team is operating, NV Energy is of the opinion that the creation of a new
glossary of terms definition such as “Inverter Based Resource” is not currently within scope for the Standard Drafting Team. NV Energy
would suggest that the Standard Drafting Team concurrently undertake the necessary process to have the SAR(s) revised to allow for the
creation of broadly applicable Glossary of Terms definitions, while also continuing to develop this definition to allow for further

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

improvements to the reliability of the Bulk Power System while adhering to the rules for standard development as prescribed by the
Standard Processes Manual.
Likes

Dislikes

Response
Thank you for the comment, the ask of the creation of the creation of an IBR definition was reaffirmed in scope for the DT, thank you for
the comment.
Ruida Shu - Northeast Power Coordinating Council - 1,2,3,4,5,6,7,8,9,10 - NPCC, Group Name NPCC RSC
Answer
Document Name
Comment
NPCC RSC supports the IBR and IBR unit definition.
Likes

Dislikes

Response
Thank you for the support.
Colby Galloway - Southern Company - Southern Company Services, Inc. - 1,3,5,6 - SERC, Group Name Southern Company
Answer
Document Name
Comment
First, there are concerns with the use of "Unit" in the IBR Unit definition due to the current and historical use of the term "Unit" with
respect to generating plants. Often, that term has been and is used to represent the entire facility, not specifically the AC power

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

producing component. Consider changing "IBR Unit" to "IBR Device" to resolve this concern and confusion. Note this possible confusion
even exists within the Comment item #3 above where the difference between Unit and unit is very significant.
Second, the SDT should consider the compatibility of the proposed IBR definition, as depicted in Figure 2.1 of the Technical Rational with
the existing BES definition, I4 inclusion. The definition does not include the collection system (below 75MVA) in the scope of the parts of
a facility.
Likes

Dislikes

Response
Thank you for the comment, the DT has taken this into consideration with the next round of posting of the IBR definition, the DT has
excluded IBR Unit language from the definition and did not repost IBR Unit for another ballot. Second comment, thank you for the
comment this will be passed along to the DT for consideration.
Marty Hostler - Northern California Power Agency - 4
Answer
Document Name
Comment
None.
Likes

Dislikes

Response
Thanks for the comment.
Megan Melham - Decatur Energy Center LLC - 5
Answer
Document Name
Comment
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Capital Power supports the NAGF comments as below:
The NAGF provides the following additional comments for consideration:
a. The NAGF is concerned with the use of the term “unit” in the proposed IBR Unit definition as it seems to conflict with the way industry
currently uses the term. Recommend that Drafting Team consider replacing with the term with “element” or “device” in the event the
Drafting Team continues to support the need for two definitions.
b. The NAGF recommends that the proposed IBR Unit definition be revised as follows:
“An individual device or a grouping of multiple devices, that uses a power electronic interface, such as an inverter or converter, capable of
exporting Real Power from a primary energy source or energy storage system, and that connects at a single point on the collector
system.”
c. Technical Rationale – the document currently references the terms “IBR”, “IBR Unit”, and “IBR plant/facility”. Recommend that the
document references align with the IBR Glossary of Terms definitions to eliminate possible confusion.
d. The NAGF notes that there are two SARs that form the basis for this project:
i. Modifications to MOD-026 and MOD-027
ii. Applicability revisions for transmission connected dynamic reactive resources
The scope of these SARs does not appear to provide the SDT with the latitude to modify the NERC Glossary of Terms for IBRs. The MOD026/027 SAR does not have the box checked for “Add, Modify or Retire a Glossary Term”. While the transmission connected dynamic
reactive resources SAR does have such box selected, it limits such changes to “also define new Glossary Terms for TCDRR or related
terms”. Therefore, the NAGF requests that the Drafting Team revisit the SARs accordingly to ensure that the Drafting Team is not
overstepping their intended scope.
Likes

Dislikes

Response
Please refer to the response to NAGF’s comment.
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Donna Wood - Tri-State G and T Association, Inc. - 1
Answer
Document Name
Comment
NA
Likes

Dislikes

Response
Thank you for the comment.
Dennis Chastain - Tennessee Valley Authority - 1,3,5,6 - SERC
Answer
Document Name
Comment
There is a need to ensure the IBR definition is sufficiently clear to determine if pumped storage facilities (particularly new variable speed
pumped storage technologies that act similar to IBRs) might be considered as an applicable generator, so that when applying standards
and requirements to these facilities, it is clear as to which applies. Does every plant need to be classified as a synchronous generator or an
IBR? If so, pumped storage facilities, for example, could be considered to act like bulk energy system synchronous machines due to
charging and discharging modes, while at the same time ride-thru capabilities may not seamlessly apply.
Likes

Dislikes

Response
Thank you for the suggestion, this will be passed along to the DT. The DT did decide when drafting to not include an exhaustive list of
types of IBRs.
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Christine Kane - WEC Energy Group, Inc. - 3, Group Name WEC Energy Group
Answer
Document Name
Comment
WEC Energy Group supports the comments of the MRO NSRF.
Likes

Dislikes

Response
Thank you for the response, please see the response to MRO NSRF's comment.
Andy Thomas - Duke Energy - 1,3,5,6 - SERC,RF
Answer
Document Name
Comment
None.
Likes

Dislikes

Response
Thank you for the support.
Srikanth Chennupati - Entergy - Entergy Services, Inc. - 1,3,5,6 - SERC
Answer
Document Name
Comment
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

none
Likes

Dislikes

Response
Thank you for the comment.
Anna Martinson - MRO - 1,2,3,4,5,6 - MRO, Group Name MRO Group
Answer
Document Name

Project 2020-06 MRO NSRF IBR Definition 20240403 Final.docx

Comment
Upon review of the SARs under which this Standard Drafting Team is operating, MRO NSRF is of the opinion that the creation of a new
glossary of terms definition such as “Inverter Based Resource” is not currently within scope for the Standard Drafting Team. MRO NSRF
would suggest that the Standard Drafting Team concurrently undertake the necessary process to have the SAR(s) revised to allow for the
creation of broadly applicable Glossary of Terms definitions, while also continuing to develop this definition to allow for further
improvements to the reliability of the Bulk Power System while adhering to the rules for standard development as prescribed by the
Standard Processes Manual.
See attachment!
Likes

Dislikes

Response
Thank you for the comment, the team is able to draft a definition under the scope of this project along with the newly added Milestone 3
SAR. To answer the second question, this suggestion will be passed along for consideration.
Israel Perez - Israel Perez On Behalf of: Mathew Weber, Salt River Project, 3, 1, 6, 5; Sarah Blankenship, Salt River Project, 3, 1, 6, 5;
Thomas Johnson, Salt River Project, 3, 1, 6, 5; Timothy Singh, Salt River Project, 3, 1, 6, 5; - Israel Perez
Answer
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

Document Name
Comment
SRP does not support the addition or modification of this term to the standard. This new term defines IBR’s being introduced directly into
a standard which previously did not have IBR applicability. SRP strongly feels Inverter Based Resources should have separate standards.
Likes

Dislikes

Response
Thank you for the comment, this will be passed along.
Jennifer Bray - Arizona Electric Power Cooperative, Inc. - 1
Answer
Document Name
Comment
Thank you for the opportunity to comment.
Likes

Dislikes

Response
Thank you for the support.
Daniela Atanasovski - APS - Arizona Public Service Co. - 1
Answer
Document Name
Comment

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

None
Likes

Dislikes

Response
Thank you for the support.
Rachel Schuldt - Black Hills Corporation - 6, Group Name Black Hills Corporation - All Segments
Answer
Document Name
Comment
Black Hills Corporation agrees with comments provided by NAGF, EEI and other industry peer groups.
Likes

Dislikes

Response
Thank you, please refer to the response to each of the respected group’s comments.
Michael Johnson - Michael Johnson On Behalf of: Marco Rios, Pacific Gas and Electric Company, 3, 1, 5; Sandra Ellis, Pacific Gas and
Electric Company, 3, 1, 5; Tyler Brun, Pacific Gas and Electric Company, 3, 1, 5; - Michael Johnson, Group Name PG&E All Segments
Answer
Document Name
Comment
PG&E has no further comments for the DT, but does wish to thank the DT for listening to the industry in making the current modifications
in a difficult and contentious process.
Likes

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

100

Dislikes

Response
Thank you for the support.
Teresa Krabe - Lower Colorado River Authority - 5
Answer
Document Name
Comment
None.
Likes

Dislikes

Response
Thank you for the support.
Kristina Marriott - Miller Bros. Solar, LLC - 5 - MRO,WECC,Texas RE
Answer
Document Name
Comment
Great Job, this is not an easy task!
Likes

Dislikes

Response
Thank you for the support.

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

101

End of Report

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 2 of IBR Definitions |July 12, 2024

102

Public

Reminder
Standards Announcement

Project 2020-06 Verifications of Models and Data for Generators
Inverter-based Resource Glossary Terms
Additional Ballots Open through April 8, 2024
Now Available

The additional ballots for Inverter-based Resource Glossary Terms are open through 8 p.m.
Eastern, Monday, April 8, 2024.
Reminder Regarding Corporate RBB Memberships

Members of the ballot pools associated with this project can log in and submit their votes by accessing
the Standards Balloting and Commenting System (SBS) here.
•

Contact NERC IT support directly at https://support.nerc.net/ (Monday – Friday, 8 a.m. - 5
p.m. Eastern) for problems regarding accessing the SBS due to a forgotten password,
incorrect credential error messages, or system lock-out.

•

Passwords expire every 6 months and must be reset.

•

The SBS is not supported for use on mobile devices.

•

Next Steps

The ballot results will be announced and posted on the project page. The drafting team will review all
responses received during the comment period and determine the next steps of the project.

Public

RELIABILITY | RESILIENCE | SECURITY

Public

North American Electric Reliability Corporation
3353 Peachtree Rd, NE
Suite 600, North Tower
Atlanta, GA 30326
404-446-2560 | www.nerc.com

Public

Standards Announcement | Project 2020-06 Ballot Open Reminder
Inverter-based Resource Glossary Terms | April 8, 2024

Standards Announcement

Project 2020-06 Verifications of Models and Data for Generators
Inverter-based Resource Glossary Terms
Formal Comment Period Open through April 8, 2024
Now Available

Under the NERC Rules of Procedure, each entity and its affiliates is collectively permitted one voting
membership per Registered Ballot Body Segment. Each entity that undergoes a change in corporate
structure (such as a merger or acquisition) that results in the entity or affiliated entities having more than
the one permitted representative in a particular Segment must withdraw the duplicate membership(s)
prior to joining new ballot pools or voting on anything as part of an existing ballot pool. Contact
[email protected] to assist with the removal of any duplicate registrations.
Commenting

Use the Standards Balloting and Commenting System (SBS) to submit comments. An unofficial Word
version of the comment form is posted on the project page.
•

Contact NERC IT support directly at https://support.nerc.net/ (Monday – Friday, 8 a.m. - 5
p.m. Eastern) for problems regarding accessing the SBS due to a forgotten password,
incorrect credential error messages, or system lock-out.

•

Passwords expire every 6 months and must be reset.

•

The SBS is not supported for use on mobile devices.

•

Next Steps

Additional ballots will be conducted March 29 – April 8, 2024.

RELIABILITY | RESILIENCE | SECURITY

For information on the Standards Development Process, refer to the Standard Processes Manual.
For more information or assistance, contact Senior Standards Developer, Chris Larson (via email) or at 404446-9708. Subscribe to this project's observer mailing list by selecting "NERC Email Distribution Lists" from
the "Service" drop-down menu and specify “Project 2020-06 Verifications of Models and Data for
Generators Observer List” in the Description Box.

North American Electric Reliability Corporation
3353 Peachtree Rd, NE
Suite 600, North Tower
Atlanta, GA 30326
404-446-2560 | www.nerc.com

Standards Announcement | Project 2020-06 Verification of Data and Models for Generators
Inverter-Based Resource Glossary Terms | February 2024

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BALLOT RESULTS
Comment: View Comment Results (/CommentResults/Index/316)
Ballot Name: 2020-06 Verifications of Models and Data for Generators Inverter-Based Resource (IBR) AB 2 DEF
Voting Start Date: 3/29/2024 12:01:00 AM
Voting End Date: 4/8/2024 8:00:00 PM
Ballot Type: DEF
Ballot Activity: AB
Ballot Series: 2
Total # Votes: 235
Total Ballot Pool: 282
Quorum: 83.33
Quorum Established Date: 4/8/2024 3:53:38 PM
Weighted Segment Value: 67.55
Ballot
Pool

Segment
Weight

Affirmative
Votes

Affirmative
Fraction

Negative Votes w/
Comment

Negative Fraction
w/ Comment

Negative Votes w/o
Comment

Abstain

No
Vote

Segment:
1

0.66

0.34

Segment:
2

0.7

0.6

0.1

Segment:
3

0.633

0.367

Segment:
4

0.6

0.4

Segment:
5

0.604

0.396

Segment:
6

0.559

0.441

Segment:
7

Segment:
8

Segment:
9

Segment:
10

0.6

Totals:

282

6.3

135

4.256

2.044

Segment

BALLOT POOL MEMBERS
Show

All

Segment

entries
Organization

1
AEP - AEP Service Corporation
© 2024 - NERC Ver 4.2.1.0 Machine Name: ATLVPEROWEB02

Search:
Voter
Dennis Sauriol

Designated Proxy

Ballot
Affirmative

NERC Memo
N/A

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Allete - Minnesota Power, Inc.

Hillary Creurer

Abstain

N/A

Ameren - Ameren Services

Tamara Evey

None

N/A

American Transmission Company, LLC

Amy Wilke

Affirmative

N/A

APS - Arizona Public Service Co.

Daniela Atanasovski

Affirmative

N/A

Arizona Electric Power Cooperative, Inc.

Jennifer Bray

Negative

Comments
Submitted

Arkansas Electric Cooperative Corporation

Emily Corley

Affirmative

N/A

Associated Electric Cooperative, Inc.

Mark Riley

Affirmative

N/A

Austin Energy

Thomas Standifur

Affirmative

N/A

Avista - Avista Corporation

Mike Magruder

Affirmative

N/A

Balancing Authority of Northern California

Kevin Smith

Affirmative

N/A

BC Hydro and Power Authority

Adrian Andreoiu

Affirmative

N/A

Berkshire Hathaway Energy - MidAmerican Energy
Co.

Terry Harbour

Affirmative

N/A

Black Hills Corporation

Micah Runner

Negative

Comments
Submitted

CenterPoint Energy Houston Electric, LLC

Daniela Hammons

Affirmative

N/A

City Utilities of Springfield, Missouri

Michael Bowman

Negative

Third-Party
Comments

Con Ed - Consolidated Edison Co. of New York

Dermot Smyth

Affirmative

N/A

Dairyland Power Cooperative

Karrie Schuldt

Negative

Third-Party
Comments

Dominion - Dominion Virginia Power

Elizabeth Weber

Negative

Comments
Submitted

Duke Energy

Katherine Street

Negative

Comments
Submitted

Edison International - Southern California Edison
Company

Robert Blackney

Affirmative

N/A

Entergy

Brian Lindsey

Negative

Comments
Submitted

Evergy

Kevin Frick

Affirmative

N/A

Eversource Energy

Joshua London

Affirmative

N/A

Exelon

Daniel Gacek

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Theresa Ciancio

Affirmative

N/A

Georgia Transmission Corporation

Greg Davis

Affirmative

N/A

Glencoe Light and Power Commission

Terry Volkmann

Negative

Third-Party
Comments

Hydro One Networks, Inc.

Emma Halilovic

Ijad Dewan

Abstain

N/A

Hydro-Quebec (HQ)

Nicolas Turcotte

Chantal Mazza

Affirmative

N/A

IDACORP - Idaho Power Company

Sean Steffensen

None

N/A

Imperial Irrigation District

Jesus Sammy Alcaraz

Denise Sanchez

Affirmative

N/A

Michael Moltane

Gail Elliott

Affirmative

N/A

1
International Transmission Company Holdings
© 2024 - NERC Ver 4.2.1.0
Machine Name: ATLVPEROWEB02
Corporation

Tim Kelley

Ellese Murphy

Alan Kloster

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

JEA

Joseph McClung

Affirmative

N/A

Lakeland Electric

Larry Watt

None

N/A

Lincoln Electric System

Josh Johnson

Negative

Comments
Submitted

Long Island Power Authority

Isidoro Behar

Abstain

N/A

Los Angeles Department of Water and Power

faranak sarbaz

Abstain

N/A

LS Power Transmission, LLC

Jennifer Richardson

Abstain

N/A

Manitoba Hydro

Nazra Gladu

Jay Sethi

None

N/A

Minnkota Power Cooperative Inc.

Theresa Allard

Nikki Carson-Marquis

Affirmative

N/A

Muscatine Power and Water

Andrew Kurriger

Negative

Third-Party
Comments

National Grid USA

Michael Jones

Affirmative

N/A

NB Power Corporation

Jeffrey Streifling

Abstain

N/A

Nebraska Public Power District

Jamison Cawley

Negative

Third-Party
Comments

NextEra Energy - Florida Power and Light Co.

Silvia Mitchell

Affirmative

N/A

NiSource - Northern Indiana Public Service Co.

Alison Nickells

Affirmative

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Terri Pyle

Negative

Third-Party
Comments

Omaha Public Power District

Doug Peterchuck

Negative

Third-Party
Comments

Oncor Electric Delivery

Byron Booker

Abstain

N/A

OTP - Otter Tail Power Company

Charles Wicklund

Negative

Third-Party
Comments

Pacific Gas and Electric Company

Marco Rios

Affirmative

N/A

Pedernales Electric Cooperative, Inc.

Bradley Collard

None

N/A

Platte River Power Authority

Marissa Archie

Abstain

N/A

PNM Resources - Public Service Company of New
Mexico

Lynn Goldstein

Affirmative

N/A

Portland General Electric Co.

Brooke Jockin

None

N/A

PPL Electric Utilities Corporation

Michelle McCartney
Longo

Affirmative

N/A

PSEG - Public Service Electric and Gas Co.

Karen Arnold

None

N/A

Public Utility District No. 1 of Chelan County

Diane E Landry

Affirmative

N/A

Public Utility District No. 1 of Snohomish County

Alyssia Rhoads

Affirmative

N/A

Sacramento Municipal Utility District

Wei Shao

Tim Kelley

Affirmative

N/A

Salt River Project

Sarah Blankenship

Israel Perez

Negative

Comments
Submitted

Santee Cooper

Chris Wagner

Abstain

N/A

SaskPower

Wayne Guttormson

None

N/A

Sempra - San Diego Gas and Electric

Mohamed Derbas

Affirmative

N/A

Tammy Porter

Michael Johnson

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Southern Company - Southern Company Services,
Inc.

Matt Carden

Affirmative

N/A

Sunflower Electric Power Corporation

Paul Mehlhaff

Negative

Third-Party
Comments

Tacoma Public Utilities (Tacoma, WA)

John Merrell

None

N/A

Tallahassee Electric (City of Tallahassee, FL)

Scott Langston

Abstain

N/A

Tennessee Valley Authority

David Plumb

Negative

Comments
Submitted

Tri-State G and T Association, Inc.

Donna Wood

Negative

Comments
Submitted

U.S. Bureau of Reclamation

Richard Jackson

None

N/A

Western Area Power Administration

Ben Hammer

None

N/A

Xcel Energy, Inc.

Eric Barry

Affirmative

N/A

California ISO

Darcy O'Connell

Affirmative

N/A

Electric Reliability Council of Texas, Inc.

Kennedy Meier

Affirmative

N/A

Independent Electricity System Operator

Helen Lainis

Affirmative

N/A

ISO New England, Inc.

John Pearson

Affirmative

N/A

Midcontinent ISO, Inc.

Bobbi Welch

Affirmative

N/A

New York Independent System Operator

Gregory Campoli

None

N/A

PJM Interconnection, L.L.C.

Thomas Foster

Affirmative

N/A

Southwest Power Pool, Inc. (RTO)

Joshua Phillips

Negative

Comments
Submitted

AEP

Leshel Hutchings

None

N/A

Ameren - Ameren Services

David Jendras Sr

Affirmative

N/A

APS - Arizona Public Service Co.

Jessica Lopez

Affirmative

N/A

Arkansas Electric Cooperative Corporation

Ayslynn Mcavoy

Affirmative

N/A

Avista - Avista Corporation

Robert Follini

Affirmative

N/A

BC Hydro and Power Authority

Ming Jiang

Affirmative

N/A

Berkshire Hathaway Energy - MidAmerican Energy
Co.

Joseph Amato

Affirmative

N/A

Black Hills Corporation

Josh Combs

Carly Miller

Negative

Comments
Submitted

Buckeye Power, Inc.

Tom Schmidt

Ryan Strom

None

N/A

CMS Energy - Consumers Energy Company

Karl Blaszkowski

Affirmative

N/A

Colorado Springs Utilities

Hillary Dobson

Affirmative

N/A

Con Ed - Consolidated Edison Co. of New York

Peter Yost

Affirmative

N/A

Dominion - Dominion Virginia Power

Bill Garvey

Negative

Comments
Submitted

DTE Energy - Detroit Edison Company

Marvin Johnson

Affirmative

N/A

Duke Energy - Florida Power Corporation

Marcelo Pesantez

Negative

Comments
Submitted

Jennie Wike

Pirouz Honarmand

Elizabeth Davis

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Edison International - Southern California Edison
Company

Romel Aquino

Affirmative

N/A

Entergy

James Keele

Negative

Comments
Submitted

Evergy

Marcus Moor

Affirmative

N/A

Eversource Energy

Vicki O'Leary

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Aaron Ghodooshim

Affirmative

N/A

Georgia System Operations Corporation

Scott McGough

Affirmative

N/A

Great River Energy

Michael Brytowski

Negative

Third-Party
Comments

Imperial Irrigation District

George Kirschner

Affirmative

N/A

JEA

Marilyn Williams

Affirmative

N/A

Lakeland Electric

Steven Marshall

Affirmative

N/A

Lincoln Electric System

Sam Christensen

Negative

Comments
Submitted

Los Angeles Department of Water and Power

Fausto Serratos

Abstain

N/A

Manitoba Hydro

Mike Smith

Negative

Comments
Submitted

MGE Energy - Madison Gas and Electric Co.

Benjamin Widder

None

N/A

Muscatine Power and Water

Seth Shoemaker

Negative

Third-Party
Comments

National Grid USA

Brian Shanahan

Affirmative

N/A

Nebraska Public Power District

Tony Eddleman

Negative

Third-Party
Comments

New York Power Authority

David Rivera

Negative

Third-Party
Comments

NextEra Energy - Florida Power and Light Co.

Karen Demos

Affirmative

N/A

NiSource - Northern Indiana Public Service Co.

Steven Taddeucci

Affirmative

N/A

North Carolina Electric Membership Corporation

Chris Dimisa

Scott Brame

Negative

Third-Party
Comments

Ocala Utility Services

Neville Bowen

LaKenya Vannorman

None

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Donald Hargrove

Negative

Third-Party
Comments

Old Dominion Electric Coop.

William Pezalla

None

N/A

Omaha Public Power District

David Heins

Negative

Third-Party
Comments

OTP - Otter Tail Power Company

Wendi Olson

Negative

Third-Party
Comments

Pacific Gas and Electric Company

Sandra Ellis

Affirmative

N/A

PNM Resources - Public Service Company of New
Mexico

Amy Wesselkamper

Affirmative

N/A

PPL - Louisville Gas and Electric Co.

James Frank

Affirmative

N/A

PSEG - Public Service Electric and Gas Co.

Christopher Murphy

None

N/A

Joyce Gundry

Affirmative

N/A

Alan Kloster

Denise Sanchez

Michael Johnson

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Sacramento Municipal Utility District

Nicole Looney

Tim Kelley

Affirmative

N/A

Salt River Project

Mathew Weber

Israel Perez

Negative

Comments
Submitted

Santee Cooper

Vicky Budreau

Abstain

N/A

Sempra - San Diego Gas and Electric

Bryan Bennett

Affirmative

N/A

Snohomish County PUD No. 1

Holly Chaney

Affirmative

N/A

Southern Company - Alabama Power Company

Joel Dembowski

Affirmative

N/A

Southern Indiana Gas and Electric Co.

Ryan Snyder

Affirmative

N/A

Tennessee Valley Authority

Ian Grant

Negative

Comments
Submitted

Tri-State G and T Association, Inc.

Ryan Walter

Negative

Comments
Submitted

WEC Energy Group, Inc.

Christine Kane

Negative

Comments
Submitted

Xcel Energy, Inc.

Nicholas Friebel

Affirmative

N/A

Alliant Energy Corporation Services, Inc.

Larry Heckert

Negative

Third-Party
Comments

Austin Energy

Tony Hua

Affirmative

N/A

Buckeye Power, Inc.

Jason Procuniar

None

N/A

CMS Energy - Consumers Energy Company

Aric Root

Affirmative

N/A

DTE Energy

Patricia Ireland

None

N/A

Electricities of North Carolina

Marcus Freeman

None

N/A

FirstEnergy - FirstEnergy Corporation

Mark Garza

Affirmative

N/A

Georgia System Operations Corporation

Katrina Lyons

Affirmative

N/A

Illinois Municipal Electric Agency

Mary Ann Todd

Abstain

N/A

North Carolina Electric Membership Corporation

Richard McCall

Negative

Third-Party
Comments

Northern California Power Agency

Marty Hostler

Negative

Comments
Submitted

Public Utility District No. 1 of Snohomish County

John D. Martinsen

Affirmative

N/A

Public Utility District No. 2 of Grant County,
Washington

Karla Weaver

None

N/A

Sacramento Municipal Utility District

Foung Mua

Tim Kelley

Affirmative

N/A

Tacoma Public Utilities (Tacoma, WA)

Hien Ho

Jennie Wike

None

N/A

Utility Services, Inc.

Carver Powers

Negative

Comments
Submitted

WEC Energy Group, Inc.

Matthew Beilfuss

None

N/A

AEP

Thomas Foltz

Affirmative

N/A

AES - AES Corporation

Ruchi Shah

Affirmative

N/A

Ameren - Ameren Missouri

Sam Dwyer

None

N/A

APS - Arizona Public Service Co.

Andrew Smith

Affirmative

N/A

Chuck Booth

Affirmative

N/A

Ryan Strom

Scott Brame

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Austin Energy

Michael Dillard

Affirmative

N/A

Avista - Avista Corporation

Glen Farmer

Affirmative

N/A

Basin Electric Power Cooperative

Amanda Wangler

None

N/A

BC Hydro and Power Authority

Quincy Wang

Affirmative

N/A

Berkshire Hathaway - NV Energy

Dwanique Spiller

Negative

Comments
Submitted

Black Hills Corporation

Sheila Suurmeier

Negative

Comments
Submitted

Bonneville Power Administration

Juergen Bermejo

Affirmative

N/A

Buckeye Power, Inc.

Kevin Zemanek

None

N/A

CMS Energy - Consumers Energy Company

David Greyerbiehl

Affirmative

N/A

Colorado Springs Utilities

Jeffrey Icke

Affirmative

N/A

Con Ed - Consolidated Edison Co. of New York

Helen Wang

Affirmative

N/A

Constellation

Alison MacKellar

Abstain

N/A

Dairyland Power Cooperative

Tommy Drea

Negative

Third-Party
Comments

Decatur Energy Center LLC

Megan Melham

Negative

Comments
Submitted

Duke Energy

Dale Goodwine

Negative

Comments
Submitted

Edison International - Southern California Edison
Company

Selene Willis

Affirmative

N/A

Enel Green Power

Natalie Johnson

None

N/A

Entergy - Entergy Services, Inc.

Gail Golden

Negative

Comments
Submitted

Evergy

Jeremy Harris

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Matthew Augustin

Affirmative

N/A

Great River Energy

Jacalynn Bentz

Negative

Third-Party
Comments

Greybeard Compliance Services, LLC

Mike Gabriel

Negative

Third-Party
Comments

Hydro-Quebec (HQ)

Junji Yamaguchi

Affirmative

N/A

Imperial Irrigation District

Tino Zaragoza

Affirmative

N/A

Invenergy LLC

Rhonda Jones

None

N/A

JEA

John Babik

Affirmative

N/A

Lincoln Electric System

Brittany Millard

Negative

Third-Party
Comments

Los Angeles Department of Water and Power

Glenn Barry

Abstain

N/A

Lower Colorado River Authority

Teresa Krabe

Affirmative

N/A

LS Power Development, LLC

C. A. Campbell

None

N/A

National Grid USA

Robin Berry

Affirmative

N/A

Fon Hiew

Affirmative

N/A

5
NB Power Corporation - New Brunswick Power
© 2024 - NERC Ver 4.2.1.0
Machine Name:
ATLVPEROWEB02
Transmission
Corporation

Carly Miller

Ryan Strom

Alan Kloster

Denise Sanchez

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Nebraska Public Power District

Ronald Bender

Negative

Third-Party
Comments

New York Power Authority

Zahid Qayyum

Negative

Third-Party
Comments

NextEra Energy

Richard Vendetti

Affirmative

N/A

NiSource - Northern Indiana Public Service Co.

Kathryn Tackett

Affirmative

N/A

North Carolina Electric Membership Corporation

Reid Cashion

Negative

Third-Party
Comments

Northern California Power Agency

Jeremy Lawson

Negative

Comments
Submitted

NRG - NRG Energy, Inc.

Patricia Lynch

Affirmative

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Patrick Wells

Negative

Third-Party
Comments

Omaha Public Power District

Kayleigh Wilkerson

Negative

Third-Party
Comments

Ontario Power Generation Inc.

Constantin Chitescu

None

N/A

OTP - Otter Tail Power Company

Stacy Wahlund

Negative

Third-Party
Comments

Pacific Gas and Electric Company

Tyler Brun

Affirmative

N/A

Pattern Operators LP

George E Brown

Negative

Third-Party
Comments

Platte River Power Authority

Jon Osell

Abstain

N/A

Portland General Electric Co.

Ryan Olson

None

N/A

PSEG Nuclear LLC

Tim Kucey

None

N/A

Public Utility District No. 1 of Chelan County

Rebecca Zahler

Affirmative

N/A

Public Utility District No. 1 of Snohomish County

Becky Burden

Affirmative

N/A

Public Utility District No. 2 of Grant County,
Washington

Nikkee Hebdon

Abstain

N/A

Sacramento Municipal Utility District

Ryder Couch

Tim Kelley

Affirmative

N/A

Salt River Project

Thomas Johnson

Israel Perez

Negative

Comments
Submitted

Santee Cooper

Don Cribb

Abstain

N/A

Seminole Electric Cooperative, Inc.

Melanie Wong

None

N/A

Sempra - San Diego Gas and Electric

Jennifer Wright

Affirmative

N/A

Southern Company - Southern Company
Generation

Leslie Burke

Affirmative

N/A

Southern Indiana Gas and Electric Co.

Larry Rogers

Affirmative

N/A

Tacoma Public Utilities (Tacoma, WA)

Ozan Ferrin

None

N/A

Talen Generation, LLC

Donald Lock

None

N/A

Tennessee Valley Authority

Darren Boehm

Negative

Comments
Submitted

TransAlta Corporation

Ashley Scheelar

None

N/A

Sergio Banuelos

Negative

Comments
Submitted

5
Tri-State G and T Association, Inc.
© 2024 - NERC Ver 4.2.1.0 Machine Name: ATLVPEROWEB02

Scott Brame

Michael Johnson

Jennie Wike

Segment

Organization

Voter

U.S. Bureau of Reclamation

Wendy Kalidass

Vistra Energy

Daniel Roethemeyer

WEC Energy Group, Inc.

Designated Proxy

Ballot

NERC Memo

None

N/A

Affirmative

N/A

Clarice Zellmer

Negative

Comments
Submitted

Xcel Energy, Inc.

Gerry Huitt

Affirmative

N/A

AEP

Mathew Miller

Affirmative

N/A

Ameren - Ameren Services

Robert Quinlivan

Affirmative

N/A

APS - Arizona Public Service Co.

Marcus Bortman

Affirmative

N/A

Arkansas Electric Cooperative Corporation

Bruce Walkup

Affirmative

N/A

Austin Energy

Imane Mrini

None

N/A

Black Hills Corporation

Rachel Schuldt

Negative

Comments
Submitted

Bonneville Power Administration

Tanner Brier

Affirmative

N/A

Cleco Corporation

Robert Hirchak

None

N/A

Con Ed - Consolidated Edison Co. of New York

Jason Chandler

Affirmative

N/A

Constellation

Kimberly Turco

Abstain

N/A

CPower

Aaron Breidenbaugh

None

N/A

Dominion - Dominion Resources, Inc.

Sean Bodkin

Negative

Comments
Submitted

Duke Energy

John Sturgeon

Negative

Comments
Submitted

Entergy

Julie Hall

Negative

Comments
Submitted

Evergy

Tiffany Lake

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Stacey Sheehan

Affirmative

N/A

Imperial Irrigation District

Diana Torres

Affirmative

N/A

Invenergy LLC

Colin Chilcoat

Affirmative

N/A

Lakeland Electric

Paul Shipps

Affirmative

N/A

Lincoln Electric System

Eric Ruskamp

Negative

Comments
Submitted

Los Angeles Department of Water and Power

Anton Vu

Abstain

N/A

Manitoba Hydro

Kelly Bertholet

Negative

Comments
Submitted

Muscatine Power and Water

Nicholas Burns

Negative

Third-Party
Comments

New York Power Authority

Shelly Dineen

Negative

Third-Party
Comments

NextEra Energy - Florida Power and Light Co.

Justin Welty

None

N/A

NiSource - Northern Indiana Public Service Co.

Dmitriy Bazylyuk

Affirmative

N/A

Northern California Power Agency

Dennis Sismaet

Negative

Comments
Submitted

Ashley F Stringer

Negative

Third-Party
Comments

6
OGE Energy - Oklahoma Gas and Electric Co.
© 2024 - NERC Ver 4.2.1.0 Machine Name: ATLVPEROWEB02

David Vickers

Alan Kloster

Denise Sanchez

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Omaha Public Power District

Shonda McCain

Negative

Third-Party
Comments

Platte River Power Authority

Sabrina Martz

None

N/A

Portland General Electric Co.

Stefanie Burke

None

N/A

Powerex Corporation

Raj Hundal

Affirmative

N/A

PPL - Louisville Gas and Electric Co.

Linn Oelker

Affirmative

N/A

PSEG - PSEG Energy Resources and Trade LLC

Laura Wu

None

N/A

Public Utility District No. 1 of Chelan County

Tamarra Hardie

Affirmative

N/A

Sacramento Municipal Utility District

Charles Norton

Tim Kelley

Affirmative

N/A

Salt River Project

Timothy Singh

Israel Perez

Negative

Comments
Submitted

Santee Cooper

Marty Watson

Abstain

N/A

Seminole Electric Cooperative, Inc.

Bret Galbraith

Abstain

N/A

Snohomish County PUD No. 1

John Liang

Affirmative

N/A

Southern Company - Southern Company
Generation

Ron Carlsen

Affirmative

N/A

Southern Indiana Gas and Electric Co.

Kati Barr

Affirmative

N/A

Tacoma Public Utilities (Tacoma, WA)

Terry Gifford

None

N/A

Tennessee Valley Authority

Armando Rodriguez

Negative

Comments
Submitted

WEC Energy Group, Inc.

David Boeshaar

Negative

Comments
Submitted

Western Area Power Administration

Jennifer Neville

Negative

Third-Party
Comments

Xcel Energy, Inc.

Steve Szablya

None

N/A

Midwest Reliability Organization

Mark Flanary

Affirmative

N/A

New York State Reliability Council

Wesley Yeomans

Affirmative

N/A

Northeast Power Coordinating Council

Gerry Dunbar

Abstain

N/A

ReliabilityFirst

Tyler Schwendiman

Affirmative

N/A

SERC Reliability Corporation

Dave Krueger

Affirmative

N/A

Texas Reliability Entity, Inc.

Rachel Coyne

Affirmative

N/A

Western Electricity Coordinating Council

Steven Rueckert

Affirmative

N/A

Jennie Wike

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Comment Forms

BALLOT RESULTS
Comment: View Comment Results (/CommentResults/Index/316)
Ballot Name: 2020-06 Verifications of Models and Data for Generators IBR Unit AB 2 DEF
Voting Start Date: 3/29/2024 12:01:00 AM
Voting End Date: 4/8/2024 8:00:00 PM
Ballot Type: DEF
Ballot Activity: AB
Ballot Series: 2
Total # Votes: 234
Total Ballot Pool: 281
Quorum: 83.27
Quorum Established Date: 4/8/2024 3:53:55 PM
Weighted Segment Value: 61.07
Ballot
Pool

Segment
Weight

Affirmative
Votes

Affirmative
Fraction

Negative Votes w/
Comment

Negative Fraction
w/ Comment

Negative Votes w/o
Comment

Abstain

No
Vote

Segment:
1

0.577

0.423

Segment:
2

0.7

0.6

0.1

Segment:
3

0.592

0.408

Segment:
4

0.5

Segment:
5

0.547

0.453

Segment:
6

0.471

0.529

Segment:
7

Segment:
8

Segment:
9

Segment:
10

0.5

Totals:

281

6.2

120

3.787

2.413

Segment

BALLOT POOL MEMBERS
Show

All

Segment

entries
Organization

1
AEP - AEP Service Corporation
© 2024 - NERC Ver 4.2.1.0 Machine Name: ATLVPEROWEB02

Search:
Voter
Dennis Sauriol

Designated Proxy

Ballot
Affirmative

NERC Memo
N/A

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Allete - Minnesota Power, Inc.

Hillary Creurer

Abstain

N/A

Ameren - Ameren Services

Tamara Evey

None

N/A

American Transmission Company, LLC

Amy Wilke

Negative

Comments
Submitted

APS - Arizona Public Service Co.

Daniela Atanasovski

Affirmative

N/A

Arizona Electric Power Cooperative, Inc.

Jennifer Bray

Negative

Comments
Submitted

Arkansas Electric Cooperative Corporation

Emily Corley

Affirmative

N/A

Associated Electric Cooperative, Inc.

Mark Riley

Affirmative

N/A

Austin Energy

Thomas Standifur

Affirmative

N/A

Avista - Avista Corporation

Mike Magruder

Affirmative

N/A

Balancing Authority of Northern California

Kevin Smith

Negative

Comments
Submitted

BC Hydro and Power Authority

Adrian Andreoiu

Negative

Comments
Submitted

Berkshire Hathaway Energy - MidAmerican Energy
Co.

Terry Harbour

Affirmative

N/A

Black Hills Corporation

Micah Runner

Negative

Comments
Submitted

CenterPoint Energy Houston Electric, LLC

Daniela Hammons

Abstain

N/A

City Utilities of Springfield, Missouri

Michael Bowman

Negative

Third-Party
Comments

Con Ed - Consolidated Edison Co. of New York

Dermot Smyth

Affirmative

N/A

Dairyland Power Cooperative

Karrie Schuldt

Negative

Third-Party
Comments

Dominion - Dominion Virginia Power

Elizabeth Weber

Negative

Comments
Submitted

Duke Energy

Katherine Street

Negative

Comments
Submitted

Edison International - Southern California Edison
Company

Robert Blackney

Affirmative

N/A

Entergy

Brian Lindsey

Negative

Comments
Submitted

Evergy

Kevin Frick

Affirmative

N/A

Eversource Energy

Joshua London

Affirmative

N/A

Exelon

Daniel Gacek

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Theresa Ciancio

Affirmative

N/A

Georgia Transmission Corporation

Greg Davis

Affirmative

N/A

Glencoe Light and Power Commission

Terry Volkmann

Negative

Third-Party
Comments

Hydro One Networks, Inc.

Emma Halilovic

Ijad Dewan

Abstain

N/A

Hydro-Quebec (HQ)

Nicolas Turcotte

Chantal Mazza

Affirmative

N/A

IDACORP - Idaho Power Company

Sean Steffensen

None

N/A

Affirmative

N/A

Jesus Sammy Alcaraz

Tim Kelley

Ellese Murphy

Alan Kloster

Denise Sanchez

Segment

Organization

Voter

International Transmission Company Holdings
Corporation

Michael Moltane

JEA

Designated Proxy

NERC Memo

Affirmative

N/A

Joseph McClung

Affirmative

N/A

Lakeland Electric

Larry Watt

None

N/A

Lincoln Electric System

Josh Johnson

Negative

Comments
Submitted

Long Island Power Authority

Isidoro Behar

Abstain

N/A

Los Angeles Department of Water and Power

faranak sarbaz

Abstain

N/A

LS Power Transmission, LLC

Jennifer Richardson

Abstain

N/A

Manitoba Hydro

Nazra Gladu

Jay Sethi

None

N/A

Minnkota Power Cooperative Inc.

Theresa Allard

Nikki Carson-Marquis

Affirmative

N/A

Muscatine Power and Water

Andrew Kurriger

Negative

Third-Party
Comments

National Grid USA

Michael Jones

Affirmative

N/A

NB Power Corporation

Jeffrey Streifling

Abstain

N/A

Nebraska Public Power District

Jamison Cawley

Negative

Third-Party
Comments

NextEra Energy - Florida Power and Light Co.

Silvia Mitchell

Affirmative

N/A

NiSource - Northern Indiana Public Service Co.

Alison Nickells

Affirmative

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Terri Pyle

Negative

Third-Party
Comments

Omaha Public Power District

Doug Peterchuck

Negative

Third-Party
Comments

Oncor Electric Delivery

Byron Booker

Abstain

N/A

OTP - Otter Tail Power Company

Charles Wicklund

Negative

Third-Party
Comments

Pacific Gas and Electric Company

Marco Rios

Affirmative

N/A

Pedernales Electric Cooperative, Inc.

Bradley Collard

None

N/A

Platte River Power Authority

Marissa Archie

Abstain

N/A

PNM Resources - Public Service Company of New
Mexico

Lynn Goldstein

Affirmative

N/A

Portland General Electric Co.

Brooke Jockin

None

N/A

PPL Electric Utilities Corporation

Michelle McCartney
Longo

Affirmative

N/A

PSEG - Public Service Electric and Gas Co.

Karen Arnold

None

N/A

Public Utility District No. 1 of Chelan County

Diane E Landry

Affirmative

N/A

Public Utility District No. 1 of Snohomish County

Alyssia Rhoads

Affirmative

N/A

Sacramento Municipal Utility District

Wei Shao

Tim Kelley

Negative

Comments
Submitted

Salt River Project

Sarah Blankenship

Israel Perez

Negative

Comments
Submitted

Santee Cooper

Chris Wagner

Abstain

N/A

Wayne Guttormson

None

N/A

Gail Elliott

Ballot

Tammy Porter

Michael Johnson

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Sempra - San Diego Gas and Electric

Mohamed Derbas

Affirmative

N/A

Southern Company - Southern Company Services,
Inc.

Matt Carden

Affirmative

N/A

Sunflower Electric Power Corporation

Paul Mehlhaff

Negative

Third-Party
Comments

Tacoma Public Utilities (Tacoma, WA)

John Merrell

None

N/A

Tallahassee Electric (City of Tallahassee, FL)

Scott Langston

Abstain

N/A

Tennessee Valley Authority

David Plumb

Negative

Comments
Submitted

Tri-State G and T Association, Inc.

Donna Wood

Negative

Comments
Submitted

U.S. Bureau of Reclamation

Richard Jackson

None

N/A

Western Area Power Administration

Ben Hammer

None

N/A

Xcel Energy, Inc.

Eric Barry

Affirmative

N/A

California ISO

Darcy O'Connell

Affirmative

N/A

Electric Reliability Council of Texas, Inc.

Kennedy Meier

Affirmative

N/A

Independent Electricity System Operator

Helen Lainis

Affirmative

N/A

ISO New England, Inc.

John Pearson

Affirmative

N/A

Midcontinent ISO, Inc.

Bobbi Welch

Affirmative

N/A

New York Independent System Operator

Gregory Campoli

None

N/A

PJM Interconnection, L.L.C.

Thomas Foster

Affirmative

N/A

Southwest Power Pool, Inc. (RTO)

Joshua Phillips

Negative

Comments
Submitted

AEP

Leshel Hutchings

None

N/A

Ameren - Ameren Services

David Jendras Sr

Affirmative

N/A

APS - Arizona Public Service Co.

Jessica Lopez

Affirmative

N/A

Arkansas Electric Cooperative Corporation

Ayslynn Mcavoy

Affirmative

N/A

Avista - Avista Corporation

Robert Follini

Affirmative

N/A

BC Hydro and Power Authority

Ming Jiang

Negative

Comments
Submitted

Berkshire Hathaway Energy - MidAmerican Energy
Co.

Joseph Amato

Affirmative

N/A

Black Hills Corporation

Josh Combs

Carly Miller

Negative

Comments
Submitted

Buckeye Power, Inc.

Tom Schmidt

Ryan Strom

None

N/A

CMS Energy - Consumers Energy Company

Karl Blaszkowski

Affirmative

N/A

Colorado Springs Utilities

Hillary Dobson

Affirmative

N/A

Con Ed - Consolidated Edison Co. of New York

Peter Yost

Affirmative

N/A

Dominion - Dominion Virginia Power

Bill Garvey

Negative

Comments
Submitted

DTE Energy - Detroit Edison Company

Marvin Johnson

Affirmative

N/A

Jennie Wike

Pirouz Honarmand

Elizabeth Davis

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Duke Energy - Florida Power Corporation

Marcelo Pesantez

Negative

Comments
Submitted

Edison International - Southern California Edison
Company

Romel Aquino

Affirmative

N/A

Entergy

James Keele

Negative

Comments
Submitted

Evergy

Marcus Moor

Affirmative

N/A

Eversource Energy

Vicki O'Leary

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Aaron Ghodooshim

Affirmative

N/A

Georgia System Operations Corporation

Scott McGough

Affirmative

N/A

Great River Energy

Michael Brytowski

Negative

Third-Party
Comments

Imperial Irrigation District

George Kirschner

Affirmative

N/A

JEA

Marilyn Williams

Affirmative

N/A

Lakeland Electric

Steven Marshall

Affirmative

N/A

Lincoln Electric System

Sam Christensen

Negative

Comments
Submitted

Los Angeles Department of Water and Power

Fausto Serratos

Abstain

N/A

Manitoba Hydro

Mike Smith

Negative

Comments
Submitted

MGE Energy - Madison Gas and Electric Co.

Benjamin Widder

None

N/A

Muscatine Power and Water

Seth Shoemaker

Negative

Third-Party
Comments

National Grid USA

Brian Shanahan

Affirmative

N/A

Nebraska Public Power District

Tony Eddleman

Negative

Third-Party
Comments

New York Power Authority

David Rivera

Affirmative

N/A

NextEra Energy - Florida Power and Light Co.

Karen Demos

Affirmative

N/A

NiSource - Northern Indiana Public Service Co.

Steven Taddeucci

Affirmative

N/A

North Carolina Electric Membership Corporation

Chris Dimisa

Scott Brame

Negative

Third-Party
Comments

Ocala Utility Services

Neville Bowen

LaKenya Vannorman

None

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Donald Hargrove

Negative

Third-Party
Comments

Old Dominion Electric Coop.

William Pezalla

None

N/A

Omaha Public Power District

David Heins

Negative

Third-Party
Comments

OTP - Otter Tail Power Company

Wendi Olson

Negative

Third-Party
Comments

Pacific Gas and Electric Company

Sandra Ellis

Affirmative

N/A

PNM Resources - Public Service Company of New
Mexico

Amy Wesselkamper

Affirmative

N/A

PPL - Louisville Gas and Electric Co.

James Frank

Affirmative

N/A

Christopher Murphy

None

N/A

Alan Kloster

Denise Sanchez

Michael Johnson

Segment

Organization

Voter

Public Utility District No. 1 of Chelan County

Joyce Gundry

Sacramento Municipal Utility District

Nicole Looney

Salt River Project

Mathew Weber

Santee Cooper

Designated Proxy

Ballot

NERC Memo

Affirmative

N/A

Tim Kelley

Negative

Comments
Submitted

Israel Perez

Negative

Comments
Submitted

Vicky Budreau

Abstain

N/A

Sempra - San Diego Gas and Electric

Bryan Bennett

Affirmative

N/A

Snohomish County PUD No. 1

Holly Chaney

Affirmative

N/A

Southern Company - Alabama Power Company

Joel Dembowski

Affirmative

N/A

Southern Indiana Gas and Electric Co.

Ryan Snyder

Negative

Comments
Submitted

Tennessee Valley Authority

Ian Grant

Negative

Comments
Submitted

Tri-State G and T Association, Inc.

Ryan Walter

Negative

Comments
Submitted

WEC Energy Group, Inc.

Christine Kane

Negative

Comments
Submitted

Xcel Energy, Inc.

Nicholas Friebel

Affirmative

N/A

Alliant Energy Corporation Services, Inc.

Larry Heckert

Negative

Third-Party
Comments

Austin Energy

Tony Hua

Affirmative

N/A

Buckeye Power, Inc.

Jason Procuniar

None

N/A

CMS Energy - Consumers Energy Company

Aric Root

Affirmative

N/A

DTE Energy

Patricia Ireland

None

N/A

Electricities of North Carolina

Marcus Freeman

None

N/A

FirstEnergy - FirstEnergy Corporation

Mark Garza

Affirmative

N/A

Georgia System Operations Corporation

Katrina Lyons

Affirmative

N/A

Illinois Municipal Electric Agency

Mary Ann Todd

Abstain

N/A

North Carolina Electric Membership Corporation

Richard McCall

Negative

Third-Party
Comments

Northern California Power Agency

Marty Hostler

Negative

Comments
Submitted

Public Utility District No. 1 of Snohomish County

John D. Martinsen

Affirmative

N/A

Public Utility District No. 2 of Grant County,
Washington

Karla Weaver

None

N/A

Sacramento Municipal Utility District

Foung Mua

Tim Kelley

Negative

Comments
Submitted

Tacoma Public Utilities (Tacoma, WA)

Hien Ho

Jennie Wike

None

N/A

Utility Services, Inc.

Carver Powers

Negative

Comments
Submitted

WEC Energy Group, Inc.

Matthew Beilfuss

None

N/A

AEP

Thomas Foltz

Affirmative

N/A

Ruchi Shah

Affirmative

N/A

5
AES - AES Corporation
© 2024 - NERC Ver 4.2.1.0 Machine Name: ATLVPEROWEB02

Ryan Strom

Scott Brame

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Ameren - Ameren Missouri

Sam Dwyer

None

N/A

APS - Arizona Public Service Co.

Andrew Smith

Affirmative

N/A

Associated Electric Cooperative, Inc.

Chuck Booth

Affirmative

N/A

Austin Energy

Michael Dillard

Affirmative

N/A

Avista - Avista Corporation

Glen Farmer

Affirmative

N/A

Basin Electric Power Cooperative

Amanda Wangler

None

N/A

BC Hydro and Power Authority

Quincy Wang

Negative

Comments
Submitted

Berkshire Hathaway - NV Energy

Dwanique Spiller

Negative

Comments
Submitted

Black Hills Corporation

Sheila Suurmeier

Negative

Comments
Submitted

Bonneville Power Administration

Juergen Bermejo

Affirmative

N/A

Buckeye Power, Inc.

Kevin Zemanek

None

N/A

CMS Energy - Consumers Energy Company

David Greyerbiehl

Affirmative

N/A

Colorado Springs Utilities

Jeffrey Icke

Affirmative

N/A

Con Ed - Consolidated Edison Co. of New York

Helen Wang

Affirmative

N/A

Constellation

Alison MacKellar

Abstain

N/A

Dairyland Power Cooperative

Tommy Drea

Negative

Third-Party
Comments

Decatur Energy Center LLC

Megan Melham

Negative

Comments
Submitted

Duke Energy

Dale Goodwine

Negative

Comments
Submitted

Edison International - Southern California Edison
Company

Selene Willis

Affirmative

N/A

Enel Green Power

Natalie Johnson

None

N/A

Entergy - Entergy Services, Inc.

Gail Golden

Negative

Comments
Submitted

Evergy

Jeremy Harris

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Matthew Augustin

Affirmative

N/A

Great River Energy

Jacalynn Bentz

Negative

Third-Party
Comments

Greybeard Compliance Services, LLC

Mike Gabriel

Negative

Third-Party
Comments

Hydro-Quebec (HQ)

Junji Yamaguchi

Affirmative

N/A

Imperial Irrigation District

Tino Zaragoza

Affirmative

N/A

Invenergy LLC

Rhonda Jones

None

N/A

JEA

John Babik

Affirmative

N/A

Lincoln Electric System

Brittany Millard

Negative

Third-Party
Comments

Los Angeles Department of Water and Power

Glenn Barry

Abstain

N/A

Teresa Krabe

Affirmative

N/A

Carly Miller

Ryan Strom

Alan Kloster

Denise Sanchez

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

LS Power Development, LLC

C. A. Campbell

None

N/A

National Grid USA

Robin Berry

Affirmative

N/A

NB Power Corporation - New Brunswick Power
Transmission Corporation

Fon Hiew

Affirmative

N/A

Nebraska Public Power District

Ronald Bender

Negative

Third-Party
Comments

New York Power Authority

Zahid Qayyum

Negative

Third-Party
Comments

NextEra Energy

Richard Vendetti

Affirmative

N/A

NiSource - Northern Indiana Public Service Co.

Kathryn Tackett

Affirmative

N/A

North Carolina Electric Membership Corporation

Reid Cashion

Negative

Third-Party
Comments

Northern California Power Agency

Jeremy Lawson

Negative

Comments
Submitted

NRG - NRG Energy, Inc.

Patricia Lynch

Affirmative

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Patrick Wells

Negative

Third-Party
Comments

Omaha Public Power District

Kayleigh Wilkerson

Negative

Third-Party
Comments

Ontario Power Generation Inc.

Constantin Chitescu

None

N/A

OTP - Otter Tail Power Company

Stacy Wahlund

Negative

Third-Party
Comments

Pacific Gas and Electric Company

Tyler Brun

Affirmative

N/A

Pattern Operators LP

George E Brown

Negative

Third-Party
Comments

Platte River Power Authority

Jon Osell

Abstain

N/A

Portland General Electric Co.

Ryan Olson

None

N/A

PSEG Nuclear LLC

Tim Kucey

None

N/A

Public Utility District No. 1 of Chelan County

Rebecca Zahler

Affirmative

N/A

Public Utility District No. 1 of Snohomish County

Becky Burden

Affirmative

N/A

Public Utility District No. 2 of Grant County,
Washington

Nikkee Hebdon

Abstain

N/A

Sacramento Municipal Utility District

Ryder Couch

Tim Kelley

Negative

Comments
Submitted

Salt River Project

Thomas Johnson

Israel Perez

Negative

Comments
Submitted

Santee Cooper

Don Cribb

Abstain

N/A

Seminole Electric Cooperative, Inc.

Melanie Wong

None

N/A

Sempra - San Diego Gas and Electric

Jennifer Wright

Affirmative

N/A

Southern Company - Southern Company
Generation

Leslie Burke

Affirmative

N/A

Southern Indiana Gas and Electric Co.

Larry Rogers

Negative

Comments
Submitted

None

N/A

5
Tacoma Public Utilities (Tacoma, WA)
© 2024 - NERC Ver 4.2.1.0 Machine Name: ATLVPEROWEB02

Ozan Ferrin

Scott Brame

Michael Johnson

Jennie Wike

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Talen Generation, LLC

Donald Lock

None

N/A

Tennessee Valley Authority

Darren Boehm

Negative

Comments
Submitted

TransAlta Corporation

Ashley Scheelar

None

N/A

Tri-State G and T Association, Inc.

