[Federal Register Volume 91, Number 36 (Tuesday, February 24, 2026)]
[Notices]
[Pages 8864-8872]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2026-03659]
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DEPARTMENT OF ENERGY
Federal Energy Regulatory Commission
[Docket Nos. RD26-1-000, RD26-2-000, RD26-3-000 (not consolidated)]
Before Commissioners: Laura V. Swett, Chairman; David Rosner,
Lindsay S. See, Judy W. Chang, and David LaCerte; North American
Electric Reliability Corporation; Order Approving Inverter-Based
Resources and Generators Modeling Reliability Standards
1. In Order No. 901, the Commission directed the North American
Electric Reliability Corporation (NERC), the Commission-certified
Electric Reliability Organization (ERO), to develop new or modified
Reliability Standards that address specific matters pertaining to the
impacts of inverter-based resources (IBR) on the reliable operation of
the Bulk-Power System.\1\ Due to the significant scope of the work, the
Commission required NERC to submit responsive Reliability Standards in
three tranches.\2\ On November 4, 2025, NERC submitted three petitions
seeking approval of five proposed Reliability Standards and related
definitions, representing the second tranche of Reliability Standards
directed by the Commission in Order No. 901.
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\1\ Reliability Standards to Address Inverter-Based Res., Order
No. 901, 185 FERC ] 61,042 (2023).
\2\ Id. P 7.
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2. Specifically, in the first petition (RD26-1-000), NERC seeks
approval of: (1) a proposed definition of the term distributed energy
resource (DER) for inclusion in the NERC Glossary of Terms Used in NERC
Reliability Standards (NERC Glossary); and (2) proposed Reliability
Standards MOD-032-2 (Data for Power System Modeling and Analysis), IRO-
010-6 (Reliability Coordinator Data and Information Specification and
Collection), and TOP-003-8 (Transmission Operator and Balancing
Authority Data and Information Specification and Collection).\3\ The
second petition (RD26-2-000) seeks approval of Reliability Standard
MOD-033-3 (Steady-State and Dynamic System Model Validation).\4\ The
third petition
[[Page 8865]]
(RD26-3-000) seeks approval of: (1) proposed definitions of model
validation and model verification in the NERC Glossary; and (2)
proposed Reliability Standard MOD-026-2 (Verification and Validation of
Dynamic Models and Data).\5\ NERC also seeks approval of the associated
implementation plans, violation risk factors, and violation severity
levels for Reliability Standards MOD-032-2, IRO-010-6, TOP-003-8, MOD-
033-3, and MOD-026-2. In addition, the first petition seeks the
retirement of currently effective Reliability Standards MOD-032-1, IRO-
010-5, and TOP-003-7; the second petition seeks retirement of currently
effective Reliability Standard MOD-033-2; and the third petition seeks
retirement of currently effective Reliability Standards MOD-026-1 and
MOD-027-1.
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\3\ NERC Petition, Docket No. RD26-1-000 (filed Nov. 4, 2025)
(NERC MOD-032-2, IRO-010-6, and TOP-003-8 Petition).
\4\ NERC Petition, Docket No. RD26-2-000 (filed Nov. 4, 2025)
(NERC MOD-033-3 Petition).
\5\ NERC Petition, Docket No. RD26-3-000 (filed Nov. 4, 2025)
(NERC MOD-026-2 Petition).
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3. For the reasons discussed below, pursuant to section 215(d)(2)
of the Federal Power Act (FPA),\6\ we grant the requested approvals.
Our action approving the three petitions and the associated Reliability
Standards should ensure that Bulk-Power System planners and operators
will have the data and models needed to plan for, operate, and reliably
integrate IBRs on the Bulk-Power System.
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\6\ 16 U.S.C. 824o(d)(2).
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I. Background
A. Section 215 and Mandatory Reliability Standards
4. Section 215 of the FPA provides that the Commission may certify
an ERO, the purpose of which is to establish and enforce Reliability
Standards, subject to Commission review and approval.\7\ Once approved,
the Reliability Standards may be enforced by the ERO, subject to
Commission oversight, or by the Commission independently.\8\ Pursuant
to section 215 of the FPA, the Commission established a process to
select and certify an ERO \9\ and subsequently certified NERC as the
ERO.\10\
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\7\ Id. Sec. 824o.
\8\ Id. Sec. 824o(e).
\9\ Rules Concerning Certification of the Elec. Reliability
Org.; & Procs. for the Establishment, Approval, and Enf't of Elec.
Reliability Standards, Order No. 672, 114 FERC ] 61,104, order on
reh'g, Order No. 672-A, 114 FERC ] 61,328 (2006).
\10\ N. Am. Elec. Reliability Corp., 116 FERC ] 61,062, order on
reh'g and compliance, 117 FERC ] 61,126 (2006), aff'd sub nom. Alcoa
Inc. v. FERC, 564 F.3d 1342 (D.C. Cir. 2009) (certifying NERC as the
ERO responsible for the development and enforcement of mandatory
Reliability Standards).
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B. Order No. 901
5. In Order No. 901, the Commission explained, among other things,
that the majority of installed IBRs use grid-following inverters, which
can track grid state parameters (e.g., voltage angle) in milliseconds
and react nearly instantaneously to changing grid conditions.\11\ The
Commission then explained that, as found by multiple NERC reports,\12\
some IBRs, as non-synchronous resources, ``are not configured or
programmed to support grid voltage and frequency in the event of a
system disturbance, and, as a result, will reduce power output, exhibit
momentary cessation, or trip in response to variations in system
voltage or frequency.'' \13\
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\11\ Order No. 901, 185 FERC ] 61,042 at P 12.
\12\ Id. P 26 n.53 (listing 12 NERC reports describing IBR
behavior during disturbances).
\13\ Id. P 12 (footnotes omitted).
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6. Therefore, the Commission directed NERC to develop new or
modified Reliability Standards pertaining to IBRs in four areas: (1)
data sharing; (2) model validation; (3) planning and operational
studies; and (4) performance requirements.\14\ The Commission required
NERC to submit, by November 4, 2025, new or modified Reliability
Standards in the first and second areas to, among other things, address
data sharing for registered IBRs,\15\ unregistered IBRs, and IBR-DERs
in the aggregate; \16\ and data and model validation for registered
IBRs, unregistered IBRs, and IBRs connected to the distribution system
that in the aggregate have a material impact on the Bulk-Power System
(IBR-DER).\17\ The first and second areas also contained directives
that can be broadly categorized as requiring the development of
Reliability Standards in the following areas: (1) modeling frameworks
for IBRs; (2) validation and verification of IBR models; and (3)
inclusion of IBRs in system-level models.
