Top 5 NERC Mistakes Solar Developers Make
By Rush Ferrell
Founded in the wake of the 2003 Northeast Blackout, the North American Electric Reliability Corporation (NERC) is responsible for ensuring the reliability of the Bulk Electric System (BES). It is an independent self-regulatory organization with a federal mandate to create Reliability Standards—an agreed rule set by which every high voltage generator and transmission line must operate.
With its frequent updates and regulatory changes, NERC compliance can be a puzzle even for seasoned solar developers. Over the course of a four-part series, we’ll cover much of what solar developers need to know about NERC.
First, here are the top mistakes solar developers make when it comes to NERC compliance.
1. Not Starting Early Enough
NERC compliance begins long before the Commercial Operation Date (COD). Getting things right from the beginning is critical to ensure compliance. Picking the right EPC, SCADA and HV provider can make or break a project.
2. Forgetting About Cyber Security
Solar developers often overlook cybersecurity, thinking it is something to be dealt with during the operations phase. However, purchasing the right site network equipment and designing it in a secure manner is critical.
3. Lack of Coordination With the O&M
O&Ms have a large depth of knowledge and lessons learned from previous projects. Solar developers should use their resources well and let the O&M opine on SCADA, site layout and controls. They can make tweaks to the site plans to ensure the site will operate in a compliant manner.
4. Forgetting to put NERC Language in the EPC Agreement
While the generator owner (GO) is ultimately held accountable by NERC, the responsibility for carrying out compliance-related activities is not so clear cut. It must be decided on a project-by-project basis by the stakeholders.
Some owners rely on internal or third-party compliance experts to ensure all requirements are met. On other projects, the EPC is responsible for NERC during the construction phase and the O&M is responsible during the operations phase. However, this cannot be assumed. The EPC agreement must spell out the specific responsibilities of the EPC in terms of NERC compliance.
5. Not Selecting Partners With NERC Experience
You can’t fake it when it comes to NERC. Most solar developers that don’t consider NERC compliance from the beginning find themselves unable to recover.
Selecting good partners that understand the NERC requirements are critical to ensuring a project is compliant at COD. A SCADA or HV partner that doesn’t understand the requirements could deliver a site that needs a complete overhaul in order to meet the compliance requirements.