Facility Interconnection Requirements

Grid transformation is a risk element in the NERC 2026 Compliance Monitoring and Enforcement Program Implementation Plan (CMEP IP). Its goal is to address the integration of new technologies posing risks to the reliable operation of the Bulk Electric System (BES). This is achieved through improved communication of interconnection requirements and further development of performance and modeling requirements.

FAC-001-4

Beginning with the FAC-001-4 NERC Reliability Standard, entities must document their Facility interconnection requirements and make them available so that entities seeking to interconnect have the necessary information, according to Requirement 1 and Requirement 2. Requirement 3 and Requirement 4 require that entities address specific procedural requirements in their Facility interconnection processes.

The questions below are intended to assist entities in effectively addressing R1 and R2 of FAC-001-4.

Texas RE has seen that a more detailed process, including respective roles and responsibilities, results in better outcomes that create a more reliable BPS. Entities should ensure that these focus points are formally answered in their documented process.

FAC-002-4

Next, the FAC-002-4 NERC Reliability Standard requires entities to study the impact of interconnecting new or changed Facilities to the BES.

NERC released a NERC Alert in June of 2024 on Inverter-Based Resource Model Quality Deficiencies and cited poor modeling and study practices as contributing causes to disturbance events involving IBRs. Following that, NERC released another NERC Alert in May of 2025, on Inverter-Based Resource Performance and Modeling instructing Transmission Owners and Operators, Planning Coordinators, and Generator Owners to enhance their technical minimum requirements and study processes to mitigate risks posed by inverter-based resource (IBR) performance during system disturbances.

The interconnection study process allows entities to address these reliability risks by assessing the impact the power generator(s) have on the Bulk Power System (BPS), confirming the accuracy of models submitted to ensure proper mitigation measures are implemented, and collaborating on applicable NERC Reliability Standards, regional and Transmission Owner planning criteria, and Facility interconnection requirements.

Best Practices for Registered Entities

• Specify and communicate model submission requirements.
• Implement internal controls designed to verify the accuracy of submitted models.
• Document Facility interconnection requirements that address specific performance criteria for IBRs.
• Identify and study IBR-specific risks to ensure proper mitigation measures are developed.
• Identify appropriate cadence for periodic reviews of Facility interconnection requirements.

Key Takeaway

FAC-001-4 and FAC-002-4 help entities understand and address areas needing exceptional attention to help ensure they are communicating efficiently and exchanging detailed, necessary interconnection information. The documentation of a comprehensive process coupled with effective internal controls position entities to mitigate the reliability risks that come with interconnecting new or changed Facilities to the Bulk Electric System.