153 FERC ¶ 61,175

DEPARTMENT OF ENERGY

FEDERAL ENERGY REGULATORY COMMISSION

18 CFR Part 35

[Docket No. RM16-1-000]

Reactive Power Requirements for Non-Synchronous Generation

(Issued November 19, 2015)

AGENCY: Federal Energy Regulatory Commission.

ACTION: Proposal to Revise Standard Generator Interconnection Agreements.

SUMMARY: The Federal Energy Regulatory Commission (Commission) is proposing 

to eliminate the exemptions for wind generators from the requirement to provide reactive

power. As a result, all newly interconnecting generators, including both synchronous and 

non-synchronous generators, would be required to provide reactive power. To implement 

this requirement, the Commission proposes to revise the pro forma Large Generator 

Interconnection Agreement (LGIA), Appendix G to the pro forma LGIA, and the 

pro forma Small Generator Interconnection Agreement (SGIA) in accordance with the 

Commission’s regulations, which require every public utility with a non-discriminatory 

open access transmission tariff on file to also have on file the pro forma LGIA and 

pro forma SGIA “required by Commission rulemaking proceedings promulgating and 

amending such interconnection procedures and agreements.” In this Proposal to Revise 

Standard Generator Interconnection Agreements (Proposal), the Commission proposes to 

modify both agreements to eliminate the exemptions for wind generators from the

requirement to provide reactive power. As a result, all newly interconnecting generators
Docket No. RM16-1-000 - 2 -

(i.e., new generators seeking to interconnect to the transmission system and all existing

non-synchronous generators making upgrades to their generation facilities that require

new interconnection requests), both synchronous and non-synchronous, would be

required to provide reactive power as a condition of interconnection as of the effective

date of the final revision.

DATES: Comments are due [INSERT DATE 60 days after publication in the 

FEDERAL REGISTER].

ADDRESSES: Comments, identified by docket number, may be filed in the following 

ways:

• Electronic Filing through http://www.ferc.gov. Documents created electronically

using word processing software should be filed in native applications or print-toPDF format and not in a scanned format.

• Mail/Hand Delivery: Those unable to file electronically may mail or hand-deliver 

comments to: Federal Energy Regulatory Commission, Secretary of the 

Commission, 888 First Street, NE, Washington, DC 20426.

Instructions: For detailed instructions on submitting comments and additional 

information on this process, see the Comment Procedures Section of this document.

FOR FURTHER INFORMATION CONTACT:

Brian Bak (Technical Information)

Office of Energy Policy and Innovation

Federal Energy Regulatory Commission

888 First Street, NE

Washington, DC 20426

(202) 502-6574

brian.bak@ferc.gov
Docket No. RM16

-1-000- 3 -

Gretchen Kershaw (Legal Information)

Office of the General Counsel

Federal Energy Regulatory Commission

888 First Street, NE

Washington, DC 20426

(202) 502-8213

gretchen.kershaw@ferc.gov

SUPPLEMENTARY INFORMATION

:
UNITED STATES OF AMERICA

FEDERAL ENERGY REGULATORY COMMISSION

Reactive Power Requirements for Non-Synchronous 

Generation

Docket No. RM16-1-000

PROPOSAL TO REVISE STANDARD GENERATOR INTERCONNECTION 

AGREEMENTS

(Issued November 19, 2015)

1. In this Proposal to Revise Standard Generator Interconnection Agreements

(Proposal), the Federal Energy Regulatory Commission (Commission) is proposing to 

eliminate the exemptions for wind generators from the requirement to provide reactive

power. As a result, all newly interconnecting generators, including both synchronous and 

non-synchronous, would be required to provide reactive power. Specifically, the 

Commission proposes to modify the two pro forma interconnection agreements, the 

Large Generator Interconnection Agreement (LGIA) and the Small Generator 

Interconnection Agreement (SGIA), to eliminate the current exemption for wind 

generators from the requirement to provide reactive power, thereby requiring all newly 

interconnecting generators (i.e., new generators seeking to interconnect to the

transmission system and all existing non-synchronous generators making upgrades to

their generation facilities that require new interconnection requests), both synchronous 

and non-synchronous, to provide reactive power. This Proposal would create comparable 

reactive power requirements for non-synchronous and synchronous generators, except 

that the Proposal requires that non-synchronous generators maintain the required power 

factor range only when the generator’s real power output exceeds 10 percent of its 
Docket No. RM16-1-000 - 2 -

nameplate capacity. Additionally, all existing non-synchronous generators making

upgrades to their generation facilities that require new interconnection requests would be 

required to provide reactive power.

2. The existing pro forma LGIA and pro forma SGIA both require, as a condition of 

interconnection, an interconnecting generator “to design its generating facility to 

maintain a composite power delivery at continuous rated power output at the Point of 

Interconnection at a power factor1 of 0.95 leading to 0.95 lagging, or a different range if 

adopted by the Transmission Provider”2 (i.e., the reactive power requirement). This 

reactive power requirement requires dynamic reactive power3 from generators. As 

discussed below, however, wind generators have been exempted from the reactive power 

 1 The power factor of an alternating current transmission system is the ratio of real 

power to apparent power. Reliable operation of a transmission system requires system 

operators to maintain a tight control of voltages (at all points) on the transmission system. 