Sergio Banuelos

Negative

Comments
Submitted

U.S. Bureau of Reclamation

Wendy Kalidass

None

N/A

Vistra Energy

Daniel Roethemeyer

Affirmative

N/A

WEC Energy Group, Inc.

Clarice Zellmer

Negative

Comments
Submitted

Xcel Energy, Inc.

Gerry Huitt

Affirmative

N/A

AEP

Mathew Miller

Affirmative

N/A

Ameren - Ameren Services

Robert Quinlivan

Affirmative

N/A

APS - Arizona Public Service Co.

Marcus Bortman

Affirmative

N/A

Arkansas Electric Cooperative Corporation

Bruce Walkup

Affirmative

N/A

Austin Energy

Imane Mrini

None

N/A

Black Hills Corporation

Rachel Schuldt

Negative

Comments
Submitted

Bonneville Power Administration

Tanner Brier

Affirmative

N/A

Cleco Corporation

Robert Hirchak

None

N/A

Con Ed - Consolidated Edison Co. of New York

Jason Chandler

Affirmative

N/A

Constellation

Kimberly Turco

Abstain

N/A

CPower

Aaron Breidenbaugh

None

N/A

Dominion - Dominion Resources, Inc.

Sean Bodkin

Negative

Comments
Submitted

Duke Energy

John Sturgeon

Negative

Comments
Submitted

Entergy

Julie Hall

Negative

Comments
Submitted

Evergy

Tiffany Lake

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Stacey Sheehan

Affirmative

N/A

Imperial Irrigation District

Diana Torres

Affirmative

N/A

Invenergy LLC

Colin Chilcoat

Affirmative

N/A

Lakeland Electric

Paul Shipps

Affirmative

N/A

Lincoln Electric System

Eric Ruskamp

Negative

Comments
Submitted

Los Angeles Department of Water and Power

Anton Vu

Abstain

N/A

Manitoba Hydro

Kelly Bertholet

Negative

Comments
Submitted

Muscatine Power and Water

Nicholas Burns

Negative

Third-Party
Comments

Shelly Dineen

Negative

Third-Party
Comments

6
New York Power Authority
© 2024 - NERC Ver 4.2.1.0 Machine Name: ATLVPEROWEB02

David Vickers

Alan Kloster

Denise Sanchez

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

NextEra Energy - Florida Power and Light Co.

Justin Welty

None

N/A

NiSource - Northern Indiana Public Service Co.

Dmitriy Bazylyuk

Affirmative

N/A

Northern California Power Agency

Dennis Sismaet

Negative

Comments
Submitted

OGE Energy - Oklahoma Gas and Electric Co.

Ashley F Stringer

Negative

Third-Party
Comments

Omaha Public Power District

Shonda McCain

Negative

Third-Party
Comments

Platte River Power Authority

Sabrina Martz

None

N/A

Portland General Electric Co.

Stefanie Burke

None

N/A

Powerex Corporation

Raj Hundal

Negative

Third-Party
Comments

PPL - Louisville Gas and Electric Co.

Linn Oelker

Affirmative

N/A

PSEG - PSEG Energy Resources and Trade LLC

Laura Wu

None

N/A

Public Utility District No. 1 of Chelan County

Tamarra Hardie

Affirmative

N/A

Sacramento Municipal Utility District

Charles Norton

Tim Kelley

Negative

Comments
Submitted

Salt River Project

Timothy Singh

Israel Perez

Negative

Comments
Submitted

Santee Cooper

Marty Watson

Abstain

N/A

Seminole Electric Cooperative, Inc.

Bret Galbraith

Abstain

N/A

Snohomish County PUD No. 1

John Liang

Affirmative

N/A

Southern Company - Southern Company
Generation

Ron Carlsen

Affirmative

N/A

Southern Indiana Gas and Electric Co.

Kati Barr

Negative

Comments
Submitted

Tacoma Public Utilities (Tacoma, WA)

Terry Gifford

None

N/A

Tennessee Valley Authority

Armando Rodriguez

Negative

Comments
Submitted

WEC Energy Group, Inc.

David Boeshaar

Negative

Comments
Submitted

Western Area Power Administration

Jennifer Neville

Negative

Third-Party
Comments

Xcel Energy, Inc.

Steve Szablya

None

N/A

Midwest Reliability Organization

Mark Flanary

Affirmative

N/A

Northeast Power Coordinating Council

Gerry Dunbar

Abstain

N/A

ReliabilityFirst

Tyler Schwendiman

Affirmative

N/A

SERC Reliability Corporation

Dave Krueger

Affirmative

N/A

Texas Reliability Entity, Inc.

Rachel Coyne

Affirmative

N/A

Western Electricity Coordinating Council

Steven Rueckert

Affirmative

N/A

Jennie Wike

Previous
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BALLOT RESULTS
Comment: View Comment Results (/CommentResults/Index/316)
Ballot Name: 2020-06 Verifications of Models and Data for Generators IBR-related Definitions | Implementation Plan AB 2 OT
Voting Start Date: 3/29/2024 12:01:00 AM
Voting End Date: 4/8/2024 8:00:00 PM
Ballot Type: OT
Ballot Activity: AB
Ballot Series: 2
Total # Votes: 233
Total Ballot Pool: 280
Quorum: 83.21
Quorum Established Date: 4/8/2024 3:54:06 PM
Weighted Segment Value: 70.04
Ballot
Pool

Segment
Weight

Affirmative
Votes

Affirmative
Fraction

Negative Votes w/
Comment

Negative Fraction
w/ Comment

Negative Votes w/o
Comment

Abstain

No
Vote

Segment:
1

0.706

0.294

Segment:
2

0.7

0.6

0.1

Segment:
3

0.688

0.313

Segment:
4

0.6

0.4

Segment:
5

0.673

0.327

Segment:
6

0.606

0.394

Segment:
7

Segment:
8

Segment:
9

Segment:
10

0.4

Totals:

280

6.1

140

4.273

1.827

Segment

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AEP - AEP Service Corporation
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Voter
Dennis Sauriol

Designated Proxy

Ballot
Affirmative

NERC Memo
N/A

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Allete - Minnesota Power, Inc.

Hillary Creurer

Abstain

N/A

Ameren - Ameren Services

Tamara Evey

None

N/A

American Transmission Company, LLC

Amy Wilke

Abstain

N/A

APS - Arizona Public Service Co.

Daniela Atanasovski

Affirmative

N/A

Arizona Electric Power Cooperative, Inc.

Jennifer Bray

Negative

Comments
Submitted

Arkansas Electric Cooperative Corporation

Emily Corley

Affirmative

N/A

Associated Electric Cooperative, Inc.

Mark Riley

Affirmative

N/A

Austin Energy

Thomas Standifur

Affirmative

N/A

Avista - Avista Corporation

Mike Magruder

Affirmative

N/A

Balancing Authority of Northern California

Kevin Smith

Affirmative

N/A

BC Hydro and Power Authority

Adrian Andreoiu

Abstain

N/A

Berkshire Hathaway Energy - MidAmerican Energy
Co.

Terry Harbour

Affirmative

N/A

Black Hills Corporation

Micah Runner

Negative

Comments
Submitted

CenterPoint Energy Houston Electric, LLC

Daniela Hammons

Affirmative

N/A

City Utilities of Springfield, Missouri

Michael Bowman

Negative

Third-Party
Comments

Con Ed - Consolidated Edison Co. of New York

Dermot Smyth

Affirmative

N/A

Dairyland Power Cooperative

Karrie Schuldt

Negative

Third-Party
Comments

Dominion - Dominion Virginia Power

Elizabeth Weber

Negative

Comments
Submitted

Duke Energy

Katherine Street

Negative

Comments
Submitted

Edison International - Southern California Edison
Company

Robert Blackney

Affirmative

N/A

Entergy

Brian Lindsey

Affirmative

N/A

Evergy

Kevin Frick

Affirmative

N/A

Eversource Energy

Joshua London

Affirmative

N/A

Exelon

Daniel Gacek

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Theresa Ciancio

Affirmative

N/A

Georgia Transmission Corporation

Greg Davis

Affirmative

N/A

Glencoe Light and Power Commission

Terry Volkmann

Negative

Third-Party
Comments

Hydro One Networks, Inc.

Emma Halilovic

Ijad Dewan

Abstain

N/A

Hydro-Quebec (HQ)

Nicolas Turcotte

Chantal Mazza

Affirmative

N/A

IDACORP - Idaho Power Company

Sean Steffensen

None

N/A

Imperial Irrigation District

Jesus Sammy Alcaraz

Denise Sanchez

Affirmative

N/A

Michael Moltane

Gail Elliott

Affirmative

N/A

International Transmission Company Holdings
Corporation
© 2024 - NERC Ver 4.2.1.0 Machine Name: ATLVPEROWEB02

Tim Kelley

Ellese Murphy

Alan Kloster

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

JEA

Joseph McClung

Affirmative

N/A

Lakeland Electric

Larry Watt

None

N/A

Lincoln Electric System

Josh Johnson

Negative

Comments
Submitted

Long Island Power Authority

Isidoro Behar

Abstain

N/A

Los Angeles Department of Water and Power

faranak sarbaz

Abstain

N/A

LS Power Transmission, LLC

Jennifer Richardson

Abstain

N/A

Manitoba Hydro

Nazra Gladu

Jay Sethi

None

N/A

Minnkota Power Cooperative Inc.

Theresa Allard

Nikki Carson-Marquis

Affirmative

N/A

Muscatine Power and Water

Andrew Kurriger

Negative

Third-Party
Comments

National Grid USA

Michael Jones

Affirmative

N/A

NB Power Corporation

Jeffrey Streifling

Abstain

N/A

Nebraska Public Power District

Jamison Cawley

Negative

Third-Party
Comments

NextEra Energy - Florida Power and Light Co.

Silvia Mitchell

Affirmative

N/A

NiSource - Northern Indiana Public Service Co.

Alison Nickells

Affirmative

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Terri Pyle

Negative

Third-Party
Comments

Omaha Public Power District

Doug Peterchuck

Negative

Third-Party
Comments

Oncor Electric Delivery

Byron Booker

Abstain

N/A

OTP - Otter Tail Power Company

Charles Wicklund

Negative

Third-Party
Comments

Pacific Gas and Electric Company

Marco Rios

Affirmative

N/A

Pedernales Electric Cooperative, Inc.

Bradley Collard

None

N/A

Platte River Power Authority

Marissa Archie

Abstain

N/A

PNM Resources - Public Service Company of New
Mexico

Lynn Goldstein

Affirmative

N/A

Portland General Electric Co.

Brooke Jockin

None

N/A

PPL Electric Utilities Corporation

Michelle McCartney
Longo

Affirmative

N/A

PSEG - Public Service Electric and Gas Co.

Karen Arnold

None

N/A

Public Utility District No. 1 of Chelan County

Diane E Landry

Affirmative

N/A

Public Utility District No. 1 of Snohomish County

Alyssia Rhoads

Affirmative

N/A

Sacramento Municipal Utility District

Wei Shao

Tim Kelley

Affirmative

N/A

Salt River Project

Sarah Blankenship

Israel Perez

Negative

Comments
Submitted

Santee Cooper

Chris Wagner

Abstain

N/A

SaskPower

Wayne Guttormson

None

N/A

Sempra - San Diego Gas and Electric

Mohamed Derbas

Affirmative

N/A

Tammy Porter

Michael Johnson

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Southern Company - Southern Company Services,
Inc.

Matt Carden

Affirmative

N/A

Sunflower Electric Power Corporation

Paul Mehlhaff

Negative

Third-Party
Comments

Tacoma Public Utilities (Tacoma, WA)

John Merrell

None

N/A

Tallahassee Electric (City of Tallahassee, FL)

Scott Langston

Abstain

N/A

Tennessee Valley Authority

David Plumb

Affirmative

N/A

Tri-State G and T Association, Inc.

Donna Wood

Affirmative

N/A

U.S. Bureau of Reclamation

Richard Jackson

None

N/A

Western Area Power Administration

Ben Hammer

None

N/A

Xcel Energy, Inc.

Eric Barry

Affirmative

N/A

California ISO

Darcy O'Connell

Affirmative

N/A

Electric Reliability Council of Texas, Inc.

Kennedy Meier

Affirmative

N/A

Independent Electricity System Operator

Helen Lainis

Affirmative

N/A

ISO New England, Inc.

John Pearson

Affirmative

N/A

Midcontinent ISO, Inc.

Bobbi Welch

Affirmative

N/A

New York Independent System Operator

Gregory Campoli

None

N/A

PJM Interconnection, L.L.C.

Thomas Foster

Affirmative

N/A

Southwest Power Pool, Inc. (RTO)

Joshua Phillips

Negative

Comments
Submitted

AEP

Leshel Hutchings

None

N/A

Ameren - Ameren Services

David Jendras Sr

Affirmative

N/A

APS - Arizona Public Service Co.

Jessica Lopez

Affirmative

N/A

Arkansas Electric Cooperative Corporation

Ayslynn Mcavoy

Affirmative

N/A

Avista - Avista Corporation

Robert Follini

Affirmative

N/A

BC Hydro and Power Authority

Ming Jiang

Abstain

N/A

Berkshire Hathaway Energy - MidAmerican Energy
Co.

Joseph Amato

Affirmative

N/A

Black Hills Corporation

Josh Combs

Carly Miller

Negative

Comments
Submitted

Buckeye Power, Inc.

Tom Schmidt

Ryan Strom

None

N/A

CMS Energy - Consumers Energy Company

Karl Blaszkowski

Affirmative

N/A

Colorado Springs Utilities

Hillary Dobson

Affirmative

N/A

Con Ed - Consolidated Edison Co. of New York

Peter Yost

Affirmative

N/A

Dominion - Dominion Virginia Power

Bill Garvey

Negative

Comments
Submitted

DTE Energy - Detroit Edison Company

Marvin Johnson

Affirmative

N/A

Duke Energy - Florida Power Corporation

Marcelo Pesantez

Negative

Comments
Submitted

Romel Aquino

Affirmative

N/A

Edison International - Southern California Edison
Company
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Jennie Wike

Pirouz Honarmand

Elizabeth Davis

Segment

Organization

Voter

Entergy

James Keele

Evergy

Marcus Moor

Eversource Energy

Designated Proxy

Ballot

NERC Memo

Affirmative

N/A

Affirmative

N/A

Vicki O'Leary

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Aaron Ghodooshim

Affirmative

N/A

Georgia System Operations Corporation

Scott McGough

Affirmative

N/A

Great River Energy

Michael Brytowski

Negative

Third-Party
Comments

Imperial Irrigation District

George Kirschner

Affirmative

N/A

JEA

Marilyn Williams

Affirmative

N/A

Lakeland Electric

Steven Marshall

Affirmative

N/A

Lincoln Electric System

Sam Christensen

Negative

Comments
Submitted

Los Angeles Department of Water and Power

Fausto Serratos

None

N/A

Manitoba Hydro

Mike Smith

Negative

Comments
Submitted

MGE Energy - Madison Gas and Electric Co.

Benjamin Widder

None

N/A

Muscatine Power and Water

Seth Shoemaker

Negative

Third-Party
Comments

National Grid USA

Brian Shanahan

Affirmative

N/A

Nebraska Public Power District

Tony Eddleman

Negative

Third-Party
Comments

New York Power Authority

David Rivera

Negative

Third-Party
Comments

NextEra Energy - Florida Power and Light Co.

Karen Demos

Affirmative

N/A

NiSource - Northern Indiana Public Service Co.

Steven Taddeucci

Affirmative

N/A

North Carolina Electric Membership Corporation

Chris Dimisa

Scott Brame

Negative

Third-Party
Comments

Ocala Utility Services

Neville Bowen

LaKenya Vannorman

None

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Donald Hargrove

Negative

Third-Party
Comments

Old Dominion Electric Coop.

William Pezalla

None

N/A

Omaha Public Power District

David Heins

Negative

Third-Party
Comments

OTP - Otter Tail Power Company

Wendi Olson

Negative

Third-Party
Comments

Pacific Gas and Electric Company

Sandra Ellis

Affirmative

N/A

PNM Resources - Public Service Company of New
Mexico

Amy Wesselkamper

Affirmative

N/A

PPL - Louisville Gas and Electric Co.

James Frank

Affirmative

N/A

PSEG - Public Service Electric and Gas Co.

Christopher Murphy

None

N/A

Public Utility District No. 1 of Chelan County

Joyce Gundry

Affirmative

N/A

Sacramento Municipal Utility District

Nicole Looney

Affirmative

N/A

Alan Kloster

Denise Sanchez

Michael Johnson

Tim Kelley

Segment

Organization

Voter

Salt River Project

Mathew Weber

Santee Cooper

Designated Proxy

NERC Memo

Negative

Comments
Submitted

Vicky Budreau

Abstain

N/A

Sempra - San Diego Gas and Electric

Bryan Bennett

Affirmative

N/A

Snohomish County PUD No. 1

Holly Chaney

Affirmative

N/A

Southern Company - Alabama Power Company

Joel Dembowski

Affirmative

N/A

Southern Indiana Gas and Electric Co.

Ryan Snyder

Affirmative

N/A

Tennessee Valley Authority

Ian Grant

Affirmative

N/A

Tri-State G and T Association, Inc.

Ryan Walter

Affirmative

N/A

WEC Energy Group, Inc.

Christine Kane

Negative

Comments
Submitted

Xcel Energy, Inc.

Nicholas Friebel

Affirmative

N/A

Alliant Energy Corporation Services, Inc.

Larry Heckert

Negative

Third-Party
Comments

Austin Energy

Tony Hua

Affirmative

N/A

Buckeye Power, Inc.

Jason Procuniar

None

N/A

CMS Energy - Consumers Energy Company

Aric Root

Affirmative

N/A

DTE Energy

Patricia Ireland

None

N/A

Electricities of North Carolina

Marcus Freeman

None

N/A

FirstEnergy - FirstEnergy Corporation

Mark Garza

Affirmative

N/A

Georgia System Operations Corporation

Katrina Lyons

Affirmative

N/A

Illinois Municipal Electric Agency

Mary Ann Todd

Abstain

N/A

North Carolina Electric Membership Corporation

Richard McCall

Negative

Third-Party
Comments

Northern California Power Agency

Marty Hostler

Negative

Comments
Submitted

Public Utility District No. 1 of Snohomish County

John D. Martinsen

Affirmative

N/A

Public Utility District No. 2 of Grant County,
Washington

Karla Weaver

None

N/A

Sacramento Municipal Utility District

Foung Mua

Tim Kelley

Affirmative

N/A

Tacoma Public Utilities (Tacoma, WA)

Hien Ho

Jennie Wike

None

N/A

Utility Services, Inc.

Carver Powers

Negative

Comments
Submitted

WEC Energy Group, Inc.

Matthew Beilfuss

None

N/A

AEP

Thomas Foltz

Affirmative

N/A

AES - AES Corporation

Ruchi Shah

Affirmative

N/A

Ameren - Ameren Missouri

Sam Dwyer

None

N/A

APS - Arizona Public Service Co.

Andrew Smith

Affirmative

N/A

Associated Electric Cooperative, Inc.

Chuck Booth

Affirmative

N/A

Austin Energy

Michael Dillard

Affirmative

N/A

Glen Farmer

Affirmative

N/A

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Avista
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Corporation
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Machine
ATLVPEROWEB02

Israel Perez

Ballot

Ryan Strom

Scott Brame

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Basin Electric Power Cooperative

Amanda Wangler

None

N/A

BC Hydro and Power Authority

Quincy Wang

Abstain

N/A

Berkshire Hathaway - NV Energy

Dwanique Spiller

Negative

Comments
Submitted

Black Hills Corporation

Sheila Suurmeier

Negative

Comments
Submitted

Bonneville Power Administration

Juergen Bermejo

Affirmative

N/A

Buckeye Power, Inc.

Kevin Zemanek

None

N/A

CMS Energy - Consumers Energy Company

David Greyerbiehl

Affirmative

N/A

Colorado Springs Utilities

Jeffrey Icke

Affirmative

N/A

Con Ed - Consolidated Edison Co. of New York

Helen Wang

Affirmative

N/A

Constellation

Alison MacKellar

Abstain

N/A

Dairyland Power Cooperative

Tommy Drea

Negative

Third-Party
Comments

Decatur Energy Center LLC

Megan Melham

Affirmative

N/A

Duke Energy

Dale Goodwine

Negative

Comments
Submitted

Edison International - Southern California Edison
Company

Selene Willis

Affirmative

N/A

Enel Green Power

Natalie Johnson

None

N/A

Entergy - Entergy Services, Inc.

Gail Golden

Affirmative

N/A

Evergy

Jeremy Harris

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Matthew Augustin

Affirmative

N/A

Great River Energy

Jacalynn Bentz

Negative

Third-Party
Comments

Greybeard Compliance Services, LLC

Mike Gabriel

Negative

Third-Party
Comments

Hydro-Quebec (HQ)

Junji Yamaguchi

Affirmative

N/A

Imperial Irrigation District

Tino Zaragoza

Affirmative

N/A

Invenergy LLC

Rhonda Jones

None

N/A

JEA

John Babik

Affirmative

N/A

Lincoln Electric System

Brittany Millard

Negative

Third-Party
Comments

Los Angeles Department of Water and Power

Glenn Barry

Abstain

N/A

Lower Colorado River Authority

Teresa Krabe

Affirmative

N/A

LS Power Development, LLC

C. A. Campbell

None

N/A

National Grid USA

Robin Berry

Affirmative

N/A

NB Power Corporation - New Brunswick Power
Transmission Corporation

Fon Hiew

Affirmative

N/A

Nebraska Public Power District

Ronald Bender

Negative

Third-Party
Comments

Zahid Qayyum

Negative

Third-Party
Comments

5
New York Power Authority
© 2024 - NERC Ver 4.2.1.0 Machine Name: ATLVPEROWEB02

Carly Miller

Ryan Strom

Alan Kloster

Denise Sanchez

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

NextEra Energy

Richard Vendetti

Affirmative

N/A

NiSource - Northern Indiana Public Service Co.

Kathryn Tackett

Affirmative

N/A

North Carolina Electric Membership Corporation

Reid Cashion

Negative

Third-Party
Comments

Northern California Power Agency

Jeremy Lawson

Negative

Comments
Submitted

NRG - NRG Energy, Inc.

Patricia Lynch

Affirmative

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Patrick Wells

Negative

Third-Party
Comments

Omaha Public Power District

Kayleigh Wilkerson

Negative

Third-Party
Comments

Ontario Power Generation Inc.

Constantin Chitescu

None

N/A

OTP - Otter Tail Power Company

Stacy Wahlund

Negative

Third-Party
Comments

Pacific Gas and Electric Company

Tyler Brun

Affirmative

N/A

Pattern Operators LP

George E Brown

Negative

Third-Party
Comments

Platte River Power Authority

Jon Osell

Abstain

N/A

Portland General Electric Co.

Ryan Olson

None

N/A

PSEG Nuclear LLC

Tim Kucey

None

N/A

Public Utility District No. 1 of Chelan County

Rebecca Zahler

Affirmative

N/A

Public Utility District No. 1 of Snohomish County

Becky Burden

Affirmative

N/A

Public Utility District No. 2 of Grant County,
Washington

Nikkee Hebdon

Abstain

N/A

Sacramento Municipal Utility District

Ryder Couch

Tim Kelley

Affirmative

N/A

Salt River Project

Thomas Johnson

Israel Perez

Negative

Comments
Submitted

Santee Cooper

Don Cribb

Abstain

N/A

Seminole Electric Cooperative, Inc.

Melanie Wong

None

N/A

Sempra - San Diego Gas and Electric

Jennifer Wright

Affirmative

N/A

Southern Company - Southern Company
Generation

Leslie Burke

Affirmative

N/A

Southern Indiana Gas and Electric Co.

Larry Rogers

Affirmative

N/A

Tacoma Public Utilities (Tacoma, WA)

Ozan Ferrin

None

N/A

Talen Generation, LLC

Donald Lock

None

N/A

Tennessee Valley Authority

Darren Boehm

Affirmative

N/A

TransAlta Corporation

Ashley Scheelar

None

N/A

Tri-State G and T Association, Inc.

Sergio Banuelos

Affirmative

N/A

U.S. Bureau of Reclamation

Wendy Kalidass

None

N/A

Vistra Energy

Daniel Roethemeyer

Affirmative

N/A

WEC Energy Group, Inc.

Clarice Zellmer

Negative

Comments
Submitted

Scott Brame

Michael Johnson

Jennie Wike

David Vickers

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Xcel Energy, Inc.

Gerry Huitt

Affirmative

N/A

AEP

Mathew Miller

Affirmative

N/A

Ameren - Ameren Services

Robert Quinlivan

Affirmative

N/A

APS - Arizona Public Service Co.

Marcus Bortman

Affirmative

N/A

Arkansas Electric Cooperative Corporation

Bruce Walkup

Affirmative

N/A

Austin Energy

Imane Mrini

None

N/A

Black Hills Corporation

Rachel Schuldt

Negative

Comments
Submitted

Bonneville Power Administration

Tanner Brier

Affirmative

N/A

Con Ed - Consolidated Edison Co. of New York

Jason Chandler

Affirmative

N/A

Constellation

Kimberly Turco

Abstain

N/A

CPower

Aaron Breidenbaugh

None

N/A

Dominion - Dominion Resources, Inc.

Sean Bodkin

Negative

Comments
Submitted

Duke Energy

John Sturgeon

Negative

Comments
Submitted

Entergy

Julie Hall

Affirmative

N/A

Evergy

Tiffany Lake

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Stacey Sheehan

Affirmative

N/A

Imperial Irrigation District

Diana Torres

Affirmative

N/A

Invenergy LLC

Colin Chilcoat

Affirmative

N/A

Lakeland Electric

Paul Shipps

Affirmative

N/A

Lincoln Electric System

Eric Ruskamp

Negative

Comments
Submitted

Los Angeles Department of Water and Power

Anton Vu

Abstain

N/A

Manitoba Hydro

Kelly Bertholet

Negative

Comments
Submitted

Muscatine Power and Water

Nicholas Burns

Negative

Third-Party
Comments

New York Power Authority

Shelly Dineen

Negative

Third-Party
Comments

NextEra Energy - Florida Power and Light Co.

Justin Welty

None

N/A

NiSource - Northern Indiana Public Service Co.

Dmitriy Bazylyuk

Affirmative

N/A

Northern California Power Agency

Dennis Sismaet

Negative

Comments
Submitted

OGE Energy - Oklahoma Gas and Electric Co.

Ashley F Stringer

Negative

Third-Party
Comments

Omaha Public Power District

Shonda McCain

Negative

Third-Party
Comments

Platte River Power Authority

Sabrina Martz

None

N/A

Portland General Electric Co.

Stefanie Burke

None

N/A

Raj Hundal

Abstain

N/A

6
Powerex Corporation
© 2024 - NERC Ver 4.2.1.0 Machine Name: ATLVPEROWEB02

Alan Kloster

Denise Sanchez

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

PPL - Louisville Gas and Electric Co.

Linn Oelker

Affirmative

N/A

PSEG - PSEG Energy Resources and Trade LLC

Laura Wu

None

N/A

Public Utility District No. 1 of Chelan County

Tamarra Hardie

Affirmative

N/A

Sacramento Municipal Utility District

Charles Norton

Tim Kelley

Affirmative

N/A

Salt River Project

Timothy Singh

Israel Perez

Negative

Comments
Submitted

Santee Cooper

Marty Watson

Abstain

N/A

Seminole Electric Cooperative, Inc.

Bret Galbraith

Abstain

N/A

Snohomish County PUD No. 1

John Liang

Affirmative

N/A

Southern Company - Southern Company
Generation

Ron Carlsen

Affirmative

N/A

Southern Indiana Gas and Electric Co.

Kati Barr

Affirmative

N/A

Tacoma Public Utilities (Tacoma, WA)

Terry Gifford

None

N/A

Tennessee Valley Authority

Armando Rodriguez

Affirmative

N/A

WEC Energy Group, Inc.

David Boeshaar

Negative

Comments
Submitted

Western Area Power Administration

Jennifer Neville

Negative

Third-Party
Comments

Xcel Energy, Inc.

Steve Szablya

None

N/A

Midwest Reliability Organization

Mark Flanary

Affirmative

N/A

Northeast Power Coordinating Council

Gerry Dunbar

Abstain

N/A

ReliabilityFirst

Tyler Schwendiman

Affirmative

N/A

SERC Reliability Corporation

Dave Krueger

Affirmative

N/A

Texas Reliability Entity, Inc.

Rachel Coyne

Affirmative

N/A

Western Electricity Coordinating Council

Steven Rueckert

Abstain

N/A

Jennie Wike

Previous
Showing 1 to 280 of 280 entries

Do not use this form for submitting nominations

Unofficial Nomination Form

Project 2020-06 Verification of Models and Data for Generators
Drafting Team
Submitting Nominations

Do not use this form for submitting nominations. Use the electronic form to submit nominations for
supplemental drafting team members by 8:00 p.m. Eastern, Wednesday, June 26, 2024. This unofficial
version is provided to assist nominees in compiling the information necessary to submit the electronic
form.

General Information

Additional information is available on the project page. If you have questions, contact Manager of
Standards Development, Jamie Calderon (via email), or at 404-960-0568.
By submitting a nomination form, you are indicating your willingness and agreement to actively participate
in face-to-face meetings and conference calls. Previous drafting or quality review team experience is
beneficial, but not required.

Project Information
Project Purpose

FERC Order No. 901 – Milestone 3, Part 2: IBR Model Validation SAR addresses regulatory directives from
NERC Standards Development Work Plan to respond to FERC Order No. 901. This SAR is intended to
establish new or revised Reliability Standards to address FERC Order No. 901 directives related to modeling
validation (and verification) activities by utilizing actual performance data, including performance of IBR
performance during a disturbance. This will help ensure the facility’s model(s) reflect(s) the in-service
equipment throughout the lifecycle of the IBR facility. NERC must file the Reliability Standards or
definitions developed under Milestone 3 by November 4, 2025.
As this SAR includes anticipated revisions to model validation for IBR, NERC recommends it be assigned to
Project 2020-06 Verifications of Models and Data for Generators. The drafting team will need to prioritize
changes for this SAR over currently assigned SARs to remove IBR from MOD-026 and MOD-027 as this
holistic approach includes some form of ongoing quality review and corrections based on new
performance-based validation. This is necessary to prevent duplicative model validation requirements that
do not align with the performance-based objectives of the regulatory directives. A second phase proposed
by this SAR to incorporate the uniform model framework revisions into FAC-002 to assure a consistent
holistic approach for model data sharing is established throughout the lifespan of IBR. As regulatory
directives included within this SAR must be addressed in revisions to Reliability Standards that must be
filed with FERC by November, 2025, NERC also recommends that this project remain prioritized as a High
Priority project. No waivers to the Standard Processes Manual are being requested at this time.

RELIABILITY | RESILIENCE | SECURITY

At the July 21, 2021 meeting, the Standards Committee accepted the original SAR assigned to Project
2020-06 Verifications of Models and Data for Generators. The drafting team has only proposed revisions
to MOD-026 at this time. The initial draft was posted May 20, 2022 through July 6, 2022. An additional
draft was posted November 21, 2022 through January 18, 2023. Another additional draft was posted June
7, 2023 through July 21, 2023. The drafting team has also posted new definitions for IBRs to assure
alignment between other 901-related projects. The drafting team will post one more draft of revisions
before being assigned this SAR and moving forward with revisions.
This project has been identified as higher priority at this time. This project has a FERC deadline under
Milestone 3 of FERC Order No. 901 to file new or modified Reliability Standards by November 4, 2025.
Standard(s) Affected

MOD-026-1 Verification of Models and Data for Generator Excitation Control System or Plant Volt/Var
Control Functions
MOD-027-1 Verification of Models and Data for Turbine/Governor and Load Control or Active
Power/Frequency Control Functions
MOD-033-2 Steady-State and Dynamic System Model Validation
Nominee Expertise Requested

For this project, NERC is seeking individuals who possess experience in one or more of the following
areas:
•

Transmission planning assessments;

•

Steady state and dynamic stability analyses;

•

Sensitivity analysis;

•

Modeling;

•

Model Validation;

•

Operational/performance data limitations

Time Commitment Expectations

Time commitments for most projects include up to two face-to-face meetings per quarter (on average
two full working days each meeting) with conference calls scheduled as needed. Team members may
agree to individual or subgroup assignments, to work in separate meetings and present to the larger
team for discussion and review. Another important component of quality reviews and drafting team
efforts is outreach. Members of the team will be expected to conduct industry outreach during the
development process to support a successful project outcome.

Project 2020-06 Verification of Models and Data for Generators
Unofficial Nomination Form | May 23, 2024

Project Priority

Each project will be developed according to that project’s priority status. While each standard project
addresses particular industry needs, some projects will be identified as a higher priority project. A
higher priority project may initially include a strict timeline, which may be needed to effectively
respond to a FERC Directive or as determined by the NERC Board of Trustees. A higher priority project
may also need to increase the frequency of meetings at any time throughout the development
process to account for project timeline needs. Similarly, other priority projects may adjust to a lower
frequency of meetings throughout the development process to reallocate resources to high priority
projects.
This project has been identified as higher priority at this time. The project has a FERC deadline of
November 4, 2025. To meet this deadline, the team will meet regularly, up to three times a week on
conference calls, with face-to-face meetings scheduled as the members’ schedule allows, up to once a
quarter.
Name:
Organization:
Address:
Telephone:
E-mail:
Please briefly describe your experience and qualifications to serve on the requested Standard
Drafting Team (Bio):

If you are currently a member of any NERC drafting team, please list each team here:
Not currently on any active SAR or standard drafting team.
Currently a member of the following SAR or standard drafting team(s):
If you previously worked on any NERC drafting team, please identify the team(s):
No prior NERC SAR or standard drafting team.
Prior experience on the following team(s):
Acknowledgement that the nominee has read and understands both the NERC Participant Conduct
Policy and the Standard Drafting Team Scope documents, available on NERC Standards Resources.
Yes, the nominee has read and understands these documents.

Project 2020-06 Verification of Models and Data for Generators
Unofficial Nomination Form | May 23, 2024

Select each NERC Region in which you have experience relevant to the Project for which you are
volunteering:
MRO
NPCC
RF

SERC
Texas RE
WECC

NA – Not Applicable

Select each Industry Segment that you represent:
1 — Transmission Owners
2 — RTOs, ISOs
3 — Load-serving Entities
4 — Transmission-dependent Utilities
5 — Electric Generators
6 — Electricity Brokers, Aggregators, and Marketers
7 — Large Electricity End Users
8 — Small Electricity End Users
9 — Federal, State, and Provincial Regulatory or other Government Entities
10 — Regional Reliability Organizations and Regional Entities
NA – Not Applicable
Select each Function in which you have current or prior expertise:
Balancing Authority
Compliance Enforcement Authority
Distribution Provider
Generator Operator
Generator Owner
Interchange Authority
Load-serving Entity
Market Operator
Planning Coordinator

Project 2020-06 Verification of Models and Data for Generators
Unofficial Nomination Form | May 23, 2024

Transmission Operator
Transmission Owner
Transmission Planner
Transmission Service Provider
Purchasing-selling Entity
Reliability Coordinator
Reliability Assurer
Resource Planner

Provide the names and contact information for two references who could attest to your technical
qualifications and your ability to work well in a group:
Name:

Telephone:

Organization:

E-mail:

Name:

Telephone:

Organization:

E-mail:

Provide the name and contact information of your immediate supervisor or a member of your
management who can confirm your organization’s willingness to support your active participation.
Name:

Telephone:

Title:

Email:

Project 2020-06 Verification of Models and Data for Generators
Unofficial Nomination Form | May 23, 2024

Standards Announcement

Project 2020-06 Verifications for Models and Data for Generators
Drafting Team Nomination Period Open through June 26, 2024
Now Available

Nominations are being sought for supplemental drafting team members through 8 p.m. Eastern,
Wednesday, June 26, 2024.
Use the electronic form to submit a nomination. Contact Wendy Muller regarding issues using the
electronic form. An unofficial Word version of the nomination form is posted on the Standard Drafting
Team Vacancies page and the project page.
Time commitments for most projects include up to two face-to-face meetings per quarter (on average
two full working days each meeting) with conference calls scheduled as needed. Team members may
agree to individual or subgroup assignments, to work in separate meetings and present to the larger
team for discussion and review. Another important component of quality reviews and drafting team
efforts is outreach. Members of the team will be expected to conduct industry outreach during the
development process to support a successful project outcome.
Project Priority

Each project will be developed according to that project’s priority status. While each standard project
addresses particular industry needs, some projects will be identified as a higher priority project. A
higher priority project may initially include a strict timeline, which may be needed to effectively respond
to a FERC Directive or as determined by the NERC Board of Trustees. A higher priority project may also
need to increase the frequency of meetings at any time throughout the development process to
account for project timeline needs. Similarly, other priority projects may adjust to a lower frequency of
meetings throughout the development process to reallocate resources to high priority projects.
This project has been identified as higher priority at this time. The project has a FERC deadline of
November 4, 2025. To meet this deadline, the team will meet regularly, up to three times a week on
conference calls, with face-to-face meetings scheduled as the members’ schedule allows, up to once a
quarter.
Next Steps
The Standards Committee is expected to appoint members to the drafting team in August 2024.
Nominees will be notified shortly after they have been appointed.
For information on the Standards Development Process, refer to the Standard Processes Manual.

RELIABILITY | RESILIENCE | SECURITY

For more information or assistance, contact Standards Developer, Jamie Calderon (via email) or at 404-9600568. Subscribe to this project's observer mailing list by selecting "NERC Email Distribution Lists" from the
"Service" drop-down menu and specify “Project 2020-06 Verifications of Models and Data for Generators
observer list” in the Title and Description Boxes.

North American Electric Reliability Corporation
3353 Peachtree Rd, NE
Suite 600, North Tower
Atlanta, GA 30326
404-446-2560 | www.nerc.com

Standards Announcement | May 23, 2024
Project 2020-06 Verification of Models and Data for Generators

The North American Electric Reliability Corporation
(NERC) welcomes suggestions to improve the
reliability of the bulk power system through improved
Reliability Standards.

Requested information
SAR Title:
Federal Energy Regulatory Commission (FERC) Order No. 901 – Milestone
3, Part 2: IBR Model Validation
Date Submitted:
4/29/24
SAR Requester
Name:
Alex Shattuck, Jamie Calderon, JP Skeath
Organization: North American Electric Reliability Corporation (NERC)
470-259-0109 (Alex Shattuck)
[email protected]
Telephone:
404-960-0568 (Jamie Calderon) Email:
[email protected]
404-823-1365 (JP Skeath)
[email protected]
SAR Type (Check as many as apply)
New Standard
Imminent Action/ Confidential Issue (SPM
Revision to Existing Standard
Section 10)
Add, Modify or Retire a Glossary Term
Variance development or revision
Withdraw/retire an Existing Standard
Other (Please specify)
Justification for this proposed standard development project (Check all that apply to help NERC prioritize
development)
Regulatory Initiation
NERC Standing Committee Identified
Emerging Risk (Reliability Issues Steering
Enhanced Periodic Review Initiated
Committee) Identified
Industry Stakeholder Identified
Reliability Standard Development Plan
What is the risk to the Bulk Electric System (What Bulk Electric System (BES) reliability benefit does the
proposed project provide?):
This Standards Authorization Request (SAR) is initiated by NERC, with consultation of the Reliability
Security Technical Committee, to address directives issued by the Federal Energy Regulatory Commission
(FERC) in Order No. 901. FERC issued Order No. 901 on October 19, 2023, which includes directives on
new or modified NERC Reliability Standard projects. FERC Order No. 901 addresses a wide spectrum of
reliability risks to the grid from the application of inverter-based resources (IBRs); including both utility
scale and behind-the-meter or distributed energy resources (DERs).
Within the Order, are four milestones that include sets of directives to NERC. In the Order, FERC has
directed NERC to propose new or modified standards to mitigate reliability gaps in the current NERC
Reliability Standards related to IBRs. Specifically, FERC directed NERC to develop new or modified

RELIABILITY | RESILIENCE | SECURITY

Requested information
Reliability Standards to address the following four broad topic areas related to IBRs: (1) data sharing; (2)
data and model validation; (3) planning and operational studies; and (4) performance.
In January 2024, NERC filed the initial Standards Development Work Plan in Response to FERC Order No.
901 (hereafter referred to as the “Work Plan). A current version of the Work Plan will be maintained here.
The Work Plan discusses how NERC will develop Reliability Standards within three tranches (Milestones
2-4) to meet FERC’s filing deadlines. This Standard Authorization Request addresses Milestone 3 – Part 2
of the Work Plan, related to Reliability Standards for IBR data sharing and model validation.
Milestone 3 of the Work Plan covers the development of data provisioning, parameters, and estimation
requirements for IBRs. FERC Order No. 901 directives address three categories of IBR: (1) registered IBR,
including sub-Bulk Electric System IBRs to be registered under NERC’s revised Compliance Registry
criteria; (2) unregistered IBR; and (3) IBR-DER, to distinguish registered bulk connected IBRs from
unregistered bulk connected IBRs as well as the transmission connected IBRs from distribution-connected
IBRs. NERC must file the Reliability Standards or definitions developed under Milestone 3 by November
4, 2025.
Purpose or Goal (What are the reliability gap(s) or risk(s) to the Bulk Electric System being addressed, and
how does this proposed project provide the reliability-related benefit described above?):
This SAR addresses specific pieces of the NERC filed Work Plan related to Milestone 3 and addresses the
various industry comments to meet the regulatory directives of FERC Order No. 901. This project shall
coordinate among other projects (i.e., act as a clearing house to tie directive language to standard
revisions), develop standard language (i.e., perform the normal duties of a standard development
Project), and build upon other Milestones from FERC Order No. 901 Standards Projects to meet regulatory
deadlines (i.e., maintain agility based on how FERC Order No. 901 related Projects proceed to meet the
directive deadlines).
Specifically, the drafting team will address FERC Order No. 901 directives related to modeling validation
(and verification) activities by utilizing actual performance data. This will help ensure the facility’s
model(s) reflects the in-service equipment throughout the lifecycle of the IBR facility.
Project Scope (Define the parameters of the proposed project):
The FERC Order No. 901 directives assigned to this SAR are outlined in the Detailed Description section
below. The project scope shall address all those directives, and should consider the following objectives
during the standards development process:
Phase 1 Objectives:
1. Either revise MOD-033 or create a new IBR model validation Reliability Standard to require model
validation using actual performance data.
a. include a complete set of validation expectations using performance data (must include
performance data of IBR during disturbances as well as other performance measures);

Standard Authorization Request (SAR)

Requested information
b. leverages the most accurate and highest quality model type available (reference data
sharing scope from Milestone 3 Part 1 SAR);
c. ensure post-interconnection validations are not solely based on staged testing, but instead
are periodically validated using performance data;
d. be designed to follow and be able to leverage new performance validations expected to
be done during the interconnection process (to be established in phase 2 of this SAR);
e. include minimum criteria for performing validation (e.g., time, tolerance, impact);
f. include some planner/operator flexibility in determining specific performance criteria –
g. Require planner and operators to communicate any performance criteria to Generator
Owners;
h. the DT should ensure any performance criteria established by the DT or by the planner and
operators are risk-based and region-specific;
i. the DT should consider other criteria may be created by planners and operators to
demonstrate performance in upcoming revisions to Reliability Standards due to Milestone
4 projects (planning and operator studies using performance data); and
j. the DT must require corrective action plans (CAPs) to be created by planners and operators
that require the GO/TO to identify and improve model performance characteristics to align
with performance.
2. Revise MOD-026 and MOD-027 to remove IBR from those Standards as this holistic approach
includes some form of ongoing quality review and corrections based on new performance-based
validation.
3. The drafting team shall ensure that implementation plans for new or modified Reliability
Standards related to Milestone 3 of the Work Plan are aligned and do not create a reliability gap
during implementation.
Phase 2 Objectives (not required as part of 901 Milestone 3 timeline)
4. Either revise FAC-002 or create a new SAR to incorporate similar changes to IBR validation during
the interconnection process or create a new IBR model validation standard to require model
validation using actual performance data to validate model quality during the interconnection
process.
a. include a complete set of validation expectations using performance data,
b. leverages the most accurate and highest quality model type available,
c. ensure post-interconnection validations are not based on staged testing but instead are
periodically validated using performance data,
d. be designed to follow and be able to leverage new performance validations done during
the interconnection process,
e. include minimum criteria for performing validation (e.g., time, tolerance, impact),
f. include some planner/operator flexibility in determining specific performance criteria,
g. These are necessary to ensure that performance criteria are risk-based and region-specific
h. These should consider parallel criteria developed for TPL-001 and the new PRC-030 to
allow corrective action plans to be created by planners and operators that require the

Standard Authorization Request (SAR)

Requested information
GO/TO to identify and improve model performance characteristics to align with
performance.
Detailed Description (Describe the proposed deliverable(s) with sufficient detail for a drafting team to
execute the project. If you propose a new or substantially revised Reliability Standard or definition,
provide: (1) a technical justification 1 of developing a new or revised Reliability Standard or definition,
which includes a discussion of the risk and impact to reliability-of the BES, and (2) a technical foundation
document (e.g., research paper) to guide development of the Standard or definition):
The project scope above will need to account for the specific FERC Directive text in FERC Order 901 to be
successful. The drafting team should consider the specific language in the FERC directives, as well as any
comments in the FERC Order No. 901 proceeding that FERC directed NERC to consider as part of the
standard development process.
FERC Order 901 Directives Assigned to this SAR:
NERC will maintain a current version of NERC Standards Development’s Work Plan to Address FERC Order
No. 901 on the NERC website under Reliability Standards Under Development. Included in this Work Plan
is a list of the directives in FERC Order No. 901 and their associated mapping to each SAR submitted by
NERC. The Work Plan will be updated should any mapping of FERC directives be reassigned due to ongoing
work in the various Standards Development Projects. As of April 1, 2024, this SAR will address the
following FERC Order No. 901 directives, with the scope for this SAR emphasized in bold as appropriate:
1. “Pursuant to section 215(d)(5) of the FPA, we adopt the NOPR proposal to direct NERC to include
in the new or modified Reliability Standards technical criteria to require registered IBR generator
owners to install disturbance monitoring equipment at their buses and elements, to require
registered IBR generator owners to provide disturbance monitoring data to Bulk-Power System
planners and operators for analyzing disturbances on the Bulk-Power System, and to require BulkPower System planners and operators to validate registered IBR models using disturbance
monitoring data from installed registered IBR generator owners’ disturbance monitoring
equipment.” (P85)
2. “With respect to NERC’s recommendation for model benchmarking, we direct NERC to determine
through its standards development process whether the development of benchmark cases to test
model performance and a subsequent report comparing model performance are needed and at
what periodicity.” (P 126)
3. “Pursuant to section 215(d)(5) of the FPA, we adopt the NOPR proposal and direct NERC to
develop new or modified Reliability Standards that require the generator owners of registered
IBRs, transmission owners that have unregistered IBRs on their system, and distribution providers
that have IBR-DERs on their system to provide models that represent the dynamic behavior of
these IBRs at a sufficient level of fidelity to provide to Bulk-Power System planners and operators
The NERC Rules of Procedure require a technical justification for new or substantially revised Reliability Standards. Please attach pertinent
information to this form before submittal to NERC.

Standard Authorization Request (SAR)

Requested information
to perform valid interconnection-wide, planning, and operational studies on a basis comparable
to synchronous generation resources.” (P 140)
4. “We also direct NERC to require the generator owners of registered IBRs and the transmission
owners that have unregistered IBRs on their system to provide to the Bulk-Power System planners
and operators (e.g., planning coordinators, transmission planners, reliability coordinators,
transmission operators, and balancing authorities) dynamic models that accurately represent the
dynamic performance of registered and unregistered IBRs, including momentary cessation and/or
tripping, and all ride through behavior.” (P 141)
5. “While we decline to include this level of detail in the directive to NERC, we nonetheless direct
NERC to establish a standard uniform model verification process.” (P 143)
6. “Therefore, we direct NERC to define the model verification process and to require consistency
among the model verification processes for existing Reliability Standards (e.g., FAC-002, MOD026, and MOD-027) and any new or modified Reliability Standards.” (P 143)
7. “Moreover, although the Reliability Standards will apply to a different (albeit overlapping) set of
entities than Order No. 2023, we believe consistency is needed between the complimentary
proceedings and therefore direct NERC to include in the new or modified Reliability Standards a
similar model verification process timeline consistent with FERC Order No. 2023 modeling
deadline requirements.” (P 149)
8. “Pursuant to section 215(d)(5) of the FPA, we adopt the NOPR proposal and direct NERC to submit
new or modified Reliability Standards that require Bulk-Power System planners and operators to
validate, coordinate, and update in a timely manner the system models by comparing all generator
owner, transmission owner, and distribution provider verified IBR models (i.e., models of
registered IBRs, unregistered IBRs, and IBR-DERs that in the aggregate have a material impact on
the Bulk-Power System) and resulting system models against actual system operational behavior.”
(P 156)
9. “Furthermore, for those areas with IBR-DERs in the aggregate that materially impact the reliable
operation of the Bulk-Power System but do not have an associated registered distribution
provider, we modify the NOPR proposal to direct NERC to determine the appropriate registered
entity responsible for the data and parameters of IBR-DERs in the aggregate and to establish a
process that requires identified registered entities to coordinate, validate, and keep up to date
the system models.” (P 157)
10. “Specifically, we direct NERC to develop new or modified Reliability Standards that require
planning coordinators, transmission planners, reliability coordinators, transmission operators, and
balancing authorities to establish for each interconnection a uniform framework with modeling
criteria, a registered modeling designee, and necessary data exchange requirements both
between themselves and with the generator owners, transmission owners, and distribution
providers to coordinate the creation of transmission planning, operations, and interconnectionwide models (i.e., system models) and the validation of each respective system model.” (P 161)

Standard Authorization Request (SAR)

Requested information
11. “Further, we direct NERC to include in the new or modified Reliability Standards a requirement for
generator owners, transmission owners, and distribution providers to regularly update and
communicate the verified data and models of registered IBRs, unregistered IBRs, and IBR-DERs by
comparing their resulting models against actual operational behavior to achieve and maintain
necessary modeling accuracy for inclusion of these resources in the system models.” (P 161)
12. “For those areas with IBR-DERs in the aggregate that have a material impact on the reliable
operation of the Bulk-Power System but do not have an associated registered distribution
provider, we modify the NOPR proposal to direct NERC to determine the appropriate registered
entity responsible for the models of those IBR-DERs and to determine the registered entities
responsible for updating, verifying, and coordinating models for IBR-DERs in the aggregate to meet
the system models directives.” (P 161)
13. “Further, we believe that there is a need to have all of the directed Reliability Standards effective
and enforceable well in advance of 2030 and direct NERC to ensure that the associated
implementation plans sequentially stagger the effective and enforceable dates to ensure an
orderly industry transition for complying with the IBR directives in this final rule prior to that date.”
(P 226)
Cost Impact Assessment, if known (Provide a paragraph describing the potential cost impacts associated
with the proposed project):
The associated cost with implementation of a new standard is currently unknown. There may be potential
cost savings if fewer reoccurring staged tests are performed.
Please describe any unique characteristics of the BES facilities that may be impacted by this proposed
standard development project (e.g., Dispersed Generation Resources):
Inverter-Based Resources connected to the Bulk Power System (BPS)
Distributed Energy Resources (DER-IBR), in aggregate
To assist the NERC Standards Committee in appointing a drafting team with the appropriate members,
please indicate to which Functional Entities the proposed standard(s) should apply (e.g., Transmission
Operator, Reliability Coordinator, etc. See the NERC Rules of Procedure Appendix 5A:
Transmission Planner
Reliability Coordinator
Distribution Provider
Generator Owner and Generator Operator
Transmission Owner and Transmission Operator
Do you know of any consensus building activities2 in connection with this SAR? If so, please provide any
recommendations or findings resulting from the consensus building activity.
Consensus building activities are occasionally conducted by NERC and/or project review teams. They typically are conducted to obtain
industry inputs prior to proposing any standard development project to revise, or develop a standard or definition.

Standard Authorization Request (SAR)

Requested information
FERC Order No. 901
NERC Standards Development Work Plan in Response to FERC Order No. 901
Inverter-Based Resource Activities, Quick Reference Guide
Distributed Energy Resource Activities, Quick Reference Guide
IBR Registration Initiative, Quick Reference Guide
Are there any related standards or SARs that should be assessed for impact as a result of this proposed
project? If so, which standard(s) or project number(s)?
1. SARs:
a. SAR titled: Federal Energy Regulatory Commission (FERC) Order No. 901 – Milestone 3,
Part 1: Modeling and Data Sharing Requirements
b. SAR titled: Federal Energy Regulatory Commission (FERC) Order No. 901 – Milestone 3,
Part 3: IBR Modeling Revision
2. Active Reliability Standards Projects:
a. 2020-06 Verifications of Models and Data for Generators (NERC Standards Development
recommends assigning the SAR to this active project)
b. 2021-01 Modifications to MOD-025 and PRC-019
c. 2022-02 Modifications to TPL-001-5.1 and MOD-032-1
d. 2022-04 EMT Modeling
e. 2023-05 Modifications to FAC-001 and FAC-002
f. 2023-08 Modifications of MOD-031 Demand and Energy Data
Are there alternatives (e.g., guidelines, white paper, alerts, etc.) that have been considered or could meet
the objectives? If so, please list the alternatives with the benefits of using them.
Reliability Principles
Does this proposed standard development project support at least one of the following Reliability
Principles (Reliability Interface Principles)? Please check all those that apply.
1. Interconnected bulk power systems shall be planned and operated in a coordinated manner to
perform reliably under normal and abnormal conditions as defined in the NERC Standards.
2. The frequency and voltage of interconnected bulk power systems shall be controlled within
defined limits through the balancing of real and reactive power supply and demand.
3. Information necessary for the planning and operation of interconnected bulk power systems
shall be made available to those entities responsible for planning and operating the systems
reliably.
4. Plans for emergency operation and system restoration of interconnected bulk power systems
shall be developed, coordinated, maintained and implemented.
5. Facilities for communication, monitoring and control shall be provided, used and maintained
for the reliability of interconnected bulk power systems.
6. Personnel responsible for planning and operating interconnected bulk power systems shall be
trained, qualified, and have the responsibility and authority to implement actions.

Standard Authorization Request (SAR)

Reliability Principles
7. The security of the interconnected bulk power systems shall be assessed, monitored and
maintained on a wide area basis.
8. Bulk power systems shall be protected from malicious physical or cyber attacks.
Market Interface Principles
Does the proposed standard development project comply with all of the following Market
Interface Principles?
1. A reliability standard shall not give any market participant an unfair competitive
advantage.
2. A reliability standard shall neither mandate nor prohibit any specific market
structure.
3. A reliability standard shall not preclude market solutions to achieving compliance
with that standard.
4. A reliability standard shall not require the public disclosure of commercially
sensitive information. All market participants shall have equal opportunity to
access commercially non-sensitive information that is required for compliance
with reliability standards.

