130 FERC ¶ 61,053 

UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

18 CFR Chapter I 

(Docket No. RM10-11-000) 

Integration of Variable Energy Resources 

(Issued January 21, 2010) 

AGENCY: Federal Energy Regulatory Commission. 

ACTION: Notice of Inquiry. 

SUMMARY: In this Notice of Inquiry, the Federal Energy Regulatory Commission 

(Commission) seeks comment on the extent to which barriers may exist that impede the 

reliable and efficient integration of variable energy resources (VERs) into the electric 

grid, and whether reforms are needed to eliminate those barriers. In order to meet the 

challenges posed by the integration of increasing numbers of VERs, ensure that 

jurisdictional rates are just and reasonable, eliminate impediments to open access 

transmission service for all resources, facilitate the efficient development of 

infrastructure, and ensure that the reliability of the grid is maintained, the Commission 

seeks to explore whether reforms are necessary to ensure that wholesale electricity tariffs 

are just, reasonable and not unduly discriminatory. This Notice will enable the 

Commission to determine whether wholesale electricity tariff reforms are necessary. 

DATES: Comments are due [Insert date that is 60 days after publication in the 

FEDERAL REGISTER]. 
Docket No. RM10-11-000 - 2 - 

ADDRESSES: You may submit comments, identified by docket number by any of the 

following methods: 

 Agency Web Site: http://ferc.gov. Documents created electronically using word 

processing software should be filed in native applications or print-to-PDF format 

and not in a scanned format. 

 Mail/Hand Delivery: Commenters unable to file comments electronically must 

mail or hand deliver an original and 14 copies of their comments to: Federal 

Energy Regulatory Commission, Secretary of the Commission, 888 First Street, 

NE, Washington, DC 20426. 

FOR FURTHER INFORMATION CONTACT: 

Mk Shean (Technical Information) 

Office of Energy Policy and Innovations 

Federal Energy Regulatory Commission 

888 First Street, NE 

Washington, DC 20426 

(202) 502-6792 

Mk.Shean@ferc.gov 

Timothy Duggan (Legal Information) 

Office of General Counsel – Energy Markets 

Federal Energy Regulatory Commission 

888 First Street, NE 

Washington, DC 20426 

(202) 502-8326 

Timothy.Duggan@ferc.gov 

SUPPLEMENTARY INFORMATION:
130 FERC ¶ 61,053 

UNITED STATES OF AMERICA 

FEDERAL ENERGY REGULATORY COMMISSION 

Integration of Variable Energy Resources Docket No. RM10-11-000 

NOTICE OF INQUIRY 

(Issued January 21, 2010) 

1. In this Notice of Inquiry, the Federal Energy Regulatory Commission 

(Commission) seeks comment on the extent to which barriers exist that may impede the 

reliable and efficient integration of variable energy resources (VERs)1

 into the electric 

grid and whether reforms are needed to eliminate those barriers. VERs, such as resources 

powered by wind and solar energy, continue to make up an increasing percentage of the 

nation’s energy supply portfolio; however, they present unique challenges (such as 

location constraints and limited dispatchability) that are not typically presented by 

conventional electricity generating resources. VERs also present benefits, such as low 

marginal energy costs and reduced greenhouse gas emissions, which have contributed to 

the accelerated development of these resources. In order to meet these challenges and 

fully realize these benefits of VERs in a reliable and efficient manner, the Commission 

 1

 For purposes of this proceeding, the term variable energy resource (VER) refers 

to renewable energy resources that are characterized by variability in the fuel source that 

is beyond the control of the resource operator. This includes wind and solar generation 

facilities and certain hydroelectric resources.
Docket No. RM10-11-000 - 2 - 

seeks to explore whether reforms of existing policies are necessary to ensure that 

jurisdictional rates are just and reasonable and that the terms of jurisdictional service do 

not unduly discriminate against these resources. 

I. Background

2. While the amount of VERs remains relatively small as a percentage of total 

generation, it is rapidly increasing, reaching a point where such resources are becoming a 

significant component of the nation’s energy supply portfolio. In 2008, new wind 

generating capacity, totaling 8,376 MW, made up 42 percent of all newly installed 

generating capacity.2

 Moreover, in recent years, a number of state renewable portfolio 

standards and other incentives/mandates have been passed to encourage the development 

of renewable energy resources, in response to a growing concern about the environmental 

impacts and sustainability of the Nation’s current electricity supply portfolio. As of 

December 2009, 30 states, including the District of Columbia, had a renewable portfolio 

standard.3

 

3. While VERs have many desirable characteristics, including low marginal energy 

costs and reduced greenhouse gas and other pollutant emissions, compared to 

conventional fossil-fueled generation, they also present unique challenges as public 

 2

 Div. of Market Oversight, Fed. Energy Regulatory Comm’n, 2008 State of the 

Markets Report 19 (2009), available at http://www.ferc.gov/market-oversight/st-mktovr/2008-som-final.pdf. 

3

 Div. of Market Oversight, Fed. Energy Regulatory Comm’n, Renewable Power 

and Energy Efficiency Market: Renewable Portfolio Standards 1 (2009), available at

http://www.ferc.gov/market-oversight/othr-mkts/renew/othr-rnw-rps.pdf. 
Docket No. RM10-11-000 - 3 - 

utilities work to integrate VERs in a way that ensures system reliability. For example, 

because VERs cannot control or store their fuel source, they have limited ability to 

control their production of electricity, and the weather-related phenomena that drive VER 

output levels can be difficult to forecast. Also, the output from some VERs can be 

negatively correlated with demand, such that a resource’s greatest energy output often 

comes at a time of limited energy demand. Changes in the rate of output from VERs may 

also result in substantial ramps,4

 which can require additional resources to allow System 

Operators5

 to balance generation and demand while maintaining reliability in real time. 

