For grid-scale solar projects connecting to the bulk electric system, NERC compliance is often treated as a post-construction concern, when the obligations take shape much earlier in the design phase. Waiting until commissioning to address compliance can leave owner-operators scrambling at the commercial operation date (COD), when full regulatory responsibility activates.

Facilities with a rating of at least 20 MVA and a point-of-interconnection voltage of at least 60 kV should consider NERC requirements from the outset. It is important to evaluate project parameters to understand anticipated registration classification as a NERC Generator Owner (GO)/Generator Operator (GOP) Category 1 or 2 for NERC standard applicability and impact level. Most projects will be classified as “low impact;” however, low impact status doesn’t mean there aren’t obligations. Even at this tier, a formal compliance program must be fully operational by COD, covering the NERC operations and planning (O&P) and critical infrastructure protection (CIP) reliability standards as applicable to the project.

Early in the process, developers and designers need to define equipment, document settings and build the compliance program framework that will carry the project through to COD. Getting this sequence right while logging the proper documentation the first time avoids rework later. For example, improper design and location of bulk electric system (BES) cyber system equipment can create risk and delays. Proper classification (low or medium) will establish CIP requirements for critical design such as physical security, placement of BES cyber assets, system architecture and many others. The cost of redesign and relocation of BES systems can be very high.

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