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Energy Law Exchange

March 4, 2016

Federal Energy Regulation Commission Seeks Comments on Primary Frequency Response


On February 18, 2016, the Federal Energy Regulatory Commission (FERC) issued a Notice of Inquiry (the NOI) seeking comments on possible reforms to its rules and regulations relating to the provision of, and compensation for, primary frequency response.

Frequency response is needed to ensure that frequency on the electric grid remains within acceptable bounds in the event of system contingencies, such as a generator going off-line, that cause frequency deviations. Such deviations can result in load shedding, generator trips, and cascading outages. Some, but not all, generators are capable of providing frequency response in the form of: (1) inertial frequency response, which helps control how fast frequency drops after a loss of generation and how fast it rises after a reduction in load; (2) primary frequency response, which arrests a frequency deviation until it reaches the minimum frequency; and/or (3) secondary frequency response, which takes place following a contingency event and restores the system frequency to its scheduled value.

In the NOI, FERC expresses concern that changes in the generation resource mix
i.e., the retirement of large amounts of baseload, synchronous units, and increased reliance on variable energy resources (VERS), distributed generation, and demand response has reduced the number of resources that are capable of providing frequency response. For example, FERC explains that VERS do not provide inertial response, and typically do not provide primary frequency response unless specifically configured to do so. For this reason, FERC seeks comments on possible actions to ensure that the provision of primary frequency response continues to remain at levels adequate to maintain the reliability of the Bulk-Power System in light of the ongoing transformation of the nations generation resource mix. The NOI identifies a number of specific issues on which FERC seeks input, including but not limited to, whether primary frequency response requirements should be imposed on new or existing resources, whether all resources should be required to provide minimum levels of primary frequency response capability or performance in real-time, and whether resources should be compensated for having minimum levels of frequency response capability or performance.

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