4. In this proceeding, the Commission seeks to explore whether existing rules, 

regulations, tariffs, or industry practices within the Commission’s jurisdiction may hinder 

the reliable and efficient integration of VERs, resulting in rates that are unjust and 

unreasonable and/or terms of service that unduly discriminate against certain types of 

resources. The Commission seeks comment on how best to reform any such rules, 

regulations, tariffs, or industry practices. 

5. Under sections 205 and 206 of the Federal Power Act, the Commission has a 

responsibility to remedy undue discrimination with respect to transmission of electric 

energy and sales of electric energy for resale in interstate commerce and to ensure that 

 4

 A ramp is the rate, expressed in megawatts per minute, that a generator changes 

its output. 

5

 System Operator refers to the individual at a control center—balancing authority, 

transmission operator, generator operator (VERs as well as conventional resources), or 

reliability coordinator—whose responsibility it is to monitor and control the electric 

system in real time. 
Docket No. RM10-11-000 - 4 - 

rates for these services are just and reasonable.6

 As the electric power industry has 

evolved, the Commission has discharged this responsibility in different ways. In Order 

No. 888, the Commission exercised its authority to remedy undue discrimination by 

requiring all public utilities to provide open access transmission service consistent with 

the terms of a pro forma open access transmission tariff (OATT).7

 The pro forma OATT 

addresses the terms of transmission service, including, among other things, the terms for 

scheduling transmission service, curtailments, and the provision of ancillary services. In 

Order No. 2003, the Commission acted to remove barriers in the generator 

interconnection process and adopted standard procedures (the Large Generation 

Interconnection Procedures or LGIP), and a standard agreement (the Large Generation 

Interconnection Agreement or LGIA) for the interconnection of generation resources 

larger than 20 MW.8

 More recently, in a further effort to remedy the potential for undue 

 6

 16 U.S.C. 824d, 824e. 

7 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). 

8 Standardization of Generator Interconnection Agreements and Procedures, Order 

No. 2003, FERC Stats. & Regs. ¶ 31,146 (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). Similarly, the Commission also adopted standard procedures for the 

 (continued...) 
Docket No. RM10-11-000 - 5 - 

discrimination, the Commission revised and updated the pro forma OATT in Order 

No. 890.9

 

6. With limited exceptions,10 these and other Commission efforts to remedy undue 

discrimination have not expressly accounted for the differences between VERs and more 

conventional generation resources. In large part this is due to the fact that the electric 

grid was developed during a time when electricity was almost exclusively generated from 

centralized, dispatchable resources that were powered by fuel sources that could be stored 

and used as needed. The Commission’s policies and the concomitant implementation of 

its responsibility under sections 205 and 206 were premised on this underlying physical 

reality of the electric grid. 

7. Where relevant, however, the Commission on several occasions has taken the 

operational characteristics of VERs into consideration in efforts to ensure just and 

 

interconnection of small generation resources. Standardization of Small Generator 

Interconnection Agreements and Procedures, Order No. 2006, FERC Stats. & Regs. 

¶ 31,180, 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). 

9 Preventing Undue Discrimination and Preference in Transmission Service, Order 

No. 890, FERC Stats. & Regs. ¶ 31,241, order on reh’g, Order No. 890-A, FERC Stats. & 

Regs. ¶ 31,261 (2007), order on reh’g, Order No. 890-B, 123 FERC ¶ 61,299 (2008),

order on reh’g, Order No. 890-C, 126 FERC ¶ 61,228, order on clarification, Order 

No. 890-D, 129 FERC ¶ 61,126 (2009). 

10 See, e.g., Interconnection for Wind Energy, Order No. 661, FERC Stats. & 

Regs. ¶ 31,186, order on reh’g, Order No. 661-A, FERC Stats. & Regs. ¶ 31,198 (2005) 

(adopting reforms to the LGIA and LGIP to establish standard technical requirements for 

interconnection of wind plants); Order No. 890, FERC Stats. & Regs. ¶ 31,241 at P 665 

(establishing a standard offer generation imbalance service, but exempting intermittent 

resources from the highest penalty band). 
Docket No. RM10-11-000 - 6 - 

reasonable rates and to remedy undue discrimination. In Order No. 661, the Commission 

required public utilities to revise their LGIAs and LGIPs to incorporate standard technical 

requirements for the interconnection of wind resources larger than 20 MW.11 In Order 

No. 890, the Commission applied a reduced penalty amount to intermittent resources’ 

imbalances that would otherwise be subject to the highest-tier generation imbalance 

penalties, recognizing “that intermittent generators cannot always accurately follow their 

schedules and that high penalties will not lessen the incentive to deviate from their 

schedules.”12 In addition, in Order No. 890 the Commission created conditional firm 

point-to-point transmission service, noting that conditional firm service can be 

particularly beneficial to renewable energy resources.13 Shortly after the issuance of 

Order No. 890, the Commission accepted a unique cost allocation mechanism for 

interconnection facilities connecting renewable energy resources that are locationconstrained, recognizing that the difficulties faced by these resources are different from 

those faced by other generation developers, and therefore support an appropriate variation 

of the interconnection pricing policy.14 

 11 Order No. 661, FERC Stats. & Regs. ¶ 31,186 (adopting, among other things, a 

low voltage ride-through standard, a power factor range, dynamic reactive power 

capability, and supervisory control and data acquisition (SCADA) capability). 

