FERC on Thursday granted a waiver request from Public Service Company of New Hampshire (PSNH), allowing ISO-NE to accept its restoration plan for the Lost Nation generating unit, which the company submitted one business day after the deadline under the RTO’s Tariff (ER18-465).
Eversource Energy, PSNH’s parent company, in January completed the sale of its fossil-fuel generation units in New Hampshire to Granite Shore Power.
On Oct. 20, ISO-NE flagged the oil-fired combustion turbine in Groveton, N.H., for having a significant decrease in capacity below its cleared capacity supply obligation (CSO) of 13.97 MW for the RTO’s 2018-2019 capacity commitment period.
Covered bridge over the Upper Ammonoosuc River next to the 18-MW Lost Nation plant in Groveton, NH.
Under the rules governing the RTO’s annual reconfiguration auctions, Lost Nation had 10 business days to either purchase additional capacity to replace the shortfall or submit a restoration plan showing how it would be able to meet its obligation.
PSNH said the decrease in capacity occurred because a summer seasonal claimed capability audit was not performed. An Eversource employee intended to file a restoration plan showing that Lost Nation was dispatched four days in September 2017 and thus should be capable of supplying output to meet its awarded CSO.
The utility said that two events caused the delay in submitting the restoration plan.
First, the mother of the employee charged with submitting the plan died on Oct. 29, 2017, while the plan was out for review. Then, after a strong storm tore through the state on Oct. 30, the employee was called to storm duty and performed three consecutive 13-hour shifts until being released on Nov. 2. He was then given leave to prepare for his mother’s Nov. 4 memorial service.
Lost Nation Turbine | Eversource
The combination of events distracted the employee from submitting the restoration plan by the close of the Friday, Nov. 3 submission window; he submitted the plan the morning of Monday, Nov. 6. The RTO said it could not unilaterally waive the Tariff-imposed deadline.
In its Feb. 15 decision, the commission found that “PSNH acted in good faith by submitting the restoration plan as soon as possible after it discovered the omission.” The commission also noted that PSNH’s waiver request was uncontested.
FERC ruled Thursday that NYISO must make additional changes to comply with Order 1000, while acknowledging in a separate docket that it erred in directing the ISO to change the indemnification language in its pro forma development agreement.
The commission said transmission developers must indemnify NYISO except for acts of “gross negligence or intentional misconduct.” In ordering NYISO to remove the word “gross” from the agreement, the commission said it failed to follow its precedent in a 2015 order involving MISO (ER15-2059-002; ER13-102-008).
| NYSEG
FERC also granted NYISO a request for clarification, saying it will allow the ISO to propose a new process for evaluating alternative regulated transmission solutions and regulated backstop solutions for interconnection. The ISO’s current process is outlined in Tariff Attachments X and S.
But the commission rejected rehearing requests by the New York Transmission Owners (NYTOs), who balked at the commission’s requirement that TOs responsible for providing “backstop” solutions to a reliability need — normally the incumbent TO — sign the development agreement, as is required of nonincumbent transmission developers.
“If responsible transmission owners developing regulated backstop solutions are not required to execute a development agreement, they will have an advantage over nonincumbent transmission developers both in seeking selection in the regional transmission plan for purposes of cost allocation and remaining selected,” the commission said, noting that the NYISO Transmission Owners Agreement and the agreement between NYISO and the NYTOs on the Comprehensive Planning Process for Reliability Needs are less stringent than those in the development agreement
The NYTOs consist of Central Hudson Gas & Electric; Consolidated Edison; New York Power Authority; New York State Electric and Gas; Niagara Mohawk Power; Long Island Power Authority; Rochester Gas & Electric; and Orange and Rockland Utilities.
Compliance Filings
| NYSEG
FERC also provided its clarification on alternatives to Attachments X and S in a concurrently issued order in which it accepted in part Order 1000 compliance filings NYISO made in March and September 2016. The commission accepted most of the ISO’s Tariff revisions but rejected language it said was discriminatory or unjust (ER13-102, et al.).