Enter
(yes/no)
yes
yes
yes
yes

Identified Existing or Potential Regional or Interconnection Variances
Region(s)/
Explanation
Interconnection
e.g., NPCC
Unknown at this time.

For Use by NERC Only
SAR Status Tracking (Check off as appropriate).
Draft SAR reviewed by NERC Staff
Draft SAR presented to SC for acceptance
DRAFT SAR approved for posting by the SC
Risk Tracking.
Grid Transformation
Resilience/Extreme Events
Security Risks

Final SAR endorsed by the SC
SAR assigned a Standards Project by NERC
SAR denied or proposed as Guidance document
Energy Policy
Critical Infrastructure Interdependencies

Version History
Version

Date

June 3, 2013

Standard Authorization Request (SAR)

Owner

Change Tracking

Revised

August 29, 2014

Standards Information Staff

Updated template

January 18, 2017

Standards Information Staff

Revised

June 28, 2017

Standards Information Staff

Updated template

February 22, 2019

Standards Information Staff

Added instructions to submit via Help
Desk

February 25, 2020

Standards Information Staff

Updated template footer

August 14, 2023

Standards
Staff

Standard Authorization Request (SAR)

Development Updated template as part of Standards
Process Stakeholder Engagement
Group

Unofficial Comment Form

Project 2020-06 Verification of Models and Data for Generators
Standard Authorization Request (SAR)
Do not use this form for submitting comments. Use the Standards Balloting and Commenting System
(SBS) to submit comments on the Project 2020-06 Verification of Models and Data for Generators SAR by
8:00 p.m. Eastern, Wednesday, June 26, 2024.
m. Eastern, Thursday, August 20, 2015
Additional information is available on the project page. If you have questions, contact Manager of
Standard Developer, Jamie Calderon (via email), or at 404-960-0568.
Background Information

RELIABILITY | RESILIENCE | SECURITY

This project has been identified as higher priority at this time. This project has a FERC deadline under
Milestone 3 of November 4, 2025.
Questions

1. Are there any areas of concern that duplicative coverage or competing expectations would occur,
if so, what are these areas the team should be aware of when drafting?
Yes
No
Comments:
2. Provide any additional comments for the drafting team to consider, if desired.
Yes
No
Comments:

Project 2020-06 Verifications of Models and Data for Generators
Unofficial Comment Form | May 23, 2024

Standards Announcement

Project 2020-06 Verification of Models and Data for Generators
Standard Authorization Request (SAR)
Formal Comment Period Open through June 26 2024
Now Available

A formal comment period for the Project 2020-06 Verification of Models and Data for Generators SAR,
is open through 8 p.m. Eastern, Wednesday, June 26, 2024.
Commenting

Use the Standards Balloting and Commenting System (SBS) to submit comments. An unofficial Word
version of the comment form is posted on the project page.
•

•

Passwords expire every 6 months and must be reset.

•

The SBS is not supported for use on mobile devices.

•

Please be mindful of ballot and comment period closing dates. We ask to allow at least 48 hours
for NERC support staff to assist with inquiries. Therefore, it is recommended that users try logging
into their SBS accounts prior to the last day of a comment/ballot period.

Next Steps

The drafting team will review all responses received during the comment period and determine the next
steps of the project.
For information on the Standards Development Process, refer to the Standard Processes Manual.
For more information or assistance, contact Standards Developer, Jamie Calderon (via email) or at 404-9600568. Subscribe to this project's observer mailing list by selecting "NERC Email Distribution Lists" from the
"Service" drop-down menu and specify “Project 2020-06 Verifications of Models and Data for Generators
observer list” in the Title and Description Boxes.

North American Electric Reliability Corporation
3353 Peachtree Rd, NE
Suite 600, North Tower
Atlanta, GA 30326
404-446-2560 | www.nerc.com

RELIABILITY | RESILIENCE | SECURITY

Comment Report
Project Name:

2020-06 Verifications of Models and Data for Generators | Standard Authorization Request

Comment Period Start Date:

5/28/2024

Comment Period End Date:

6/26/2024

Associated Ballots:

There were 40 sets of responses, including comments from approximately 111 different people from approximately 69 companies
representing 10 of the Industry Segments as shown in the table on the following pages.

Questions
1. Are there any areas of concern that duplicative coverage or competing expectations would occur, if so, what are these areas the team
should be aware of when drafting?
2. Provide any additional comments for the drafting team to consider, if desired.

Organization
Name
Southwest
Power Pool,
Inc. (RTO)

Entergy

FirstEnergy FirstEnergy
Corporation

Name

Charles Yeung 2

Julie Hall

Mark Garza

DTE Energy - Mohamad
Detroit Edison Elhusseini
Company

Southern

Segment(s)

Region

MRO,SPP
RE,WECC

1,3,6

SRC 2024

Entergy

1,4,5,6

FE Voter

3,5

Pamela Hunter 1,3,5,6

Group Name

DTE Energy

SERC

Southern

Group Member
Name

Group
Member
Organization

Group
Member
Segment(s)

Group Member
Region

Charles Yeung

SPP

MRO

Ali Miremadi

CAISO

WECC

Helen Lainis

IESO

NPCC

Bobbi Welch

Midcontinent
ISO, Inc.

MRO

Greg Campoli

NYISO

NPCC

Elizabeth Davis

PJM

Kennedy Meier

Electric
Reliability
Council of
Texas, Inc.

Texas RE

Matt Goldberg

ISO New
England

NPCC

Oliver Burke

Entergy 1
Entergy
Services, Inc.

SERC

Jamie Prater

Entergy

SERC

Julie Severino

FirstEnergy FirstEnergy
Corporation

Aaron
Ghodooshim

FirstEnergy FirstEnergy
Corporation

Robert Loy

FirstEnergy FirstEnergy
Solutions

Mark Garza

FirstEnergyFirstEnergy

1,3,4,5,6

Stacey Sheehan

FirstEnergy FirstEnergy
Corporation

Mohamad
Elhusseini

DTE Energy

Patricia Ireland

DTE Energy

Marvin Johnson

DTE Energy - 3
Detroit Edison
Company

Matt Carden

Southern

SERC

Company Southern
Company
Services, Inc.

Black Hills
Corporation

Northeast
Power
Coordinating
Council

Company

Rachel Schuldt 1,3,5,6

Ruida Shu

1,2,3,4,5,6,7,8,9,10 NPCC

Company Southern
Company
Services, Inc.
Joel Dembowski

Southern
Company Alabama
Power
Company

SERC

Ron Carlsen

Southern
Company Southern
Company
Generation

SERC

Leslie Burke

Southern
Company Southern
Company
Generation

SERC

Black Hills
Corporation

WECC

Black Hills
Corporation

WECC

Rachel Schuldt

Black Hills
Corporation

WECC

Carly Miller

Black Hills
Corporation

WECC

Sheila Suurmeier Black Hills
Corporation

WECC

Gerry Dunbar

Northeast
Power
Coordinating
Council

NPCC

Deidre Altobell

Con Edison

NPCC

Michele Tondalo

United
Illuminating
Co.

NPCC

Stephanie UllahMazzuca

Orange and
Rockland

NPCC

Michael Ridolfino Central
1
Hudson Gas &
Electric Corp.

NPCC

Randy Buswell

Vermont
1
Electric Power
Company

NPCC

James Grant

NYISO

NPCC

Black Hills
Micah Runner
Corporation All Segments Josh Combs

NPCC RSC

Dermot Smyth

Con Ed 1
Consolidated
Edison Co. of
New York

NPCC

David Burke

Orange and
Rockland

NPCC

Peter Yost

Con Ed 3
Consolidated
Edison Co. of
New York

NPCC

Salvatore
Spagnolo

New York
Power
Authority

NPCC

Sean Bodkin

Dominion Dominion
Resources,
Inc.

NPCC

David Kwan

Ontario Power 4
Generation

NPCC

Silvia Mitchell

NextEra
1
Energy Florida Power
and Light Co.

NPCC

Sean Cavote

PSEG

NPCC

Jason Chandler

Con Edison

NPCC

Tracy MacNicoll

Utility Services 5

NPCC

Shivaz Chopra

New York
Power
Authority

NPCC

Vijay Puran

New York
6
State
Department of
Public Service

NPCC

David Kiguel

Independent

NPCC

Joel Charlebois

AESI

NPCC

Joshua London

Eversource
Energy

NPCC

Emma Halilovic

Hydro One
1,2
Networks, Inc.

NPCC

Emma Halilovic

Hydro One
1,2
Networks, Inc.

NPCC

Chantal Mazza

Hydro Quebec 1,2

NPCC

Southwest
Power Pool,
Inc. (RTO)

Shannon
Mickens

MRO,SPP
RE,WECC

SPP RTO

Emma Halilovic

Hydro One
1,2
Networks, Inc.

NPCC

Chantal Mazza

Hydro Quebec 1,2

NPCC

Nicolas Turcotte

Hydro-Quebec 1
(HQ)

NPCC

Jeffrey Streifling

NB Power
Corporation

1,4,10

NPCC

Jeffrey Streifling

NB Power
Corporation

1,4,10

NPCC

Jeffrey Streifling

NB Power
Corporation

1,4,10

NPCC

Joel Charlebois

AESI

NPCC

Shannon Mickens Southwest
Power Pool
Inc.

MRO

Mia Wilson

Southwest
Power Pool
Inc.

MRO

Eddie Watson

Southwest
Power Pool
Inc.

MRO

Steve Purdy

Southwest
Power Pool
Inc.

MRO

Jim Williams

Southwest
Power Pool
Inc.

MRO

Jeff McDiarmid

Southwest
Power Pool
Inc.

MRO

Mason Favazza

Southwest
Power Pool
Inc.

MRO

Eric Sullivan

Southwest
Power Pool
Inc.

MRO

Heather Harris

Southwest
Power Pool
Inc.

MRO

Scott Jordan

Southwest
Power Pool
Inc

MRO

Hugh Benfer

Southwest
Power Pool
Inc.

MRO

Western
Electricity
Coordinating
Council

Steven
Rueckert

WECC

Zach Sabey

Southwest
Power Pool
Inc.

MRO

Bryan Wood

Southwest
Power Pool
Inc

MRO

Margaret Quispe

Southwest
Power Pool
Inc

MRO

Will Tootle

Southwest
Power Pool
Inc.

MRO

ashley Stringer

Southwest
Power Pool
Inc.

MRO

Brett Springfield

Southwest
Power Pool
Inc.

MRO

Steve Rueckert

WECC

Curtis Crews

WECC

1. Are there any areas of concern that duplicative coverage or competing expectations would occur, if so, what are these areas the team
should be aware of when drafting?
Mohamad Elhusseini - DTE Energy - Detroit Edison Company - 3,5, Group Name DTE Energy
Answer

Document Name
Comment
Possible answers:Yes (could not correct it above).
There may be overlap with theFAC-002 and/or MOD-025/026/027/032 Standards that could occur if not coordinated together.
How will this Standard or Standards be different from the requirements for FR, DDR, and SER data in PRC-028 as noted in item #1 under detailed
description to install and provide disturbance monitoring information to BPS planners and operators.
Will the specific attributes being required in the dynamic model be similar to that which is required in MOD-032 currently or will there be a separate set
of criteria to be met?
There appears that there could be significant overlap with SARs 2022-04, 2022-02, and 2023-05.
Likes

Dislikes

Response

(Drafting team’s response to submitter’s comments)
Mark Garza - FirstEnergy - FirstEnergy Corporation - 1,4,5,6, Group Name FE Voter
Answer

Document Name
Comment
Until the Order 901 Milestone 3 SARs are more clearly defined, we cannot effectively assess whether this SAR contains any duplication in coverage or
competing expectations.
Likes

Dislikes

Response
Daniel Gacek - Exelon - 1,3
Answer
Document Name

Comment
Not at this time, however several SARs are posted for comments and subject to modifications.
Likes

Dislikes

Response
Patricia Lynch - NRG - NRG Energy, Inc. - 5,6
Answer

Document Name
Comment
Likes

Dislikes

Response
Stephen Stafford - Georgia Transmission Corporation - 1 - SERC
Answer

Document Name
Comment
Likes

Dislikes

Response
Diana Aguas - CenterPoint Energy Houston Electric, LLC - 1 - Texas RE
Answer

Document Name
Comment
Likes
Dislikes

0
0

Response
Anna Todd - Southern Indiana Gas and Electric Co. - 3,5,6 - RF
Answer

Document Name
Comment
Likes

Dislikes

Response
Steven Rueckert - Western Electricity Coordinating Council - 10, Group Name WECC
Answer

Document Name
Comment
Likes

Dislikes

Response
Jessica Cordero - Unisource - Tucson Electric Power Co. - 1
Answer

Yes

Document Name
Comment
TEPC agrees with EEI's response - EEI believes that until the Order 901 Milestone SARs are better defined, we cannot address whether the SARs
provide any duplication in coverage.
Likes

Dislikes

Response
Jennifer Weber - Tennessee Valley Authority - 1,3,5,6 - SERC

Answer

Yes

Document Name
Comment
Request that this SAR be revised to combine with the previous SAR accepted by the Standards Committee on 7/21/2021. Three draft revisions of
MOD-026-2 have been balloted as well as 2 new definitions. This is not addressed in this new proposed SAR. It is confusing to industry to have
multiple SARs open on the same standard and leaves industry unclear on the path forward for this Project.
Likes

Dislikes

Response
Duane Franke - Manitoba Hydro - 1,3,5,6 - MRO
Answer

Yes

Document Name
Comment
It looks like the Phase-2 objectives duplicate the scope of the Project 2022-04 EMT Modeling Standard Drafting Team, where FAC-002-4 is currently
under revision to include EMT modeling and study requirements. Coordinating with the Project 2022-04 EMT Modeling Standard Drafting Team is
advisable to check whether they can address some of the objectives in this new SAR.
Phase 2 Objectives (not required as part of 901 Milestone 3 timeline)
4. Either revise FAC-002 or create a new SAR to incorporate similar changes to IBR validation during the interconnection process or create a new IBR
model validation standard to require model validation using actual performance data to validate model quality during the interconnection process.
Likes

Dislikes

Response
Kimberly Turco - Constellation - 5,6
Answer

Yes

Document Name
Comment
Constellation feels projects have listed PRC-029 or PRC 030 as examples to may necessitate some form of change to the model but also are
mentioning impacts in existing standards such as TPL-001-5, MOD-32, MOD-026, MOD-027, MOD-025, PRC-019 and IRO-010, the standard drafting
team should ensure there is not duplicative requirements.

Kimberly Turco on behalf of Constellation Segments 5 and 6
Likes

Dislikes

Response
Julie Hall - Entergy - 1,3,6, Group Name Entergy
Answer

Yes

Document Name
Comment
Entergy has the following concerns around duplicative coverage or competing expectations:
•
•
•
•
•

Multiple projects appear to be asking for or talking about similar/same questions and issues.
Mod-033 is not appropriate Standard to do model validation for IBRs.
If IBRs are removed from MOD-026 and MOD-027, then MOD-033 needs to include requirements for all the testing and validation that are
required in MOD-026 and MOD-27.
Various SDTs do not seem to be communicating.
This project appears to be negating much of the previous work done to approve and implement MOD-026 and MOD-027.

Likes

Dislikes

Response
Alison MacKellar - Constellation - 5,6
Answer

Yes

Dislikes
Response

Rachel Schuldt - Black Hills Corporation - 1,3,5,6, Group Name Black Hills Corporation - All Segments
Answer

Yes

Document Name
Comment
Black Hills Corporation agrees with the NAGF in their 3 detailed description sections that the narratives added confusion and could lead to duplicative or
competing outcomes, as written below:
The NAGF provides the following comments regarding possible duplication/overlap for consideration:
a.

Detailed Description Section:

i. FERC Order 901 Directives Assigned to this SAR (page 4) – The paragraph states “As of April 1, 2024, this SAR will address the following FERC
Order 901 directives, with the scope for this SAR emphasized in bold as appropriate:”. 13 sections of the FERC Order 901 directives are included in the
Detailed Description Section of which only 3 are bolded (1, 9, and 10). It is unclear as to value of including the non-bolded narratives as it adds
significant confusion to the SAR. Recommend removing the non-bolded FERC Order 901 directive narratives from this section or clearly identify DT
work activities associated with these non-bolded narratives.
ii. The NAGF notes that the inclusion of the following FERC Order 901 directive narratives in both the Project 2022-02 and this draft SARs Detailed
Description section could lead to duplicative or competing outcomes:
#4 (unbolded)
#9 (bolded)
#10 (bolded)
#13 (unbolded)
iii. Given the numerous parallel NERC IBR efforts and the speed at which they are progressing, it is unclear as to the potential for duplication/overlap
among these efforts. The NAGF and industry expect that NERC will have checks in place to ensure there are no duplication or competing expectations
for these important IBR activities.
Likes

Dislikes

Response
Wayne Sipperly - North American Generator Forum - 5 - MRO,WECC,Texas RE,NPCC,SERC,RF
Answer

Yes

Document Name
Comment
The NAGF provides the following comments regarding possible duplication/overlap for consideration:

Detailed Description Section:

i.
FERC Order 901 Directives Assigned to this SAR (page 4) – The paragraph states “As of April 1, 2024, this SAR will address the following
FERC Order 901 directives, with the scope for this SAR emphasized in bold as appropriate:”. 13 sections of the FERC Order 901 directives are included
in the Detailed Description Section of which only 3 are bolded (1, 9, and 10). It is unclear as to value of including the non-bolded narratives as it adds
significant confusion to the SAR. Recommend removing the non-bolded FERC Order 901 directive narratives from this section or clearly identify DT
work activities associated with these non-bolded narratives.
ii.
The NAGF notes that the inclusion of the following FERC Order 901 directive narratives in both the Project 2022-02 and this draft SARs
Detailed Description section could lead to duplicative or competing outcomes:
#4 (unbolded)
#9 (bolded)
#10 (bolded)
#13 (unbolded)
iii.
Given the numerous parallel NERC IBR efforts and the speed at which they are progressing, it is unclear as to the potential for
duplication/overlap among these efforts. The NAGF and industry expect that NERC will have checks in place to ensure there are no duplication or
competing expectations for these important IBR activities.
Likes

Dislikes

Response
Pamela Hunter - Southern Company - Southern Company Services, Inc. - 1,3,5,6 - SERC, Group Name Southern Company
Answer

Yes

Document Name
Comment
The purpose section of the SAR needs to limited to the specific purpose of the SAR (the second paragraph).
The detailed description section should be much more precise and not include items that are to be action items for the drafting team. Consider only
including the bolded part of the long list of directive elements which are unique to the purpose of this SAR. Take care to not include duplicative bolded
text in two concurrent SARs being written. See the comment below regarding this subject.
The project scope of the SR needs to be more succinct and not include material duplicated in other SARs (e.g. 2022-02) for both phases listed.
Some detailed description section duplicates bolded text in two SARs – creating confusion of which project is supposed to address the directive. FERC
Order 901 Directives Assigned to this SAR (page 5) – The paragraph states “As of April 1, 2024, this SAR will address the following FERC Order 901
directives, with the scope for this SAR emphasized in bold as appropriate:”. 26 sections of the FERC Order 901 directives are included in the Detailed
Description Section of which only 3 are bolded (17, 24, and 25). It is unclear as to value of including the non-bolded narratives and it adds significant
confusion to the SAR. We recommend removing the non-bolded FERC Order 901 directive narratives from this section or clearly identify DT work
activities associated with these non-bolded narratives.
With so many standards currently in revision with unknown outcomes, it is impossible to predict conflicts before they occur. NERC supposably has

internal groups tasked with preventing duplication and conflicting competition between standards during development.
Likes

Dislikes

Response
Hayden Maples - Evergy - 1,3,5,6 - MRO
Answer

Yes

Document Name
Comment
Evergy supports and incorporates by reference the comments of the Edison Electric Institute (EEI) on question 1
Likes

Dislikes

Response
Christy Thompson - PPL - Louisville Gas and Electric Co. - 3,5,6 - SERC
Answer

Yes

Document Name
Comment
The recently released PRC-029-1 standard from project 2020-02 include multiple requirements in the form “Each GO or TO of an applicable IBR shall
ensure that…” followed by a condition and a performance requirement. Measures include requirements in the form “Each GO and TO shall have
evidence of actual recorded data…”. Essentially, PRC-029-1 requires post-event validation against performance criteria. This SAR requires post-event
validation against models. These two things may be competing goals if model performance indicates failure to meet performance criteria. Though PRC029-1 is still under development and the event validation components may be an overstep in its scope, care should be taken to not duplicate event
validation work.
The recently released PRC-030-1 standard from project 2023-02 also includes requirements that overlap the stated purpose of this SAR. Specifically,
requirement R4 of PRC-030-1 requires GOs to “analyze its IBRs performance” for certain system events. While this standard is also under
development, the DT must consider that two different entities will be attempting to complete the same task. Again, this poses risk for duplicative
coverage and competing expectations. For example, suppose due to PRC-030-1 the GO initiates a project to change inverter settings in a way that
improves the simulated performance match for the event studied under PRC-030-1, but degrades the simulated performance match for an event studied
by the TP under the requirements developed by this SAR. It is well known in the industry that model tweaks can simultaneously improve and degrade
model performance depending on the event studied.
The DT must consider the scope and frequency of MOD-033. MOD-033 currently requires steady-state and stability validation once every 24 calendar
months. Moreover, the stability portion only requires a validation of a single dynamic local event. The DT must keep in mind that MOD-033 is considered
sufficient for the validation of the entire BES and has been serving the industry well. It is unreasonable to subject PCs and TPs to IBR validation
activities that are inconsistent with the expectations of MOD-033. I.e., if the entire system is validated once every two years, a DER does not need to be

validated for every event.
The DT must consider the scope, timelines, and mitigations associated with MOD-026 and MOD-027. These standards directly relative to the scope of
the SAR. Requirement R3 in each standard states “Each GO shall provide a written response to its TP” if the TP indicates that “the simulated …
response did not match[approximate] the recorded response” for one to three events. While it is understood not all IBR owners are NERC registered
entities, these standards currently set the expectation for the exact types of concerns raised in the SAR. The current mitigation requires coordination
between the TP and GO to resolve or technically justify model issues.
Likes

Dislikes

Response
Daniela Atanasovski - APS - Arizona Public Service Co. - 1,3,5,6
Answer

Yes

Dislikes

Response
Greg Sorenson - ReliabilityFirst - 10 - RF
Answer

Yes

Document Name
Comment
The SAR states, “Specifically, we direct NERC to develop new or modified Reliability Standards that require planning coordinators, transmission
planners, reliability coordinators, transmission operators, and balancing authorities to establish for each interconnection a uniform framework with
modeling criteria, a registered modeling designee, and necessary data exchange requirements both between themselves and with the generator
owners, transmission owners, and distribution providers to coordinate the creation of transmission planning, operations, and interconnection wide
models (i.e., system models) and the validation of each respective system model.” This may create a competing expectation, or order-of-operation issue
with the effort to modify MOD-032. The modeling criteria would need to be established prior to the development of the validation requirements. There
also could be some duplication with MOD-033 as it also deals with system model validation.
Likes

Dislikes
Response

Scott Thompson - PNM Resources - 1,3,5 - WECC
Answer

Yes

Document Name
Comment
Potential for duplicate coverage to the following projects: 2022-04, 2022-02, and 2023-05.
FAC-002 and/or MOD-025/026/027/032 Standards that could occur if not coordinated together
How will this Standard or Standards be different from the requirements for FR, DDR, and SER data in PRC-028 as noted in item #1 under detailed
description to install and provide disturbance monitoring information to BPS planners and operators. Will the specific attributes being required in the
dynamic model be similar to that which is required in MOD-032 currently or will there be a separate set of criteria to be met?
Likes

Dislikes

Response
Joseph Gatten - Xcel Energy, Inc. - 1,3,5,6 - MRO,WECC
Answer

Yes

Document Name
Comment
Xcel Energy supports the comments of the EEI.
Likes

Dislikes

Response
Bobbi Welch - Midcontinent ISO, Inc. - 2
Answer

Yes

Document Name
Comment
MISO supports comments submitted by the ISO/RTO Council (IRC) Standards Review Committee (SRC).
Likes
Dislikes

0
0

Response
Charles Yeung - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC, Group Name SRC 2024
Answer

Yes

Document Name
Comment
The ISO/RTO Council (IRC) Standards Review Committee (SRC) submits four comments in response to this question:
1) Need clarity on the expected entity for compliance with IBR model validation. The SRC proposes the IBR facility owner as the appropriate entity to
validate the models that represent its equipment and devices.
2) Allow flexibility to revise all standards to ensure the IBR requirements are not applied to non-IBR.
3) Clarify whether this project or 2021-01 has authority over final proposed language.
4) Validation requirements for an interconnection study need to recognize limitations on data.

Phase 1 objectives:

Item 1:
MOD-033 is already a “system model validation” standard that requires comparison of simulation results to an actual event (field measurement). It
seems odd to reference this existing standard (applicable to the PC, RC, and TOP) if the intention of this SAR is to require IBR-specific model
validation. The SAR should be more clear about the intended entity that would have a compliance obligation to perform model validation. As a practical
matter, the SRC proposes the IBR-facility owner should be the entity obligated to validate the models that represent its equipment and devices.

“2. Revise MOD-026 and MOD-027 to remove IBR from those Standards as this holistic approach
includes some form of ongoing quality review and corrections based on new performance-based
validation.”
The SAR should provide better clarity on the expectations of how it will align with the SAR from 2021 Since that SAR is still valid and not being revised
to preclude IBRs, this SAR needs to be clear on the “authority” over the 2021 SAR for IBR requirements. Furthermore MOD-026/027 seems to be a
logical starting point for an SDT to consider since those currently address model verification for generating plant volt/var and active power/frequency
control functions.
However, if the SDT elects to create a separate standard for IBR model validation, the SAR scope should provide the SDT the flexibility to determine
how best to establish IBR-specific model validation requirements (and whether they should be a part of MOD-026/027, MOD-033, or a new standard). If
the SDT elects to create a separate standard for IBR model validation, the SAR scope should allow the SDT the flexibility needed to make appropriate
revisions to MOD-026/027 (e.g. limiting applicability to non-IBR, etc.).

“3. The drafting team shall ensure that implementation plans for new or modified Reliability
Standards related to Milestone 3 of the Work Plan are aligned and do not create a reliability gap
during implementation.”
Both this SAR and the SAR for Project 2021-01 reference the same objective to address gaps for all Milestone 3 standards.
We agree with the need to ensure there are no reliability gaps during implementation. But it is unclear in the SAR how this team’s work is different than
the work the Project 2021-01 drafting team will be responsible for.

The comparison exercises currently required by MOD-033 are themselves duplicative – if a system model consists of validated and verified models of
individual components (generators, plants, IBR, transmission elements, loads, etc.), that are tuned to reflect actual event conditions, then system
simulation results would more closely match with actual performance. Correcting system model performance to match measured values can only be
effectively and conclusively completed by correcting/validating individual component models impacted by the disturbance event.

Phase 2 objectives:
“4. Either revise FAC-002 or create a new SAR to incorporate similar changes to IBR validation during the interconnection process or create a new IBR
model validation standard to require model validation using actual performance data to validate model quality during the interconnection process.”
The FAC-002 standard’s purpose is to require the study of interconnection requests, not to address model validation, whereas the MOD series of
standards is focused on the accuracy and integrity of models. Whether the team decides to revise FAC-002 or create a new standard for model
validation, the scope must consider the limitations of model validation at the time of an interconnection study.

If validation is intended to refer to a confirmation that IBR simulation model performance matches field performance, validation is not possible
throughout most of the interconnection process since there is no field performance that can be measured until after construction is complete. If the SAR
is contemplating validation tests that occur as part of plant commissioning, the SAR should be more precise in identifying that portion of the
interconnection process.
Likes

Dislikes

Response
Kennedy Meier - Electric Reliability Council of Texas, Inc. - 2
Answer

Yes

Document Name
Comment
ERCOT joins the comments submitted by the ISO/RTO Council (IRC) Standards Review Committee (SRC) and adopts them as its own.
Likes

Dislikes

Response
Andy Thomas - Duke Energy - 1,3,5,6 - SERC,RF
Answer
Document Name
Comment
Duke Energy agrees with and supports EEI comments for Question 1.
Likes

Dislikes

Response
David Jendras Sr - Ameren - Ameren Services - 1,3,6
Answer
Document Name
Comment
Ameren supports EEI's Comments on this project.
Likes

Dislikes

Response
Mark Gray - Edison Electric Institute - NA - Not Applicable - NA - Not Applicable
Answer
Document Name
Comment
Until the Order 901 Milestone 3 SARs are more clearly defined, we cannot effectively assess whether this SAR contains any duplication in coverage or
competing expectations.
Likes

Dislikes
Response

Dwanique Spiller - Berkshire Hathaway - NV Energy - 5
Answer
Document Name
Comment
Until the Order 901 Milestone 3 SARs are more clearly defined, we cannot effectively assess whether this SAR contains any duplication in coverage or
competing expectations.

Likes

Dislikes

Response
Shannon Mickens - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC, Group Name SPP RTO
Answer
Document Name
Comment
N/A
Likes

Dislikes
Response

2. Provide any additional comments for the drafting team to consider, if desired.
Kennedy Meier - Electric Reliability Council of Texas, Inc. - 2
Answer
Document Name
Comment
ERCOT joins the comments submitted by the IRC SRC and adopts them as its own.
Likes

Dislikes

Response
Charles Yeung - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC, Group Name SRC 2024
Answer
Document Name
Comment
The SRC submits five comments in response to this question:
1) The SAR should be revised to clarify whether the responsible party for non-associated DERs will be identified by NERC or by the NERC standards
process.
2) Require minimum categories or data to be identified to meet FERC directive.
3) Address use of phasor-domain vs EMT specific models.
4) Allow for creation of guidelines to address older facilities that may not have EMT data available.
5) Models for IBRs not subject to NERC standards and registration are not available.

It is unclear how the standard language is to be written to meet objective no. 9. The language directs NERC (the organization) to determine and specify
the team that will assign responsibility for non-associated DERs, which suggests that NERC staff will execute this directive. It would be preferable if the
drafting team had the ability to propose the responsible entity and allow for stakeholder feedback and ballot.

9. “Furthermore, for those areas with IBR-DERs in the aggregate that materially impact the reliable
operation of the Bulk-Power System but do not have an associated registered distribution
provider, we modify the NOPR proposal to direct NERC to determine the appropriate registered

entity responsible for the data and parameters of IBR-DERs in the aggregate and to establish a
process that requires identified registered entities to coordinate, validate, and keep up to date
the system models.” (P 157)
The scope of the SAR should include item 4 from the FERC Order approving the NERC IBR Workplan. The bolded text is a clear directive from FERC.
4. “Regarding CAISO’s concern regarding the potential “compliance trap” where planners and operators rely on third-party data and IRC’s request that
the final rule specify the data to be submitted by all IBRs (i.e., registered IBRs, unregistered IBRs, and IBR-DERs in the aggregate) and transmission
devices using similar technologies, we direct NERC to determine through its standards development process the minimum categories or types of data
that must be provided to transmission planners, transmission operators, transmission owners, and distribution providers necessary to predict the
behavior of all IBRs and to ensure that compliance obligations are clear.”

The SAR must direct the SDT to address the use of Phasor domain models or detailed EMT models. The final standards must be clear in how these
models will be used. Our preference is to address both types of models and to require benchmarking of both types against each other.

Similarly, the scope should include the ability for the SDT to develop guidelines on how to address grandfathered facilities with no EMT models. For
many of these facilities, the OEM is no longer supporting the inverter vintage or is completely out of business.

The SAR should recognize modeling limitations for non-registered IBRs or those connected to non-registered distribution providers. Regarding the
multiple SAR references to unregistered IBRs and IBR-DERs – the SRC agrees that such data exchange, modeling, validation and coordination is best
served by the generation owners, transmission owners, and distribution providers. However, such data and parameter requests will presumptively not
meet the intended results as unregistered IBRs and IBR-DERs are not required to comply with NERC Reliability Standards. This is even further
magnified for unregistered IBRs and IBR-DERs that are connected to non-registered distribution providers. Generally, case studies do not include
resources of 20MW or lower, and the requirement to add such resources is anticipated to result in significant costs without any known benefits to
modeling at the distribution level.

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Response
Shannon Mickens - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC, Group Name SPP RTO
Answer
Document Name
Comment
The relevance of modeling validation references in sub-part H to revisions of FAC-002 for the Inverter-Based Resource (IBR) during the interconnection
process is unclear. The drafting team should clarify the relationship to the Correction Action Plan (CAP) criteria and indicate these other projects should
be finalized before adopting similar criteria to TPL-001 and PRC-030. The drafting team should also consider if this is a separate issue that needs to be

removed and addressed by a different drafting team for not aligning with the Phase 2 Objective.
As noted in the SRC comments, we recommend that the drafting team provide more clarity in the SAR on responsibilities and how modeling data is
validated.
Finally, SPP recommends that the drafting team add the Planning Coordinator (PC) to the applicable entities of the SAR. We anticipate the PC may be
impacted via this validation of modeling data.
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Dwanique Spiller - Berkshire Hathaway - NV Energy - 5
Answer
Document Name
Comment
The following comments are intended to address NV Energy concerns with the Proposed SAR. Our negative response also reflects our opinion that the
SAR needs to be revised prior to final approval.
Detail Description/FERC Order 901 Directives for Milestone 3 Part 2 Comments
While NV Energy generally agrees that many of the FERC Order 901 directives allocated to this project are reflected in this proposed Project Scope
(i.e., Items 1, 3, 5, 6, 7, & 10), we do not agree the following directives have been sufficiently addressed in the SAR:
Note: Item numbers below align with those contained in the Detailed Description Section of the SAR.
{C}·
Item 2 contains a directive that requires the assessment and development of benchmark cases to test model performance as well as a report
comparing model performance and associated periodicity requirements. In our review of the Scope items, we do not find this task. We further note that
if this task is to be done outside of this project, then it should be made clear where this work is being done and this directive should be removed from
the Detail Scope section of the SAR.
{C}·
Item 5 directs the establishment of uniform model verification processes. While we have included this item as being addressed in the
proposed SAR, we do suggest that clearer language be added to certain SAR scope items to strengthen this directive and ensure it will be thoroughly
addressed.
{C}·
Items 4, 8, and 11 all contain directives that address issues with unregistered IBRs yet none of the language in the SAR scope clearly
addresses those entities or the associated NERC obligations. To address this issue, we ask that the SAR be modified to make it clearer where
unregistered IBRs directives are to be addressed.
{C}·
Items 8, and 11 contain directives that address issues with IBR-DERs yet none of the language in the SAR scope clearly address those
entities and the associated NERC obligations. To address this issue, we ask that the SAR be modified to make it clearer where IBR-DERs directives
are to be addressed.
{C}·
Item 8 addresses the verification of aggregated models for unregistered IBRs and IBR-DER that have a material impact on the BPS, but the
proposed SAR contains nothing in the proposed Project Scope that addresses this issue. To address this issue, we suggest adding language to the
proposed scope to address the associated directives on verifying aggregated unregistered IBRs and IBR DERs and the process differences associated

with validating those models.

NV Energy also suggests that Items 9 and 12 be removed from the Detailed Description section of this SAR because the directives contained in these
Items are directives for NERC not the DT.

Next, we offer the following comments on the specifics of the Project Scope items and offer some suggested comments, edits, and deletions that
provide clearer alignment to the directives, noting not all the concerns listed above are reflected in the comments below.

Phase 1 Objectives Comments:
Item 1: NV Energy is concerned that some of the suggested changes under the Item 1 work scope, which aligns to MOD-033 seem to confuse the
intent of this Reliability Standard. Specifically, MOD-033 is intended to validate resource models against actual system events/data, whereas MOD-026
and MOD-027 are intended to verify individual resource models in dynamic simulations. We additionally ask that the phrase “actual performance data”
be clarified, noting this is an undefined term and could be understood to mean many things. To address the clarity issue of Item 1 we suggest the
following edits in boldface below:
Either revise MOD-033 or create a new IBR model system model validation Reliability Standard that more accurately validates IBR performance
within those interconnected transmission system studies to require model validation using actual performance data.

Item 1a: NV Energy suggests not using the phrase “validation expectations” because the phrase has no meaning in the context of a NERC Reliability
Standard. Noting an expectation is not a requirement. NV ENERGY also suggests that given MOD-033 is the focus of Item 1, it is important to maintain
context that MOD-033 is focused specifically on validating resource performance within system models. Verifying the accuracy of IBR models should
be conducted under the new Reliability Standard that would be created under Item 2. We additionally suggest adding aggregated IBR models for nonregistered IBR and IBR-DERs that have a material impact on the BPS because both need to be validated within MOD-033. Furthermore, additional
clarity is needed regarding what performance data is going to be available for the aggregated unregistered IBRs and IBR DERs that have a material
impact, while registered IBR owners will have specific data requirements through PRC-028, we are unaware of similar requirements for unregistered
resources. To address all but the performance data issues for unregistered resources, we offer the following suggested changes in boldface for Item
1a:
include a complete set of validation expectations criteria for validating system planning models that requires assessing and validating IBR
performance, as well as assessing the impact of both unregistered IBRs (in aggregate) and IBR-DERs (in aggregate) that have been identified
as having a material impact on the BPS through the use of using performance data (must include performance data of IBR during disturbances as
well as other performance measures);
Item 1b: NV Energy suggest deleting item 1b because it is unnecessary to include language within a NERC Reliability Standard that simply asks for
accurate and high-quality standards.
Item 1c: As stated above, we suggest that the term “performance data” be clarified.
Item 1d: Suggest deleting Item 1d because it lacks clarity about what the DT is expected to do to fulfill this item. Moreover, we understand Phase 2 is
necessary to fulfill other Milestones not Milestone 3, Part 2 and therefore should not be included in this SAR.
Item 1e: The SAR should not attempt to prescriptively define how system planning models are to be validated. The DT should only develop
requirements that obligate Planning Coordinators to have processes in place that validate IBR models within system planning models and include
methods to reconcile any model issues with resource owners (i.e., IBR-GOs).

include requirements that ensure Planning Coordinators have processes in place that can identify IBR model problems within system
planning models and requirements for insuring IBR GOs are held accountable for providing updated models that more accurately validate
IBR performance against actual performance data. minimum criteria for performing validation (e.g., time, tolerance, impact);
Item 1f: NV Energy does not agree with Item 1f. As stated in paragraph 143 of FERC Order 901, what is required is the development of a new or
revised Reliability Standard that establishes “uniform model verification processes” not specific performance criteria. For this reason, we suggest
deleting Item 1f because this item goes beyond what was directed by the Commission.
Item 1g: NV Energy supports requirements that include expanded communication processes that obligate IBR owners and planners to cooperatively
communicate to resolve issues with IBR model validation. However, we do not support including “performance criteria” because that is not what Order
901 directed. For this reason, we suggest the following changes to Item 1g:
Include Require requirements that obligate planner and operators to incorporate in their model verification processes documented
communications with communicate any performance criteria to Generator Owners IBR owners to address deficiencies in IBR models.
Include requirements for IBR owners to provide timely updates to their IBR models in response to issues identified in communications from
planners and operators.
Item 1h: This item should be deleted because none of the directives associated with this project include the establishment of “performance criteria”,
what is directed is the development of processes to validate IBR models. The development of performance criteria goes beyond the directives of FERC
Order 901.
Item 1i: NV Energy believes that trying to add considerations for other future work overly complicates this project. Consider deleting this item.
Item 1j: NV Energy does not agree that the use of Corrective Action Plans is the right tool for addressing issues with IBR model performance within
dynamic simulations (New Standard) and system planning models (MOD-033 or New Reliability Standard). Instead, we suggest that the DT develop
requirements in that model some of the processes successfully used in MOD-026 & MOD-027 for synchronous resources but tailored to the model
verification process needs of for both individual IBRs and aggregated IBR resources.

Item 2:
NV Energy suggests Items 1 & 2 do not fully capture the directives identified in FERC Order 901 specific to model verification. We also suggest that
Item 2 should more clearly capture all the directives noted in FERC Order 901 specific to model verification (see Items 5, 6, & 7). To address these
directives, we offer the following:
Develop a new or revised Reliability Standard that address IBR model verification processes that:
{C}·

Establishes uniform processes regardless of the IBR type; and

{C}·

Provides consistency among verification processes with other NERC Reliability Standards; and

{C}·

Contains process timelines consistent with FERC Order No. 2023 modeling deadline requirements; and

{C}·

Removes IBRs from MOD-026 and MOD-027.

Item 3: No suggested changes.

Item 4 (Phase 2):
NV Energy does not agree that there is any benefit in adding scope items that fall outside of Milestone 3 at this time. The scope is already very large

and including Phase 2 work that is so prescriptive and speculative when it is not clear exactly what additional work will be necessary does not add to the
SAR and may only delay approval of the SAR. NV Energy recognizes that additional work will be needed to address all the directives in FERC Order
901, but it is more important at this time to address those directives identified as Milestone 3. There will be plenty of time to add additional scope later.
For these reasons we suggest deleting the Phase 2 work and submitting a revised SAR later to address this work.

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Response
Daniel Gacek - Exelon - 1,3
Answer
Document Name
Comment
In Project Scope, Phase 2, Section 4c, clarify the action to be taken if performance data (of IBR during disturbances...) if no such events have taken
place. Consider defining performance data as performance during disturbances combined with performance during staged testing.
In Detailed Description, Sections 3 and 9, registered entities may be limited in some case with the quality and level of fidelity that can be provided of the
dynamic behavior of existing, unregistred IBR and IBR-DER resources.
Additionally, Exelon support the concerns expressed in the EEI comments.
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Response
Bobbi Welch - Midcontinent ISO, Inc. - 2
Answer
Document Name
Comment
MISO supports comments submitted by the ISO/RTO Council (IRC) Standards Review Committee (SRC).
In addition, while the resulting standard may or may not apply directly to the function of Planning Coordinator, MISO requests that Planning
Coordinators be added to the list of functions considered to serve on the Standard Drafting Team due to the role they play in performing wide area
planning studies. (SAR, page 6)
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Response
Steven Rueckert - Western Electricity Coordinating Council - 10, Group Name WECC
Answer
Document Name
Comment
None
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Response
Joseph Gatten - Xcel Energy, Inc. - 1,3,5,6 - MRO,WECC
Answer
Document Name
Comment
Xcel Energy supports the comments of the EEI.
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Response
Scott Thompson - PNM Resources - 1,3,5 - WECC
Answer
Document Name
Comment
MOD-033 is about validating the full system model not a specific generator models. A holistic approach has been cited as the reason to remove IBR
from MOD-026 and Mod-027. Thus, adding IBRs specifically to MOD-033 seems to counter that approach. As does, adding IBR validation during the
interconnection process to FAC-002.. The addition will also put an additional burden on the PC to work with GO for get data for generators that are not
yet in service and may not have an obligation under the NERC standards.
Modeling gaps that exists in the interconnection process needs to be handled through FERC revisions to the interconnection process not through NERC
standards.

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Mark Garza - FirstEnergy - FirstEnergy Corporation - 1,4,5,6, Group Name FE Voter
Answer
Document Name
Comment
FirstEnergy supports EEI's comments which state:
The following comments are intended to address EEI concerns with the Proposed SAR. Our negative response also reflect our opinion that the SAR
needs to be revised prior to final approval.
Detail Description/FERC Order 901 Directives for Milestone 3 Part 2 Comments
While EEI generally agrees that many of the FERC Order 901 directives allocated to this project are reflected in this proposed Project Scope (i.e., Items
1, 3, 5, 6, 7, & 10), we do not agree the following directives have been sufficiently addressed in the SAR:
Note: Item numbers below align with those contained in the Detailed Description Section of the SAR.
Item 2 contains a directive that requires the assessment and development of benchmark cases to test model performance as well as a report
comparing model performance and associated periodicity requirements. In our review of the Scope items, we do not find this task. We further note that
if this task is to be done outside of this project, then it should be made clear where this work is being done and this directive should be removed from
the Detail Scope section of the SAR.
Item 5 directs the establishment of uniform model verification processes. While we have included this item as being addressed in the proposed SAR,
we do suggest that clearer language be added to certain SAR scope items to strengthen this directive and ensure it will be thoroughly addressed.
Items 4, 8, and 11 all contain directives that address issues with unregistered IBRs yet none of the language in the SAR scope clearly addresses those
entities or the associated NERC obligations. To address this issue, we ask that the SAR be modified to make it clearer where unregistered IBRs
directives are to be addressed.
Items 8, and 11 contain directives that address issues with IBR-DERs yet none of the language in the SAR scope clearly address those entities and the
associated NERC obligations. To address this issue, we ask that the SAR be modified to make it clearer where IBR-DERs directives are to be
addressed.
Item 8 addresses the verification of aggregated models for unregistered IBRs and IBR-DER that have a material impact on the BPS, but the proposed
SAR contains nothing in the proposed Project Scope that addresses this issue. To address this issue, we suggest adding language to the proposed
scope to address the associated directives on verifying aggregated unregistered IBRs and IBR DERs and the process differences associated with
validating those models.
EEI also suggests that Items 9 and 12 be removed from the Detailed Description section of this SAR because the directives contained in these Items
are directives for NERC not the DT.
Next, we offer the following comments on the specifics of the Project Scope items and offer some suggested comments, edits, and deletions that
provide clearer alignment to the directives, noting not all of the concerns listed above are reflected in the comments below.

Phase 1 Objectives Comments:
Item 1: EEI is concerned that some of the suggested changes under the Item 1 work scope, which aligns to MOD-033 seem to confuse the intent of this
Reliability Standard. Specifically, MOD-033 is intended to validate resource models against actual system events/data, whereas MOD-026 and MOD027 are intended to verify individual resource models in dynamic simulations. We additionally ask that the phrase “actual performance data” be
clarified, noting this is an undefined term and could be understood to mean many things. To address the clarity issue of Item 1 we suggest the following
edits in boldface below:
Either revise MOD-033 or create a new IBR model system model validation Reliability Standard that more accurately validates IBR performance
within those interconnected transmission system studies to require model validation using actual performance data.
Item 1a: EEI suggests not using the phrase “validation expectations” because the phrase has no meaning in the context of a NERC Reliability
Standard. Noting an expectation is not a requirement. EEI also suggests that given MOD-033 is the focus of Item 1, it is important to maintain context
that MOD-033 is focused specifically on validating resource performance within system models. Verifying the accuracy of IBR models should be
conducted under the new Reliability Standard that would be created under Item 2. We additionally suggest adding aggregated IBR models for nonregistered IBR and IBR-DERs that have a material impact on the BPS because both need to be validated within MOD-033. Furthermore, additional
clarity is needed regarding what performance data is going to be available for the aggregated unregistered IBRs and IBR DERs that have a material
impact, while registered IBR owners will have specific data requirements through PRC-028, we are unaware of similar requirements for unregistered
resources. To address all but the performance data issues for unregistered resources, we offer the following suggested changes in boldface for Item
1a:
include a complete set of validation expectations criteria for validating system planning models that requires assessing and validating IBR
performance, as well as assessing the impact of both unregistered IBRs (in aggregate) and IBR-DERs (in aggregate) that have been identified
as having a material impact on the BPS through the use of using performance data (must include performance data of IBR during disturbances as
well as other performance measures);
Item 1b: EEI suggest deleting item 1b because it is unnecessary to include language within a NERC Reliability Standard that simply asks for accurate
and high quality standards.
Item 1c: As stated above, we suggest that the term “performance data” be clarified.
Item 1d: Suggest deleting Item 1d because it lacks clarity about what the DT is expected to do to fulfill this item. Moreover, we understand Phase 2 is
necessary to fulfill other Milestones not Milestone 3, Part 2 and therefore should not be included in this SAR.
Item 1e: The SAR should not attempt to prescriptively define how system planning models are to be validated. The DT should only develop
requirements that obligate Planning Coordinators to have processes in place that validate IBR models within system planning models and include
methods to reconcile any model issues with resource owners (i.e., IBR-GOs).
include requirements that ensure Planning Coordinators have processes in place that are capable of identifying IBR model problems within
system planning models and requirements for insuring IBR GOs are held accountable for providing updated models that more accurately
validate IBR performance against actual performance data. minimum criteria for performing validation (e.g., time, tolerance, impact);
Item 1f: EEI does not agree with Item 1f. As stated in paragraph 143 of FERC Order 901, what is required is the development of a new or revised
Reliability Standard that establishes “uniform model verification processes” not specific performance criteria. For this reason, we suggest deleting Item
1f because this item goes beyond what was directed by the Commission.
Item 1g: EEI supports requirements that include expanded communication processes that obligate IBR owners and planners to cooperatively
communicate to resolve issues with IBR model validation. However, we do not support including “performance criteria” because that is not what Order
901 directed. For this reason, we suggest the following changes to Item 1g:
Include Require requirements that obligate planner and operators to incorporate in their model verification processes documented
communications with communicate any performance criteria to Generator Owners IBR owners to address deficiencies in IBR models.
Include requirements for IBR owners to provide timely updates to their IBR models in response to issues identified in communications from

planners and operators.
Item 1h: This item should be deleted because none of the directives associated with this project include the establishment of “performance criteria”,
what is directed is the development of processes to validate IBR models. The development of performance criteria goes beyond the directives of FERC
Order 901.
Item 1i: EEI believes that trying to add considerations for other future work overly complicates this project. Consider deleting this item.
Item 1j: EEI does not agree that the use of Corrective Action Plans is the right tool for addressing issues with IBR model performance within dynamic
simulations (New Standard) and system planning models (MOD-033 or New Reliability Standard). Instead, we suggest that the DT develop
requirements in that model some of the processes successfully used in MOD-026 & MOD-027 for synchronous resources but tailored to the model
verification process needs of for both individual IBRs and aggregated IBR resources.

Establishes uniform processes regardless of the IBR type; and
Provides consistency among verification processes with other NERC Reliability Standards; and
Contains process timelines consistent with FERC Order No. 2023 modeling deadline requirements; and
Removes IBRs from MOD-026 and MOD-027.

Item 3: No suggested changes.

Item 4 (Phase 2):
EEI does not agree that there is any benefit in adding scope items that fall outside of Milestone 3 at this time. The scope is already very large and
including Phase 2 work that is so prescriptive and speculative when it is not clear exactly what additional work will be necessary does not add to the
SAR and may only delay approval of the SAR. EEI recognizes that additional work will be needed to address all of the directives in FERC Order 901,
but it is more important at this time to address those directives identified as Milestone 3. There will be plenty of time to add additional scope later. For
these reasons we suggest deleting the Phase 2 work and submitting a revised SAR at a later date to address this work.
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Response
Cain Braveheart - Bonneville Power Administration - 1,3,5,6 - WECC
Answer
Document Name
Comment

BPA believes the industry will still need IBR model data if IBR applicability was removed from MOD-025/026/027 and PRC-019. BPA believes MOD-033
is not the correct standard to modify. BPA recommends a new suite of standards be created for IBR model verification.
BPA believes MOD-033 should not be modified for the following observations:
Under “Project Scope”, the “Phase 1 Objectives” 1. Says “Either revise MOD-033 or create a new IBR model validation Reliability Standard to require
model validation using actual performance data.” Item ‘b’ says “leverage the most accurate and highest quality model type available”. BPA believes that
according to NERC MOD-033-2 A.1, MOD-033-2 is a system model validation standard. According to A.3., the purpose is to analyze the reliability of the
interconnected transmission system. For Transmission Operators in WECC, using the highest quality model type available could imply using generator
models outside of the WECC base cases (and potentially in a different simulation domain altogether). BPA believes using different models would create
difficulties meeting the purpose of MOD-033-2 because the models validated may differ from those most often used to analyze the reliability of the
interconnected transmission system.
“Project Scope… Phase 1 Objectives:… d” suggests revising MOD-033 to “be designed to follow and be able to leverage new performance validations
expected to be done during the interconnection process…”. The performance validations as part of the interconnection process are also detailed and
local to plants. BPA believes it is unrealistic to validate details of all plants in a system model validation like MOD-033. BPA also believes following
performance validation procedures performed during commissioning for all plants is a separate set of activities than MOD-033 event analysis. BPA
believes leveraging performance validations done during the interconnection process can be helpful, but should not be specifically required for
Transmission Operators to demonstrate the models match actual data for the event and timestamp chosen under MOD-033-2.
MOD-033-2 compliance obligations can be met with one dynamic event and one steady state timestamp. BPA believes including “a complete set of
validation expectations” as in Phase 1 Objectives,1,a seems to imply that all IBR models are getting validated. BPA recognizes the intent to remove
“IBR” from MOD-026/027. If modeling data is still required after being removed from MOD-026/027, BPA recommends data would be best placed in a
standard with a targeted electrical scope, not a system model validation.
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Greg Sorenson - ReliabilityFirst - 10 - RF
Answer
Document Name
Comment
There is some concern about the development of requirements to both create and validate dynamic models for 1) transmission owners that have
unregistered IBRs on their system, and 2) distribution providers that have IBR-DERs on their system. It may be difficult to hold transmission owners and
distribution providers accountable for model creation and validation for unregistered IBRs and IBR-DERs.
It may be challanging for transmission owners to consistently obtain quality IBR data from unregistered entities. Item 141 of FERC Order No. 901 (page
105) contains language that adds caveats to this requirement. “Recognizing that there may be instances in which transmission owners are unable to
gather accurate unregistered IBR modeling data and parameters to create and maintain accurate unregistered IBR dynamic models in their
transmission owner areas, we modify the NOPR proposal and direct NERC to develop new or modified Reliability Standards that require each
transmission owner, if unable to gather accurate unregistered IBR data or unable to gather unregistered IBR data at all, to provide instead to the BulkPower System planners and operators in their areas, dynamic models of unregistered IBRs using estimated data in accordance with this final rule’s
section IV.B.3data sharing directives.” The drafted SAR does not contain this language, but should be amended to have it included for clarity on overall
expectations. This would follow SPIDERWG recommendations for setting the initial parameterization for the DER-A dynamic model based on the
estimated vintage of IEEE 1547 that is dominant in the area. However, setting default parameters based on estimates does not lend itself to successful

validation of the model. RF also does not recommend adjusting model parameters to exactly match real-world measurements during anomalous events,
but rather using these events as an opportunity to adjust.
There are several places in the SAR that uses the terms “in the aggregate have a material impact on the Bulk-Power System” What criteria is being
proposed to define this?
The SAR includes language that directs “NERC to determine the appropriate registered entity responsible for the data and parameters of IBR-DERs” for
those entities that “do not have an associated distribution provider.” Can this be accomplished in a Reliability Standard? Or would this require the review
of a new Registered Function (similar to a Load Serving Entity)?
The SAR states, “Specifically, we direct NERC to develop new or modified Reliability Standards that require planning coordinators, transmission
planners, reliability coordinators, transmission operators, and balancing authorities to establish for each interconnection a uniform framework with
modeling criteria, a registered modeling designee, and necessary data exchange requirements both between themselves and with the generator
owners, transmission owners, and distribution providers to coordinate the creation of transmission planning, operations, and interconnection wide
models (i.e., system models) and the validation of each respective system model.” For the Eastern Interconnection, the MOD-032 designee is presently
the Eastern Interconnection Reliability Assessment Group (ERAG), which is comprised of NERC, MRO, RF, SERC, and NPCC. The SDT should be
made aware of this and strongly consider utilization of the existing MOD-032 designees for each Interconnection.
The SAR also states, “Further, we direct NERC to include in the new or modified Reliability Standards a requirement for generator owners, transmission
owners, and distribution providers to regularly update and communicate the verified data and models of registered IBRs, unregistered IBRs, and IBRDERs by comparing their resulting models against actual operational behavior to achieve and maintain necessary modeling accuracy for inclusion of
these resources in the system models.” It may be impractical to compare all IBR-DER models to actual operational behavior due to the vast number of
connections to the electric grid and operational scenarios. Consideration should be given to the utilization of sampling representative equipment,
configurations, operational conditions, and/or delivery points rather than require the validation of thousands of IBR-DER installations. Will the SDT
recommend different alternatives to achieve this or leave it up to each registered entity?
ReliabilityFirst appreciates the efforts of the drafting team on this important project.
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Mark Gray - Edison Electric Institute - NA - Not Applicable - NA - Not Applicable
Answer
Document Name
Comment
The following comments are intended to address EEI concerns with the Proposed SAR. Our negative response also reflects our opinion that the SAR
needs to be revised prior to final approval.
Detail Description/FERC Order 901 Directives for Milestone 3 Part 2 Comments
While EEI generally agrees that many of the FERC Order 901 directives allocated to this project are reflected in this proposed Project Scope (i.e., Items
1, 3, 5, 6, 7, & 10), we do not agree the following directives have been sufficiently addressed in the SAR:
Note: Item numbers below align with those contained in the Detailed Description Section of the SAR.
Item 2 contains a directive that requires the assessment and development of benchmark cases to test model performance as well as a report

comparing model performance and associated periodicity requirements. In our review of the Scope items, we do not find this task. We further note that
if this task is to be done outside of this project, then it should be made clear where this work is being done and this directive should be removed from
the Detail Scope section of the SAR.
Item 5 directs the establishment of uniform model verification processes. While we have included this item as being addressed in the proposed SAR,
we do suggest that clearer language be added to certain SAR scope items to strengthen this directive and ensure it will be thoroughly addressed.
Items 4, 8, and 11 all contain directives that address issues with unregistered IBRs yet none of the language in the SAR scope clearly addresses those
entities or the associated NERC obligations. To address this issue, we ask that the SAR be modified to make it clearer where unregistered IBRs
directives are to be addressed.
Items 8, and 11 contain directives that address issues with IBR-DERs yet none of the language in the SAR scope clearly address those entities and the
associated NERC obligations. To address this issue, we ask that the SAR be modified to make it clearer where IBR-DERs directives are to be
addressed.
Item 8 addresses the verification of aggregated models for unregistered IBRs and IBR-DER that have a material impact on the BPS, but the proposed
SAR contains nothing in the proposed Project Scope that addresses this issue. To address this issue, we suggest adding language to the proposed
scope to address the associated directives on verifying aggregated unregistered IBRs and IBR DERs and the process differences associated with
validating those models.

