Modeling
Planning and operating the electric grid in a reliable manner requires models that accurately represent system conditions, to detect and prevent reliability and security issues. As the grid evolves with the integration of new technologies, it is critical to ensure that models are updated to reflect the behavior of equipment installed on the system. RF gave modeling a medium-high risk score for the 2025-26 RRA.
RF examined violations of NERC Modeling (MOD) and Facility (FAC) Standards to better understand model quality issues and related risks within the footprint. From 2020-2025, 91% of MOD Standards violations were self-reported by entities. As shown in Figure 16, there was a year-over-year decrease in MOD Standard violations from 15 violations in 2024 to 11 violations in 2025.
Figure 16. MOD Violation Intake in RF Footprint (2020-2025)
Figure 16. MOD Violation Intake in RF Footprint (2020-2025)
RF observed that smaller asset owners were responsible for many of the MOD violations between 2020 and 2025. With the new registration of Category 2 Generator Owners, which includes smaller asset owners, RF plans to continue monitoring this performance. Violations of the MOD-025 Standard, which includes requirements to verify generator Real and Reactive Power capabilities, represented 56% of the total MOD violations reported between 2020 and 2025.
FAC-008-5 (Facility Ratings) ensures accurate modeling of thermal limits for system elements within operational and planning cases, which is essential for the safe and reliable operation of the grid. As shown in Figure 17, FAC-008-5 violations experienced a year-over-year increase from 5 violations in 2024 to 17 violations in 2025.
Figure 17. FAC-008 Violation Intake in RF Footprint (2020-2025)
Figure 17. FAC-008 Violation Intake in RF Footprint (2020-2025)
The uptick in violations may be partly attributable to increased compliance monitoring engagements (i.e., audits) and equipment walk-downs. RF has been working closely with asset owners on awareness and performance improvement related to this standard. These activities may result in asset owners implementing new or enhanced internal controls and strengthening equipment walk down procedures.
Representation of forecasted demand and large loads
As discussed earlier in this report, ten-year model forecasts for the RF region show a sharp acceleration in load growth, mainly driven by data center expansion, electrification of buildings and vehicles, and manufacturing. The most current models diverge from historical load growth trends and highlight the inherent uncertainty associated with model development.
RF participates in NERC’s Large Load Task Force, which acts as a forum for discussion and establishing guidelines related to risks surrounding large loads. The task force produced a whitepaper, Characteristics and Risks of Emerging Large Loads, that stresses the importance of accurate modeling of protection and control systems to avoid potential load loss events during strained system conditions.
In September 2025, NERC issued a Level 2 Industry Recommendation Alert that recommended actions to mitigate reliability risks from large load integration. Alert recipients were required to provide responses that emphasized dynamic modeling evaluation and interconnection practices to address deficiencies.
FERC has issued an Advanced Notice of Proposed Rule Making (ANOPR) related to Large Load interconnections. This ANOPR covers topics such as thresholds to better define large loads and appropriate study processes for large loads with co-located generation. RF plans to monitor the progress of this FERC action and any potential developments to the NERC Reliability Standards.
Representation of inverter-based resources
NERC has published an event analysis report on inverter-based resource disturbances in the Western Interconnection that identified generation losses of up to 1 GW. This report highlights industry efforts to improve the representation of inverter-based resources within models to better reflect operational behavior. Similarly, FERC Order No. 901 resulted in multiple proposed changes to the NERC Reliability Standards to address this risk. RF monitors standards development processes while performing outreach and collaborating with registered entities via its technical committees to help address the modeling risk.
NERC has also expanded the applicability of its Reliability Standards to include more inverter-based resources by registering new generator owners that are required to adhere to applicable requirements, which include ensuring accurate model representation.
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