It ordered the ISO to make changes in its proposed transmission interconnection procedures that it found unjust and unreasonable, including language on scheduling and definitions.
It also required the ISO to make changes in its proposed Operating Agreement regarding maintenance schedules, compliance with local reliability rules and investigations of equipment malfunctions.
The commission found “incorrect” the Tariff revision that said nothing in Attachment Y affects a TO’s right to recover the costs of upgrades to its facilities regardless of whether the upgrade has been selected in the regional transmission plan for purposes of cost allocation.
“Pursuant to Order No. 1000, once NYISO selects a transmission project in the regional transmission plan for purposes of cost allocation, the regional cost allocation method set forth in Attachment Y of the [Tariff] applies, unless the project developer ‘decline[s] to pursue regional cost allocation,’” the commission said.
Below is a summary of the issues scheduled to be brought to a vote at the PJM Markets and Reliability Committee on Thursday. (The scheduled Members Committee meeting was canceled.) Each item is listed by agenda number, description and projected time of discussion, followed by a summary of the issue and links to prior coverage in RTO Insider.
RTO Insider will be in Wilmington, Del., covering the discussions and votes. See next Tuesday’s newsletter for a full report.
Markets and Reliability Committee
2. PJM Manuals (9:10-9:30)
Members will be asked to endorse the following proposed manual changes:
A. Manual 2: Transmission Service Request. Revisions developed to align manual with Tariff changes endorsed at the Dec. 21 meeting to revise the process for analyzing transmission service requests. The initial study is replaced by the firm transmission feasibility study.
B. Manual 11: Energy & Ancillary Services. Clarifies the energy-offer verification process for demand-side bids, including caps on price-sensitive demand bids; reverses prior change to pre-emergency and emergency demand response because they are outside the scope of FERC Order 831.
3. Tariff Revisions to Address Overlapping Congestion (9:30-9:45)
Members will be asked to endorse proposed Tariff and Operating Agreement changes to address overlapping congestion. PJM and MISO have been working to remove duplicative congestion charges and have developed a two-phase plan to eliminate them. These changes encompass the second phase. (See MISO, PJM Pursue Pseudo-Tie Double-Charge Relief.)
4. Summer-Only Demand Response Senior Task Force Charter (SODRSTF) (9:45-9:55)
Members will be asked to endorse a draft charter for the SODRSTF. The task force, which was developed to consider ways to take advantage of excess summer-only resources, has met several times. (See Stakeholders Seek Load Discussion in PJM DR Task Force.)
5. Sunsetting Senior Task Forces (9:55-10:15)
Members will be asked to sunset the Underperformance Risk Management Senior Task Force (URMSTF) and the Regulation Market Issues Senior Task Force (RMISTF). The URMSTF developed proposals on underperformance risk management, which failed to receive MRC stakeholder endorsement, and changes to external capacity performance requirements, which were endorsed. The RMISTF resulted in a new regulation signal being implemented, along with a package of regulation procedure and requirement changes. (See PJM Regulation Compensation Changes Cleared over Opposition.)
FERC last week accepted several small revisions to MISO’s new interconnection queue design but also told the RTO it must keep working to ensure it sticks to a commitment to reduce restudies.
The commission provided MISO a month to revise its Tariff to eliminate a practice of automatically conducting a restudy based on predetermined triggers, which include a project’s termination or the withdrawal of a project from the queue (ER17-156-002).
| MISO
“In the October 2016 queue reform filing, MISO proposed that, instead of conducting a restudy automatically upon each occurrence of a restudy trigger, the RTO would re-evaluate the need for any common use or shared network upgrades associated with the project,” FERC said.
