Enforcement Explained: Managing NERC compliance during generator uprates
By Mike Hattery, Joe Pilch, and Dirk Baker
In this column, ReliabilityFirst Enforcement Staff share information on a variety of topics with a focus on communicating risk and providing transparency into the enforcement process. This includes: (a) identification of concerning violation trends, common failure types, and suggested solutions; (b) communication of expectations; and (c) commentary on enforcement approaches and specific factors that may affect the outcome in any given case. If you want to learn more about any of the topics discussed herein, please reach out to the author or your case manager.
We are amid a dynamic grid transformation driven by a litany of factors including: (a) large increases in long-term load forecasts; (b) a generation fleet experiencing unit retirements; and (c) the complexities of integrating both Inverter-Based Resources and large loads. The Electric Reliability Organization’s 2026 Long Term Reliability Assessment found that the overall resource adequacy outlook for the North American Bulk Power System is worsening.¹ The report further provides “to ensure there are sufficient resources for supplying electricity in the future and to reliably meet the growing electricity needs for North Americans, industry, regulators, and policymakers need to be vigilant for shifting projections, keep plans for deactivating existing generators flexible, expedite system development, and perform robust adequacy assessments of future scenarios.”²
One of the ways in which industry has been confronting this challenge at the margins is through generator uprates, that is, modifying or rewinding existing generator components to increase MW/MVA output. With increased interest in and frequency of generator uprates, ReliabilityFirst’s (RF’s) Enforcement and Risk teams felt it was important to flag NERC compliance considerations associated with such a change.
Therefore, RF staff reviewed the O&P requirements applicable to Generator Owners (GOs) and Generator Operators (GOPs) to identify standards and requirements that are most likely to be impacted by an entity completing a generator uprate. From there, we created an excel spreadsheet viewable here. The sheet includes two categories (tabs): (1) the standard and requirements with a *higher likelihood* to be impacted by an uprate with commentary to consider (first tab); and (2) standards which *may* be impacted under unique circumstances (second tab).
The intention is to flag requirements which may have specific required acts if the entity chooses to uprate a generator. Therefore, perpetually applicable requirements like NERC Standard TOP-001-6 (Transmission Operations) R3 requiring GOPs to follow Operating Instructions, COM-002-4 (Operating Personnel Communications Protocols) R6 requiring the use of three-part communication, and others are not included as the obligations are not impacted by an uprate. Further, requirements related to curing flawed data submissions (e.g., MOD-026-2 [Verification and Validation of Dynamic Models and Data] R6) or implementing Corrective Action Plans (e.g., PRC-004-6 [Protection System Misoperation Identification and Correction] R6) relating to other underlying acts were not flagged as the obligations do not originate from the uprate itself.
It is important to note that RF is unable to contemplate or address all possible uprate/configuration modification scenarios in building this sheet. This sheet should not be taken to be a complete universe of potentially implicated standards for all generator uprates or configuration changes and RF disclaims its use to that end. It is intended as a useful tool in starting your compliance analysis. However, if you have any questions about specific generator uprates or configuration changes, please reach out to your case manager or Entity Engagement for a detailed discussion of compliance implications for your unique situation.
- See LTRA Executive Summary at page 6.
- Id at page 6.