The ability to vary the ratio of real power to apparent power (i.e., adjust the power factor) 

allows system operators to maintain scheduled voltages within allowed for tolerances on 

the transmission system and maintain the reliability of the transmission system. The 

Commission established a required power factor range in Order No. 2003 of 0.95 leading 

to 0.95 lagging. See Standardization of Generator Interconnection Agreements and 

Procedures, Order No. 2003, FERC Stats. & Regs. ¶ 31,146, at P 542 (2003), order on 

reh’g, Order No. 2003-A, FERC Stats. & Regs. ¶ 31,160, order on reh’g, Order No. 

2003-B, FERC Stats. & Regs. ¶ 31,171 (2004), order on reh’g, Order No. 2003-C, FERC 

Stats. & Regs. ¶ 31,190 (2005), aff'd sub nom. Nat’l Ass’n of Regulatory Util. Comm’rs v. 

FERC, 475 F.3d 1277 (D.C. Cir. 2007), cert. denied, 552 U.S. 1230 (2008).

2 Section 9.6.1 of the pro forma LGIA and section 1.8.1 of the pro forma SGIA.

3 Reactive power sources are generally categorized as static or dynamic based on 

the speed and continuity at which they can produce or absorb reactive power in response 

to changes in system conditions. In general, dynamic reactive power devices are 

characterized by faster acting and continuously variable voltage control capability.
Docket No. RM16-1-000 - 3 -

requirement absent a study finding the provision of reactive power necessary, because 

historically, costs for an interconnection customer to design and build a wind generator 

that could provide reactive power were high and could have created an obstacle to the 

development of wind generation.4

 However, due to technological advancements, wind 

generators can now provide reactive power more cheaply and the cost of providing 

reactive power no longer presents an obstacle to the development of wind generation.5

 

The subsequent decline in the cost to wind generators of providing reactive power may 

make it unduly discriminatory and preferential to exempt wind generators from the 

reactive power requirement when other types of generators are not exempt. Further, the 

growing penetration of wind generators on some systems increases the potential for a 

deficiency in reactive power.

6

 Given this potential, the Commission’s current 

requirement that the transmission provider conduct a study to determine whether each 

new wind generator needs to provide reactive power may unduly place the burden of 

supplying reactive power on synchronous generators without a reasonable technological 

or cost-based basis.

3. Therefore, the Commission proposes to eliminate the existing exemptions for wind 

generators, and thereby require that all newly interconnecting non-synchronous

 4 Interconnection for Wind Energy, Order No. 661, FERC Stats. & Regs. ¶ 31,186,

at P 51, order on reh’g, Order No. 661-A, FERC Stats. & Regs. ¶ 31,198 (2005).

5 Payment for Reactive Power, Commission Staff Report, Docket No. AD14-7, 

app. 2, at 1-3 (Apr. 22, 2014).

6 See PJM Interconnection, L.L.C., 151 FERC ¶ 61,097, at P 7 (2015).
Docket No. RM16-1-000 - 4 -

generators provide dynamic reactive power as a condition of interconnection. This

requirement would also apply to all existing non-synchronous generators making

upgrades to their generation facilities that require new interconnection requests. The 

proposals set forth in this Proposal are intended to ensure that all generators, synchronous 

and non-synchronous, are treated in a not unduly discriminatory or preferential manner, 

as required by sections 205 and 206 of the Federal Power Act (FPA),7 and to ensure 

sufficient reactive power is available on the electric grid as more non-synchronous 

generators seek to interconnect.

4. The Commission seeks comment on these proposed reforms sixty (60) days after 

publication of this Proposal in the Federal Register.

Background

5. Transmission providers require reactive power to control system voltage for 

efficient and reliable operation of an alternating current transmission system. At times, 

transmission providers need generators to either supply or consume reactive power. 

Starting with Order No. 888,8 which included provisions regarding reactive power from 

 7 16 U.S.C. §§ 824a, 824b (2012).

8 Promoting Wholesale Competition Through Open Access Non-Discriminatory 

Transmission Services by Public Utilities; Recovery of Stranded Costs by Public Utilities 

and Transmitting Utilities, Order No. 888, FERC Stats. & Regs. ¶ 31,036 (1996), order 

on reh’g, Order No. 888-A, FERC Stats. & Regs. ¶ 31,048, order on reh’g, Order No. 

888-B, 81 FERC ¶ 61,248 (1997), order on reh’g, Order No. 888-C, 82 FERC ¶ 61,046 

(1998), aff’d in relevant part sub nom. Transmission Access Policy Study Group v. 

FERC, 225 F.3d 667 (D.C. Cir. 2000), aff’d sub nom. New York v. FERC, 535 U.S. 1 

(2002).
Docket No. RM16-1-000 - 5 -

generators as an ancillary service in Schedule 2 of the pro forma Open Access 

Transmission Tariff (OATT), the Commission issued a series of orders intended to ensure 

that sufficient reactive power is available to maintain the reliability of the electric grid.

