FERC Order No. 901: IBR 9-1-1
Jason Doering, P.Eng
Grid & Physics Advocate - physics trumps rhetoric every time
On October 19, 2023, FERC published Order No. 901 Reliability Standards to Address Inverter-Based Resources which directs NERC to develop new or modified Reliability Standards to specifically address reliability risks associated with inverter-based resources (IBR) – wind and solar generation and battery energy storage.? The intent of this article is to provide a brief overview of Order No. 901 and its significance to transmission planning and power system operations.
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Our Synchronous Past
NERC is the US agency responsible for developing, maintaining, and enforcing mandatory Reliability Standards for the North American bulk power system (BPS).? Following the historic 2003 Northeast Blackout , NERC established a comprehensive set of mandatory Reliability Standards that dictated the planning and operational requirements and practices for entities that develop, plan, and operate transmission and generation facilities on North American power systems.? Prior to the 2003 Blackout, compliance to Reliability Standards was not mandatory and standards were essentially guidelines for good practice, but the Blackout demonstrated that reliability could not be left to chance and that compliance to planning and operating standards was required to ensure the ongoing reliability of North America’s interconnected power systems. ??
When the mandatory Reliability Standards were implemented in 2003, virtually all power generators were “synchronous”, meaning that they use rotating generators that are directly electromagnetically coupled, or “synchronized” to the power system.? Synchronous power generators include steam turbines (turbines driven by steam generated by coal-fired boilers, gas-fired boilers, or nuclear fission), simple cycle gas turbines, combined cycle gas turbines, and hydroelectric turbines.? Synchronous generators provide electrical energy as well as frequency and voltage support, which are essential to enable power system operators to maintain operational reliability.? Understandably, the Reliability Standards were focused on synchronous generators since this was almost exclusively how power was generated.?
However, power systems around the world have seen a dramatic shift in the generation resource mix over the past 10 years as government climate change policies have increasingly incented the growth of renewable energy generation and dis-incented fossil fuel based conventional generation.? While these policies have been successful in greatly increasing the volume of electricity generated from wind and solar facilities, the unintended consequence has been significant changes to the operational characteristics of power systems that are reducing reliability margins and exposing customers to increased risks of disturbances and blackouts.?
The reason for this is that renewable energy facilities (wind and solar) and batteries are not synchronized to the power system like conventional generators, and this creates new challenges for power system operators. ?These generators are connected to the power system indirectly through sophisticated power electronics called inverters, and for this reason they are collectively known as Inverter-based Resources (IBRs).? IBRs provide electrical energy, similar to synchronous generators, but the challenge with IBRs is that they do not inherently provide frequency and voltage support like synchronous generators.? Their electronics can be designed and configured to provide some degree of voltage and frequency support during disturbances and abnormal operating conditions, but the current Reliability Standards do not adequately address the configuration and operation of IBRs, which is leading to significant operational challenges as power generation from IBRs increases while generation from synchronous generators decreases.
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Better Late Than Never
The operational challenges with IBRs have been known for some time, and NERC has attempted to address some of the issues through the publication of multiple reliability guidelines and initiating a number of projects to identify Reliability Standard revisions to address IBR challenges.? However, there have been a number of significant power system disturbances involving IBRs in recent years, and the 2022 Odessa Disturbance in Texas and 2023 Southwest Utah disturbance seem to have pushed FERC to the limit of its patience, resulting in Order No. 901 this year.?
The statements by Commissioner Danly in the Order clearly demonstrate FERC’s frustration:
“I concur in today’s order in which we direct NERC to develop new or modified mandatory and enforceable Reliability Standards prior to 2030 in order to address a set of reliability risks we have known about, and been actively discussing, since at least 2016 and about which I have long warned.? Is today’s order important and necessary?? Yes.? Is it timely?? No.? Six of the thirteen documented events occurred in 2021.?? The Commission and NERC could have, and should have, acted sooner, particularly since 2030 marks the time at which inverter-based resources (IBRs) “are projected to account for a significant share of the electric energy generated in the United States.”
The reliability risks at issue arise from the rapid, widespread (one might say reckless) addition of IBRs (e.g., wind and solar) to the Bulk-Power System (BPS).
Our oversight role requires us to remain vigilant in ensuring that NERC Reliability Standards are timely, efficient, and effective.? Up to nearly fourteen years to establish mandatory and enforceable NERC Reliability Standards to address a known, and potentially catastrophic, risk to the reliability of the BPS is simply too long a time to wait.? And we will have to wait yet longer to learn whether the standards we do ultimately implement end up proving effective.? Who knows what will happen in the meantime.
