UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
Reactive Power Requirements)
for Non-Synchronous Generation)Docket No. RM16-1
___________________)
Comments of the ISO/RTO Council
The ISO/RTO Council submits comments on the proposal of the Federal Energy
Regulatory Commission to revise standard generator interconnection agreements to
eliminate the exemptions for wind generators from the requirement to provide reactive
power.1 If adopted, the Commission’s proposal would require all newly interconnecting
generators that are subject to the interconnection procedures of an independent system
operator (ISO) or regional transmission provider (RTO), including both synchronous and
non-synchronous generators, to provide dynamic reactive power capability to the
electricity grid. This proposal eliminates unduly discriminatory treatment as between
synchronous and non-synchronous resources with respect to the requirement to provide
reactive power capability. Technology enhancements, as well as the relatively modest
incremental cost to non-synchronous resources of providing reactive power capability,
support the Commission’s proposal as just and reasonable. For these reasons, the
ISO/RTO Council urges the Commission to adopt its proposal as soon as possible.
1
Reactive Power Requirements for Non-Synchronous Generation, Proposal to Revise Standard
Generator Interconnection Agreements (Proposal); RM16-1 (2015).
The ISO/RTO Council includes the Alberta Electric System Operator (AESO), the California
Independent System Operator Corporation (CAISO), the Electric Reliability Council of Texas, Inc.,
(ERCOT) the Independent Electricity System Operator (IESO), ISO New England, Inc., (ISO-NE), the
Midcontinent Independent System Operator, Inc. (MISO), the New York Independent System Operator,
Inc. (NYISO), PJM Interconnection, L.L.C., (PJM) and the Southwest Power Pool (SPP). ERCOT, AESO
and IESO are not subject to the Commission’s jurisdiction and are not joining these comments.
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I.Background
Since the adoption of Order 661 and Order 661-A, transmission providers have
had to undertake time-consuming interconnection studies to assess whether a wind
resource needs to provide reactive power capability in order to safely and reliably
interconnect to the grid.2 Last year, the Commission approved tariff revisions submitted by PJM Interconnection that require that all non-synchronous resources, including wind resources, seeking to interconnect to the grid use enhanced inverters and provide
reactive power capability without requiring PJM to demonstrate the need for this
capability in the interconnection study process.3 Other jurisdictions in North America
have also established requirements for non-synchronous resources to provide reactive power capability as a condition of interconnection.4 Last month, the Essential Reliability Services Task Force of the North American Electric Reliability Corporation (NERC)
determined that all new resources need to provide sufficient voltage control as an
essential component of a reliable Bulk Power System.5
2
Interconnection for Wind Energy, Order No. 661, FERC Stats. & Regs. ¶ 31,186, at P 51, order
on reh’g, Order No. 661-A, FERC Stats. & Regs. ¶ 31,198 (2005).
3
PJM Interconnection LLC, 151 FERC ¶ 61,097 (2015)
4
For example, Electric Reliability Council of Texas, Inc. (ERCOT), a region that has well in excess
5
See Abstract of NERC Essential Reliability Task Force Measures Framework Report dated
The Commission is proposing to modify its pro forma large generator
interconnection agreement and pro forma small generator interconnection agreement to
eliminate the current exemption for wind generators from the requirement to provide
reactive power. As a result, all new generators seeking to interconnect to the
transmission system and all existing non-synchronous generators making upgrades to
their generation facilities that require new interconnection requests will need to provide
reactive power capability. The Commission proposes that these resources design their
generating facilities to maintain a composite power delivery at continuous rated power
output at the point of interconnection at a power factor of 0.95 leading to 0.95 lagging,
or a different range if adopted by the transmission provider. Similar to reactive power
provided by synchronous resources, the Commission proposes that reactive power
capability installed by non-synchronous generators must be dynamic. The Commission
also proposes to require that non-synchronous generators maintain the required power
factor range only when the generator’s real power output exceeds 10 percent of its
nameplate capacity.
The ISO/RTO Council generally supports the Commission’s proposed technical
specifications, but requests that the Commission recognize appropriate independent
entity variations and regional differences as part of compliance with a final order in this
proceeding. For example, each ISO and RTO in the ISO/RTO Council does not
uniformly agree that non-synchronous resources should maintain the required power
factor range only when the generator’s real power output exceeds 10 percent of its
nameplate capacity. Instead, each ISO and RTO believes non-synchronous resources
should provide reactive power capability in a manner comparable to synchronous
3
resources, with each ISO/RTO able to establish rules on a showing that their individual situation merits.