6. Starting with Order No. 2003, the Commission adopted standard procedures and a 

standard agreement for the interconnection of large generation facilities (the pro forma 

LGIA), which included the reactive power requirement.9

 The Commission recognized in 

Order No. 2003-A that the pro forma LGIA was “designed around the needs of large 

synchronous generators and that generators relying on newer technologies may find that 

either a specific requirement is inapplicable or that it calls for a slightly different 

approach” because such generators “may have unique electrical characteristics.”10 

Therefore, the Commission exempted wind generators from the reactive power 

requirement and added a blank Appendix G to the pro forma LGIA as a placeholder for

future interconnection requirements for newer technologies.11

 9 Order No. 2003, FERC Stats. & Regs. ¶ 31,146 at PP 1, 542.

10 Order No. 2003-A, FERC Stats. & Regs. ¶ 31,160 at P 407 & n.85.

11 Id. Article 9.6.1 of the pro forma LGIA provides: “Interconnection Customer 

shall design the Large Generating Facility to maintain a composite power delivery at 

continuous rated power output at the Point of Interconnection at a power factor within the 

range of 0.95 leading to 0.95 lagging, unless Transmission Provider has established 

different requirements that apply to all generators in the Control Area on a comparable 

basis. The requirements of this paragraph shall not apply to wind generators.”
Docket No. RM16-1-000 - 6 -

7. In June 2005, the Commission issued Order No. 661,12 establishing 

interconnection requirements in Appendix G to the pro forma LGIA for large wind 

generators.13 Recognizing that, unlike traditional synchronous generators, wind 

generators had to “install costly equipment” in order to maintain reactive power 

capability, the Commission in Order No. 661 preserved the exemption for large wind 

generators from the reactive power requirement unless the transmission provider shows, 

through a System Impact Study, that reactive power capability is required to ensure safety 

or reliability.14 The Commission explained that this qualified exemption from the 

reactive power requirement for large wind generators would provide certainty to the 

industry and “remove unnecessary obstacles to the increased growth of wind 

generation.”15

8. In May 2005, the Commission issued Order No. 2006,16 in which it adopted 

standard procedures and a standard agreement for the interconnection of small generation 

 12 Interconnection for Wind Energy, Order No. 661, FERC Stats. & Regs. 

¶ 31,186, Appendix B (Appendix G – Interconnection Requirements for a Wind 

Generating Plant), order on reh’g, Order No. 661-A, FERC Stats. & Regs. ¶ 31,198 

(2005).

13 Id. P 1.

14 Id. PP 50-51. Appendix G states: “A wind generating plant shall maintain a 

power factor within the range of 0.95 leading to 0.95 lagging, measured at the Point of 

Interconnection as defined in this LGIA, if the Transmission Provider’s System Impact 

Study shows that such a requirement is necessary to ensure safety and reliability.”

15 Id. P 50.

16 Standardization of Small Generator Interconnection Agreements and 

Procedures, Order No. 2006, FERC Stats. & Regs. ¶ 31,180, Attachment F (Small 

(continued...)
Docket No. RM16-1-000 - 7 -

facilities (pro forma SGIA).17 In Order No. 2006, the Commission completely exempted 

small wind generators from the reactive power requirement.18 The Commission reasoned 

that, similar to large wind generators, small wind generators would face increased costs 

to provide reactive power that could create an obstacle to the development of small wind 

generators. Additionally, the Commission reasoned that small wind generators would 

“have minimal impact on the Transmission Provider’s electric system” and therefore the 

reliability requirements for large wind generators that were eventually imposed in Order 

No. 661 were not needed for small wind generators.19

9. Since the Commission provided these exemptions from the reactive power 

requirement for wind generators, the equipment needed for a wind generator to provide 

reactive power appears to have become more commercially available and less costly, 

such that the cost of installing equipment that is capable of providing reactive power is 

 

Generator Interconnection Agreement), order on reh’g, Order No. 2006-A, FERC Stats. 

& Regs. ¶ 31,196 (2005), order granting clarification, Order No. 2006-B, FERC Stats. & 

Regs. ¶ 31,221 (2006).

17 Id. P 1.

18 Id. P 387. Section 1.8.1 of the pro forma SGIA states: “The Interconnection 

Customer shall design its Small Generating Facility to maintain a composite power 

delivery at continuous rated power output at the Point of Interconnection at a power 

factor within the range of 0.95 leading to 0.95 lagging, unless the Transmission Provider 

has established different requirements that apply to all similarly situated generators in the 

control area on a comparable basis. The requirements of this paragraph shall not apply to 

wind generators.”

19 Id. P 24.
Docket No. RM16-1-000 - 8 -

comparable to the costs of a traditional generator.

20 Recognizing these factors, the 

Commission recently accepted a proposal by PJM Interconnection, L.L.C. (PJM) to 

effectively remove the wind generator exemption from the PJM tariff.

21 Specifically, the

Commission granted PJM an “independent entity variation” from Order No. 661 in 

accepting PJM’s proposal to require interconnection customers seeking to interconnect 

non-synchronous generators,22 including wind generators, to use “enhanced inverters” 

with the capability to provide reactive power.23 The Commission observed that, 

“[a]lthough there are still technical differences between non-synchronous generators

[such as wind generators] and traditional generators, with regard to the provision of 

reactive power, those differences have significantly diminished since the Commission 

issued Order No. 661.”24 The Commission agreed with PJM “that the technology has 

changed both in availability and in cost since the Commission rejected [the California 

 20 Payment for Reactive Power, Commission Staff Report, Docket No. AD14-7, 

app. 1, at 6, app. 2, at 4-5 (Apr. 22, 2014).

21 PJM Interconnection, L.L.C., 151 FERC ¶ 61,097, at P 28 (2015).

22 Non-synchronous generators are “connected to the bulk power system through 

power electronics, but do not produce power at system frequency (60 Hz).” They “do not 

operate in the same way as traditional generators and respond differently to network 

disturbances.” Id. P 1 n.3 (citing Order No. 661, FERC Stats. & Regs. ¶ 31,198 at P 3 

n.4). Wind and solar photovoltaic generators are two examples of non-synchronous 

generators.

