On October 20, 2011, FERC issued an order regarding Puget Sound Energy, Inc.'s ("Puget's") filing to (1) update its rates for regulation service, (2) assess regulation service charges on wind generators that export from its balancing authority, and (3) require the wind generators to purchase regulation service equal to 16.77% of the customer's transmission reservation while requiring load and dispatchable generation to purchase an amount equal to 2%. In this Order, FERC accepted the filing subject to refund, suspended the effective date for five months (to become effective January 5, 2012), and set the filing for hearing.
FERC made several rulings in this Order. First, FERC held that assessing different regulation charges for service from wind and dispatchable resources is acceptable, even without grid operating reforms like intra-hour scheduling. Second, FERC rejected arguments that Puget failed to properly assign integration costs to dispatchable generation by stating that the issue was not before the Commission. Third, FERC rejected arguments that Puget's filing somehow impaired the customer self-supply option by including pro forma language that the customer must either purchase the service from Puget or make alternate comparable arrangements. Fourth, FERC accepted Puget's explanation that wind generators that pay the regulation service charge may still be subject to curtailment, but that Puget will not curtail them for economic reasons. Finally, FERC accepted (on an interim basis) Puget's method of calculating the regulating service purchase obligation, a method that compared 10-minute schedule deviations to 60-minute persistence forecasts.