The line between NERC PRC-023 and PRC-025, what Generator Owners need to know

During certifications or audits to NERC Reliability Standards, conflicting interpretations confront registered entities. This is particularly true for Independent Power Producers located in multiple regions and continually facing audits on an ongoing basis. In the recent past, the specific lack of a clear and unambiguous definition of Generator Owners applicability resulted in frequent misapplication of NERC Standard PRC-023. To avoid gaps in reliability, Generator Owners (GOs) were included in the applicability section of PRC023, even though the application of the standard to GOs is included for exceptions. Nevertheless, the inclusion of Generator Owners has led to interpretation errors of the standard. As a result, regional compliance organizations have previously applied PRC-023 in ways that directly contradict the explicit wording and direction of the FERC Orders approving and mandating their application. With the approval of NERC Standards PRC-023-3 and PRC-025-1, Generator Owners need to understand which relays must comply with Generator Loadability requirements, regardless of the prior application of transmission loadability requirements.