12 Order No. 890, FERC Stats. & Regs. ¶ 31,241 at P 664-65. 

13 Id. P 912. 

14 Cal. Indep. Sys. Operator Corp., 119 FERC ¶ 61,061, at P 69-70 (2007). See 

also Southwest Power Pool, Inc., 127 FERC ¶ 61,283, at P 29 (2009) (accepting a 

proposal to allocate network upgrade costs differently for wind resources being used to 

 (continued...) 
Docket No. RM10-11-000 - 7 - 

8. Such actions are premised on the notion that targeted revisions to Commission 

policies are sometimes necessary to ensure that jurisdictional rates are just and reasonable 

and to prevent undue discrimination against any one type of customer or resource as the 

characteristics of the nation’s generation portfolio change. 

II. Subject of the Notice of Inquiry

9. In this proceeding, the Commission seeks to take a fresh look at existing policies 

and practices in light of the changing characteristics of the nation’s generation portfolio 

with the aim of removing unnecessary barriers to transmission service and wholesale 

markets for VERs (and other technologies that may aid their integration) and promoting 

greater efficiencies that ultimately will reduce costs to consumers. While the 

Commission seeks comment on numerous challenges presented by the integration of 

VERs, this proceeding will not address issues related to transmission planning and cost 

allocation, as the Commission is considering those issues in another forum.15 

10. Our goal is not to adopt rules that favor one type of supply source over another. 

Instead, the Commission’s purpose in this proceeding is to investigate market and 

operational reforms necessary to achieve two goals: first, to ensure that rates for 

jurisdictional service are just and reasonable, reflecting the implementation of practices 

that increase the efficiency of providing service; and second, to prevent VERs from 

 

serve demand in a different zone than the methodology used for other resources). 

15 Transmission Planning Processes Under Order No. 890, Docket No. AD09-8-

000 (Oct. 8, 2009) (notice of request for comments). 
Docket No. RM10-11-000 - 8 - 

facing undue discrimination. These goals are consistent with the requirements of sections 

205 and 206 of the FPA. 

11. In addition, the Commission must ensure that any reforms are consistent with the 

need to maintain system reliability in accordance with Reliability Standards proposed by 

the North American Electric Reliability Corp. (NERC) and approved by the Commission 

pursuant to section 215 of the FPA.16 Although the scope of this proceeding is directed 

to market and operational reforms, in certain instances where commenters believe 

existing NERC Reliability Standards should be modified or new standards developed in 

conjunction with the market reforms considered herein, they may indicate as much, if 

directly related to this proceeding. In responding to the following questions, 

commenters should indicate how the reforms that they propose ensure the reliable 

operation of the grid, or would impact the reliable operation of the grid, as required by 

the reliability standards.17 

III. Questions for Response

12. To ensure that all generation resources are afforded non-discriminatory access to 

wholesale markets and the electric power grid and that wholesale market prices and the 

rates for transmission service are just and reasonable, the Commission seeks comment on 

the perceived barriers, and suggested solutions to removing those barriers, of integrating 

 16 16 U.S.C. 824o. 

17 See id. at 824o(a)(3). We note that NERC has an ongoing stakeholder process 

to examine how to accommodate high levels of variable generation. See North American 

Elec. Reliability Corp., Accommodating High Levels of Variable Generation (2009). 
Docket No. RM10-11-000 - 9 - 

VERs into the electric grid in a reliable and efficient manner. The Commission’s 

preliminary view is that one of the most important operational issues affecting the 

integration costs for VERs involves the reserves necessary to address variability in VER 

output. Addressing this issue means examining a number of operational practices and 

processes that affect both the determination of the amount of reserves needed as well as 

the cost of those reserves. The Commission seeks comment on the impact of integrating 

an increasing number of VERs in the following subject areas: (1) data and reporting 

requirements, including the use of accurate forecasting tools; (2) scheduling practices, 

flexibility, and incentives for accurate scheduling of VERs; (3) forward market structure 

and reliability commitment processes; (4) balancing authority area coordination and/or 

consolidation; (5) suitability of reserve products and reforms necessary to encourage the 

efficient use of reserve products; (6) capacity market reforms; and, (7) redispatch and 

curtailment practices necessary to accommodate VERs in real time. 

13. The Commission does not seek to limit its inquiry and encourages all comments 

regarding the topics broadly discussed herein. Commenters are invited to share with the 

Commission their overall thoughts, including technical, commercial, and legal 

observations, on the challenges posed by the increasing number of VERs, operational and 

technical barriers faced by VERs, and the extent to which Commission policies can 

and/or should be revisited in light of the increasing number of VERs. Where commenters 

believe specific revisions to Commission rules and/or pro forma OATT provisions are 

necessary to implement their proposed reforms, they are encouraged to cite those rules 

and/or provisions with specificity and suggest revised language as appropriate. In this 
Docket No. RM10-11-000 - 10 - 

Notice of Inquiry we seek information with regard to whether changes to rules or 

practices as applied to VERs will achieve the Commission’s goals. However, there may 

be instances where a change to a rule or practice could also assure just and reasonable 

rates and address undue discrimination if applied to other resources. Therefore, we ask 

commenters to address whether any proposed changes to the Commission rules or OATT 

provisions should apply to all resources. In addition, the Commission seeks responses to 

the specific questions listed below. 