23 Id. PP 1, 6.

24 Id. P 28.
Docket No. RM16-1-000 - 9 -

Independent System Operator’s] proposal in 2010,” such that “PJM’s proposal will not 

present a barrier to non-synchronous resources.”25

Discussion

10. The continued exemption from the reactive power requirement in the pro forma

LGIA and the pro forma SGIA for newly interconnecting wind generators appears to be 

unjust, unreasonable, and unduly discriminatory or preferential. Older wind turbine 

generators consumed reactive power; however, they lacked the capability to produce and 

control reactive power without the use of costly equipment because they did not use 

inverters like other non-synchronous generators.

26 Technological advances have been 

made in the inverters used by wind generators.27 Based on these improvements, requiring 

newly interconnecting wind generators to provide reactive power does not appear to be 

the obstacle to the development of wind generation that it was when the Commission 

issued Order Nos. 2003, 661, and 2006.28 In particular, the wind turbines being installed 

 25 Id.

26 Order No. 661, FERC Stats. & Regs. ¶ 31,186 at PP 50-51.

27 Non-synchronous generators produce electricity that is not synchronized to the 

electric grid (i.e., direct current (DC) power or alternating current (AC) power at a 

frequency other than 60 hertz). Inverters convert non-synchronized AC or DC power into 

synchronized AC power that can be transmitted on the transmission system.

28 As discussed above, in exempting wind generators from the reactive power 

requirement, the Commission sought to avoid creating an obstacle to the development of 

wind generation. For example, in Order No. 661, the Commission was concerned with 

“remov[ing] unnecessary obstacles to the increased growth of wind generation.” Id. P 50.
Docket No. RM16-1-000 - 10 -

today are generally Type III and Type IV inverter-based turbines,29 which are capable of 

producing and controlling dynamic reactive power, which was not the case in 2005 when 

the Commission exempted wind generators from the reactive power requirement in Order 

No. 661.30 The Commission preliminarily concludes that improvements in technology 

and the corresponding declining costs to newly interconnecting wind generators in 

providing reactive power make it unduly discriminatory and preferential to exempt such 

non-synchronous generators from the reactive power requirement when other types of 

generators are not exempt. Given the reduced costs to newly interconnecting wind 

generators to provide reactive power, requiring them to operate within the required power 

factor range would ensure they satisfy the same requirements as other generators and 

satisfy a basic requirement of interconnection.

31

11. Further, the Commission is concerned that, as the penetration of wind generation 

continues to grow, exempting a class of generators from providing reactive power could 

create reliability issues if those generators represent a substantial amount of total 

 29 A Type III wind turbine is a non-synchronous wound-rotor generator that has a 

three phase AC field applied to the rotor from a partially-rated power-electronics 

converter. A Type IV wind turbine is an AC generator in which the stator windings are 

connected to the power system through a fully-rated power-electronics converter. Both 

Type III and Type IV wind turbines have inherent reactive power capabilities.

30 Id. PP 50-51.

31 See, e.g., Sw. Power Pool, Inc., 119 FERC ¶ 61,199, at P 29 (“Providing 

reactive power within the [standard power factor range] is an obligation of a generator, 

and is as much an obligation of a generator as, for example, operating in accordance with 

Good Utility Practice.”), order on reh’g, 121 FERC ¶ 61,196 (2007).
Docket No. RM16-1-000 - 11 -

generation, or if many of the resources that currently provide reactive power are retired 

from operation. Local reliability issues, due to the short distances that reactive power can 

be transmitted, that are not readily apparent given the current generation mix could result 

if a region were to lose synchronous resources that supply reactive power and the 

resulting generation mix consisted of a significant quantity of resources that were exempt 

from providing reactive power. Further, the Commission believes that maintaining this 

exemption may unduly place the burden of supplying reactive power on synchronous 

generators without a reasonable technological or cost-based distinction between 

synchronous and non-synchronous generators.

32

12. Therefore, the Commission preliminarily concludes that the continued exemption 

from the reactive power requirement for newly interconnecting wind generators is unjust 

and unreasonable and unduly discriminatory and preferential. The Commission, 

therefore, proposes to revise the pro forma LGIA, Appendix G of the pro forma LGIA, 

and the pro forma SGIA to eliminate the exemptions for wind generators from the

reactive power requirement.33 Under this Proposal, newly interconnecting non-

 32 See PJM Interconnection, L.L.C., 151 FERC ¶ 61,097, at P 7 (2015); Payment 

for Reactive Power, Commission Staff Report, Docket No. AD14-7, app. 1 (Apr. 22, 

2014).