EEI also suggests that Items 9 and 12 be removed from the Detailed Description section of this SAR because the directives contained in these Items
are directives for NERC not the DT.
Next, we offer the following comments on the specifics of the Project Scope items and offer some suggested comments, edits, and deletions that
provide clearer alignment to the directives, noting not all of the concerns listed above are reflected in the comments below.
Phase 1 Objectives Comments:
Item 1: EEI is concerned that some of the suggested changes under the Item 1 work scope, which aligns to MOD-033 seem to confuse the intent of this
Reliability Standard. Specifically, MOD-033 is intended to validate resource models against actual system events/data, whereas MOD-026 and MOD027 are intended to verify individual resource models in dynamic simulations. We additionally ask that the phrase “actual performance data” be
clarified, noting this is an undefined term and could be understood to mean many things. To address the clarity issue of Item 1 we suggest the following
edits in boldface below:
Either revise MOD-033 or create a new system model validation Reliability Standard that more accurately validates IBR performance within those
interconnected transmission system studies using actual performance data.
Item 1a: EEI suggests not using the phrase “validation expectations” because the phrase has no meaning in the context of a NERC Reliability
Standard. Noting an expectation is not a requirement. EEI also suggests that given MOD-033 is the focus of Item 1, it is important to maintain context
that MOD-033 is focused specifically on validating resource performance within system models. Verifying the accuracy of IBR models should be
conducted under the new Reliability Standard that would be created under Item 2. We additionally suggest adding aggregated IBR models for nonregistered IBR and IBR-DERs that have a material impact on the BPS because both need to be validated within MOD-033. Furthermore, additional
clarity is needed regarding what performance data is going to be available for the aggregated unregistered IBRs and IBR DERs that have a material
impact, while registered IBR owners will have specific data requirements through PRC-028, we are unaware of similar requirements for unregistered
resources. To address all but the performance data issues for unregistered resources, we offer the following suggested changes in boldface for Item
1a:
include criteria for validating system planning models that requires assessing and validating IBR performance, as well as assessing the
impact of both unregistered IBRs (in aggregate) and IBR-DERs (in aggregate) that have been identified as having a material impact on the
BPS through the use of using performance data (must include performance data of IBR during disturbances as well as other performance measures);
Item 1b: EEI suggest deleting item 1b because it is unnecessary to include language within a NERC Reliability Standard that simply asks for accurate

and high quality standards.
Item 1c: As stated above, we suggest that the term “performance data” be clarified.
Item 1d: Suggest deleting Item 1d because it lacks clarity about what the DT is expected to do to fulfill this item. Moreover, we understand Phase 2 is
necessary to fulfill other Milestones not Milestone 3, Part 2 and therefore should not be included in this SAR.
Item 1e: The SAR should not attempt to prescriptively define how system planning models are to be validated. The DT should only develop
requirements that obligate Planning Coordinators to have processes in place that validate IBR models within system planning models and include
methods to reconcile any model issues with resource owners (i.e., IBR-GOs).
include requirements that ensure Planning Coordinators have processes in place that are capable of identifying IBR model problems within
system planning models and requirements for insuring IBR GOs are held accountable for providing updated models that more accurately
validate IBR performance against actual performance data.;
Item 1f: EEI does not agree with Item 1f. As stated in paragraph 143 of FERC Order 901, what is required is the development of a new or revised
Reliability Standard that establishes “uniform model verification processes” not specific performance criteria. For this reason, we suggest deleting Item
1f because this item goes beyond what was directed by the Commission.
Item 1g: EEI supports requirements that include expanded communication processes that obligate IBR owners and planners to cooperatively
communicate to resolve issues with IBR model validation. However, we do not support including “performance criteria” because that is not what Order
901 directed. For this reason, we suggest the following changes to Item 1g:
Include Require requirements that obligate planner and operators to incorporate in their model verification processes documented
communications with IBR owners to address deficiencies in IBR models. Include requirements for IBR owners to provide timely updates to
their IBR models in response to issues identified in communications from planners and operators.
Item 1h: This item should be deleted because none of the directives associated with this project include the establishment of “performance criteria”,
what is directed is the development of processes to validate IBR models. The development of performance criteria goes beyond the directives of FERC
Order 901.
Item 1i: EEI believes that trying to add considerations for other future work overly complicates this project. Consider deleting this item.
Item 1j: EEI does not agree that the use of Corrective Action Plans is the right tool for addressing issues with IBR model performance within dynamic
simulations (New Standard) and system planning models (MOD-033 or New Reliability Standard). Instead, we suggest that the DT develop
requirements in that model some of the processes successfully used in MOD-026 & MOD-027 for synchronous resources but tailored to the model
verification process needs of for both individual IBRs and aggregated IBR resources.
Item 2:
EEI suggests Items 1 & 2 do not fully capture the directives identified in FERC Order 901 specific to model verification. We also suggest that Item 2
should more clearly capture all of the directives noted in FERC Order 901 specific to model verification (see Items 5, 6, & 7). To address these
directives, we offer the following:
Develop a new or revised Reliability Standard that address IBR model verification processes that:
•

Establishes uniform processes regardless of the IBR type; and

•

Provides consistency among verification processes with other NERC Reliability Standards; and

•
•

Contains process timelines consistent with FERC Order No. 2023 modeling deadline requirements; and
Removes IBRs from MOD-026 and MOD-027.

Item 3: No suggested changes.

Dislikes

Response
Kyle Thomas - Elevate Energy Consulting - NA - Not Applicable - NA - Not Applicable
Answer
Document Name
Comment
The SAR appears open-ended in terms of proposed revisions, detailed descriptions, and overlap with the other two modeling SARs (Milestone 3 Part 1
SAR and Part 3 SAR) – which are primarily text extracted from FERC Order 901. NERC, the NERC RSTC, the NERC Standards Committee, and
industry have tended to avoid creating new standards projects with open-ended SARs as this shows insufficient supporting evidence and background to
help a small SDT accomplish its mission. This seems particularly relevant given the massive scale, depth, and breadth of these proposed changes and
do not believe this is the most effective/efficient SAR definition to address the directives and reliability risks, as it is unclear what the SARs are actually
addressing from a reliability perspective. It also appears there are some FERC directives that are linked to a reliability risk that needs to be mitigated,
but between this SAR and the other two it is unclear if they are being addressed or not – these risks should be mitigated between these SARs.
In the Purpose or Goal section, this SAR and the Project 2022-02 SAR both state the projects and SDTs will be a clearing house for the modeling work.
It seems having two SARs act as a clearing house for modeling work is not necessary and should be clarified.
In the Project Scope, it is unclear which NERC entities have what roles for each of the IBR categories (registered IBRs, non-registered IBRs, and DERs)
during the interconnection process are applicable to this SAR and the other two modeling related SARs.
In the Detailed Description section, repeating all FERC Order 901 directives in full and then only bolding the specific directives that this SAR addresses
is confusing and inefficient. Recommend deleting all unrelated language and only keeping the specific directives that this SAR is addressing to add
clarity to this SAR.
It seems there has been insufficient attention given to the cost-benefit analysis for this SAR. NERC has simply stated “currently unknown” and did not
provide any additional analysis or consideration for costs and how to minimize such costs across all registered entities involved, except for one mention
of if fewer reoccurring staged tests are performed, which is fairly vague. The vast proposed revisions will significantly increase costs to registered
entities, affecting business operations and costs to consumers. Therefore, more due diligence and consideration should be given to cost across all the
proposed standards projects.
We recommend that the SAR drafting team extend the comment period on this SAR and the other two modeling related SARs until after the July 10
NERC Webinar that will inform the industry further about these three SARs and have a question-and-answer period for attendees. This webinar seems

like it will be very informative and helpful to the industry in understanding these three SARs, which would further support the comment period and
balloting process for getting the SARs approved.
There should be a much clearer linkage to the EMT-related NERC projects and EMT modeling requirements in general, which are the best models and
studies to evaluated IBR ride-through and other technical performance criteria. While FERC did not call out EMT requirements in Order 901, it did
recommend continuing to pursue efforts and those efforts should be closely aligned with this SAR.
Likes

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Response
Anna Todd - Southern Indiana Gas and Electric Co. - 3,5,6 - RF
Answer
Document Name
Comment
Southern Indiana Gas and Electric Company d/b/a CenterPoint Energy Indiana South (SIGE) supports comments submitted by the Edison Electric
Institute (EEI).
Regarding Phase 2 Objectives, SIGE believes that IBR validation requirements during the interconnection process should be addressed within the
Generator Interconnection process itself instead of being addressed within a new or revised standard.
SIGE requests further detail surrounding FERC Order 901 Directive 1 regarding “Bulk-Power System planners and operators to validate registered IBR
models using disturbance monitoring data from installed registered IBR generator owners’ disturbance monitoring equipment”.
Likes

Dislikes

Response
Diana Aguas - CenterPoint Energy Houston Electric, LLC - 1 - Texas RE
Answer
Document Name
Comment
CenterPoint Energy Houston Electric, LLC (CEHE) agrees with the comments as submitted by Edison Electric Institute (EEI) for Phase 1 Objective 1j as
listed below.
EEI Item 1j: EEI does not agree that the use of Corrective Action Plans is the right tool for addressing issues with IBR model performance within
dynamic simulations (New Standard) and system planning models (MOD-033 or New Reliability Standard). Instead, we suggest that the DT develop
requirements in that model some of the processes successfully used in MOD-026 & MOD-027 for synchronous resources but tailored to the model
verification process needs of for both individual IBRs and aggregated IBR resources.

Additionally, CEHE believes the associated cost with the implementation of a new standard with model validation will require Transmission
Owners/Transmission Planners to incur high costs for additional resources to coordinate/validate data in the creation of these interconnection-wide
models.
Likes

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Response
Ijad Dewan - Hydro One Networks, Inc. - 1 - NPCC
Answer
Document Name
Comment
The SAR may clarify model validation by performance data is for what time scale, is it for PSS/E, PSLF type dynamic model only or also include EMT
and short circuit model for IBR?

In related standard list, PRC-028 (new) can be considered, since this SAR is for model validation by performance data, it may consider what data is
available under PRC-028.
Likes

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Response
David Jendras Sr - Ameren - Ameren Services - 1,3,6
Answer
Document Name
Comment
Ameren supports EEI's Comments on this project.
Likes

Dislikes

Response
Ruida Shu - Northeast Power Coordinating Council - 1,2,3,4,5,6,7,8,9,10 - NPCC, Group Name NPCC RSC
Answer

Document Name
Comment
From the proposed SAR, it is not possible to determine if it is intended to address only RMS models or also include EMT models. The scope of the SAR
should be clarified.

Model requirements for existing IBR projects should be addressed by the DT, especially what to do for projects whose manufacturer does not exist
anymore (for instance, propose a library of generic models to use for project owners who cannot provide OEM models, perhaps based on site tests to
determine the parameters to use).

The required testing for model validation needs to be periodic and often enough to reflect software/firmware updates provided by the OEMs for the
inverter controls. These software/firmware updates are expected to be released somewhat frequently over the lifespan of the equipment to provide both
security and performance improvements. The controls of large synchronous generators did not change in any appreciable manner over decades unless
completely replaced, but the functionality of IBR (either intermittent resource or storage-based) can be changed dramatically just by a simple upload of
new firmware.

Item 1d: Suggest deleting Item 1d because it lacks clarity about what the DT is expected to do to fulfill this item.
Item 1 Part F seems to be missing some language since it doesn’t have a complete thought and ends with a “-“ instead of a “;” like the rest of the items.
The model data sharing related to FAC-002 must consider both the models and the model parameters.
Likes

Dislikes

Response
Daniela Atanasovski - APS - Arizona Public Service Co. - 1,3,5,6
Answer
Document Name
Comment
AZPS supports the following comments that were submitted by EEI on behalf of their members:

The following comments are intended to address EEI concerns with the Proposed SAR. Our negative response also reflects our opinion that the SAR
needs to be revised prior to final approval.
Detail Description/FERC Order 901 Directives for Milestone 3 Part 2 Comments
While EEI generally agrees that many of the FERC Order 901 directives allocated to this project are reflected in this proposed Project Scope (i.e., Items

1, 3, 5, 6, 7, & 10), we do not agree the following directives have been sufficiently addressed in the SAR:
Note: Item numbers below align with those contained in the Detailed Description Section of the SAR.
•

•
•
•
•

Item 2 contains a directive that requires the assessment and development of benchmark cases to test model performance as well as a report
comparing model performance and associated periodicity requirements. In our review of the Scope items, we do not find this task. We further
note that if this task is to be done outside of this project, then it should be made clear where this work is being done and this directive should be
removed from the Detail Scope section of the SAR.
Item 5 directs the establishment of uniform model verification processes. While we have included this item as being addressed in the proposed
SAR, we do suggest that clearer language be added to certain SAR scope items to strengthen this directive and ensure it will be thoroughly
addressed.
Items 4, 8, and 11 all contain directives that address issues with unregistered IBRs yet none of the language in the SAR scope clearly
addresses those entities or the associated NERC obligations. To address this issue, we ask that the SAR be modified to make it clearer where
unregistered IBRs directives are to be addressed.
Items 8, and 11 contain directives that address issues with IBR-DERs yet none of the language in the SAR scope clearly address those entities
and the associated NERC obligations. To address this issue, we ask that the SAR be modified to make it clearer where IBR-DERs directives
are to be addressed.
Item 8 addresses the verification of aggregated models for unregistered IBRs and IBR-DER that have a material impact on the BPS, but the
proposed SAR contains nothing in the proposed Project Scope that addresses this issue. To address this issue, we suggest adding language
to the proposed scope to address the associated directives on verifying aggregated unregistered IBRs and IBR DERs and the process
differences associated with validating those models.

EEI also suggests that Items 9 and 12 be removed from the Detailed Description section of this SAR because the directives contained in these Items
are directives for NERC not the DT.
Next, we offer the following comments on the specifics of the Project Scope items and offer some suggested comments, edits, and deletions that
provide clearer alignment to the directives, noting not all of the concerns listed above are reflected in the comments below.
Phase 1 Objectives Comments:
Item 1: EEI is concerned that some of the suggested changes under the Item 1 work scope, which aligns to MOD-033 seem to confuse the intent of this
Reliability Standard. Specifically, MOD-033 is intended to validate resource models against actual system events/data, whereas MOD-026 and MOD027 are intended to verify individual resource models in dynamic simulations. We additionally ask that the phrase “actual performance data” be
clarified, noting this is an undefined term and could be understood to mean many things. To address the clarity issue of Item 1 we suggest the following
edits below:
Either revise MOD-033 or create a new system model validation Reliability Standard that more accurately validates IBR performance within those
interconnected transmission system studies using actual performance data.
Item 1a: EEI suggests not using the phrase “validation expectations” because the phrase has no meaning in the context of a NERC Reliability
Standard. Noting an expectation is not a requirement. EEI also suggests that given MOD-033 is the focus of Item 1, it is important to maintain context
that MOD-033 is focused specifically on validating resource performance within system models. Verifying the accuracy of IBR models should be
conducted under the new Reliability Standard that would be created under Item 2. We additionally suggest adding aggregated IBR models for nonregistered IBR and IBR-DERs that have a material impact on the BPS because both need to be validated within MOD-033. Furthermore, additional
clarity is needed regarding what performance data is going to be available for the aggregated unregistered IBRs and IBR DERs that have a material
impact, while registered IBR owners will have specific data requirements through PRC-028, we are unaware of similar requirements for unregistered
resources. To address all but the performance data issues for unregistered resources, we offer the following suggested changes in boldface for Item
1a:
include criteria for validating system planning models that requires assessing and validating IBR performance, as well as assessing the impact of both
unregistered IBRs (in aggregate) and IBR-DERs (in aggregate) that have been identified as having a material impact on the BPS through the use of
performance data (must include performance data of IBR during disturbances as well as other performance measures);

Item 1b: EEI suggest deleting item 1b because it is unnecessary to include language within a NERC Reliability Standard that simply asks for accurate
and high quality standards.
Item 1c: As stated above, we suggest that the term “performance data” be clarified.
Item 1d: Suggest deleting Item 1d because it lacks clarity about what the DT is expected to do to fulfill this item. Moreover, we understand Phase 2 is
necessary to fulfill other Milestones not Milestone 3, Part 2 and therefore should not be included in this SAR.
Item 1e: The SAR should not attempt to prescriptively define how system planning models are to be validated. The DT should only develop
requirements that obligate Planning Coordinators to have processes in place that validate IBR models within system planning models and include
methods to reconcile any model issues with resource owners (i.e., IBR-GOs).
include requirements that ensure Planning Coordinators have processes in place that are capable of identifying IBR model problems within system
planning models and requirements for insuring IBR GOs are held accountable for providing updated models that more accurately validate IBR
performance against actual performance data.
Item 1f: EEI does not agree with Item 1f. As stated in paragraph 143 of FERC Order 901, what is required is the development of a new or revised
Reliability Standard that establishes “uniform model verification processes” not specific performance criteria. For this reason, we suggest deleting Item
1f because this item goes beyond what was directed by the Commission.
Item 1g: EEI supports requirements that include expanded communication processes that obligate IBR owners and planners to cooperatively
communicate to resolve issues with IBR model validation. However, we do not support including “performance criteria” because that is not what Order
901 directed. For this reason, we suggest the following changes to Item 1g:
Include requirements that obligate planner and operators to incorporate in their model verification processes documented communications with IBR
owners to address deficiencies in IBR models. Include requirements for IBR owners to provide timely updates to their IBR models in response to issues
identified in communications from planners and operators.
Item 1h: This item should be deleted because none of the directives associated with this project include the establishment of “performance criteria”,
what is directed is the development of processes to validate IBR models. The development of performance criteria goes beyond the directives of FERC
Order 901.
Item 1i: EEI believes that trying to add considerations for other future work overly complicates this project. Consider deleting this item.
Item 1j: EEI does not agree that the use of Corrective Action Plans is the right tool for addressing issues with IBR model performance within dynamic
simulations (New Standard) and system planning models (MOD-033 or New Reliability Standard). Instead, we suggest that the DT develop
requirements in that model some of the processes successfully used in MOD-026 & MOD-027 for synchronous resources but tailored to the model
verification process needs of for both individual IBRs and aggregated IBR resources.
Item 2:
EEI suggests Items 1 & 2 do not fully capture the directives identified in FERC Order 901 specific to model verification. We also suggest that Item 2
should more clearly capture all of the directives noted in FERC Order 901 specific to model verification (see Items 5, 6, & 7). To address these
directives, we offer the following:
Develop a new or revised Reliability Standard that address IBR model verification processes that:
•
•
•
•

Item 3: No suggested changes.

Dislikes

Response
Christy Thompson - PPL - Louisville Gas and Electric Co. - 3,5,6 - SERC
Answer
Document Name
Comment
The FERC Directives assigned to this SAR, as listed in the Detailed Description, are not addressed in a straightforward manner in the Objectives listed
in the Project Scope.
The Directives can be summarized in the following groups:
1. Providing accurate models (Directives 3, 4, and 12)
2. Developing a model verification process (Directives 2, 5, 6, 7, and 9)
3. Performing model validation (Directives 1, 8, 10, and 11)

The first group of Directives regarding the provision or maintenance of updated models is within the scope of MOD-032. Indeed, recent revisions the
MOD-032 have already begun to address these issues, including the party responsible for models of unregistered IBRs and IBR-DERs (Directive 12).
Requirement R1 of MOD-032-2 requires PCs and TPs to develop “modeling data requirements and reporting procedures.” Moreover, Requirement R2
of MOD-032-2 provides a mechanism for the correction of inaccurate models. The DT should not modify MOD-033 or create a new Reliability Standard
that conflicts with or causes confusion with MOD-032. Thus, Directives 3, 4, and 12 should be coordinated appropriately with the DTs working on MOD032.

The second group of Directives require the development of a model verification process. MOD-026 and MOD-027 already provide a framework for
model verification that has been effective for synchronous generators. While the DT may consider a new standard for a model verification process due
to some of the particular concerns of IBRs and IBR-DERs, there are several issues with the DT’s Objectives:
• Objective 1 identifies MOD-033 as a potential standard to revise. MOD-033 pertains exclusively model validation against actual system
events/data. It is critical to understand the distinction between MOD-033 and MOD-026/027 in this regard.
• Objective 1(a) is a potential over-reach of FERC’s Directives in its requirement of a “complete set of validation expectations”.
• Objective 1(b) again over-specifies and is unnecessary. PCs and TPs should develop model requirements and verification processes including

the specification of required models and model types. Moreover, the “highest quality model type available” depends on the simulation being performed.
EMT models have the potential for much higher accuracy than RMS models, but they cannot be used in interconnection-wide base cases. Again, PCs
and TPs must have the flexibility to develop requirements on when each type of model should be used.
• Objective 1(d) introduces confusion between staged testing and system event response. The process used to validate models in interconnection
studies or in plant commissioning is not suitable to be “followed” in validations against system event data.
• Objective 1(e) again over-reaches the FERC Directives. TPs are already required to justify their verification requirements through MOD-026 and
MOD-027 (see Requirements R3 and R6). These processes are sufficient today, and the SAR scope should be modified to permit a similar process for
IBRs. It should also be noted that the diverse and expert team developing IEEE Std 2800-2022 was unable to come to a consensus on what constitutes
an acceptable “match” for model validation.
• Objective 1(f) is related to Objective 1(e). The FERC Directives only call for the Reliability Standard to address the development of a model
verification process. The Directives do not call on NERC to establish minimum criteria for validation allowing TPs and TOs “some” flexibility.
• Objective 1(h) is related to Objective 1(e) and 1(f). Again, the DT is not responsible for establishing criteria, nor does the DT have responsibility to
ensure TP or TO criteria is risk-based and region-specific. The DT is only tasked with developing or modifying a Reliability Standard to accomplish the
FERC Directives, none of which require the establishment of specific performance criteria.
• Objective 1(j) needs to be removed. The development of CAPs for failed model validation is inconsistent with MOD-026/027. While a mitigation
process should be defined, this process should not amount to a CAP.

The third group of Directives require model validation to be performed against actual system data. These Directives are consistent with the purpose of
MOD-033 and may be adequately addressed by minor revisions to that standard. Specifically, Directive 1 requires model validations against disturbance
data “from installed registered IBR generator owners’ disturbance monitoring equipment,” however provision of data from these entities is not covered
by Requirement R2.

Given the issues and concerns presented above, it is recommended that the DT replace Objective 1 of the SAR with three items better aligned to
FERC’s Directives. Below is a suggested structure:

1. Coordinate with the DT assigned to Project 2022-02 and any other DTs working on revisions to MOD-032 to ensure that:
a. Generator owners of registered IBRs, transmission owners that have unregistered IBRs on their system, and distribution providers that have IBRDERs on their system to provide models that represent the dynamic behavior of these IBRs.
b. Provided models are at a sufficient level of fidelity to provide to Bulk-Power System planners and operators to perform valid interconnection-wide,
planning, and operational studies on a basis comparable to synchronous generation resources.
c. Provided models accurately represent the dynamic performance of registered and unregistered IBRs, including momentary cessation and/or tripping,
and all ride through behavior.
2. Either revise MOD-026 and MOD-027 or create a new Reliability Standard to require a model verification process that:
a. Determines whether the development of benchmark cases to test model performance and a subsequent report comparing model performance are
needed and at what periodicity.
b. Provides a uniform model verification process that creates consistency among the model verification processes for existing and any new or modified
Reliability Standards.

c. Utilizes a timeline consistent with FERC Order No. 2023 modeling deadline requirements.
d. Requires identified registered entities to coordinate, validate, and keep up to date their models.
3. Revise MOD-033 to ensure that:
a. Registered IBR models can be validated using disturbance monitoring data from installed registered IBR generator owners’ disturbance monitoring
equipment.
b. All generator owner, transmission owner, and distribution provider verified IBR models (i.e., models of registered IBRs, unregistered IBRs, and IBRDERs that in the aggregate have a material impact on the Bulk-Power System) and resulting system models are validated against actual system
operational behavior.

Regarding Phase 2 Objective 4, the opportunity to do model verification using “actual performance data” “during the interconnection process” is
extremely limited. Most model verification during the interconnection process is aimed at ensuring consistency in submitted data, adherence to model
requirements, and evaluation of model performance. Only during the plant commissioning process is there an opportunity to validate models against
“actual performance data” (in this case, from staged testing). Specific notes on the sub-items of Objective 2 follow:
• Items (a), (b), (e), (f), and (g) are also included under Objective 1, and the comments made on those items previously also apply under Objective
2.
• Item (c) is beyond the scope of FAC-002, and is covered by Phase 1 of this SAR. FAC-002 should remain focused on studies during the
interconnection process, and allow other standard to address “post-interconnection validations” (as they already do).
• Item (d) does not make sense in the context of Objective 2 as the Objective pertains to the development of the validation process that item (d)
says to leverage.
• Item (h) should also be removed as CAPs should not apply to facilities that are not yet commercially operational, and model verification should be
required in the interconnection process prior to commercial operation.
Likes

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Response
Hayden Maples - Evergy - 1,3,5,6 - MRO
Answer
Document Name
Comment
Evergy supports and incorporates by reference the comments of the Edison Electric Institute (EEI) on question 2
Likes

Dislikes
Response

Pamela Hunter - Southern Company - Southern Company Services, Inc. - 1,3,5,6 - SERC, Group Name Southern Company
Answer
Document Name
Comment
Condensation of the document is needed. Only the specific actions to be taken by the standard drafting team need to be included in the Purpose or
Goal, Project Scope, and Detailed Description sections. The remainder of the background information needs to be removed from the SAR.
We provide the following additional comments for consideration:
a. IBR manufacturer-specific user written models are unique to each facility. These models require a significant investment of time and money to
develop/test/validate and therefore sharing of such OEM proprietary models is unlikely. The NAGF proposes that NERC consider developing model
specifications as a method for determining the most appropriate models for industry to use.
b. The NAGF notes that current IBR models do not accurately represent momentary cessation/tripping and ride through behavior.
Likes

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Response
Wayne Sipperly - North American Generator Forum - 5 - MRO,WECC,Texas RE,NPCC,SERC,RF
Answer
Document Name
Comment
The NAGF provides the following additional comments for consideration:
a. The NAGF recommends that the SAR identify actions to be performed by the Drafting Team. Including unapplicable/background narrative from
FERC Order 901 directives in the SAR only adds confusion and uncertainty as to the actions to be performed by the DT.
b. Project Scope Phase 1 Objectives (pages 2-3) – The NAGF notes that every time a system disturbance occurs, there is the possibility that an IBR
model will need to be revised to accurately reflect actual IBR facility response. IBR facilities reaction to system conditions/disturbances will vary due to
the type of system disturbance experienced. Trying to modify IBR models to replicate actual IBR performance for all types of system events is not
feasible and would be an inefficient use of limited GO/GOP resources.
c.
The NAGF notes that this project and other IBR related projects being fast tracked will apply to registered IBR, unregistered IBRs and IBR-DER.
However, the new entry IBR facilities have yet to be identified and therefore are not stakeholders participating in the development process for NERC
IBR related projects. This is unacceptable and must be addressed by NERC ASAP.
Likes

Dislikes
Response

Junji Yamaguchi - Hydro-Quebec (HQ) - 1,5
Answer
Document Name
Comment
From the proposed SAR, it is not possible to determine if it is intended to address only RMS models or also include EMT models. The scope of the SAR
should be clarified.

Dislikes

Response
Rachel Coyne - Texas Reliability Entity, Inc. - 10
Answer
Document Name
Comment
Texas RE supports the development of a new IBR model validation Reliability Standard and the phase 1 objectives.

Texas RE encourages the drafting team to consider that the initial model should be developed based on staged testing to establish a baseline model
data. These data parameters should be verified at the Point of Interconnection through field testing at individual unit model and aggregated unit models
to accurately represent the actual system operating conditions. Any adjustments to the model parameters should be done to meet the Transmission
Planner or Planning Coordinator’s requirements.

Periodic model validations must be conducted based on actual performance data from disturbance events or periodic testing timeframe to verify that the
system changes are not impacting the IBR performances.
Likes

Dislikes
Response

Andy Thomas - Duke Energy - 1,3,5,6 - SERC,RF
Answer
Document Name
Comment
Duke Energy agrees with and supports EEI comments for Question 2.
Additionally, Duke Energy submits the following Project Scope comments in addition to EEI comments:
Item 1c: Please clarify the phrase "staged testing".
Item 1j: Suggest the implementation of a hybrid two-stage process that:
(a) initially utilizes requirements that model some of the processes successfully used in MOD-026/027 (and MOD-033) for synchronous resources but
tailored to the model verification process needs of transmission planners for both individual IBRs and aggregated IBR resources, and, (b) transitions to
a CAP if the MOD-026/027/033 efforts are inadequate.
Likes

Dislikes

Response
Chantal Mazza - Hydro-Quebec (HQ) - 1 - NPCC
Answer
Document Name
Comment
From the proposed SAR, it is not possible to determine if it is intended to address only RMS models or also include EMT models. The scope of the SAR
should be clarified.
Model requirements for existing IBR projects should be addressed by the DT, especially what to do for projects whose manufacturer does not exist
anymore (for instance, propose a library of generic models to use for project owners who cannot provide OEM models, perhaps based on site tests to
determine the parameters to use).
The required testing for model validation needs to be periodic and often enough to reflect software/firmware updates provided by the OEMs for the
inverter controls. These software/firmware updates are expected to be released somewhat frequently over the lifespan of the equipment to provide both
security and performance improvements. The controls of large synchronous generators did not change in any appreciable manner over decades unless
completely replaced, but the functionality of IBR (either intermittent resource or storage-based) can be changed dramatically just by a simple upload of
new firmware.
Item 1d: Suggest deleting Item 1d because it lacks clarity about what the DT is expected to do to fulfill this item.
Item 1 Part F seems to be missing some language since it doesn’t have a complete thought and ends with a “-“ instead of a “;” like the rest of the items.
The model data sharing related to FAC-002 must consider both the models and the model parameters.

Likes

Dislikes

Response
Rachel Schuldt - Black Hills Corporation - 1,3,5,6, Group Name Black Hills Corporation - All Segments
Answer
Document Name
Comment
Black Hills Corporation agrees with additional comments from NAGF and EEI, as follows:

The NAGF provides the following additional comments for consideration:
a.
The NAGF recommends that the SAR identify actions to be performed by the Drafting Team. Including unapplicable/background narrative from
FERC Order 901 directives in the SAR only adds confusion and uncertainty as to the actions to be performed by the DT.
b.
Project Scope Phase 1 Objectives (pages 2-3) – The NAGF notes that every time a system disturbance occurs, there is the possibility that an IBR
model will need to be revised to accurately reflect actual IBR facility response. IBR facilities reaction to system conditions/disturbances will vary due to
the type of system disturbance experienced. Trying to modify IBR models to replicate actual IBR performance for all types of system events is not
feasible and would be an inefficient use of limited GO/GOP resources.
c.
The NAGF notes that this project and other IBR related projects being fast tracked will apply to registered IBR, unregistered IBRs and IBR-DER.
However, the new entry IBR facilities have yet to be identified and therefore are not stakeholders participating in the development process for NERC
IBR related projects. This is unacceptable and must be addressed by NERC ASAP.

EEI provides the following additional comments for consideration:
While EEI generally agrees that many of the FERC Order 901 directives allocated to this project are reflected in this proposed Project Scope, when EEI
edits are included (i.e., Items 1, 3, 5, 6, 7, 10, ), we do not agree the following directives have been sufficiently addressed in the SAR:
Note: Item numbers below align with those contained in the Detailed Description Section of the SAR.
· Item 2 contains a directive that requires the assessment and development of benchmark cases to test model performance as well as a report
comparing model performance and associated periodicity requirements. In our review of the Scope items, we do not find this task. We further note that
if this task is to be done outside of this project, then it should be made clear where this work is being done and this directive should be removed from
the Detail Scope section of the SAR.
· Item 5 directs the establishment of uniform model verification processes. While we have included this item as being addressed in the proposed SAR,
we do suggest that clearer language be added to certain SAR scope items to strengthen this directive and ensure it will be thoroughly addressed.
· Items 4, 8, and 11 all contain directives that address issues with unregistered IBRs yet none of the language in the SAR scope clearly addresses
those entities or the associated NERC obligations. To address this issue, we ask that the SAR be modified to make it clearer where unregistered IBRs

directives are to be addressed.
· Items 8, and 11 contain directives that address issues with IBR-DERs yet none of the language in the SAR scope clearly address those entities and
the associated NERC obligations. To address this issue, we ask that the SAR be modified to make it clearer where IBR-DERs directives are to be
addressed.
· Item 8 addresses the verification of aggregated models for unregistered IBRs and IBR-DER that have a material impact on the BPS, but the proposed
SAR contains nothing in the proposed Project Scope that addresses this issue. To address this issue, we suggest adding language to the proposed
scope to address the associated directives on verifying aggregated unregistered IBRs and IBR DERs and the process differences associated with
validating those models.
EEI also suggests that Items 9 and 12 be removed from the Detailed Description section of this SAR because the directives contained in these Items
are directives for NERC not the DT.
Next, we offer the following comments on the specifics of the Project Scope items and offer some suggested comments, edits, and deletions that
provide clearer alignment to the directives, noting not all of the concerns listed above are reflected in the comments below.
Phase 1 Objectives Comments:
Item 1: Please clarify what is meant by actual performance data, noting this is an undefined term and could be understood to mean many things.
Item 1a: EEI suggests not using the phrase “validation expectations” because the phrase has no meaning in the context of a NERC Reliability
Standard. Noting an expectation is not a requirement. We additionally suggest adding aggregated IBR models for non-registered IBR and IBR-DERs
that have a material impact on the BPS because both need to be validated. Finally, we suggest that the DT clarify the term performance data by
adding “from disturbance monitoring equipment”, unless something else was meant by that term and if so, please clarify the intended meaning. To
address our concerns, we offer the following suggested changes:
Include (remove: a complete set of criteria validation expectations) for validating models received from registered IBR-GOs and TOs (nonregistered aggregated IBRs with material impacts on the BPS) and DPs (aggregated IBR-DERs with material impacts on the BPS) using
performance data from disturbance monitoring equipment (must include performance data of IBR during disturbances as well as other performance
measures);
Item 1b: EEI suggest deleting item 1b because it is unnecessary to include language within a NERC Reliability Standard that simply asks for accurate
and high quality standards.
Item 1c: As stated above, we suggest that the term “performance data” be clarified.
Item 1d: Suggest deleting Item 1d because it lacks clarity about what the DT is expected to do to fulfill this item. Moreover, we understand Phase 2 is
necessary to fulfill other Milestones not Milestone 3, Part 2 and therefore should not be included in this SAR.
Item 1e: The SAR should not attempt to prescriptively define how IBR models are to be validated. The DT should only develop requirements that
obligate transmission planners to have processes for model validation and records to demonstrate they followed those processes.
include requirements that require transmission planners to have processes for model validation that include documentation that those
processes were followed. (remove: minimum criteria for performing validation (e.g., time, tolerance, impact));
Item 1f: EEI does not agree with Item 1f. As stated in paragraph 143 of FERC Order 901, what is required is the development of a new or revised
Reliability Standard that establishes “uniform model verification processes” not specific performance criteria. For this reason, we suggest deleting Item
1f because this item goes beyond what was directed by the Commission.
Item 1g: EEI supports requirements that include expanded communication processes that obligate IBR owners and planners to cooperatively
communicate to resolve issues with IBR model validation. However, we do not support including “performance criteria” because that is not what Order
901 directed. For this reason, we suggest the following changes to Item 1g:

Include (remove: Require) requirements that obligate planner and operators to incorporate in their model verification processes documented
communications with (remove: communicate any performance criteria to Generator Owners) IBR owner to address deficiencies in IBR
models.
Item 1h: This item should be deleted because none of the directives aligned with this project include the establishment of “performance criteria”, what is
directed is the development of processes to validate IBR models. The development of performance criteria goes beyond the directives of FERC Order
901.
Item 1i: EEI believes that trying to add considerations for other future work overly complicates this project. Consider deleting this item.
Item 1j: EEI does not agree that the use of Corrective Action Plans is the right tool for addressing issues with IBR model performance. Instead, we
suggest that the DT develop requirements in a new Reliability Standard that model some of the processes successfully used in MOD-026 & MOD-027
for synchronous resources but tailored to the model verification process needs of transmission planners for both individual IBRs and aggregated IBR
resources.

Item 2:
EEI suggests Items 1 & 2 do not fully capture the directives identified in FERC Order 901 specific to model verification. We also suggest that Item 2
should more clearly capture all of the directives noted in FERC Order 901 specific to model verification (see Items 5, 6, & 7). To address these
directives, we offer the following:
Develop a new or revised Reliability Standard that address IBR model verification processes that:
· Establishes uniform processes regardless of the IBR type; and
· Provides consistency among verification processes with other NERC Reliability Standards; and
· Contains process timelines consistent with FERC Order No. 2023 modeling deadline requirements; and
· Removes IBRs from MOD-026 and MOD-027.

Item 3: No suggested changes.

Likes
Dislikes

0
0

Response
Alison MacKellar - Constellation - 5,6
Answer
Document Name
Comment
NERC needs to find a way to incorporate the intent of this standard into existing/future standards. Competing projects have made it very difficult to track
in conjunction with FERC 901 and areas should be consolidated as much as possible which it sounds the intent of this SAR.
Alison Mackellar on behalf of Constellation Segments 5 and 6
Likes

Dislikes

Response
Stephen Stafford - Georgia Transmission Corporation - 1 - SERC
Answer
Document Name
Comment
•

•

Likes

The developers of the SAR did not answer the question: Are there alternatives (e.g. guidelines, white papers, alerts, etc.) that have been
considered or could meet the objectives? The question should be answered. The answer should paraphrase the following:
o Since the directives of FERC Order 901 instruct NERC to develop new or modified standards, there were no other alternatives
considered.
Regarding the Objective 4 (Either revise FAC-002 or create a new SAR to incorporate similar changes to IBR validation during the
interconnection process or create a new IBR model validation standard to require model validation using actual performance data to validate
model quality during the interconnection process.):
o GTC opposes such a requirement on the basis that you do not have an actual disturbance from which to collect data when the
generator is initially interconnected. Therefore, a staged test should be done by the Generator Owner.
Regarding Directives 3 & 4 which (among other things) require Transmission Owners that have unregistered IBRs on their system to provide
dynamic models that accurately represent the dynamic performance of registered and unregistered IBRs, including momentary cessation and/or
tripping, and all ride through behavior:
o GTC objects to such a requirement; we recommend NERC consider a different approach that places the requirement on the generator
owner.
0

Dislikes

Response
Julie Hall - Entergy - 1,3,6, Group Name Entergy

Answer
Document Name
Comment
Phase1 – Item 1.a – How will actual performance data be useful for IBR validation if no appropriate disturbance (e.g. fault response or steady-state
voltage dip) has occurred near a particular IBR plant?
Phase1 – Item 1.a – Requiring PC validation for faults/events near each of the IBR plants to perform effective model validation (stability, short circuit, &
EMT models) and compare each IBR response against performance criteria is a significant scope addition for MOD-033.
Likes

Dislikes

Response
Joshua London - Eversource Energy - 1,3
Answer
Document Name
Comment
The required testing for model validation needs to be periodic and often enough to reflect software/firmware updates provided by the OEMs for the
inverter controls. These software/firmware updates are expected to be released somewhat frequently over the lifespan of the equipment in order to
provide both security and performance improvements. The controls of large synchronous generators did not change in any appreciable manner over
decades unless completely replaced, but the functionality of IBR (either intermittent resource or storage-based) can be changed dramatically just by a
simple upload of new firmware.

Dislikes

Response
Kimberly Turco - Constellation - 5,6
Answer
Document Name

Comment
NERC needs to find a way to incorporate the intent of this standard into existing/future standards. Competing projects have made it very difficult to track
in conjunction with FERC 901 and areas should be consolidated as much as possible which it sounds the intent of this SAR.

Kimberly Turco on behalf of Constellation Segments 5 and 6
Likes

Dislikes

Response
Jennifer Weber - Tennessee Valley Authority - 1,3,5,6 - SERC
Answer
Document Name
Comment
As with Project 2022-02 (Uniform Modeling Framework for IBR), it’s unreasonable to place requirements on TOs for “unregistered IBRs” as they (the
unregistered IBRs) have no requirements to provide any information (test data, models, etc.) that would allow the TOs to do the things the SAR is
requiring. If the “unregistered IBRs” models are that important to the planning studies, they should have to register and provide required data like
registered generators.
If NERC is going to go down this path such that TO provided models, based on operational data, are acceptable for unregistered IBRs, why can’t the
TOs provide the models for other generators and, thereby, get rid of the requirements for the GOs to provide verified models in MOD-026 and MOD027?
Likes

Dislikes

Response
Mohamad Elhusseini - DTE Energy - Detroit Edison Company - 3,5, Group Name DTE Energy
Answer
Document Name
Comment
What is the threshold for IBR-DER to be required to provide this information to the TO's or DP's. How will this be enforced as it will be the responsibility
of the generator owner/operator of the site to provide the information to the TO/DP
If the GO/GOP does not want to provide the necessary information for whatever reason, the TO/DP should not be considered non-compliant with the
Standard. This needs responsibility needs to be placed on the GO/GOP to provide the information to the TO/DP.

Likes

Dislikes

Response
Jessica Cordero - Unisource - Tucson Electric Power Co. - 1
Answer
Document Name
Comment
TEPC agrees with the following EEI comments: EEI does not agree that the proposed Project SAR is sufficiently clear or covers all of the items listed in
the Detailed Description Section of this SAR and needs further work before this SAR is approved.

Likes

Dislikes

Response
Thomas Foltz - AEP - 3,5,6
Answer
Document Name
Comment
This SAR does not seem to recognize that MOD-026-2 is well along and on track to eventually replace MOD-026-1 and MOD-027-1. If the SAR’s intent
is to remove IBRs from MOD-026-2, that would be a disruption to the progress made by the MOD-026-2 standard drafting team. AEP advises against
redirecting Project 2020-06 SDT in this manner.
MOD-026-2 under draft by the Project 2020-06 SDT already allows for (though is not dependent on) use of performance data as recorded during
system events to verify and validate dynamic modeling, including dynamic modeling of IBRs. Some aspects of this SAR’s phase 1 scope may be
appropriate for the Project 2020-06 SDT to consider but not under MOD-033. MOD-033 is system level model verification and validation, not individual
plant verification and validation. Project 2020-06 should be allowed to proceed with MOD-026-2 under the original plan and SAR. This will cover postcommissioning model verification and validation well enough. The need at present is for IBR dynamic model verification and validation prior to
interconnection to support the interconnection study process. This newly proposed SAR does address that in phase 2 of its scope. However,
introducing model verification and validation (which is a big piece of IEEE 2800.2, now underway) will slow down the interconnection process, which
FERC order 2023 seeks to accelerate. If NERC desires to support interconnection study process with model verification and validation, then the
existing SAR should be revised to merely expand the scope of 2020-06 to encompass pre-commissioning model verification and validation of IBRs and
stay clear of MOD-033 and FAC-002. FAC-002 is concerned with the reliability impact of interconnections and should not get diverted into model
verification and validation and the correcting of substandard IBR performance.
CAPs are typically executed by the same entity who creates the CAP. This SAR mentions corrective action plans devised by TPs and TOPs for GOs
and TOs to execute which is an arrangement that GOs and TOs may not view favorably. At the very least, there would need to be some agreement
between the two parties so that an entity is not expected to execute a CAP that they believe is not practical or feasible.

This SAR seems to seek performance data as recorded during system events as the chief basis on which to validate dynamic modeling. However,
dependence on chance events cannot be the basis for any systematic or periodic validation and should be considered only as a supplemental basis if
suitable events occur. As stated above, MOD-026-2 allows for the use of performance data as recorded during system events to verify and validate
dynamic modeling including dynamic modeling of IBRs but is not dependent on it. AEP believes that the process being defined in MOD-026-2 sets forth
the proper perspective on the use of performance data for model validation.
Likes

Dislikes

Response
Patricia Lynch - NRG - NRG Energy, Inc. - 5,6
Answer
Document Name
Comment
None
Likes

Dislikes

Response

Comments received from Gail Elliott/ITC
1. Are there any areas of concern that duplicative coverage or competing expectations would occur, if so, what are these areas the team should be
aware of when drafting?
Yes
No
Comments: Consideration should be given to the existing MOD-026 Project 2020-06 and other standards to determine if these requirements can be
incorporated into this standard revision. Maintaining a one standard approach should be evaluated for ease in both GOs and TPs making sure
evaluations both by generators and planners of the submitted data.
2. Provide any additional comments for the drafting team to consider, if desired.
Yes
No
Comments: ITC submits following comments:
1. Consider the inclusion of Planning Coordinators as an entity that may be included in the required work.

2. Disturbance Monitoring - Review the requirements in PRC-028 to confirm that no duplication of work will be required for the GOs, including
Category 2 IBRs, for the installation of disturbance monitoring. A consideration if disturbance monitoring should be required for synchronous
machines connected to the 60kV – 100 kV BPS.
The following comments are intended to address ITC’s concerns with the Proposed SAR. Our negative response also reflect our opinion that the SAR needs
to be revised prior to final approval.
Detail Description/FERC Order 901 Directives for Milestone 3 Part 2 Comments
While ITC generally agrees that many of the FERC Order 901 directives allocated to this project are reflected in this proposed Project Scope (i.e., Items 1, 3,
5, 6, 7, & 10), we do not agree the following directives have been sufficiently addressed in the SAR:
Note: Item numbers below align with those contained in the Detailed Description Section of the SAR.
• Item 2 contains a directive that requires the assessment and development of benchmark cases to test model performance as well as a report
comparing model performance and associated periodicity requirements. In our review of the Scope items, we do not find this task. We further
note that if this task is to be done outside of this project, then it should be made clear where this work is being done and this directive should be
removed from the Detail Scope section of the SAR.
• Item 5 directs the establishment of uniform model verification processes. While we have included this item as being addressed in the proposed
SAR, we do suggest that clearer language be added to certain SAR scope items to strengthen this directive and ensure it will be thoroughly
addressed.
• Items 4, 8, and 11 all contain directives that address issues with unregistered IBRs yet none of the language in the SAR scope clearly addresses
those entities or the associated NERC obligations. To address this issue, we ask that the SAR be modified to make it clearer where unregistered
IBRs directives are to be addressed.
• Items 8, and 11 contain directives that address issues with IBR-DERs yet none of the language in the SAR scope clearly address those entities and
the associated NERC obligations. To address this issue, we ask that the SAR be modified to make it clearer where IBR-DERs directives are to be
addressed.
• Item 8 addresses the verification of aggregated models for unregistered IBRs and IBR-DER that have a material impact on the BPS, but the proposed
SAR contains nothing in the proposed Project Scope that addresses this issue. To address this issue, we suggest adding language to the proposed
scope to address the associated directives on verifying aggregated unregistered IBRs and IBR DERs and the process differences associated with
validating those models.
ITC also suggests that Items 9 and 12 be removed from the Detailed Description section of this SAR because the directives contained in these Items are
directives for NERC not the DT.
Next, we offer the following comments on the specifics of the Project Scope items and offer some suggested comments, edits, and deletions that provide
clearer alignment to the directives, noting not all of the concerns listed above are reflected in the comments below.
Phase 1 Objectives Comments:
Item 1: ITC is concerned that some of the suggested changes under the Item 1 work scope, which aligns to MOD-033 seem to confuse the intent of this
Reliability Standard. Specifically, MOD-033 is intended to validate resource models against actual system events/data, whereas MOD-026 and MOD-027
are intended to verify individual resource models in dynamic simulations. We additionally ask that the phrase “actual performance data” be clarified,
noting this is an undefined term and could be understood to mean many things. To address the clarity issue of Item 1 we suggest the following edits in
boldface below:

Either revise MOD-033 or create a new IBR model system model validation Reliability Standard that more accurately validates IBR performance
within those interconnected transmission system studies to require model validation using actual performance data.
Item 1a: ITC suggests not using the phrase “validation expectations” because the phrase has no meaning in the context of a NERC Reliability Standard.
Noting an expectation is not a requirement. ITC also suggests that given MOD-033 is the focus of Item 1, it is important to maintain context that MOD-033 is
focused specifically on validating resource performance within system models. Verifying the accuracy of IBR models should be conducted under the new
Reliability Standard that would be created under Item 2. We additionally suggest adding aggregated IBR models for non-registered IBR and IBR-DERs that
have a material impact on the BPS because both need to be validated within MOD-033. Furthermore, additional clarity is needed regarding what
performance data is going to be available for the aggregated unregistered IBRs and IBR DERs that have a material impact, while registered IBR owners will
have specific data requirements through PRC-028, we are unaware of similar requirements for unregistered resources. To address all but the performance
data issues for unregistered resources, we offer the following suggested changes in boldface for Item 1a:
include a complete set of validation expectations criteria for validating system planning models that requires assessing and validating IBR
performance, as well as assessing the impact of both unregistered IBRs (in aggregate) and IBR-DERs (in aggregate) that have been identified as
having a material impact on the BPS through the use of using performance data (must include performance data of IBR during disturbances as
well as other performance measures);
Item 1b: ITC suggest deleting item 1b because it is unnecessary to include language within a NERC Reliability Standard that simply asks for accurate and
high quality standards.
Item 1c: As stated above, we suggest that the term “performance data” be clarified.
Item 1d: Suggest deleting Item 1d because it lacks clarity about what the DT is expected to do to fulfill this item. Moreover, we understand Phase 2 is
necessary to fulfill other Milestones not Milestone 3, Part 2 and therefore should not be included in this SAR.
Item 1e: The SAR should not attempt to prescriptively define how system planning models are to be validated. The DT should only develop requirements
that obligate Planning Coordinators to have processes in place that validate IBR models within system planning models and include methods to reconcile
any model issues with resource owners (i.e., IBR-GOs).
include requirements that ensure Planning Coordinators have processes in place that are capable of identifying IBR model problems within
system planning models and requirements for insuring IBR GOs are held accountable for providing updated models that more accurately
validate IBR performance against actual performance data. minimum criteria for performing validation (e.g., time, tolerance, impact);
Item 1f: ITC does not agree with Item 1f. As stated in paragraph 143 of FERC Order 901, what is required is the development of a new or revised Reliability
Standard that establishes “uniform model verification processes” not specific performance criteria. For this reason, we suggest deleting Item 1f because
this item goes beyond what was directed by the Commission.
Item 1g: ITC supports requirements that include expanded communication processes that obligate IBR owners and planners to cooperatively communicate
to resolve issues with IBR model validation. However, we do not support including “performance criteria” because that is not what Order 901 directed. For
this reason, we suggest the following changes to Item 1g:
Include Require requirements that obligate planner and operators to incorporate in their model verification processes documented
communications with communicate any performance criteria to Generator Owners IBR owners to address deficiencies in IBR models. Include
requirements for IBR owners to provide timely updates to their IBR models in response to issues identified in communications from planners
and operators.
Item 1h: This item should be deleted because none of the directives associated with this project include the establishment of “performance criteria”, what
is directed is the development of processes to validate IBR models. The development of performance criteria goes beyond the directives of FERC Order
901.

Item 1i: ITC believes that trying to add considerations for other future work overly complicates this project. Consider deleting this item.
Item 1j: ITC does not agree that the use of Corrective Action Plans is the right tool for addressing issues with IBR model performance within dynamic
simulations (New Standard) and system planning models (MOD-033 or New Reliability Standard). Instead, we suggest that the DT develop requirements in
that model some of the processes successfully used in MOD-026 & MOD-027 for synchronous resources but tailored to the model verification process
needs of for both individual IBRs and aggregated IBR resources.
Item 2:
ITC suggests Items 1 & 2 do not fully capture the directives identified in FERC Order 901 specific to model verification. We also suggest that Item 2 should
more clearly capture all of the directives noted in FERC Order 901 specific to model verification (see Items 5, 6, & 7). To address these directives, we offer
the following:
Develop a new or revised Reliability Standard that address IBR model verification processes that:
• Establishes uniform processes regardless of the IBR type; and
• Provides consistency among verification processes with other NERC Reliability Standards; and
• Contains process timelines consistent with FERC Order No. 2023 modeling deadline requirements; and
• Either include the new work required into the new MOD-026 or develop a new standard for this work and remove IBRs from MOD-026 and MOD-027.
Item 3: No suggested changes.
Item 4 (Phase 2):
ITC does not agree that there is any benefit in adding scope items that fall outside of Milestone 3 at this time. The scope is already very large and including
Phase 2 work that is so prescriptive and speculative when it is not clear exactly what additional work will be necessary does not add to the SAR and may
only delay approval of the SAR. ITC recognizes that additional work will be needed to address all of the directives in FERC Order 901, but it is more
important at this time to address those directives identified as Milestone 3. There will be plenty of time to add additional scope later. For these reasons
we suggest deleting the Phase 2 work and submitting a revised SAR at a later date to address this work.

