
[Federal Register Volume 82, Number 163 (Thursday, August 24, 2017)]
[Proposed Rules]
[Pages 40081-40085]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2017-17952]


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DEPARTMENT OF ENERGY

Federal Energy Regulatory Commission

18 CFR Part 35

[Docket No. RM16-6-000]


Essential Reliability Services and the Evolving Bulk-Power 
System--Primary Frequency Response: Notice of Request for Supplemental 
Comments

AGENCY: Federal Energy Regulatory Commission, Department of Energy.

ACTION: Request for supplemental comments.

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[[Page 40082]]

SUMMARY: On November 17, 2016, the Federal Energy Regulatory Commission 
(Commission) issued a Notice of Proposed Rulemaking (NOPR) that, among 
other things, proposed to revise the Commission's regulations to 
require all newly interconnecting large and small generating 
facilities, both synchronous and non-synchronous, to install and enable 
primary frequency response capability as a condition of 
interconnection. In this document, the Commission seeks supplemental 
comments related to whether and when electric storage resources should 
be required to provide primary frequency response, and the costs 
associated with primary frequency response capabilities for small 
generating facilities.

DATES: Comments are due September 14, 2017.

ADDRESSES: You may submit comments, identified by Docket No. RM16-6-
000, by any of the following methods:
     Electronic filing through http://www.ferc.gov. Documents 
created electronically using word processing software should be filed 
in native applications or print-to-PDF format and not in a scanned 
format. Commenters filing electronically do not need to make a paper 
filing.
     Mail/Hand Delivery: Commenters unable to file comments 
electronically may mail or hand deliver comments to: Federal Energy 
Regulatory Commission, Secretary of the Commission, 888 First Street 
NE., Washington, DC 20426.

FOR FURTHER INFORMATION CONTACT: 
    Jomo Richardson (Technical Information), Office of Electric 
Reliability, Federal Energy Regulatory Commission, 888 First Street 
NE., Washington, DC 20426, (202) 502-6281, Jomo.Richardson@ferc.gov.

    Mark Bennett (Legal Information), Office of the General Counsel, 
Federal Energy Regulatory Commission, 888 First Street NE., Washington, 
DC 20426, (202) 502-8524, Mark.Bennett@ferc.gov.

SUPPLEMENTARY INFORMATION: 
    1. On November 17, 2016, the Federal Energy Regulatory Commission 
(Commission) issued a Notice of Proposed Rulemaking (NOPR) \1\ that 
proposed to modify the pro forma Large Generator Interconnection 
Agreement (LGIA) and the pro forma Small Generator Interconnection 
Agreement (SGIA), pursuant to its authority under section 206 of the 
Federal Power Act (FPA) to ensure that rates, terms and conditions of 
jurisdictional service remain just and reasonable and not unduly 
discriminatory or preferential.\2\ As modified, the pro forma LGIA and 
pro forma SGIA would require all new large and small generating 
facilities, both synchronous and non-synchronous, to install, maintain, 
and operate equipment capable of providing primary frequency response 
as a condition of interconnection. The Commission also proposed certain 
operating requirements, including minimum requirements for droop and 
deadband parameters, and requirements to ensure the timely and 
sustained response to frequency deviations in the pro forma LGIA and 
pro forma SGIA. In this document, the Commission seeks supplemental 
comments related to whether and when electric storage resources should 
be required to provide primary frequency response, and the costs 
associated with primary frequency response capabilities for small 
generating facilities.
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    \1\ Essential Reliability Services and the Evolving Bulk-Power 
System--Primary Frequency Response, Notice of Proposed Rulemaking, 
81 FR 85176 (November 25, 2016), 157 FERC ] 61,122 (2016) (NOPR).
    \2\ 16 U.S.C. 824e (2012).
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I. Background