33 The Commission does not propose to revise any regulatory text. The 

Commission proposes to revise the pro forma LGIA and pro forma SGIA in accordance 

with section 35.28(f)(1) of the Commission’s regulations, which provides: “Every public 

utility that is required to have on file a non-discriminatory open access transmission tariff 

under this section must amend such tariff by adding the standard interconnection 

procedures and agreement and the standard small generator interconnection procedures 

and agreement required by Commission rulemaking proceedings promulgating and 

(continued...)
Docket No. RM16-1-000 - 12 -

synchronous generators would be eligible for the same payments for reactive power as 

other generators.34 Any compensation would be based on the cost of providing reactive 

power. We note that the cost to a wind generator of providing reactive power may not be 

easily estimated using existing methods that are applied to synchronous generators.35 

The Commission also proposes that transmission providers that are not public utilities 

will have to adopt the requirements of this Proposal as a condition of maintaining the 

status of their safe harbor tariff or otherwise satisfying the reciprocity requirement of 

Order No. 888.36

13. Removing the exemptions for wind generators from the reactive power 

requirement would specifically require all newly interconnecting non-synchronous 

generators, and all existing non-synchronous generators proposing upgrades to their 

generation facilities that require new interconnection requests, to design their generating 

 

amending such interconnection procedures and agreements, or such other interconnection 

procedures and agreements as may be required by Commission rulemaking proceedings 

promulgating and amending the standard interconnection procedures and agreement and 

the standard small generator interconnection procedures and agreement.” 18 C.F.R. § 

35.28(f)(1) (2015). See Integration of Variable Energy Resources, Order No. 764, FERC 

Stats. & Regs. ¶ 31,331, at PP 343-345 (adopting this regulatory text effective September 

11, 2012), order on reh’g and clarification, Order No. 764-A, 141 FERC ¶ 61,232 

(2012), order on clarification and reh’g, Order No. 764-B, 144 FERC ¶ 61,222 (2013). 

While not revising regulatory text, the Commission is using the process provided for 

rulemaking proceedings, as defined in 5 U.S.C. § 551(4)-(5) (2012).

34 Order No. 2003-A, FERC Stats. & Regs. ¶ 31,160 at P 416.

35 See Payment for Reactive Power, Commission Staff Report, Docket No. AD14-

7, app. 2 (Apr. 22, 2014).

36 Order No. 888, FERC Stats. & Regs. ¶ 31,036 at 31,760-63.
Docket No. RM16-1-000 - 13 -

facilities to maintain reactive power within a power factor range of 0.95 leading to 0.95 

lagging, or the standard range established by the transmission provider and approved by 

the Commission, to be measured at the Point of Interconnection.37 

14. The Commission also proposes to require that the reactive power capability 

installed by non-synchronous generators be dynamic. In Order No. 661, the Commission 

declined to require dynamic reactive power capability from wind generators, unless the 

System Impact Study showed that dynamic reactive power capability was needed for 

system reliability, reasoning that dynamic reactive power capability may not be needed in 

every case.

38 Based on technological advancements, the Commission no longer believes 

it is just and reasonable and not unduly discriminatory or preferential to exempt wind 

generators from the requirement to provide dynamic reactive power.39

15. Further, the Commission proposes to require that newly interconnecting nonsynchronous generators be required to design the generating facility to maintain the 

required power factor range only when the generator’s real power output exceeds 10 

 37 The pro forma LGIA defines “Point of Interconnection” as “the point, as set 

forth in Appendix A to the Standard Large Generator Interconnection Agreement, where 

the Interconnection Facilities connect to the Transmission Provider’s Transmission 

System.” Similarly, the pro forma SGIA defines “Point of Interconnection” as “[t]he 

point where the Interconnection Facilities connect with the Transmission Provider’s 

Transmission System.”

38 See Order No. 661, FERC Stats. & Regs. ¶ 31,186 at P 66.

39 Payment for Reactive Power, Commission Staff Report, Docket No. AD14-7, at 

7 (Apr. 22, 2014).
Docket No. RM16-1-000 - 14 -

percent of its nameplate capacity.40 In requiring a generator to provide reactive power, 

the interconnection agreements would state: “Non-synchronous generators shall only be 

required to maintain the above power factor when their output is above 10 percent of the 

Generating Facility Capacity.” The Commission’s understanding is that the inverters 

used by non-synchronous generators are not capable of producing reactive power when 

operating below 10 percent of nameplate capacity.41

16. Specifically, the Commission proposes to revise section 9.6.1 of the pro forma 

LGIA to read:

Interconnection Customer shall design the Large Generating Facility to 

maintain a composite power delivery at continuous rated power output at 

the Point of Interconnection at a power factor within the range of 0.95 

leading to 0.95 lagging, unless Transmission Provider has established 

different requirements that apply to all generators in the Control Area on a 

comparable basis. The requirements of this paragraph shall not apply to 

wind generators. Non-synchronous generators shall only be required to

maintain the above power factor when their output is above 10 percent of 

the Generating Facility Capacity.42

The Commission similarly proposes to revise section 1.8.1 of the pro forma SGIA to 

read:

The Interconnection Customer shall design its Small Generating Facility to 

maintain a composite power delivery at continuous rated power output at 

the Point of Interconnection at a power factor within the range of 0.95 

leading to 0.95 lagging, unless the Transmission Provider has established 

different requirements that apply to all similarly situated generators in the 

control area on a comparable basis. The requirements of this paragraph 

 40 See Order No. 661, FERC Stats. & Regs. ¶ 31,186 at P 46.

41 Id.

42 Section 9.6.1 of the pro forma LGIA.
Docket No. RM16-1-000 - 15 -

shall not apply to wind generators. Non-synchronous generators shall only 

be required to maintain the above power factor when their output is above 

10 percent of the generator nameplate capacity.

43

In addition, the Commission would strike paragraph A.ii of Appendix G to the pro forma 

LGIA, “Technical Standards Applicable to a Wind Generation Plant.”44

A wind generating plant shall maintain a power factor within the range of 

0.95 leading to 0.95 lagging, measured at the Point of Interconnection as 

defined in this LGIA, if the Transmission Provider’s System Impact Study 

shows that such a requirement is necessary to ensure safety or reliability. 

