ESA Comment on FERC Docket RM16-6 on Frequency Response

Posted: April 25, 2016 - 19:17 / FERC / ESA Filings

The Energy Storage Association (“ESA”) submits these Comments in response to the February 18, 2016, Notice of Inquiry issued by the Federal Energy Regulatory Commission (“FERC” or the “Commission”) on the need for reform to its rule and regulations regarding the provision and compensation of primary frequency response.
With the advent of proven technologies that are specifically designed to mitigate grid disturbances, including frequency response, it is no longer cost-effective to require generators to maintain frequency response capability. Non-generator resources can provide frequency response performance superior to that of generators; in particular, energy storage technologies provide instantaneous response and ramping performance critical for cost-effective and more efficient frequency response service. Moreover, frequency response services can and should be procured competitively. RTOs/ISOs should utilize a market pricing mechanism to procure frequency response from competing resource bids, which will ensure market-efficient, cost-effective provision.
Accordingly, for the reasons outlined below, ESA respectfully requests that the Commission direct RTOs/ISOs to establish a competitive procurement and pricing mechanism for frequency response service. Specifically, ESA recommends the creation of frequency response market products that accord with pay-for-performance principles consistent with those outlined in FERC Order 755.