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\14\ E.g., id. PP 1, 5, 53.
\15\ Registered IBRs include generator owners and generator
operators. Under the NERC Glossary, category 1 generator owners are
entities that own and maintain generating bulk electric system (BES)
facilities; category 2 generator owners are entities that own and
maintain non-BES IBRs that either have or contribute to an aggregate
nameplate capacity of greater than or equal to 20 MVA, connected
through a system designed primarily for delivering such capacity to
a common point of connection at a voltage greater than or equal to
60 kV. Category 1 generator operators are entities that operate
generating BES facilities and perform the functions of supplying
energy and interconnected operations services; category 2 generator
owners are entities that operate non-BES IBRs that either have or
contribute to an aggregate nameplate capacity of greater than or
equal to 20 MVA, connected through a system designed primarily for
delivering such capacity to a common point of connection at a
voltage greater than or equal to 60 kV. NERC, Glossary of Terms Used
in NERC Reliability Standards (updated Oct. 1, 2025) (NERC
Glossary).
\16\ Order No. 901, however, is clear that unregistered IBRs and
IBR-DERs that do not have a material impact on the Bulk-Power System
``will not be subject to the mandatory and enforceable Reliability
Standards set forth herein.'' Order No. 901, 185 FERC ] 61,042 at P
4 n.14.
\17\ Id. P 229.
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1. Modeling Frameworks for IBRs
7. In Order No. 901, the Commission directed NERC to develop new or
modified Reliability Standards to support accurate modeling of IBRs,
including requirements for IBR-specific modeling data; the use of
industry generic library IBR models; the provision of dynamic models of
dynamic performance of IBRs; the use of DER_A model; \18\ and the
development of a uniform modeling framework of IBRs.
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\18\ The DER_A model is the approved steady state and dynamic
model that industry has validated and maintained to model IBR-DERs
in the aggregate and used to study the potential impacts of IBR-DERs
in the aggregate on the Bulk-Power System. Id. P 31 n.67.
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2. Validation and Verification of IBR Models
8. The Commission directed NERC to include in the new or modified
Reliability Standards provisions to require registered IBR generator
owners ``to install disturbance monitoring equipment at their buses and
elements . . . [and] to provide disturbance monitoring data to Bulk-
Power System planners and operators for analyzing disturbances on the
Bulk-Power System.'' \19\ Further, the Commission directed NERC to
include in the new or modified Reliability Standards technical criteria
that require Bulk-Power System planners and operators to validate
registered IBR models using disturbance monitoring data from the
installed registered IBR generator owners' disturbance monitoring
equipment.\20\
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\19\ Id. P 85.
\20\ Id.
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9. Additionally, the Commission directed NERC to develop new or
modified Reliability Standards that require the generator owners of
registered IBRs, transmission owners that have unregistered IBRs on
their system, and distribution providers that have IBR-DERs on their
system to provide models that represent the dynamic behavior of these
IBRs at a sufficient level of fidelity to Bulk-Power System planners
and operators to ``perform valid interconnection-wide, planning, and
operational studies on a basis comparable to synchronous generation
resources.'' \21\
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\21\ Id. P 140.
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[[Page 8866]]
10. Further, the Commission directed NERC to establish a standard
uniform modeling verification process. The Commission instructed that a
uniform modeling verification process will ensure that all entities use
the same set of minimum requirements to verify that both synchronous
and non-synchronous models are complete and that the models
``accurately represent the dynamic behavior of all generation resources
at a sufficient level of fidelity for Bulk-Power System planners and
operators to perform valid interconnection-wide, planning, and
operational studies.'' \22\ The Commission directed NERC to define the
model verification process and to require consistency among the model
verification processes for existing Reliability Standards and any new
or modified Reliability Standards.\23\
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\22\ Id. P 143.
\23\ Id.
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11. The Commission acknowledged that the new or modified
Reliability Standards pertaining to the standard uniform modeling
verification process would apply to a different, but overlapping, set
of entities than those required to comply with the requirements of
Order No. 2023.\24\ Consequently, the Commission directed NERC to
``include in the new or modified Reliability Standards a similar model
verification process timeline consistent with Order No. 2023 modeling
deadline requirements.'' \25\
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\24\ See Improvements to Generator Interconnection Procs. &
Agreements, Order No. 2023, 184 FERC ] 61,054, order on reh'g, 185
FERC ] 61,063 (2023), order on reh'g, Order No. 2023-A, 186 FERC ]
61,199, errata notice, 188 FERC ] 61,134 (2024).
\25\ Order No. 901, 185 FERC ] 61,042 at P 149.
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3. Inclusion of IBRs in System Models
12. The Commission directed NERC to submit new or modified
Reliability Standards that require Bulk-Power System planners and
operators to validate, coordinate, and update in a timely manner the
system models of registered IBRs, unregistered IBRs, and IBR-DERs that
in the aggregate have a material impact on the Bulk-Power System
against actual system operational behavior.\26\
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\26\ Id. P 156.
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13. Moreover, the Commission directed NERC ``to determine the
appropriate registered entity responsible for the data and parameters
of IBR-DERs in the aggregate and to establish a process that requires
identified registered entities to coordinate, validate, and keep up to
date the system models'' for those areas with IBR-DERs in the aggregate
that materially impact the reliable operation of the Bulk-Power System
but lack an associated registered distribution provider.\27\
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\27\ Id. P 157.
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14. The Commission also directed NERC to develop new or modified
Reliability Standards that require Bulk-Power System planners and
operators to establish for each interconnection: ``a uniform framework
with modeling criteria, a registered modeling designee, and necessary
data exchange requirements both between themselves and with the
generator owners, transmission owners, and distribution providers to
coordinate the creation of transmission planning, operations, and
interconnection-wide models (i.e., system models) and the validation of
each respective system model.'' \28\
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\28\ Id. P 161.