Project 2020-06 Verifications of Models and Data for Generators – IBR Definition

Description of Current Draft

This is the third draft of the proposed Glossary Term posted for formal comment and additional ballot.
Completed Actions

Date

Standards Committee approved Standards Authorization Request (SAR)

September 24, 2020

SAR posted for comment

December 16, 2020 – January 14, 2021

45-day formal comment period with initial ballot

November 16, 2023 – January 9, 2024

45-day formal comment period with additional ballot

February 22 – April 8, 2024

Standards Committee approved Standards Authorization Request (SAR)

May 15, 2024

Anticipated Actions

Date

30-day formal comment period with additional ballot

June 21 – July 22, 2024

10-day final ballot

TBD

NERC Board adoption

August 2025

Project 2020-06 | Draft 3 of IBR Definition
July 2024

Page 1 of 3

Project 2020-06 Verifications of Models and Data for Generators – IBR Definition

New or Modified Term(s) Used in NERC Reliability Standards

Project 2020-06 | Draft 3 of IBR Definition
July 2024

Page 2 of 3

2020-06 Verifications of Models and Data for Generators – IBR Definition

Version History
Version
0

Date
TBD

Project 2020-06 | Draft 3 of IBR Definition
June 2024

Action

Change Tracking

New IBR Definition

Page 3 of 3

Project 2020‐06 Verifications of Models and Data for Generators – IBR Definition

Description of Current Draft
This is the third draft of the proposed Glossary Term posted for a formal comment period and
additional ballot.
Completed Actions

Date

Standards Committee approved Standards Authorization Request (SAR)

September 24, 2020

SAR posted for comment

December 16, 2020 –
January 14, 2021

45‐day formal comment period with initial ballot

November 16, 2023 –
January 9, 2024

45‐day formal comment period with additional ballot

February 22, 2024 – April 8,
2024

Standards Committee approved Standards Authorization Request (SAR)

May 15, 2024

Anticipated Actions

Date

30‐day formal comment period with additional ballot

June 21 – July 19, 2024

10‐day final ballot

TBD

NERC Board adoption

August 2025

Project 2020‐06 | Draft 3 of IBR
Definition July 2024

Page 1 of 3

Project 2020‐06 Verifications of Models and Data for Generators – IBR Definition

New or Modified Term(s) Used in NERC Reliability Standards
This section includes all new or modified terms used in the proposed standard that will be
included in the Glossary of Terms Used in NERC Reliability Standards upon applicable regulatory
approval. The termsterm proposed below isare intended to be used in MOD‐026‐2 and other
inverter‐based resource related standards.
Term(s):

Inverter‐Based Resource (IBR): A plant/facility that is connected to the electric system,
consisting of one or more IBR Unit(s)consisting of individual devices that are capable of
exporting Real Power through a power electronic interface(s) such as an inverter or converter,
and that are operated together as a single resource at a common point of interconnection to
the electric system. IBRs Examples include, but are not limited to, plants/facilities with solar
photovoltaic (PV), Type 3 and Type 4 wind, battery energy storage system (BESS), and fuel cell
devices.
Inverter‐Based Resource Unit (IBR Unit): An individual device that uses a power electronic
interface, such as an inverter or converter, capable of exporting Real Power from a primary
energy source or energy storage system, and that connects at a single point on the collector
system; or a grouping of multiple devices that uses a power electronic interface(s), such as an
inverter or converter, capable of exporting Real Power from a primary energy source or energy
storage system, and that connect together at a single point on the collector system.

Project 2020‐06 | Draft 3 of IBR
Definition July 2024

Page 2 of 3

2020‐06 Verifications of Models and Data for Generators – IBR Definition

Version History
Version

Date

Action

TBD

New IBR Definition

Project 2020‐06 | Draft 3 of IBR
Definition July 2024

Change
Tracking

Page 3 of 3

Implementation Plan

Project 2020-06 Verifications of Models and Data for Generators
Inverter-based Resource Definition
Applicable Standard(s)
•

None

Requested Retirement(s)
•

None

Prerequisite Standard(s)

These standard(s) or definitions must be approved before the Applicable Standard becomes effective:
•

None

Applicable Entities
•

None

New/Modified/Retired Terms in the NERC Glossary of Terms
•

Inverter-Based Resource (IBR)

Background

As multiple standards development projects are actively addressing risks related to inverter-based
generation, NERC evaluated the need for a single standards project to move forward with definitions that
would be leveraged by all other projects. Project 2020-06 was identified as the drafting team (DT) that would
coalesce development efforts for these definitions and coordinate proposed definitions with the other NERC
developers. The DT proposes the two definitions of IBR and IBR Unit to be used in Reliability Standard MOD026-2, as well as other IBR- related standards development projects.
General Considerations
Multiple standards in development will use the definition(s), and the proposed implementation timeframe is
intended to reflect that any one of those standards may be the first to use one or more of the definitions.
Additionally, this implementation plan only affects the date that these new definitions will become effective
terms in the NERC Glossary of Terms. A separate implementation plan will be developed for MOD-026-2,
including requirements that use these proposed definitions.

RELIABILITY | RESILIENCE | SECURITY

Effective Date

The effective date(s) for the proposed definitions for Glossary of Terms are provided below.
Where approval by an applicable governmental authority is required, the proposed definitions shall become
effective on the first day of the first calendar quarter after the applicable governmental authority’s order
approving the definitions, or as otherwise provided for by the applicable governmental authority.
Where approval by an applicable governmental authority is not required, the proposed definitions shall
become effective on the first day of the first calendar quarter after the date the definitions are adopted by
the NERC Board of Trustees, or as otherwise provided for in that jurisdiction.

Implementation Plan for IBR-related Definition
Project 2020-06 Verifications of Models and Data for Generators | July 2024

Technical Rationale

Project 2020-06 Verification of Models and Data for Generators
Inverter-based Resource Definition | July 2024
Inverter-based Resource (IBR) Definition

The drafting team (DT) utilized the IEEE 2800-2022 definitions as an initial basis for the inverter-based
resource terms for the NERC Glossary of Terms and adjusted, as necessary. The DT acknowledges the
efforts of the P2800 Wind and Solar Plant Interconnection Performance Working Group and IEEE members
in developing those definitions. The DT also used recent FERC and NERC documents, which included
inverter-based resource related terms and descriptions, as the basis for the IBR definitions.
The IBR definition is intended to describe technologies that shall be considered IBR. An IBR is defined by
technology, thus voltage connection level (kV), facility capability level (MW/MVA), or other factors do not
impact the inclusion as an IBR. An IBR can be connected to any part the transmission system, subtransmission system, or distribution system. For Reliability Standards that use the IBR term, the
Applicability Section for that Reliability Standard(s) will specify which IBRs are applicable. Each of these
Reliability Standards, including the Applicability Section(s) will be balloted in accordance with the NERC
Rules of Procedure, and the Applicability Section. For example, an Applicability Section may specify that IBR
Facilities (BES), IBRs that are owned by a Generator Owner (Category 2), or IBRs that are operated by a
Generator Operator (Category 2), are considered applicable.
IBRs have commonly been referred to as “generating resources.” An IBR is not a HVDC system (except for a
VSC HVDC with a dedicated connection to an IBR, as this is part of the IBR facility), stand-alone flexible ac
transmission systems (FACTS) (e.g., static synchronous compensators (STATCOM) and static VAR
compensators (SVC)), or any resources that are not inverter-based, e.g., gas and steam power plants with
synchronous generators. A list of IBRs is provided in Table 1 below.
IBRs may include any hybrid combination of IBR types (e.g., BESS and solar PV). IBRs also include co-located
portions of a facility that are IBR technologies (e.g., a BESS, which is co-located at synchronous generation
facility), see table below.
Examples
IBR
•
•
•
•
•
•
•
•
•

Not an IBR
•
•
•
•
•
•
•

Stand-alone FACTS device (e.g., STATCOM or SVC)
Flywheels
Synchronous generator
Synchronous condenser
VSC HVDC
LCC HVDC
This is not an all-inclusive list.

RELIABILITY | RESILIENCE | SECURITY

An inverter is a power electronic device that inverts DC power to AC sinusoidal power. A rectifier is a power
electronic device that rectifies AC sinusoidal power to DC power. A converter is a power electronic device
that performs rectification and/or inversion.
Figure 1 shows an example diagram of an IBR. The IBR (red box) includes the IBR Units (blue boxes),
collection system (green boxes), power plant controller(s) (not shown), and reactive resources within the IBR
plant. If the IBR is connected to the electric system via a dedicated voltage source converter high-voltage
direct current (VSC HVDC) system, the VSC HVDC system is part of the IBR.

Project 2020-02 Generator Ride-through (new PRC-029, modified PRC-024)

Technical Rationale for IBR Definition
2020-06 Verification of Models and Data for Generators | July 2024

•

Project 2021-01 Modifications to PRC-019 and MOD-025

•

Project 2021-04 Modifications to PRC-002 (new PRC-028)

•

Project 2022-04 EMT Modeling

•

Project 2023-01 EOP-004 IBR Event Reporting

•

Project 2023-02 Analysis and Mitigation of BES Inverter-Based Resource Performance Issues (new
PRC-030)

Distributed Energy Resources (DER) related projects that may or may not need to use IBR (if they end up
with their own definition)
•

Project 2022-02 Modifications to TPL-001 and MOD-032 (DER)

•

Project 2023-05 FAC-001/FAC-002 DER

•

Project 2023-08 MOD-031 Demand and Energy (DER)

Technical Rationale for IBR Definition
2020-06 Verification of Models and Data for Generators | July 2024

Unofficial Comment Form

Project 2020-06 Verification of Models and Data for Generators
Inverter-based Resource-related Definition
Do not use this form for submitting comments. Use the Standards Balloting and Commenting System
(SBS) to submit comments on draft three of the Inverter-based Resource (IBR)-related Glossary Term by
8 p.m. Eastern, Monday, August 12, 2024.
m. Eastern, Thursday, August 20, 2015

Additional information is available on the project page. If you have questions, contact Standards Developer,
Josh Blume (via email).
Background

The NERC IBR Performance Task Force (IRPTF) performed a comprehensive review of all NERC Reliability
Standards to identify any potential gaps and/or improvements. The IRPTF discovered several issues as part
of this effort and documented its findings and recommendations in the IRPTF Review of NERC Reliability
Standards White Paper, which was approved in March 2020 by the Operating Committee and the Planning
Committee (now part of the Reliability and Security Technical Committee (RSTC)). Among the findings
noted in the white paper, the IRPTF identified issues with MOD-026-1 and MOD-027-1 that should be
addressed by a project. The RSTC endorsed the standard authorization request (SAR) June 10, 2020.
The Standards Committee accepted two revised SARs at its July 21, 2021 meeting. The scope of the project
includes the potential to add, modify, or retire Glossary Terms for NERC Reliability Standards. The term IBR
originally gained industry approval during the initial ballot, but due to a term within the definition that was
not accepted, the IBR definition would be unenforceable. The Project 2020-06 drafting team (DT) proposes
a new term as part of this formal comment and additional ballot period.
Please provide your responses to the questions listed below, along with any detailed comments.
Questions

RELIABILITY | RESILIENCE | SECURITY

Technical Rationale

Project 2020-06 Verification of Models and Data for Generators
Inverter-based Resource Definition | July 2024

Inverter-based Resource (IBR) Definition
The drafting team (DT) utilized the IEEE 2800‐2022 definitions as an initial basis for the inverter‐based
resource terms for the NERC Glossary of Terms and adjusted as necessary. The DT acknowledges the
efforts of the P2800 Wind and Solar Plant Interconnection Performance Working Group and IEEE
members in developing those definitions. The DT also used recent FERC and NERC documents, which
included inverter‐based resource related terms and descriptions, as the basis for the IBR definitions.
The IBR and IBR Unit definitions is are intended to describe technologies that shall be considered IBR and
to distinguish between a unit and resource. An IBR is defined by technology, thus voltage connection level
(kV), facility capability level (MW/MVA), or other factors do not impact the inclusion as an IBR. An IBR can
be connected to any part the transmission system, sub‐transmission system, or distribution system. For a
Reliability Standard(s) that uses either the IBR or IBR Unit terms, the Applicability Section for that
Reliability Standard(s) will specific which IBRs are applicable. Each of these Reliability Standards, including
the Applicability Section(s) will be balloted in accordance with the NERC Rules of Procedure, and the
Applicability Section. For exampleexample, an Applicability Section may specify that IBR Facilities (BES),
IBRs that are owned by a Generator Owner (Category 2), or IBRs that are operated by a Generator
Operator (Category 2), are considered applicable.
IBRs have commonly been referred to as “generating resources.” An IBR is not a HVDC system (except for
a VSC HVDC with a dedicated connection to an IBR, as this is part of the IBR facility), stand‐alone flexible
ac transmission systems (FACTS) (e.g., static synchronous compensators (STATCOM) and static VAR
compensators (SVC)), or any resources that are not inverter‐based, e.g., gas and steam power plants with
synchronous generators. A list of IBRs is provided in Table 1 below.
IBRs may include any hybrid combination of IBR types (e.g., BESS and solar PV), see Ttable 1below.
IBRs also include co‐located portions of a facility that are IBR technologies (e.g., a BESS, which is co‐
located at synchronous generation facility), see Ttable below1.
Examples
IBR
•
•
•

Solar photovoltaic
Type 3 wind
Type 4 wind

Not an IBR
•
•
•

Stand‐alone FACTS device (e.g., STATCOM or SVC)
Flywheels
Synchronous generator

RELIABILITY | RESILIENCE | SECURITY

Examples
IBR
•
•
•
•
•
•

Not an IBR
•
•
•
•

Battery energy storage system (BESS)
Fuel cell(s)
Hybrid combination of IBRs
Portions of co‐located facility that are IBR
VSC HVDC with dedicated connection to IBR
This is not an all‐inclusive list.

Synchronous condenser
VSC HVDC
LCC HVDC
This is not an all‐inclusive list.

Examples of IBRs include:
Inverter‐Based Resource (IBR)
•
•
•
•
•
•
•
•
•

Solar photovoltaic
Type 3 wind
Type 4 wind
Battery energy storage system
(BESS)
Fuel cell(s)
Hybrid combination of IBRs
Portions of co‐located facility
that are IBR
VSC HVDC with dedicated
connection to IBR
This is not an all‐inclusive list.

Not an IBR
•
•
•
•
•
•
•

Stand‐alone FACTS device (e.g.
STATCOM or SVC)
Flywheels
Synchronous generator
Synchronous condenser
VSC HVDC
LCC HVDC
This is not an all‐inclusive list.

Table 1: Inverter‐Based Resource (IBR) examples

An inverter is a power electronic device that inverts DC power to AC sinusoidal power. A rectifier is a
power electronic device that rectifies AC sinusoidal power to DC power. A converter is a power electronic
device that performs rectification and/or inversion.
Figure 1ABC shows an example diagram of an IBR. The IBR (red box) includes the IBR Units (blue boxes),
collection system (green boxes), power plant controller(s) (not shown), and reactive resources within the
Technical Rationale for IBR Definition
2020‐06 Verification of Models and Data for Generators | July 2024

IBR plant. If the IBR is connected to the electric system via a dedicated voltage source converter high‐
voltage direct current (VSC HVDC) system, the VSC HVDC system is part of the IBR.

Figure 12.1 Example diagram of an IBR depicting the IBR (red box), collector system
(green box), and devices IBR Units (blue boxes).
The inclusion of ‘capable of exporting Real Power’ is to clarify that loads connected to the electric
system via power electronics are not IBRs. IBRs are capable of exporting Real Power and may also
be capable of providing Reactive Power. The DT contemplated adding the phrase “may also be
capable of providing Reactive Power” in the definition(s). However, the DT believed this may be
misinterpreted that IBRs include technologies such as FACTS devices or HVDC.
Battery energy storage systems (BESS) are considered IBRs whether the device is operating in a
charging, idle, or discharging mode. Within each Reliability Standard, a DT may draft operating
mode‐specific Requirements, as needed.
The Project 2020‐06 DT intends to use the Glossary Terms of IBR Unit and IBR for MOD‐026‐2.
Additional standards development projects and related standards that may use these defined
terms include:
 Project 2020‐02 Generator Ride‐through (new PRC‐029, modified PRC‐024)
 Project 2021‐01 Modifications to PRC‐019 and MOD‐025
Technical Rationale for IBR Definition
2020‐06 Verification of Models and Data for Generators | July 2024






Project 2021‐04 Modifications to PRC‐002 (new PRC‐028)
Project 2022‐04 EMT Modeling
Project 2023‐01 EOP‐004 IBR Event Reporting
Project 2023‐02 Analysis and Mitigation of BES Inverter‐Based Resource Performance
IssuesPerformance of IBRs (new PRC‐030)
Distributed Energy Resources (DER) related projects that may or may not need to use IBR/IBR Unit
if they end up with their own definition)
 Project 2022‐02 Modifications to TPL‐001 and MOD‐032 (DER)
 Project 2023‐05 FAC‐001/FAC‐002 DER
 Project 2023‐08 MOD‐031 Demand and Energy (DER)

Technical Rationale for IBR Definition
2020‐06 Verification of Models and Data for Generators | July 2024

UPDATED
Standards Announcement

Project 2020-06 Verifications of Models and Data for Generators
Inverter-based Resource Glossary Term
Formal Comment Period Open through August 12, 2024
Now Available

A formal comment period for the Inverter-based Resource Glossary Term is open through 8 p.m.
Eastern, Monday, August 12, 2024.
The standard drafting team’s considerations of the responses received from the previous comment
period are reflected in this draft of the definition.
Reminder Regarding Corporate RBB Memberships

Under the NERC Rules of Procedure, each entity and its affiliates is collectively permitted one voting
membership per Registered Ballot Body Segment. Each entity that undergoes a change in corporate
structure (such as a merger or acquisition) that results in the entity or affiliated entities having more than
the one permitted representative in a particular Segment must withdraw the duplicate membership(s)
prior to joining new ballot pools or voting on anything as part of an existing ballot pool. Contact
[email protected] to assist with the removal of any duplicate registrations.
Commenting

Use the Standards Balloting and Commenting System (SBS) to submit comments. An unofficial Word
version of the comment form is posted on the project page.
•

Contact NERC IT support directly at https://support.nerc.net/ (Monday – Friday, 8 a.m. - 5
p.m. Eastern) for problems regarding accessing the SBS due to a forgotten password,
incorrect credential error messages, or system lock-out.

•

Passwords expire every 6 months and must be reset.

•

The SBS is not supported for use on mobile devices.

•

Next Steps

Additional ballots will be conducted August 2-12, 2024.

RELIABILITY | RESILIENCE | SECURITY

For information on the Standards Development Process, refer to the Standard Processes Manual.
For more information or assistance, contact Standards Developer, Josh Blume (via email) or at 404-4462593. Subscribe to this project's observer mailing list by selecting "NERC Email Distribution Lists" from the
"Service" drop-down menu and specify “Project 2020-06 Verifications of Models and Data for Generators
Observer List” in the Description Box.

North American Electric Reliability Corporation
3353 Peachtree Rd, NE
Suite 600, North Tower
Atlanta, GA 30326
404-446-2560 | www.nerc.com

Standards Announcement | Project 2020-06 Verification of Data and Models for Generators
Inverter-based Resource Glossary Term | July 2024

Standards Announcement

Project 2020-06 Verifications of Models and Data for Generators
Inverter-based Resource Glossary Term
Formal Comment Period Open through August 13, 2024
Now Available

A formal comment period for the Inverter-based Resource Glossary Term is open through 8 p.m.
Eastern, Tuesday, August 13, 2024.
The standard drafting team’s considerations of the responses received from the previous comment
period are reflected in this draft of the definition.
Reminder Regarding Corporate RBB Memberships

Under the NERC Rules of Procedure, each entity and its affiliates is collectively permitted one voting
membership per Registered Ballot Body Segment. Each entity that undergoes a change in corporate
structure (such as a merger or acquisition) that results in the entity or affiliated entities having more than
the one permitted representative in a particular Segment must withdraw the duplicate membership(s)
prior to joining new ballot pools or voting on anything as part of an existing ballot pool. Contact
[email protected] to assist with the removal of any duplicate registrations.
Commenting

Use the Standards Balloting and Commenting System (SBS) to submit comments. An unofficial Word
version of the comment form is posted on the project page.
•

Contact NERC IT support directly at https://support.nerc.net/ (Monday – Friday, 8 a.m. - 5
p.m. Eastern) for problems regarding accessing the SBS due to a forgotten password,
incorrect credential error messages, or system lock-out.

•

Passwords expire every 6 months and must be reset.

•

The SBS is not supported for use on mobile devices.

•

Next Steps

Additional ballots will be conducted August 2-13, 2024.

RELIABILITY | RESILIENCE | SECURITY

North American Electric Reliability Corporation
3353 Peachtree Rd, NE
Suite 600, North Tower
Atlanta, GA 30326
404-446-2560 | www.nerc.com

Standards Announcement | Project 2020-06 Verification of Data and Models for Generators
Inverter-based Resource Glossary Term | July 2024

Comment Report
Project Name:

2020-06 Verifications of Models and Data for Generators | Draft 3 of IBR Definitions

Comment Period Start Date:

7/12/2024

Comment Period End Date:

8/12/2024

Associated Ballots:

2020-06 Verifications of Models and Data for Generators IBR-related Definitions | Implementation Plan AB 3 OT
2020-06 Verifications of Models and Data for Generators Inverter-Based Resource (IBR) AB 3 DEF

Organization
Name
MRO

Name

Anna
Martinson

Segment(s)

1,2,3,4,5,6

Region

MRO

Group Name

MRO Group

Group
Member
Name

Group
Group
Member
Member
Organization Segment(s)

Group
Member
Region

Shonda
McCain

Omaha Public 1,3,5,6
Power District
(OPPD)

MRO

Michael
Brytowski

Great River
Energy

1,3,5,6

MRO

Jamison
Cawley

Nebraska
Public Power
District

1,3,5

MRO

Jay Sethi

Manitoba
Hydro (MH)

1,3,5,6

MRO

Husam AlHadidi

Manitoba
1,3,5,6
Hydro
(System
Preformance)

MRO

Kimberly
Bentley

Western Area 1,6
Power
Adminstration

MRO

Jaimin Patal

Saskatchewan 1
Power
Coporation
(SPC)

MRO

George Brown Pattern
5
Operators LP

MRO

Larry Heckert Alliant Energy 4
(ALTE)

MRO

Terry Harbour MidAmerican
Energy
Company
(MEC)

1,3

MRO

Dane Rogers

Oklahoma
Gas and
Electric
(OG&E)

1,3,5,6

MRO

Seth
Shoemaker

Muscatine
Power &
Water

1,3,5,6

MRO

Michael
Ayotte

ITC Holdings

MRO

Andrew
Coffelt

Board of
1,3,5,6
Public
UtilitiesKansas (BPU)

MRO

Peter Brown

Dominion Dominion
Resources,
Inc.

Southwest
Power Pool,
Inc. (RTO)

Barbara
Marion

Charles
Yeung

ACES Power Jodirah
Marketing
Green

5,6

1,3,4,5,6

FirstEnergy - Mark Garza 4
FirstEnergy

Dominion

MRO,NPCC,RF,SERC,SPP
RE,Texas RE,WECC

SRC 2024

Invenergy

MRO

Angela Wheat Southwestern 1
Power
Administration

MRO

Bobbi Welch

MRO

Victoria Crider Dominion

NA - Not
Applicable

Barbara
Marion

Dominion

NA - Not
Applicable

Sean Bodkin

Dominion

NA - Not
Applicable

Steven Belle

Dominion

NA - Not
Applicable

Charles
Yeung

SPP

MRO

Ali Miremadi

CAISO

WECC

Bobbi Welch

Midcontinent
ISO, Inc.

MRO

Greg Campoli NYISO

NPCC

Matt Goldberg ISO New
England

NPCC

Midcontinent
ISO, Inc.

MRO,NPCC,RF,SERC,Texas ACES
Bob Soloman Hoosier
RE,WECC
Collaborators
Energy
Electric
Cooperative

FE Voter

5,6

Kris Carper

Arizona
1
Electric Power
Cooperative,
Inc.

WECC

Jason
Procuniar

Buckeye
Power, Inc.

Jolly Hayden

East Texas
Electric
Cooperative,
Inc.

NA - Not
Applicable

Texas RE

Scott Brame

North Carolina 3,4,5
Electric
Membership
Corporation

SERC

Nick
Fogleman

Prairie Power, 1,3
Inc.

SERC

Julie Severino FirstEnergy FirstEnergy

Corporation

Michael
Johnson

Corporation

Michael
Johnson

DTE Energy - Mohamad
Detroit
Elhusseini
Edison
Company

Southern
Pamela
Company Hunter
Southern
Company
Services, Inc.

WECC

3,5

1,3,5,6

PG&E All
Segments

DTE Energy

SERC

Southern
Company

Aaron
Ghodooshim

FirstEnergy FirstEnergy
Corporation

Robert Loy

FirstEnergy FirstEnergy
Solutions

Mark Garza

FirstEnergyFirstEnergy

1,3,4,5,6

Stacey
Sheehan

FirstEnergy FirstEnergy
Corporation

Marco Rios

Pacific Gas
and Electric
Company

WECC

Sandra Ellis

Pacific Gas
and Electric
Company

WECC

Tyler Brun

Pacific Gas
and Electric
Company

WECC

Mohamad
Elhusseini

DTE Energy

Patricia
Ireland

DTE Energy

Marvin
Johnson

DTE Energy - 3
Detroit Edison
Company

Matt Carden

Southern
1
Company Southern
Company
Services, Inc.

SERC

Joel
Dembowski

Southern
Company Alabama
Power
Company

SERC

Ron Carlsen

Southern
Company Southern
Company
Generation

SERC

Leslie Burke

Southern
Company Southern

SERC

Company
Generation
Black Hills
Corporation

Rachel
Schuldt

Northeast
Ruida Shu
Power
Coordinating
Council

1,2,3,4,5,6,7,8,9,10 NPCC

Black Hills
Micah Runner Black Hills
Corporation Corporation
All Segments Josh Combs Black Hills
Corporation

NPCC RSC

WECC

Rachel
Schuldt

Black Hills
Corporation

WECC

Carly Miller

Black Hills
Corporation

WECC

Sheila
Suurmeier

Black Hills
Corporation

WECC

Gerry Dunbar Northeast
Power
Coordinating
Council

NPCC

Deidre Altobell Con Edison

NPCC

Michele
Tondalo

United
Illuminating
Co.

NPCC

Stephanie
UllahMazzuca

Orange and
Rockland

NPCC

Michael
Ridolfino

Central
1
Hudson Gas &
Electric Corp.

NPCC

Randy
Buswell

Vermont
1
Electric Power
Company

NPCC

James Grant

NYISO

NPCC

Dermot Smyth Con Ed 1
Consolidated
Edison Co. of
New York

NPCC

David Burke

Orange and
Rockland

NPCC

Peter Yost

Con Ed 3
Consolidated
Edison Co. of
New York

NPCC

Salvatore
Spagnolo

New York
Power
Authority

NPCC

Sean Bodkin

Dominion Dominion

NPCC

Resources,
Inc.
David Kwan

Ontario Power 4
Generation

NPCC

Silvia Mitchell NextEra
1
Energy Florida Power
and Light Co.

NPCC

Sean Cavote

PSEG

NPCC

Jason
Chandler

Con Edison

NPCC

Tracy
MacNicoll

Utility
Services

NPCC

Shivaz
Chopra

New York
Power
Authority

NPCC

Vijay Puran

New York
6
State
Department of
Public Service

NPCC

David Kiguel

Independent

NPCC

Joel
Charlebois

AESI

NPCC

Joshua
London

Eversource
Energy

NPCC

Jeffrey
Streifling

NB Power
Corporation

1,4,10

NPCC

Joel
Charlebois

AESI

NPCC

John Hastings National Grid

NPCC

Erin Wilson

NB Power

NPCC

James Grant

NYISO

NPCC

Michael
Couchesne

ISO-NE

NPCC

Kurtis Chong

IESO

NPCC

Michele
Pagano

Con Edison

NPCC

Bendong Sun Bruce Power

NPCC

Carvers
Powers

NPCC

Utility
Services

Wes Yeomans NYSRC

Dominion Dominion
Resources,
Inc.

Sean
Bodkin

Western
Steven
Electricity
Rueckert
Coordinating
Council
Tim Kelley

Tim Kelley

Dominion

WECC

SMUD and
BANC

Victoria Crider Dominion
Energy

NA - Not
Applicable

Sean Bodkin

Dominion
Energy

NA - Not
Applicable

Steven Belle

Dominion
Energy

NA - Not
Applicable

Barbara
Marion

Dominion
Energy

NA - Not
Applicable

Steve
Rueckert

WECC

Curtis Crews

WECC

Nicole Looney Sacramento
Municipal
Utility District

WECC

Charles
Norton

Sacramento
Municipal
Utility District

WECC

Wei Shao

Sacramento
Municipal
Utility District

WECC

Foung Mua

Sacramento
Municipal
Utility District

WECC

Nicole Goi

Sacramento
Municipal
Utility District

WECC

Kevin Smith

Balancing
Authority of
Northern
California

WECC

Document Name
Comment
Idaho Power Company believes a definition of an IBR Unit is still needed and would be a helpful addition. It also seems like keeping the last section of
the original definition could serve useful as this detail was excluded from the new proposed definition.
Likes

Dislikes

Response
Mark Garza - FirstEnergy - FirstEnergy Corporation - 4, Group Name FE Voter
Answer

Document Name
Comment
FirstEnergy supports EEI’s proposed changes which state:
Inverter-Based Resource (IBR): A plant/facility consisting of individual devices that are capable of exporting Real Power through a power electronic
interface(s) such as an inverter or converter, and that are operated together through a common facility-level controller as a single resource at a
common point of interconnection to the electric system. Examples include, but are not limited to, plants/facilities with solar photovoltaic (PV), Type 3 and
Type 4 wind, battery energy storage system (BESS), VSC-HVDC systems used to connect off-shore renewable resources to the BPS, and fuel cell
devices.
In addition, FirstEnergy requests the DT provide a definition for Type 3 and Type 4 wind devices to ensure intent and applicability of compliance toward
this definition.

Likes

Dislikes

Response
Anna Todd - Southern Indiana Gas and Electric Co. - 3,5,6 - RF
Answer

Dislikes

Response
Devin Shines - PPL - Louisville Gas and Electric Co. - 1,3,5,6 - SERC,RF
Answer

Document Name
Comment
LG&E/KU suggest the following revisions to the proposed definition, with a clean version of the edits provided at the bottom.
1. Describing an IBR as a “plant/facility” risks confusion around IBRs that are co-located with synchronous generators as components of a hybrid
plant. Suggesting the more generic “generating resource”.
2. An IBR may consist of only one inverter. The definition should use “one or more device(s)” from IEEE Std 2800-2022 rather than the current
“individual devices”.
3. The phrase “to the electric system” should be moved to the immediate context of exporting power through the power electronic interface.
4. The wording “at a common point of interconnection” risks confusion at locations where multiple IBRs share a point of interconnection. Here also
it should be noted that the NERC IBR definition parallels the IEEE Std 2800-2022 definition of “IBR Plant” rather than “IBR”. In any case, it is
recommended to use IEEE Std 2800-2022 wording: “operated by a common facility-level controller” (however, due to the use of “facility” in
various NERC contexts, “facility-level” should be removed; it is also unnecessary as “common” already requires that the controller operates all
devices).
5. The wording of the last sentence implies a plant with a BESS is an IBR. Again (see point 1), this risks confusion for IBRs that are co-located
with synchronous generators as part of a hybrid plant. Only the IBR components should be defined as IBRs.
"A generating resource consisting of one or more device(s) capable of exporting Real Power through a power electronic interface to the electric system
and operated by a common controller. Examples include, but are not limited to, solar photovoltaic (PV), Type 3 and Type 4 wind, battery energy storage
system, and fuel cell generating resources."
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Andy Thomas - Duke Energy - 1,3,5,6 - SERC,RF
Answer
Document Name

Comment
Duke Energy suggests the following modifications:
Inverter-Based Resource (IBR): A plant/facility consisting of individual devices that are capable of exporting Real Power through a power electronic
interface(s) such as an inverter or converter, and that are operated together “through a common facility-level control system” “STRIKE” at a common
point of interconnection to the electric system.
The above enhancement will eliminate the vagueness of the phrase single resource at a point of interconnect. Using the "facility-level control system"
prevents confusion of plant/facility since some locations may have a feeder bus with multiple GO's connecting to the feeder that feed to a single point of
interconnect. Additionally, this modification would clarify that each plant/facility is responsible for their own PRC-028 thru -030 requirements, among
others.
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Brian Van Gheem - Radian Generation - NA - Not Applicable - NA - Not Applicable
Answer

Document Name
Comment
1. We believe the proposed definition should align with the Category 2 Generator Owner language recently added to the NERC Rules of
Procedure. Instead of referencing “operated” and “point of interconnection to the electric system,” the definition of a Category 2 Generator
Owner uses “delivering capacity” and “point of connection.” We propose the following definition in its place, “Plant/facility consisting of individual
devices that are capable of exporting Real Power through a power electronic interface(s), such as an inverter or converter, delivering such
capacity to a common point of connection at a voltage greater than or equal to 60 kV...” We believe such a definition could be applied to
Category 1 Generator Owners with IBR Facilities as well.
2. We propose a minor, non-content modification to the definition. We recommend adding a comma after the word “interface(s)” to separate the
word from the prepositional phrase.
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Jennifer Weber - Tennessee Valley Authority - 1,3,5,6 - SERC
Answer

Document Name
Comment
The entire definition could be consolidated slightly for ease of reading and understanding.

Example:
Inverter-Based Resource (IBR): A plant/facility comprising of individual devices capable of exporting Real Power through power electronics e.g.
inverters or converters. These devices operate collectively at a single connection point to the electric system. Examples include but are not limited to,
solar photovoltaic (PV), Type 3 & 4 wind, battery energy storage system (BESS), and fuel cell devices.
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Israel Perez - Israel Perez On Behalf of: Laura Somak, Salt River Project, 3, 6, 5, 1; Mathew Weber, Salt River Project, 3, 6, 5, 1; Thomas
Johnson, Salt River Project, 3, 6, 5, 1; Timothy Singh, Salt River Project, 3, 6, 5, 1; - Israel Perez
Answer

Document Name
Comment
Proposed Definition: A plant/facility consisting of individual devices that are capable of exporting Real Power through a power electronic interface(s)
such as an inverter or converter. Examples include, but are not limited to, plants/facilities with solar photovoltaic (PV), Type 3 and Type 4 wind, battery
energy storage system (BESS), and fuel cell devices.
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Response
Scott Thompson - PNM Resources - Public Service Company of New Mexico - 1,3,5 - WECC
Answer

Document Name
Comment
PNM agrees with the comment of EEI:
Inverter-Based Resource (IBR): A plant/facility consisting of individual devices that are capable of exporting Real Power through a power electronic
interface(s) such as an inverter or converter, and that are operated together through a common facility-level controller as a single resource at a
common point of interconnection to the electric system. Examples include, but are not limited to, plants/facilities with solar photovoltaic (PV), Type 3 and
Type 4 wind, battery energy storage system (BESS), VSC-HVDC systems used to connect off-shore renewable resources to the BPS, and fuel cell
devices.
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0
0

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LaTroy Brumfield - LaTroy Brumfield On Behalf of: Amy Wilke, American Transmission Company, LLC, 1; - LaTroy Brumfield
Answer

Document Name
Comment
The definition should make clear that standalone HVDC facilities are not included in the definition. If the phrases, “plant/facility” are intended to do that,
it could still be confusing as an HVDC could theoretically be called a facility. Adding the phrase, “from a primary energy source or energy storage
system” to the definition might help make this more clear
The suggested definition could read like the example below:
Inverter‐Based Resource (IBR): A plant/facility consisting of individual devices that are capable of exporting Real Power (active power) from a primary
energy source or energy storage system through a power electronic interface(s) such as an inverter or converter, and that are operated together as a
single resource at a common point of interconnection to the electric system.
Examples include, but are not limited to, plants/facilities with solar photovoltaic (PV), Type 3 and Type 4 wind, inverter-interfaced battery energy storage
systems (BESS), and fuel cell devices.

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Rachel Coyne - Texas Reliability Entity, Inc. - 10
Answer
Document Name
Comment

Yes

Texas RE recommends the drafting team consider using the terms generator or generator plant instead of the term “plant/facility”. Since Facility is a
defined term, using lower-case facility could cause confusion.

Texas RE inquires as to whether the term “turbines” should be added after the phrase “Type 3 and 4 wind.”
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Rachel Schuldt - Black Hills Corporation - 6, Group Name Black Hills Corporation - All Segments
Answer

Yes

Document Name
Comment
Black Hills Corporation supports the addition of the proposed IBR definition from the EEI that would provide improved clarity. That definition is as
follows:
Inverter-Based Resource (IBR): A plant/facility consisting of individual devices that are capable of exporting Real Power through a power electronic
interface(s) such as an inverter or converter, and that are operated together through a common facility-level controller as a single resource at a
common point of interconnection to the electric system. Examples include, but are not limited to, plants/facilities with solar photovoltaic (PV), Type 3 and
Type 4 wind, battery energy storage system (BESS), VSC-HVDC systems used to connect off-shore renewable resources, and fuel cell devices.
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Srikanth Chennupati - Entergy - Entergy Services, Inc. - 1,3,5,6 - SERC
Answer

Yes

Document Name
Comment
No comments
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Cain Braveheart - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

Yes

Document Name
Comment
As BPA understands, power electronic interfaces are flexible. BPA believes adding “devices capable of exporting real power through a power electronic
interface” would now include a broad spectrum of equipment that can produce electric power.
BPA recommends revising the following language:
from:
“…consisting of individual devices that are capable of exporting Real Power through a power electronic interface(s)…”
to:
“…consisting of individual devices that export Real Power through a power electronic interface(s)…”
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Yes

Document Name
Comment
SMUD and BANC support this definition for IBR but strongly feel that a definition for “IBR Unit” is needed to help drafting teams in future NERC Order
901 Work Plan Projects.
The drafting team should consider adding the word “turbines” after “wind” and defining what Type 3 and Type 3 wind turbines are. Adding the word
“turbines” is a non-substantive change and could be made in the final ballot.
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Mohamad Elhusseini - DTE Energy - Detroit Edison Company - 3,5, Group Name DTE Energy
Answer

Yes

Document Name
Comment
I have reviewed the proposed definition of IBR and support the proposed definition.
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Hayden Maples - Hayden Maples On Behalf of: Jeremy Harris, Evergy, 3, 5, 1, 6; Kevin Frick, Evergy, 3, 5, 1, 6; Tiffany Lake, Evergy, 3, 5, 1, 6;
- Evergy - 1,3,5,6 - MRO
Answer

Yes

Document Name
Comment
Evergy supports and incorporates by reference the comments of the Edison Electric Institute (EEI) and Midwest Reliability Organization's NERC
Standards Review Forum (MRO NSRF) on question 1
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Wayne Sipperly - North American Generator Forum - 5 - MRO,WECC,Texas RE,NPCC,SERC,RF
Answer

Yes

Document Name
Comment
The NAGF supports the proposed IBR definition.
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Anna Martinson - MRO - 1,2,3,4,5,6 - MRO, Group Name MRO Group
Answer
Document Name

Yes

Comment
The NSRF supports the proposed IBR definition, but would request the standard drafting team consider the following non-substantive changes to
improve clarity.
Inverter-Based Resource (IBR): A plant/facility consisting of individual devices capable of exporting Real Power through a power electronic interface(s)
such as an inverter or converter, and operated together as a single resource at a common point of interconnection to the electric system. Examples
include, but are not limited to, on shore and off-shore wind and solar plants/facilities, Type 3 and Type 4 wind, battery energy storage system (BESS),
and fuel cell devices.
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Alison MacKellar - Constellation - 5
Answer

Yes

Document Name
Comment
Constellation aligns with the NAGF comments.
Alison Mackellar on behalf of Constellation Segments 5 and 6
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Kimberly Turco - Constellation - 6
Answer

Yes

Document Name
Comment
Constellation aligns with NAGF comments.

Kimberly Turco on behalf of Constellation Energy Segments 5 and 6.
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0
0

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Kristine Martz - Edison Electric Institute - NA - Not Applicable - NA - Not Applicable
Answer

Yes

Document Name
Comment
EEI does not object to the revisions made to the proposed IBR definition but there are some non-substantive changes (in boldface text) that we feel
would provide improved clarify to the intent of the definition.
Inverter-Based Resource (IBR): A plant/facility consisting of individual devices that are capable of exporting Real Power through a power electronic
interface(s) such as an inverter or converter, and that are operated together through a common facility-level controller as a single resource at a
common point of interconnection to the electric system. Examples include, but are not limited to, plants/facilities with solar photovoltaic (PV), Type 3 and
Type 4 wind, battery energy storage system (BESS), VSC-HVDC systems used to connect off-shore renewable resources, and fuel cell devices.
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Hillary Creurer - Allete - Minnesota Power, Inc. - 1
Answer

Yes

Document Name
Comment
Minnesota Power supports the definition for IBR as proposed, but also supports EEI and MRO’s NERC Standards Review Forum’s (NSRF) suggestions
to improve clarity.
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Selene Willis - Edison International - Southern California Edison Company - 5
Answer
Document Name
Comment
"Please see EEI Comments"

Yes

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Nick Leathers - Nick Leathers On Behalf of: David Jendras Sr, Ameren - Ameren Services, 3, 6, 1; - Nick Leathers
Answer

Yes

Document Name
Comment
Ameren does not have any additional comments for consideration by the drafting team.
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Carver Powers - Utility Services, Inc. - 4
Answer

Yes

Document Name
Comment
1. Recommend clarifying “Type 3 and Type 4 wind” by including “turbine” after wind in the proposed IBR definition.
2. Without a clear definition of “power electronic interface(s)” it could be determined that it includes transformers which we believe is not the intent of this
definition. Can the SDT provide clarity on what is and what is not a “power electronic interface(s)”
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George E Brown - Pattern Operators LP - 5
Answer

Yes

Document Name
Comment
Pattern Energy supports Midwest Reliability Organization’s NERC Standards Review Forum’s (MRO NSRF) comments on this question.

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Jodirah Green - ACES Power Marketing - 1,3,4,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name ACES Collaborators
Answer

Yes

Document Name
Comment
It is the opinion of ACES that the inclusion of the phrase “plant/facility” within the proposed IBR definition introduces additional confusion into this
definition. As this term is not explicitly defined, it allows for a considerable amount of interpretation by the industry. It is our opinion that the term facility
should instead be included within the defined term itself (i.e., Inverter-Based Resource Facility) to be consistent with other uses of this phrase within the
NERC Glossary of Terms.
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Jennifer Bray - Arizona Electric Power Cooperative, Inc. - 1
Answer

Yes

Document Name
Comment
AEPC signed on to ACES comments:
It is the opinion of ACES that the inclusion of the phrase “plant/facility” within the proposed IBR definition introduces additional confusion into this
definition. As this term is not explicitly defined, it allows for a considerable amount of interpretation by the industry. It is our opinion that the term facility
should instead be included within the defined term itself (i.e., Inverter-Based Resource Facility) to be consistent with other uses of this phrase within the
NERC Glossary of Terms.
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Charles Yeung - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC,Texas RE,NPCC,SERC,RF, Group Name SRC 2024
Answer
Document Name

Yes

Comment
The ISO/RTO Council (IRC) Standards Review Committee (SRC) supports the revised term, but notes that the deletion of “connected to the electric
system” from the IBR definition, implies that the IBR term is not in and of itself applicable to BES or non-BES interconnections. Therefore, those
reliability requirements applicable to IBRs will need to specify whether they apply to the new registration categories of “GO/GOP Category 1” and
“GO/GOP Category 2” to complement the IBR definition. Any and all current and proposed standards applicable to IBR should be reviewed and updated
to clarify their applicability.
In addition, the SRC proposes the changes in red below.
Inverter-Based Resource (IBR): A plant/facility that includes one or more individual devices that are capable of exporting Real Power through a power
electronic interface(s) such as an inverter or converter, and that are operated together as a single resource at a common point of interconnection{C}[1]
to the electric system. Examples include, but are not limited to, plants/facilities with that include one or more solar photovoltaic (PV), Type 3 and Type 4
wind, battery energy storage system (BESS), and fuel cell devices.
The SRC proposes that a definition or examples of what constitutes a “common point of interconnection” be provided (such as in a footnote) since this
term is not defined in the NERC Glossary of Terms and it is unclear whether it refers to a transformer, a bus, or some other point of interconnection.
Illustrative examples are also useful to clarify how a hybrid plant, in which only a portion of the interconnected facility employs an inverter or converter,
falls under the definition.
The SRC proposes that the language “one or more” be restored in the first sentence of the definition and added to the second sentence for clarity and
consistency.
Finally, the SRC is concerned that the word “with” in the second sentence of the definition is unclear. Therefore, we propose replacing the word “with”
with “that include.”
Footnote: ISO NE is a party to these comments however does not support the comments provided in reponse to Q1.
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Kennedy Meier - Electric Reliability Council of Texas, Inc. - 2
Answer

Yes

Document Name
Comment
ERCOT joins the comments submitted by the ISO/RTO Council (IRC) Standards Review Committee (SRC) and adopts them as its own.
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Thomas Foltz - AEP - 5
Answer

Yes

Document Name
Comment
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Response
Jessica Cordero - Unisource - Tucson Electric Power Co. - 1
Answer

Yes

Document Name
Comment
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Response
Sean Bodkin - Dominion - Dominion Resources, Inc. - 6, Group Name Dominion
Answer

Yes

Document Name
Comment
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Response
Barbara Marion - Dominion - Dominion Resources, Inc. - 5,6, Group Name Dominion
Answer
Document Name
Comment

Yes

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Response
Donna Wood - Tri-State G and T Association, Inc. - 1
Answer

Yes

Document Name
Comment
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Response
Daniela Atanasovski - APS - Arizona Public Service Co. - 1
Answer

Yes

Document Name
Comment
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Response
Diana Aguas - CenterPoint Energy Houston Electric, LLC - 1 - Texas RE
Answer

Yes

Document Name
Comment
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Response
Sing Tay - AES - AES Corporation - 5 - MRO,WECC,Texas RE,NPCC,SERC,RF

Answer

Yes

Document Name
Comment
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Yes

Document Name
Comment
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Response
Casey Jones - Berkshire Hathaway - NV Energy - 5 - WECC
Answer

Yes

Document Name
Comment
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Response
Stephen Stafford - Stephen Stafford On Behalf of: Greg Davis, Georgia Transmission Corporation, 1; - Stephen Stafford
Answer
Document Name
Comment

Yes

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Response
Constantin Chitescu - Ontario Power Generation Inc. - 5
Answer

Yes

Document Name
Comment
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Response
Pamela Hunter - Southern Company - Southern Company Services, Inc. - 1,3,5,6 - SERC, Group Name Southern Company
Answer

Yes

Document Name
Comment
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Response
Mike Magruder - Avista - Avista Corporation - 1
Answer

Yes

Document Name
Comment
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Response
Steven Rueckert - Western Electricity Coordinating Council - 10, Group Name WECC

Answer

Yes

Document Name
Comment
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Response
Patricia Lynch - NRG - NRG Energy, Inc. - 5
Answer
Document Name
Comment
NRG Energy Inc is in support of the comments made by EPSA.
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Response
Martin Sidor - NRG - NRG Energy, Inc. - 5,6
Answer
Document Name
Comment
NRG agrees with the EPSA comments.
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Gail Elliott - Gail Elliott On Behalf of: Michael Moltane, International Transmission Company Holdings Corporation, 1; - Gail Elliott
Answer
Document Name
Comment

ITC has no comments on the proposed definition for Project 2020-06.
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2. Provide any additional comments for the DT to consider, if desired.
Kyle Thomas - Elevate Energy Consulting - NA - Not Applicable - NA - Not Applicable
Answer
Document Name
Comment
Elevate appreciates the opportunity to comment on the draft NERC standards, particularly those pertaining to future IBR NERC Reliability Standards,
and FERC Order No. 901 directives.
The IBR definition appears to be using IEEE 2800-2022 as a reference; however, there are notable differences between definitions. Most importantly,
IEEE 2800-2022 is careful in its consideration of supplemental devices, defined as “any equipment within an IBR plant, which may or may not be
inverter-based…” These could include capacitor banks, STATCOMs, harmonic filters, protection systems, plant-level controllers, etc., which should all
be considered as part of the overall IBR facility. If the resource (or part of the resource) is deemed “IBR”, then all applicable components that support
that resource (such as those listed above) should be considered part of the IBR.
We also would like to see the re-introduction of an IBR Unit definition, which we believe is necessary for meaningful standards applications. The
difference between IBR Unit requirements/capabilities and IBR requirements/capabilities can be significant, so defining these two clearly is strongly
encouraged. Creating an IBR Unit definition that matches the IEEE 2800 standard would help facilitate this process efficiently and is recommended for
the definition.
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Kennedy Meier - Electric Reliability Council of Texas, Inc. - 2
Answer
Document Name
Comment
ERCOT joins the comments submitted by the IRC SRC and adopts them as its own.
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Steven Rueckert - Western Electricity Coordinating Council - 10, Group Name WECC
Answer
Document Name

Comment
WECC voted yes but offers the following for consideration. WECC appreciates the efforts to provide a definition for Inverter-Based Resource (IBR).
WECC asks if the DT is planning to provide some examples so that “misunderstanding” will be avoided when the definition is applied within
Standards/Requirements? Compliance can create interesting arguments that ignore the reliability (and risk) concerns. It is understood that the
registration candidate pool will be limited to the definition of Generator Operator and Generator Owner recently approved by FERC. The definitions did
not use IBR directly and, instead, used “non-BES inverter based generating resources” (for Cat 2) and “generating Facility(ies)” for Cat 1. It is clear to
WECC that the proposed IBR definition is applicable for Cat 1 and Cat 2 GOs and GOPs.
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Charles Yeung - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC,Texas RE,NPCC,SERC,RF, Group Name SRC 2024
Answer
Document Name

2020-06_IBR_Definition_Unofficial_Comment_Form_SRCFinal.docx

Further, the SRC notes that existing NERC standards apply requirements at the unit level. For instance, MOD-026, Requirement R2, Part 2.1 has unitspecific requirements for excitation control systems.
2.1. Each applicable unit’s model shall be verified by the Generator Owner using one or more models acceptable to the Transmission Planner.
Verification for individual units less than 20 MVA (gross nameplate rating) in a generating plant (per Section 4.2.1.2, 4.2.2.2, or 4.2.3.2) may be

performed using either individual unit or aggregate unit model(s), or both. Each verification shall include the following: . . .

Similarly, PRC-024, Section 4 Applicability, Part 4.2 Facilities, Part 4.2.1.4 includes individual dispersed power producing resource(s) as applicable
facilities identified in Inclusion I4 of the BES Definition.
4.2.1.4 Individual dispersed power producing resource(s) identified in the BES Definition, Inclusion I4.

For these reasons, the SRC believes consideration should be given to retaining a definition of “IBR Unit” as it will engender common understanding and
application of the term among Registered Entities. While an “IBR Unit” definition may not need to be finalized in this immediate project, there will likely
be a need to complete this task in the future to align with developing frameworks.
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Jennifer Bray - Arizona Electric Power Cooperative, Inc. - 1
Answer
Document Name
Comment
AEPC signed on to ACES comments:
We at ACES applaud the SDT for the work that has been put into developing the IBR definition. We are greatly encouraged by the SDT’s willingness to
heed industry feedback and implement changes to the IBR definition. However, it is the opinion of ACES that consolidating the IBR Unit and IBR Facility
definitions into a single definition is a mistake.
It is the perspective of ACES that, without a way to clearly define what constitutes the individual devices of an IBR, each individual Standards Drafting
Team is left to provide their own (potentially unique) definition. We believe that this will be a detriment to consistency and will potentially have a negative
impact on compliance. We suggest utilizing terms and/or language already contained within the Glossary of Terms whenever possible. Thus, we
recommend using the following terms to define these types of generating resources (a:
Inverter-Based Resource (IBR) Facility: One or more IBR Unit(s), and any associated Element(s) required for the operation thereof, connected to the
electric system and operated as a single resource at a common point of Interconnection.
Inverter-Based Resource (IBR) Unit: An individual generating resource capable of exporting electric power that uses a power electronic interface,
such as an inverter or converter, and connects at a single point to a system designed primarily for delivering such electric power to a common point of
Interconnection (note: a system designed primarily for delivering such electric power to a common point of Interconnection is commonly referred to as a
collector system).
Thank you for the opportunity to comment.
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0
0

Response
Jodirah Green - ACES Power Marketing - 1,3,4,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name ACES Collaborators
Answer
Document Name
Comment
We at ACES applaud the SDT for the work that has been put into developing the IBR definition. We are greatly encouraged by the SDT’s willingness to
heed industry feedback and implement changes to the IBR definition. However, it is the opinion of ACES that consolidating the IBR Unit and IBR Facility
definitions into a single definition is a mistake.
It is the perspective of ACES that, without a way to clearly define what constitutes the individual devices of an IBR, each individual Standards Drafting
Team is left to provide their own (potentially unique) definition. We believe that this will be a detriment to consistency and will potentially have a negative
impact on compliance. We suggest utilizing terms and/or language already contained within the Glossary of Terms whenever possible. Thus, we
recommend using the following terms to define these types of generating resources (a:
Inverter-Based Resource (IBR) Facility: One or more IBR Unit(s), and any associated Element(s) required for the operation thereof, connected to the
electric system and operated as a single resource at a common point of Interconnection.
Inverter-Based Resource (IBR) Unit: An individual generating resource capable of exporting electric power that uses a power electronic interface,
such as an inverter or converter, and connects at a single point to a system designed primarily for delivering such electric power to a common point of
Interconnection (note: a system designed primarily for delivering such electric power to a common point of Interconnection is commonly referred to as a
collector system).
Thank you for the opportunity to comment.
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George E Brown - Pattern Operators LP - 5
Answer
Document Name
Comment
Pattern Energy supports Midwest Reliability Organization’s NERC Standards Review Forum’s (MRO NSRF) comments on this question.
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Ruida Shu - Northeast Power Coordinating Council - 1,2,3,4,5,6,7,8,9,10 - NPCC, Group Name NPCC RSC
Answer
Document Name
Comment
NPCC RSC supports the project.
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Scott Thompson - PNM Resources - Public Service Company of New Mexico - 1,3,5 - WECC
Answer
Document Name
Comment
Any and all items listed items/assets in the proposed IBR definition should be defined and in the NERC Glossary of Terms.
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Pamela Hunter - Southern Company - Southern Company Services, Inc. - 1,3,5,6 - SERC, Group Name Southern Company
Answer
Document Name
Comment
Southern Company has no further comments.
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Response
Constantin Chitescu - Ontario Power Generation Inc. - 5
Answer

Document Name
Comment
OPG supports NPCC Regional Standards Committee’s comments.
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Nick Leathers - Nick Leathers On Behalf of: David Jendras Sr, Ameren - Ameren Services, 3, 6, 1; - Nick Leathers
Answer
Document Name
Comment
Ameren does not have any additional comments for consideration by the drafting team.
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Romel Aquino - Edison International - Southern California Edison Company - 3
Answer
Document Name

Project 2020-06 _ EEI Near Final Revised IBR Definition Draft 3 Rev 0a 8_06_2024.docx

Comment
See comments submitted by the Edison Eclectic Institute in the attached file
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Kimberly Turco - Constellation - 6
Answer
Document Name
Comment

Constellation has no additional comments

Kimberly Turco on behalf of Constellation Energy Segments 5 and 6.
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Alison MacKellar - Constellation - 5
Answer
Document Name
Comment
Constellation has no additional comments.
Alison Mackellar on behalf of Constellation Segments 5 and 6
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Wayne Sipperly - North American Generator Forum - 5 - MRO,WECC,Texas RE,NPCC,SERC,RF
Answer
Document Name

Comment
The NAGF has no additional comments.
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Martin Sidor - NRG - NRG Energy, Inc. - 5,6
Answer
Document Name
Comment
NRG agrees with the EPSA comments.
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Dislikes

Response
Mohamad Elhusseini - DTE Energy - Detroit Edison Company - 3,5, Group Name DTE Energy
Answer
Document Name
Comment
No other comments to provide.
Likes

Dislikes

Response
Jennifer Weber - Tennessee Valley Authority - 1,3,5,6 - SERC
Answer
Document Name
Comment

Technical Rationale:
•
•

Need to define the acronym “LCC” as, while it may be obvious to some, it isn’t necessarily known to all. Note that the definition of “VSC HVDC”
should be moved up to the first time it’s used.
Contains the term “IBR Unit,” which is no longer a defined term, and, as such, should not be included in the document.

