FERC Order 827 and reactive power

Federal energy regulators have issued a final rule requiring all newly interconnecting non-synchronous generators to provide reactive power, which supports the reliability of the electric grid.  The rule adopted by the Federal Energy Regulatory Commission in Order No. 827 primarily affects wind generators, who have previously been exempt, and some solar projects.

Reactive power -- and generators capable of supplying or consuming it -- play an important role in controlling system voltage for efficient and reliable operation of an alternating current transmission system.  Previously, as a condition of interconnection under the FERC's pro forma Large Generator Interconnection Agreement and Small Generator Interconnection Agreement, most generators have been required “to maintain a composite power delivery at continuous rated power output at the Point of Interconnection at a power factor within the range of 0.95 leading to 0.95 lagging.”

But historically, the costs to design and build a wind generator that could provide this kind of reactive power were high.  In recognition that requiring wind generators to provide reactive power could have created an obstacle to the development of wind generation, the Commission previously exempted wind generators from the general requirement to provide reactive power, absent a study finding that the provision of reactive power is necessary to ensure safety or reliability.

But in 2014, a FERC staff report found that the cost of providing reactive power no longer presents an obstacle to the development of wind generation.  So-called Type III and Type IV inverter-based turbines now offer inherent reactive power capabilities.  As described in Order No. 827, "The resulting decline in the cost to wind generators of providing reactive power renders the current absolute exemptions unjust, unreasonable, and unduly discriminatory and preferential."  The Commission also noted that integrating increasing amounts of wind increases the potential that some systems will need more reactive power.

Acting under Section 206 of the Federal Power Act, on June 16, 2016, the Commission found "that wind generators should not have an exemption from the reactive power requirement which is unavailable to other generators." At the same time, the Commission recognized technical differences that would add costs if non-synchronous generators were required to provide reactive power at the Point of Interconnection -- and that these "added costs will ultimately be borne by customers, whether through reactive power payments in regions that compensate for reactive power capability, or through elevated prices for capacity or energy in regions that do not compensate for reactive power capability."

It thus adopted reactive power requirements for newly interconnecting non-synchronous generators, but let non-synchronous generators provide dynamic reactive power at the high-side of the generator substation, as opposed to the Point of Interconnection.

The Commission described its expectation that non-synchronous generators may meet the dynamic reactive power requirement by utilizing a combination of the inherent dynamic reactive power capability of the inverter, dynamic reactive power devices (e.g., Static VAR Compensators), and static reactive power devices (e.g., capacitors) to make up for losses.

The Final Rule will become effective 90 days after its publication in the Federal Register.  Its requirements will apply to all newly interconnecting non-synchronous generators that have not yet executed a Facilities Study Agreement as of the rule's effective date.

4th California blackout FERC enforcement case settles

Federal regulators have approved a settlement with another federal agency over its role in a 2011 blackout in California, Arizona, and Mexico.

On September 8, 2011, the Southwest's electric grid was hit with a widespread power outage that left over 5 million people in California, Arizona and Baja California, Mexico, without power for up to 12 hours.  Previous investigations by the Federal Energy Regulatory Commission (FERC) and the North American Electric Reliability Corporation (NERC) found that the blackout occurred when Arizona Public Service Company's 500-kilovolt Hassayampa-N.Gila transmission line tripped out of service, overloading the remaining elements of the regional grid. 

Earlier this year, FERC approved stipulations and consent agreements among its Office of Enforcement, NERC, and three public utilities.  Arizona Public Service agreed to pay $3.25 million in civil penalties, California's Imperial Irrigation District agreed to a $12 million settlement, and  Southern California Edison Company agreed to pay a $650,000 civil penalty and undertake additional compliance actions.

FERC approved a fourth settlement on November 24, 2014, with the Western Area Power Administration – Desert Southwest Region (Western-DSW).  One of four power marketing administrations within the United States Department of Energy, the Western Area Power Administration (WAPA) markets and transmits electricity to a fifteen-state region from hydroelectric power facilities at the Hoover, Parker, and Davis dams. Western-DSW is one of four regions carrying out this mission for WAPA, serving customers in Arizona, Southern California, and Southern Nevada. It sells more than ten billion kilowatt hours of hydroelectric power to approximately seventy municipalities, cooperatives, federal and state agencies, and irrigation districts. Western-DSW also operates and maintains more than forty substations and 3,100 miles of transmission lines.

In the FERC Order Approving Stipulation and Consent Agreement, the Commission notes that Western-DSW violated four Requirements of three Reliability Standards in the Transmission Operations (TOP) and Voltage and Reactive Control (VAR) categories. These groups of standards cover the responsibilities and decision making authority for reliable operations and maintenance of Bulk Power system facilities within voltage and reactive power limits to protect equipment and ensure reliable operation of the interconnection.  In particular, FERC Enforcement staff and NERC found that Western-DSW failed to operate its portion of the transmission system within voltage system operating limits and to maintain sufficient situational awareness prior to and during the event, undermining reliable operation of the Bulk Power System.

Western-DSW stipulated to the facts in the agreement and agreed to implement compliance measures necessary to mitigate the violations and improve overall reliability, including improving its models, better coordination with neighboring entities, and improving its situational awareness by adding a real-time monitoring tool that analyzes and alerts operators to potential contingencies. Western-DSW also agreed to make semi-annual compliance reports to Enforcement staff and NERC for at least one year.  Notably, the stipulation does not require Western-DSW to pay a civil penalty.

FERC's general investigative report on the incident identified six potential targets for enforcement action.  With cases settled against Western-DSW, SoCal Edison, the Imperial Irrigation District, and Arizona Public Service, only the California Independent System Operator and the Western Electricity Coordinating Council Reliability Coordinator have not yet been parties to a stipulation and consent agreement.