Energy storage is a good option for frequency response, a storage trade group will tell the Federal Energy Regulatory Commission this month.
Markets would be less efficient and “system costs greater than necessary if resource owners are mandated to provide frequency response service from generators more suited to provide energy and capacity,” the Energy Storage Association wrote in previously filed comments.
The group is responding to FERC’s request for supplemental comment on its November 2016 notice of proposed rulemaking (NOPR) to begin the process of revising its interconnection rules for both large and small generators. FERC’s concern was that fewer generators were providing primary frequency response.
According to ESA, requiring generators to provide frequency response could produce an oversupply of frequency response headroom, imposing additional system costs. The group noted that many generators are not well suited to provide frequency response because doing so can lower operational efficiency, which will eventually result in higher system costs. Additionally, requiring all generators to provide frequency response would fail to create a market signal.
On the other hand, energy storage, particularly batteries, are well suited to provide frequency response, ESA said. They are fast responding and do not lose efficiency by needing to reserve headroom. In its comments, ESA cited studies by the Electric Reliability Council of Texas that found 1 MW of fast responding resources could be substituted for 2 MW of primary frequency response resources during some system conditions.
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