As of Nov. 2017 | MISO
FERC largely accepted MISO’s new, three-stage interconnection queue in January 2017, but it sought more detail on a few aspects of the plan, prompting a follow-up filing. (See FERC Accepts MISO’s 2nd Try on Queue Reform.) The commission at the time directed MISO to conduct restudies on an as-needed basis only, even when a triggering event occurs. It said the RTO “could decide in its discretion whether a restudy was needed or not.”
In revisions filed last March, MISO altered its Tariff to enable it to conduct restudies for reasons other than triggering events. In the most recent ruling, FERC reversed that move, saying the RTO cannot conduct a restudy absent a trigger.
FERC accepted several other smaller Tariff revisions that it had directed MISO to make, including:
Stipulating mandatory attendance of transmission owners in scoping-level meetings between MISO staff and interconnection customers;
Describing the types of events that trigger a queue restudy; and
Offering customers a provisional generator interconnection agreement option at any time in the interconnection process, regardless of whether MISO failed to meet a study deadline.
MISO was also required to scale back its site control requirement by the queue’s second decision point from 100% to 75% after FERC determined that complete site control is difficult to obtain so early in the process.
The RTO also had to clarify that an interconnection customer that withdraws early in the queue — at either the first or second decision points — will not be responsible for the costs of other customers’ interconnection studies, and that a customer withdrawing at the third decision point should only pay a study deposit fee to cover a potential restudy for another interconnection customer.
Finally, MISO added language to clarify that the batch of projects entering the definitive planning phase in August 2015 was grandfathered into the old queue design.
However, FERC’s recent ruling gave the RTO 30 days to clarify that the queue’s third and fourth $4,000/MW milestone payment collection is only an initial charge subject to change as costs become clearer in the study process.
“This language implies that the M3 and M4 milestone payments are set to $4,000/MW and are not subject to a true-up as more accurate estimates become available, which is not in line with MISO’s indication in its testimony,” FERC said.
In accepting MISO’s filing, FERC dismissed a bundle of complaints from EDF Renewable Energy as being outside the scope of the proceeding. EDF had asked FERC to force MISO to share more network modeling details and prescribe “remedies” should the RTO fail to complete studies on time. The company also sought a directive instructing MISO to develop a fast-track queue option for vetted projects, and complained that the RTO failed to coordinate its generator interconnection process with the transmission planning process.
Avangrid announced Friday that Massachusetts has selected the transmission project of its subsidiary, Central Maine Power, as the alternative for the state’s 9.45-TWh clean energy solicitation if New Hampshire regulators do not approve the Northern Pass transmission line by March 27.
Massachusetts awarded the contract to Eversource Energy and Hydro-Quebec’s Northern Pass on Jan. 25, only to see the New Hampshire Site Evaluation Committee (SEC) unanimously reject the 1,090-MW transmission project a week later. Eversource appealed the decision, saying in a statement Feb. 16: “We have a strong legal argument for a reconsideration by the SEC.” (See New Hampshire Rejects Permit for Northern Pass.)
| Eversource, Central Maine Power
CMP and Hydro-Quebec’s New England Clean Energy Connect (NECEC) transmission project would deliver up to 1,200 MW of Canadian hydropower to the New England grid via a 145-mile transmission line. The partners estimate the project to cost $950 million.
News of the selection drew a protesting tweet from Dan Dolan, president of the New England Power Generators Association: “Massachusetts is now all-in on Hydro-Quebec, going from the fatally flawed Northern Pass to a Maine project that still lacks virtually all its key permits. Hydro-Quebec is asking for Massachusetts consumers to guarantee them revenue through an above-market contract for electricity for the next two decades.”
Hydro-Québec Major Facilities | Hydro-Québec
Dolan said existing power plant operators in the region have invested more than $13 billion in their plants without any guarantee of cost recovery or profit.
Beginning Negotiations
CMP submitted applications for state and federal permits for NECEC in mid-2017 and said it expects to receive state approvals later this year and final federal permits in early 2019. The company said it will immediately begin negotiation of long-term contracts with the Massachusetts electric distribution companies to prepare for a submission to the state’s Department of Public Utilities in April 2018.