The power factor range standard can be met by using, for example, power 

electronics designed to supply this level of reactive capability 606 (taking 

into account any limitations due to voltage level, real power output, etc.) or 

fixed and switched capacitors if agreed to by the Transmission Provider, or 

a combination of the two. The Interconnection Customer shall not disable 

power factor equipment while the wind plant is in operation. Wind plants 

shall also be able to provide sufficient dynamic voltage support in lieu of 

the power system stabilizer and automatic voltage regulation at the 

generator excitation system if the System Impact Study shows this to be 

required for system safety or reliability.45

17. The Commission proposes to apply the reactive power requirement to all newly

interconnecting non-synchronous generators, as well as all existing non-synchronous

generators making upgrades to their generation facilities that require new interconnection

requests, as of the effective date of the final revision. The Commission also proposes to

apply the reactive power requirement to all newly interconnecting non-synchronous

 43 Section 1.8.1 of the pro forma SGIA.

44 The full text of the pro forma LGIA will be posted on the Commission’s 

internet page at: http://www.ferc.gov/industries/electric/indus-act/gi/stnd-gen.asp. The 

full text of the pro forma SGIA will be posted on the Commission’s internet page at: 

http://www.ferc.gov/industries/electric/indus-act/gi/small-gen.asp.

45 Section A.ii of Appendix G to the pro forma LGIA.
Docket No. RM16-1-000 - 16 -

generators that have requested that an LGIA or SGIA be filed unexecuted with the

Commission that is still pending before the Commission as of the effective date of the

final revision. Thus, the requirement would not apply to non-synchronous generators that

have executed an LGIA or SGIA, as relevant, prior to the effective date of the final

revision, unless they propose upgrades to their generation facilities that require new

interconnection requests. Given that not all existing wind generators are capable of 

providing reactive power without incurring substantial costs to install new equipment, we 

do not believe it is reasonable or necessary to require those generators to provide reactive 

power. However, existing wind generators that make upgrades to their generation facility 

that require a new interconnection request will be required to conform to this new 

requirement.

18. The Commission seeks comments on the Proposal to remove the exemptions for

wind generators from the reactive power requirement. Further, the Commission seeks

comments on whether the current power factor range of 0.95 leading to 0.95 lagging, as

set forth in the existing pro forma interconnection agreements,46 is reasonable given the

technology used by non-synchronous generators. The Commission also seeks comments

on the proposed requirement that newly interconnecting non-synchronous generators only

be required to produce reactive power when the generator’s real power output is greater

than 10 percent of nameplate capacity. And finally, we note that a non-synchronous

generator will be eligible for compensation for reactive power, consistent with the

 46 Section 9.6.1 of the pro forma LGIA and section 1.8.1 of the pro forma SGIA.
Docket No. RM16-1-000 - 17 -

compensation provisions of the pro forma LGIA and pro forma SGIA.

47 The

Commission seeks comment on whether the existing methods used to determine reactive

power compensation are appropriate for wind generators and, if not, what alternatives

would be appropriate.

48

Proposed Compliance Procedures

19. To comply with the requirements of this Proposal, the Commission proposes to 

require each public utility49 transmission provider to submit a compliance filing within 90 

days of the effective date of the final revision in this proceeding revising its pro forma

LGIA and pro forma SGIA subject to the Commission’s jurisdiction as necessary to 

demonstrate that it meets the requirements set forth in this Proposal.

20. In some cases, public utility transmission providers may have provisions in their 

currently effective pro forma LGIAs and pro forma SGIAs related to the provision of 

reactive power by non-synchronous generators that the Commission has deemed to be 

consistent with or superior to the pro forma LGIA and pro forma SGIA. Where these pro 

forma LGIA and pro forma SGIA provisions will be modified by the final revision, 

public utility transmission providers must either comply with the final revision or 

 47 Section 9.6.3 of the pro forma LGIA and section 1.8.2 of the pro forma SGIA.

48 See Payment for Reactive Power, Commission Staff Report, Docket No. AD14-

7, app. 1 (Apr. 22, 2014).

49 For purposes of this Proposal, a public utility is a utility that owns, controls, or 

operates facilities used for transmitting electric energy in interstate commerce, as defined 

by the FPA. See 16 U.S.C. § 824(e) (2012). A non-public utility that seeks voluntary 

compliance with the reciprocity condition of an OATT may satisfy that condition by 

filing an OATT, which includes the pro forma LGIA and SGIA.
Docket No. RM16-1-000 - 18 -

demonstrate that these previously-approved pro forma LGIA and pro forma SGIA 

variations continue to be consistent with or superior to the pro forma LGIA and pro 

forma SGIA as modified by the final revision.

21. The Commission will assess whether each compliance filing satisfies the proposed 

requirements and principles stated above and issue additional orders as necessary to 

ensure that each public utility transmission provider meets the requirements of this 

Proposal and the subsequent final revision.

22. The Commission proposes that transmission providers that are not public utilities

will have to adopt the requirements of this Proposal and subsequent final revision as a 

condition of maintaining the status of their safe harbor tariff or otherwise satisfying the 

reciprocity requirement of Order No. 888.50

Information Collection Statement

23. The collection of information contained in this Proposal to Revise Standard 

Generator Interconnection Agreements is subject to review by the Office of Management 

and Budget (OMB) regulations under section 3507(d) of the Paperwork Reduction Act of 

1995 (PRA).51 OMB’s regulations require approval of certain informational collection 

requirements imposed by an agency.