Implementation Plan:
•
•

The Background section contains the term “IBR Unit,” which is no longer a defined term, and, as such, should not be included in the document.
The General Considerations section makes reference to multiple definitions, but there is only one (“IBR”) now.

Likes

Dislikes

Response
Brian Van Gheem - Radian Generation - NA - Not Applicable - NA - Not Applicable
Answer
Document Name
Comment
1. Thank you for the opportunity to comment.
Likes

Dislikes

Response
Michael Johnson - Michael Johnson On Behalf of: Marco Rios, Pacific Gas and Electric Company, 3, 1, 5; Sandra Ellis, Pacific Gas and
Electric Company, 3, 1, 5; Tyler Brun, Pacific Gas and Electric Company, 3, 1, 5; - Michael Johnson, Group Name PG&E All Segments
Answer
Document Name
Comment
PGAE is curious why the SDT did not use the IEEE definition of an IBR and IBR Unit so there is alignment between NERC and IEEE? The difference
does not appear to change the overall meaning but may lead to confusion/conflict down the road between product developers and compliance related
tasks.
Likes

Dislikes
Response

Andy Thomas - Duke Energy - 1,3,5,6 - SERC,RF
Answer
Document Name
Comment
None.
Likes

Dislikes

Response
Devin Shines - PPL - Louisville Gas and Electric Co. - 1,3,5,6 - SERC,RF
Answer
Document Name
Comment
LG&E/KU thanks the DT for their work on this desperately needed definition. The suggested edits sharpen the proposed definition and reduce the risk of
confusion regarding IBRs co-located with synchronous generators and separate IBRs sharing a point of interconnection. Most of these edits are
believed to be non-substantive relative to the intent of the DT.
Likes

Dislikes

Response
Anna Todd - Southern Indiana Gas and Electric Co. - 3,5,6 - RF
Answer
Document Name
Comment
N/A
Likes

Dislikes

Response
Sing Tay - AES - AES Corporation - 5 - MRO,WECC,Texas RE,NPCC,SERC,RF

Answer
Document Name
Comment
AES Clean Energy believes that a definition for IBR Unit is still required. Currently, PRC-028 proposed Draft 4 has its own “IBR unit” definition within the
standard in order to create the requirement language needed. Since other Standards are being revised or created to meet FERC Order 901, AES Clean
Energy believes that having a NERC Glossary definition for IBR Unit will help maintain consistency between all the different Standards that will be
applicable to IBRs. AES Clean Energy strongly recommends that NERC continues to pursue a definition for IBR Unit.
Likes

Dislikes

Response
Mark Garza - FirstEnergy - FirstEnergy Corporation - 4, Group Name FE Voter
Answer
Document Name
Comment
None
Likes

Dislikes

Response
Srikanth Chennupati - Entergy - Entergy Services, Inc. - 1,3,5,6 - SERC
Answer
Document Name
Comment
None
Likes

Dislikes

Response
Daniela Atanasovski - APS - Arizona Public Service Co. - 1

Answer
Document Name
Comment
None
Likes

Dislikes

Response
Donna Wood - Tri-State G and T Association, Inc. - 1
Answer
Document Name
Comment
N/A
Likes

Dislikes

Response
Sean Steffensen - IDACORP - Idaho Power Company - 1
Answer
Document Name
Comment
IPC has concerns about removing the entire current definition of IBR Units. Will “IBR Unit” be defined somewhere else, or excluded altogether? IPC
believes a broader definition of IBR (unit) is still necessary and would be helpful to the process.
Likes

Dislikes
Response

Consideration of Comments
Project Name:

2020-06 Verifications of Models and Data for Generators | Draft 3 of IBR Definitions

Comment Period Start Date:

7/12/2024

Comment Period End Date:

8/12/2024

Associated Ballot(s):

There were 52 sets of responses, including comments from approximately 147 different people from approximately 100 companies
representing 10 of the Industry Segments as shown in the table on the following pages.
All comments submitted can be reviewed in their original format on the project page.
If you feel that your comment has been overlooked, let us know immediately. Our goal is to give every comment serious consideration in this
process. If you feel there has been an error or omission, contact Manager of Standards Information, Nasheema Santos (via email) or at (404) 4462564.

RELIABILITY | RESILIENCE | SECURITY

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

The Industry Segments are:

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Organization
Name
MRO

Name
Anna
Martinson

Segment(s)
1,2,3,4,5,6

Group
Name

Region
MRO

MRO Group

Group
Member
Name

Group
Group
Member
Member
Organization Segment(s)

Shonda
McCain

Omaha Public
Power District
(OPPD)

1,3,5,6

MRO

Michael
Brytowski

Great River
Energy

1,3,5,6

MRO

Jamison
Cawley

Nebraska
Public Power
District

1,3,5

MRO

Jay Sethi

Manitoba
Hydro (MH)

1,3,5,6

MRO

Husam AlHadidi

1,3,5,6
Manitoba
Hydro (System
Performance)

MRO

Kimberly
Bentley

Western Area 1,6
Power
Administration

MRO

Jaimin Patal

Saskatchewan
Power
Corporation
(SPC)

George Brown Pattern
Operators LP

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Group
Member
Region

MRO

Organization
Name

Name

Segment(s)

Group
Name

Region

Group
Member
Name
Larry Heckert

Group
Group
Member
Member
Organization Segment(s)
Alliant Energy
(ALTE)

Terry Harbour MidAmerican
Energy
Company
(MEC)

5,6

Dominion

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

MRO

1,3

MRO

Dane Rogers

Oklahoma Gas 1,3,5,6
and Electric
(OG&E)

MRO

Seth
Shoemaker

Muscatine
1,3,5,6
Power & Water

MRO

Michael Ayotte ITC Holdings

Barbara
Marion

Group
Member
Region

MRO

Andrew Coffelt Board of Public 1,3,5,6
Utilities- Kansas
(BPU)

MRO

Peter Brown

MRO

Invenergy

5,6

Angela Wheat Southwestern 1
Power
Administration

MRO

Bobbi Welch

MRO

NA - Not
Applicable

Midcontinent
ISO, Inc.

Victoria Crider Dominion

Organization
Name

Name

Segment(s)

Group
Name

Region

Dominion Dominion
Resources, Inc.

Southwest
Power Pool,
Inc. (RTO)

Charles
Yeung

MRO,NPCC,RF,SERC,SPP
RE,Texas RE,WECC

SRC 2024

Group
Member
Name

Group
Group
Member
Member
Organization Segment(s)

Barbara
Marion

Dominion

NA - Not
Applicable

Sean Bodkin

Dominion

NA - Not
Applicable

Steven Belle

Dominion

NA - Not
Applicable

Charles Yeung SPP

MRO

Ali Miremadi

CAISO

WECC

Bobbi Welch

Midcontinent
ISO, Inc.

MRO

Greg Campoli

NYISO

NPCC

Matt Goldberg ISO New
England
ACES Power
Marketing

Jodirah
Green

1,3,4,5,6

MRO,NPCC,RF,SERC,Texas ACES
Bob Soloman
Collaborators
RE,WECC

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Group
Member
Region

Hoosier Energy 1
Electric
Cooperative

Kris Carper

Arizona Electric 1
Power
Cooperative,
Inc.

WECC

Jason
Procuniar

Buckeye
Power, Inc.

Organization
Name

FirstEnergy FirstEnergy
Corporation

Name

Mark Garza 4

Segment(s)

Group
Name

Region

FE Voter

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Group
Member
Name

Group
Group
Member
Member
Organization Segment(s)
NA - Not
Applicable

Jolly Hayden

East Texas
Electric
Cooperative,
Inc.

Scott Brame

North Carolina 3,4,5
Electric
Membership
Corporation

Group
Member
Region
Texas RE

SERC

Nick Fogleman Prairie Power,
Inc.

1,3

SERC

Julie Severino

FirstEnergy FirstEnergy
Corporation

Aaron
Ghodooshim

FirstEnergy FirstEnergy
Corporation

Robert Loy

FirstEnergy FirstEnergy
Solutions

Mark Garza

FirstEnergyFirstEnergy

1,3,4,5,6

Stacey
Sheehan

FirstEnergy FirstEnergy
Corporation

Organization
Name
Michael
Johnson

DTE Energy Detroit Edison
Company

Southern
Company Southern
Company
Services, Inc.

Name

Segment(s)

Michael
Johnson

Mohamad
Elhusseini

Pamela
Hunter

Region
WECC

3,5

1,3,5,6

Group
Name
PG&E All
Segments

DTE Energy

SERC

Southern
Company

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Group
Member
Name

Group
Group
Member
Member
Organization Segment(s)

Group
Member
Region

Marco Rios

Pacific Gas and 1
Electric
Company

WECC

Sandra Ellis

Pacific Gas and 3
Electric
Company

WECC

Tyler Brun

Pacific Gas and 5
Electric
Company

WECC

Mohamad
Elhusseini

DTE Energy

Patricia Ireland DTE Energy

Marvin
Johnson

DTE Energy Detroit Edison
Company

Matt Carden

Southern
Company Southern
Company
Services, Inc.

SERC

Joel
Dembowski

Southern
3
Company Alabama Power
Company

SERC

Organization
Name

Black Hills
Corporation

Northeast
Power
Coordinating
Council

Name

Rachel
Schuldt

Ruida Shu

Segment(s)

1,2,3,4,5,6,7,8,9,10 NPCC

Group
Name

Region

Group
Member
Name

Group
Group
Member
Member
Organization Segment(s)

Group
Member
Region

Ron Carlsen

Southern
Company Southern
Company
Generation

SERC

Leslie Burke

Southern
Company Southern
Company
Generation

SERC

Black Hills
Micah Runner Black Hills
Corporation Corporation
All Segments
Josh Combs
Black Hills
Corporation

WECC

Rachel Schuldt Black Hills
Corporation

WECC

Carly Miller

Black Hills
Corporation

WECC

Sheila
Suurmeier

Black Hills
Corporation

WECC

Gerry Dunbar

Northeast
Power
Coordinating
Council

NPCC

NPCC RSC

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Organization
Name

Name

Segment(s)

Region

Group
Name

Group
Member
Name

Group
Group
Member
Member
Organization Segment(s)

Deidre Altobell Con Edison
Michele
Tondalo

NPCC

United
1
Illuminating Co.

NPCC

Stephanie
Orange and
Ullah-Mazzuca Rockland

NPCC

Central Hudson 1
Gas & Electric
Corp.

NPCC

Randy Buswell Vermont
Electric Power
Company

NPCC

James Grant

NPCC

Dermot Smyth Con Ed Consolidated
Edison Co. of
New York

NPCC

David Burke

Orange and
Rockland

NPCC

Peter Yost

Con Ed Consolidated
Edison Co. of
New York

NPCC

Michael
Ridolfino

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Group
Member
Region

NYISO

Organization
Name

Name

Segment(s)

Region

Group
Name

Group
Member
Name

Group
Group
Member
Member
Organization Segment(s)

Salvatore
Spagnolo

New York
Power
Authority

NPCC

Sean Bodkin

6
Dominion Dominion
Resources, Inc.

NPCC

David Kwan

Ontario Power 4
Generation

NPCC

Silvia Mitchell NextEra Energy 1
- Florida Power
and Light Co.

NPCC

Sean Cavote

NPCC

Utility Services 5

NPCC

Vijay Puran

New York State 6
Department of
Public Service

NPCC

David Kiguel

Independent

NPCC

PSEG

Jason Chandler Con Edison
Tracy
MacNicoll

Shivaz Chopra New York
Power
Authority

Joel Charlebois AESI
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Group
Member
Region

Organization
Name

Name

Dominion Sean Bodkin 6
Dominion
Resources, Inc.

Segment(s)

Group
Name

Region

Dominion

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Group
Member
Name

Group
Group
Member
Member
Organization Segment(s)

Group
Member
Region

Joshua London Eversource
Energy

NPCC

Jeffrey
Streifling

1,4,10

NPCC

Joel Charlebois AESI

NPCC

John Hastings

National Grid

NPCC

Erin Wilson

NB Power

NPCC

James Grant

NYISO

NPCC

Michael
Couchesne

ISO-NE

NPCC

Kurtis Chong

IESO

NPCC

Michele
Pagano

Con Edison

NPCC

Bendong Sun

Bruce Power

NPCC

Carvers
Powers

Utility Services 5

NPCC

NB Power
Corporation

Wes Yeomans NYSRC

NPCC

Victoria Crider Dominion
Energy

NA - Not
Applicable

Sean Bodkin

NA - Not
Applicable

Dominion
Energy

Organization
Name

Name

Western
Electricity
Coordinating
Council

Steven
Rueckert

Tim Kelley

Segment(s)

Group
Name

Region

WECC

SMUD and
BANC

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Group
Member
Name

Group
Group
Member
Member
Organization Segment(s)

Group
Member
Region

Steven Belle

Dominion
Energy

NA - Not
Applicable

Barbara
Marion

Dominion
Energy

NA - Not
Applicable

Steve Rueckert WECC

WECC

Curtis Crews

WECC

Nicole Looney Sacramento
Municipal
Utility District

WECC

Charles Norton Sacramento
Municipal
Utility District

WECC

Wei Shao

Sacramento
Municipal
Utility District

WECC

Foung Mua

Sacramento
Municipal
Utility District

WECC

Nicole Goi

Sacramento
Municipal
Utility District

WECC

Organization
Name

Name

Segment(s)

Region

Group
Name

Group
Member
Name
Kevin Smith

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Group
Group
Member
Member
Organization Segment(s)
Balancing
Authority of
Northern
California

Group
Member
Region
WECC

Dislikes

Response
Thank you for the response, the Drafting Team (DT) is considering using the term IBR Unit as a standard only definition for MOD-026. Other DTs can
use the standard only definition approach as needed.
Mark Garza - FirstEnergy - FirstEnergy Corporation - 4, Group Name FE Voter
Answer

Document Name
Comment
FirstEnergy supports EEI’s proposed changes which state:
Inverter-Based Resource (IBR): A plant/facility consisting of individual devices that are capable of exporting Real Power through a power electronic
interface(s) such as an inverter or converter, and that are operated together through a common facility-level controller as a single resource at a
common point of interconnection to the electric system. Examples include, but are not limited to, plants/facilities with solar photovoltaic (PV), Type 3
and Type 4 wind, battery energy storage system (BESS), VSC-HVDC systems used to connect off-shore renewable resources to the BPS, and fuel cell
devices.

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

In addition, FirstEnergy requests the DT provide a definition for Type 3 and Type 4 wind devices to ensure intent and applicability of compliance
toward this definition.
Likes

Dislikes

Response
The DT considered adding this to the IBR definition, however decided against it due to Type 3 and Type 4 wind already being listed within the
definition. An offshore wind IBR is still an IBR whether or not it is connected via an AC or HVDC cable. Further, the DT felt as though the discussion
within the technical rationale was sufficient to explain that the HVDC terminals are part of the IBR in this case.
Anna Todd - Southern Indiana Gas and Electric Co. - 3,5,6 - RF
Answer

Document Name
Comment
Renewable generation must at some point cover Reactive Power if we are moving towards all renewable generation in the future. Due to this,
Southern Indiana Gas & Electric, Company recommends adding “Reactive Power” to the definition.
Likes

Dislikes

Response
By requiring active capabilities the DT is referring to generating resources, and not transmission connected reactive resources. The DT includes the
fact that an IBR produces reactive power, and does not define IBR by having to create reactive power.
Devin Shines - PPL - Louisville Gas and Electric Co. - 1,3,5,6 - SERC,RF
Answer

Document Name
Comment

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

LG&E/KU suggest the following revisions to the proposed definition, with a clean version of the edits provided at the bottom.
1. Describing an IBR as a “plant/facility” risks confusion around IBRs that are co-located with synchronous generators as components of a hybrid

plant. Suggesting the more generic “generating resource”.
An IBR may consist of only one inverter. The definition should use “one or more device(s)” from IEEE Std 2800-2022 rather than the current
“individual devices”.
The phrase “to the electric system” should be moved to the immediate context of exporting power through the power electronic interface.
The wording “at a common point of interconnection” risks confusion at locations where multiple IBRs share a point of interconnection. Here
also it should be noted that the NERC IBR definition parallels the IEEE Std 2800-2022 definition of “IBR Plant” rather than “IBR”. In any case, it
is recommended to use IEEE Std 2800-2022 wording: “operated by a common facility-level controller” (however, due to the use of “facility” in
various NERC contexts, “facility-level” should be removed; it is also unnecessary as “common” already requires that the controller operates all
devices).
The wording of the last sentence implies a plant with a BESS is an IBR. Again (see point 1), this risks confusion for IBRs that are co-located with
synchronous generators as part of a hybrid plant. Only the IBR components should be defined as IBRs.

2.
3.
4.

"A generating resource consisting of one or more device(s) capable of exporting Real Power through a power electronic interface to the electric
system and operated by a common controller. Examples include, but are not limited to, solar photovoltaic (PV), Type 3 and Type 4 wind, battery
energy storage system, and fuel cell generating resources."
Likes

Dislikes

Response
The DT had found that the plant/facility was the most fitting wording for the definition. The DT wanted to stay away from the NERC
definition “Facility”
2.
The DT agrees that IBR may only consist of one inverter, the definition does not exclude this.
3.
Thank you for the comment and concern. The DT intent was for the whole facility connecting to the system.
4.
The key part of the IBR definition is “operating together as a single resource at a common point of interconnection.” Please review the
TR as that goes into more detail.
5.
The DT BESS would be considered an IBR but a Hybrid IBR. The IBR language would apply to the BESS, please see the TR for further
explanation.
1.

Andy Thomas - Duke Energy - 1,3,5,6 - SERC,RF
Answer

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Document Name
Comment
Duke Energy suggests the following modifications:
Inverter-Based Resource (IBR): A plant/facility consisting of individual devices that are capable of exporting Real Power through a power electronic
interface(s) such as an inverter or converter, and that are operated together “through a common facility-level control system” “STRIKE” at a common
point of interconnection to the electric system.
The above enhancement will eliminate the vagueness of the phrase single resource at a point of interconnect. Using the "facility-level control system"
prevents confusion of plant/facility since some locations may have a feeder bus with multiple GO's connecting to the feeder that feed to a single point
of interconnect. Additionally, this modification would clarify that each plant/facility is responsible for their own PRC-028 thru -030 requirements,
among others.
Likes

Dislikes

Response
DT believes the phrase “operated together as a single resource” is sufficiently clear. Please review the TR as that goes more into depth.
Brian Van Gheem - Radian Generation - NA - Not Applicable - NA - Not Applicable
Answer

Document Name
Comment
1. We believe the proposed definition should align with the Category 2 Generator Owner language recently added to the NERC Rules of

Procedure. Instead of referencing “operated” and “point of interconnection to the electric system,” the definition of a Category 2 Generator
Owner uses “delivering capacity” and “point of connection.” We propose the following definition in its place, “Plant/facility consisting of
individual devices that are capable of exporting Real Power through a power electronic interface(s), such as an inverter or converter,
delivering such capacity to a common point of connection at a voltage greater than or equal to 60 kV...” We believe such a definition could be
applied to Category 1 Generator Owners with IBR Facilities as well.
2. We propose a minor, non-content modification to the definition. We recommend adding a comma after the word “interface(s)” to separate
the word from the prepositional phrase.
Likes

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Dislikes

Response
The DT decided the “capable of exporting Real Power” is preferable to “delivering such capacity”. The DT does not want to insert
applicability into the definition and the DT does not want to add the phrase “voltage greater than or equal to 60 kV.”
2.
The DT does not feel this is a necessary change.
1.

Jennifer Weber - Tennessee Valley Authority - 1,3,5,6 - SERC
Answer

Document Name
Comment
The entire definition could be consolidated slightly for ease of reading and understanding.
Example:
Inverter-Based Resource (IBR): A plant/facility comprising of individual devices capable of exporting Real Power through power electronics e.g.
inverters or converters. These devices operate collectively at a single connection point to the electric system. Examples include but are not limited to,
solar photovoltaic (PV), Type 3 & 4 wind, battery energy storage system (BESS), and fuel cell devices.
Likes

Dislikes

Response
Thank you for the comment.
Israel Perez - Israel Perez On Behalf of: Laura Somak, Salt River Project, 3, 6, 5, 1; Mathew Weber, Salt River Project, 3, 6, 5, 1; Thomas Johnson, Salt
River Project, 3, 6, 5, 1; Timothy Singh, Salt River Project, 3, 6, 5, 1; - Israel Perez
Answer

Document Name
Comment

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Proposed Definition: A plant/facility consisting of individual devices that are capable of exporting Real Power through a power electronic interface(s)
such as an inverter or converter. Examples include, but are not limited to, plants/facilities with solar photovoltaic (PV), Type 3 and Type 4 wind,
battery energy storage system (BESS), and fuel cell devices.
Likes

Dislikes

Response
Thank you for the comment, the DT feels the proposed removed wording, "...and that are operated together as a single resource at a common point
of interconnection to the electric system” is necessary for reliability in the IBR Definition.
Scott Thompson - PNM Resources - Public Service Company of New Mexico - 1,3,5 - WECC
Answer

Document Name
Comment
PNM agrees with the comment of EEI:
Inverter-Based Resource (IBR): A plant/facility consisting of individual devices that are capable of exporting Real Power through a power electronic
interface(s) such as an inverter or converter, and that are operated together through a common facility-level controller as a single resource at a
common point of interconnection to the electric system. Examples include, but are not limited to, plants/facilities with solar photovoltaic (PV), Type 3
and Type 4 wind, battery energy storage system (BESS), VSC-HVDC systems used to connect off-shore renewable resources to the BPS, and fuel cell
devices.
Likes

Dislikes

Response
Please see response to EEI’s comment.
LaTroy Brumfield - LaTroy Brumfield On Behalf of: Amy Wilke, American Transmission Company, LLC, 1; - LaTroy Brumfield
Answer

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Document Name
Comment
The definition should make clear that standalone HVDC facilities are not included in the definition. If the phrases, “plant/facility” are intended to do
that, it could still be confusing as an HVDC could theoretically be called a facility. Adding the phrase, “from a primary energy source or energy storage
system” to the definition might help make this more clear
The suggested definition could read like the example below:
Inverter‐Based Resource (IBR): A plant/facility consisting of individual devices that are capable of exporting Real Power (active power) from a primary
energy source or energy storage system through a power electronic interface(s) such as an inverter or converter, and that are operated together as a
single resource at a common point of interconnection to the electric system.
Examples include, but are not limited to, plants/facilities with solar photovoltaic (PV), Type 3 and Type 4 wind, inverter-interfaced battery energy
storage systems (BESS), and fuel cell devices.
Likes

Dislikes

Response
Thank you for the comment, please refer to the TR. The TR has a table of what qualifies as an IBR and what does not qualify. HVDC is listed in the “Not
qualifying” as an IBR column.
Rachel Coyne - Texas Reliability Entity, Inc. - 10
Answer

Yes

Document Name
Comment
Texas RE recommends the drafting team consider using the terms generator or generator plant instead of the term “plant/facility”. Since Facility is a
defined term, using lower-case facility could cause confusion.
Texas RE inquires as to whether the term “turbines” should be added after the phrase “Type 3 and 4 wind.”
Likes

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Dislikes

Response
The DT had found that the plant/facility was the most fitting wording for the definition. The DT wanted to stay away from the NERC definition
“Facility.” The DT felt the Glossary definition for Facility was too vague.
Thank you for the concern, but the DT feels the wording is clear enough as stated.
Rachel Schuldt - Black Hills Corporation - 6, Group Name Black Hills Corporation - All Segments
Answer

Yes

Document Name
Comment
Black Hills Corporation supports the addition of the proposed IBR definition from the EEI that would provide improved clarity. That definition is as
follows:
Inverter-Based Resource (IBR): A plant/facility consisting of individual devices that are capable of exporting Real Power through a power electronic
interface(s) such as an inverter or converter, and that are operated together through a common facility-level controller as a single resource at a
common point of interconnection to the electric system. Examples include, but are not limited to, plants/facilities with solar photovoltaic (PV), Type 3
and Type 4 wind, battery energy storage system (BESS), VSC-HVDC systems used to connect off-shore renewable resources, and fuel cell devices.
Likes

Dislikes

Response
Please see response to EEI’s comment.
Srikanth Chennupati - Entergy - Entergy Services, Inc. - 1,3,5,6 - SERC
Answer

Yes

Document Name
Comment
No comments
Likes

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Dislikes

Response
Thank you for the response.
Cain Braveheart - Bonneville Power Administration - 1,3,5,6 - WECC
Answer

Yes

Document Name
Comment
As BPA understands, power electronic interfaces are flexible. BPA believes adding “devices capable of exporting real power through a power
electronic interface” would now include a broad spectrum of equipment that can produce electric power.
BPA recommends revising the following language:
from:
“…consisting of individual devices that are capable of exporting Real Power through a power electronic interface(s)…”
to:
“…consisting of individual devices that export Real Power through a power electronic interface(s)…”
Likes

Dislikes

Response
Thank you for the comment, the DT is going to retain the current wording of the IBR definition as the change does not appear to be substantive or
enhance the intent of the IBR definition.
Tim Kelley - Tim Kelley On Behalf of: Charles Norton, Sacramento Municipal Utility District, 3, 6, 4, 1, 5; Foung Mua, Sacramento Municipal Utility
District, 3, 6, 4, 1, 5; Kevin Smith, Balancing Authority of Northern California, 1; Nicole Looney, Sacramento Municipal Utility District, 3, 6, 4, 1, 5;
Ryder Couch, Sacramento Municipal Utility District, 3, 6, 4, 1, 5; Wei Shao, Sacramento Municipal Utility District, 3, 6, 4, 1, 5; - Tim Kelley, Group
Name SMUD and BANC
Answer

Yes

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Dislikes

Response
Thank you for the response, the (DT) is considering using the term IBR Unit as a standard only definition for MOD-026. Other DTs can use the standard
only definition approach as needed.
Thank you for the suggestion the DT feels this change is not needed and the wording is clear as stated from posting.
Mohamad Elhusseini - DTE Energy - Detroit Edison Company - 3,5, Group Name DTE Energy
Answer

Yes

Document Name
Comment
I have reviewed the proposed definition of IBR and support the proposed definition.
Likes

Dislikes

Response
Thank you for the comment and support.
Hayden Maples - Hayden Maples On Behalf of: Jeremy Harris, Evergy, 3, 5, 1, 6; Kevin Frick, Evergy, 3, 5, 1, 6; Tiffany Lake, Evergy, 3, 5, 1, 6; - Evergy
- 1,3,5,6 - MRO
Answer

Yes

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Dislikes

Response
Thank you for the comment, please see the response to EEI’s and NAGF’s comment.
Wayne Sipperly - North American Generator Forum - 5 - MRO,WECC,Texas RE,NPCC,SERC,RF
Answer

Yes

Document Name
Comment
The NAGF supports the proposed IBR definition.
Likes

Dislikes

Response
Thank you for the comment.
Anna Martinson - MRO - 1,2,3,4,5,6 - MRO, Group Name MRO Group
Answer

Yes

Document Name
Comment
The NSRF supports the proposed IBR definition, but would request the standard drafting team consider the following non-substantive changes to
improve clarity.
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Inverter-Based Resource (IBR): A plant/facility consisting of individual devices capable of exporting Real Power through a power electronic interface(s)
such as an inverter or converter, and operated together as a single resource at a common point of interconnection to the electric system. Examples
include, but are not limited to, on shore and off-shore wind and solar plants/facilities, Type 3 and Type 4 wind, battery energy storage system (BESS),
and fuel cell devices.
Likes

Dislikes

Response
Thank you for the comment, the DT agrees that these changes are non-substantive and are not inclined to make these modifications.
Alison MacKellar - Constellation - 5
Answer

Yes

Document Name
Comment
Constellation aligns with the NAGF comments.
Alison Mackellar on behalf of Constellation Segments 5 and 6
Likes

Dislikes

Response
Thank you for the comment, please see the response to NAGF’s comment.
Kimberly Turco - Constellation - 6
Answer

Yes

Document Name
Comment
Constellation aligns with NAGF comments.

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Kimberly Turco on behalf of Constellation Energy Segments 5 and 6.
Likes

Dislikes

Response
Thank you for the comment, please see the response to NAGF’s comment.
Kristine Martz - Edison Electric Institute - NA - Not Applicable - NA - Not Applicable
Answer

Yes

Document Name
Comment
EEI does not object to the revisions made to the proposed IBR definition but there are some non-substantive changes (in boldface text) that we feel
would provide improved clarification of the intent of the definition.
Inverter-Based Resource (IBR): A plant/facility consisting of individual devices that are capable of exporting Real Power through a power electronic
interface(s) such as an inverter or converter, and that are operated together through a common facility-level controller as a single resource at a
common point of interconnection to the electric system. Examples include, but are not limited to, plants/facilities with solar photovoltaic (PV), Type 3
and Type 4 wind, battery energy storage system (BESS), VSC-HVDC systems used to connect off-shore renewable resources, and fuel cell devices.
Likes

Dislikes

Response
The DT considered adding this to the IBR definition, however decided against it due to already listed Type 3 and Type 4 wind within the definition. An
offshore wind IBR is still an IBR whether it is connected via an AC or HVDC cable. Further, the DT felt as though the discussion within the technical
rationale was sufficient to explain that the HVDC terminals are part of the IBR in this case.
Hillary Creurer - Allete - Minnesota Power, Inc. - 1
Answer

Yes

Document Name
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Comment
Minnesota Power supports the definition for IBR as proposed, but also supports EEI and MRO’s NERC Standards Review Forum’s (NSRF) suggestions to
improve clarity.
Likes

Dislikes

Response
Please see the responses to EEI’s and MRO NSRF’s comments.
Selene Willis - Edison International - Southern California Edison Company - 5
Answer

Yes

Document Name
Comment
"Please see EEI Comments"
Likes

Dislikes

Response
Please see response to EEI’s comment.
Nick Leathers - Nick Leathers On Behalf of: David Jendras Sr, Ameren - Ameren Services, 3, 6, 1; - Nick Leathers
Answer

Yes

Document Name
Comment
Ameren does not have any additional comments for consideration by the drafting team.
Likes

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Dislikes

Response
Thank you for the comment.
Carver Powers - Utility Services, Inc. - 4
Answer

Yes

Document Name
Comment
1. Recommend clarifying “Type 3 and Type 4 wind” by including “turbine” after wind in the proposed IBR definition.
2. Without a clear definition of “power electronic interface(s)” it could be determined that it includes transformers which we believe is not the intent
of this definition. Can the SDT provide clarity on what is and what is not a “power electronic interface(s)”
Likes

Dislikes

Response
Please see the response to Texas RE’s comment.
DT believes transformers are decidedly not power electronic interfaces.

1.
2.

George E Brown - Pattern Operators LP - 5
Answer

Yes

Document Name
Comment
Pattern Energy supports Midwest Reliability Organization’s NERC Standards Review Forum’s (MRO NSRF) comments on this question.
Likes

Dislikes

Response
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Please see response to MRO’s NSRF’s comment.
Jodirah Green - ACES Power Marketing - 1,3,4,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name ACES Collaborators
Answer

Yes

Document Name
Comment
It is the opinion of ACES that the inclusion of the phrase “plant/facility” within the proposed IBR definition introduces additional confusion into this
definition. As this term is not explicitly defined, it allows for a considerable amount of interpretation by the industry. It is our opinion that the term
facility should instead be included within the defined term itself (i.e., Inverter-Based Resource Facility) to be consistent with other uses of this phrase
within the NERC Glossary of Terms.
Likes

Dislikes

Response
The DT believes the plant/facility is sufficiently described by what follows the term in the first sentence of the definition. There should not be
confusion, but one can refer to the TR for further explanation.
Jennifer Bray - Arizona Electric Power Cooperative, Inc. - 1
Answer

Yes

Document Name
Comment
AEPC signed on to ACES comments:
It is the opinion of ACES that the inclusion of the phrase “plant/facility” within the proposed IBR definition introduces additional confusion into this
definition. As this term is not explicitly defined, it allows for a considerable amount of interpretation by the industry. It is our opinion that the term
facility should instead be included within the defined term itself (i.e., Inverter-Based Resource Facility) to be consistent with other uses of this phrase
within the NERC Glossary of Terms.
Likes
Dislikes

0
0

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Response
Please see response to ACES’s comment.
Charles Yeung - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC,Texas RE,NPCC,SERC,RF, Group Name SRC 2024
Answer

Yes

Document Name
Comment
The ISO/RTO Council (IRC) Standards Review Committee (SRC) supports the revised term, but notes that the deletion of “connected to the electric
system” from the IBR definition, implies that the IBR term is not in and of itself applicable to BES or non-BES interconnections. Therefore, those
reliability requirements applicable to IBRs will need to specify whether they apply to the new registration categories of “GO/GOP Category 1” and
“GO/GOP Category 2” to complement the IBR definition. Any and all current and proposed standards applicable to IBR should be reviewed and
updated to clarify their applicability.
In addition, the SRC proposes the changes in red below.
Inverter-Based Resource (IBR): A plant/facility that includes one or more individual devices that are capable of exporting Real Power through a power
electronic interface(s) such as an inverter or converter, and that are operated together as a single resource at a common point of interconnection{C}[1]
to the electric system. Examples include, but are not limited to, plants/facilities with that include one or more solar photovoltaic (PV), Type 3 and Type
4 wind, battery energy storage system (BESS), and fuel cell devices.
The SRC proposes that a definition or examples of what constitutes a “common point of interconnection” be provided (such as in a footnote) since this
term is not defined in the NERC Glossary of Terms and it is unclear whether it refers to a transformer, a bus, or some other point of interconnection.
Illustrative examples are also useful to clarify how a hybrid plant, in which only a portion of the interconnected facility employs an inverter or
converter, falls under the definition.
The SRC proposes that the language “one or more” be restored in the first sentence of the definition and added to the second sentence for clarity and
consistency.
Finally, the SRC is concerned that the word “with” in the second sentence of the definition is unclear. Therefore, we propose replacing the word
“with” with “that include.”
Footnote: ISO NE is a party to these comments however does not support the comments provided in response to Q1.
Likes

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Dislikes

Response
The DT agrees to leave applicability to the specific Drafting Teams. DT believes the phrase “operated together as a single resource” is sufficiently clear.
Please review the Technical Rationale (TR) as that goes more into depth. The drafting team agrees the definition by itself is not applicable to BES or
non-BES interconnections as this is the intent of the language. Decisions about applicability are left to the standard drafting team using the definition.
For example: BES-IBR, DER-IBR, BPS-IBR, Category 1 IBR, Category 2 IBR, etc. The DT also agrees that proposed standards will need to be reviewed for
conformance. The DT views the wording of the second sentence as easy to understand and will retain the current wording.
Kennedy Meier - Electric Reliability Council of Texas, Inc. - 2
Answer

Yes

Document Name
Comment
ERCOT joins the comments submitted by the ISO/RTO Council (IRC) Standards Review Committee (SRC) and adopts them as its own.
Likes

Dislikes

Response
Please see response to IRC SRC comment.
Thomas Foltz - AEP - 5
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the comment.
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Jessica Cordero - Unisource - Tucson Electric Power Co. - 1
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the comment.
Sean Bodkin - Dominion - Dominion Resources, Inc. - 6, Group Name Dominion
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the comment.
Barbara Marion - Dominion - Dominion Resources, Inc. - 5,6, Group Name Dominion
Answer

Yes

Document Name
Comment
Likes
Dislikes

0
0

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Response
Thank you for the comment.
Donna Wood - Tri-State G and T Association, Inc. - 1
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the comment.
Daniela Atanasovski - APS - Arizona Public Service Co. - 1
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the comment.
Diana Aguas - CenterPoint Energy Houston Electric, LLC - 1 - Texas RE
Answer

Yes

Document Name
Comment

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Likes

Dislikes

Response
Thank you for the comment.
Sing Tay - AES - AES Corporation - 5 - MRO,WECC,Texas RE,NPCC,SERC,RF
Answer

Yes

Document Name
Comment
Likes

Dislikes

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the comment.
Casey Jones - Berkshire Hathaway - NV Energy - 5 - WECC
Answer

Yes

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Document Name
Comment
Likes

Dislikes

Response
Thank you for the comment.
Stephen Stafford - Stephen Stafford On Behalf of: Greg Davis, Georgia Transmission Corporation, 1; - Stephen Stafford
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the comment.
Constantin Chitescu - Ontario Power Generation Inc. - 5
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the comment.
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Pamela Hunter - Southern Company - Southern Company Services, Inc. - 1,3,5,6 - SERC, Group Name Southern Company
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the comment.
Mike Magruder - Avista - Avista Corporation - 1
Answer

Yes

Document Name
Comment
Likes

Dislikes

Response
Thank you for the comment.
Steven Rueckert - Western Electricity Coordinating Council - 10, Group Name WECC
Answer

Yes

Document Name
Comment
Likes
Dislikes

0
0

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Response
Thank you for the comment.
Patricia Lynch - NRG - NRG Energy, Inc. - 5
Answer
Document Name
Comment
NRG Energy Inc is in support of the comments made by EPSA.
Likes

Dislikes

Response
Thank you for the response please see response to EPSA.
Martin Sidor - NRG - NRG Energy, Inc. - 5,6
Answer
Document Name
Comment
NRG agrees with the EPSA comments.
Likes

Dislikes

Response
Thank you for the response please see response to EPSA.
Gail Elliott - Gail Elliott On Behalf of: Michael Moltane, International Transmission Company Holdings Corporation, 1; - Gail Elliott
Answer
Document Name
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Comment
ITC has no comments on the proposed definition for Project 2020-06.
Likes

Dislikes

Response
Thank you for the comment.

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Dislikes

Response
Thank you for the comment.
Kennedy Meier - Electric Reliability Council of Texas, Inc. - 2
Answer
Document Name
Comment
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

ERCOT joins the comments submitted by the IRC SRC and adopts them as its own.
Likes

Dislikes

Response
Please see the response to IRC SRC’s comment.
Steven Rueckert - Western Electricity Coordinating Council - 10, Group Name WECC
Answer
Document Name
Comment
WECC voted yes but offers the following for consideration. WECC appreciates the efforts to provide a definition for Inverter-Based Resource
(IBR). WECC asks if the DT is planning to provide some examples so that “misunderstanding” will be avoided when the definition is applied within
Standards/Requirements? Compliance can create interesting arguments that ignore the reliability (and risk) concerns. It is understood that the
registration candidate pool will be limited to the definition of Generator Operator and Generator Owner recently approved by FERC. The definitions
did not use IBR directly and, instead, used “non-BES inverter based generating resources” (for Cat 2) and “generating Facility(ies)” for Cat 1. It is clear
to WECC that the proposed IBR definition is applicable for Cat 1 and Cat 2 GOs and GOPs.
Likes

Dislikes

Response
Thank you for the comments, DT has provided examples in the TR on this topic but did not want to create an exhaustive list within the definition. The
drafting team agrees the definition by itself is not applicable to BES or non-BES interconnections as this was the intent of the language. Decisions
about applicability are left to the standard drafting team using the definition. For example: BES-IBR, DER-IBR, BPS-IBR, Category 1 IBR, Category 2 IBR,
etc. The drafting team also agrees that proposed standards will need to be reviewed for conformance.
Charles Yeung - Southwest Power Pool, Inc. (RTO) - 2 - MRO,WECC,Texas RE,NPCC,SERC,RF, Group Name SRC 2024
Answer
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Document Name

2020-06_IBR_Definition_Unofficial_Comment_Form_SRCFinal.docx

Comment
Concerns Associated with Removing the IBR Unit Definition
The SRC is aware of a draft Standards Authorization Request (SAR) entitled Revisions to FAC-001-4 and FAC-002-4 that the Inverter-Based Resource
Performance Subcommittee (IRPS) is currently composing that seeks to address modeling conformity. The SRC believes that this may require unitlevel model validation and benchmarking (where the original manufacturer conducts laboratory tests to compare the actual equipment response to
the modeled response) before models can be accurately applied at the plant/facility level. This may make the elimination of the IBR Unit definition
problematic if this term will be needed when drafting future standard requirements.
See Purpose or Goal, bullet item #2 (on page 3):
2.” …require Transmission Planners (TPs) and Planning Coordinators (PCs) to assess IBR plant capability and performance conformity for example
through a combination of review of documentation, simulation studies, and physical tests that a newly interconnecting IBR complies with applicable
IBR performance requirements.”
See Purpose or Goal, paragraph (on page 4):
“Having a specific conformity assessment process (in addition to currently performed interconnection studies) will ensure that the TP and PC verify
generator conformity with applicable interconnection requirements, preferably prior to IBR plant commissioning. Standard drafting team should
consider FERC GIA/GIP requirements to determine an aligning timeline to resolve discrepancies in plant conformity. Enhancing current generator
interconnection processes with clear conformity assessment processes will ensure that new BPS-connected IBR facilities are designed with the
capabilities necessary for reliable operation.”
Further, the SRC notes that existing NERC standards apply requirements at the unit level. For instance, MOD-026, Requirement R2, Part 2.1 has unitspecific requirements for excitation control systems.
2.1. Each applicable unit’s model shall be verified by the Generator Owner using one or more models acceptable to the Transmission Planner.
Verification for individual units less than 20 MVA (gross nameplate rating) in a generating plant (per Section 4.2.1.2, 4.2.2.2, or 4.2.3.2) may be
performed using either individual unit or aggregate unit model(s), or both. Each verification shall include the following: . . .
Similarly, PRC-024, Section 4 Applicability, Part 4.2 Facilities, Part 4.2.1.4 includes individual dispersed power producing resource(s) as applicable
facilities identified in Inclusion I4 of the BES Definition.
4.2.1.4 Individual dispersed power producing resource(s) identified in the BES Definition, Inclusion I4.
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

For these reasons, the SRC believes consideration should be given to retaining a definition of “IBR Unit” as it will engender common understanding
and application of the term among Registered Entities. While an “IBR Unit” definition may not need to be finalized in this immediate project, there will
likely be a need to complete this task in the future to align with developing frameworks.
Likes

Dislikes

Response
Thank you for the response, however the (DT) is considering using the term IBR Unit as a standard only definition for MOD-026 at this time. Other DTs
can use the standard only definition approach as needed.
Jennifer Bray - Arizona Electric Power Cooperative, Inc. - 1
Answer
Document Name
Comment
AEPC signed on to ACES comments:
We at ACES applaud the SDT for the work that has been put into developing the IBR definition. We are greatly encouraged by the SDT’s willingness to
heed industry feedback and implement changes to the IBR definition. However, it is the opinion of ACES that consolidating the IBR Unit and IBR Facility
definitions into a single definition is a mistake.
It is the perspective of ACES that, without a way to clearly define what constitutes the individual devices of an IBR, each individual Standards Drafting
Team is left to provide their own (potentially unique) definition. We believe that this will be a detriment to consistency and will potentially have a
negative impact on compliance. We suggest utilizing terms and/or language already contained within the Glossary of Terms whenever possible. Thus,
we recommend using the following terms to define these types of generating resources (a:
Inverter-Based Resource (IBR) Facility: One or more IBR Unit(s), and any associated Element(s) required for the operation thereof, connected to the
electric system and operated as a single resource at a common point of Interconnection.
Inverter-Based Resource (IBR) Unit: An individual generating resource capable of exporting electric power that uses a power electronic interface, such
as an inverter or converter, and connects at a single point to a system designed primarily for delivering such electric power to a common point of

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Interconnection (note: a system designed primarily for delivering such electric power to a common point of Interconnection is commonly referred to
as a collector system).
Thank you for the opportunity to comment.
Likes

Dislikes

Response
Please see response to ACES’ comment.
Jodirah Green - ACES Power Marketing - 1,3,4,5,6 - MRO,WECC,Texas RE,SERC,RF, Group Name ACES Collaborators
Answer
Document Name
Comment
We at ACES applaud the SDT for the work that has been put into developing the IBR definition. We are greatly encouraged by the SDT’s willingness to
heed industry feedback and implement changes to the IBR definition. However, it is the opinion of ACES that consolidating the IBR Unit and IBR Facility
definitions into a single definition is a mistake.
It is the perspective of ACES that, without a way to clearly define what constitutes the individual devices of an IBR, each individual Standards Drafting
Team is left to provide their own (potentially unique) definition. We believe that this will be a detriment to consistency and will potentially have a
negative impact on compliance. We suggest utilizing terms and/or language already contained within the Glossary of Terms whenever possible. Thus,
we recommend using the following terms to define these types of generating resources (a:
Inverter-Based Resource (IBR) Facility: One or more IBR Unit(s), and any associated Element(s) required for the operation thereof, connected to the
electric system and operated as a single resource at a common point of Interconnection.
Inverter-Based Resource (IBR) Unit: An individual generating resource capable of exporting electric power that uses a power electronic interface, such
as an inverter or converter, and connects at a single point to a system designed primarily for delivering such electric power to a common point of
Interconnection (note: a system designed primarily for delivering such electric power to a common point of Interconnection is commonly referred to
as a collector system).
Thank you for the opportunity to comment.

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Likes

Dislikes

Response
The DT will consider this if the DT decides to create a standard only definition for IBR Unit. It was not the teams intention to combine IBR Unit and IBR
Facility into the same the definition, the team is not using “Facility” in the definition but using the undefined “facility” term.
George E Brown - Pattern Operators LP - 5
Answer
Document Name
Comment
Pattern Energy supports Midwest Reliability Organization’s NERC Standards Review Forum’s (MRO NSRF) comments on this question.
Likes

Dislikes

Response
Please see the response to MRO NSRFs comment.
Ruida Shu - Northeast Power Coordinating Council - 1,2,3,4,5,6,7,8,9,10 - NPCC, Group Name NPCC RSC
Answer
Document Name
Comment
NPCC RSC supports the project.
Likes

Dislikes

Response
Thank you for the support.
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Scott Thompson - PNM Resources - Public Service Company of New Mexico - 1,3,5 - WECC
Answer
Document Name
Comment
Any and all items listed items/assets in the proposed IBR definition should be defined and in the NERC Glossary of Terms.
Likes

Dislikes

Response
Thank you for the comment, the team did not want to make an limiting and exhaustive list within the definition, this information can be found in the
TR.
Pamela Hunter - Southern Company - Southern Company Services, Inc. - 1,3,5,6 - SERC, Group Name Southern Company
Answer
Document Name
Comment
Southern Company has no further comments.
Likes

Dislikes

Response
Thank you for the comment.
Constantin Chitescu - Ontario Power Generation Inc. - 5
Answer
Document Name
Comment
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

OPG supports NPCC Regional Standards Committee’s comments.
Likes

Dislikes

Response
Please see the response to NPCC’s RS comment.
Nick Leathers - Nick Leathers On Behalf of: David Jendras Sr, Ameren - Ameren Services, 3, 6, 1; - Nick Leathers
Answer
Document Name
Comment
Ameren does not have any additional comments for consideration by the drafting team.
Likes

Dislikes

Response
Thank you for the comment.
Romel Aquino - Edison International - Southern California Edison Company - 3
Answer
Document Name

Project 2020-06 _ EEI Near Final Revised IBR Definition Draft 3 Rev 0a 8_06_2024.docx

Comment
See comments submitted by the Edison Eclectic Institute in the attached file
Likes

Dislikes

Response
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Thank you for the comments, please response to EEI’s comment.
Kimberly Turco - Constellation - 6
Answer
Document Name
Comment
Constellation has no additional comments
Kimberly Turco on behalf of Constellation Energy Segments 5 and 6.
Likes

Dislikes

Response
Thank you for the comment.
Gail Elliott - Gail Elliott On Behalf of: Michael Moltane, International Transmission Company Holdings Corporation, 1; - Gail Elliott
Answer
Document Name
Comment
ITC has no comments on the proposed definition for Project 2020-06.
Likes

Dislikes

Response
Thank you for the comment.
Alison MacKellar - Constellation - 5
Answer
Document Name
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Comment
Constellation has no additional comments.
Alison Mackellar on behalf of Constellation Segments 5 and 6
Likes

Dislikes

Response
Thank you for the comment.
Wayne Sipperly - North American Generator Forum - 5 - MRO,WECC,Texas RE,NPCC,SERC,RF
Answer
Document Name
Comment
The NAGF has no additional comments.
Likes

Dislikes

Response
Thank you for the comment.
Martin Sidor - NRG - NRG Energy, Inc. - 5,6
Answer
Document Name
Comment
NRG agrees with the EPSA comments.
Likes

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Dislikes

Response
Please see EPSA comment for response.
Mohamad Elhusseini - DTE Energy - Detroit Edison Company - 3,5, Group Name DTE Energy
Answer
Document Name
Comment
No other comments to provide.
Likes

Dislikes

Response
Thank you for the comment.
Jennifer Weber - Tennessee Valley Authority - 1,3,5,6 - SERC
Answer
Document Name
Comment
Technical Rationale:
•
•

Need to define the acronym “LCC” as, while it may be obvious to some, it isn’t necessarily known to all. Note that the definition of “VSC
HVDC” should be moved up to the first time it’s used.
Contains the term “IBR Unit,” which is no longer a defined term, and, as such, should not be included in the document.

Implementation Plan:
•
•

The Background section contains the term “IBR Unit,” which is no longer a defined term, and, as such, should not be included in the
document.
The General Considerations section makes reference to multiple definitions, but there is only one (“IBR”) now.

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Likes

Dislikes

Response
Thank you for these comments, the team has made the conforming changes to the IP and TR regarding IBR Unit. The DT has made the TR conforming
changes.
Brian Van Gheem - Radian Generation - NA - Not Applicable - NA - Not Applicable
Answer
Document Name
Comment
1. Thank you for the opportunity to comment.

Likes

Dislikes

Response
Thank you for the comment.
Michael Johnson - Michael Johnson On Behalf of: Marco Rios, Pacific Gas and Electric Company, 3, 1, 5; Sandra Ellis, Pacific Gas and Electric
Company, 3, 1, 5; Tyler Brun, Pacific Gas and Electric Company, 3, 1, 5; - Michael Johnson, Group Name PG&E All Segments
Answer
Document Name
Comment
PGAE is curious why the SDT did not use the IEEE definition of an IBR and IBR Unit so there is alignment between NERC and IEEE? The difference does
not appear to change the overall meaning but may lead to confusion/conflict down the road between product developers and compliance related
tasks.
Likes
Dislikes

0
0

Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Response
The DT does align the NERC IBR definition with IEEE 2800 definition, but the NERC definition only applies to NERC standards.
Andy Thomas - Duke Energy - 1,3,5,6 - SERC,RF
Answer
Document Name
Comment
None.
Likes

Dislikes

Response
Thank you for the comment.
Devin Shines - PPL - Louisville Gas and Electric Co. - 1,3,5,6 - SERC,RF
Answer
Document Name
Comment
LG&E/KU thanks the DT for their work on this desperately needed definition. The suggested edits sharpen the proposed definition and reduce the risk
of confusion regarding IBRs co-located with synchronous generators and separate IBRs sharing a point of interconnection. Most of these edits are
believed to be non-substantive relative to the intent of the DT.
Likes

Dislikes

Response
Thank you for the support.
Anna Todd - Southern Indiana Gas and Electric Co. - 3,5,6 - RF
Answer
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Document Name
Comment
N/A
Likes

Dislikes

Response
Thank you for the comment.
Sing Tay - AES - AES Corporation - 5 - MRO,WECC,Texas RE,NPCC,SERC,RF
Answer
Document Name
Comment
AES Clean Energy believes that a definition for IBR Unit is still required. Currently, PRC-028 proposed Draft 4 has its own “IBR unit” definition within
the standard in order to create the requirement language needed. Since other Standards are being revised or created to meet FERC Order 901, AES
Clean Energy believes that having a NERC Glossary definition for IBR Unit will help maintain consistency between all the different Standards that will
be applicable to IBRs. AES Clean Energy strongly recommends that NERC continues to pursue a definition for IBR Unit.
Likes

Dislikes

Response
Thank you for the response, however the (DT) is considering using the term IBR Unit as a standard only definition for MOD-026 at this time. Other DTs
can use the standard only definition approach as needed. PRC-028 is including IBR Unit in a footnote.
Mark Garza - FirstEnergy - FirstEnergy Corporation - 4, Group Name FE Voter
Answer
Document Name
Comment
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

None
Likes

Dislikes

Response
Thank you for the comment.
Srikanth Chennupati - Entergy - Entergy Services, Inc. - 1,3,5,6 - SERC
Answer
Document Name
Comment
None
Likes

Dislikes

Response
Thank you for the comment.
Daniela Atanasovski - APS - Arizona Public Service Co. - 1
Answer
Document Name
Comment
None
Likes

Dislikes

Response
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

Thank you for the comment.
Donna Wood - Tri-State G and T Association, Inc. - 1
Answer
Document Name
Comment
N/A
Likes

Dislikes

Response
Thank you for the comment.
Sean Steffensen - IDACORP - Idaho Power Company - 1
Answer
Document Name
Comment
IPC has concerns about removing the entire current definition of IBR Units. Will “IBR Unit” be defined somewhere else, or excluded altogether? IPC
believes a broader definition of IBR (unit) is still necessary and would be helpful to the process.
Likes

Dislikes

End of Report
Consideration of Comments | Project 2020-06 Verifications of Models and Data for Generators
Draft 3 of IBR Definition | September, 2024

UPDATED
Standards Announcement

Project 2020-06 Verifications of Models and Data for Generators
Inverter-based Resource Glossary Term
Formal Comment Period Open through August 12, 2024
Now Available

Under the NERC Rules of Procedure, each entity and its affiliates is collectively permitted one voting
membership per Registered Ballot Body Segment. Each entity that undergoes a change in corporate
structure (such as a merger or acquisition) that results in the entity or affiliated entities having more than
the one permitted representative in a particular Segment must withdraw the duplicate membership(s)
prior to joining new ballot pools or voting on anything as part of an existing ballot pool. Contact
[email protected] to assist with the removal of any duplicate registrations.
Commenting

Use the Standards Balloting and Commenting System (SBS) to submit comments. An unofficial Word
version of the comment form is posted on the project page.
•

Contact NERC IT support directly at https://support.nerc.net/ (Monday – Friday, 8 a.m. - 5
p.m. Eastern) for problems regarding accessing the SBS due to a forgotten password,
incorrect credential error messages, or system lock-out.