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II. NERC Petitions
A. MOD-032-2, IRO-010-6, and TOP-003-8 Petition
1. DER Definition
15. NERC proposes to define DER as: ``A generator or energy storage
technology connected to a distribution system that is capable of
providing Real Power in non-isolated parallel operation with the Bulk-
Power System, including one connected behind the meter of an end-use
customer that is supplied from a distribution system.'' \29\
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\29\ NERC MOD-032-2, IRO-010-6, and TOP-003-8 Petition at 29.
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2. Proposed Reliability Standard MOD-032-2
16. NERC states that the purpose of proposed Reliability Standard
MOD-032-2 is ``to establish consistent modeling data requirements and
reporting procedures for development of planning horizon cases
necessary to support analysis of the reliability of the interconnected
transmission system.'' \30\
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\30\ Id. at 27.
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17. The proposed Standard requires planning coordinators, working
jointly with their associated transmission planner(s), to develop
steady-state, dynamic, and short circuit modeling data requirements and
reporting procedures.\31\ Proposed Attachment 1 of the Standard
indicates the data that is required to effectively model the
interconnected transmission system for the near-term transmission
planning horizon and long-term transmission planning horizon.\32\ The
proposed Standard requires balancing authorities, distribution
providers, generator owners, resource planners, transmission owners,
and transmission service providers to provide IBR and IBR-DER data.\33\
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\31\ Id. at 31.
\32\ Id., Ex. A-1 (Proposed Reliability Standard MOD-032-2
Redline to Last Approved (MOD-032-1)) at 16.
\33\ NERC MOD-032-2, IRO-010-6, and TOP-003-8 Petition at 43-44.
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18. The proposed Standard requires the submission of ``standard
library models incorporated within the software(s) utilized to create
the interconnection-wide case(s); user-defined models; or both standard
library models and user-defined models'' \34\ and requires each
planning coordinator and transmission planner that accepts user-defined
models to provide the user-defined model requirements to other planning
coordinators and transmission planners within the interconnection when
requested.\35\
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\34\ Id. at 32.
\35\ Id.
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3. Proposed Reliability Standards IRO-010-6 and TOP-003-8
19. NERC states that the purpose of proposed Reliability Standard
IRO-010-6 is ``to prevent instability, uncontrolled separation, or
[c]ascading outages that adversely impact reliability, by ensuring each
[r]eliability [c]oordinator has the data and information it needs to
plan, monitor and assess the operation of its [r]eliability
[c]oordinator [a]rea.'' \36\ NERC states that the purpose of proposed
Reliability Standard TOP-003-8 is ``to ensure that each [t]ransmission
[o]perator and [b]alancing [a]uthority has the data and information it
needs to plan, monitor, and assess the operation of its [t]ransmission
[o]perator [a]rea or [b]alancing [a]uthority [a]rea.'' \37\
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\36\ Id. at 59-60.
\37\ Id. at 60.
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20. NERC proposes minor modifications to proposed Reliability
Standards IRO-010-6 and TOP-003-8 to add ``Inverter-based Resource
(IBR)-specific data and parameters'' to the list of information
reliability coordinators, transmission operators, and balancing
authorities must address in their documented data specifications.\38\
Additionally, both proposed Reliability Standards include a new
proposed Requirement that specifies that requirements for model
submission for reliability coordinators, transmission operators, and
balancing authorities are to be consistent with ``the model submitted
for planning purposes, subject to modifications for operations
purposes, as applicable.'' \39\
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\38\ Id. at 60-61.
\39\ Id. at 62.
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[[Page 8867]]
B. MOD-033-3 Petition
21. NERC states that the purpose of proposed Reliability Standard
MOD-033-3 is ``to establish a process for system model validation to
facilitate achieving and maintaining model accuracy.'' \40\
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\40\ NERC MOD-033-3 Petition at 23.
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22. The proposed Standard requires each planning coordinator to
develop and implement a model validation process for the planning
system models developed in accordance with Reliability Standard MOD-
032, representing its portion of the existing system.\41\ The model
validation process includes the comparison of power flow simulation
performance of the steady-state planning system model to actual system
behavior at least once every 24 calendar months. The model validation
process also includes the comparison of dynamic local event simulation
performance of the dynamic planning system model to actual system
behavior at least once every 24 calendar months under proposed
Requirement R1.2.\42\ Further, the proposed Standard requires each
reliability coordinator and transmission operator to provide actual
system behavior data to any planning coordinator performing model
validation under Requirement R1.\43\
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\41\ Id. at 24.
\42\ Id.
\43\ Id. at 27.
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23. NERC claims that proposed Reliability Standard MOD-033-3 is
responsive to the Commission's directive in Order No. 901 to validate
models of registered IBRs, unregistered IBRs, and IBR-DERs that in the
aggregate have a material impact on the Bulk-Power System by comparing
resulting system models against system operational behavior
establishing a process to require identified registered entities to
coordinate, validate, and keep up to date system models. NERC further
claims that proposed Reliability Standard MOD-033-3 is responsive to
the directive that the new or modified Reliability Standards require
Bulk-Power System planners and operators to validate registered IBR
models using disturbance monitoring data from the installed registered
IBR generator owners' disturbance monitoring equipment.\44\
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\44\ Id. at 29-31.
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C. MOD-026-2 Petition
1. Proposed Definitions of Model Verification and Model Validation
24. In response to the directive in Order No. 901 to develop new or
modified Reliability Standards related to model validation for IBRs,
NERC proposes to define model validation as ``[t]he process of
comparing simulation results with measurements to assess how closely a
model's behavior matches the measured behavior,'' and to define model
verification as ``[t]he process of confirming that model structure and
parameter values are representative of the equipment or facility design
and settings by reviewing equipment or facility design and settings
documentation.'' \45\
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\45\ NERC MOD-026-2 Petition at 25.
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2. Proposed Reliability Standard MOD-026-2
25. NERC states that the purpose of proposed Reliability Standard
MOD-026-2 is ``to verify and validate that the dynamic models and
associated parameters used to assess Bulk Electric System (BES)
reliability represent the in-service equipment of Bulk Power System . .