    2. Following a Notice of Inquiry (NOI) that explored a broad range 
of issues regarding primary frequency response and the evolving Bulk-
Power System,\3\ the Commission issued the NOPR at issue in this 
proceeding. In the NOPR, the Commission explained that its proposals 
address concerns that the existing pro forma LGIA contains only limited 
primary frequency response requirements, and those requirements only 
apply to large synchronous generating facilities, and do not reflect 
recent technological advancements enabling new large and small non-
synchronous generating facilities to install the capability to provide 
primary frequency response.\4\ Further, the Commission stated that to 
avoid establishing new requirements that could be unduly discriminatory 
or preferential, the proposed reforms would impose comparable primary 
frequency response requirements on both new large and small generating 
facilities.\5\ In addition, the Commission did not propose to: (1) 
Apply these requirements to generating facilities regulated by the 
Nuclear Regulatory Commission; (2) impose a headroom requirement; or 
(3) mandate that new generating facilities receive compensation for 
complying with the proposed requirements, noting that a public utility 
is not prohibited from filing a proposal for primary frequency response 
compensation under FPA section 205,\6\ if it so chooses.\7\
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    \3\ Essential Reliability Services and the Evolving Bulk-Power 
System--Primary Frequency Response, 154 FERC ] 61,117 (2016).
    \4\ NOPR, 157 FERC ] 61,122 at PP 2, 11, 13.
    \5\ Id. P 2.
    \6\ 16 U.S.C. 824d (2012).
    \7\ Id. PP 1, 55.
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    3. In the NOPR, the Commission explained that the proposed 
requirements will help ensure adequate primary frequency response 
capability as the resource mix continues to evolve, with fair and 
consistent treatment for all types of generating facilities, and will 
help balancing authorities meet their frequency response obligations 
under NERC Reliability Standard BAL-003-1.1.\8\
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    \8\ Id. P 43. In January 2014, the Commission approved 
Reliability Standard BAL-003-1 requiring balancing authorities to 
meet a minimum required Frequency Response Obligation. While 
Reliability Standard BAL-003-1 establishes requirements for 
balancing authorities, it does not impose requirements on individual 
generating facilities. Frequency Response and Frequency Bias Setting 
Reliability Standard, Order No. 794, 146 FERC ] 61,024 (2014).
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II. Request for Comments

A. Electric Storage Resources

    4. The NOPR proposals did not propose provisions specific to 
electric storage resources. Several commenters raise concerns that, by 
failing to address electric storage resources' unique technical 
attributes, the NOPR requirements could pose an unduly discriminatory 
burden on electric storage resources. The Energy Storage Association 
(ESA) asserts that the proposed requirements could result in unique, 
adverse impacts on electric storage resources. Particularly, ESA states 
that the proposed use of nameplate capacity as the basis for primary 
frequency response service and the fact that electric storage resources 
are capable of operating at the full range of their capacity (i.e., 
they have no minimum set point) will require storage to provide a 
``greater magnitude of [primary frequency response] service than 
traditional generating facilities.'' \9\ ESA also explains that while 
traditional generating facilities would have no primary frequency 
response obligations while offline, electric storage resources are 
always online, even when not charging or discharging, and under the 
requirements proposed in the NOPR, they would therefore be required to 
provide primary frequency response on a more frequent basis than 
generating facilities that can go offline.\10\ Further, ESA explains 
that the optimal depth of discharge differs among various electric 
storage technologies, and exceeding the optimal depth of discharge 
accelerates the degradation of the facility and

[[Page 40083]]