II. The Commission’s proposal treats synchronous and non-synchronous
resources in a comparable manner for purposes of reactive power.
As the number and size of non-synchronous resources increases, the
Commission is appropriately proposing to require that all resources interconnecting to
the transmission system provide reactive power capability. By extending this
requirement to non-synchronous resources as a condition of interconnection - for those
generators subject to an ISO’s or RTO’s interconnection process - the Commission is
treating non-synchronous resources in a manner that is comparable to synchronous
resources.
The disparate treatment of wind resources under Order 661 and Order 661-A as
compared to synchronous resources may constitute undue discrimination among
resource types and can create operational challenges.6 Non-synchronous resources
use inverters to convert non-synchronized power into synchronized alternating current
power that can flow on the transmission system. The ISO/RTO Council understands
that current manufacturers routinely include reactive power capability in standard
inverters used by non-synchronous resources, thereby making the cost of reactive
power capability minimal.7 As such, there is no technical reason why non-synchronous
resources should not provide this capability in a manner comparable to synchronous
6
Absent maintaining sufficient voltages, non-synchronous resources may face operational issues.
See e.g. Bonneville Power Administration description of wind facilities having to operate at lower than optimal levels until they could provide voltage control even though Bonneville’s interconnection studies did not detect voltage issues. April 17, 2012 FERC Technical Conference on Reactive Power Resources (AD12-10-000), Transcript at 150:24-152:16.
7
See e.g. Comments of Siemens. April 17, 2012 FERC Technical Conference on Reactive Power
Resources (AD12-10-000), Transcript at 119:21-121:13.
4
resources. By requiring non-synchronous resources to provide reactive power
capability as a condition of interconnection, the Commission can cure this unduly disparate treatment.
Operation and planning of the electric grid requires an adequate level of voltage
support, which is provided by the generation and transmission that make up the grid.
The most efficient and effective means of ensuring there is adequate voltage support
from an operations and planning perspective is to require that all generators subject to
the interconnection procedures of an ISO or RTO provide dynamic reactive power
capability. This establishes a known and consistent baseline of capability to support
system voltage needs. Transmission planners can then remedy any deficiencies
through transmission infrastructure that provides voltage support. This approach is far
more effective than trying to tailor voltage requirements of specific resources (in this
case intermittent resources) relative to a grid that changes all the time. Trying to
determine the voltage requirements of a non-synchronous resources through an
interconnection study specific to a point in time may not reflect reality relative to a
changing grid and creates the potential for voltage deficiencies. Transmission planners
must remedy these deficiencies and they can result in shifting the cost to other entities
(e.g. load paying for transmission equipment). Alternatively, establishing a known
voltage baseline for all resources to provide reactive power capacity mitigates this risk
and supports effective and efficient system operations and planning.
5
III.The cost of providing reactive power capability is not a significant
percentage of overall project development costs for non-synchronous resources.
The cost of including reactive power capability as a percentage of total project
costs is relatively small.8 The ISO/RTO Council recognizes that some entities may
contest this fact and argue that applying a uniform reactive power requirement to non-
synchronous resources creates significant capital cost.9 While the Commission’s
proposed uniform requirement for asynchronous resources to provide dynamic reactive
power capability could impose higher inverter costs on those projects that would
otherwise avoid such requirements through the system impact study approach, these
costs are not significant capital costs. Inverter manufacturers have informed ISO/RTO
Council members that a small percentage of total plant cost is attributable to inverters
and associated equipment. This is a required cost because non-synchronous resources
must use inverters to transfer synchronous power onto the electricity grid. As
referenced above, reactive power capability is now a standard feature of inverters used
in both wind and solar photovoltaic applications at the transmission system level. There
is, therefore, no significant additional cost for reactive power capability. At most,
developers may need to size their inverters appropriately to ensure they can provide
reactive power capability as well as real power output they have committed to provide.
8
9
Id. at 141:10-124:6.
See e.g. Comments of the American Wind Energy Association in response to the April 22, 2014
IV.Non-synchronous resources should receive compensation comparable to
synchronous resources for reactive power capability for the provision/absorption of reactive power.