. facilities including generating facilities, transmission connected
dynamic reactive resources, and high-voltage direct current (HVDC)
systems.'' \46\ Reliability Standard MOD-026-2 consolidates the
currently effective Reliability Standards MOD-026-1 and MOD-027-1.\47\
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\46\ Id. at 26.
\47\ Id. at 23.
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26. The proposed Standard requires each generator owner or
transmission owner to provide its transmission planner ``positive
sequence dynamic model(s) with associated parameters, any information
pertaining to changes to the model(s) or its parameters, and
accompanying documentation in accordance with the periodicity
requirements of Attachment 2.'' \48\ Requirement R3 of the proposed
Standard requires each generator owner or transmission owner to provide
EMT models for flexible alternating current transmission system (FACTS)
devices, HVDC systems, and registered IBRs to its transmission planner.
Legacy facilities are excluded from this requirement where the original
equipment manufacturer no longer supports EMT model(s) for the facility
as well as legacy facilities not identified by the transmission
planner.\49\ NERC argues that the positive sequence model and EMT model
provisions in proposed Reliability Standard MOD-026-2 are responsive to
a series of directives in Order No. 901.\50\
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\48\ Id. at 32; Ex. A-1 (Proposed Reliability Standard MOD-026-
2--Clean) at 5.
\49\ NERC MOD-026-2 Petition at 36. A legacy facility is defined
as ``any facility with a commercial operation date prior to the
effective date of MOD-026-2.'' Id. at 29.
\50\ Id. at 44 (citing Order No. 901, 185 FERC ] 61,042 at PP
85, 126, 140-141, 143, 149, 161).
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III. Notice of Filing and Responsive Pleadings
27. Notice of NERC's November 4, 2025, filings was published in the
Federal Register, 90 FR 53320 (Nov. 25, 2026), with comments and
interventions due on or before December 8, 2025. Calpine Corporation
filed motions to intervene in Docket Nos. RD26-1-000, RD26-2-000, and
RD26-3-000. The Electric Reliability Council of Texas, Inc., ISO New
England Inc., Midcontinent Independent System Operator Inc., New York
System Operator Inc., PJM Interconnection, L.L.C., and Southwest Power
Pool, Inc. (collectively, the ISO) submitted comments in Docket No.
RD26-3-000. On December 19, 2025, NERC submitted reply comments to the
ISOs' comments.
28. The ISOs support proposed Reliability Standard MOD-026-2
because it advances the reliability of the Bulk-Power System in
improving the accuracy and dependability of models used in planning and
interconnection analyses through model verification and validation
requirements.\51\ However, the ISOs disagree with the provision that
excludes generator owners or transmission owners of legacy facilities
with no original equipment manufacturer support for EMT models from the
requirement to provide EMT models to their transmission planners.\52\
The ISOs express concern that the definition of legacy facilities
include both IBRs that are already in-service and those that are
currently going through the interconnection process.\53\ The ISOs
maintain that the exclusion ``inappropriately shifts the burden'' of
obtaining EMT models for legacy facilities from generator owners and
transmission owners to transmission planners, which lack the knowledge
and access to the facilities.\54\ The ISOs claim that without EMT
models from the owners of legacy facilities, transmission planners
would be unable to accurately assess the reliability of their systems
due to the inadequacy of the ISOs' purely positive sequencing modeling
when analyzing systems with significant levels of IBRs and IBR-
DERs.\55\ Further, the ISOs assert that the exclusion eliminates
incentives for original equipment manufacturers to maintain EMT models
for the life of a legacy
[[Page 8868]]
facility and reduces the ability of owners of legacy facilities to
require the continued maintenance of EMT models for the facility's
life.\56\ The ISOs request that the Commission direct NERC to revise
proposed Requirement R3 to remove the legacy facility exclusion
language.
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\51\ ISOs Comments at 1.
\52\ Id. at 4.
\53\ Id.
\54\ Id. at 5.
\55\ Id.
\56\ Id. at 7.
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29. In its reply comments, NERC states that the standard drafting
team recognized the practical limitations associated with requiring EMT
models for legacy facilities where the original equipment manufacturer
no longer supports EMT models for those facilities and so adopted a
limited and narrowly tailored exclusion for such facilities. NERC notes
that the standard drafting team concluded that requiring owners of
legacy facilities to develop their own EMT models would be burdensome
and costly as they have to rely on extensive testing to approximate EMT
behavior of the facilities. Further, the drafting team determined that
mandating legacy facilities to develop their own models would pose a
risk to reliability as it would require intentionally stressing the
facilities to determine how and when large signal disturbances might
occur. Moreover, NERC states that the drafting team considered that
alternatives to costly and burdensome testing are available; for
example, transmission planners and planning coordinators could rely on
generic EMT models with parameters from similarly situated facilities
for legacy facilities that lack original equipment manufacturer
support.\57\ Lastly, NERC disagrees with the ISOs' assertion that the
exclusion eliminates the incentives for original equipment
manufacturers to require the continued maintenance of EMT models for
the life of the facility because the exclusion is limited to where
original equipment manufacturer support is no longer available and NERC
anticipates that the number of facilities eligible for exclusion will
shrink as new resources are developed for which EMT models will be
available.\58\
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\57\ NERC Reply Comments at 4-5.
\58\ Id. at 5-6.
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IV. Determination
A. Procedural Matters
30. Pursuant to Rule 214 of the Commission's Rules of Practice and
Procedure, 18 CFR 385.214 (2025), the timely, unopposed motion to
intervene serves to make Calpine a party to this proceeding.
31. Rule 213(a)(2) of the Commission's Rules of Practice and
Procedure, 18 CFR 385.213(a)(2) (2025), prohibits an answer to a
protest unless otherwise ordered by the decisional authority. We accept
NERC's reply comment filed in this proceeding because it provides
information that assisted us in our decision-making process.
