FERC Requests More Comments on Grid Service Proposal
In November 2016, FERC issued a Notice of Proposed Rulemaking (NOPR) that would require new generating facilities to install and operate equipment that provides primary frequency response service to the grid. Based on some of the comments received on the NOPR, FERC issued a request for supplemental comments.
The reliable operation of the alternating current (AC) North American electric grid depends on maintaining a frequency near 60 Hertz (Hz). Variations from this frequency can occur due to sudden changes in the balance between generation and load on the system and cause instability. Frequency responsive power control equipment can sense changes in system frequency and autonomously adjust a generating facility’s power output.
More background on frequency response service and the NOPR may be found in the November 28, 2016 post on this blog.
FERC requested supplemental comments on two topics. The first topic is whether and when electric storage resources should be required to provide primary frequency response. The NOPR did not propose provisions specific to electric storage resources. Some commenters raised concerns that, by failing to address electric storage resources’ unique technical attributes, the new requirements could pose an unduly discriminatory burden on electric storage resources and even result in adverse impacts on those resources. In light of these concerns, FERC asks a series of detailed questions to obtain additional information regarding:
The performance characteristics and limitations of electric storage resources;
Possible ramifications of the proposed primary frequency response requirements on electric storage resources; and
What changes, if any, are needed to address the issues raised by commenters.