•

Passwords expire every 6 months and must be reset.

•

The SBS is not supported for use on mobile devices.

•

Next Steps

Additional ballots will be conducted August 2-12, 2024.

RELIABILITY | RESILIENCE | SECURITY

North American Electric Reliability Corporation
3353 Peachtree Rd, NE
Suite 600, North Tower
Atlanta, GA 30326
404-446-2560 | www.nerc.com

Standards Announcement | Project 2020-06 Verification of Data and Models for Generators
Inverter-based Resource Glossary Term | July 2024

Standards Announcement

Project 2020-06 Verifications of Models and Data for Generators
Inverter-based Resource Glossary Term
Formal Comment Period Open through August 13, 2024
Now Available

Under the NERC Rules of Procedure, each entity and its affiliates is collectively permitted one voting
membership per Registered Ballot Body Segment. Each entity that undergoes a change in corporate
structure (such as a merger or acquisition) that results in the entity or affiliated entities having more than
the one permitted representative in a particular Segment must withdraw the duplicate membership(s)
prior to joining new ballot pools or voting on anything as part of an existing ballot pool. Contact
[email protected] to assist with the removal of any duplicate registrations.
Commenting

Use the Standards Balloting and Commenting System (SBS) to submit comments. An unofficial Word
version of the comment form is posted on the project page.
•

Contact NERC IT support directly at https://support.nerc.net/ (Monday – Friday, 8 a.m. - 5
p.m. Eastern) for problems regarding accessing the SBS due to a forgotten password,
incorrect credential error messages, or system lock-out.

•

Passwords expire every 6 months and must be reset.

•

The SBS is not supported for use on mobile devices.

•

Next Steps

Additional ballots will be conducted August 2-13, 2024.

RELIABILITY | RESILIENCE | SECURITY

North American Electric Reliability Corporation
3353 Peachtree Rd, NE
Suite 600, North Tower
Atlanta, GA 30326
404-446-2560 | www.nerc.com

Standards Announcement | Project 2020-06 Verification of Data and Models for Generators
Inverter-based Resource Glossary Term | July 2024

NERC Balloting Tool (/)

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Users

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BALLOT RESULTS
Comment: View Comment Results (/CommentResults/Index/337)
Ballot Name: 2020-06 Verifications of Models and Data for Generators Inverter-Based Resource (IBR) AB 3 DEF
Voting Start Date: 8/2/2024 12:01:00 AM
Voting End Date: 8/12/2024 8:00:00 PM
Ballot Type: DEF
Ballot Activity: AB
Ballot Series: 3
Total # Votes: 241
Total Ballot Pool: 282
Quorum: 85.46
Quorum Established Date: 8/12/2024 3:52:35 PM
Weighted Segment Value: 91.57
Ballot
Pool

Segment
Weight

Affirmative
Votes

Affirmative
Fraction

Negative Votes w/
Comment

Negative Fraction
w/ Comment

Negative Votes w/o
Comment

Abstain

No
Vote

Segment:
1

0.887

0.113

Segment:
2

0.8

Segment:
3

0.894

0.106

Segment:
4

0.923

0.077

Segment:
5

0.9

0.1

Segment:
6

0.857

0.143

Segment:
7

Segment:
8

Segment:
9

Segment:
10

0.6

Totals:

282

6.4

190

5.861

0.539

Segment

BALLOT POOL MEMBERS
Show

All

Segment

entries
Organization

Search:
Voter
Dennis Sauriol

Designated Proxy

Ballot
Affirmative

NERC Memo
N/A

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Allete - Minnesota Power, Inc.

Hillary Creurer

Affirmative

N/A

Ameren - Ameren Services

Tamara Evey

Affirmative

N/A

American Transmission Company, LLC

Amy Wilke

Negative

Comments
Submitted

APS - Arizona Public Service Co.

Daniela Atanasovski

Affirmative

N/A

Arizona Electric Power Cooperative, Inc.

Jennifer Bray

Affirmative

N/A

Arkansas Electric Cooperative Corporation

Emily Corley

None

N/A

Associated Electric Cooperative, Inc.

Mark Riley

Affirmative

N/A

Austin Energy

Thomas Standifur

None

N/A

Avista - Avista Corporation

Mike Magruder

Affirmative

N/A

Balancing Authority of Northern California

Kevin Smith

Affirmative

N/A

BC Hydro and Power Authority

Adrian Andreoiu

Abstain

N/A

Berkshire Hathaway Energy - MidAmerican Energy
Co.

Terry Harbour

Affirmative

N/A

Black Hills Corporation

Micah Runner

Affirmative

N/A

CenterPoint Energy Houston Electric, LLC

Daniela Hammons

Abstain

N/A

City Utilities of Springfield, Missouri

Michael Bowman

Affirmative

N/A

Con Ed - Consolidated Edison Co. of New York

Dermot Smyth

Affirmative

N/A

Dairyland Power Cooperative

Karrie Schuldt

Affirmative

N/A

Dominion - Dominion Virginia Power

Steven Belle

Affirmative

N/A

Duke Energy

Katherine Street

Negative

Comments
Submitted

Edison International - Southern California Edison
Company

Robert Blackney

Affirmative

N/A

Entergy

Brian Lindsey

Affirmative

N/A

Evergy

Kevin Frick

Affirmative

N/A

Eversource Energy

Joshua London

Affirmative

N/A

Exelon

Daniel Gacek

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Theresa Ciancio

Negative

Comments
Submitted

Georgia Transmission Corporation

Greg Davis

Affirmative

N/A

Glencoe Light and Power Commission

Terry Volkmann

Affirmative

N/A

Hydro One Networks, Inc.

Emma Halilovic

Ijad Dewan

Abstain

N/A

Hydro-Quebec (HQ)

Nicolas Turcotte

Chantal Mazza

Affirmative

N/A

IDACORP - Idaho Power Company

Sean Steffensen

Abstain

N/A

Imperial Irrigation District

Jesus Sammy Alcaraz

Denise Sanchez

Affirmative

N/A

International Transmission Company Holdings
Corporation

Michael Moltane

Gail Elliott

Affirmative

N/A

JEA

Joseph McClung

Affirmative

N/A

Lakeland Electric

Larry Watt

None

N/A

LaTroy Brumfield

Tim Kelley

Ellese Murphy

Hayden Maples

Stephen Stafford

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Lincoln Electric System

Josh Johnson

Affirmative

N/A

Long Island Power Authority

Isidoro Behar

Abstain

N/A

Los Angeles Department of Water and Power

faranak sarbaz

None

N/A

LS Power Transmission, LLC

Jennifer Richardson

Abstain

N/A

Manitoba Hydro

Nazra Gladu

None

N/A

Minnkota Power Cooperative Inc.

Theresa Allard

Affirmative

N/A

Muscatine Power and Water

Andrew Kurriger

Affirmative

N/A

National Grid USA

Michael Jones

Abstain

N/A

NB Power Corporation

Jeffrey Streifling

Abstain

N/A

Nebraska Public Power District

Jamison Cawley

Affirmative

N/A

NextEra Energy - Florida Power and Light Co.

Silvia Mitchell

Affirmative

N/A

NiSource - Northern Indiana Public Service Co.

Alison Nickells

Affirmative

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Terri Pyle

Affirmative

N/A

Omaha Public Power District

Doug Peterchuck

Affirmative

N/A

Oncor Electric Delivery

Byron Booker

Abstain

N/A

OTP - Otter Tail Power Company

Charles Wicklund

None

N/A

Pacific Gas and Electric Company

Marco Rios

Affirmative

N/A

Pedernales Electric Cooperative, Inc.

Bradley Collard

None

N/A

Platte River Power Authority

Marissa Archie

Affirmative

N/A

PNM Resources - Public Service Company of New
Mexico

Lynn Goldstein

Affirmative

N/A

Portland General Electric Co.

Brooke Jockin

Abstain

N/A

PPL Electric Utilities Corporation

Michelle McCartney
Longo

Negative

Comments
Submitted

PSEG - Public Service Electric and Gas Co.

Karen Arnold

None

N/A

Public Utility District No. 1 of Chelan County

Diane E Landry

Affirmative

N/A

Public Utility District No. 1 of Snohomish County

Alyssia Rhoads

Affirmative

N/A

Sacramento Municipal Utility District

Wei Shao

Tim Kelley

Affirmative

N/A

Salt River Project

Laura Somak

Israel Perez

Negative

Comments
Submitted

Santee Cooper

Chris Wagner

Affirmative

N/A

SaskPower

Wayne Guttormson

Abstain

N/A

Sempra - San Diego Gas and Electric

Mohamed Derbas

Affirmative

N/A

Southern Company - Southern Company Services,
Inc.

Matt Carden

Affirmative

N/A

Sunflower Electric Power Corporation

Paul Mehlhaff

Affirmative

N/A

Tacoma Public Utilities (Tacoma, WA)

John Merrell

Affirmative

N/A

Tallahassee Electric (City of Tallahassee, FL)

Scott Langston

Abstain

N/A

Tennessee Valley Authority

David Plumb

Negative

Comments
Submitted

Jay Sethi

Tammy Porter

Michael Johnson

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Tri-State G and T Association, Inc.

Donna Wood

Affirmative

N/A

U.S. Bureau of Reclamation

Richard Jackson

Abstain

N/A

Western Area Power Administration

Ben Hammer

Affirmative

N/A

Xcel Energy, Inc.

Eric Barry

Affirmative

N/A

California ISO

Darcy O'Connell

Affirmative

N/A

Electric Reliability Council of Texas, Inc.

Kennedy Meier

Affirmative

N/A

Independent Electricity System Operator

Helen Lainis

Affirmative

N/A

ISO New England, Inc.

John Pearson

Affirmative

N/A

Midcontinent ISO, Inc.

Bobbi Welch

Affirmative

N/A

New York Independent System Operator

Gregory Campoli

Affirmative

N/A

PJM Interconnection, L.L.C.

Thomas Foster

Affirmative

N/A

Southwest Power Pool, Inc. (RTO)

Joshua Phillips

Affirmative

N/A

AEP

Leshel Hutchings

Affirmative

N/A

Ameren - Ameren Services

David Jendras Sr

Affirmative

N/A

APS - Arizona Public Service Co.

Jessica Lopez

Affirmative

N/A

Arkansas Electric Cooperative Corporation

Ayslynn Mcavoy

Affirmative

N/A

Avista - Avista Corporation

Robert Follini

Negative

Comments
Submitted

BC Hydro and Power Authority

Ming Jiang

Abstain

N/A

Berkshire Hathaway Energy - MidAmerican Energy
Co.

Joseph Amato

Affirmative

N/A

Black Hills Corporation

Josh Combs

Carly Miller

Affirmative

N/A

Buckeye Power, Inc.

Tom Schmidt

Ryan Strom

Affirmative

N/A

CMS Energy - Consumers Energy Company

Karl Blaszkowski

Affirmative

N/A

Colorado Springs Utilities

Hillary Dobson

None

N/A

Con Ed - Consolidated Edison Co. of New York

Peter Yost

Affirmative

N/A

Dominion - Dominion Virginia Power

Victoria Crider

Affirmative

N/A

DTE Energy - Detroit Edison Company

Marvin Johnson

Affirmative

N/A

Duke Energy - Florida Power Corporation

Marcelo Pesantez

Negative

Comments
Submitted

Edison International - Southern California Edison
Company

Romel Aquino

Affirmative

N/A

Entergy

James Keele

Affirmative

N/A

Evergy

Marcus Moor

Affirmative

N/A

Eversource Energy

Vicki O'Leary

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Aaron Ghodooshim

None

N/A

Georgia System Operations Corporation

Scott McGough

Affirmative

N/A

Great River Energy

Michael Brytowski

Affirmative

N/A

Imperial Irrigation District

George Kirschner

Affirmative

N/A

Affirmative

N/A

Marilyn Williams

Pirouz Honarmand

Elizabeth Davis

Nick Leathers

Denise Sanchez

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Lakeland Electric

Steven Marshall

None

N/A

Lincoln Electric System

Sam Christensen

Affirmative

N/A

Los Angeles Department of Water and Power

Fausto Serratos

None

N/A

Manitoba Hydro

Mike Smith

None

N/A

MGE Energy - Madison Gas and Electric Co.

Benjamin Widder

Affirmative

N/A

Muscatine Power and Water

Seth Shoemaker

Affirmative

N/A

National Grid USA

Brian Shanahan

Abstain

N/A

Nebraska Public Power District

Tony Eddleman

Affirmative

N/A

New York Power Authority

Richard Machado

Affirmative

N/A

NextEra Energy - Florida Power and Light Co.

Karen Demos

Affirmative

N/A

NiSource - Northern Indiana Public Service Co.

Steven Taddeucci

Affirmative

N/A

North Carolina Electric Membership Corporation

Chris Dimisa

Scott Brame

Affirmative

N/A

Ocala Utility Services

Neville Bowen

LaKenya Vannorman

None

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Donald Hargrove

Affirmative

N/A

Old Dominion Electric Coop.

William Pezalla

None

N/A

Omaha Public Power District

David Heins

Affirmative

N/A

OTP - Otter Tail Power Company

Wendi Olson

Affirmative

N/A

Pacific Gas and Electric Company

Sandra Ellis

Affirmative

N/A

PNM Resources - Public Service Company of New
Mexico

Amy Wesselkamper

Affirmative

N/A

PPL - Louisville Gas and Electric Co.

James Frank

None

N/A

PSEG - Public Service Electric and Gas Co.

Christopher Murphy

Affirmative

N/A

Public Utility District No. 1 of Chelan County

Joyce Gundry

Affirmative

N/A

Sacramento Municipal Utility District

Nicole Looney

Tim Kelley

Affirmative

N/A

Salt River Project

Mathew Weber

Israel Perez

Negative

Comments
Submitted

Santee Cooper

Vicky Budreau

Affirmative

N/A

Sempra - San Diego Gas and Electric

Bryan Bennett

Affirmative

N/A

Snohomish County PUD No. 1

Holly Chaney

Affirmative

N/A

Southern Company - Alabama Power Company

Joel Dembowski

Affirmative

N/A

Southern Indiana Gas and Electric Co.

Ryan Snyder

Negative

Comments
Submitted

Tennessee Valley Authority

Ian Grant

Negative

Comments
Submitted

Tri-State G and T Association, Inc.

Ryan Walter

Affirmative

N/A

WEC Energy Group, Inc.

Christine Kane

Affirmative

N/A

Xcel Energy, Inc.

Nicholas Friebel

Affirmative

N/A

Alliant Energy Corporation Services, Inc.

Larry Heckert

Affirmative

N/A

Austin Energy

Tony Hua

Affirmative

N/A

Affirmative

N/A

Jason Procuniar

Stephen Sines

Michael Johnson

Ryan Strom

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

CMS Energy - Consumers Energy Company

Aric Root

Affirmative

N/A

DTE Energy

Patricia Ireland

Affirmative

N/A

Electricities of North Carolina

Marcus Freeman

None

N/A

FirstEnergy - FirstEnergy Corporation

Mark Garza

Negative

Comments
Submitted

Georgia System Operations Corporation

Katrina Lyons

Affirmative

N/A

Illinois Municipal Electric Agency

Mary Ann Todd

Abstain

N/A

North Carolina Electric Membership Corporation

Richard McCall

Affirmative

N/A

Northern California Power Agency

Marty Hostler

None

N/A

Public Utility District No. 1 of Snohomish County

John D. Martinsen

Affirmative

N/A

Public Utility District No. 2 of Grant County,
Washington

Karla Weaver

Abstain

N/A

Sacramento Municipal Utility District

Foung Mua

Affirmative

N/A

Tacoma Public Utilities (Tacoma, WA)

Hien Ho

Affirmative

N/A

Utility Services, Inc.

Carver Powers

Affirmative

N/A

WEC Energy Group, Inc.

Matthew Beilfuss

Affirmative

N/A

AEP

Thomas Foltz

Affirmative

N/A

AES - AES Corporation

Ruchi Shah

Affirmative

N/A

Ameren - Ameren Missouri

Sam Dwyer

Affirmative

N/A

APS - Arizona Public Service Co.

Andrew Smith

Affirmative

N/A

Associated Electric Cooperative, Inc.

Chuck Booth

Affirmative

N/A

Austin Energy

Michael Dillard

Affirmative

N/A

Avista - Avista Corporation

Glen Farmer

None

N/A

Basin Electric Power Cooperative

Amanda Wangler

None

N/A

BC Hydro and Power Authority

Quincy Wang

Abstain

N/A

Berkshire Hathaway - NV Energy

Dwanique Spiller

None

N/A

Black Hills Corporation

Sheila Suurmeier

Affirmative

N/A

Bonneville Power Administration

Juergen Bermejo

Affirmative

N/A

Buckeye Power, Inc.

Kevin Zemanek

Affirmative

N/A

CMS Energy - Consumers Energy Company

David Greyerbiehl

Affirmative

N/A

Colorado Springs Utilities

Jeffrey Icke

Affirmative

N/A

Con Ed - Consolidated Edison Co. of New York

Michelle Pagano

Affirmative

N/A

Constellation

Alison MacKellar

Affirmative

N/A

Dairyland Power Cooperative

Tommy Drea

Affirmative

N/A

Decatur Energy Center LLC

Megan Melham

Affirmative

N/A

Duke Energy

Dale Goodwine

Negative

Comments
Submitted

Edison International - Southern California Edison
Company

Selene Willis

Affirmative

N/A

Natalie Johnson

Abstain

N/A

Scott Brame

Tim Kelley

Ryan Strom

Segment

Organization

Voter

Entergy - Entergy Services, Inc.

Gail Golden

Evergy

Jeremy Harris

FirstEnergy - FirstEnergy Corporation

Designated Proxy

Ballot

NERC Memo

Affirmative

N/A

Affirmative

N/A

Matthew Augustin

Negative

Comments
Submitted

Great River Energy

Jacalynn Bentz

Affirmative

N/A

Greybeard Compliance Services, LLC

Mike Gabriel

None

N/A

Hydro-Quebec (HQ)

Junji Yamaguchi

Chantal Mazza

Affirmative

N/A

Imperial Irrigation District

Tino Zaragoza

Denise Sanchez

Affirmative

N/A

Invenergy LLC

Rhonda Jones

Affirmative

N/A

JEA

John Babik

Affirmative

N/A

Lincoln Electric System

Brittany Millard

Affirmative

N/A

Los Angeles Department of Water and Power

Robert Kerrigan

None

N/A

Lower Colorado River Authority

Teresa Krabe

Affirmative

N/A

LS Power Development, LLC

C. A. Campbell

Abstain

N/A

National Grid USA

Robin Berry

Abstain

N/A

NB Power Corporation - New Brunswick Power
Transmission Corporation

Fon Hiew

Abstain

N/A

Nebraska Public Power District

Ronald Bender

Affirmative

N/A

New York Power Authority

Zahid Qayyum

Affirmative

N/A

NextEra Energy

Richard Vendetti

Negative

No Comment
Submitted

NiSource - Northern Indiana Public Service Co.

Kathryn Tackett

Affirmative

N/A

North Carolina Electric Membership Corporation

Reid Cashion

Affirmative

N/A

Northern California Power Agency

Jeremy Lawson

None

N/A

NRG - NRG Energy, Inc.

Patricia Lynch

Abstain

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Patrick Wells

Affirmative

N/A

Omaha Public Power District

Kayleigh Wilkerson

None

N/A

Ontario Power Generation Inc.

Constantin Chitescu

Affirmative

N/A

OTP - Otter Tail Power Company

Stacy Wahlund

Affirmative

N/A

Pacific Gas and Electric Company

Tyler Brun

Affirmative

N/A

Pattern Operators LP

George E Brown

Affirmative

N/A

Platte River Power Authority

Jon Osell

Affirmative

N/A

Portland General Electric Co.

Ryan Olson

None

N/A

PSEG Nuclear LLC

Tim Kucey

None

N/A

Public Utility District No. 1 of Chelan County

Rebecca Zahler

Affirmative

N/A

Public Utility District No. 1 of Snohomish County

Becky Burden

Affirmative

N/A

Public Utility District No. 2 of Grant County,
Washington

Nikkee Hebdon

None

N/A

Sacramento Municipal Utility District

Ryder Couch

Affirmative

N/A

Hayden Maples

Scott Brame

Michael Johnson

Tim Kelley

Segment

Organization

Voter

Salt River Project

Thomas Johnson

Santee Cooper

Designated Proxy

NERC Memo

Negative

Comments
Submitted

Carey Salisbury

Affirmative

N/A

Seminole Electric Cooperative, Inc.

Melanie Wong

Abstain

N/A

Sempra - San Diego Gas and Electric

Jennifer Wright

Affirmative

N/A

Southern Company - Southern Company
Generation

Leslie Burke

Affirmative

N/A

Southern Indiana Gas and Electric Co.

Larry Rogers

Negative

Comments
Submitted

Tacoma Public Utilities (Tacoma, WA)

Ozan Ferrin

None

N/A

Talen Generation, LLC

Donald Lock

None

N/A

Tennessee Valley Authority

Darren Boehm

Negative

Comments
Submitted

TransAlta Corporation

Ashley Scheelar

None

N/A

Tri-State G and T Association, Inc.

Sergio Banuelos

Affirmative

N/A

U.S. Bureau of Reclamation

Wendy Kalidass

Abstain

N/A

Vistra Energy

Daniel Roethemeyer

Affirmative

N/A

WEC Energy Group, Inc.

Michelle Hribar

Affirmative

N/A

Xcel Energy, Inc.

Gerry Huitt

Affirmative

N/A

AEP

Mathew Miller

Affirmative

N/A

Ameren - Ameren Services

Robert Quinlivan

Affirmative

N/A

APS - Arizona Public Service Co.

Marcus Bortman

Affirmative

N/A

Arkansas Electric Cooperative Corporation

Bruce Walkup

Affirmative

N/A

Austin Energy

Imane Mrini

Affirmative

N/A

Black Hills Corporation

Rachel Schuldt

Affirmative

N/A

Bonneville Power Administration

Tanner Brier

Affirmative

N/A

Cleco Corporation

Robert Hirchak

Affirmative

N/A

Con Ed - Consolidated Edison Co. of New York

Jason Chandler

Affirmative

N/A

Constellation

Kimberly Turco

Affirmative

N/A

CPower

Aaron Breidenbaugh

None

N/A

Dominion - Dominion Resources, Inc.

Sean Bodkin

Affirmative

N/A

Duke Energy

John Sturgeon

Negative

Comments
Submitted

Entergy

Julie Hall

Affirmative

N/A

Evergy

Tiffany Lake

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Stacey Sheehan

None

N/A

Imperial Irrigation District

Diana Torres

Affirmative

N/A

Invenergy LLC

Colin Chilcoat

Affirmative

N/A

Lakeland Electric

Paul Shipps

Affirmative

N/A

Eric Ruskamp

None

N/A

Israel Perez

Ballot

Jennie Wike

David Vickers

Hayden Maples

Denise Sanchez

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Los Angeles Department of Water and Power

Anton Vu

None

N/A

Manitoba Hydro

Brandin Stoesz

None

N/A

Muscatine Power and Water

Nicholas Burns

None

N/A

New York Power Authority

Shelly Dineen

Affirmative

N/A

NextEra Energy - Florida Power and Light Co.

Justin Welty

Affirmative

N/A

NiSource - Northern Indiana Public Service Co.

Dmitriy Bazylyuk

Affirmative

N/A

Northern California Power Agency

Dennis Sismaet

None

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Ashley F Stringer

Affirmative

N/A

Omaha Public Power District

Shonda McCain

Affirmative

N/A

Platte River Power Authority

Sabrina Martz

Affirmative

N/A

Portland General Electric Co.

Stefanie Burke

Abstain

N/A

Powerex Corporation

Raj Hundal

Abstain

N/A

PPL - Louisville Gas and Electric Co.

Linn Oelker

Negative

Comments
Submitted

PSEG - PSEG Energy Resources and Trade LLC

Laura Wu

None

N/A

Public Utility District No. 1 of Chelan County

Robert Witham

Affirmative

N/A

Sacramento Municipal Utility District

Charles Norton

Tim Kelley

Affirmative

N/A

Salt River Project

Timothy Singh

Israel Perez

Negative

Comments
Submitted

Santee Cooper

Marty Watson

Affirmative

N/A

Seminole Electric Cooperative, Inc.

Bret Galbraith

None

N/A

Snohomish County PUD No. 1

John Liang

Affirmative

N/A

Southern Company - Southern Company
Generation

Ron Carlsen

Affirmative

N/A

Southern Indiana Gas and Electric Co.

Kati Barr

Negative

Comments
Submitted

Tacoma Public Utilities (Tacoma, WA)

Terry Gifford

None

N/A

Tennessee Valley Authority

Armando Rodriguez

Negative

Comments
Submitted

WEC Energy Group, Inc.

David Boeshaar

Affirmative

N/A

Western Area Power Administration

Jennifer Neville

Affirmative

N/A

Xcel Energy, Inc.

Steve Szablya

Affirmative

N/A

Midwest Reliability Organization

Mark Flanary

Affirmative

N/A

New York State Reliability Council

Wesley Yeomans

Affirmative

N/A

Northeast Power Coordinating Council

Gerry Dunbar

Abstain

N/A

ReliabilityFirst

Tyler Schwendiman

Affirmative

N/A

SERC Reliability Corporation

Dave Krueger

Affirmative

N/A

Texas Reliability Entity, Inc.

Rachel Coyne

Affirmative

N/A

Western Electricity Coordinating Council

Steven Rueckert

Affirmative

N/A

Jennie Wike

Greg Sorenson

NERC Balloting Tool (/)

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Ballots

Comment Forms

BALLOT RESULTS
Comment: View Comment Results (/CommentResults/Index/337)
Ballot Name: 2020-06 Verifications of Models and Data for Generators IBR-related Definitions | Implementation Plan AB 3 OT
Voting Start Date: 8/2/2024 12:01:00 AM
Voting End Date: 8/12/2024 8:00:00 PM
Ballot Type: OT
Ballot Activity: AB
Ballot Series: 3
Total # Votes: 238
Total Ballot Pool: 280
Quorum: 85
Quorum Established Date: 8/12/2024 3:53:04 PM
Weighted Segment Value: 92.45
Ballot
Pool

Segment
Weight

Affirmative
Votes

Affirmative
Fraction

Negative Votes w/
Comment

Negative Fraction
w/ Comment

Negative Votes w/o
Comment

Abstain

No
Vote

Segment:
1

0.889

0.111

Segment:
2

0.8

Segment:
3

0.915

0.085

Segment:
4

0.917

0.083

Segment:
5

0.922

0.078

Segment:
6

0.882

0.118

Segment:
7

Segment:
8

Segment:
9

Segment:
10

0.5

Totals:

280

6.3

192

5.824

0.476

Segment

BALLOT POOL MEMBERS
Show

All

Segment

entries
Organization

Search:
Voter
Dennis Sauriol

Designated Proxy

Ballot
Affirmative

NERC Memo
N/A

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Allete - Minnesota Power, Inc.

Hillary Creurer

Affirmative

N/A

Ameren - Ameren Services

Tamara Evey

Affirmative

N/A

American Transmission Company, LLC

Amy Wilke

Negative

Comments
Submitted

APS - Arizona Public Service Co.

Daniela Atanasovski

Affirmative

N/A

Arizona Electric Power Cooperative, Inc.

Jennifer Bray

Affirmative

N/A

Arkansas Electric Cooperative Corporation

Emily Corley

None

N/A

Associated Electric Cooperative, Inc.

Mark Riley

Affirmative

N/A

Austin Energy

Thomas Standifur

None

N/A

Avista - Avista Corporation

Mike Magruder

Affirmative

N/A

Balancing Authority of Northern California

Kevin Smith

Affirmative

N/A

BC Hydro and Power Authority

Adrian Andreoiu

Abstain

N/A

Berkshire Hathaway Energy - MidAmerican Energy
Co.

Terry Harbour

Affirmative

N/A

Black Hills Corporation

Micah Runner

Affirmative

N/A

CenterPoint Energy Houston Electric, LLC

Daniela Hammons

Affirmative

N/A

City Utilities of Springfield, Missouri

Michael Bowman

Affirmative

N/A

Con Ed - Consolidated Edison Co. of New York

Dermot Smyth

Affirmative

N/A

Dairyland Power Cooperative

Karrie Schuldt

Affirmative

N/A

Dominion - Dominion Virginia Power

Steven Belle

Affirmative

N/A

Duke Energy

Katherine Street

Negative

Comments
Submitted

Edison International - Southern California Edison
Company

Robert Blackney

Affirmative

N/A

Entergy

Brian Lindsey

Affirmative

N/A

Evergy

Kevin Frick

Affirmative

N/A

Eversource Energy

Joshua London

Affirmative

N/A

Exelon

Daniel Gacek

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Theresa Ciancio

Negative

Comments
Submitted

Georgia Transmission Corporation

Greg Davis

Affirmative

N/A

Glencoe Light and Power Commission

Terry Volkmann

Affirmative

N/A

Hydro One Networks, Inc.

Emma Halilovic

Ijad Dewan

Abstain

N/A

Hydro-Quebec (HQ)

Nicolas Turcotte

Chantal Mazza

Affirmative

N/A

IDACORP - Idaho Power Company

Sean Steffensen

Abstain

N/A

Imperial Irrigation District

Jesus Sammy Alcaraz

Denise Sanchez

Affirmative

N/A

International Transmission Company Holdings
Corporation

Michael Moltane

Gail Elliott

Affirmative

N/A

JEA

Joseph McClung

Affirmative

N/A

Lakeland Electric

Larry Watt

None

N/A

LaTroy Brumfield

Tim Kelley

Ellese Murphy

Hayden Maples

Stephen Stafford

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Lincoln Electric System

Josh Johnson

Affirmative

N/A

Long Island Power Authority

Isidoro Behar

Abstain

N/A

Los Angeles Department of Water and Power

faranak sarbaz

None

N/A

LS Power Transmission, LLC

Jennifer Richardson

Abstain

N/A

Manitoba Hydro

Nazra Gladu

None

N/A

Minnkota Power Cooperative Inc.

Theresa Allard

Affirmative

N/A

Muscatine Power and Water

Andrew Kurriger

Affirmative

N/A

National Grid USA

Michael Jones

Abstain

N/A

NB Power Corporation

Jeffrey Streifling

Abstain

N/A

Nebraska Public Power District

Jamison Cawley

Affirmative

N/A

NextEra Energy - Florida Power and Light Co.

Silvia Mitchell

Affirmative

N/A

NiSource - Northern Indiana Public Service Co.

Alison Nickells

Affirmative

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Terri Pyle

Affirmative

N/A

Omaha Public Power District

Doug Peterchuck

Affirmative

N/A

Oncor Electric Delivery

Byron Booker

Abstain

N/A

OTP - Otter Tail Power Company

Charles Wicklund

None

N/A

Pacific Gas and Electric Company

Marco Rios

Affirmative

N/A

Pedernales Electric Cooperative, Inc.

Bradley Collard

None

N/A

Platte River Power Authority

Marissa Archie

Affirmative

N/A

PNM Resources - Public Service Company of New
Mexico

Lynn Goldstein

Affirmative

N/A

Portland General Electric Co.

Brooke Jockin

Abstain

N/A

PPL Electric Utilities Corporation

Michelle McCartney
Longo

Negative

Comments
Submitted

PSEG - Public Service Electric and Gas Co.

Karen Arnold

None

N/A

Public Utility District No. 1 of Chelan County

Diane E Landry

Affirmative

N/A

Public Utility District No. 1 of Snohomish County

Alyssia Rhoads

Affirmative

N/A

Sacramento Municipal Utility District

Wei Shao

Tim Kelley

Affirmative

N/A

Salt River Project

Laura Somak

Israel Perez

Negative

Comments
Submitted

Santee Cooper

Chris Wagner

Affirmative

N/A

SaskPower

Wayne Guttormson

Abstain

N/A

Sempra - San Diego Gas and Electric

Mohamed Derbas

Affirmative

N/A

Southern Company - Southern Company Services,
Inc.

Matt Carden

Affirmative

N/A

Sunflower Electric Power Corporation

Paul Mehlhaff

Affirmative

N/A

Tacoma Public Utilities (Tacoma, WA)

John Merrell

Affirmative

N/A

Tallahassee Electric (City of Tallahassee, FL)

Scott Langston

Abstain

N/A

Tennessee Valley Authority

David Plumb

Negative

Comments
Submitted

Jay Sethi

Tammy Porter

Michael Johnson

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Tri-State G and T Association, Inc.

Donna Wood

Affirmative

N/A

U.S. Bureau of Reclamation

Richard Jackson

Abstain

N/A

Western Area Power Administration

Ben Hammer

Affirmative

N/A

Xcel Energy, Inc.

Eric Barry

Affirmative

N/A

California ISO

Darcy O'Connell

Affirmative

N/A

Electric Reliability Council of Texas, Inc.

Kennedy Meier

Affirmative

N/A

Independent Electricity System Operator

Helen Lainis

Affirmative

N/A

ISO New England, Inc.

John Pearson

Affirmative

N/A

Midcontinent ISO, Inc.

Bobbi Welch

Affirmative

N/A

New York Independent System Operator

Gregory Campoli

Affirmative

N/A

PJM Interconnection, L.L.C.

Thomas Foster

Affirmative

N/A

Southwest Power Pool, Inc. (RTO)

Joshua Phillips

Affirmative

N/A

AEP

Leshel Hutchings

Affirmative

N/A

Ameren - Ameren Services

David Jendras Sr

Affirmative

N/A

APS - Arizona Public Service Co.

Jessica Lopez

Affirmative

N/A

Arkansas Electric Cooperative Corporation

Ayslynn Mcavoy

Affirmative

N/A

Avista - Avista Corporation

Robert Follini

Negative

Comments
Submitted

BC Hydro and Power Authority

Ming Jiang

Abstain

N/A

Berkshire Hathaway Energy - MidAmerican Energy
Co.

Joseph Amato

Affirmative

N/A

Black Hills Corporation

Josh Combs

Carly Miller

Affirmative

N/A

Buckeye Power, Inc.

Tom Schmidt

Ryan Strom

Affirmative

N/A

CMS Energy - Consumers Energy Company

Karl Blaszkowski

Affirmative

N/A

Colorado Springs Utilities

Hillary Dobson

None

N/A

Con Ed - Consolidated Edison Co. of New York

Peter Yost

Affirmative

N/A

Dominion - Dominion Virginia Power

Victoria Crider

Affirmative

N/A

DTE Energy - Detroit Edison Company

Marvin Johnson

Affirmative

N/A

Duke Energy - Florida Power Corporation

Marcelo Pesantez

Negative

Comments
Submitted

Edison International - Southern California Edison
Company

Romel Aquino

Affirmative

N/A

Entergy

James Keele

Affirmative

N/A

Evergy

Marcus Moor

Affirmative

N/A

Eversource Energy

Vicki O'Leary

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Aaron Ghodooshim

None

N/A

Georgia System Operations Corporation

Scott McGough

Affirmative

N/A

Great River Energy

Michael Brytowski

Affirmative

N/A

Imperial Irrigation District

George Kirschner

Affirmative

N/A

Affirmative

N/A

Marilyn Williams

Pirouz Honarmand

Elizabeth Davis

Nick Leathers

Denise Sanchez

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Lakeland Electric

Steven Marshall

None

N/A

Lincoln Electric System

Sam Christensen

Affirmative

N/A

Los Angeles Department of Water and Power

Fausto Serratos

None

N/A

Manitoba Hydro

Mike Smith

None

N/A

MGE Energy - Madison Gas and Electric Co.

Benjamin Widder

Affirmative

N/A

Muscatine Power and Water

Seth Shoemaker

Affirmative

N/A

National Grid USA

Brian Shanahan

Abstain

N/A

Nebraska Public Power District

Tony Eddleman

Affirmative

N/A

New York Power Authority

Richard Machado

Affirmative

N/A

NextEra Energy - Florida Power and Light Co.

Karen Demos

Affirmative

N/A

NiSource - Northern Indiana Public Service Co.

Steven Taddeucci

Affirmative

N/A

North Carolina Electric Membership Corporation

Chris Dimisa

Scott Brame

Affirmative

N/A

Ocala Utility Services

Neville Bowen

LaKenya Vannorman

None

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Donald Hargrove

Affirmative

N/A

Old Dominion Electric Coop.

William Pezalla

None

N/A

Omaha Public Power District

David Heins

Affirmative

N/A

OTP - Otter Tail Power Company

Wendi Olson

Affirmative

N/A

Pacific Gas and Electric Company

Sandra Ellis

Affirmative

N/A

PNM Resources - Public Service Company of New
Mexico

Amy Wesselkamper

Affirmative

N/A

PPL - Louisville Gas and Electric Co.

James Frank

None

N/A

PSEG - Public Service Electric and Gas Co.

Christopher Murphy

Affirmative

N/A

Public Utility District No. 1 of Chelan County

Joyce Gundry

Affirmative

N/A

Sacramento Municipal Utility District

Nicole Looney

Tim Kelley

Affirmative

N/A

Salt River Project

Mathew Weber

Israel Perez

Negative

Comments
Submitted

Santee Cooper

Vicky Budreau

Affirmative

N/A

Sempra - San Diego Gas and Electric

Bryan Bennett

Affirmative

N/A

Snohomish County PUD No. 1

Holly Chaney

Affirmative

N/A

Southern Company - Alabama Power Company

Joel Dembowski

Affirmative

N/A

Southern Indiana Gas and Electric Co.

Ryan Snyder

Affirmative

N/A

Tennessee Valley Authority

Ian Grant

Negative

Comments
Submitted

Tri-State G and T Association, Inc.

Ryan Walter

Affirmative

N/A

WEC Energy Group, Inc.

Christine Kane

Affirmative

N/A

Xcel Energy, Inc.

Nicholas Friebel

Affirmative

N/A

Alliant Energy Corporation Services, Inc.

Larry Heckert

Affirmative

N/A

Austin Energy

Tony Hua

Affirmative

N/A

Affirmative

N/A

Jason Procuniar

Stephen Sines

Michael Johnson

Ryan Strom

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

CMS Energy - Consumers Energy Company

Aric Root

Affirmative

N/A

DTE Energy

Patricia Ireland

Affirmative

N/A

Electricities of North Carolina

Marcus Freeman

None

N/A

FirstEnergy - FirstEnergy Corporation

Mark Garza

Negative

Comments
Submitted

Georgia System Operations Corporation

Katrina Lyons

Affirmative

N/A

Illinois Municipal Electric Agency

Mary Ann Todd

Abstain

N/A

North Carolina Electric Membership Corporation

Richard McCall

Affirmative

N/A

Northern California Power Agency

Marty Hostler

None

N/A

Public Utility District No. 1 of Snohomish County

John D. Martinsen

Affirmative

N/A

Public Utility District No. 2 of Grant County,
Washington

Karla Weaver

Abstain

N/A

Sacramento Municipal Utility District

Foung Mua

Affirmative

N/A

Tacoma Public Utilities (Tacoma, WA)

Hien Ho

Affirmative

N/A

Utility Services, Inc.

Carver Powers

Affirmative

N/A

WEC Energy Group, Inc.

Matthew Beilfuss

None

N/A

AEP

Thomas Foltz

Affirmative

N/A

AES - AES Corporation

Ruchi Shah

Affirmative

N/A

Ameren - Ameren Missouri

Sam Dwyer

Affirmative

N/A

APS - Arizona Public Service Co.

Andrew Smith

Affirmative

N/A

Associated Electric Cooperative, Inc.

Chuck Booth

Affirmative

N/A

Austin Energy

Michael Dillard

Affirmative

N/A

Avista - Avista Corporation

Glen Farmer

None

N/A

Basin Electric Power Cooperative

Amanda Wangler

None

N/A

BC Hydro and Power Authority

Quincy Wang

Abstain

N/A

Berkshire Hathaway - NV Energy

Dwanique Spiller

None

N/A

Black Hills Corporation

Sheila Suurmeier

Affirmative

N/A

Bonneville Power Administration

Juergen Bermejo

Affirmative

N/A

Buckeye Power, Inc.

Kevin Zemanek

Affirmative

N/A

CMS Energy - Consumers Energy Company

David Greyerbiehl

Affirmative

N/A

Colorado Springs Utilities

Jeffrey Icke

Affirmative

N/A

Con Ed - Consolidated Edison Co. of New York

Michelle Pagano

Affirmative

N/A

Constellation

Alison MacKellar

Affirmative

N/A

Dairyland Power Cooperative

Tommy Drea

Affirmative

N/A

Decatur Energy Center LLC

Megan Melham

Affirmative

N/A

Duke Energy

Dale Goodwine

Negative

Comments
Submitted

Edison International - Southern California Edison
Company

Selene Willis

Affirmative

N/A

Natalie Johnson

Abstain

N/A

Scott Brame

Tim Kelley

Ryan Strom

Segment

Organization

Voter

Entergy - Entergy Services, Inc.

Gail Golden

Evergy

Jeremy Harris

FirstEnergy - FirstEnergy Corporation

Designated Proxy

Ballot

NERC Memo

Affirmative

N/A

Affirmative

N/A

Matthew Augustin

Negative

Comments
Submitted

Great River Energy

Jacalynn Bentz

Affirmative

N/A

Greybeard Compliance Services, LLC

Mike Gabriel

None

N/A

Hydro-Quebec (HQ)

Junji Yamaguchi

Chantal Mazza

Affirmative

N/A

Imperial Irrigation District

Tino Zaragoza

Denise Sanchez

Affirmative

N/A

Invenergy LLC

Rhonda Jones

Affirmative

N/A

JEA

John Babik

Affirmative

N/A

Lincoln Electric System

Brittany Millard

Affirmative

N/A

Los Angeles Department of Water and Power

Robert Kerrigan

None

N/A

Lower Colorado River Authority

Teresa Krabe

Affirmative

N/A

LS Power Development, LLC

C. A. Campbell

Abstain

N/A

National Grid USA

Robin Berry

Abstain

N/A

NB Power Corporation - New Brunswick Power
Transmission Corporation

Fon Hiew

Abstain

N/A

Nebraska Public Power District

Ronald Bender

Affirmative

N/A

New York Power Authority

Zahid Qayyum

Affirmative

N/A

NextEra Energy

Richard Vendetti

Affirmative

N/A

NiSource - Northern Indiana Public Service Co.

Kathryn Tackett

Affirmative

N/A

North Carolina Electric Membership Corporation

Reid Cashion

Affirmative

N/A

Northern California Power Agency

Jeremy Lawson

None

N/A

NRG - NRG Energy, Inc.

Patricia Lynch

Abstain

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Patrick Wells

Affirmative

N/A

Omaha Public Power District

Kayleigh Wilkerson

None

N/A

Ontario Power Generation Inc.

Constantin Chitescu

Affirmative

N/A

OTP - Otter Tail Power Company

Stacy Wahlund

Affirmative

N/A

Pacific Gas and Electric Company

Tyler Brun

Affirmative

N/A

Pattern Operators LP

George E Brown

Affirmative

N/A

Platte River Power Authority

Jon Osell

Affirmative

N/A

Portland General Electric Co.

Ryan Olson

None

N/A

PSEG Nuclear LLC

Tim Kucey

None

N/A

Public Utility District No. 1 of Chelan County

Rebecca Zahler

Affirmative

N/A

Public Utility District No. 1 of Snohomish County

Becky Burden

Affirmative

N/A

Public Utility District No. 2 of Grant County,
Washington

Nikkee Hebdon

None

N/A

Sacramento Municipal Utility District

Ryder Couch

Tim Kelley

Affirmative

N/A

Thomas Johnson

Israel Perez

Negative

Comments
Submitted

Hayden Maples

Scott Brame

Michael Johnson

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

Santee Cooper

Carey Salisbury

Affirmative

N/A

Seminole Electric Cooperative, Inc.

Melanie Wong

Abstain

N/A

Sempra - San Diego Gas and Electric

Jennifer Wright

Affirmative

N/A

Southern Company - Southern Company
Generation

Leslie Burke

Affirmative

N/A

Southern Indiana Gas and Electric Co.

Larry Rogers

Affirmative

N/A

Tacoma Public Utilities (Tacoma, WA)

Ozan Ferrin

None

N/A

Talen Generation, LLC

Donald Lock

None

N/A

Tennessee Valley Authority

Darren Boehm

Negative

Comments
Submitted

TransAlta Corporation

Ashley Scheelar

None

N/A

Tri-State G and T Association, Inc.

Sergio Banuelos

Affirmative

N/A

U.S. Bureau of Reclamation

Wendy Kalidass

Abstain

N/A

Vistra Energy

Daniel Roethemeyer

Affirmative

N/A

WEC Energy Group, Inc.

Michelle Hribar

Affirmative

N/A

Xcel Energy, Inc.

Gerry Huitt

Affirmative

N/A

AEP

Mathew Miller

Affirmative

N/A

Ameren - Ameren Services

Robert Quinlivan

Affirmative

N/A

APS - Arizona Public Service Co.

Marcus Bortman

Affirmative

N/A

Arkansas Electric Cooperative Corporation

Bruce Walkup

Affirmative

N/A

Austin Energy

Imane Mrini

Affirmative

N/A

Black Hills Corporation

Rachel Schuldt

Affirmative

N/A

Bonneville Power Administration

Tanner Brier

Affirmative

N/A

Con Ed - Consolidated Edison Co. of New York

Jason Chandler

Affirmative

N/A

Constellation

Kimberly Turco

Affirmative

N/A

CPower

Aaron Breidenbaugh

None

N/A

Dominion - Dominion Resources, Inc.

Sean Bodkin

Affirmative

N/A

Duke Energy

John Sturgeon

Negative

Comments
Submitted

Entergy

Julie Hall

Affirmative

N/A

Evergy

Tiffany Lake

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Stacey Sheehan

None

N/A

Imperial Irrigation District

Diana Torres

Affirmative

N/A

Invenergy LLC

Colin Chilcoat

Affirmative

N/A

Lakeland Electric

Paul Shipps

Affirmative

N/A

Lincoln Electric System

Eric Ruskamp

None

N/A

Los Angeles Department of Water and Power

Anton Vu

None

N/A

Manitoba Hydro

Brandin Stoesz

None

N/A

Nicholas Burns

None

N/A

Jennie Wike

David Vickers

Hayden Maples

Denise Sanchez

Segment

Organization

Voter

Designated Proxy

Ballot

NERC Memo

New York Power Authority

Shelly Dineen

Affirmative

N/A

NextEra Energy - Florida Power and Light Co.

Justin Welty

Affirmative

N/A

NiSource - Northern Indiana Public Service Co.

Dmitriy Bazylyuk

Affirmative

N/A

Northern California Power Agency

Dennis Sismaet

None

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Ashley F Stringer

Affirmative

N/A

Omaha Public Power District

Shonda McCain

Affirmative

N/A

Platte River Power Authority

Sabrina Martz

Affirmative

N/A

Portland General Electric Co.

Stefanie Burke

Abstain

N/A

Powerex Corporation

Raj Hundal

Abstain

N/A

PPL - Louisville Gas and Electric Co.

Linn Oelker

Negative

Comments
Submitted

PSEG - PSEG Energy Resources and Trade LLC

Laura Wu

None

N/A

Public Utility District No. 1 of Chelan County

Robert Witham

Affirmative

N/A

Sacramento Municipal Utility District

Charles Norton

Tim Kelley

Affirmative

N/A

Salt River Project

Timothy Singh

Israel Perez

Negative

Comments
Submitted

Santee Cooper

Marty Watson

Affirmative

N/A

Seminole Electric Cooperative, Inc.

Bret Galbraith

None

N/A

Snohomish County PUD No. 1

John Liang

Affirmative

N/A

Southern Company - Southern Company
Generation

Ron Carlsen

Affirmative

N/A

Southern Indiana Gas and Electric Co.

Kati Barr

Affirmative

N/A

Tacoma Public Utilities (Tacoma, WA)

Terry Gifford

None

N/A

Tennessee Valley Authority

Armando Rodriguez

Negative

Comments
Submitted

WEC Energy Group, Inc.

David Boeshaar

Affirmative

N/A

Western Area Power Administration

Jennifer Neville

Affirmative

N/A

Xcel Energy, Inc.

Steve Szablya

Affirmative

N/A

Midwest Reliability Organization

Mark Flanary

Affirmative

N/A

Northeast Power Coordinating Council

Gerry Dunbar

Abstain

N/A

ReliabilityFirst

Tyler Schwendiman

Affirmative

N/A

SERC Reliability Corporation

Dave Krueger

Affirmative

N/A

Texas Reliability Entity, Inc.

Rachel Coyne

Affirmative

N/A

Western Electricity Coordinating Council

Steven Rueckert

Affirmative

N/A

Jennie Wike

Greg Sorenson

Previous
Showing 1 to 280 of 280 entries

Project 2020-06 Verifications of Models and Data for Generators – IBR Definition

Description of Current Draft
Completed Actions

Date

Standards Committee approved Standards Authorization Request (SAR)

September 24, 2020

SAR posted for comment

December 16, 2020 – January 14, 2021

45-day formal comment period with initial ballot

November 16, 2023 – January 9, 2024

45-day formal comment period with additional ballot

February 22 – April 8, 2024

Standards Committee approved Standards Authorization Request (SAR)

May 15, 2024

30-day formal comment period with additional ballot

June 21 – July 22, 2024

Anticipated Actions
NERC Board adoption

Date
October 8-9, 2024

Project 2020-06 | Draft 3 of IBR Definition
July 2024

Page 1 of 3

Project 2020-06 Verifications of Models and Data for Generators – IBR Definition

New or Modified Term(s) Used in NERC Reliability Standards

Project 2020-06 | Draft 3 of IBR Definition
July 2024

Page 2 of 3

2020-06 Verifications of Models and Data for Generators – IBR Definition

Version History
Version
1

Date
TBD

Action

Change Tracking

New IBR Definition

Project 2020-06 | Draft 3 of IBR Definition
July 2024

Page 3 of 3

Implementation Plan

Project 2020-06 Verifications of Models and Data for Generators
Inverter-Based Resource Definition
Applicable Standard(s)
•

None

Requested Retirement(s)
•

None

Prerequisite Standard(s)

These standard(s) or definition must be approved before the Applicable Standard becomes effective:
•

None

Applicable Entities
•

None

New/Modified/Retired Terms in the NERC Glossary of Terms
•

Inverter-Based Resource (IBR)

Background

As multiple standards development projects are actively addressing risks related to inverter-based
generation, NERC evaluated the need for a single standards project to move forward with definitions that
would be leveraged by all other projects. Project 2020-06 was identified as the drafting team (DT) that would
coalesce development efforts for the definition and coordinate proposed definition with the other NERC
developers. The DT proposes the definition of IBR to be used in Reliability Standard MOD-026-2, as well as
other IBR related standards development projects.
General Considerations
Multiple standards in development will use the definition, and the proposed implementation timeframe is
intended to reflect that any one of those standards may be the first to use the definition. Additionally, this
implementation plan only affects the date that this new definition will become an effective term in the NERC
Glossary of Terms. A separate implementation plan will be developed for MOD-026-2, including
requirements that use the proposed definition.

RELIABILITY | RESILIENCE | SECURITY

Effective Date

Implementation Plan for IBR Definition
Project 2020-06 Verifications of Models and Data for Generators | July 2024

Project 2020-06 Verifications of Models and Data for Generators – IBR Definition

Description of Current Draft
Completed Actions

Date

Standards Committee approved Standards Authorization Request (SAR)

September 24, 2020

SAR posted for comment

December 16, 2020 – January 14, 2021

45-day formal comment period with initial ballot

November 16, 2023 – January 9, 2024

45-day formal comment period with additional ballot

February 22 – April 8, 2024

Standards Committee approved Standards Authorization Request (SAR)

May 15, 2024

30-day formal comment period with additional ballot

July 12 – August 12, 2024

Anticipated Actions

Date

10-day final ballot

September 3 – September 12, 2024

NERC Board adoption

October 8-9, 2024

Project 2020-06 | Final Draft of IBR Definition
September 2024

Page 1 of 3

Project 2020-06 Verifications of Models and Data for Generators – IBR Definition

New or Modified Term(s) Used in NERC Reliability Standards

Project 2020-06 | Final Draft of IBR Definition
September 2024

Page 2 of 3

2020-06 Verifications of Models and Data for Generators – IBR Definition

Version History
Version
1

Date
TBD

Action

Change Tracking

New IBR Definition

Project 2020-06 | Final Draft of IBR Definition
August 2024

Page 3 of 3

Implementation Plan

Project 2020-06 Verifications of Models and Data for Generators
Inverter-Based Resource Definition
Applicable Standard(s)
•

None

Requested Retirement(s)
•

None

Prerequisite Standard(s)

These standard(s) or definition must be approved before the Applicable Standard becomes effective:
•

None

Applicable Entities
•

None

New/Modified/Retired Terms in the NERC Glossary of Terms
•

Inverter-Based Resource (IBR)

Background

RELIABILITY | RESILIENCE | SECURITY

Effective Date

Implementation Plan for IBR Definition
Project 2020-06 Verifications of Models and Data for Generators | September 2024

Implementation Plan

Project 2020-06 Verifications of Models and Data for Generators
Inverter-Based Resource Definition
Applicable Standard(s)
•

None

Requested Retirement(s)
•

None

Prerequisite Standard(s)

These standard(s) or definition must be approved before the Applicable Standard becomes effective:
•

None

Applicable Entities
•

None

New/Modified/Retired Terms in the NERC Glossary of Terms
•

Inverter-Based Resource (IBR)

Background

As multiple standards development projects are actively addressing risks related to inverter-based
generation, NERC evaluated the need for a single standards project to move forward with definitions that
would be leveraged by all other projects. Project 2020-06 was identified as the drafting team (DT) that would
coalesce development efforts for these definitionsthe definition and coordinate proposed
definitionsdefinition with the other NERC developers. The DT proposes the two definitionsdefinition of IBR
and IBR Unit to be used in Reliability Standard MOD026-2MOD-026-2, as well as other IBR- related
standards development projects.
General Considerations
Multiple standards in development will use the definition(s), and the proposed implementation time frame
is intended to reflect that any one of those standards may be the first to use one or more of the
definitionsdefinition. Additionally, this implementation plan only affects the date that thesethis new
definitionsdefinition will become an effective termsterm in the NERC Glossary of Terms. A separate
implementation plan will be developed for MOD-026-2, including requirements that use thesethe proposed
definitionsdefinition.

RELIABILITY | RESILIENCE | SECURITY

Effective Date

The effective date(s) for the proposed definitionsdefinition for Glossary of Terms are provided below.
Where approval by an applicable governmental authority is required, the proposed definitionsdefinition shall
become effective on the first day of the first calendar quarter after the applicable governmental authority’s
order approving the definitionsdefinition, or as otherwise provided for by the applicable governmental
authority.
Where approval by an applicable governmental authority is not required, the proposed definitionsdefinition
shall become effective on the first day of the first calendar quarter after the date the definitionsdefinition
are adopted by the NERC Board of Trustees, or as otherwise provided for in that jurisdiction.