52 Upon approval of a collection(s) of information, 

OMB will assign an OMB control number and an expiration date. Respondents subject 

 50 Order No. 888, FERC Stats. & Regs. ¶ 31,036 at 31,760-63.

51 44 U.S.C. § 3507(d) (2012).

52 5 C.F.R. § 1320.11 (2015).
Docket No. RM16-1-000 - 19 -

to the filing requirements will not be penalized for failing to respond to these collections 

of information unless the collections of information display a valid OMB control number.

24. The reforms proposed in this Proposal would amend the Commission’s standard 

generator interconnection agreements in accordance with section 35.28(f)(1) of the 

Commission’s regulations53 to require that each public utility transmission provider 

amend its pro forma LGIA and pro forma SGIA to: (1) eliminate the exemptions for 

wind generators from the requirement to provide reactive power; and (2) require that all 

newly interconnecting non-synchronous generators, as well as all existing nonsynchronous generators making upgrades to their generation facilities that require new 

interconnection requests, provide reactive power as a condition of interconnection, as of 

the effective date of the final revision. The reforms proposed in this Proposal would 

require filings of pro forma LGIAs and pro forma SGIAs with the Commission. The 

Commission anticipates the reforms proposed in this Proposal, once implemented, would 

not significantly change currently existing burdens on an ongoing basis. With regard to 

those public utility transmission providers that believe that they already comply with the 

reforms proposed in this Proposal, they could demonstrate their compliance in the filing 

required 90 days after the effective date of the final revision in this proceeding. The 

Commission will submit the proposed reporting requirements to OMB for its review and 

approval under section 3507(d) of the Paperwork Reduction Act.54

 53 18 C.F.R. § 35.28(f)(1) (2015).

54 44 U.S.C. § 3507(d) (2012).
Docket No. RM16-1-000 - 20 -

25. While the Commission expects the adoption of the reforms proposed in this 

Proposal to provide significant benefits, the Commission understands that 

implementation can be a complex and costly endeavor. The Commission solicits 

comments on the accuracy of provided burden and cost estimates and any suggested 

methods for minimizing the respondents’ burdens.

Burden Estimate and Information Collection Costs: The Commission believes that the 

burden estimates below are representative of the average burden on respondents. The 

estimated burden and cost55 for the requirements contained in this Proposal follow.

 55 The estimates for cost per response are derived using the following formula: 

Average Burden Hours per Response * $72 per Hour = Average Cost per Response. The 

hourly cost figure comes from the FERC average salary of $149,489. Subject matter 

experts found that industry employment costs closely resemble FERC’s regarding the 

FERC-516 information collection.
Docket No. RM16-1-000 - 21 -

Data Collection

FERC 516

Number of 

Applicable 

Registered 

Entities

(1)

Annual 

Number of 

Responses 

per 

Respondent

(2)

Total 

Number of 

Responses 

(1)*(2)=(3)

Average 

Burden 

(Hours) & 

Cost Per 

Response56

(4)

Total 

Annual 

Burden 

Hours & 

Total 

Annual Cost

(3)*(4)=(5)

Conforming 

LGIA

changes to 

incorporate 

proposed 

revisions

132 1 132 7.5

$540.00

990 hours

$71,280.00 

Conforming 

SGIA

changes to 

incorporate 

proposed 

revisions

132 1 132 7.5

$540.00

990 hours

$71,280.00

Total 264 15 hours

$1,080

1,980 hours

$142,560.00

Cost to Comply: The Commission has projected the total cost of compliance as 

follows:57

• Year 1: $142,560 ($1,080/utility)

• Year 2: $0

 56 $149,489 / $2,080 = $71.8697 and is rounded to $72.00 per hour.

57 The costs for Year 1 would consist of filing proposed changes to the pro forma

LGIA and pro forma SGIA with the Commission within 90 days of the effective date of 

the final revision plus initial implementation. The Commission does not expect any 

ongoing costs beyond the initial compliance in Year 1.
Docket No. RM16-1-000 - 22 -

After Year 1, the reforms proposed in this Proposal, once implemented, would not 

significantly change existing burdens on an ongoing basis.

Title: FERC-516, Electric Rate Schedules and Tariff Filings.

Action: Proposed revisions to an information collection.

OMB Control No.: 1902-0096

Respondents for this Proposal: Businesses or other for profit and/or not-for-profit 

institutions.

Frequency of Information: One-time during year one.

Necessity of Information: The Federal Energy Regulatory Commission makes this 

Proposal to improve the reliability of the electric grid by requiring all newly 

interconnecting non-synchronous generators to provide reactive power and to ensure that 

all generators are being treated in a not unduly discriminatory or preferential manner.

Internal Review: The Commission has reviewed the proposed changes and has 

determined that such changes are necessary. These requirements conform to the 

Commission’s need for efficient information collection, communication, and 

management within the energy industry. The Commission has specific, objective support 

for the burden estimates associated with the information collection requirements.

26. Interested persons may obtain information on the reporting requirements by 

contacting the following: Federal Energy Regulatory Commission, 888 First Street, NE, 

Washington, DC 20426 [Attention: Ellen Brown, Office of the Executive Director], 

e-mail: DataClearance@ferc.gov, phone: (202) 502-8663, fax: (202) 273-0873. 

