Where NERC CIP impact ratings go wrong for generation operators

Generation operators often assume a whole CIP program is low impact because a single solar or wind plant rarely reaches the 1,500 MW medium-impact threshold under criterion 2.1. However, criterion 2.11 separately rates a Control Center performing Generator Operator functions for 1,500 MW or more in one Interconnection as medium impact, so growing portfolios need rechecking. CIP-002 R2 requires reviewing these identifications at least every 15 calendar months with CIP Senior Manager approval, since new plants, repowering, or operator changes can shift ratings. Low impact sites still need a CIP-003-9 plan with evidence of implementation, and whether a medium impact system has External Routable Connectivity determines which requirements and upcoming CIP-015-1 monitoring apply.