or below award when across all improvement trigger triggered minutes in from incr. 2016 100 MW RRS 59.983 Hz 83,775 min/yr 1.24 MW 0.197 MW 0.8% (generators) (15.896%) FFR (Apex 59.955 Hz 1,039 min/yr 100 MW 0.197 MW 0.8% proposal) (0.197%) FFR (ERCOT 59.850 Hz 0 min/yr NA ~0 MW ~0% proposal) (~0%) FFR should provide response at a 60.038 Hz trigger, when available, to match “down” the expected Primary Frequency Response of RRS-gen. Pursuant to PFR mandate BAL-001-TRE-1, most online generators must also respond to frequency deviations at or above 60.017 Hz. PFR suppliers are required to provide this response to the extent that the unit output exceeds the Low Sustained Limit. While “down” BAL-001-TRE-1 applies to it is unclear if Energy Storage Resources would “generators”, need to comply with PFR requirements. Therefore, it is important that Energy Storage Resources that supply FFR are treated in an equivalent manner to generation supplying RRS since the FFR product would be paid the same as RRS-gen. To find an equivalency between FFR and RRS-gen, RRS-gen deployment for each “down” minute of 2016 is calculated based on the actual 1-minute frequencies. Based on this method, the FFR trigger should be set at 60.038 Hz for the primary frequency response to be equivalent to RRS (see Table B). Table B: Equivalent frequency response above 60Hz for FFR & RRS “down” Average Number of Average Average 2016 CPS1 deployment deployment score intervals at from 100 MW from 100 MW improvement Frequency or above award when award in from incr. Product trigger trigger triggered 2016 100 MW RRS 60.017 Hz 45,322 min/yr 0.72 MW 0.062 MW 0.3% (generators) (8.600%) FFR (Apex 60.038 Hz 325 min/yr 100 MW 0.062 MW 0.3% proposal) (0.062%) FFR (ERCOT NA NA NA 0 MW 0% proposal)
or below trigger award when triggered across all minutes in 2016 improvement from incr. 100 MW RRS (generators) 59.983 Hz 83,775 min/yr (15.896%) 1.24 MW 0.197 MW 0.8% FFR (Apex proposal) 59.955 Hz 1,039 min/yr (0.197%) 100 MW 0.197 MW 0.8% FFR (ERCOT proposal) 59.850 Hz 0 min/yr (~0%) NA ~0 MW ~0% FFR should provide “down” response at a 60.038 Hz trigger, when available, to match the expected Primary Frequency Response of RRS-gen. Pursuant to PFR mandate BAL-001-TRE-1, most online generators must also respond to frequency deviations at or above 60.017 Hz. PFR suppliers are required to provide this “down” response to the extent that the unit output exceeds the Low Sustained Limit. While BAL-001-TRE-1 applies to “generators”, it is unclear if Energy Storage Resources would need to comply with PFR requirements. Therefore, it is important that Energy Storage Resources that supply FFR are treated in an equivalent manner to generation supplying RRS since the FFR product would be paid the same as RRS-gen. To find an equivalency between FFR and RRS-gen, RRS-gen “down” deployment for each minute of 2016 is calculated based on the actual 1-minute frequencies. Based on this method, the FFR trigger should be set at 60.038 Hz for the primary frequency response to be equivalent to RRS (see Table B). Table B: Equivalent “down” frequency response above 60Hz for FFR & RRS Product Frequency trigger Number of intervals at or above trigger Average deployment from 100 MW award when triggered Average deployment from 100 MW award in 2016 Average 2016 CPS1 score improvement from incr. 100 MW RRS (generators) 60.017 Hz 45,322 min/yr (8.600%) 0.72 MW 0.062 MW 0.3% FFR (Apex proposal) 60.038 Hz 325 min/yr (0.062%) 100 MW 0.062 MW 0.3% FFR (ERCOT proposal) NA NA NA 0 MW 0%
828NPRR-13_Apex_Comments_103117.docx