Comments concerning the collection of information and the associated burden 
Docket No. RM16-1-000 - 23 -

estimate(s), may also be sent to the Office of Information and Regulatory Affairs, 

Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503 

[Attention: Desk Officer for the Federal Energy Regulatory Commission, phone: 

(202) 395-0710, fax: (202) 395-7285]. Due to security concerns, comments should be 

sent electronically to the following e-mail address: oira_submission@omb.eop.gov. 

Comments submitted to OMB should include FERC-516 and OMB Control 

No. 1902-0096.

Regulatory Flexibility Act Certification

27. The Regulatory Flexibility Act of 1980 (RFA)58 generally requires a description 

and analysis of rules that will have significant economic impact on a substantial number 

of small entities. The RFA does not mandate any particular outcome in a rulemaking. It 

only requires consideration of alternatives that are less burdensome to small entities and 

an agency explanation of why alternatives were rejected.

28. To the extent the RFA applies to this proceeding, the Commission estimates that 

the total number of public utility transmission providers that would have to modify their 

currently effective pro forma LGIA and pro forma SGIA is 132. Of these, the 

Commission estimates the total number that are small entities is 11. The Commission 

estimates the average total cost of these entities will be minimal, requiring on average 15 

hours, or $1,080 in expenses. The Commission does not consider this to be a significant 

economic impact. As a result, the Commission certifies that the reforms proposed in this 

 58 5 U.S.C. § 601-12 (2012).
Docket No. RM16-1-000 - 24 -

Proposal would not have a significant economic impact on a substantial number of small 

entities.

Environmental Analysis

29. The Commission is required to prepare an Environmental Assessment or an 

Environmental Impact Statement for any action that may have a significant adverse effect 

on the human environment.59 The Commission concludes that neither an Environmental 

Assessment nor an Environmental Impact Statement is required for this Proposal under 

section 380.4(a)(15) of the Commission’s regulations, which provides a categorical 

exemption for approval of actions under sections 205 and 206 of the FPA relating to the 

filing of schedules containing all rates and charges for the transmission or sale of electric 

energy subject to the Commission’s jurisdiction, plus the classification, practices, 

contracts and regulations that affect rates, charges, classifications, and services.60 The 

revisions proposed in this Proposal would update and clarify the application of the 

Commission’s standard interconnection requirements to wind generators. Therefore, this 

Proposal falls within the categorical exemptions provided in the Commission’s 

regulations, and as a result neither an environmental impact statement nor an 

environmental assessment is required.

 59 Regulations Implementing the National Environmental Policy Act of 1969, 

Order No. 486, 52 Fed. Reg. 47,897 (Dec. 17, 1987), FERC Stats. & Regs., Regulations 

Preambles 1986-1990 ¶ 30,783 (1987).

60 18 C.F.R. § 380.4(a)(15) (2015).
Docket No. RM16-1-000 - 25 -

Comment Procedures

30. The Commission invites interested persons to submit comments on the matters and 

issues proposed in this Proposal to be adopted, including any related matters or 

alternative proposals that commenters may wish to discuss. Comments are due [60 days 

after publication in the FEDERAL REGISTER]. Comments must refer to Docket No. 

RM16-1-000, and must include the commenter’s name, the organization they represent, if 

applicable, and their address.

31. The Commission encourages comments to be filed electronically via the eFiling 

link on the Commission’s web site at http://www.ferc.gov. The Commission accepts 

most standard word processing formats. Documents created electronically using word 

processing software should be filed in native applications or print-to-PDF format and not 

in a scanned format. Commenters filing electronically do not need to make a paper 

filing.

32. Commenters that are not able to file comments electronically must send an 

original of their comments to: Federal Energy Regulatory Commission, Secretary of the 

Commission, 888 First Street, NE, Washington, DC 20426.

33. All comments will be placed in the Commission’s public files and may be viewed, 

printed, or downloaded remotely as described in the Document Availability section 

below. Commenters on this Proposal are not required to serve copies of their comments 

on other commenters.
Docket No. RM16-1-000 - 26 -

Document Availability

34. In addition to publishing the full text of this document in the Federal Register, the 

Commission provides all interested persons an opportunity to view and/or print the 

contents of this document via the Internet through the Commission’s Home Page 

(http://www.ferc.gov) and in the Commission’s Public Reference Room during normal 

business hours (8:30 a.m. to 5:00 p.m. Eastern time) at 888 First Street, NE, Room 2A, 

Washington, DC 20426.

35. From the Commission’s Home Page on the Internet, this information is available 

on eLibrary. The full text of this document is available on eLibrary in PDF and 

Microsoft Word format for viewing, printing, and/or downloading. To access this 

document in eLibrary, type the docket number of this document, excluding the last 

three digits, in the docket number field.

36. User assistance is available for eLibrary and the Commission’s website during 

normal business hours from the Commission’s Online Support at (202) 502-6652 (toll 

free at 1-866-208-3676) or email at ferconlinesupport@ferc.gov, or the Public Reference 

Room at (202) 502-8371, TTY (202) 502-8659. E-mail the Public Reference Room at 

public.referenceroom@ferc.gov.
Docket No. RM16-1-000 - 27 -

List of subjects in 18 C.F.R. Part 35:

Electric power rates

Electric utilities

Non-discriminatory open access transmission tariffs

By direction of the Commission.

( S E A L )

Nathaniel J. Davis, Sr.,

Deputy Secretary.