Enforcement discretion filings for nearly 40 plants, drafted overnight

A large renewable owner needed to notify its Regional Entities, before October 1, 2026, that nearly 40 of its wind, solar and storage plants would miss the PRC-029-1 design date while their manufacturers worked through settings and firmware. NERC had revised its enforcement-discretion guide three weeks before the deadline.

The owner handed the notification workbook to one compliance lead on a Wednesday afternoon. His plan was to write the manufacturer language over the weekend and fill in 70 to 90 unit rows by hand on the day it was due. The manufacturer correspondence it depended on sat in two different systems.

NERC's enforcement discretion for PRC-029-1 runs to 2028 for a plant whose owner notifies its Regional Entity before the compliance date, on NERC's own workbook: an entity row with the communications with the manufacturer, and a unit row for every registered unit with its commercial operation date, rating, setting implementation date and manufacturer. A regulator-facing document, so every value has to be traceable.

We had already built a tool that fills NERC's notification workbook. It reads NERC's template without disturbing it, reads the owner's asset verification forms in every layout NERC has issued, joins them to the registration data and commissioning records, applies the owner's approved wording for each equipment family, and works out each plant's compliance date.

For this owner it read about 40 forms in four layouts and wrote one master workbook with a row per registered unit across the owner's Regional Entities. Every cell names its source. Every gap is marked in red for the owner to fill. It does not guess: a value is read off a form with its cell reference, stated by a named person, or left red.

Of roughly 900 cells, about 60 needed the owner's hand: about 25 items across a third of the plants. The owner chose to file for every plant that qualified. Better to hold the protection and not need it.

The owner's package arrived on a Monday evening. The draft filing was on the shared drive before 8:30 the next morning. By that afternoon the compliance lead had everything he needed, and the first notifications went out that evening, a day ahead of the deadline.

One person finished a fleet filing in an afternoon instead of typing 90 rows against the clock.