“Our applications for state and federal permits are moving forward with the strong support of communities and stakeholders in Maine,” CMP CEO Doug Herling said in a statement.
Eversource’s statement said that Friday’s decision “strikes a sensible balance by allowing negotiations with Northern Pass to continue, while establishing a back-up protocol that can be initiated if necessary.”
Avangrid Networks CEO Bob Kump said, “A new transmission link between Maine and Quebec would deliver a reliable, firm supply of clean energy to help dampen seasonal price instability when high demand puts pressure on natural gas supplies.”
Massachusetts issued its MA 83D solicitation for hydro and Class I renewables (wind, solar or energy storage) last July. The selection committee for the clean energy request for proposals issued in July 2017 includes representatives from the state’s Department of Energy Resources and from distribution utilities Eversource, National Grid and Avangrid subsidiary Unitil.
Any contract awarded under the request for proposals must be negotiated by March 27 and submitted to the DPU by April 25.
Other proposals for the RFP included Nova Scotia-based Emera’s Atlantic Link project, a 375-mile submarine HVDC transmission line from New Brunswick to Plymouth, Mass., to deliver 5.69 TWh of clean energy per year. National Grid partnered with Citizens Energy on two transmission projects; one of them, the Granite State Power Link, is a 59-mile HVDC line from northern Vermont to New Hampshire to deliver 1,200 MW of new wind power from Canada.
The state-owned Hydro-Quebec also partnered separately with Transmission Developers Inc. for the RFP and, as with Northern Pass, made two proposals, one pure hydro and one with a wind energy component.
FERC last week ordered the shutdown of a Michigan hydroelectric project over longtime safety violations — the most significant of which relate to inadequate spillway capacity.
The commission will revoke the license for Boyce Hydro’s 4.8-MW Edenville Dam in northern Michigan on March 1 following its Feb. 15 cease generation order and denial of the company’s request for rehearing on the issue (10808-058).
FERC dismissed Boyce’s arguments that the commission didn’t consider corrective measures the dam had already taken; that it doesn’t have authority to order a dam to shut down; and that the cease generation order was arbitrary and capricious. FERC has been threatening to close Edenville since late last spring.
The commission last month gave Boyce until March 1 to correct violations, some of which that have persisted since 2004, including:
Failing to increase spillway capacity to address the increased likelihood of more frequent flooding;
Performing unauthorized dam repairs and excavation;
Neglecting to file a public safety plan or follow its own water monitoring plan; and
Failing to acquire all property rights and to construct required recreation facilities near the dam.
FERC has repeatedly told Boyce to construct two auxiliary spillways to reduce the risk of flooding, “a grave danger to the public,” the commission wrote.
“Boyce Hydro’s license includes terms and conditions concerning dam safety, property rights, water quality, public recreation and safety, and other areas of public concern,” the commission said. “Boyce Hydro has a long history of noncompliance with those terms and conditions … [and] failed to comply … except for the obligations to acquire and document certain property rights (although the lack of designs for the new and revised spillways makes it difficult to determine if it has acquired all necessary property rights).”
Edenville Dam spillway
The commission in January granted Boyce a temporary stay of shutdown until the beginning of March so the company can use the dam’s powerhouse to pass flows to alleviate ice formation on spillway gates during winter. (See Michigan Dam Faces Shutdown over Longtime Safety Concerns.)
FERC said Edenville’s current spillway can only currently handle 50% of a probable maximum flood.
The commission ordered Boyce last year to file plans to construct spillways and provide public access and recreational facilities by late 2017, but the filings never materialized, it said. Although Boyce had hired an engineering firm to design a new spillway and promised to create an escrow account for 50% of its gross revenues to fund construction, FERC found those plans insufficient, saying that it would take the company two years to save enough money to fund spillway construction.