A. Data and Forecasting

14. The scheduling and operational practices of the bulk power system are predicated 

on the ability to predict, with relative precision, the output of generation resources and 

the ability of reserve products to accommodate fluctuations in demand and emergency 

conditions. The rapid increase in the development of VERs has presented the industry 

with a variety of challenges related to predicting the exact output of VERs at any point in 

time. 

15. These challenges could become more manageable for System Operators through 

the development and use of state-of-the-art meteorological forecasts, which are supplied 

with data from multiple diverse locations. Specifically, the implementation of enhanced 

forecasting tools and procedures could assist in projecting the output of VERs with 

greater accuracy, thereby promoting the efficient scheduling of all generation resources to 

meet expected demand, especially during the morning increase and evening decrease in 

demand. Enhanced forecasting could also allow System Operators in all regions to 

anticipate system ramping events more effectively and respond to them in an 
Docket No. RM10-11-000 - 11 - 

economically efficient manner, thereby ensuring that jurisdictional rates are just and 

reasonable. 

16. To assist in the development of state-of-the-art forecasting tools for VERs, the 

Commission seeks comment on whether and, if so, how the Commission should modify 

existing operational data reporting requirements. The Commission also aims to 

determine what data and what level of data-sharing is necessary, coupled with advanced 

communication and metering tools, to ensure that VERs are integrated in a reliable and 

efficient manner, particularly with respect to scheduling, ramping needs, and the 

procurement of reserve services. 

17. To that end, the Commission seeks comment on the following questions: 

1. What are the current practices used to forecast generation from VERs? Will 

current practices in forecasting VERs’ electricity production be adequate as the 

number of VERs increases? If so, why? 

2. What is necessary to transition from the existing power generation forecasting 

systems for wind and solar generation resources to a state-of-the-art forecasting 

system? What type of data (e.g., meteorological, outage, etc.), sampling 

frequency, and sampling location requirements are necessary to develop and 

integrate state-of-the-art forecasts, and what technical or market barriers 

impede such development? 

3. What data, forecasting tools and processes do System Operators need to more 

effectively address ramping events and other variations in VER output, and to 

validate enhanced forecasting tools and procedures? 
Docket No. RM10-11-000 - 12 - 

4. What operational, outage and meteorological data should the Commission 

require VERs to provide to non-VER System Operators? To what size 

resources, in MWs, should any such data requirements apply, and what 

revisions to the pro forma OATT would be necessary to accommodate these 

requirements? 

5. State-of-the-art forecasts may necessitate the sharing of meteorological data 

across regions to assure that the movement of weather patterns can be 

accurately predicted and analyzed. To what extent should meteorological data 

be made publically available to aid in the development of state-of-the-art 

forecasts? Should the Commission require public utilities to maintain a 

meteorological data reporting system? If so, should such a system be akin to 

or in collaboration with Open Access Same Time Information System (OASIS) 

postings? In order to retain the confidentiality of commercially sensitive data 

reported by VERs for the purpose of developing state-of-the-art forecasts, what 

limits and/or safeguards should be established to protect operational data and 

generator outage reports? 

6. Should the Commission encourage both decentralized and centralized 

meteorological and VER energy production forecasting? For example, should 

transmission providers have independent forecasting obligations as part of their 

reliability commitment processes similar to what is done today for demand 

forecasting? 

7. To what extent is a lack of data regarding the operational status and forecasted 
Docket No. RM10-11-000 - 13 - 

output of distributed, or behind-the-meter, VERs leading to a need for 

additional reserves? To what extent would the provision of such data reduce 

the need for System Operators to rely on reserves? 

B. Scheduling Flexibility and Scheduling Incentives

1. Scheduling Flexibility 

18. Existing scheduling practices were designed at a time when virtually all generation 

on the system could be scheduled with relative precision. With increasing numbers of 

VERs, System Operators appear to be relying more on expensive reserves, such as 

regulation reserves, to balance the variation in energy output from VERs. Improvements 

in scheduling procedures may offer the potential for greater efficiency in dispatching all 

energy resources if the degree of variability can be reduced, better anticipated, and/or 

planned for more precisely. 

19. In regions outside of those run by regional transmission organizations (RTOs) or 

independent system operators (ISOs), resources typically schedule transmission service 

on an hourly basis and are only allowed to adjust their schedules during the hour for 

emergency situations that threaten reliability.18 Because transmission schedules for 

VERs are typically set 20-30 minutes ahead of the hour, the forecast of output may be 

90 minutes old by the end of the operating hour. Additionally, by limiting the ability of 

 18 Section 13.8 of the pro forma OATT requires transmission customers to 

schedule use of firm point-to-point transmission service by 10:00 a.m. the day prior to 

operation. However, section 13.8 of the pro forma OATT gives the transmission provider 

the discretion to accept schedule changes no later than 20 minutes prior to the operating 

hour. 
Docket No. RM10-11-000 - 14 - 

resources to adjust their schedules during the hour or to submit shorter scheduling 

timeframes, non-RTO/ISO System Operators may not be utilizing the full operational 

flexibility of the resources on their systems to change output levels to address the variable 

output of VERs. 

