MOD-032 for Category 2 IBRs
The 2026 plan notes Category 2 inverter-based resources are included in MOD-032 beginning May 15, 2026. Newly registered GO/GOPs need model data that meets their Planning Coordinator and Transmission Planner requirements.
The ERO Enterprise names Grid Transformation as a 2026 risk element because the resource mix is changing faster than models, interconnection requirements and protection practices are keeping up.
The requirements it points to — planning assessments, model verification, interconnection requirements and protection — are all engineering-evidence requirements. Keentel Engineering reviews and refreshes that evidence so it is ready for this year’s audits, spot checks and self-certifications.
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Each year the ERO Enterprise publishes a CMEP Implementation Plan identifying the risk elements that Regional Entities will emphasize in compliance monitoring. The 2026 plan names seven. Grid Transformation is the broadest of them, and the plan states plainly that it “remains a significant risk to the reliable operation of the electric system.”
The plan describes five concerns under this element. Our work addresses the four that are engineering and compliance problems; the fifth, workforce adequacy, is one we help with by providing the specialist engineering capacity many entities do not have in-house.
Focus areas do not add new requirements. They tell you which existing requirements a Regional Entity is most likely to test this year — which makes them the right place to start an evidence refresh.

The table lists the Operations & Planning requirements the 2026 plan associates with this risk element, and the engineering evidence that typically demonstrates each. The plan also lists several CIP requirements; CIP is a separate discipline and outside the scope of this service.
| Standard & requirements | What the requirements address | Evidence we review or produce |
|---|---|---|
| TPL-001-5.1 R1–R7 | Planning models, Planning Assessments, performance criteria, studies, Corrective Action Plans and distribution of results | Model basis, case lists, contingency definitions, study results, CAPs and distribution records |
| MOD-025-2 R1–R3 | Verification and reporting of generator real and reactive capability | Test plans, test data, capability curves and submittals to the Transmission Planner |
| MOD-026-1 R2, R6 | Excitation or plant volt/var control model verification and model data provision | Model verification reports and responses to Transmission Planner requests |
| MOD-027-1 R5 | Turbine/governor and active power/frequency control model verification | Model data and verification records provided to the Transmission Planner |
| MOD-031-3 R1, R2 | Demand and energy data | Data request and data submission records |
| MOD-032-1 R1–R4 | Modeling data for planning; Category 2 IBRs included beginning May 15, 2026 | Data submissions to each PC and TP’s published requirements, including EMT models where required |
| FAC-001-4 R1, R2 | Facility interconnection requirements | Documented, current interconnection requirements and how they are made available |
| FAC-002-4 R1, R2 | Studies and coordination for new or materially modified Facilities | Study reports and coordination correspondence covering the required elements |
| PRC-005-6 R3, R5 | Protection System, Automatic Reclosing and Sudden Pressure Relaying maintenance and Unresolved Maintenance Issues | Component inventory, interval tracking, test records and corrective-action records |
| PRC-024-3 / PRC-024-4 R1, R2 | Generator frequency and voltage protective relay settings; PRC-024-4 effective October 1, 2026 | Setting evaluations against the no-trip zones and documented exceptions |
| PRC-027-1 R1–R3 | Coordination of Protection Systems for faults | Coordination process, fault studies and periodic review records |
The 2026 plan notes Category 2 inverter-based resources are included in MOD-032 beginning May 15, 2026. Newly registered GO/GOPs need model data that meets their Planning Coordinator and Transmission Planner requirements.
The plan lists PRC-024-3 and PRC-024-4, with PRC-024-4 effective October 1, 2026. Settings evidence should show which version applies to each unit on each date.
The plan emphasizes validating modeling assumptions not only at interconnection but throughout the life of assets — after firmware updates, controller tuning, augmentation and repowering.
Where an unregistered third party operates plants for multiple Generator Owners, responsibilities, communications and evidence ownership need to be clearly documented.
Tell us your registered functions and facilities. Keentel will map every named requirement, sample the evidence and close the engineering gaps before your Regional Entity asks.
Map each named requirement to your registered functions, facilities and effective dates — including Category 2 IBRs and PRC-024 version transitions.
Pull the evidence a Regional Entity would request for each requirement and test it for completeness, currency and traceability.
Verify that models, settings, studies and capability tests actually reflect the installed equipment and current system.
Perform the missing verifications, studies, setting evaluations or data submissions.
Organize evidence by requirement with narratives and indexes a reviewer can follow.
Summarize readiness, open actions and risk so leadership understands the entity’s position on this focus area.
| Gap | Why it matters |
|---|---|
| Planning Assessment assumptions undocumented | TPL-001 R1–R7 evidence depends on showing the right cases, contingencies and criteria were used. |
| Models not updated after plant changes | Firmware, controller and equipment changes leave submitted models behind the plant. |
| New Category 2 IBRs without model data | Newly registered owners may not have received complete models from EPCs and OEMs. |
| Interconnection requirements out of date | FAC-001 documents that do not reflect current practice or IBR requirements invite questions. |
| PRC-005 inventories incomplete | Missing components mean missed intervals and unresolved maintenance issues. |
| PRC-024 version not tracked by unit | The transition to PRC-024-4 requires clarity about which requirements applied when. |
| Deliverable | Purpose |
|---|---|
| Focus-area applicability matrix | Every named requirement mapped to your functions, facilities and effective dates |
| Evidence readiness scorecard | A rating of each requirement’s evidence with specific gaps identified |
| Engineering gap closure | Model verifications, studies, setting evaluations and data submissions as needed |
| Requirement-indexed evidence packages | Evidence organized for audit, spot check or self-certification |
| Management briefing | A concise summary of readiness, open actions and residual risk |

PSS®E, PSLF and PSCAD™ planning, verification and EMT work performed by our own engineers.
PRC-005 program design, PRC-024 setting evaluations and PRC-027 coordination studies.
POI interconnection engineering and system impact studies across ISOs and utilities.
Former audit-team leadership helps us sample evidence the way a Regional Entity will.
Tell us your registered functions and facilities. Keentel will map every named requirement, sample the evidence and close the engineering gaps before your Regional Entity asks.
Technical articles related to Grid Transformation, modeling, inverter-based resources, protection and upcoming NERC requirements.






Tell us your registered functions and facilities. Keentel will map every named requirement, sample the evidence and close the engineering gaps before your Regional Entity asks.
Tell us which assessments are due and what models you have. Keentel will scope the studies, document every assumption and track every Corrective Action Plan to completion.

























































































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