At its June 16, 2022, open meeting, the Federal Energy Regulatory Commission (FERC or Commission) issued a notice of proposed rulemaking (NOPR), Improvements to Generator Interconnection Procedures and Agreements, 179 FERC ¶ 61,194 (2022), proposing reforms to the Commission’s standard generator interconnection procedures and agreements. The goal of the NOPR is to reduce queue
Melan Patel is an associate in Stoel Rives’ Energy Development group. He primarily represents clients in the energy industry in regulatory, litigation, and transactional matters before the Federal Energy Regulatory Commission (FERC). Melan has experience drafting and defending applications for the construction and authorization of natural gas pipeline facilities. He has represented natural gas pipeline companies in rate proceedings before FERC and defended them in administrative litigation related to shipper-initiated complaints. Melan has also negotiated and drafted a variety of natural gas and liquids agreements, including processing, gathering, sales, and intrastate and interstate transportation agreements.
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Reactive Power Compensation for Renewable Generators – On the Chopping Block?
On November 18, 2021, FERC issued a Notice of Inquiry (NOI) seeking comments on reactive power capability compensation and market design. (Link to NOI here). Reactive power is a critical component of the bulk electric system. Almost all bulk electric power is generated, transported, and consumed in AC networks. These AC systems consume both real and reactive power. Reactive power supports the voltages necessary for system reliability to allow the supply of real power from generation to load. All balancing authorities must procure enough sources of reactive power to safely manage the grid and generator interconnection agreements contain provisions requiring generators to operate within certain reactive power limits. Reactive power is an ancillary service and costs are recovered separately from the cost of standard transmission service.
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Public Utilities Commission of Texas Adopts New Winter Weatherization Rules in Response to Winter Storm Uri
On October 21, 2021, the Public Utility Commission of Texas (PUCT) approved a rule that creates requirements for power companies to better prepare for winter weather. The rule stems from the Texas Legislature’s passage of Senate Bill 3 (S.B. 3) in response to the devastation caused to the energy grid by Winter Storm Uri.
S.B. 3, effective June 8, 2021, is a multi-pronged law that attempts to make the Texas energy system more resilient to the effects of extreme winter weather events. Key to S.B. 3 is a requirement that the PUCT implement winter weatherization requirements so that each of the entities providing electric generation service must implement measures to prepare its generation assets to provide adequate electric generation service during a weather emergency. The new rule, codified as 16 Texas Administrative Code §25.55, requires electric generators and transmission service providers (TSPs) (collectively, generation entities) to implement the winter weather readiness recommendations identified in the 2012 Quanta Technology Report on Extreme Weather Preparedness Best Practices and the FERC/NERC 2011 Report on Outages and Curtailments During the Southwest Cold Weather Event on February 1-5, 2011. The rule also requires affected entities to fix any known, acute issues that arose from winter weather conditions during the 2020-2021 winter weather season. The deadline for implementation of many components of the new rule is December 1, 2021.
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