20. In RTOs/ISOs, real-time markets are employed to address imbalance energy 

needs. Real-time markets utilize intra-hour economic dispatch of internal resources, 

which affords RTOs/ISOs the ability to respond quickly and economically to fluctuations 

in VER supply. However, RTOs/ISOs often schedule external resources on an hourly 

basis, consistent with non-RTO/ISO scheduling practices. 

21. The Commission questions whether the retention of existing transmission 

scheduling practices as additional VERs come on-line is causing rates for reserves (as 

part of transmission service) to become unjust and unreasonable by inhibiting the ability 

of VERs to establish operationally-viable schedules and preventing System Operators 

from utilizing the full flexibility of their systems. Accordingly, the Commission seeks to 

explore whether greater scheduling flexibility, such as intra-hour scheduling, could 

provide benefits to the system and facilitate the reliable and efficient use of all resources. 

22. To that end, the Commission seeks comment on the following questions: 

1. Would shorter scheduling intervals allow System Operators to more efficiently 

manage the ramps of VERs and/or demand? To what extent would the 

availability of intra-hour scheduling decrease the overall reliance on regulation 

reserves to manage the variability of VERs? 

2. What are the benefits and costs of allowing resources and transactions to 
Docket No. RM10-11-000 - 15 - 

schedule on an intra-hour basis, and what tariff and/or technical barriers exist 

to implementing intra-hour scheduling? Are there best practices that could be 

implemented to facilitate greater intra-hour scheduling? 

3. Are there an optimum number of intervals within the hour for scheduling? 

What time increments would be necessary and/or desirable in order to achieve 

optimum flexibility while still meeting the relevant reliability requirements? 

4. Identify any reliability issues that may result from changes to the scheduling 

rules. What changes, if any, to NERC Reliability Standards would be needed 

to fully implement additional scheduling flexibility while still ensuring 

reliability? 

5. How would intra-hour scheduling affect the operation of other processes such 

as available transfer capability (ATC), the E-Tag system, issuance of dispatch 

instructions for generation and/or demand resources, transmission loading 

relief procedures, and/or dynamic schedules? What costs would be incurred as 

a result? 

6. If intra-hour scheduling is implemented in non-RTO/ISO regions, how would 

RTO/ISO scheduling practices at interties be affected? Would intra-hour 

scheduling at interties present problems for RTO/ISO markets? If so, describe 

the problems and feasible solutions for intra-hour scheduling at interties. 

2. Scheduling Incentives

23. Reforms to existing scheduling practices to promote intra-hour scheduling could 

enable VERs to more accurately meet their schedules, which in turn should help to ensure 
Docket No. RM10-11-000 - 16 - 

that rates for reserves are just and reasonable. In order to achieve overall improvements 

in scheduling accuracy, particularly with respect to VERs, it is also important to ensure 

that such resources have the appropriate incentives to meet their schedules with real-time 

output to the extent feasible. 

24. In Order No. 890, the Commission adopted pro forma OATT imbalance 

provisions that implemented a graduated bandwidth approach to imbalance penalties that 

recognized the link between escalating deviations and potential reliability impacts on the 

system.19 The Commission exempted intermittent resources from the third tier deviation 

band, which required imbalances of greater than 7.5 percent of scheduled amounts (or 10 

MW) to be settled at 125 percent of the incremental cost or 75 percent of the decremental 

cost of providing the imbalance energy.20 Instead, intermittent resources with such 

imbalances would only be subject to the second tier imbalance penalties, i.e., 110 percent 

of the incremental or 90 percent of the decremental cost.21 The Commission is interested 

in examining the experience with this exemption to determine whether it has resulted in 

scheduling practices that may result in an overall rate for transmission service that is not 

just and reasonable. 

 19 Order No. 890, FERC Stats. & Regs. ¶ 31,241 at P 663-64. 

20 Id. P 664-65. 

21 In RTOs/ISOs, because real-time markets are used to address imbalance energy 

needs, VERs are typically exempt from some pro forma OATT deviation penalties. 
Docket No. RM10-11-000 - 17 - 

25. To that end, the Commission seeks comment on the following questions: 

1. Has the exemption from third-tier penalty imbalances worked as a targeted 

exemption that recognizes operational limitations of VERs,22 or has it 

encouraged inefficient scheduling behaviors to develop? If the latter, what 

reforms to this exemption would encourage more accurate scheduling 

practices? 

2. Assuming that efficient forecasting and scheduling practices help minimize 

deviations between scheduled and actual energy output of VERs, are additional 

incentives needed to encourage VERs to submit schedules that are informed by 

state-of-the-art forecasting? What would be the proper incentives? 

3. Under an RTO/ISO market design, are there sufficient incentives to encourage 

VERs to submit accurate schedules? What costs and/or penalties should be 

assigned to VERs when their real-time output is not accurately scheduled on a 

forward basis? Should VERs be treated the same as conventional resources 

with respect to deviations from their production schedules? 