increases operations and maintenance costs.\11\
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    \9\ ESA Comments at 4.
    \10\ Id. at 3-4.
    \11\ Id.
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    5. To address its concerns, ESA requests that the Final Rule: (1) 
Allow electric storage resources to specify a minimum set point for the 
purposes of primary frequency response capability as a condition of 
interconnection; and (2) include inadequate state of charge as an 
operational constraint that would relieve electric storage resources 
from the sustained response requirement.\12\ In the absence of these 
changes, ESA requests an exemption from the proposed primary frequency 
response requirements.\13\ In its comments, AES Companies (AES) seeks a 
complete exemption from the proposed NOPR requirements for electric 
storage resources.\14\ AES also asserts that a droop requirement of 
five percent would needlessly limit the contribution that electric 
storage resources that are specifically designed for primary frequency 
response can make to grid stability.\15\
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    \12\ Id. at 4-5.
    \13\ Id. at 5.
    \14\ AES Comments at 17 and 19 (specifying changes to the 
proposed pro forma language).
    \15\ Id. at 6-7.
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    6. In light of these concerns, the Commission seeks additional 
information to better understand 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 ESA and others. Accordingly, the Commission seeks 
comment on the following questions:
    1. Some commenters state that certain proposed requirements are not 
appropriate for electric storage resources, in particular, certain of 
the proposed settings related to droop (e.g., basing the droop 
parameter on nameplate capacity) and the requirement for timely and 
sustained response to frequency deviations.
    a. Are there challenges or operational implications (e.g., unusual 
or excessive wear and tear) of requiring electric storage resources to 
implement the proposed operating settings for droop (including basing 
the droop parameter on nameplate capacity), deadband, and timely and 
sustained response? If so, please provide an explanation, and explain 
how these challenges are different than those faced by other 
synchronous and non-synchronous generating facilities.
    b. Also, please explain whether and how possible impacts of the 
proposed requirements on electric storage resources vary by their state 
of charge, and whether those possible impacts are the same or different 
for all electric storage technologies. If these impacts vary by the 
type of electric storage technology, please elaborate.
    c. If the proposed operating settings for droop, deadband, and 
sustained response would cause any operational or other concerns unique 
to electric storage resources that would justify different operating 
settings than those proposed in the NOPR, what minimum requirements for 
droop, deadband, and timely and sustained response might be more 
appropriate for the effective provision of primary frequency response 
from electric storage resources? Or are there parameters other than 
those discussed in the NOPR (e.g., droop, deadband) that are more 
applicable to electric storage resources that could be used to 
accomplish effective timely and sustained primary frequency response? 
If so, what would those parameters be?
    2. Are there risks associated with requiring electric storage 
resources, which are energy-limited, to provide timely and sustained 
primary frequency response, such as possible adverse effects on an 
electric storage resource's ability to fulfill other obligations (e.g., 
providing energy or other ancillary services)?
    3. Please describe the relationship between electric storage 
resources being online and the provision of primary frequency response.
    a. Are electric storage resources that are always online available 
on a more frequent basis to provide primary frequency response than 
generating facilities that start-up and shut-down (i.e., go offline)? 
If so, please elaborate on possible operational or other impacts, if 
any, that the proposed requirements may have on generating facilities 
that are always online, as compared to generating facilities that go 
offline.
    b. Please discuss whether it is possible to ``turn off'' an 
electric storage resource's primary frequency response capability 
(i.e., disable the ability to respond to frequency deviations without 
physically disconnecting from the grid) when the electric storage 
resource is neither charging nor discharging and not providing other 
services (e.g., energy or other ancillary services) to the power 
system. To the extent possible, please explain if this ability would 
vary by the type of electric storage technology.
    4. Please explain what is meant by ``minimum set point'' and 
elaborate on how and by whom it would be defined and determined.
    a. Could possible adverse impacts of the proposed primary frequency 
response requirements on electric storage resources be minimized or 
eliminated, if owners/operators of such resources or another entity 
were allowed to establish a minimum set point for the provision of 
primary frequency response service? If so, please elaborate.
    b. Would the primary frequency response requirements proposed in 
the NOPR result in electric storage resources that have no such minimum 
set point providing a greater magnitude of primary frequency response 
for a given frequency deviation than other generating facilities of 
equal nameplate capacity that have a minimum set point? Please provide 
an explanation as to why this is or is not the case.
    c. How and in what ways would the implementation of such a minimum 
set point change an electric storage resource's response to frequency 
deviations, as compared to other generating facilities that do not 
implement a minimum set point? As part of this explanation, please 
explain whether the implementation of a minimum set point would: (1) 
Limit the provision of primary frequency response for electric storage 
resources to a megawatt (MW) range (i.e., between a minimum value and 
the nameplate capacity of the electric storage resource); (2) be used 
in lieu of nameplate capacity as the basis of the droop curve (i.e., 
reduce the expected proportional MW response to frequency deviations 
below that of other generating facilities of equivalent nameplate 
capacity for a given percentage droop (e.g., a 5 percent droop)); or 
(3) be used in some other way.
    d. If owners/operators of electric storage resources or another 
entity were allowed to establish a minimum set point for the purposes 
of primary frequency response:
    i. How would they determine the appropriate value of the minimum 
set point for a given electric storage resource? What technical 
characteristics or economic factors should be considered in 
establishing a minimum set point for the various types of electric 
storage resources?
    ii. Should the minimum set point be static, or dynamic and subject 
to change based on technical or other factors? If it is subject to 
change, please explain the factors that would warrant such changes.
    iii. Should owners/operators of electric storage resources be 
required to specify in their interconnection agreements the value of 
the minimum set point and indicate whether it is