Implementation Plan for IBR Definition
Project 2020-06 Verifications of Models and Data for Generators | September 2024

Technical Rationale

Project 2020-06 Verification of Models and Data for Generators
IBR Definition | August 2024
Inverter-based Resource Definition

Not an IBR
•
•
•
•
•
•
•

Stand-alone FACTS device (e.g., STATCOM or SVC)
Flywheels
Synchronous generator
Synchronous condenser
VSC HVDC
Line-Commutated Converters (LCC) HVDC
This is not an all-inclusive list.

RELIABILITY | RESILIENCE | SECURITY

Project 2020-02 Generator Ride-through (new PRC-029, modified PRC-024)

Technical Rationale for IBR Definition
2020-06 Verification of Models and Data for Generators | September 2024

•

Project 2021-01 Modifications to PRC-019 and MOD-025

•

Project 2021-04 Modifications to PRC-002 (new PRC-028)

•

Project 2022-04 EMT Modeling

•

Project 2023-01 EOP-004 IBR Event Reporting

•

Project 2023-02 Analysis and Mitigation of BES Inverter-Based Resource Performance Issues (new
PRC-030)

Distributed Energy Resources (DER) related projects that may or may not need to use IBR (if they end up
with their own definition)
•

Project 2022-02 Modifications to TPL-001 and MOD-032 (DER)

•

Project 2023-05 Modifications to FAC-001 and FAC-002 (DER)

•

Project 2023-08 MOD-031 Demand and Energy (DER)

Technical Rationale for IBR Definition
2020-06 Verification of Models and Data for Generators | September 2024

Technical Rationale

Project 2020-06 Verification of Models and Data for Generators
IBR Definition | August 2024
Inverter-based Resource Definition

The drafting team (DT) utilized the IEEE 2800-2022 definitions as an initial basis for the inverter-based
resource terms for the NERC Glossary of Terms and adjusted, as necessary. The DT acknowledges the
efforts of the P2800 Wind and Solar Plant Interconnection Performance Working Group and IEEE members
in developing those definitions. The DT also used recent FERC and NERC documents, which included
inverter-based resource related terms and descriptions, as the basis for the IBR definitions.
The IBR definition is intended to describe technologies that shall be considered IBR. An IBR is defined by
technology, thus voltage connection level (kV), facility capability level (MW/MVA), or other factors do not
impact the inclusion as an IBR. An IBR can be connected to any part the transmission system, subtransmission system, or distribution system. For Reliability Standards that use the IBR term, the
Applicability Section for that Reliability Standard(s) will specify which IBRs are applicable. Each of these
Reliability Standards, including the Applicability Section(s) will be balloted in accordance with the NERC
Rules of Procedure, and the Applicability Section. For example, an Applicability Section may specify that IBR
Facilities (BES), IBRs that are owned by a Generator Owner (Category 2), or IBRs that are operated by a
Generator Operator (Category 2), are considered applicable.
IBRs have commonly been referred to as “generating resources.” An IBR is not a high-voltage direct current
(HVDC) system (except for a VSC HVDC with a dedicated connection to an IBR, as this is part of the IBR
facility), stand-alone flexible ac transmission systems (FACTS) (e.g., static synchronous compensators
(STATCOM) and static VAR compensators (SVC)), or any resources that are not inverter-based, e.g., gas and
steam power plants with synchronous generators. A list of IBRs is provided in Table 1 below.
IBRs may include any hybrid combination of IBR types (e.g., BESS and solar PV). IBRs also include co-located
portions of a facility that are IBR technologies (e.g., a BESS, which is co-located at synchronous generation
facility), see table below.
Examples
IBR
•
•
•
•
•
•
•
•
•

Not an IBR
•
•
•
•
•
•
•

Stand-alone FACTS device (e.g., STATCOM or SVC)
Flywheels
Synchronous generator
Synchronous condenser
VSC HVDC
Line-Commutated Converters (LCC) HVDC
This is not an all-inclusive list.

RELIABILITY | RESILIENCE | SECURITY

Project 2020-02 Generator Ride-through (new PRC-029, modified PRC-024)

Technical Rationale for IBR Definition
2020-06 Verification of Models and Data for Generators | September 2024

•

Project 2021-01 Modifications to PRC-019 and MOD-025

•

Project 2021-04 Modifications to PRC-002 (new PRC-028)

•

Project 2022-04 EMT Modeling

•

Project 2023-01 EOP-004 IBR Event Reporting

•

Project 2023-02 Analysis and Mitigation of BES Inverter-Based Resource Performance Issues (new
PRC-030)

Distributed Energy Resources (DER) related projects that may or may not need to use IBR (if they end up
with their own definition)
•

Project 2022-02 Modifications to TPL-001 and MOD-032 (DER)

•

Project 2023-05 Modifications to FAC-001 and FAC-002 (DER)

•

Project 2023-08 MOD-031 Demand and Energy (DER)

Technical Rationale for IBR Definition
2020-06 Verification of Models and Data for Generators | September 2024

Standards Announcement

Project 2020-06 Verifications of Models and Data for Generators
Inverter-Based Resource (IBR) Glossary Term
Final Ballot Open through September 12, 2024
Now Available

A final ballot for the Inverter-Based Resource (IBR) Glossary Term is open through 8 p.m. Eastern,
Thursday, September 12, 2024.
Balloting

In the final ballot, votes are counted by exception. Votes from the previous ballot are automatically
carried over in the final ballot. Only members of the applicable ballot pools can cast a vote. Ballot pool
members who previously voted have the option to change their vote in the final ballot. Ballot pool
members who did not cast a vote during the previous ballot can vote in the final ballot.
Members of the ballot pool(s) associated with this project can log into the Standards Balloting and
Commenting System (SBS) and submit votes here.
•

Contact NERC IT support directly at https://support.nerc.net/ (Monday – Friday, 8 a.m. - 5
p.m. Eastern) for problems regarding accessing the SBS due to a forgotten password,
incorrect credential error messages, or system lock-out.

•

Passwords expire every 6 months and must be reset.

•

The SBS is not supported for use on mobile devices.

•

Please be mindful of ballot and comment period closing dates. We ask to allow at least 48 hours
for NERC support staff to assist with inquiries. Therefore, it is recommended that users try
logging into their SBS accounts prior to the last day of a comment/ballot period.

Next Steps

The voting results will be posted and announced after the ballots close. If approved, the standard will be
submitted to the Board of Trustees for adoption and then filed with the appropriate regulatory
authorities.
For information on the Standards Development Process, refer to the Standard Processes Manual.
For more information or assistance, contact Standards Developer, Josh Blume (via email) or at 470-7550346.

RELIABILITY | RESILIENCE | SECURITY

North American Electric Reliability Corporation
3353 Peachtree Rd, NE
Suite 600, North Tower
Atlanta, GA 30326
404-446-2560 | www.nerc.com

Standards Announcement | Project 2020-06 Verifications of Models and Data for Generators
Inverter-Based Resource (IBR) Glossary Term
Final Ballot | September 2024

NERC Balloting Tool (/)

Dashboard (/)

Users

Ballots

Comment Forms

BALLOT RESULTS
Ballot Name: 2020-06 Verifications of Models and Data for Generators Inverter-Based Resource (IBR) FN 4 DEF
Voting Start Date: 9/3/2024 11:37:06 AM
Voting End Date: 9/12/2024 8:00:00 PM
Ballot Type: DEF
Ballot Activity: FN
Ballot Series: 4
Total # Votes: 254
Total Ballot Pool: 282
Quorum: 90.07
Quorum Established Date: 9/4/2024 10:02:37 AM
Weighted Segment Value: 92.82
Ballot
Pool

Segment
Weight

Affirmative
Votes

Affirmative
Fraction

Negative Votes w/
Comment

Negative Fraction
w/ Comment

Negative Votes w/o
Comment

Abstain

No
Vote

Segment:
1

0.929

0.071

Segment:
2

0.8

Segment:
3

0.898

0.102

Segment:
4

0.929

0.071

Segment:
5

0.925

0.075

Segment:
6

0.861

0.139

Segment:
7

Segment:
8

Segment:
9

Segment:
10

0.6

Totals:

282

6.4

203

5.941

0.459

Segment

BALLOT POOL MEMBERS
Show

All

Segment

entries

Organization

Search:

Voter
Dennis Sauriol

Designated Proxy

Ballot
Affirmative

NERC
Memo
N/A

Segment

Organization

Voter

Designated Proxy

Ballot

NERC
Memo

Allete - Minnesota Power, Inc.

Hillary Creurer

Affirmative

N/A

Ameren - Ameren Services

Tamara Evey

Affirmative

N/A

American Transmission Company, LLC

Amy Wilke

Affirmative

N/A

APS - Arizona Public Service Co.

Daniela Atanasovski

Affirmative

N/A

Arizona Electric Power Cooperative, Inc.

Jennifer Bray

Affirmative

N/A

Arkansas Electric Cooperative Corporation

Emily Corley

None

N/A

Associated Electric Cooperative, Inc.

Mark Riley

Affirmative

N/A

Austin Energy

Thomas Standifur

None

N/A

Avista - Avista Corporation

Mike Magruder

Affirmative

N/A

Balancing Authority of Northern California

Kevin Smith

Affirmative

N/A

BC Hydro and Power Authority

Adrian Andreoiu

Abstain

N/A

Berkshire Hathaway Energy - MidAmerican Energy
Co.

Terry Harbour

Affirmative

N/A

Black Hills Corporation

Micah Runner

Affirmative

N/A

CenterPoint Energy Houston Electric, LLC

Daniela Hammons

Abstain

N/A

City Utilities of Springfield, Missouri

Michael Bowman

Affirmative

N/A

Con Ed - Consolidated Edison Co. of New York

Dermot Smyth

Affirmative

N/A

Dairyland Power Cooperative

Karrie Schuldt

Affirmative

N/A

Dominion - Dominion Virginia Power

Steven Belle

Affirmative

N/A

Duke Energy

Katherine Street

Negative

N/A

Edison International - Southern California Edison
Company

Robert Blackney

Affirmative

N/A

Entergy

Brian Lindsey

Affirmative

N/A

Evergy

Kevin Frick

Affirmative

N/A

Eversource Energy

Joshua London

Affirmative

N/A

Exelon

Daniel Gacek

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Theresa Ciancio

Negative

N/A

Georgia Transmission Corporation

Greg Davis

Affirmative

N/A

Glencoe Light and Power Commission

Terry Volkmann

Affirmative

N/A

Hydro One Networks, Inc.

Emma Halilovic

Ijad Dewan

Abstain

N/A

Hydro-Quebec (HQ)

Nicolas Turcotte

Chantal Mazza

Affirmative

N/A

IDACORP - Idaho Power Company

Sean Steffensen

Abstain

N/A

Imperial Irrigation District

Jesus Sammy Alcaraz

Denise Sanchez

Affirmative

N/A

International Transmission Company Holdings
Corporation

Michael Moltane

Gail Elliott

Affirmative

N/A

JEA

Joseph McClung

Affirmative

N/A

Lakeland Electric

Larry Watt

None

N/A

Lincoln Electric System

Josh Johnson

Affirmative

N/A

Isidoro Behar

Abstain

N/A

LaTroy Brumfield

Tim Kelley

Ellese Murphy

Hayden Maples

Stephen Stafford

Segment

Organization

Voter

Designated Proxy

Ballot

NERC
Memo

Los Angeles Department of Water and Power

faranak sarbaz

Abstain

N/A

LS Power Transmission, LLC

Jennifer Richardson

Abstain

N/A

Manitoba Hydro

Nazra Gladu

Affirmative

N/A

Minnkota Power Cooperative Inc.

Theresa Allard

Affirmative

N/A

Muscatine Power and Water

Andrew Kurriger

Affirmative

N/A

National Grid USA

Michael Jones

Abstain

N/A

NB Power Corporation

Jeffrey Streifling

Abstain

N/A

Nebraska Public Power District

Jamison Cawley

Affirmative

N/A

NextEra Energy - Florida Power and Light Co.

Silvia Mitchell

Affirmative

N/A

NiSource - Northern Indiana Public Service Co.

Alison Nickells

Affirmative

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Terri Pyle

Affirmative

N/A

Omaha Public Power District

Doug Peterchuck

Affirmative

N/A

Oncor Electric Delivery

Byron Booker

Abstain

N/A

OTP - Otter Tail Power Company

Charles Wicklund

None

N/A

Pacific Gas and Electric Company

Marco Rios

Affirmative

N/A

Pedernales Electric Cooperative, Inc.

Bradley Collard

Abstain

N/A

Platte River Power Authority

Marissa Archie

Affirmative

N/A

PNM Resources - Public Service Company of New
Mexico

Lynn Goldstein

Affirmative

N/A

Portland General Electric Co.

Brooke Jockin

Abstain

N/A

PPL Electric Utilities Corporation

Michelle McCartney
Longo

Negative

N/A

PSEG - Public Service Electric and Gas Co.

Karen Arnold

Affirmative

N/A

Public Utility District No. 1 of Chelan County

Diane E Landry

Affirmative

N/A

Public Utility District No. 1 of Snohomish County

Alyssia Rhoads

Affirmative

N/A

Sacramento Municipal Utility District

Wei Shao

Tim Kelley

Affirmative

N/A

Salt River Project

Laura Somak

Israel Perez

Affirmative

N/A

Santee Cooper

Chris Wagner

Affirmative

N/A

SaskPower

Wayne Guttormson

Abstain

N/A

Sempra - San Diego Gas and Electric

Mohamed Derbas

Affirmative

N/A

Southern Company - Southern Company Services,
Inc.

Matt Carden

Affirmative

N/A

Sunflower Electric Power Corporation

Paul Mehlhaff

Affirmative

N/A

Tacoma Public Utilities (Tacoma, WA)

John Merrell

Affirmative

N/A

Tallahassee Electric (City of Tallahassee, FL)

Scott Langston

Affirmative

N/A

Tennessee Valley Authority

David Plumb

Negative

N/A

Tri-State G and T Association, Inc.

Donna Wood

Affirmative

N/A

U.S. Bureau of Reclamation

Richard Jackson

Abstain

N/A

Ben Hammer

Affirmative

N/A

Tammy Porter

Michael Johnson

Segment

Organization

Voter

Designated Proxy

Ballot

NERC
Memo

Xcel Energy, Inc.

Eric Barry

Affirmative

N/A

California ISO

Darcy O'Connell

Affirmative

N/A

Electric Reliability Council of Texas, Inc.

Kennedy Meier

Affirmative

N/A

Independent Electricity System Operator

Helen Lainis

Affirmative

N/A

ISO New England, Inc.

John Pearson

Affirmative

N/A

Midcontinent ISO, Inc.

Bobbi Welch

Affirmative

N/A

New York Independent System Operator

Gregory Campoli

Affirmative

N/A

PJM Interconnection, L.L.C.

Thomas Foster

Affirmative

N/A

Southwest Power Pool, Inc. (RTO)

Joshua Phillips

Affirmative

N/A

AEP

Leshel Hutchings

Affirmative

N/A

Ameren - Ameren Services

David Jendras Sr

Affirmative

N/A

APS - Arizona Public Service Co.

Jessica Lopez

Affirmative

N/A

Arkansas Electric Cooperative Corporation

Ayslynn Mcavoy

Affirmative

N/A

Avista - Avista Corporation

Robert Follini

Negative

N/A

BC Hydro and Power Authority

Ming Jiang

Abstain

N/A

Berkshire Hathaway Energy - MidAmerican Energy
Co.

Joseph Amato

Affirmative

N/A

Black Hills Corporation

Josh Combs

Carly Miller

Affirmative

N/A

Buckeye Power, Inc.

Tom Schmidt

Ryan Strom

Affirmative

N/A

CMS Energy - Consumers Energy Company

Karl Blaszkowski

Affirmative

N/A

Colorado Springs Utilities

Hillary Dobson

None

N/A

Con Ed - Consolidated Edison Co. of New York

Peter Yost

Affirmative

N/A

Dominion - Dominion Virginia Power

Victoria Crider

Affirmative

N/A

DTE Energy - Detroit Edison Company

Marvin Johnson

Affirmative

N/A

Duke Energy - Florida Power Corporation

Marcelo Pesantez

Negative

N/A

Edison International - Southern California Edison
Company

Romel Aquino

Affirmative

N/A

Entergy

James Keele

Affirmative

N/A

Evergy

Marcus Moor

Affirmative

N/A

Eversource Energy

Vicki O'Leary

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Aaron Ghodooshim

Negative

N/A

Georgia System Operations Corporation

Scott McGough

Affirmative

N/A

Great River Energy

Michael Brytowski

Affirmative

N/A

Imperial Irrigation District

George Kirschner

Affirmative

N/A

JEA

Marilyn Williams

Affirmative

N/A

Lakeland Electric

Steven Marshall

None

N/A

Lincoln Electric System

Sam Christensen

Affirmative

N/A

Fausto Serratos

Abstain

N/A

Pirouz Honarmand

Elizabeth Davis

Nick Leathers

Denise Sanchez

Segment

Organization

Voter

Manitoba Hydro

Mike Smith

MGE Energy - Madison Gas and Electric Co.

Designated Proxy

NERC
Memo

Affirmative

N/A

Benjamin Widder

Affirmative

N/A

Muscatine Power and Water

Seth Shoemaker

Affirmative

N/A

National Grid USA

Brian Shanahan

Abstain

N/A

Nebraska Public Power District

Tony Eddleman

Affirmative

N/A

New York Power Authority

Richard Machado

Affirmative

N/A

NextEra Energy - Florida Power and Light Co.

Karen Demos

Affirmative

N/A

NiSource - Northern Indiana Public Service Co.

Steven Taddeucci

Affirmative

N/A

North Carolina Electric Membership Corporation

Chris Dimisa

Scott Brame

Affirmative

N/A

Ocala Utility Services

Neville Bowen

LaKenya Vannorman

None

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Donald Hargrove

Affirmative

N/A

Old Dominion Electric Coop.

William Pezalla

None

N/A

Omaha Public Power District

David Heins

Affirmative

N/A

OTP - Otter Tail Power Company

Wendi Olson

Affirmative

N/A

Pacific Gas and Electric Company

Sandra Ellis

Affirmative

N/A

PNM Resources - Public Service Company of New
Mexico

Amy Wesselkamper

Affirmative

N/A

PPL - Louisville Gas and Electric Co.

James Frank

None

N/A

PSEG - Public Service Electric and Gas Co.

Christopher Murphy

Affirmative

N/A

Public Utility District No. 1 of Chelan County

Joyce Gundry

Affirmative

N/A

Sacramento Municipal Utility District

Nicole Looney

Tim Kelley

Affirmative

N/A

Salt River Project

Mathew Weber

Israel Perez

Affirmative

N/A

Santee Cooper

Vicky Budreau

Affirmative

N/A

Sempra - San Diego Gas and Electric

Bryan Bennett

Affirmative

N/A

Snohomish County PUD No. 1

Holly Chaney

Affirmative

N/A

Southern Company - Alabama Power Company

Joel Dembowski

Affirmative

N/A

Southern Indiana Gas and Electric Co.

Ryan Snyder

Negative

N/A

Tennessee Valley Authority

Ian Grant

Negative

N/A

Tri-State G and T Association, Inc.

Ryan Walter

Affirmative

N/A

WEC Energy Group, Inc.

Christine Kane

Affirmative

N/A

Xcel Energy, Inc.

Nicholas Friebel

Affirmative

N/A

Alliant Energy Corporation Services, Inc.

Larry Heckert

Affirmative

N/A

Austin Energy

Tony Hua

Affirmative

N/A

Buckeye Power, Inc.

Jason Procuniar

Affirmative

N/A

CMS Energy - Consumers Energy Company

Aric Root

Affirmative

N/A

DTE Energy

Patricia Ireland

Affirmative

N/A

Electricities of North Carolina

Marcus Freeman

None

N/A

Mark Garza

Negative

N/A

Stephen Sines

Ballot

Michael Johnson

Ryan Strom

Segment

Organization

Voter

Designated Proxy

Ballot

NERC
Memo

Georgia System Operations Corporation

Katrina Lyons

Affirmative

N/A

Illinois Municipal Electric Agency

Mary Ann Todd

Abstain

N/A

North Carolina Electric Membership Corporation

Richard McCall

Affirmative

N/A

Northern California Power Agency

Marty Hostler

Affirmative

N/A

Public Utility District No. 1 of Snohomish County

John D. Martinsen

Affirmative

N/A

Public Utility District No. 2 of Grant County,
Washington

Karla Weaver

Abstain

N/A

Sacramento Municipal Utility District

Foung Mua

Affirmative

N/A

Tacoma Public Utilities (Tacoma, WA)

Hien Ho

Affirmative

N/A

Utility Services, Inc.

Carver Powers

Affirmative

N/A

WEC Energy Group, Inc.

Matthew Beilfuss

Affirmative

N/A

AEP

Thomas Foltz

Affirmative

N/A

AES - AES Corporation

Ruchi Shah

Affirmative

N/A

Ameren - Ameren Missouri

Sam Dwyer

Affirmative

N/A

APS - Arizona Public Service Co.

Andrew Smith

Affirmative

N/A

Associated Electric Cooperative, Inc.

Chuck Booth

Affirmative

N/A

Austin Energy

Michael Dillard

Affirmative

N/A

Avista - Avista Corporation

Glen Farmer

None

N/A

Basin Electric Power Cooperative

Amanda Wangler

None

N/A

BC Hydro and Power Authority

Quincy Wang

Abstain

N/A

Berkshire Hathaway - NV Energy

Dwanique Spiller

Affirmative

N/A

Black Hills Corporation

Sheila Suurmeier

Affirmative

N/A

Bonneville Power Administration

Juergen Bermejo

Affirmative

N/A

Buckeye Power, Inc.

Kevin Zemanek

Affirmative

N/A

CMS Energy - Consumers Energy Company

David Greyerbiehl

Affirmative

N/A

Colorado Springs Utilities

Jeffrey Icke

Affirmative

N/A

Con Ed - Consolidated Edison Co. of New York

Michelle Pagano

Affirmative

N/A

Constellation

Alison MacKellar

Affirmative

N/A

Dairyland Power Cooperative

Tommy Drea

Affirmative

N/A

Decatur Energy Center LLC

Megan Melham

Affirmative

N/A

Duke Energy

Dale Goodwine

Negative

N/A

Edison International - Southern California Edison
Company

Selene Willis

Affirmative

N/A

Enel Green Power

Natalie Johnson

Abstain

N/A

Entergy - Entergy Services, Inc.

Gail Golden

Affirmative

N/A

Evergy

Jeremy Harris

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Matthew Augustin

Negative

N/A

Jacalynn Bentz

Affirmative

N/A

Scott Brame

Tim Kelley

Ryan Strom

Hayden Maples

Segment

Organization

Voter

Greybeard Compliance Services, LLC

Mike Gabriel

Hydro-Quebec (HQ)

Junji Yamaguchi

Imperial Irrigation District

Tino Zaragoza

Invenergy LLC

Designated Proxy

Ballot

NERC
Memo

None

N/A

Chantal Mazza

Affirmative

N/A

Denise Sanchez

Affirmative

N/A

Rhonda Jones

Affirmative

N/A

JEA

John Babik

Affirmative

N/A

Lincoln Electric System

Brittany Millard

Affirmative

N/A

Los Angeles Department of Water and Power

Robert Kerrigan

None

N/A

Lower Colorado River Authority

Teresa Krabe

Affirmative

N/A

LS Power Development, LLC

C. A. Campbell

Abstain

N/A

National Grid USA

Robin Berry

Abstain

N/A

NB Power Corporation - New Brunswick Power
Transmission Corporation

Fon Hiew

Abstain

N/A

Nebraska Public Power District

Ronald Bender

Affirmative

N/A

New York Power Authority

Zahid Qayyum

Affirmative

N/A

NextEra Energy

Richard Vendetti

Affirmative

N/A

NiSource - Northern Indiana Public Service Co.

Kathryn Tackett

Affirmative

N/A

North Carolina Electric Membership Corporation

Reid Cashion

Affirmative

N/A

Northern California Power Agency

Jeremy Lawson

None

N/A

NRG - NRG Energy, Inc.

Patricia Lynch

Abstain

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Patrick Wells

Affirmative

N/A

Omaha Public Power District

Kayleigh Wilkerson

None

N/A

Ontario Power Generation Inc.

Constantin Chitescu

Affirmative

N/A

OTP - Otter Tail Power Company

Stacy Wahlund

Affirmative

N/A

Pacific Gas and Electric Company

Tyler Brun

Affirmative

N/A

Pattern Operators LP

George E Brown

Affirmative

N/A

Platte River Power Authority

Jon Osell

Affirmative

N/A

Portland General Electric Co.

Ryan Olson

None

N/A

PSEG Nuclear LLC

Tim Kucey

None

N/A

Public Utility District No. 1 of Chelan County

Rebecca Zahler

Affirmative

N/A

Public Utility District No. 1 of Snohomish County

Becky Burden

Affirmative

N/A

Public Utility District No. 2 of Grant County,
Washington

Nikkee Hebdon

None

N/A

Sacramento Municipal Utility District

Ryder Couch

Tim Kelley

Affirmative

N/A

Salt River Project

Thomas Johnson

Israel Perez

Affirmative

N/A

Santee Cooper

Carey Salisbury

Affirmative

N/A

Seminole Electric Cooperative, Inc.

Melanie Wong

Abstain

N/A

Sempra - San Diego Gas and Electric

Jennifer Wright

Affirmative

N/A

Leslie Burke

Affirmative

N/A

Scott Brame

Michael Johnson

Segment

Organization

Voter

Southern Indiana Gas and Electric Co.

Larry Rogers

Tacoma Public Utilities (Tacoma, WA)

Ozan Ferrin

Talen Generation, LLC

Designated Proxy

Ballot

NERC
Memo

Negative

N/A

None

N/A

Donald Lock

None

N/A

Tennessee Valley Authority

Darren Boehm

Negative

N/A

TransAlta Corporation

Ashley Scheelar

Affirmative

N/A

Tri-State G and T Association, Inc.

Sergio Banuelos

Affirmative

N/A

U.S. Bureau of Reclamation

Wendy Kalidass

Abstain

N/A

Vistra Energy

Daniel Roethemeyer

Affirmative

N/A

WEC Energy Group, Inc.

Michelle Hribar

Affirmative

N/A

Xcel Energy, Inc.

Gerry Huitt

Affirmative

N/A

AEP

Mathew Miller

Affirmative

N/A

Ameren - Ameren Services

Robert Quinlivan

Affirmative

N/A

APS - Arizona Public Service Co.

Marcus Bortman

Affirmative

N/A

Arkansas Electric Cooperative Corporation

Bruce Walkup

Affirmative

N/A

Austin Energy

Imane Mrini

Affirmative

N/A

Black Hills Corporation

Rachel Schuldt

Affirmative

N/A

Bonneville Power Administration

Tanner Brier

Affirmative

N/A

Cleco Corporation

Robert Hirchak

Affirmative

N/A

Con Ed - Consolidated Edison Co. of New York

Jason Chandler

Affirmative

N/A

Constellation

Kimberly Turco

Affirmative

N/A

CPower

Aaron Breidenbaugh

None

N/A

Dominion - Dominion Resources, Inc.

Sean Bodkin

Affirmative

N/A

Duke Energy

John Sturgeon

Negative

N/A

Entergy

Julie Hall

Affirmative

N/A

Evergy

Tiffany Lake

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Stacey Sheehan

Negative

N/A

Imperial Irrigation District

Diana Torres

Affirmative

N/A

Invenergy LLC

Colin Chilcoat

Affirmative

N/A

Lakeland Electric

Paul Shipps

Affirmative

N/A

Lincoln Electric System

Eric Ruskamp

None

N/A

Los Angeles Department of Water and Power

Anton Vu

Abstain

N/A

Manitoba Hydro

Brandin Stoesz

None

N/A

Muscatine Power and Water

Nicholas Burns

None

N/A

New York Power Authority

Shelly Dineen

Affirmative

N/A

NextEra Energy - Florida Power and Light Co.

Justin Welty

Affirmative

N/A

NiSource - Northern Indiana Public Service Co.

Dmitriy Bazylyuk

Affirmative

N/A

Dennis Sismaet

Abstain

N/A

Jennie Wike

David Vickers

Hayden Maples

Denise Sanchez

Segment

Organization

Voter

Designated Proxy

Ballot

NERC
Memo

OGE Energy - Oklahoma Gas and Electric Co.

Ashley F Stringer

Affirmative

N/A

Omaha Public Power District

Shonda McCain

Affirmative

N/A

Platte River Power Authority

Sabrina Martz

Affirmative

N/A

Portland General Electric Co.

Stefanie Burke

Abstain

N/A

Powerex Corporation

Raj Hundal

Abstain

N/A

PPL - Louisville Gas and Electric Co.

Linn Oelker

Negative

N/A

PSEG - PSEG Energy Resources and Trade LLC

Laura Wu

None

N/A

Public Utility District No. 1 of Chelan County

Robert Witham

Affirmative

N/A

Sacramento Municipal Utility District

Charles Norton

Tim Kelley

Affirmative

N/A

Salt River Project

Timothy Singh

Israel Perez

Affirmative

N/A

Santee Cooper

Marty Watson

Affirmative

N/A

Seminole Electric Cooperative, Inc.

Bret Galbraith

None

N/A

Snohomish County PUD No. 1

John Liang

Affirmative

N/A

Southern Company - Southern Company Generation

Ron Carlsen

Affirmative

N/A

Southern Indiana Gas and Electric Co.

Kati Barr

Negative

N/A

Tacoma Public Utilities (Tacoma, WA)

Terry Gifford

None

N/A

Tennessee Valley Authority

Armando Rodriguez

Negative

N/A

WEC Energy Group, Inc.

David Boeshaar

Affirmative

N/A

Western Area Power Administration

Jennifer Neville

Affirmative

N/A

Xcel Energy, Inc.

Steve Szablya

Affirmative

N/A

Midwest Reliability Organization

Mark Flanary

Affirmative

N/A

New York State Reliability Council

Wesley Yeomans

Affirmative

N/A

Northeast Power Coordinating Council

Gerry Dunbar

Abstain

N/A

ReliabilityFirst

Tyler Schwendiman

Affirmative

N/A

SERC Reliability Corporation

Dave Krueger

Affirmative

N/A

Texas Reliability Entity, Inc.

Rachel Coyne

Affirmative

N/A

Western Electricity Coordinating Council

Steven Rueckert

Affirmative

N/A

Jennie Wike

Greg Sorenson

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BALLOT RESULTS
Ballot Name: 2020-06 Verifications of Models and Data for Generators IBR-related Definitions | Implementation Plan FN 4
OT
Voting Start Date: 9/3/2024 11:38:03 AM
Voting End Date: 9/12/2024 8:00:00 PM
Ballot Type: OT
Ballot Activity: FN
Ballot Series: 4
Total # Votes: 251
Total Ballot Pool: 280
Quorum: 89.64
Quorum Established Date: 9/4/2024 10:02:44 AM
Weighted Segment Value: 93.66
Ballot
Pool

Segment
Weight

Affirmative
Votes

Affirmative
Fraction

Negative Votes w/
Comment

Negative Fraction
w/ Comment

Negative Votes w/o
Comment

Abstain

No
Vote

Segment:
1

0.93

0.07

Segment:
2

0.8

Segment:
3

0.918

0.082

Segment:
4

0.923

0.077

Segment:
5

0.943

0.057

Segment:
6

0.886

0.114

Segment:
7

Segment:
8

Segment:
9

Segment:
10

0.5

Totals:

280

6.3

204

5.9

0.4

Segment

BALLOT POOL MEMBERS
Show

All

Segment

entries

Organization

Search:

Voter
Dennis Sauriol

Designated Proxy

Ballot
Affirmative

NERC
Memo
N/A

Segment

Organization

Voter

Designated Proxy

Ballot

NERC
Memo

Allete - Minnesota Power, Inc.

Hillary Creurer

Affirmative

N/A

Ameren - Ameren Services

Tamara Evey

Affirmative

N/A

American Transmission Company, LLC

Amy Wilke

Affirmative

N/A

APS - Arizona Public Service Co.

Daniela Atanasovski

Affirmative

N/A

Arizona Electric Power Cooperative, Inc.

Jennifer Bray

Affirmative

N/A

Arkansas Electric Cooperative Corporation

Emily Corley

None

N/A

Associated Electric Cooperative, Inc.

Mark Riley

Affirmative

N/A

Austin Energy

Thomas Standifur

None

N/A

Avista - Avista Corporation

Mike Magruder

Affirmative

N/A

Balancing Authority of Northern California

Kevin Smith

Affirmative

N/A

BC Hydro and Power Authority

Adrian Andreoiu

Abstain

N/A

Berkshire Hathaway Energy - MidAmerican Energy
Co.

Terry Harbour

Affirmative

N/A

Black Hills Corporation

Micah Runner

Affirmative

N/A

CenterPoint Energy Houston Electric, LLC

Daniela Hammons

Affirmative

N/A

City Utilities of Springfield, Missouri

Michael Bowman

Affirmative

N/A

Con Ed - Consolidated Edison Co. of New York

Dermot Smyth

Affirmative

N/A

Dairyland Power Cooperative

Karrie Schuldt

Affirmative

N/A

Dominion - Dominion Virginia Power

Steven Belle

Affirmative

N/A

Duke Energy

Katherine Street

Negative

N/A

Edison International - Southern California Edison
Company

Robert Blackney

Affirmative

N/A

Entergy

Brian Lindsey

Affirmative

N/A

Evergy

Kevin Frick

Affirmative

N/A

Eversource Energy

Joshua London

Affirmative

N/A

Exelon

Daniel Gacek

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Theresa Ciancio

Negative

N/A

Georgia Transmission Corporation

Greg Davis

Affirmative

N/A

Glencoe Light and Power Commission

Terry Volkmann

Affirmative

N/A

Hydro One Networks, Inc.

Emma Halilovic

Ijad Dewan

Abstain

N/A

Hydro-Quebec (HQ)

Nicolas Turcotte

Chantal Mazza

Affirmative

N/A

IDACORP - Idaho Power Company

Sean Steffensen

Abstain

N/A

Imperial Irrigation District

Jesus Sammy Alcaraz

Denise Sanchez

Affirmative

N/A

International Transmission Company Holdings
Corporation

Michael Moltane

Gail Elliott

Affirmative

N/A

JEA

Joseph McClung

Affirmative

N/A

Lakeland Electric

Larry Watt

None

N/A

Lincoln Electric System

Josh Johnson

Affirmative

N/A

Isidoro Behar

Abstain

N/A

LaTroy Brumfield

Tim Kelley

Ellese Murphy

Hayden Maples

Stephen Stafford

Segment

Organization

Voter

Designated Proxy

Ballot

NERC
Memo

Los Angeles Department of Water and Power

faranak sarbaz

Abstain

N/A

LS Power Transmission, LLC

Jennifer Richardson

Abstain

N/A

Manitoba Hydro

Nazra Gladu

Affirmative

N/A

Minnkota Power Cooperative Inc.

Theresa Allard

Affirmative

N/A

Muscatine Power and Water

Andrew Kurriger

Affirmative

N/A

National Grid USA

Michael Jones

Abstain

N/A

NB Power Corporation

Jeffrey Streifling

Abstain

N/A

Nebraska Public Power District

Jamison Cawley

Affirmative

N/A

NextEra Energy - Florida Power and Light Co.

Silvia Mitchell

Affirmative

N/A

NiSource - Northern Indiana Public Service Co.

Alison Nickells

Affirmative

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Terri Pyle

Affirmative

N/A

Omaha Public Power District

Doug Peterchuck

Affirmative

N/A

Oncor Electric Delivery

Byron Booker

Abstain

N/A

OTP - Otter Tail Power Company

Charles Wicklund

None

N/A

Pacific Gas and Electric Company

Marco Rios

Affirmative

N/A

Pedernales Electric Cooperative, Inc.

Bradley Collard

Abstain

N/A

Platte River Power Authority

Marissa Archie

Affirmative

N/A

PNM Resources - Public Service Company of New
Mexico

Lynn Goldstein

Affirmative

N/A

Portland General Electric Co.

Brooke Jockin

Abstain

N/A

PPL Electric Utilities Corporation

Michelle McCartney
Longo

Negative

N/A

PSEG - Public Service Electric and Gas Co.

Karen Arnold

Affirmative

N/A

Public Utility District No. 1 of Chelan County

Diane E Landry

Affirmative

N/A

Public Utility District No. 1 of Snohomish County

Alyssia Rhoads

Affirmative

N/A

Sacramento Municipal Utility District

Wei Shao

Tim Kelley

Affirmative

N/A

Salt River Project

Laura Somak

Israel Perez

Affirmative

N/A

Santee Cooper

Chris Wagner

Affirmative

N/A

SaskPower

Wayne Guttormson

Abstain

N/A

Sempra - San Diego Gas and Electric

Mohamed Derbas

Affirmative

N/A

Southern Company - Southern Company Services,
Inc.

Matt Carden

Affirmative

N/A

Sunflower Electric Power Corporation

Paul Mehlhaff

Affirmative

N/A

Tacoma Public Utilities (Tacoma, WA)

John Merrell

Affirmative

N/A

Tallahassee Electric (City of Tallahassee, FL)

Scott Langston

Affirmative

N/A

Tennessee Valley Authority

David Plumb

Negative

N/A

Tri-State G and T Association, Inc.

Donna Wood

Affirmative

N/A

U.S. Bureau of Reclamation

Richard Jackson

Abstain

N/A

Ben Hammer

Affirmative

N/A

Tammy Porter

Michael Johnson

Segment

Organization

Voter

Designated Proxy

Ballot

NERC
Memo

Xcel Energy, Inc.

Eric Barry

Affirmative

N/A

California ISO

Darcy O'Connell

Affirmative

N/A

Electric Reliability Council of Texas, Inc.

Kennedy Meier

Affirmative

N/A

Independent Electricity System Operator

Helen Lainis

Affirmative

N/A

ISO New England, Inc.

John Pearson

Affirmative

N/A

Midcontinent ISO, Inc.

Bobbi Welch

Affirmative

N/A

New York Independent System Operator

Gregory Campoli

Affirmative

N/A

PJM Interconnection, L.L.C.

Thomas Foster

Affirmative

N/A

Southwest Power Pool, Inc. (RTO)

Joshua Phillips

Affirmative

N/A

AEP

Leshel Hutchings

Affirmative

N/A

Ameren - Ameren Services

David Jendras Sr

Affirmative

N/A

APS - Arizona Public Service Co.

Jessica Lopez

Affirmative

N/A

Arkansas Electric Cooperative Corporation

Ayslynn Mcavoy

Affirmative

N/A

Avista - Avista Corporation

Robert Follini

Negative

N/A

BC Hydro and Power Authority

Ming Jiang

Abstain

N/A

Berkshire Hathaway Energy - MidAmerican Energy
Co.

Joseph Amato

Affirmative

N/A

Black Hills Corporation

Josh Combs

Carly Miller

Affirmative

N/A

Buckeye Power, Inc.

Tom Schmidt

Ryan Strom

Affirmative

N/A

CMS Energy - Consumers Energy Company

Karl Blaszkowski

Affirmative

N/A

Colorado Springs Utilities

Hillary Dobson

None

N/A

Con Ed - Consolidated Edison Co. of New York

Peter Yost

Affirmative

N/A

Dominion - Dominion Virginia Power

Victoria Crider

Affirmative

N/A

DTE Energy - Detroit Edison Company

Marvin Johnson

Affirmative

N/A

Duke Energy - Florida Power Corporation

Marcelo Pesantez

Negative

N/A

Edison International - Southern California Edison
Company

Romel Aquino

Affirmative

N/A

Entergy

James Keele

Affirmative

N/A

Evergy

Marcus Moor

Affirmative

N/A

Eversource Energy

Vicki O'Leary

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Aaron Ghodooshim

Negative

N/A

Georgia System Operations Corporation

Scott McGough

Affirmative

N/A

Great River Energy

Michael Brytowski

Affirmative

N/A

Imperial Irrigation District

George Kirschner

Affirmative

N/A

JEA

Marilyn Williams

Affirmative

N/A

Lakeland Electric

Steven Marshall

None

N/A

Lincoln Electric System

Sam Christensen

Affirmative

N/A

Fausto Serratos

Abstain

N/A

Pirouz Honarmand

Elizabeth Davis

Nick Leathers

Denise Sanchez

Segment

Organization

Voter

Manitoba Hydro

Mike Smith

MGE Energy - Madison Gas and Electric Co.

Designated Proxy

NERC
Memo

Affirmative

N/A

Benjamin Widder

Affirmative

N/A

Muscatine Power and Water

Seth Shoemaker

Affirmative

N/A

National Grid USA

Brian Shanahan

Abstain

N/A

Nebraska Public Power District

Tony Eddleman

Affirmative

N/A

New York Power Authority

Richard Machado

Affirmative

N/A

NextEra Energy - Florida Power and Light Co.

Karen Demos

Affirmative

N/A

NiSource - Northern Indiana Public Service Co.

Steven Taddeucci

Affirmative

N/A

North Carolina Electric Membership Corporation

Chris Dimisa

Scott Brame

Affirmative

N/A

Ocala Utility Services

Neville Bowen

LaKenya Vannorman

None

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Donald Hargrove

Affirmative

N/A

Old Dominion Electric Coop.

William Pezalla

None

N/A

Omaha Public Power District

David Heins

Affirmative

N/A

OTP - Otter Tail Power Company

Wendi Olson

Affirmative

N/A

Pacific Gas and Electric Company

Sandra Ellis

Affirmative

N/A

PNM Resources - Public Service Company of New
Mexico

Amy Wesselkamper

Affirmative

N/A

PPL - Louisville Gas and Electric Co.

James Frank

None

N/A

PSEG - Public Service Electric and Gas Co.

Christopher Murphy

Affirmative

N/A

Public Utility District No. 1 of Chelan County

Joyce Gundry

Affirmative

N/A

Sacramento Municipal Utility District

Nicole Looney

Tim Kelley

Affirmative

N/A

Salt River Project

Mathew Weber

Israel Perez

Affirmative

N/A

Santee Cooper

Vicky Budreau

Affirmative

N/A

Sempra - San Diego Gas and Electric

Bryan Bennett

Affirmative

N/A

Snohomish County PUD No. 1

Holly Chaney

Affirmative

N/A

Southern Company - Alabama Power Company

Joel Dembowski

Affirmative

N/A

Southern Indiana Gas and Electric Co.

Ryan Snyder

Affirmative

N/A

Tennessee Valley Authority

Ian Grant

Negative

N/A

Tri-State G and T Association, Inc.

Ryan Walter

Affirmative

N/A

WEC Energy Group, Inc.

Christine Kane

Affirmative

N/A

Xcel Energy, Inc.

Nicholas Friebel

Affirmative

N/A

Alliant Energy Corporation Services, Inc.

Larry Heckert

Affirmative

N/A

Austin Energy

Tony Hua

Affirmative

N/A

Buckeye Power, Inc.

Jason Procuniar

Affirmative

N/A

CMS Energy - Consumers Energy Company

Aric Root

Affirmative

N/A

DTE Energy

Patricia Ireland

Affirmative

N/A

Electricities of North Carolina

Marcus Freeman

None

N/A

Mark Garza

Negative

N/A

Stephen Sines

Ballot

Michael Johnson

Ryan Strom

Segment

Organization

Voter

Designated Proxy

Ballot

NERC
Memo

Georgia System Operations Corporation

Katrina Lyons

Affirmative

N/A

Illinois Municipal Electric Agency

Mary Ann Todd

Abstain

N/A

North Carolina Electric Membership Corporation

Richard McCall

Affirmative

N/A

Northern California Power Agency

Marty Hostler

Affirmative

N/A

Public Utility District No. 1 of Snohomish County

John D. Martinsen

Affirmative

N/A

Public Utility District No. 2 of Grant County,
Washington

Karla Weaver

Abstain

N/A

Sacramento Municipal Utility District

Foung Mua

Affirmative

N/A

Tacoma Public Utilities (Tacoma, WA)

Hien Ho

Affirmative

N/A

Utility Services, Inc.

Carver Powers

Affirmative

N/A

WEC Energy Group, Inc.

Matthew Beilfuss

None

N/A

AEP

Thomas Foltz

Affirmative

N/A

AES - AES Corporation

Ruchi Shah

Affirmative

N/A

Ameren - Ameren Missouri

Sam Dwyer

Affirmative

N/A

APS - Arizona Public Service Co.

Andrew Smith

Affirmative

N/A

Associated Electric Cooperative, Inc.

Chuck Booth

Affirmative

N/A

Austin Energy

Michael Dillard

Affirmative

N/A

Avista - Avista Corporation

Glen Farmer

None

N/A

Basin Electric Power Cooperative

Amanda Wangler

None

N/A

BC Hydro and Power Authority

Quincy Wang

Abstain

N/A

Berkshire Hathaway - NV Energy

Dwanique Spiller

Affirmative

N/A

Black Hills Corporation

Sheila Suurmeier

Affirmative

N/A

Bonneville Power Administration

Juergen Bermejo

Affirmative

N/A

Buckeye Power, Inc.

Kevin Zemanek

Affirmative

N/A

CMS Energy - Consumers Energy Company

David Greyerbiehl

Affirmative

N/A

Colorado Springs Utilities

Jeffrey Icke

Affirmative

N/A

Con Ed - Consolidated Edison Co. of New York

Michelle Pagano

Affirmative

N/A

Constellation

Alison MacKellar

Affirmative

N/A

Dairyland Power Cooperative

Tommy Drea

Affirmative

N/A

Decatur Energy Center LLC

Megan Melham

Affirmative

N/A

Duke Energy

Dale Goodwine

Negative

N/A

Edison International - Southern California Edison
Company

Selene Willis

Affirmative

N/A

Enel Green Power

Natalie Johnson

Abstain

N/A

Entergy - Entergy Services, Inc.

Gail Golden

Affirmative

N/A

Evergy

Jeremy Harris

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Matthew Augustin

Negative

N/A

Jacalynn Bentz

Affirmative

N/A

Scott Brame

Tim Kelley

Ryan Strom

Hayden Maples

Segment

Organization

Voter

Greybeard Compliance Services, LLC

Mike Gabriel

Hydro-Quebec (HQ)

Junji Yamaguchi

Imperial Irrigation District

Tino Zaragoza

Invenergy LLC

Designated Proxy

Ballot

NERC
Memo

None

N/A

Chantal Mazza

Affirmative

N/A

Denise Sanchez

Affirmative

N/A

Rhonda Jones

Affirmative

N/A

JEA

John Babik

Affirmative

N/A

Lincoln Electric System

Brittany Millard

Affirmative

N/A

Los Angeles Department of Water and Power

Robert Kerrigan

None

N/A

Lower Colorado River Authority

Teresa Krabe

Affirmative

N/A

LS Power Development, LLC

C. A. Campbell

Abstain

N/A

National Grid USA

Robin Berry

Abstain

N/A

NB Power Corporation - New Brunswick Power
Transmission Corporation

Fon Hiew

Abstain

N/A

Nebraska Public Power District

Ronald Bender

Affirmative

N/A

New York Power Authority

Zahid Qayyum

Affirmative

N/A

NextEra Energy

Richard Vendetti

Affirmative

N/A

NiSource - Northern Indiana Public Service Co.

Kathryn Tackett

Affirmative

N/A

North Carolina Electric Membership Corporation

Reid Cashion

Affirmative

N/A

Northern California Power Agency

Jeremy Lawson

None

N/A

NRG - NRG Energy, Inc.

Patricia Lynch

Abstain

N/A

OGE Energy - Oklahoma Gas and Electric Co.

Patrick Wells

Affirmative

N/A

Omaha Public Power District

Kayleigh Wilkerson

None

N/A

Ontario Power Generation Inc.

Constantin Chitescu

Affirmative

N/A

OTP - Otter Tail Power Company

Stacy Wahlund

Affirmative

N/A

Pacific Gas and Electric Company

Tyler Brun

Affirmative

N/A

Pattern Operators LP

George E Brown

Affirmative

N/A

Platte River Power Authority

Jon Osell

Affirmative

N/A

Portland General Electric Co.

Ryan Olson

None

N/A

PSEG Nuclear LLC

Tim Kucey

None

N/A

Public Utility District No. 1 of Chelan County

Rebecca Zahler

Affirmative

N/A

Public Utility District No. 1 of Snohomish County

Becky Burden

Affirmative

N/A

Public Utility District No. 2 of Grant County,
Washington

Nikkee Hebdon

None

N/A

Sacramento Municipal Utility District

Ryder Couch

Tim Kelley

Affirmative

N/A

Salt River Project

Thomas Johnson

Israel Perez

Affirmative

N/A

Santee Cooper

Carey Salisbury

Affirmative

N/A

Seminole Electric Cooperative, Inc.

Melanie Wong

Abstain

N/A

Sempra - San Diego Gas and Electric

Jennifer Wright

Affirmative

N/A

Leslie Burke

Affirmative

N/A

Scott Brame

Michael Johnson

Segment

Organization

Voter

Southern Indiana Gas and Electric Co.

Larry Rogers

Tacoma Public Utilities (Tacoma, WA)

Ozan Ferrin

Talen Generation, LLC

Designated Proxy

Ballot

NERC
Memo

Affirmative

N/A

None

N/A

Donald Lock

None

N/A

Tennessee Valley Authority

Darren Boehm

Negative

N/A

TransAlta Corporation

Ashley Scheelar

Affirmative

N/A

Tri-State G and T Association, Inc.

Sergio Banuelos

Affirmative

N/A

U.S. Bureau of Reclamation

Wendy Kalidass

Abstain

N/A

Vistra Energy

Daniel Roethemeyer

Affirmative

N/A

WEC Energy Group, Inc.

Michelle Hribar

Affirmative

N/A

Xcel Energy, Inc.

Gerry Huitt

Affirmative

N/A

AEP

Mathew Miller

Affirmative

N/A

Ameren - Ameren Services

Robert Quinlivan

Affirmative

N/A

APS - Arizona Public Service Co.

Marcus Bortman

Affirmative

N/A

Arkansas Electric Cooperative Corporation

Bruce Walkup

Affirmative

N/A

Austin Energy

Imane Mrini

Affirmative

N/A

Black Hills Corporation

Rachel Schuldt

Affirmative

N/A

Bonneville Power Administration

Tanner Brier

Affirmative

N/A

Con Ed - Consolidated Edison Co. of New York

Jason Chandler

Affirmative

N/A

Constellation

Kimberly Turco

Affirmative

N/A

CPower

Aaron Breidenbaugh

None

N/A

Dominion - Dominion Resources, Inc.

Sean Bodkin

Affirmative

N/A

Duke Energy

John Sturgeon

Negative

N/A

Entergy

Julie Hall

Affirmative

N/A

Evergy

Tiffany Lake

Affirmative

N/A

FirstEnergy - FirstEnergy Corporation

Stacey Sheehan

Negative

N/A

Imperial Irrigation District

Diana Torres

Affirmative

N/A

Invenergy LLC

Colin Chilcoat

Affirmative

N/A

Lakeland Electric

Paul Shipps

Affirmative

N/A

Lincoln Electric System

Eric Ruskamp

None

N/A

Los Angeles Department of Water and Power

Anton Vu

Abstain

N/A

Manitoba Hydro

Brandin Stoesz

None

N/A

Muscatine Power and Water

Nicholas Burns

None

N/A

New York Power Authority

Shelly Dineen

Affirmative

N/A

NextEra Energy - Florida Power and Light Co.

Justin Welty

Affirmative

N/A

NiSource - Northern Indiana Public Service Co.

Dmitriy Bazylyuk

Affirmative

N/A

Northern California Power Agency

Dennis Sismaet

Abstain

N/A

Ashley F Stringer

Affirmative

N/A

Jennie Wike

David Vickers

Hayden Maples

Denise Sanchez

Segment

Organization

Voter

Designated Proxy

Ballot

NERC
Memo

Omaha Public Power District

Shonda McCain

Affirmative

N/A

Platte River Power Authority

Sabrina Martz

Affirmative

N/A

Portland General Electric Co.

Stefanie Burke

Abstain

N/A

Powerex Corporation

Raj Hundal

Abstain

N/A

PPL - Louisville Gas and Electric Co.

Linn Oelker

Negative

N/A

PSEG - PSEG Energy Resources and Trade LLC

Laura Wu

None

N/A

Public Utility District No. 1 of Chelan County

Robert Witham

Affirmative

N/A

Sacramento Municipal Utility District

Charles Norton

Tim Kelley

Affirmative

N/A

Salt River Project

Timothy Singh

Israel Perez

Affirmative

N/A

Santee Cooper

Marty Watson

Affirmative

N/A

Seminole Electric Cooperative, Inc.

Bret Galbraith

None

N/A

Snohomish County PUD No. 1

John Liang

Affirmative

N/A

Southern Company - Southern Company Generation

Ron Carlsen

Affirmative

N/A

Southern Indiana Gas and Electric Co.

Kati Barr

Affirmative

N/A

Tacoma Public Utilities (Tacoma, WA)

Terry Gifford

None

N/A

Tennessee Valley Authority

Armando Rodriguez

Negative

N/A

WEC Energy Group, Inc.

David Boeshaar

Affirmative

N/A

Western Area Power Administration

Jennifer Neville

Affirmative

N/A

Xcel Energy, Inc.

Steve Szablya

Affirmative

N/A

Midwest Reliability Organization

Mark Flanary

Affirmative

N/A

Northeast Power Coordinating Council

Gerry Dunbar

Abstain

N/A

ReliabilityFirst

Tyler Schwendiman

Affirmative

N/A

SERC Reliability Corporation

Dave Krueger

Affirmative

N/A

Texas Reliability Entity, Inc.

Rachel Coyne

Affirmative

N/A

Western Electricity Coordinating Council

Steven Rueckert

Affirmative

N/A

Jennie Wike

Greg Sorenson

Previous
Showing 1 to 280 of 280 entries

Exhibit F
Standard Drafting Team Roster

RELIABILITY | RESILIENCE | SECURITY

Standard Drafting Team Roster

Project 2020-06 Verifications of Models and Data for Generators
Name

Entity

Chair

Brad Marszalkowski

ISO-New England

Vice Chair

Katie Iverson

S Power

Members

Andrew Arana

Florida Power & Light

Jonathan Rose

ERCOT

Sam Li

BC Hydro

Jason MacDowell

GE Energy Consulting

Robert J. O’Keefe

American Electric Power

Biju Gopi N.

California ISO

Michael (Bing) Xia

Powertech Labs

Emily Greene

AES Corp

Zhibo Wang

Mitsubishi Electric Power Product Inc

Husam Al-Hadidi

Manitoba Hydro

Mohamed El Khatib

Invenergy

Mohamed Elnozahy

IESO

David Marshall

Southern Company

Sarah Habriga

ATC

Ellese Murphy

Duke Energy

Josh Blume – Standards Developer

North American Electric Reliability Corporation

Alain Rigaud – Counsel

North American Electric Reliability Corporation

PMOS Liaison

NERC Staff

RELIABILITY | RESILIENCE | SECURITY

File Type	application/pdf
Author	Lauren Perotti
File Modified	2024-11-04
File Created	2024-11-04