UNITED STATES OF AMERICA
BEFORE THE

FEDERAL ENERGY REGULATORY COMMISSION

Essential Reliability Services and)

the Evolving Bulk-Power System— )Docket No. RM16-6-000

Primary Frequency Response)

SUPPLEMENTAL COMMENTS OF THE ISO-RTO COUNCIL ON
NOTICE OF PROPOSED RULEMAKING REGARDING

PRIMARY FREQUENCY RESPONSE

Pursuant to the Federal Energy Regulatory Commission’s (the “Commission” or “FERC”) Notice of Request for Supplemental Comments issued on August 18, 2017,1 the ISO-RTO Council (“IRC”)2 respectfully submits these supplemental comments.

I.BACKGROUND

On  November17,2016,  the  Commission  issued  a  Notice  of  Proposed

Rulemaking3 proposing revisions to its pro forma Large Generator Interconnection
Agreement (“LGIA”)  and pro  forma Small  Generator  Interconnection  Agreement
(“SGIA”) to require new large and small generating facilities, both synchronous and non-

1 Essential Reliability Services and the Evolving Bulk-Power System - Primary Frequency Response, Notice of Notice of Request for Supplemental Comments, 160 FERC ¶ 61,011 (Aug. 18, 2017) (“Request for Supplemental Comments”).

2 The IRC comprises the Alberta Electric System Operator (“AESO”), California Independent System
Operator (“CAISO”), Electric Reliability Council of Texas, Inc. (“ERCOT”), the Independent Electricity
System  Operator  of  Ontario,  Inc. (“IESO”),  ISO  New  England,  Inc. (“ISO-NE”),  Midcontinent

Independent System Operator, Inc. (“MISO”), New York Independent System Operator, Inc. (“NYISO”), PJM Interconnection, L.L.C. (“PJM”), and Southwest Power Pool, Inc. (“SPP”).  The AESO and ERCOT are not subject to the Commission’s jurisdiction with respect to the matters addressed in this rulemaking and, therefore, do not join these comments.

3 Essential Reliability Services and the Evolving Bulk-Power System - Primary Frequency Response, Notice of Proposed Rulemaking, 157 FERC ¶ 61,122 (Nov. 17, 2016) (“NOPR”).

synchronous, to install, maintain, and operate equipment capable of providing primary frequency response as a condition of interconnection.4  Multiple parties, including the IRC,5 filed comments in response to the NOPR.  In response to certain comments, the Commission issued the Request for Supplemental Comments to better understand the possible ramifications of the proposed primary frequency response requirements on electric storage resources and small generators.

II.COMMENTS

The IRC supports the requirements proposed in the NOPR and the application of
such requirements to all resource types, including electric storage resources and small
generators.  The purpose of the Commission’s proposal is to ensure adequate levels of
primary frequency response continue to exist given the transformation in the resource
mix  and the  Commission’s  concerns  about  declining  frequency response.6   This
transformation includes the retirement of baseload, synchronous generating facilities and
the loss of the inertia and primary frequency response contributions from such generators.
At  the  same  time,  asynchronous  generators,  small  generators,  distributed  energy
resources, and electric storage resources comprise an increasing percentage of the future
generation mix.  Providing an exemption or variation to the NOPR requirements for
small generators and electric storage resources could allow such resources to avoid
solving the very problem to which such resources contribute and the NOPR rules were
meant to address.  In fact, the Commission has conducted recent proceedings exploring

4 Id. at P 44.

5 Comments of the ISO-RTO Council on Notice of Proposed Rulemaking Regarding Primary Frequency Response, Docket No. RM16-6-000 (Jan. 24, 2017) (“IRC NOPR Comments”).

6 Id. at P 3.

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the increased participation of small and storage resources in the wholesale markets.  The performance expectations discussed in those proceedings seems out of synch with an effort to exempt these resources from performance expectations.