“Given that the public has already been at risk for more than 13 years due to the licensee’s refusal to remediate the project spillways, we cannot accept a proposal that will perpetuate the problem even longer,” FERC said.
The commission expressed disbelief that Boyce’s lengthy history of noncooperation would change now.
“After weighing the relevant factors, commission staff determined that the violations required prompt action and that the licensee’s persistent pattern of noncompliance provided strong evidence that it would not make serious efforts to come into compliance absent an order disrupting its operation,” the commission wrote.
FERC said it didn’t take the economic impacts of a shutdown lightly but said the move is “a situation of Boyce Hydro’s own making.”
Boyce can seek a rehearing of the order before a FERC administrative law judge within 30 days.
A distributed energy resource trade group is calling on MISO to open its markets to customer-owned demand response and urging state regulators and utilities to develop programs that reimburse small DR providers.
The Advanced Energy Management Alliance (AEMA) last week issued a white paper containing model Tariff language intended to extend access to MISO’s wholesale markets to customer-owned demand-side resources.
The white paper suggests that states in the RTO’s footprint adopt DR programs like those in New York and the portion of Indiana in PJM.
| Advanced Energy Management Alliance
“While not new to the Midwest, the growth and development of demand response in the region has largely stagnated,” AEMA wrote. “To create shared value for utilities and consumers, states should take near-term action to create robust demand response programs where demand response is lacking and evolve demand response program design in territories that have had the same tariffs for over a decade.”
Like in the PJM area of Indiana, AEMA suggests having utility-qualified DR providers register their customers with a utility, which would then enroll the customers in MISO’s DR program. The utility would receive capacity credit for customers they enroll, and DR providers would get either an average price from MISO’s annual capacity auction or 35% of the net cost of new entry. AEMA said the approach would be “an effective means for stimulating cost-effective DR while working within existing state and MISO market constructs.”
As an alternative, AEMA said MISO could adopt New York-style programs that concentrate on reducing transmission and distribution costs and stay independent of wholesale capacity programs.
The organization also said that if states agree, MISO could devise Tariff rules for peak load management, distribution-level services and, eventually, additional wholesale market programs.
AEMA also suggested that Midwestern states allow bilateral contracting between utilities and DR providers. Under this scenario, the utility and the provider contract for a specific number of megawatts for enrollment, a price per megawatt and program design — including the terms of dispatch.
“AEMA is eager to collaborate with MISO-based utilities, regulators and system operators in this endeavor. Our goal is not to overturn existing bans that prohibit demand response providers from directly enrolling customers in wholesale market programs, but instead to develop new creative approaches to exploiting the full potential of demand response,” the group said.
It said new DR resources are less expensive than running aging generation.
“Energy leaders in the Midwest should not let excess capacity stop them from pursuing all cost-effective demand response,” the organization said.
AEMA Executive Director Katherine Hamilton said the white paper is a “roadmap” for state regulators and utilities.
“We hope that this white paper is used as intended — to inform and offer options for regulators and utilities seeking to partner with third-party providers and consumers. AEMA members seek to grow our businesses while giving consumers additional choices and providing cost-effective, environmentally sustainable services to the electric grid,” Hamilton said.
Several utilities in MISO states have interruptible DR programs, but AEMA said those programs need to evolve.
MISO had 10.7 GW of wholesale DR capacity in 2016, 8.9% of its annual load peak. The RTO’s DR is mostly derived from interruptible load and behind-the-meter generation under state-regulated and utility-run programs and accredited as load-modifying resources or emergency demand resources.
FERC last week authorized an ITC Holdings subsidiary to purchase transmission assets from a small southwestern Michigan city.
The ruling authorizes Michigan Electric Transmission Co. to spend $201,206 to buy transmission assets at the Black River Substation from the City of Holland Board of Public Works (EC18-21). The assets include surge arrestors, relay panels, circuit breakers, backup relays and disconnect switches that Michigan Electric plans to use in its transmission operations.