B. Substantive Matters
1. MOD-032-2, IRO-010-06, and TOP-003-8 Petition
32. Pursuant to section 215(d)(2) of the FPA, we approve the
proposed DER definition for inclusion in the NERC Glossary, as well as
proposed Reliability Standards MOD-032-2, IRO-010-6 and TOP-003-8, as
just, reasonable, not unduly discriminatory or preferential, and in the
public interest. We find that the proposed DER definition is sufficient
for defining requirements in Reliability Standards, excluding load
resources (e.g., energy efficiency and demand response) that are
typically reflected in base case load level assumptions, capturing both
synchronous resources and IBRs, and conveying that a DER is a resource
that is connected to the distribution system and not the Bulk-Power
System. We further find that proposed Reliability Standards MOD-032-2,
IRO-010-06, and TOP-003-8 are responsive to the relevant directives in
Order No. 901 and improve upon the existing standards by supporting
accurate modeling of IBRs, which will advance the reliability of the
Bulk-Power System.
33. We also approve the proposed Reliability Standards' associated
violation risk factors and violation severity levels, as well as the
implementation plans. Finally, we approve the retirement of Reliability
Standards MOD-032-1, IRO-010-5, and TOP-003-7 immediately prior to the
effective date of proposed Reliability Standards MOD-032-2, IRO-010-6,
and TOP-003-8, respectively.
2. MOD-033-3 Petition
34. Pursuant to section 215(d)(2) of the FPA, we approve proposed
Reliability Standard MOD-033-3, as just, reasonable, not unduly
discriminatory or preferential, and in the public interest. We
determine that proposed Reliability Standard MOD-033-3 is responsive to
relevant directives in Order No. 901 and improves upon the existing
standard by requiring the inclusion of IBRs in system-wide models,
which will help system planners and operators ensure the reliability of
the Bulk-Power System.
35. We also approve the proposed Reliability Standard's associated
violation risk factors and violation severity levels, as well as the
proposed implementation plan. Finally, we approve the retirement of
Reliability Standard MOD-033-2 immediately prior to the effective date
of proposed Reliability Standard MOD-033-3.
3. MOD-026-2 Petition
36. Pursuant to section 215(d)(2) of the FPA, we approve the
proposed model verification and model validation definitions for
inclusion in the NERC Glossary, as well as proposed Reliability
Standard MOD-026-2, as just, reasonable, not unduly discriminatory or
preferential, and in the public interest. We find that the proposed
model validation and model verification definitions establish a
consistent understanding of the meaning of the defined terms across all
Reliability Standards going forward and establish clear expectations
for model verification and model validation. We further determine that
proposed Reliability Standard MOD-026-2 is responsive to the relevant
directives in Order No. 901 and improves upon existing Reliability
Standards MOD-026-1 and MOD-027-1 by establishing a process for the
model validation and model verification of IBRs, which will advance the
reliability of the Bulk-Power System.
37. We decline the ISOs' request to direct NERC to remove the
legacy facility exclusion language from proposed Requirement R3 of
proposed Reliability Standard MOD-026-2. As NERC observes, developing a
non-generic EMT model for equipment that is no longer supported by the
original equipment manufacturer will pose a significant financial,
technical, and time burden on the owners of legacy facilities to
develop their own EMT models through stress testing that could pose a
risk to the reliability of the Bulk-Power System.\59\ Giving due weight
to NERC as the ERO, we are not persuaded that the ISOs have stated a
significant reliability risk that merits removing the exclusion.
Additionally, we are persuaded by NERC that the impact of the exclusion
will be limited: all facilities (including legacy facilities) that have
original equipment manufacturer support will be required to provide EMT
models when needed.\60\ Further, owners of legacy facilities who claim
that the facilities have no original equipment manufacturer support
will have to substantiate that claim through
---------------------------------------------------------------------------
\59\ Id. at 4-5.
\60\ Id. at 5-6.
---------------------------------------------------------------------------
[[Page 8869]]
documentation.\61\ We also note that, while such legacy facilities
verified to have no original equipment manufacturer support will be
excluded from Requirement R3, such facilities may still use generic EMT
modeling and, as NERC describes, alternatives approximating EMT
modeling exist, too. Consequently, we find that it is reasonable to
allow legacy facilities where the original equipment manufacturer no
longer supports EMT model(s) for the facility to be excluded from
Requirement R3 and decline to direct NERC to remove the language.
---------------------------------------------------------------------------
\61\ See NERC MOD-026-2 Petition at 36, Ex. F (Analysis of
Violation Risk Factors and Violation Severity Levels) at 12 (listing
the failure to provide accompanying documentation for EMT models--
i.e., documentation of the original equipment manufacturer no longer
supporting EMT models--as a violation of Requirement R3).
---------------------------------------------------------------------------
38. We find that the proposed Standard is consistent with the
Commission's directive in Order No. 901 to ensure that the model
verification process timeline is consistent with Order No. 2023
modeling deadline requirements. We clarify that nothing in Reliability
Standard MOD-026-2 relieves an interconnection customer requesting to
interconnect a non-synchronous generating facility of its obligation
under a transmission provider's tariff to provide a validated EMT model
to a transmission provider (including a regional transmission
organization/independent system operator) if the transmission provider
performs an EMT study as part of the interconnection study process.\62\
We also approve the proposed Reliability Standard's associated
violation risk factors and violation severity levels, as well as the
proposed implementation plans. Finally, we approve the retirement of
Reliability Standards MOD-026-1 and MOD-027-1 immediately prior to the
effective date of proposed Reliability Standard MOD-026-2.
---------------------------------------------------------------------------
\62\ Order No. 2023, 184 FERC ] 61,054 at P 1659; see pro forma
Large Generator Interconnection Procedures, app. 1, attach. A; see
also pro forma Small Generator Interconnection Procedures, attach.
2.
---------------------------------------------------------------------------
V. Information Collection Statement
39. The FERC-725A, FERC-725L, and FERC-725Z information collections
requirements are subject to review by the Office of Management and
Budget (OMB) under section 3507(d) of the Paperwork Reduction Act of
1995. OMB's regulations require approval of certain information
collection requirements imposed by agency rules. Upon approval of a
collection of information, OMB will assign an OMB control number and
expiration date. Respondents subject to the filing requirements will
not be penalized for failing to respond to these collections of
information unless the collections of information display a valid OMB
control number. The Commission solicits comments on the need for this
information, whether the information will have practical utility, the
accuracy of the burden estimates, ways to enhance the quality, utility,
and clarity of the information to be collected or retained, and any
suggested methods for minimizing respondents' burden, including the use
of automated information techniques.
