The Western Interconnection Regional Advisory Body (WIRAB) submitted advice to the Federal Energy Regulatory Commission (FERC) on its 2016 Notice of Proposed Rulemaking (NOPR) on Essential Reliability Services and the Evolving Bulk-Power System – Primary Frequency Response (Docket No.: RM16-6). FERC proposed to revise its regulations to require all newly interconnecting large and small generating facilities (exempting nuclear facilities) to install and enable primary frequency response capability as a condition of interconnection. Among other things, the proposed requirements would require new generating facilities to install a governor or equivalent controls; require specific maximum droop and deadband settings; require a timely and sustained response; and require droop parameters to be based on nameplate capability with a linear operating range of 59 to 61 HZ. WIRAB’s advice is aligned with its previous advice to FERC on the need for this rulemaking, which is available here.