ITC transmission | ITC
The commission said the acquisition was consistent with the public interest and won’t hinder competition in the area. Michigan Electric has also pledged to hold all transmission customers harmless from any transaction costs for five years.
“The proposed transaction does not involve any change in ownership or control of any generating facilities. Accordingly, the proposed transaction will not have any impact on concentration in any relevant market,” FERC said. The commission also said that prior experience suggests that sales involving only the transfer of transmission facilities are unlikely to result in uncompetitive activity.
FERC last week declined to grant Ameren additional transmission incentive rates for portions of the company’s 500-mile Grand Rivers project in Illinois and Missouri.
Ameren sought a 100-basis-point incentive adder for the return on equity for the Illinois Rivers and Mark Twain components of the project, which is intended to create a continuous 345-kV path from Iowa to Indiana. The company also requested authorization to assign the incentive to any affiliate that undertakes the development, construction or ownership of those portions of the project.
Grand River Project | Ameren
The commission said the segments were already too far developed to be considered risky enough for incentive rate treatment (ER18-463).
“We find that, due to the late stage of … development, including the substantial completion of the Illinois Rivers component, Ameren Transmission has failed to demonstrate that the remaining risks and challenges associated with the components warrant the requested ROE incentive,” the commission sad. “A project that is further along in construction and thus closer to completion typically faces fewer remaining risks and challenges, and we find that is true here.”
FERC agreed with the contention by the Organization of MISO States and the Missouri Public Service Commission that Ameren had already spent 77% of its cost estimate on the two lines when it asked for the rate incentive in mid-December, when permitting risks were minimal and already covered by a previously approved abandonment incentive. Ameren had argued that the two lines face “unprecedented” risks that are not covered by its other rate incentives.
The commission has previously granted several incentives for the Grand Rivers Project, including 100% construction-work-in-progress recovery, abandoned-plant recovery, a hypothetical capital structure and the authority to assign incentives to affiliated entities.
New generators seeking interconnections must be equipped to provide primary frequency response, FERC ruled Thursday (Order 842, RM16-6).
The commission said the requirement that generators have governors or other equipment to respond automatically to frequency disturbances must be included in the pro forma generator interconnection agreements (GIAs) for both large (20 MW+) and small generators.
The rules will apply to new generation and existing generators that seek a new interconnection agreement because of “material modifications” to their facilities. The commission declined to order existing generators to retrofit their facilities to provide the service, saying it would be “prohibitively expensive” for some.
The final rule makes only small changes from the commission’s November 2016 Notice of Proposed Rulemaking, which cited concerns by NERC and others that frequency response has declined with the loss of traditional synchronous generation and the increase in asynchronous renewables. (See FERC: Renewables Must Provide Frequency Response.)
The commission cited a 2010 NERC survey that found only 30% of generators in the Eastern Interconnection provided primary frequency response and that only 10% provided “sustained” response. The commission said the existing pro forma large GIA — which required primary frequency response from only synchronous generating facilities — does not reflect technological advances allowing nonsynchronous generation to provide the service.
The commission set operating requirements of a maximum droop setting of 5% and a deadband setting of ±0.036 Hz.
“We find that the establishment of minimum uniform operating requirements for all newly interconnecting generating facilities is preferable to the fragmented and inconsistent primary frequency response settings currently in place throughout the Eastern and Western Interconnections,” FERC said. ERCOT already has minimum frequency response requirements, FERC noted.
FERC agreed with recommendations by the Edison Electric Institute and the Western Interconnection Regional Advisory Body that it modify the rule to explicitly prohibit interconnection customers from blocking their governors’ ability to respond to frequency deviations.
“One of the commission’s concerns with the current lack of clear, uniform primary frequency response requirements is NERC’s finding indicating that a number of generator owners/operators have implemented operating settings that have effectively removed the availability of their generating facilities from providing timely and sustained primary frequency response (e.g., wide deadband settings, uncoordinated plant-level controls). The reforms adopted in this final rule, to be applied uniformly to new generating facilities, are intended to eliminate these practices.”
