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FERC Approves NERC Reliability Standard On Balancing Authority Frequency Response

Peter S. Glaser
Troutman Sanders LLP - Washington Office

Kevin C. Greene
Troutman Sanders LLP - Atlanta Office

Daniel L. Larcamp
Clifford S. Sikora
Troutman Sanders LLP - Washington Office

Lara L. Skidmore
Troutman Sanders LLP - Portland Office

February 4, 2014

Previously published on January 27, 2014

On January 16, 2014, FERC issued a final rule approving the North American Electric Reliability Corporation (“NERC”) proposed Reliability Standard BAL-003-1 pertaining to Frequency Response and Frequency Bias Setting. This standard directs “the amount of frequency response needed from balancing authorities to maintain interconnection frequency within defined bounds and includes requirements for the measurement and provision of frequency response.”

According to NERC, “Frequency Response is a measure of an Interconnection’s ability to stabilize frequency immediately following the sudden loss of generation or load.” Normally, balancing authorities respond to frequency fluctuations through adjustments to the output of generators with the goal of restoring balance between generation and load. The purpose of the new reliability standard is to ensure that each balancing authority has sufficient frequency response in order to guard against under-frequency load shedding due to an event in the interconnection in which the balancing authority is located.

FERC found that the standard complements FERC’s directives set forth in Order No. 693, and addresses a currently unmet need. According to NERC, the standard will:

Establish a minimum Frequency Response Obligation for each balancing authority;

  • Provide a uniform calculation of frequency response;
  • Establish Frequency Bias Settings that set values closer to actual balancing authority frequency response; and
  • Encourage coordinated automatic generation control (or AGC) operation.

In approving the standard, FERC explained that certain portions of the standard required additional consideration. In the order, FERC directs NERC to determine the effectiveness of the standard in providing an adequate amount of frequency response. Additionally, NERC must submit two reports to FERC after implementing the standard. The first should address the results and recommendations of a light-load case study of the Eastern Interconnection, using actual turbine governor response data. The second report should provide an evaluation of the use of the linear regression methodology to calculate frequency response as well as outlining the availability of resources for applicable entities to actually meet the Frequency Response Obligation.  If NERC finds that there are insufficient resources available to meet the balancing authorities’ requirements, it must provide mitigation recommendations.


The views expressed in this document are solely the views of the author and not Martindale-Hubbell. This document is intended for informational purposes only and is not legal advice or a substitute for consultation with a licensed legal professional in a particular case or circumstance.

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