[[Page 40084]]

static or dynamic? In what manner should this information be provided 
to the relevant balancing authority?
    5. Please explain what is meant by ``inadequate state of charge'' 
and elaborate on how and by whom it would be defined and determined.
    a. Could possible adverse impacts of the proposed primary frequency 
response requirements on electric storage resources be minimized or 
eliminated if owners/operators of such resources or another entity were 
allowed to define inadequate state of charge as an explicit operational 
constraint relieving electric storage resources from providing 
sustained response when in that ``inadequate'' state? If so, please 
elaborate.
    b. If owners/operators of electric storage resources or another 
entity were allowed to define inadequate state of charge as an 
operational constraint for electric storage resources:
    i. How would they determine what level of charge is ``inadequate'' 
thus preventing electric storage resources from providing sustained 
primary frequency response output?
    ii. Should the inadequate state of charge parameter be static, or 
dynamic and subject to change based on technical or other factors? If 
it is subject to change, please explain the factors that would warrant 
such changes.
    iii. Should owners/operators of electric storage resources be 
required to specify in their interconnection agreements a parameter for 
``inadequate state of charge'' and indicate whether it is static or 
dynamic? In what manner should this information be provided to the 
relevant balancing authority?
    6. What impacts, if any, would owners/operators of electric storage 
resources experience if their resources are not allowed to maintain a 
specified range of state of charge?
    a. Is there a certain range of state of charge (expressed as a 
percentage of total charge) that would enable an electric storage 
resource to provide primary frequency response without possible adverse 
impacts?
    b. Would this range be the same for all electric storage resources, 
or would it depend on the particular technology of a given electric 
storage resource and/or the duration that the resource could sustain 
its output?
    c. Are there differences in terms of adverse impacts on an electric 
storage resource depending on whether its state of charge is low (e.g., 
five percent remaining charge) or high (e.g., 98 percent remaining 
charge)? If so, please elaborate.
    d. To the extent there are adverse impacts, would they differ for 
different electric storage technologies? If so, please elaborate.
    7. In lieu of (1) establishing a minimum set point for electric 
storage resources and (2) including an inadequate state of charge as an 
operational constraint, could owners/operators of all or certain types 
of electric storage resources or another entity specify an operating 
range \16\ outside of which electric storage resources would not be 
required to provide and/or sustain primary frequency response to 
prevent adverse impacts on the electric storage resources?
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    \16\ For the purposes of this document, ``operating range'' is 
defined as minimum state of charge, maximum state of charge, maximum 
rate of charge, and maximum rate of discharge.
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    a. Would it be possible to base such an operating range on 
manufacturer specifications and, if so, would establishing such an 
operating range potentially address concerns about the harm to the 
resource, degradation of its useful life, or other potential adverse 
impacts?
    b. Would it be possible to specify such an operating range at the 
time of interconnection and include the operating range in the 
interconnection agreement? By what means should the operating range be 
communicated to the relevant balancing authority?
    8. Are there other mechanisms or ways to address the concerns 
raised by ESA and others on the proposed primary frequency response 
requirements instead of: (1) Establishing a minimum set point and 
including an inadequate state of charge as an operational constraint; 
or (2) establishing an operating range as described above.

B. Small Generating Facilities

    7. In the NOPR, the Commission proposed that small generating 
facilities be subject to new primary frequency response requirements in 
the pro forma SGIA. The Commission stated that the record indicates 
that small generating facilities are capable of installing and enabling 
governors at low cost in a manner comparable to large generating 
facilities.\17\
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    \17\ NOPR, 157 FERC ] 61,122 at P 41 (citing IEEE-P1547 Working 
Group Comments at 1, 5, and 7).
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    8. Some commenters raise concerns that small generating facilities 
could face disproportionate costs to install primary frequency response 
capability.\18\ For example, the Public Interest Organizations state 
that the Commission's discussion of the economic impact on small 
generating facilities of installing primary frequency response 
capability is limited, and claims the information in the NOPR does not 
directly support the Commission's conclusion that ``small generating 
facilities are capable of installing and enabling governors at low cost 
in a manner comparable to large generating facilities.'' \19\ Public 
Interest Organizations encourage the Commission to further investigate 
the cost for small renewable energy generating facilities to install 
frequency response capability before making the proposed revisions to 
the pro forma SGIA.\20\ National Rural Electric Cooperative Association 
(NRECA) asserts that the record is insufficient to conclude that the 
proposed primary frequency response capability requirement will not 
pose an undue burden on smaller generating facilities.\21\
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    \18\ Public Interest Organizations Comments at 3; NRECA Comments 
at 8.
    \19\ Public Interest Organizations Comments at 3 (citing NOPR, 
157 FERC ] 61,122 at P 42).
    \20\ Id. at 3-4.
    \21\ NRECA Comments at 8.
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    9. Other commenters request that the Commission consider a size 
limitation. In particular, Idaho Power Company (Idaho Power), NRECA, 
and Tennessee Valley Authority (TVA) request the Commission adopt a 
size limitation for applying the NOPR requirements.\22\
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    \22\ Idaho Power Comments at 2; NRECA Comments at 8; TVA 
Comments at 3-4.
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    10. To augment the record regarding the ability of small generating 
facilities to comply with the proposed primary frequency response 
requirements, and their potential economic impact, the Commission seeks 
comment on the following questions:
    1. Are the costs for small generating facilities to install, 
maintain, and operate governors or equivalent controls proportionally 
comparable to the costs for large generating facilities? If costs are 
proportionally higher for small generating facilities to install, 
maintain, and operate governors or equivalent controls, what accounts 
for these higher costs? Quantify, to the extent possible, any general 
differences in these costs between small and large generating 
facilities.
    2. If small generating facilities were required to comply with the 
proposed primary frequency response requirements, do recent 
technological advances in primary frequency response capability 
minimize or eliminate possible barriers to entry of small generating 
facilities? If not, in what specific ways could the proposed 
requirements be a barrier to entry? Should such negative impacts occur, 
please discuss means by which the