40. The Commission bases its paperwork burden estimates on the
additional paperwork burden for balancing authorities, generator
owners, planning coordinators, reliability coordinators, transmission
planners, transmission owners, and transmission operators presented by
Reliability Standards MOD-032-2, IRO-010-6, TOP-003-8, MOD-033-3, and
MOD-026-2, as modified, and the NERC Glossary definitions of DER, model
validation, and model verification. Reliability Standards are
objective-based and allow entities to choose compliance approaches best
tailored to their systems. The new or modified NERC Glossary
definitions are not expected to produce any new burden. The number of
respondents that are subject to mandatory compliance with Reliability
Standards MOD-032-2, IRO-010-6, TOP-003-8, MOD-033-3, and MOD-026-2, in
the tables below, are based on the NERC Compliance Registry as of
December 3, 2025, and good faith estimates provided by NERC to
Commission staff, in August 2025. NERC estimates that there are 491
category 2 generator owners and 310 category 2 generator operators,
which will be added to the respective category 1 generator owners and
generator operators in the NERC Compliance Registry to reach an
estimate of the total number of generator owners and generator
operators.
Based on these assumptions, we estimate the following reporting
burden:
---------------------------------------------------------------------------
\63\ The ``Number of Entity'' data is compiled from the December
3, 2025, edition of the NERC Compliance Registry. ``BA'' means
balancing authority; ``DP'' means distribution provider; ``GO''
means generator owner; ``PC'' means planning coordinator; ``RP''
means resource planner; ``TO'' means transmission owner; ``TP''
means transmission planner; ``TSP'' means transmission service
provider; ``GOP'' means generator operator; ``RC'' means reliability
coordinator; and ``TOP'' means transmission operator.''
\64\ The estimated hourly cost (salary plus benefits) is a
combination of the following categories from the BLS website, http://www.bls.gov/oes/current/naics2_22.htm: 75% of the average of an
Electrical Engineer (17-2071) $71.19/hr., x .75 = 53.3925 ($53.39-
rounded) ($53.39/hour); and 25% of an Information and Record Clerk
(43-4199) $40.51/hr., $40.51 x .25 = 10.1275 ($10.13 rounded)
($10.13/hour), for a total ($53.39 + $10.13 = $63.52/hour).
\65\ For this collection the GO will include category 1 entities
(1,343 entities) from the December 3, 2025, NERC Compliance
Registry; and NERC's estimate to Commission staff in August 2025 of
category 2 generator owners registered entities in the United States
(491 entities) for a total of (1,343 + 491) = 1,834. The estimate
for category 2 generator owner entities is subject to change
according to NERC due to: (1) facility cancellations or facilities
with an expected commercial operation date delayed past May 15,
2026; (2) identification of type 1 and type 2 wind facilities that
do not qualify as category 2 resources; (3) identification of
facilities as category 1 resources; and (4) facilities can be
inaccurately reported and subsequently removed from the list. NERC,
Inverter-Based Resources Work Plan Progress Update, Docket No. RD22-
4-001, at 2 n.7 (filed Oct. 31, 2025) (NERC October 2025 Work Plan
Update).
Proposed Changes in Burden MOD-032-2 Docket No. RD26-1
--------------------------------------------------------------------------------------------------------------------------------------------------------
Number of
Type and number of entity annual Total number of Average number of burden
Reliability standard \63\ responses responses hours per response \64\ Total burden hours
per entity
(1)........................ (2) (1) * (2) = (3) (4)...................... (3) * (4) = (5)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Annual Collection MOD-032-2 FERC-725 L
--------------------------------------------------------------------------------------------------------------------------------------------------------
Annual review and record 97 (BA).................... 1 97 8 hrs. $ 508.16/hr....... 776 hrs. $49,291.52.
retention.
299 (DP)................... 1 299 8 hrs. $508.16/hr........ 2,392 hrs. $151,939.84.
1,834 (GO) \65\............ 1 1,834 8 hrs. $508.16/hr........ 14,672 hrs. $931,965.44.
62 (PC).................... 1 62 16 hrs. $1016.32/hr...... 992 hrs. $63,011.84.
157 (RP)................... 1 157 8 hrs. $508.16/hr........ 1,256 hrs. $79,781.12.
341 (TO)................... 1 341 8 hrs. $508.16/hr........ 2,728 hrs. $173,282.56.
208 (TP)................... 1 208 16 hrs. $1016.32/hr...... 3,328 hrs. $211,394.56.
[[Page 8870]]
70 (TSP)................... 1 70 8 hrs. $508.16/hr........ 560 hrs. $35,571.20.
---------------------------------------------------------------------------------------------
Total for MOD-032-2...... ........................... ........... 3,068 ......................... 26,704 hrs. $1,696,238.08.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Proposed Changes in Burden IRO-010-6 Docket No. RD26-1
--------------------------------------------------------------------------------------------------------------------------------------------------------
Number of
Type and number of entity annual Total number of Average number of burden
Reliability standard \66\ responses responses hours per response \67\ Total burden hours
per entity
(1)........................ (2) (1) * (2) = (3) (4)...................... (3) * (4) = (5)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Annual Collection IRO-010-6 FERC-725 Z
--------------------------------------------------------------------------------------------------------------------------------------------------------
Annual review and record 12 (RC).................... 1 12 8 hrs. $508.16/hr........ 96 hrs. $6,097.92.
retention.
97 (BA).................... 1 97 8 hrs. $508.16/hr........ 776 hrs. $49,291.52.
1,834 (GO)................. 1 1,834 8 hrs. $508.16/hr........ 14,672 hrs. $931,965.44.
1,333 (GOP) \68\........... 1 1,333 8 hrs. $508.16/hr........ 10,664 hrs. $677,377.28.
170 (TOP).................. 1 170 8 hrs. $508.16/hr........ 1,360 hrs. $86,387.20.
341 (TO)................... 1 341 8 hrs. $508.16/hr........ 2,728 hrs. $173,282.56.
299 (DP)................... 1 299 8 hrs. $508.16/hr........ 2,392 hrs. $151,939.84.
