ESA Comments to Docket No. RM16-6

Posted: January 24, 2017 - 16:38 / ESA Filings
The Energy Storage Association (“ESA”) submitted the attached Comments in response to the notice of proposed rule issued on November 17, 2016 pertaining to above-captioned docket. While ESA does not oppose the requirement of primary frequency (“PFR”) response capability as a condition of interconnection, it is critical that FERC refrain from mandating a PFR provision. As detailed herein, mandating provision of PFR would create undue or discriminatory burdens on electric storage resources. Accordingly, ESA respectfully asks FERC to modify its proposal and direct RTOs/ISOs to make provision of primary frequency response a compensated service.
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ESA agrees with FERC that reservation of headroom for the provision of PFR should not be required. ESA interprets the following proposed tariff language as an explicit prohibition against requiring reserving headroom as a condition of interconnection:
 
“Nothing in Sections 9.6.4, 9.6.4.1 and 9.6.4.2 shall require the Large Generating Facility to operate above its minimum operating limit or below its maximum operating limit, or otherwise alter its dispatch to have headroom to provide primary frequency response.”
 
Additionally, ESA interprets the following proposed tariff language to mean that generating unit operations shall not be required to modify expected operations as a condition of interconnection:

“…if a generating facility that is subject to these proposed requirements has been dispatched by its balancing authority to a set-point at which there is no available operating range to increase or decrease its output in response to frequency deviations, it would not be in violation of the proposed requirements in regards to providing sustained response...”
In its Final Order, ESA respectfully requests that FERC not mandate the provision of PFR service.

2. Requirements of interconnecting resources to provide primary frequency response capability should accommodate the unique technical attributes of electric storage to avoid undue or discriminatory burdens on electric storage resources.

FERC proposes to require a governor or equivalent controls capable of providing PFR capability as a condition of interconnection. ESA agrees with FERC that interconnection should provide the option for “equivalent controls,” as governors are inappropriate for advanced electric storage, such as batteries, which do not have the physical characteristics of traditional generators or pumped hydro storage.
 
Full Comments is available here.