By Rich Heidorn Jr.

FERC clarified Friday that its February order requiring new generators to provide primary frequency response did not imply that existing generators are entitled to compensation for providing the service (RM16-6-001).

Order 842 required transmission providers to amend their pro forma generator interconnection agreements (GIAs) to require generators have governors or other equipment to respond automatically to frequency disturbances. (See FERC Finalizes Frequency Response Requirement.)

PJM requested a clarification on the order, saying some stakeholders have questioned the RTO’s authority to require existing facilities to provide primary frequency response without compensation.

In its order Friday, FERC dismissed the notion that Order 842 created a blanket prohibition on frequency response requirements on existing generating facilities, saying such a conclusion would be “inconsistent with the fundamental purpose” of the order in ensuring adequate frequency response capability.

“In setting forth requirements for primary frequency response capability and operations, the commission did not address and therefore did not nullify existing requirements for the provision of primary frequency response for existing generators,” FERC said. “We find that Order No. 842 does not relieve existing generating facilities from existing requirements for primary frequency response, including requirements set forth in transmission provider tariffs or business practice manuals, including operating requirements for governors or equivalent controls and/or sustained response.”

The commission said the order also does not prevent transmission providers from proposing additional frequency response requirements under Section 205 of the Federal Power Act, “including requirements for existing generating facilities.”

FERC also rejected AES’ request to reconsider its decision not to mandate compensation for providing frequency response. AES said the lack of compensation “is directly preventing the wide-scale deployment of the very technology that could arrest the aggregate decline in systemwide primary frequency response most efficiently — lithium batteries.”

The company said Order 842’s reference to an individual company’s right to seek compensation under Section 205 of the FPA “is of little consolation to companies currently trying to plan investments on a nationwide basis.”

FERC said AES’ rehearing request did not provide any new information the commission had not already considered and that the company did not address the commission’s findings that the costs of installing and operating a governor or equivalent controls are minimal.

The commission also rejected a rehearing request from Arizona Public Service, which suggested that subjecting projects in the later stages of the interconnection queue to the order’s requirements could be unduly burdensome. “APS provides no specific information that would persuade us to modify Order No. 842’s applicability criteria,” the commission said.