As part of its proposal, the Commission states that non-synchronous generators would be eligible for the same payments for reactive power as other generators and any compensation would be based on the cost of providing reactive power.10 The
Commission seeks comment on whether the existing methods used to determine
reactive power compensation are appropriate for wind generators and, if not, what
alternatives would be appropriate.11
The Commission should adopt an approach that takes into account that various
approaches to compensate resources for reactive power capability exist in different
ISO/RTO regions.12 In this respect, the Commission should not adopt a uniform
approach to compensating synchronous or non-synchronous resources for reactive
power capability or the provision/absorption of reactive power in this proceeding. Nor
should the Commission direct transmission providers to modify their compensation
structures except as necessary to recognize new resource types as eligible to receive
compensation for leading and lagging reactive power that they are capable of supplying
to the grid. To this end, the Commission should allow synchronous and non-
synchronous resources to receive comparable compensation, provided they are
providing comparable services. To the extent it is necessary to modify compensation
approaches for synchronous and non-synchronous facilities providing reactive power
10
11
12
Proposal at P 12. Id. at P 18.
See generally Commission Staff Report, Payment for Reactive Power issued inAD14-7 date April
capability, the Commission should allow transmission providers the opportunity to fashion any necessary revisions to their compensation rules on compliance.
V.Conclusion
The Commission should adopt its proposal to require all newly interconnecting
generators that are subject to an ISO’s or RTO’s interconnection procedures, including
both synchronous and non-synchronous generators, to provide reactive power
capability to the electricity grid. The proposal eliminates unnecessary disparate
treatment among resource types. Technology enhancements as well as the relatively
modest incremental cost to non-synchronous resources of providing reactive power
capability support the Commission’s proposal as just and reasonable. The ISO/RTO
Council generally supports the Commission’s proposed technical specifications, but
requests that the Commission recognize appropriate independent entity variations and
regional differences as part of compliance with a final order in this proceeding.
Respectfully submitted,
/s/ Anna McKenna
Roger E. Collanton,
General Counsel
Anna A. McKenna,*
Assistant General Counsel,
California Independent System Operator Corporation
250 Outcropping Way
Folsom, California 95630
amckenna@caiso.com
/s/ Sara B. Keegan
Robert E. Fernandez, General Counsel
Raymond Stalter,
Director of Regulatory Affairs Carl F. Patka,*
Assistant General Counsel Sara B. Keegan,*
Senior Attorney
New York Independent System Operator, Inc.
10 Krey Boulevard
Rensselaer, NY 12144
cpatka@nyiso.com
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/s/ Theodore J. Paradise
Raymond W. Hepper,
Vice President, General Counsel, and Secretary
Theodore J. Paradise,*
Assistant General Counsel, Operations and Planning
ISO New England Inc.
One Sullivan Road
Holyoke, Massachusetts 01040
tparadise@iso-ne.com
/s/ Stephen G. Kozey
Stephen G. Kozey,*
Vice President, General Counsel, and Secretary
J. Matt Harnish,*
Senior Corporate Counsel
Midcontinent Independent System Operator, Inc.
P.O. Box 4202
Carmel, Indiana 46082-4202
skozey@midwestiso.org
*Designated to receive service
Dated: January 27, 2016
/s/ Craig Glazer
Craig Glazer,*
Vice President-Federal Government Policy
Robert V. Eckenrod,* Senior Counsel
PJM Interconnection, L.L.C.
Suite 600
1200 G Street, N.W. Washington, D.C. 20005 202-423-4743
Craig.Glazer@pjm.com
Robert.Eckenrod@pjm.com
/s/ Paul Suskie
Paul Suskie,*
Sr. VP Regulatory Policy & General Counsel
Mike Riley,
Assoc. General Counsel
Southwest Power Pool, Inc.
201 Worthen Drive
Little Rock, Arkansas 72223-4936
psuskie@spp.org
9
CERTIFICATE OF SERVICE
I hereby certify that I have served the foregoing document upon the
parties listed on the official service lists in the above-referenced proceedings, in accordance with the requirements of Rule 2010 of the Commission’s Rules of Practice and Procedure (18 C.F.R. § 385.2010).
Dated at Folsom, California this 27th day of January 2016.
/s/ Anna Pascuzzo
Anna Pascuzzo
