FERC Order 845 reforms interconnection process

U.S. utility regulators have issued an order adopting a final rule reforming the procedures through which electric generators obtain interconnections to the utility grid. The Federal Energy Regulatory Commission's Order No. 845 adopts a final rule which implements ten specific reforms designed to provide interconnection customers better information and more options, in the hopes that transmission providers will better be able to focus on interconnection requests that are likely to reach commercial operation.

Generally speaking, generators need to interconnect to the utility grid (and to consumers) for their power to be valuable. Under the Federal Power Act, many generator interconnections are subject to regulation by the Commission. In December 2016, the Commission issued a Notice of Proposed Rulemaking proposing 14 sets of reforms to its interconnection regulations. In that notice, the Commission cited changes to the electric power industry since the Commission issued its Order No. 2003 governing interconnections, and concerns including long queues and delays for interconnection studies, and a lack of certainty around timing and costs.

As a result, in 2016 the Commission preliminarily found that the interconnection process may hinder the timely development of new generation, and thereby stifle wholesale competition, resulting in rates, terms, and conditions that are not just and reasonable or are unduly discriminatory or preferential. The Commission also preliminarily found the interconnection process could result in uncertainty and inaccurate information, and a potential for discrimination as new technologies enter the market.

Now, following a technical conference and 63 public comments, the Commission issued its order adopting the final rule on April 19, 2018. The final order adopted many of the Commission's 2016 proposals, while deviating from that earlier proposal in some regards.

Among other items, the final rule includes two sets of reforms designed to improve certainty for interconnection customers, four aimed at promoting more informed interconnection decisions, and four designed to enhance the interconnection process.

The Commission also decide to revise its pro forma Large Generator Interconnection Procedures and  Large Generator Interconnection Agreement, to mitigate concerns about systemic inefficiencies, discriminatory utility practices, and time spent on interconnection requests that are unlikely to reach commercial operation.

The final rule, codified as 18 C.F.R. Part 37, will become effective 75 days after its publication in the Federal Register.

FERC Order 842 requires primary frequency response by generators

U.S. energy regulators have issued an order amending standard interconnection agreements to require new generators to install, maintain and operate a functioning governor or equivalent controls capable of primary frequency response as a precondition of interconnection. The Federal Energy Regulatory Commission's Order No. 842 also amended the pro forma interconnection agreements to include certain operating requirements including maximum droop and deadband parameters, and sustained response provisions.

As described by the Commission, reliable operation of an alternating current grid requires maintaining system frequency within predetermined boundaries above and below 60 Hertz. Frequency response describes an interconnected grid’s ability to arrest and stabilize deviations from this predetermined range of frequencies after a sudden loss of generation or load.

Historically, the U.S. grid's primary frequency response capability came from baseload synchronous generators such as coal-fired power plants. But many such plants have retired in recent years, with further retirements expected. In 2016, the Commission noted that shifts in the portfolio of U.S. electric generators meant fewer resources could likely provide primary frequency response, especially if new variable energy resources such as wind and solar did not provide this service. In response, it opened an inquiry into what primary frequency response reforms it should make.

On February 15, 2018, the Commission issued its Order No. 842 revising its regulations to require newly interconnecting 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 final rule also amends the Commission's pro forma interconnection agreements to include certain operating requirements including maximum droop and deadband parameters, and sustained response provisions. It provides exemptions for nuclear power plants and some combined heat-and-power plants.

These requirements will apply to most newly interconnecting generation facilities that execute, or request the unexecuted filing of, an LGIA or SGIA on or after the rule’s effective date, as well as to existing large and small generating facilities that take any action that requires the submission of a new interconnection request that results in the filing of an executed or unexecuted interconnection agreement on or after the effective date.

In a press release, the Commission said its action was intended to address "the increasing impact of the evolving generation resource mix." Commissioner LaFleur made a separate statement in which she noted that while decreases in the nation's portfolio percentage of synchronous generation have contributed to declining frequency response performance, "recent technological advancements have enabled new non-synchronous generating facilities, such as wind and solar, to cost-effectively include primary frequency response capabilities in their facilities." Improved inverters and battery storage are among these innovations.

The Commission has also recently noted the potential of electric storage resources to provide frequency response and other services. Its Order No. 841 is designed to remove barriers to the participation of electric storage resources in wholesale markets operated by regional transmission organization and independent system operators, including markets for frequency response.