C. Day-Ahead Market Participation and Reliability Commitments

1. Day-ahead Market Participation

26. The presence of a day-ahead market is a key characteristic of most RTOs/ISOs. 

When resources are scheduled accurately in the day-ahead market, subsequent out-of-

 22 For the purposes of this section, the term “VERs” refers to the same resources 

that the Commission identified as “intermittent” in Order No. 890. Order No. 890, FERC 

Stats. & Regs. ¶ 31,241 at P 666. 
Docket No. RM10-11-000 - 18 - 

market commitments are minimized and market participants can manage their financial 

exposure more effectively. However, VERs appear to participate in the day-ahead 

market on a limited basis, choosing instead to self-schedule the majority of their supply 

in the real-time energy markets (i.e., act as a price taker). Because day-ahead schedules 

are financially binding, there can be significant financial risk for VERs participating in 

the day-ahead market and not being able to meet these obligations in the real-time 

market. This may serve as a disincentive for VERs to participate in the day-ahead 

market. 

27. In light of the increasing number of VERs, the Commission is interested in 

receiving comments on whether the lack of day-ahead market participation may be 

resulting in costly out-of-market commitments, thereby rendering rates unjust and 

unreasonable, as well as whether the financial risk associated with participating in the 

day-ahead market may unduly discriminate against VERs by inhibiting their ability to 

participate in such a market. Such comments should enable the Commission to determine 

whether reforms are necessary to facilitate VERs to participate more in the day ahead 

market rather than primarily in the real time market. 

28. To that end, the Commission seeks comment on the following questions: 

1. Does the lack of day-ahead market participation by VERs present operational 

challenges or reduce market transparency as the number of VERs increases? 

Will out-of-market commitments increase as the number of VERs increases? 

If so, why? 

2. How can new or existing market design features assure that the day-ahead 
Docket No. RM10-11-000 - 19 - 

market will accurately represent real-time system conditions and that dayahead and real-time energy prices will converge under the scenario of 

increasing numbers of VERs? 

3. Do current RTO/ISO market designs place undue barriers to participation in 

forward markets by VERs? Could the timing of certain RTO/ISO market 

design elements, such as the day-ahead market, be modified in a manner that 

would facilitate VERs to participate more in the day ahead market rather than 

primarily in the real time market? If so, how? 

4. Would the use of more accurate forecasting tools facilitate participation of 

VERs in the day-ahead market rather than primarily in the real time market? If 

so, how? 

5. Should the financial risk of VERs’ participating in the day-ahead market be 

different than the risk imposed on other resources in that market in recognition 

of their unique characteristics? Are there settlement practices, such as netting 

deviations, which could be employed to address VERs’ participating in the 

day-ahead market? If so, what are they? 

6. Will changes to the financial risk of participating in the day-ahead market 

encourage VERs to participate in day-ahead markets, and will this participation 

result in day-ahead market schedules that accurately reflect real-time market 

activity? 
Docket No. RM10-11-000 - 20 - 

2. Reliability Commitments

29. Following the results of the day-ahead market, RTOs/ISOs conduct a reliability 

unit commitment process to ensure that sufficient generation will be available in the 

appropriate places to meet the RTO/ISO’s estimate of the next day’s forecasted demand. 

If the cleared resources are insufficient to meet that demand, the RTO/ISO commits 

additional units. Non-RTOs/ISOs conduct a similar assessment to evaluate the 

sufficiency of bilaterally scheduled resources. 

30. Similar to the inefficiency associated with the lack of intra-hour transmission 

scheduling, the lack of a more frequent unit commitment process may result in unjust and 

unreasonable rates by causing System Operators to make inefficient reliability 

commitment decisions, which may cause unnecessary system uplift costs. 

31. To that end, the Commission seeks comment on the following questions: 

1. Would the implementation of a formalized and transparent intra-day reliability 

assessment and commitment process prior to each operating hour reduce the 

amount of reserves needed and/or reduce system uplift costs? What would be 

the optimal time (e.g., 4 to 6 hours ahead of the operating hour) for such a 

process? 

2. Would an additional market that coincides with the timing of an intra-day 

reliability commitment process be beneficial in the forward scheduling of 

VERs? If such a market is implemented, would an intra-day reliability 

commitment process be necessary? Should the frequency of scheduling 
Docket No. RM10-11-000 - 21 - 

intervals resulting from such a market coincide with intra-hour schedules 

discussed above? 

3. What role should centralized forecasting of VERs’ output play in reliability 

assessment and commitment processes? 

D. Balancing Authority Coordination

32. Smaller balancing authorities may be unable to capture the benefits associated 

with VERs that are spread across a large and/or diverse geographical area. Accordingly, 

the Commission is interested in determining whether a limited ability of smaller 

balancing authorities to efficiently integrate VERs may result in rates that are unjust and 

unreasonable. Therefore, the Commission seeks to explore whether increased 

coordination among balancing authorities has the potential to enlarge the base of 

generation and demand available to customers, thereby making variability more 

manageable and ultimately reducing overall costs. In this proceeding, the Commission 

seeks comments on ways to increase customer access to energy, capacity, and reserve 

products through the use of pseudo-ties,23 dynamic scheduling, and/or other tools and 

agreements. 

33. To that end, the Commission seeks comment on the following questions: 

1. Will smaller balancing authorities, when operated individually, have higher 

 23 Pseudo-ties are defined as telemetered readings or values that are used as 

“virtual” tie line flows between balancing authorities where no physical tie line exists. 
Docket No. RM10-11-000 - 22 - 

VER integration costs than geographically or electrically larger balancing 

authorities? If so, why? 

2. Should the Commission encourage the consolidation of balancing authorities? 

If so, indicate the potential for and impediments to consolidation among 

balancing authorities and the means by which the Commission should 

encourage consolidation. 

