The 2026 Development Plan was developed in accordance with section 310 of the North American Electric Reliability Corporation (NERC) Rules of Procedure and identifies the priorities and plans for development and modification of NERC Reliability Standards over the next three years. NERC is required to annually develop a Reliability Standards Development Plan (RSDP) for Reliability Standards development. Each RSDP must include a progress report, comparing results achieved to the prior year’s RSDP. The RSDP serves three main purposes:
- As a management tool to guide and coordinate the development of Reliability Standards and provide benchmarks for assessing progress.
- It also serves as a communication tool for coordinating standards development work with applicable governmental agencies in the United States and Canada and for engaging stakeholders in Reliability Standards development activities.
- Provides a basis for developing annual plans and budgets for the NERC Reliability Standards Program.
In 2024, all four projects that were anticipated to be completed in the previous RSDP were filed with the NERC Board of Trustees in December 2024. There are currently 19 projects listed in the 2025-2027 RSDP that continued into the current year with 22 projects anticipated to continue into 2026. In Fall of 2023, Standards Development utilized the prioritization process. The prioritization process has been an essential tool to balance the number of active projects, projects with firm deadlines to complete, as well as residual risk for slowing some projects down. This has helped with the availability of resources to complete higher priority projects. Since initiation, this tool has been essential in managing a high quantity of active projects. As part of the progress report, Standards development has been tracking pass/fail results to provide an indicator for general project progress. Reviewing data back to 2017 through the current day, previous projects had taken on average two ballots to pass. More recent projects in development have shown a trend towards three or more ballots to pass. This increasing trend has been attributed to a variety of factors. Among them are the increased volume of high priority projects that contribute to an increase in the number of ballots being posted for industry voting and formal comment periods. Valuable feedback has continued to be provided regarding communication from NERC Staff as well as identifying ongoing resource constraints within the industry. In 2024, medium and low priority projects were placed on a posting restriction to focus on higher priority projects. The Staff will continue to provide consistent quarterly outlook of anticipated project postings and increase targeted outreach before the initial ballot and between additional ballots. This could be done with more technical workshops if appropriate. Beyond the roles and responsibilities of drafting teams there are other influencing factors that continue to impact drafts failing to pass. Staff will continue to simultaneously pursue implementing additional ways to collect and focus feedback on certain aspects of the development process or communication on projects overall.
As the technological pace in our industry continues to increase, NERC projects have been increasing in quantity. Many of these projects are identified as high priority as they are associated with FERC orders and directives leaving them with strict timelines. Due to this, NERC has been driving prioritization to ensure available resources are focused on the most critical issues. Efforts are being made to identify the Reliability Standards Projects that must be allocated resources as well as how NERC may acceptably lower the resource demands on projects that have not been deemed “high priority.” When more than 50% of active projects have been designated as high priority, medium and low priority projects will be restricted to informal postings or paused altogether to mitigate strain on resources. The prioritization process was put into place to formalize a consistent approach to relieving strain on resources. NERC Standards Development continues to implement a process to ensure prioritization efforts continue beyond initial efforts and eventually become common practice. As the process has matured, the initial baseline strategy and approach have been revised to reflect lessons learned. Due to the high volume of high priority projects in 2024, projects of medium and low priority will be continuing into 2025 and beyond. Projects of medium priority were not allowed to post for formal or informal comments in 2024. Low priority projects were additionally placed on the same restrictions. All restrictions were released starting in Q1 of 2025. Due to this, no anticipated completion times of these projects have been given. Based on the trigger point of 50% or more high priority projects, no restrictions are expected to be placed throughout the end of the year. Over the next six months, the percentage of high priority projects is expected to be around 30 % and will therefore not cause any restrictions.
In determining high, medium or low priority designations, the following factors were taken into consideration:
- Outstanding regulatory Board directives with filing deadlines and NERC annual work plan priorities (High Priority)
- RISC category rankings of high impact with consideration of probability of occurrence (High or Medium Priority)
- Potential reliability risks from stakeholders and technical committees provided through feedback mechanisms (High, Medium, or Low Priority, based on the risk)
- Outstanding regulatory directives without regulatory deadlines or “soft directives” such as considerations (High or Medium Priority)
- Compliance feedback or study to address a specific risk (High or Medium Priority)
- Outstanding requirements that are known candidates for retirement (Low Priority)
- Any known adverse content
On a quarterly basis, NERC will take these factors into account to prioritize projects. A full listing of FERC directives, continuing projects, completed projects and anticipated projects by priority can be found in the 2026-2028 Reliability Standards Development Plan.
For question or comments, reach out to GDS.
Justin Monk or Chris White