---------------------------------------------------------------------------------------------
Total for IRO-010-6...... ........................... ........... 4,086 ......................... 32,688 hrs. $2,076,341.76.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Proposed Changes in Burden TOP-003-8 Docket No. RD26-1
--------------------------------------------------------------------------------------------------------------------------------------------------------
Number of
Type and number of entity annual Total number of Average number of burden
Reliability standard \69\ responses responses hours per response \70\ Total burden hours
per entity
(1)........................ (2) (1) * (2) = (3) (4)...................... (3) * (4) = (5)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Annual Collection TOP-003-8 FERC-725 A
--------------------------------------------------------------------------------------------------------------------------------------------------------
Annual review and record 170 (TOP).................. 1 170 8 hrs. $508.16/hr........ 1,360 hrs. $86,387.20.
retention.
97 (BA).................... 1 97 8 hrs. $508.16/hr........ 776 hrs. $49,291.52.
1,834 (GO)................. 1 1,834 8 hrs. $508.16/hr........ 14,672 hrs. $931,965.44.
1,333 (GOP)................ 1 1,333 8 hrs. $565.36/hr........ 10,664 hrs. $677,377.28.
341 (TO)................... 1 341 8 hrs. $508.16/hr........ 2,728 hrs. $173,282.56.
299 (DP)................... 1 299 8 hrs. $508.16/hr........ 2,392 hrs. $151,939.84.
---------------------------------------------------------------------------------------------
Total for TOP-003-8...... ........................... ........... 4,074 ......................... 32,592 hrs. $2,070,243.84.
--------------------------------------------------------------------------------------------------------------------------------------------------------
---------------------------------------------------------------------------
\66\ The ``Number of Entity'' data is compiled from the December
3, 2025, edition of the NERC Compliance Registry.
\67\ The estimated hourly cost (salary plus benefits) is a
combination of the following categories from the BLS website, http://www.bls.gov/oes/current/naics2_22.htm: 75% of the average of an
Electrical Engineer (17-2071) $71.19/hr., x .75 = 53.3925 ($53.39-
rounded) ($53.39/hour); and 25% of an Information and Record Clerk
(43-4199) $40.51/hr., $40.51 x .25 = 10.1275 ($10.13 rounded)
($10.13/hour), for a total ($53.39 + $10.13 = $63.52/hour).
\68\ For this collection the generator operators (GOP) will
include category 1 entities (1,023 entities) from the December 3,
2025, NERC Compliance Registry; and NERC's estimate to Commission
staff in August 2025 of category 2 generator operators registered
entities in the United States (310 entities) for a total of (1,023 +
310) = 1,333. The estimate for category 2 generator operator
entities is subject to change according to NERC due to: (1) facility
cancellations or facilities with an expected commercial operation
date delayed past May 15, 2026; (2) identification of type 1 and
type 2 wind facilities that do not qualify as category 2 resources;
(3) identification of facilities as category 1 resources; and (4)
facilities can be inaccurately reported and subsequently removed
from the list. NERC October 2025 Work Plan Update at 2 n.7.
\69\ The ``Number of Entity'' data is compiled from the December
3, 2025, edition of the NERC Compliance Registry.
\70\ The estimated hourly cost (salary plus benefits) is a
combination of the following categories from the BLS website, http://www.bls.gov/oes/current/naics2_22.htm: 75% of the average of an
Electrical Engineer (17-2071) $71.19/hr., x .75 = 53.3925 ($53.39-
rounded) ($53.39/hour); and 25% of an Information and Record Clerk
(43-199) $40.51/hr., $40.51 x .25 = 10.1275 ($10.13 rounded)
($10.13/hour), for a total ($53.39 + $10.13 = $63.52/hour).
[[Page 8871]]
Proposed Burden MOD-033-3 Docket No. RD26-2
--------------------------------------------------------------------------------------------------------------------------------------------------------
Number of
Type and number of entity annual Total number of Average number of burden
Reliability standard \71\ responses responses hours per response \72\ Total burden hours
per entity
(1)........................ (2) (1) * (2) = (3) (4)...................... (3) * (4) = (5)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Annual Collection MOD-033-3 FERC-725 L
--------------------------------------------------------------------------------------------------------------------------------------------------------
Annual review and record 62 (PC).................... 1 62 8 hrs. $508.16 hr........ 496 hrs. $31,505.92.
retention.
12 (RC).................... 1 12 8 hrs. $508.16/hr........ 96 hrs. $6,097.92.
170 (TOP).................. 1 170 8 hrs. $508.16/hr........ 1,360 hrs. $86,387.20.
---------------------------------------------------------------------------------------------
Total for MOD-033-3...... ........................... ........... 244 ......................... 1,952 hrs. $123,991.04.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Proposed Changes in Burden MOD-26-2 Docket No. RD26-3
--------------------------------------------------------------------------------------------------------------------------------------------------------
Number of
Type and number of entity annual Total number of Average number of burden
Reliability standard \73\ responses responses hours per response \74\ Total burden hours
per entity
(1)........................ (2) (1) * (2) = (3) (4)...................... (3) * (4) = (5)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Annual Collection MOD-026-2 FERC-725 L
--------------------------------------------------------------------------------------------------------------------------------------------------------
Annual review and record 1,834 (GO)................. 1 1834 12 hrs. $762.24/hr....... 22,008 hrs. $1,397,948.16.
retention.
62 (PC).................... 1 62 8 hrs. $508.16/hr........ 496 hrs. $31,505.92.
341 (TO)................... 1 341 8 hrs. $508.16/hr........ 2,728 hrs. $173,282.56.
208 (TP)................... 1 208 10 hrs. $635.20/hr....... 2,080 hrs. $132,121.60.
---------------------------------------------------------------------------------------------
Total for MOD-026-2...... ........................... ........... 2,445 ......................... 27,312 hrs. $1,734,858.24.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Titles: Mandatory Reliability Standards within Interconnection
Reliability Operations and Coordination (IRO); Reliability Coordinator
Data and information Specification and Collection (IRO-010-6) (RD26-1-
000), Bulk-Power System Transmission Operations (TOP); Transmission
Operator and Balancing Authority Data and Information Specification and
Collection (TOP-003-8) (RD26-1-000), Modeling, Data, and Analysis
(MOD); Data for Power System Modeling and Analysis (MOD-032-2) (RD26-1-
000), Steady-State and Dynamic System Model Validation (MOD-033-3)
(RD26-2-000),Verification and Validation of Dynamic Models and Data
(MOD-026-2) (RD26-3-000).