3. What tools or arrangements (e.g., dynamic schedules, pseudo-ties, and virtual 

balancing authorities) are available and/or could be enhanced or created to 

reduce barriers to greater operational coordination among balancing 

authorities? What role should the Commission play in facilitating interbalancing authority coordination? 

4. What are the costs and benefits, if any, associated with the proliferation of 

small generation-only balancing authorities? How do NERC Certification and 

Reliability Standards encourage or discourage the creation of small generationonly balancing authorities? 

5. The Commission is interested in receiving comments on whether the 

integration of VERs with small host balancing authorities may limit the 

benefits derived from geographical diversity and increase integration costs. 

Should the Commission encourage and/or facilitate the creation of a VER 

balancing authority, essentially a large area virtual balancing authority 

primarily designed to accommodate VERs across a broad geographic region? 

What would be the benefits and costs of creating such a large area entity? 
Docket No. RM10-11-000 - 23 - 

6. Would a large area VER balancing authority be capable of capturing the 

reduced variability of VERs located across a broad and geographically diverse 

region? What tariff or technical limitations would prevent and/or inhibit the 

development of a large area VER balancing authority? 

7. What reliability impacts may be associated with the creation of a large area 

VER balancing authority? 

8. Should a large area VER balancing authority be limited only to VERs? Why 

or why not? 

9. Should the Commission consider establishing specific policies that support the 

creation of a large area VER balancing authority? If so, why? 

E. Reserve Products and Ancillary Services

34. During normal operations, System Operators maintain reserve products to ensure 

that demand and generation are kept in balance.24 Reserve products are generally defined 

by the timeframes in which they are available. In the moments-to-seconds timeframe, 

Frequency Response services provide an immediate arresting of the frequency decline or 

increase due to any system imbalance. In the seconds-to-minutes timeframe, regulation 

services provide maneuverable capacity (typically through automatic generation control), 

 24 Contingency Reserves are used to recover from variations caused by a system 

disturbance but not for balancing normal variations. 
Docket No. RM10-11-000 - 24 - 

and in the minutes-to-hours time frame, following services25 allow for the rapid 

deployment of resources to maintain and/or restore system balance. 

35. The Commission seeks to explore whether the variability associated with 

increased VER deployment may result in an over-reliance on expensive reserves, such as 

regulation reserves. The Commission seeks to ensure that reserves are being used 

efficiently such that the resulting rates are just, reasonable, and not unduly 

discriminatory. The Commission is also interested in ensuring that requirements for 

VERs to contribute to system reliability are not unduly discriminatory. Finally, the 

Commission seeks to ensure that changes to the rules or requirements do not hinder the 

reliable operation of the grid under the reliability standards.26

36. To that end, the Commission seeks comment on the following questions: 

1. To what extent do existing reserve products provide System Operators with the 

most cost-effective means of maintaining reliability during VER ramping 

events? To what extent would the other reforms discussed herein, if 

implemented, mitigate the need for additional reforms to existing reserve 

products without adversely impacting system reliability? 

 25 In RTO/ISO markets, following services are generally provided through realtime energy markets. 

26 See 16 U.S.C. 824o(a)(3). 
Docket No. RM10-11-000 - 25 - 

2. How could System Operators, managing the variability of VER resources, 

more fully utilize forecasting information and knowledge about existing 

system conditions to optimize reserve requirement levels? 

3. Would a following or similar reserve product facilitate the reduction of costs 

associated with ensuring that sufficient reserve capacity is available to address 

the uncertainty and variability associated with VERs? If so, what are the ideal 

characteristics of such a product? 

4. Existing contingency reserve products were designed to be utilized by System 

Operators to respond to disturbances (i.e., contingency events) due to a loss of 

supply and to assure system reliability.27 Does or should the definition of a 

contingency event include extreme VER ramping events? If so, would an 

additional level of contingency reserves be needed to achieve the same level of 

system reliability? In responding to this question, please include a proposed 

definition of “extreme ramping event.” 

5. Should a new category of reserves, that would be similar to contingency 

reserves, be developed to maintain reliability during VER ramping events in a 

cost effective manner? If so, what benefit would such reserves provide to 

System Operators and customers? 

 27 Disturbance Control Performance, Standard No. BAL-002-0 (Apr. 1, 2005). 
Docket No. RM10-11-000 - 26 - 

6. Could the expanded use of reserve-sharing programs between balancing 

authorities contribute to lowering the costs associated with integrating VERs? 

If so, how? 

7. Should the ancillary services provisions of the pro forma OATT be revised or 

new provisions added to expressly address the added reserve capacity 

necessitated by increased number of VERs? If so, how? 

8. Are there new sources and/or providers for reserve products (such as interbalancing authority pooling arrangements, demand response aggregators and/or 

storage devices) that can be used to maintain reliability and lower reserve costs 

during VER ramping events? Based on experience, are there characteristics of 

these new sources of reserves that would positively or negatively impact their 

ability to match the reserve product needs presented by the variability of 

VERs? 

9. To what extent are VERs capable of providing reserve services? Should 

VERs be expected to provide reserve services? What are the tariff and 

technical barriers that may impede VERs from providing these reserve 

products? 

10. To what extent should all resources, and VERs in particular, be required to 

provide Frequency Response? How would such a requirement be 

implemented? 

11. Should the Commission revisit the reactive power requirements set forth in 
Docket No. RM10-11-000 - 27 - 

Order No. 661?28 What other requirements, if any, should apply to VERs to 

ensure that all resources contribute to grid reliability in a manner that is not 

unduly discriminatory? 

