Last week, the Federal Energy Regulatory Commission issued a Notice of Inquiry (NOI) seeking comment on the need for reforms regarding the provision of and compensation for primary frequency response. The NOI notes that fewer generation resources may currently be providing primary frequency response than in the past. The Commission expects this trend to continue as more Variable Energy Resources (VER), such as solar or wind generators, are integrated into the nation’s electric grid. As the Commission explained, the NOI is necessary due to the significance of primary frequency response to the reliable operation of the electric grid.