FERC Filings

Comments of EPSA on FERC's Staff Report and Technical Conference Regarding Reactive Power and Voltage Control

Reactive Power "Markets" And Equipment Testing

EPSA supports the development and operation of energy and ancillary service markets. However, the localized nature of reactive power and voltage support services indicates that utilizing markets as a compensation mechanism for reactive power would be inappropriate at this time. The costs associated with reactive power and voltage support are largely fixed costs (and opportunity costs on rare occasions when a generator must reduce real power output). These characteristics, plus the universal principle that reactive power cannot be transmitted over significant distances, strongly suggest that operating markets for reactive power and voltage support as a “product” would be extremely problematic.

EPSA supports performance and capability testing, provided design ratings are properly considered and metrics are clear and transparent. An additional, and significant, consideration in this regard is that whatever testing may be imposed, all generators, both IPPs and transmission provider affiliates, be required to comply. Further, EPSA recommends that the Commission review requirements that transmission providers have crafted that impose requirements that effectively exclude from compliance a substantial portion of the generating facilities in their systems.

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