Statement: January 20, 2011 Docket No.: AD11-08-000

Statement of Commissioner Marc Spitzer on frequency response study

"Let me add my appreciation to Mr. Eto and the Lawrence Berkeley National Laboratory staff who contributed to this study. The Lawrence Berkeley Study is an important analysis of the impact on frequency response from adding variable resources to the grid. The validation of frequency response as a predicative, objective measure to assess the reliable operation of the grid with more variable resources will help planners establish how to reliably integrate wind, but really all types of, generation resources.

The Lawrence Berkeley Study already has received some attention. I think it important to explain my understanding of what the Lawrence Berkeley Study does, and just as importantly, what the Study does not do.

First, what the Lawrence Berkeley Study does. The study makes the case that primary and secondary frequency response metrics are tangible measures by which to judge the ability of a system to "bounce back" under certain conditions after the unexpected loss of a large amount of generation. The study also makes specific recommendations about how to use the frequency response metrics and identifies areas for further study and evaluation. The study shows that, assuming planned generation and transmission is built on schedule, the amount of wind generation that is currently scheduled to come on line in 2012 can be integrated reliably.

Now, for what the Lawrence Berkeley Study does not do. The study does not make any recommendations about what is an "optimal" amount of wind generation on the system. The study does not make any predictions about reliable integration of wind beyond 2012. The study also makes clear that even for the integration of wind resources for 2012, and certainly after 2012, reliable integration is based on assumptions and requires the presence of other generation and transmission infrastructure coming on line in time to accommodate that integration.

In sum, the Lawrence Berkeley Study is an engineering study on the state of frequency response under certain conditions. It should not be read to make any findings or conclusions as to costs, rates, economic choices or resource choices. Specifically, the study does not provide a basis for changing our rules or policies for certain types of resources, to incent certain types of energy resources, or create preferences as between types of resources. As we have stated before, the Commission does not pick "winners and losers" in generation - the ultimate goal of all of the Commission's activities in this arena is the Commission's standard obligation to ensure reliable service and ensure that rates are just and reasonable and not unduly discriminatory. I have no doubt that the metrics the Lawrence Berkeley Study discusses to address frequency response under these conditions may play some role in ensuring the reliable operation of the grid.

I understand that there comments will be taken on the study, so I encourage all with an interest in reliable resource integration to share their views."