The  Commission’s  proposed  requirements  are  consistent  with  guidelines
developed by North American Electric Reliability Corporation (“NERC”) to maintain and
enhance the reliability of the bulk electric system.  As FERC stated in the NOPR, the
NERC Essential Reliability Services Task Force, “…concluded that it is prudent and
necessary to ensure that primary frequency response capabilities are present in the future
generation resource mix, and recommended that all new generators support the capability
to manage frequency.”7  Furthermore, the NERC guidelines on which the NOPR
requirements are based recommend that “…all resources connected to an Interconnection
be equipped with a working governor or equivalent frequency control device” with
response characteristics such as those described in the guidelines8 and proposed in the
NOPR.  Similar to traditional resources and large generators, electric storage resources
and small generators should contribute their fair share of primary frequency response in
accordance with the requirements proposed in the NOPR.

The NOPR proposals are also consistent with current requirements of PJM,
NYISO, ISO-NE, and CAISO.  As stated in its NOPR comments, a number of ISOs and
RTOs already require resources, including small generators and/or electric storage
resources, to install, maintain, and operate equipment capable of providing primary
frequency response as a condition of interconnection.  These requirements have been in

7 Id. at P 15.

8 See NERC Primary Frequency Control Guideline Final Draft, p. 3 (Dec. 2015),

http://www.nerc.com/comm/OC/Reliability%20Guideline%20DL/Primary_Frequency_Control_final.pdf
(“NERC Guideline”).

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place for several years, have not resulted in operational issues or challenges associated
with such requirements, and have not required exemptions for either electric storage
resources or small generators.  Moreover, areas with substantial penetration of renewable
resources already impose a primary frequency response capability requirement on all
resources, with no negative impacts.9  To the best of its knowledge, the IRC is unaware
of any limitations that would render the Commission’s proposed requirements infeasible
or unduly burdensome for electric storage resources or small generators.

III.ANSWERS TO QUESTIONS POSED IN THE REQUEST FOR

SUPPLEMENTAL COMMENTS

In response to the certain questions posed by the Commission, the IRC provides the following.10

A. IRC  Response  Regarding  Challenges,  Operational  Implications,  and

Impacts of the Proposed Requirements on Electric Storage Resources (Questions 1(a), (b), and (c) in Section II A)

The IRC is not aware of any challenges of requiring electric storage resources to
implement the proposed operating settings for droop, deadband, and timely and sustained
response proposed in the NOPR.  Moreover, as stated in section II above, the NOPR
proposal is consistent with NERC guidelines and the current requirements of certain
RTOs and ISOs.

9 For example, in the European Union, all generators seeking to connect to the grid must have primary
frequency response capability.  See ENTSO-E Requirements for Generators, Chapter 1, Article 13 available
at https://electricity.network-codes.eu/network_codes/rfg/.

10 The IRC responds to only certain questions in the Request for Supplemental Comments because many of the questions in the Request for Supplemental Comments are technical questions that are better addressed by electric storage resources, small generators, and their manufacturers.

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B.IRC  Response  Regarding  Risks  Associated  with  Requiring  Electric

Storage Resources to Provide Primary Frequency Response (Question 2 in Section II A)

The IRC is not aware of risks associated with requiring electric storage resources 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).  With regard to sustained response, NERC states in its Reliability Guideline that frequency deviations often persist for longer than one minute, and frequency response should be sustained until the frequency returns to a value within the governor deadband.11  The Commission’s proposed requirements to provide sustained frequency response is consistent with NERC’s guideline and should be applied to both traditional and electric storage resources.

C. IRC Response Regarding the Relationship between Electric Storage

Resources  Being  Online  and  the  Provision  of  Primary  Frequency Response (Question 3(a) and (b) in Section II A)

As the IRC indicated in the IRC NOPR Comments, all newly interconnecting
generating resources, and all existing interconnections that require the submission of a
new interconnection request, should be required to install the capability necessary to
provide primary frequency response and operate in accordance with the settings proposed
in the NOPR.12  Moreover, electric storage resources should be required to provide
primary frequency response in accordance with each RTO’s and ISO’s respective tariff
and in a manner similar to all other resources.  For example, under PJM’s tariff, all
resources, including electric storage resources, that are actively providing energy or

11 NERC Guideline at p. 11.

12 IRC NOPR Comments at p. 2.

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certain ancillary services are expected to provide primary frequency response.  Similarly,
in ISO-NE, the LGIA already requires the provision and maintenance of a functioning
governor on all new generating units comprising the Large Generating Facility in
accordance with applicable provisions of the ISO New England Operating Documents
and applicable Reliability Standards.  ISO New England Operating Procedure No. 14
contains specific frequency response requirements.  If an electric storage resource is
online but is not providing energy or certain ancillary services, it is not expected to
provide primary frequency response, similar to all other resources within PJM.