The commission disagreed with the National Rural Electric Cooperative Association’s (NRECA) contention that the rule is premature, saying “adopting these requirements now is more prudent than waiting until the lack of primary frequency response undermines grid reliability, a point acknowledged by NERC’s Essential Reliability Services Task Force.”
Headroom, Compensation
The commission rejected EEI’s proposal that generators be required to maintain headroom — allowing them to increase output in response to low frequency — and receive compensation for doing so. “If future conditions necessitate a headroom requirement, we will then consider any appropriate compensation,” it said.
FERC also said it would consider on a case-by-case basis requests from transmission providers seeking to impose a headroom requirement “in a particular factual circumstance” that includes a compensation mechanism.
The commission said compensation is not necessary because “the cost of installing, maintaining and operating a governor or equivalent controls is minimal.” FERC estimated the cost of adding governors to new wind and solar generators would average $3,300/MW, about 0.2% of total capital costs for wind and solar.
FERC also rejected requests that it order compensation for traditional generators that provide inertial response. “No commenter asserts that inertial response trends on the Eastern and Western Interconnections are approaching levels that could threaten reliability. In addition, because inertial response is provided automatically by the rotating mass of synchronous machines as system frequency deviates and is not controllable, synchronous generating facilities do not incur additional incremental costs to provide inertial response,” the commission said.
Exceptions and Accommodations
The commission exempted or offered accommodations to some classes of resources:
Combined heat and power (CHP) generators that are sized to serve onsite load and have no ability to export power to the grid will be exempt from the operating requirements but must install a governor “in the event that there is an increased need in the future for primary frequency response capability.”
Energy storage will only be required to provide frequency response within specified operating ranges representing minimum and maximum states of charge. The commission said the accommodation would prevent the premature degradation of storage resources.
Distributed energy resources will be required to provide frequency response only when they are allowed to ride through disturbances, the commission said in response to Xcel Energy’s concern that dynamic frequency response at the distribution level can interfere with anti-islanding protections. The rule does “not supersede a generating facility’s ride-through settings or require an interconnection customer to override anti-islanding protection or any protective relaying that has been set to disconnect the generating facility during certain abnormal system conditions,” the commission said.
Nuclear generators are exempt from the rule because their licenses with the Nuclear Regulatory Commission often restrict providing frequency response.
No Exemption for Wind, Small Generators
Wind generation must comply with the requirement, the commission said, rejecting an exemption request by Sunflower Electric Power and Mid-Kansas Electric.
“Unlike certain CHP or nuclear generating facilities, the record does not indicate that there is an economic, technical or regulatory basis for a generic exemption for newly interconnecting wind generating facilities,” FERC said. “In particular, we are persuaded by [the American Wind Energy Association’s] assertion that the proposed primary frequency response capability requirements can be met at low cost for new wind projects, and that newly interconnecting wind facilities should not have difficulty complying.”
Small generators also will not be exempt. The commission said the rule will not result in “unduly burdensome” costs or create a barrier to entry, noting that PJM has not seen a decrease in small generator interconnections since it required nonsynchronous generation to install enhanced inverters with frequency response capability. “We are persuaded by commenter assertions that that small generating facilities are making up a growing percentage of the generation resource mix, and that as the market penetration of small generating facilities increases, there will be a growing need for primary frequency response from these generating facilities,” FERC said.
The commission rejected NRECA’s request that individual balancing authorities be permitted to seek waivers from the rule but agreed that “unique circumstances or needs of some individual regions or areas may warrant different operating requirements.” FERC said it would consider variations based on Regional Entity reliability requirements; variations that are “consistent with or superior to” the final rule; and “independent entity variations” filed by RTOs and ISOs.
The revised GIAs are due 70 days after publication of the rule in the Federal Register.
