PJM Primary Frequency Response Requirement Problem Statement / Issue Charge

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1 PJM Primary Frequency Response Requirement Problem Statement / Issue Charge David Schweizer Manager, Generation PJM Operating Committee May 3, 2017

2 Primary Frequency Response Requirement Overview Background Recent industry initiatives Current PJM business rules FERC NOPR PJM Governor Survey BAL Performance Generator governor criteria in other areas PJM observations / recommendations 2

3 Problem Statement / Issue Charge Summary Evaluate need for generator Primary Frequency Response (PFR) capability requirement in PJM, consistent with the NERC Industry Advisory and industry practice Sr. Task Force reporting to the MRC Operational and compensation aspects Key work activities: Education on PFR Evaluation of existing state of PFR in PJM and other areas Discussions on potential compensation issues and mechanisms Evaluation of PJM OA, OATT and Manuals Deliverables: PJM Operating Agreement, Tariff and Manual revisions 3

4 Next Steps Problem Statement / Issue Charge, endorsement and assignment April / May 2017 OC MRC 4/11/2017 5/3/2017 (Endorsement) 4/27/2017 5/25/2017 (Endorsement) 4

5 Appendix

6 Primary Frequency Response Primary Frequency Response (PFR) is an essential reliability product, needed to ensure system reliability and stability in both real-time operations and also during system restoration events. First stage of system frequency control Provided automatically by unit governors or equivalent speed control systems Response is in seconds and not controlled by any centralized system Critical for controlling frequency in system restoration event 6

7 Frequency Disturbance Example 7

8 Recent Industry Activities NERC Frequency Response Initiative Report - The Reliability Role of Frequency Response - October 30, 2012 NERC Industry Advisory - Generator Governor Frequency Response - February 2015 NERC Essential Reliability Services Report November 2015 NERC Reliability Standard BAL November 2015 FERC Notice of Inquiry-Primary Frequency Response - February 18, 2016 FERC NOPR: Essential Reliability Services and the Evolving Bulk-Power System - Primary Frequency Response under RM November 2016 NERC Resources Subcommittee announcement for industry webinar November 22, 2016 NERC Frequency Response Survey Webinar - 12/8/2016 8

9 Current PJM Manual Requirements M-12 Balancing Operations, Section 4.6 Black Start Service Resources to maintain voltage and frequency under varying load M-14-D Generator Operational Requirements, Section Real Power Control Specifies units should operate on unrestricted governor control Provides direction on proper governor droop and deadband M-36 System Restoration, Section 6.1 Generating Stations Requires unit governors to be in service Critical to providing dynamic reserve 9

10 Primary Frequency Response NOPR Issued by FERC on November 17, 2016 Requires all new small and large generators to install and enable primary frequency response capability Applies to synchronous and non-synchronous resources Specifies governor or equivalent controls to be operated with maximum 5% droop and ±0.036 Hz dead band settings Requires timely and sustained response to frequency deviations Would prohibit any controls that override governor response 10

11 Primary Frequency Response NOPR The NOPR does not propose: That the requirements apply to Nuclear units That the requirements apply to existing units (requirements will only apply to new units & units requiring a revised ISA) A headroom requirement on generating facilities Any compensation for complying with the proposed requirements 11

12 PJM Governor Survey Follow Up (2017) GO Governor Survey Initiated in February of 2016 PJM initiated outreach to generators to clarify responses Clarifications to date for key restoration resources: Black Start resources: 100% indicated a functional governor 91% indicated settings as recommended Critical Load resources: 95% indicated a functional governor 75% indicated settings as recommended by NERC 25% indicated having controls that override frequency response 12

13 BAL PJM has been evaluating primary frequency response against the requirements in BAL since 2011 Evaluation based on RTO performance as opposed to unitspecific performance Primary frequency response measured as the median response for the selected events PJM Frequency Response Measures (FRM) has always been greater than the Frequency Response Obligation (FRO) There is variability in the PFR on an event-to-event basis - some events measure below the set FRO 13

14 PJM BAL Field Trial Performance 14

15 PJM Observations Many generators not providing any Primary Frequency Response (PFR) Many generators withdraw PFR or respond in the opposite direction Significant portion of PFR comes from load which cannot be predicted or controlled 15

16 Examples of Generator Governor Criteria in other areas IESO, ISONE, MISO, Progress & CAISO: have formal documented requirements in their operating procedures that are consistent with (or tighter than) the NERC Industry Advisory guidelines WECC & TRE: have regional reliability criteria or standards that are consistent with (or tighter than) the NERC Industry Advisory guidelines 16

17 PJM Recommendations Evaluate need for generator Primary Frequency Response (PFR) requirement in PJM via new Problem Statement / Issue Charge: Clarify and strengthen PJM requirements, consistent with the NERC Industry Advisory and industry practice: Applicable to all generation resources (except nuclear) Aligned with NERC Advisory settings Dead band settings +/- 36mHz / droop settings not to exceed 5% Removal of controls that could limit governor action 17

18 Advantages Advantages of enhancing PJM s requirements Predictability of PFR during real time operations Certainty that black start and critical load units will provide frequency control and dynamic reserves during system restoration Consistent with other requirements in the Eastern Interconnection including the NERC advisory and the FERC NOPR. Support BAL compliance 18

19 Next Steps Present Problem Statement / Issue Charge, endorsement and assignment April / May 2017 OC MRC 4/11/2017 5/2/2017 (Endorsement) 4/27/2017 5/25/2017 (Endorsement) 19

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