Jim Burlew, senior counsel, reviewed the Federal Energy Regulatory Commission’s August clarifications on primary frequency response at the Primary Frequency Response Senior Task Force meeting on Wednesday.
The task force has been discussing the implementation of FERC Order 842, which requires all new generation to provide primary frequency response as a condition of the Interconnection Service Agreement (ISA). The clarification addressed whether or not similar requirements are able to be applied to the existing resource fleet.
Primary frequency response is an essential reliability product and is needed to ensure system reliability and stability both in real-time operations and during system restoration events. As the first line of defense in frequency disturbance events, primary frequency response is also critical for controlling frequency in system restoration events.
FERC agreed with PJM that creating a blanket prohibition of all primary frequency response requirements on existing generating facilities was too broad an interpretation of the order.
FERC noted that existing generators must continue to provide primary frequency response in accordance with currently effective rules for grid operators. In addition, there is nothing barring transmission providers from proposing to add additional primary frequency response requirements to existing generators.