UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION

Transcription

1 UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Essential Reliability Services and the ) Evolving Bulk-Power System ) Docket No. RM Primary Frequency Response ) MOTION FOR EXPEDITED ACTION, MOTION FOR LEAVE TO ANSWER, AND ANSWER OF PJM INTERCONNECTION, L.L.C. PJM Interconnection, L.L.C. ( PJM ) respectfully requests expedited action on PJM s request for clarification of Order No filed in this docket on March 16, 2018 ( Request for Clarification ). Furthermore, PJM answers: (1) the answer submitted by PJM Power Providers Group ( P3 ) and the Electric Power Supply Association ( EPSA ); 2 and (2) the answer submitted by the PJM Utilities Coalition 3 in response to PJM s Request for Clarification. I. MOTION FOR EXPEDITED ACTION AND ANSWER Pursuant to Rule 212 of the Rules of Practice and Procedure of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (the Commission or FERC ), 4 PJM respectfully requests: (1) expedited action on its Request for Clarification; and (2) to the extent the Commission requires additional time 1 Order No. 842, Essential Reliability Services and the Evolving Bulk-Power System Primary Frequency Response, 162 FERC 61,128, 83 Fed. Reg (2018) ( Order No. 842 ), rehearing pending. 2 Answer and Motion for Leave to Answer of the PJM Power Providers Group and the Electric Power Supply Association, FERC Docket No. RM (Mar. 20, 2018) ( P3 Answer ). 3 Answer and Motion for Leave to Answer of the PJM Utilities Coalition, FERC Docket No. RM (Apr. 2, 2018) ( PJM Utilities Coalition Answer ) CFR (2018).

2 to consider other parties rehearing requests, that the Commission issue a separate order granting PJM s Request for Clarification. Time is of the essence and a prompt order granting PJM s Request for Clarification will avoid an unsustainable reliability issue that would result from certain generator owners current interpretation of Order No Indeed, some generator owners have gone as far as suggesting that based upon Order No. 842 and the Commission s statements therein regarding not obligating existing generation resources to provide primary frequency response they will cease providing primary frequency response from their resources that already have governors or equivalent equipment. Under certain generator owners interpretation of Order No. 842, PJM s existing manual language is insufficient and PJM lacks the authority to require existing generators to provide primary frequency response. 5 Based on this interpretation and without Commission clarification, existing generator owners within PJM could stop providing primary frequency response as of May 15, 2018, which is the effective date for Order No As stated in PJM s Request for Clarification, such an interpretation is untenable considering it would create an unsustainable reliability need and leave PJM and its transmission owners in the position of relying on only new or future interconnecting generating facilities to support primary frequency response as of May 15, This, in turn, could severely harm reliability by potentially causing a loss of service. Furthermore, PJM would face a potential inability to recover service during emergency 5 See, e.g., PJM Utilities Coalition at p. 3 (for example, although PJM s manuals already require that generators provide primary frequency response, PJM Utilities Coalition states, Order No. 842 challenged PJM s intent to impose unnecessary requirements on almost all generators within its borders.the Commission correctly concluded in Order No. 842 that requiring existing generating facilities that have not submitted a new interconnection request to install and operate governors or equivalent controls would be overly expensive and unnecessarily burdensome. ). 2

3 restoration due to insufficient primary frequency response if it cannot direct existing generator owners to provide frequency response from their existing facilities. Further, generator owners are stating that a new compensatory rate for frequency response is required, notwithstanding the fact that such resources providing primary frequency response are in fact receiving compensation through the PJM markets. The P3 Answer and PJM Utilities Coalition Answer clearly demonstrate the need for clarification of Order No For example, P3 and EPSA state, this Commission specifically affirmed that existing generators would not be required to institute new PFR requirements, absent a new interconnection request. 6 Similarly, PJM Utilities Coalition states, The Commission correctly concluded in Order No. 842 that requiring existing generating facilities that have not submitted a new interconnection request to install and operate governors or equivalent controls would be overly expensive and unnecessarily burdensome. 7 While PJM does not disagree with P3, EPSA, and the PJM Utilities Coalition that Order No. 842 does not impose a requirement to add primary frequency response capability on existing generators, Order No 842 should not preclude the application of primary frequency response requirements to existing generators that have installed capability to provide such support through existing tariff or manual provisions for example, the Commission has acknowledged throughout this proceeding that ISO New England, Inc. and New York Independent System Operator, Inc. already apply such rules to existing generators or through new tariff provisions filed pursuant to section 205 of 6 P3 Answer at p.3. 7 PJM Utilities Coalition Answer at p.3. 3

4 the Federal Power Act. Indeed, the Commission s statement cited by P3, EPSA, and the PJM Utilities Coalition was simply an acknowledgement of the high cost of attempting to retrofit generating facilities that lacked such capability. For these reasons, PJM seeks prompt Commission action and reiterates its request for clarification that Order No. 842: (1) does not create a blanket prohibition for transmission providers from requiring existing generators with an installed governor or equivalent controls to provide primary frequency response when needed for regional transmission organization ( RTO ) operations; (2) does not mandate additional compensation to existing generators in PJM that are capable of providing primary frequency response where such resources are participating in the PJM markets as the market prices effectively include the cost of providing primary frequency response service; and (3) does not relieve existing resources that have governors or other primary frequency response capabilities from the obligation to maintain those capabilities, as well as their existing operation settings, consistent with current practice and RTO requirements. Moreover, PJM requests the Commission provide such clarification prior to May 15, 2018, for the reasons stated above. II. MOTION FOR LEAVE TO ANSWER Pursuant to the Commission s Rules of Practice and Procedure, 18 CFR (a)(2), answers to requests for rehearing are not permitted unless otherwise ordered by the decisional authority. However, the Commission has discretion to accept answers not otherwise permitted by right and has done so when a party s answer helps to clarify complex issues, provide additional information, or are otherwise helpful in the Commission s decision-making process. In this answer, PJM seeks to provide the 4

5 Commission with information helpful to the Commission s decision-making process in deciding upon the Request for Clarification. PJM, therefore, respectfully request that this answer be permitted. III. CONCLUSION WHEREFORE, for the reasons set forth herein, PJM s Request for Clarification should be granted on an expedited basis. Respectfully submitted, /s/ James M. Burlew Craig Glazer James M. Burlew Vice President, Federal Government Policy Senior Counsel PJM Interconnection, L.L.C. PJM Interconnection, L.L.C G Street, N.W., Suite Monroe Boulevard Washington, D.C Audubon, PA (202) (610) craig.glazer@pjm.com james.burlew@pjm.com May 9,

6 CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregoing document upon each person designated on the official service list compiled by the Secretary in this proceeding. Dated at Audubon, PA, this 9th day of May, /s/ James M. Burlew James M. Burlew Senior Counsel PJM Interconnection, L.L.C Monroe Boulevard Audubon, PA (610)