As our industry continues to evolve with an ever-increasing percentage of inverter-based resources, coupled with the recent focus on generator operations, especially during extreme cold weather, NERC and the regional entities should re-evaluate their staffing mix. Based on our participation in recent industry efforts, it appears that most regulators have few staff members with significant generator experience. This, coupled with a perceived lack of understanding of how different industry participants are funded, operate and are staffed, may be contributing to a failure to develop appropriate rules for the changing grid. Bringing on support personnel at the regulators with broad-based experience would foster communication and understanding between the regulators and regulated entities. Regulators should look for staff with significant generation operational experience, including non-utility generation.
Ideally, the regulators would have personnel with experience associated with Inverter Based Resources (IBRs), Distributed Energy Resources (DERs), generator operations, and centralized market operations. Another desired trait would be experience in project development related to generation resources, both conventional and renewable.
The regulators of the future should be aligned with the structure of the industry, not just the historical utility structure. Our regulators need to understand the business models of all entities they are regulating, preferably by having walked in the shoes of those entities.
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