ESA Comment to MISO Interconnection Process Task Force on Frequency Response and the Generator Interconnection Agreement

Posted: March 24, 2016 - 15:57 / Frequency Response / ESA Filings

ESA appreciates MISO’s request for feedback on changes to the Generator Interconnection Agreement (GIA) under consideration in response to the FERC Notice of Inquiry on Frequency Response (Docket RM16-6). Requiring generating resources to provide frequency response service would fail to be a leastcost option for several reasons. Without an economic benefit to service provision, many generators would seek to recover additional cost of elsewhere. Additionally, requiring all generators to provide frequency response will likely result in an oversupply of the service, thereby creating additional cost to the system. Given that other resources, like energy storage, can provide frequency response efficiently, ESA suggests that allowing the resource fleet to provide the required amount of frequency response, as determined by MISO, through a market mechanism would be a lower cost option.