[[Page 40085]]

Commission could potentially mitigate or eliminate them?
    3. Is an exemption appropriate for all or a subset of small 
generating facilities based on possible disproportionate cost impacts 
of installing the capability to provide primary frequency response? If 
so, please provide specific cost data demonstrating that is the case.
    4. Given their increasing market penetration and operational role 
in the Bulk-Power System, please discuss the extent to which small 
generating facilities are necessary to ensure adequate primary 
frequency response.
    5. Please discuss whether PJM Interconnection, L.L.C.'s (PJM's) 
recent changes to its interconnection agreements, which require new 
large and small non-synchronous generating facilities to install 
enhanced inverters that include primary frequency response 
capability,\23\ address concerns regarding possible disproportionate 
costs or barriers resulting from applying the NOPR proposals to the 
entire set of small generating facilities. If yes, please discuss the 
viability of applying PJM's approach in other regions.
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    \23\ See NOPR, 157 FERC ] 61,122 at P 42 (citing PJM 
Interconnection, L.L.C., 151 FERC ] 61,097, at P 28 (2015)).
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III. Comment Procedures

    11. The Commission invites interested persons to submit comments on 
the matters and issues proposed in this document to be adopted, 
including any related matters or alternative proposals that commenters 
may wish to discuss. Comments are due September 14, 2017. Comments must 
refer to Docket No. RM16-6-000, and must include the commenter's name, 
the organization they represent, if applicable, and their address in 
their comments.
    12. The Commission encourages comments to be filed electronically 
via the eFiling link on the Commission's Web site at http://www.ferc.gov. The Commission accepts most standard word processing 
formats. Documents created electronically using word processing 
software should be filed in native applications or print-to-PDF format 
and not in a scanned format. Commenters filing electronically do not 
need to make a paper filing.
    13. Commenters that are not able to file comments electronically 
must send an original of their comments to: Federal Energy Regulatory 
Commission, Secretary of the Commission, 888 First Street NE., 
Washington, DC 20426.
    14. All comments will be placed in the Commission's public files 
and may be viewed, printed, or downloaded remotely as described in the 
Document Availability section below. Commenters on this proposal are 
not required to serve copies of their comments on other commenters.

IV. Document Availability

    15. In addition to publishing the full text of this document in the 
Federal Register, the Commission provides all interested persons an 
opportunity to view and/or print the contents of this document via the 
Internet through FERC's Home Page (http://www.ferc.gov) and in FERC's 
Public Reference Room during normal business hours (8:30 a.m. to 5:00 
p.m. Eastern time) at 888 First Street NE., Room 2A, Washington, DC 
20426.
    16. From FERC's Home Page on the Internet, this information is 
available on eLibrary. The full text of this document is available on 
eLibrary in PDF and Microsoft Word format for viewing, printing, and/or 
downloading. To access this document in eLibrary, type the docket 
number excluding the last three digits of this document in the docket 
number field.
    17. User assistance is available for eLibrary and the FERC's Web 
site during normal business hours from FERC Online Support at 202-502-
6652 (toll free at 1-866-208-3676) or email at 
ferconlinesupport@ferc.gov, or the Public Reference Room at (202) 502-
8371, TTY (202) 502-8659. Email the Public Reference Room at 
public.referenceroom@ferc.gov.

    By direction of the Commission.

    Issued: August 18, 2017.
Nathaniel J. Davis, Sr.,
Deputy Secretary.
[FR Doc. 2017-17952 Filed 8-23-17; 8:45 am]
 BILLING CODE P