F. Capacity Markets

37. The procurement of capacity services, either through resource adequacy bilateral 

programs or centralized capacity markets, is commonplace in RTO/ISO markets.29 

Typically, VERs are eligible to receive compensation for capacity services in most 

RTOs/ISOs. However, due to their operating characteristics and the capacity rating rules, 

which vary among RTOs/ISOs, VERs are eligible to offer only a portion of their 

nameplate capacity. The price paid for capacity services depends in part on the amount 

of available capacity. Additionally, resources that participate in capacity markets 

typically are required to offer capacity in the day-ahead market, which, as discussed 

above, VERs often do not do. 

38. The Commission questions whether existing rules governing capacity markets 

may result in rates for capacity services that are not just and reasonable. Moreover, to the 

extent existing rules limit the ability of VERs to provide capacity services that they are 

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

29 Centralized capacity markets exist in ISO New England, Inc., New York 

Independent System Operator, Inc., and PJM Interconnection LLC. California 

Independent System Operator Corp. and Midwest Independent Transmission System 

Operator, Inc. rely primarily on bilateral resource adequacy programs to procure capacity 

services. 
Docket No. RM10-11-000 - 28 - 

capable of providing, the Commission seeks to explore whether such rules may be unduly 

discriminatory. 

39. To that end, the Commission seeks comment on the following questions: 

1. Should the Commission examine whether capacity rating rules as applied to 

VERs are unduly discriminatory and investigate whether standard rules may be 

appropriate? 

2. Do obligations for capacity resources to offer into the day-ahead market 

unfairly discriminate against VERs? If so, how? 

3. As more VERs choose to become capacity resources, will existing processes 

for compensating capacity services adequately compensate all generating 

resources that may be needed for reliability services? If not, what reforms may 

be necessary? For instance, should the Commission examine formation of 

forward ancillary services capacity markets? 

4. Should capacity markets incorporate a goal of ensuring sufficient generation 

flexibility to accommodate ramping events in addition to the goal of ensuring 

sufficient generation to meet peak demand? 

G. Real-time Adjustments

40. Redispatch and curtailment protocols vary depending on the region of the country 

and scenario. The Commission is interested in receiving comments on whether VERs 

may be curtailed too frequently in response to transmission congestion, minimum 
Docket No. RM10-11-000 - 29 - 

generation events,30 and ramping events, because of a lack of clarity in curtailment 

protocols. Accordingly, the Commission seeks to explore whether redispatch and 

curtailment practices and protocols, especially as they relate to VERs, are transparent, 

non-discriminatory and efficient. The Commission also seeks to determine whether 

redispatch and curtailment protocols may result in unnecessary costs, thereby rendering 

rates unjust and unreasonable. 

41. To that end, the Commission seeks comment on the following questions: 

1. How have redispatch and curtailment practices changed with increased 

numbers of VERs? Are there any shortcomings of current redispatch and 

curtailment practices? 

2. Do existing redispatch and curtailment processes unduly discriminate against 

VERs? If so, how should they be modified? 

3. Some RTOs/ISOs will redispatch VERs based on required economic bids. 

Should all RTOs/ISOs implement similar practices? Why or why not? 

4. Should transmission loading relief protocols be altered to allow reliability 

coordinators in non-RTO/ISO regions to consider economic merit when 

considering curtailing VERs? If so, how? Similarly, should redispatch and 

curtailment protocols in non-RTOs/ISOs be revised to consider economic merit 

for all resources? If so, how? 

 30 During a minimum generation event, system demand is at its lowest and 

generation resources tend to operate at the minimum feasible output level. 
Docket No. RM10-11-000 - 30 - 

5. Is the increasing number of VERs affecting operational issues that arise during 

minimum generation events? Are there ways to minimize curtailments during 

a minimum generation event? Should conventional base-load resources be 

offered incentives to lower their minimum operating levels or even shut down 

during minimum generation events to reflect an economically efficient 

dispatch of resources? If so, what would be the benefits and costs of doing so? 

6. To what extent do VERs have the capability to respond to specific dispatch 

instructions? Are there any advanced technologies that could be adopted by 

VERs to control output to match system needs more effectively? Should 

incentives be put into place for VERs that can respond to dispatch instructions? 

If so, what types of incentives would be appropriate? 

IV. Comment Procedures

42. The Commission invites interested persons to submit comments, and other 

information on the matters, issues and specific questions identified in this notice. 

43. Comments are due [Insert date that is 60 days from publication in the 

FEDERAL REGISTER]. Comments must refer to Docket No. RM10-11-000, and must 

include the commenter’s name, the organization they represent, if applicable, and their 

address in their comments. 

44. 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 
Docket No. RM10-11-000 - 31 - 

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. 

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

original and 14 copies of their comments to: Federal Energy Regulatory Commission, 

Secretary of the Commission, 888 First Street NE, Washington, DC 20426. 

46. 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. 

V. Document Availability

47. 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 FERC’s Home Page 

(http://www.ferc.gov) and in FERC’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. 

48. From FERC’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 excluding the last three digits of this document in the 

docket number field. 
Docket No. RM10-11-000 - 32 - 

49. User assistance is available for eLibrary and the FERC’s website during normal 

business hours from FERC 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. 

By direction of the Commission. Commissioner Norris voting present. 

( S E A L ) 

Kimberly D. Bose, 

Secretary.