Project 2021-01 System Model Validation with IBRs

Status
The formal comment period for draft one of MOD-033-3 Steady-State and Dynamic System Model Validation concluded 8 p.m. Eastern, Wednesday, May 21, 2025. The comments received and ballot results can be accessed via the links below.

The drafting team will review all responses received during the comment period and determine the next steps of the project.

Background
The Federal Energy Regulatory Commission (FERC) issued Order No. 901 on October 19, 2023, which includes directives on new or modified NERC Reliability Standard projects. Order No. 901 addresses a wide spectrum of reliability risks to the grid from the application of inverter-based resources (IBR), including both utility scale and behind-the-meter or distributed energy resources. Within the Order, are four milestones that include sets of directives to NERC. NERC developed a directive mapping document as part of its workplan to address all aspects of Order No. 901. The Milestone 3 projects will address deficiencies within the current state of model quality.

Project 2021-01 addresses Model Validation of both steady-state and dynamic system models against actual system behavior.

To facilitate the development of this Milestone, Standard Authorization Requests were assigned to active projects that already had some aspects of Order No. 901-directed modeling improvements and drafting team familiarity with the Reliability Standards to be changed. Project 2021-01 Modifications to MOD-025 and PRC-019 will resume upon completion of this Milestone 3 project.

All Milestone 3 projects must be filed with FERC by November 4, 2025, with full implementation by January 1, 2030, to comply with Order No. 901.

Standard(s) Affected – MOD-033-2 Steady-State and Dynamic System Model Validation

Purpose/Industry Need
The proposed revisions to MOD-033-2 are described in the SAR.

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Draft	Actions	Dates	Results	Consideration of Comments
Draft 1 MOD-033-3 Clean \| Redline Implementation Plan Supporting Materials Unofficial Comment Form (Word) Technical Rationale VRF/VSL Justifications Consideration of Directives	Initial Ballots and Non-binding Poll Ballots Open Reminder Info Vote	05/12/25 – 05/21/25	Ballot Results MOD-033-3 Implementation Plan Non-binding Poll Results
	Join Ballot Pools	04/17/25 – 04/28/25
	Comment Period Info Submit Comments	04/17/25 – 05/21/25	Comments Received
Supplemental Drafting Team Nominations Supporting Materials Unofficial Nomination Form (Word)	Nomination Period Info Submit Nominations	11/21/24 - 12/20/24
Standard Authorization Request Clean \| Redline	The Standards Committee authorized standard(s) drafting on November 13, 2024.
Supplemental Drafting Team Nominations Supporting Materials Unofficial Nomination Form (Word)	Nomination Period Info Submit Nominations	08/15/2024 - 09/13/24
Standard Authorization Request Supporting Materials Unofficial Comment Form (Word)	Comment Period Info Submit Comments	05/23/24 - 06/28/24	Comments Received	Consideration of Comments
Draft 2 MOD-025-3 Clean \| Redline to Last Posted \| Redline to Last Approved PRC-019-3 Clean \| Redline to Last Posted \| Redline to Last Approved MOD-025-3 Implementation Plan Clean \| Redline PRC-019-3 Implementation Plan Clean \| Redline Supporting Materials Unofficial Comment Form (Word) Technical Rationales MOD-025-3 PRC-019-3 VRF/VSL Justifications MOD-025-3 PRC-019-3 Implementation Guidance for PRC-019-2	Additional Ballots and Non-binding Polls Ballot Open Reminder Info Vote	05/30/23 - 06/08/23	Ballot Results MOD-025-3 MOD-025-3 Implementation Plan PRC-019-3 PRC-019-3 Implementation Plan Non-binding Poll Results MOD-025-3 PRC-019-3
	Comment Period Info Submit Comments	04/25/23 - 06/08/23	Comments Received
Draft 1 MOD-025-3 Clean \| Redline PRC-019-3 Clean \| Redline Implementation Plans MOD-025-3 PRC-019-3 Supporting Materials Unofficial Comment Form (Word) Technical Rationales MOD-025-3 PRC-019-3 VRF/VSL Justifications MOD-025-3 PRC-019-3	Initial Ballots and Non-binding Polls Updated Info Info Vote	11/04/22 - 11/17/22 (extended)	Ballot Results MOD-025-3 MOD-025-3 Implementation Plan PRC-019-3 PRC-019-3 Implementation Plan Non-binding Poll Results MOD-025-3 PRC-019-3
	Join Ballot Pools	09/29/22 - 10/28/22
	Comment Period Info Submit Comments	09/29/22 - 11/17/22 (extended)	Comments Received	Consideration of Comments
MOD-025-2 SAR Clean \| Redline PRC-019-2 SAR Clean \| Redline	The Standards Committee accepted the SARs on December 15, 2021
Supplemental Drafting Team Nominations Supporting Materials Unofficial Nomination Form (Word)	Nomination Period Info Submit Nominations	04/30/21 - 05/20/21
Drafting Team Nominations Supporting Materials Unofficial Nomination Form (Word)	Nomination Period Info Submit Nominations	03/04/21 - 04/2/21
MOD-025-2 SAR PRC-019-2 SAR Project 2020-02 SAR Supporting Materials Unofficial Comment Form (Word)	Comment Period Info Submit Comments	03/04/21 - 04/2/21	Comments Received	Consideration of Comments

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