D. IRC Response Regarding Whether an Exemption is Appropriate for All or

a Subset of Small Generating Facilities (Question 3 in Section II B)

For the reasons stated above in section II, exemptions are not appropriate for small generators or any subset thereof.

E. IRC Response Regarding the Extent to which Small Generating Facilities

are Necessary to ensure Adequate Primary Frequency Response (Question

4 in Section II B)

Given small generators’ increasing market penetration, small generators should be
required to provide adequate primary frequency response in a manner similar to large
generators.  For example, within PJM, 30 new generators were placed in service in the
past year.  Of those, 25 are small generators (i.e., generators having a capacity of no more
than 20 MW) and 5 are large generators.  Similarly, in ISO-NE, 12 new generators were
placed in service in the past year.  Of those, 8 are small generators, and 4 are large
generators.

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F.IRC Response Regarding Whether PJM’s Changes to its Interconnection

Agreements Address Concerns Regarding Costs and Barriers and whether
PJM’s Approach is Viable in other Regions (Question 5 in Section II B)

PJM has not experienced any decrease in the number of interconnections requests or   interconnections   of   small   non-synchronous   generators   since   requiring   nonsynchronous generating facilities to install enhanced inverters that include primary frequency response capability.  The PJM approach is viable in other regions.

IV.CONCLUSION

In response to the Request for Supplemental Comments, the IRC respectfully

requests that the Commission consider the comments contained herein.

Respectfully submitted,

/s/ James M. Burlew/s/ Margoth R. Caley

Craig GlazerRaymond W. Hepper

Vice President-Federal Government PolicyVice President, General Counsel, and

James M. BurlewSecretary

Senior CounselTheodore J. Paradise

PJM Interconnection, L.L.C.Assistant General Counsel, Operations and

2750 Monroe BoulevardPlanning

Audubon, Pennsylvania  19403Margoth R. Caley

james.burlew@pjm.comSenior Regulatory Counsel

ISO New England Inc.

One Sullivan Road

Holyoke, Massachusetts  01040 mcaley@iso-ne.com

/s/ Anna McKenna/s/ Gregory J. Campbell

Roger E. Collanton, General CounselRobert E. Fernandez, General Counsel

Anna McKennaRaymond Stalter

Assistant General Counsel, RegulatoryDirector of Regulatory Affairs

Andrew Ulmer Director, Federal RegulatoryGregory J. Campbell, Attorney

AffairsNew York Independent System Operator,

California Independent System OperatorInc.

Corporation10 Krey Boulevard

250 Outcropping WayRensselaer, NY  12144

Folsom, California  95630gcampbell@nyiso.com

amckenna@caiso.com

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/s/ Andre Porter/s/ Paul Suskie

Andre PorterPaul Suskie

Vice President and General CounselExecutive Vice President & General Counsel

Joseph G. GardnerTessie Kentner

Vice President & Chief Compliance OfficerSenior Attorney

Midcontinent Independent SystemSouthwest Power Pool, Inc.

Operator, Inc.201 Worthen Drive

720 City Center DriveLittle Rock, Arkansas  72223-4936

Carmel, Indiana  46032psuskie@spp.org

aporter@misoenergy.org

/s/ Tam Wagner

Tam Wagner

Senior Manager, Regulatory Affairs Maia Chase

Senior Regulatory Analyst

Independent Electricity System Operator

1600-120 Adelaide Street West

Toronto Ontario  M5H1T1
Canada

tam.wagner@ieso.ca
maia.chase@ieso.ca

October 10, 2017

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CERTIFICATE OF SERVICE

I hereby certify that I have this day served the foregoing document upon each
person designated on the official service list compiled by the Secretary in this proceeding.

Dated at Norristown, PA, this 10th day of October, 2017.

James M. Burlew

Senior Counsel

PJM Interconnection, L.L.C.
2750 Monroe Boulevard
Audubon, PA  19403
(610) 666-4345