Generator interconnection technical conference scheduled

The Federal Energy Regulatory Commission has scheduled a technical conference to generator interconnection issues, including interconnection of energy storage.

The case has its origins in a 2015 petition to the Commission by the American Wind Energy Association, seeking a rulemaking to revise certain provisions of the Commission's pro forma Large Generator Interconnection Procedures (“GIP”) and pro forma Large Generator Interconnection Agreement (“GIA”).

AWEA is a national trade association representing a broad range of entities with a common interest in encouraging the expansion and facilitation of wind energy resources in the United States. Its members include wind energy facility developers, owners and operators, construction contractors, turbine manufacturers, component suppliers, financiers, researchers, utilities, marketers, customers, and their advocates.

In that petition, the trade group argued:

the time is ripe for the Commission to make certain regulatory and policy changes to interconnection procedures in order to remedy unduly discriminatory and unreasonable barriers to generator market access that inhibit the development of electric generation to meet the growing needs of electricity customers, and to facilitate the current dramatic transformation of the electric generation system (driven, in part, by Federal and State policies) in a timely, reliable and cost-effective manner.

AWEA's petition called for a variety of reforms to the interconnection procedures and agreement, particularly aimed at improving "(a) certainty in the study/restudy process; (b) transparency in the interconnection process; (c) certainty of network upgrade costs; and (d) accountability in the interconnection process."  After many comments were submitted on the rulemaking petition, AWEA asked the Commission to hold a technical conference as a forum for "open discussion" among interested parties.

The Commission has now issued notice of a technical conference to be held on May 13.  According to the notice:

The purpose of this conference is to discuss select issues related to a petition for rulemaking submitted by the American Wind Energy Association (Docket No. RM15-21-000). In addition, the conference will explore other generator interconnection issues, including interconnection of energy storage.

The notice also states that discussions at the conference may involve issues raised in other proceedings pending before the Commission, including without limitation 8 sets of specifically listed cases:

• E.ON Climate & Renewables North America LLC, Pioneer Trail Wind Farm, LLC, Settlers Trail Wind Farm, LLC v. Northern Indiana Public Service Company, Docket No. EL14-66-002;

• Entergy Arkansas, Inc., Docket No. ER14-671-000;

• Internal MISO Generators v. Midcontinent Independent System Operator, Inc., Docket No. EL15-99-000;

• Midcontinent Independent System Operator, Inc., Docket No. ER16-675-000;

• California Independent System Operator Corporation, Docket No. ER16-693-000;

• ISO New England, Inc., Docket No. ER16-946-000;

• Midcontinent Independent System Operator, Inc., Docket No. ER16-1120-000; and

• Midcontinent Independent System Operator, Inc., Docket No. ER16-1211-000. 

The conference will be held on May 13 at Commission headquarters in Washington, DC.

FERC considers Primary Frequency Response reforms

U.S. energy regulators are considering whether reforms are needed to regulations for the provision and compensation of primary frequency response, a function essential to the electric grid's operation.

In general, the U.S. bulk power system operates on an alternating current.  For reliability and interoperability, that current must maintain its frequency within predetermined boundaries above and below 60 Hertz.  An interconnected grid’s ability to arrest and stabilize frequency deviations within those boundaries after a sudden loss of generation or load is called "frequency response." A grid's frequency response characteristics are affected by factors including inertial response (as spinning generators speed up or slow down when load changes), primary frequency response, and secondary frequency response.  Historically, most primary frequency response has been provided by baseload synchronous generators as an ancillary service.

But the U.S. electric grid's energy mix is changing.  In a Notice of Inquiry released on February 18, 2016, the Federal Energy Regulatory Commission notes that changes to the U.S. electric supply portfolio likely mean that fewer resources are now primary frequency response.  In particular, the U.S. has seen broad retirement of coal-fired baseload synchronous generators, some of which provide primary frequency response, while some have been replaced with variable energy resources such as wind and solar which do not typically have primary frequency response capabilities.

In response, FERC solicited public input on whether and what action is needed, including whether to:

• Amend the pro forma Large Generator and Small Generator interconnection agreements to require that all new generation resources have frequency response capabilities as a precondition of interconnection;


• Implement primary frequency response requirements for existing generation resources; and


• Establish procurement and compensation mechanisms for primary frequency response.

FERC has docketed the matter as RM16-6-000, Essential Reliability Services and the Evolving Bulk-Power System — Primary Frequency Response.  Comments on the Notice of Inquiry are due 60 days after publication in the Federal Register.