Better late than never, I suppose.”
Mic drop by Commissioner Danly!!
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What Does Order No. 901 Include?
The Order directs NERC to develop new or modified Reliability Standards to address the following areas:
FERC is crystal clear in the Order that, from its perspective, “the currently effective Reliability Standards do not ensure that Bulk-Power System planners and operators have the necessary tools to plan for and reliably integrate IBRs into the Bulk-Power System”.? This puts the onus squarely on NERC to develop specific Reliability Standards and requirements for IBRs that parallel the current standards for synchronous resources.? This will affect the standards that cover planning, modeling, and system operations.
What is also notable in the Order is that FERC explicitly recognizes the need for the Reliability Standards to include the impacts of IBRs connected to the distribution system (distributed energy resources (DERs)).? FERC states that “the currently effective Reliability Standards do not ensure that Bulk-Power System planners and operators have the necessary tools… to plan for IBRs connected to the distribution system that in the aggregate have a material impact on the Bulk-Power System (IBR-DER).? IBRs, individually and in the aggregate, and IBR-DERs in the aggregate can have a material impact on the reliable operation of the Bulk-Power System”.? This will be a significant change in practice for both distribution and transmission system planners and operators.? It also highlights the growing convergence of distribution and transmission system planning and operations as a feature of the energy transition, with the growing trend of consumers installing solar generation and battery storage at the distribution level which is and will materially change traditional power flow patterns between the transmission and distribution systems.
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Compressed Implementation Schedule
FERC makes it clear in the Order that all IBR related Reliability Standards must be in place well before 2030 and sets the following deadlines for NERC:
FERC makes no apologies for what appears to be a relatively aggressive implementation schedule and says, “we emphasize that industry has been aware of and alerted to the need to address the impacts of IBRs on the Bulk-Power System since at least 2016”.
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Concluding Thoughts
With Order No. 901, FERC has essentially pulled the fire alarm and put the industry on notice that the reliability risks posed by IBRs to North American power systems have reached unacceptable levels and immediate action is required by NERC.? We are seeing degrading inertial response, voltage management challenges, significant disturbances, and increasing volumes of Energy Emergency Alerts on power systems across North America – reliability is at significant risk.
Although Alberta is not NERC jurisdictional, we adopt the relevant NERC standards as Alberta Reliability Standards.? The process to adopt and implement NERC Reliability Standards in Alberta can be lengthy but given the reliability risks associated with increasing levels of IBRs in Alberta, I urge the AESO to consider an expedited process for adopting IBR-related NERC standards as soon as they are implemented by NERC.? I think this should be a top priority to ensure the ongoing reliability and security of the Alberta power system.
Electrical Engineer
11 个月well written posts. thank you
MAINTENANCE MANAGEMENT PROFESSIONAL | INSTRUMENTATION TECHNICIAN/ELECTRICIAN | CERTIFIED ENGINEERING TECH>>> Driving Performance Through Safety-First Leadership, Transformational Change & Innovative Solutions
12 个月Excellent article Jason Doering, P.Eng . Thank you for sharing and, I hope you continue to help educate the masses on the challenges ahead for AESO and the collective ‘Grid’.
Retired
1 年Great idea
Retired Lead Engineer with front line experience in utility industry
1 年Thank you Jason for bringing forward issues relating to Alberta power system and overall North America power system. Great dedication of your time and knowledge to all stakeholders. As a side note relating to AESO rules. AESO has voltage support and voltage ride through requirement rule for Wind Aggregating generation facilities (WAGF) for least 15+ years. These requirements are very similar to requirements for synchronous generators. It is a well known fact in real time operation that some WAGF locations are not meeting voltage support requirements in real time operation to the level synchronous generators do. Either rule’s requirements are not checked/monitored during commissioning process by practically demonstrating that facility meet the rule requirement or rule get relaxed location to location. Any rule and reliability standard in place must be enforced when facilities are commissioned before being permitted to connect to AIES to avoid becoming a problem to real time system reliability in future.
Managing Director Lodestone Energy, Director and investor in solar power, power generation, energy retailing and financial services.
1 年This is interesting and thanks for posting! It illustrates the importance of standards as new technology enters the market. I have all the confidence in the world that by 2030 the issues with IBRs will be sorted. Clearly no need here to panic and announce Daniel smith- style moritoriums when thoughtful integration can be dealt with over the next seven years in conjunction with NERC. It would also behoove AESO to have a look at Australia states, as the penetration of IBR is several time more than Alberta and it gives a glimpse of what 2030 might look like. Keep calm and carry on!