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NERC CIP Version 4 Generation Facilities and Units

The following changes to NERC CIP Version 4 as it applies to generation facilities and units are listed below followed by a brief description of each:

1.1. Each group of generating units (including nuclear generation) at a single plant location with an aggregate highest rated net Real Power capability of the preceding 12 months equal to or exceeding 1500 MW in a single Interconnection.

Generating units (including nuclear generation) that produce more than 1500 MW are now in the scope of NERC CIP. This has been called the bright line criteria and essentially provides little room o state that a plant that has an output capacity of anything greater than 1500 MW.

1.2. Reactive resources or group of resources that have an aggregate net reactive power nameplate rating of 1000 MVAR or greater.

Since MVAR refers to reactive power, the standard is essentially stating that any resource (excluding generation facilities, they are covered in 1.1 and other sections) that are used in a reactive power model of 1000 MVAR or greater are in scope. So if you have the ability to respond to a power shortage greater than 1000 MVAR, the resource or pool of resources with this capability are now Critical Assets.

1.3. Generation facilities the Planning Coordinator or Transmission Planner designates and informs the Generator Owner or Generator Operator, that they are necessary to avoid BES Adverse Reliability Impacts in the long-term planning horizon.

This statement effectively addresses the fact that planners (including transmission planners) have designated some generation facilities as critical to the stability of the bulk electric system. If these facilities were not available, according to planning’s perspective, a disruption to the BES could result. As a result addition generation facilities should be included as Critical Assets, even if they produce power at less than what is identified in the bright line criteria. Auditors will potentially be able to leverage transmission planning information to ensure that Critical Assets have been properly identified in this regard.