---------------------------------------------------------------------------
\71\ The ``Number of Entity'' data is compiled from the December
3, 2025, edition of the NERC Compliance Registry.
\72\ The estimated hourly cost (salary plus benefits) is a
combination of the following categories from the BLS website, http://www.bls.gov/oes/current/naics2_22.htm: 75% of the average of an
Electrical Engineer (17-2071) $71.19/hr., x .75 = 53.3925 ($53.39-
rounded) ($53.39/hour); and 25% of an Information and Record Clerk
(43-4199) $40.51/hr., $40.51 x .25 = 10.1275 ($10.13 rounded)
($10.13/hour), for a total ($53.39 + $10.13 = $63.52/hour).
\73\ The ``Number of Entity'' data is compiled from the December
3, 2025, edition of the NERC Compliance Registry.
\74\ The estimated hourly cost (salary plus benefits) is a
combination of the following categories from the BLS website, http://www.bls.gov/oes/current/naics2_22.htm: 75% of the average of an
Electrical Engineer (17-2071) $71.19/hr., x .75 = 53.3925 ($53.39-
rounded) ($53.39/hour); and 25% of an Information and Record Clerk
(43-4199) $40.51/hr., $40.51 x .25 = 10.1275 ($10.13 rounded)
($10.13/hour), for a total ($53.39 + $10.13 = $63.52/hour).
---------------------------------------------------------------------------
Action: Revisions to Existing Collections of Information in FERC-
725A (TOP-003-8), FERC-725L (MOD-026-2, MOD-032-2, MOD-033-3), FERC-
725Z (IRO-010-6).
OMB Control Nos: Bulk-Power System Transmission Operations (TOP)
FERC-725A (1902-0244), Modeling, Data, and Analysis (MOD) FERC-725L
(1902-0261), and Interconnection Reliability Operations and
Coordination (IRO) FERC-725Z (1902-0276).
Respondents: Business or other for profit institutions, and not for
profit institutions.
Frequency of Responses: On occasion.
Necessity of the Information: This order approves the requested
modifications to Reliability Standards related to IBR-specific modeling
data and analysis; interconnection reliability operations and
coordination; and transmission operations. The order also approves the
proposed definitions in the NERC Glossary of distributed energy
resources, model validation, and verification. As discussed above, the
Commission approves proposed Reliability Standards MOD-032-2, IRO-010-
6, TOP-003-8, MOD-033-3, and MOD-026-2 and the proposed definitions,
pursuant to section 215(d)(2), because they establish data and model
requirements that ensure that Bulk-Power System planners and operators
will have the data and models needed to plan for, operate, and reliably
integrate IBRs on the Bulk-Power System.
Internal review: The Commission has reviewed the proposed
Reliability Standards and made a determination that its action is
necessary to implement section 215 of the FPA. The Commission has
assured itself, by means of its internal review, that there is
specific, objective support for the burden estimates associated with
the information requirements.
41. Interested persons may obtain information on the reporting
requirements by contacting the Federal Energy Regulatory Commission,
Office of the Executive Director, 888 First Street, NE, Washington, DC
20426 [Attention: Kayla Williams, email: [email protected], phone:
(202) 502-6468].
42. Comments concerning the information collections and
requirements approved for retirement in this order and the associated
burden estimates, should be sent to the Commission (identified by
Docket Nos. RD26-1-000, RD26-2-000, and RD26-3-000 as appropriate),
using the following methods. Electronic filing through https://www.ferc.gov is preferred. Electronic Filing should be filed in
acceptable native applications and print-to-PDF, but not in scanned or
picture format. For those unable to file electronically, comments may
be filed by U.S. Postal Service mail or by hand
[[Page 8872]]
(including courier) delivery: Mail via U.S. Postal Service Only:
Addressed to: Federal Energy Regulatory Commission, Secretary of the
Commission, 888 First Street NE, Washington, DC 20426. Hand (including
courier) delivery: Deliver to: Federal Energy Regulatory Commission,
12225 Wilkins Avenue, Rockville, MD 20852.
VI. Document Availability
43. In addition to publishing the full text of this document in the
Federal Register, the Commission provides all interested persons an
opportunity to view and/or print the contents of this document via the
internet through the Commission's Home Page (http://www.ferc.gov).
44. From the Commission's Home Page on the internet, this
information is available on eLibrary. The full text of this document is
available on eLibrary in PDF and Microsoft Word format for viewing,
printing, and/or downloading. To access this document in eLibrary, type
the docket number excluding the last three digits of this document in
the docket number field.
45. User assistance is available for eLibrary and the Commission's
website during normal business hours from the Commission's Online
Support at (202) 502-6652 (toll free at 1-866-208-3676) or email at
[email protected], or the Public Reference Room at (202) 502-
8371, TTY (202) 502-8659. Email the Public Reference Room at
[email protected].
The Commission orders:
(A) Proposed Reliability Standards MOD-032-2, IRO-010-6, and TOP-
003-8, their associated implementation plan, violation risk factors,
and violation severity levels, the defined term distributed energy
resource, and the proposed retirements of Reliability Standard MOD-032-
1, IRO-010-5, and TOP-003-7 immediately prior to the effective date of
the successor reliability standards are hereby approved, as discussed
in the body of this order.
(B) Proposed Reliability Standard MOD-033-3, its associated
implementation plan, violation risk factors, and violation severity
levels and the proposed retirement of Reliability Standard MOD-033-2
immediately prior to the effective date of proposed Reliability
Standard MOD-033-3 are hereby approved, as discussed in the body of
this order.
(C) Proposed Reliability Standard MOD-026-2, its associated
implementation plan, violation risk factors, and violation severity
levels, the defined terms model validation and model verification, and
the proposed retirements of Reliability Standards MOD-026-1 and MOD-
027-1 immediately prior to the effective date of proposed Reliability
Standard MOD-026-2 are hereby approved, as discussed in the body of
this order.
By the Commission.
Issued: February 19, 2026.
Debbie-Anne A. Reese,
Secretary.
[FR Doc. 2026-03659 Filed 2-23-26; 8:45 am]
BILLING CODE 6717-01-P