On February 18, 2016, the Federal Energy Regulatory Commission (“FERC” or the “Commission”) issued a Notice of Inquiry (“NOI”) seeking comments on the need for reforms to its rules and regulations regarding the provision and compensation of primary frequency response. As described by the Commission, “Frequency Response” is “a measure of an Interconnection’s ability to arrest and stabilize frequency deviations within pre-determined limits following the sudden loss of generation or load.” Primary frequency response is used to maintain an electrical frequency of 60 Hz among the three synchronous interconnections in the United States (Eastern, Western, and the Electric Reliability Council of Texas), when certain contingencies (e.g. the loss of a large generator) disrupt the balance between generation and load.

The Commission cited, among other things, the drastic increase in the amount of generation from variable energy resources like wind and solar, and the simultaneous retirement of significant amounts of conventional baseload generation that have traditionally provided primary frequency response (e.g. coal, nuclear) as key reasons for its NOI. The Commission also noted that most variable energy resources do not provide frequency response unless specifically configured to do so.

The NOI seeks comments on a number of specific items based around the following three primary questions:

1. Whether the pro forma Large Generator Interconnection Agreement (“LGIA”) and Small Generator Interconnection Agreement (“SGIA”) should be amended to require that all new generation resources have frequency response capabilities, as a precondition of interconnection, and if so, how?

2. Should the Commission implement primary frequency response requirements for existing generation resources, and if so, what should those requirements be?

3. Is there a need to establish or modify procurement and compensation mechanisms for primary frequency response, and if so, would such mechanisms ensure that the resulting rates are just and reasonable?

Comments are due sixty days after publication of the NOI in the Federal Register.

A copy of the NOI, including the specific items the Commission is seeking comments on within each of the three primary questions listed above, may be found here.