Call To Action For Energy Storage Companies

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Pierce Atwood LLP

WHO:

Energy Storage technologies awaiting regulatory authority to operate in the wholesale energy, capacity, and ancillary services markets.

WHAT:

Per FERC’s Storage Notice of Proposed Rulemaking (NOPR), RTOs/ISOs have fewer than nine months to assure the implementation of favorable rules to enable energy storage resource providers to participate in all wholesale markets. 

The substance of the new rules will directly impact your success in the marketplace. Make sure that your company’s technology interests are well-represented in this process.

WHY NOW?

On February 15, 2018, FERC set out rules that ensure energy storage resources are able to provide a full spectrum of services to the grid. In its Storage NOPR, FERC mandated that each RTO/ISO propose additions or modifications to their existing tariff provisions so that:

  1. Storage resources are eligible to provide all capacity, energy and ancillary services
  2. Storage resources can be dispatched as to set the wholesale market clearing price as both wholesale sellers and buyers
  3. Tariffs account for the physical and operational characteristics of electric storage resources through bidding parameters and other means  
  4. Tariffs establish a minimum size requirement for participation of no more than 100 kW
  5. Ensure that the sale of electric energy from the RTO/ISO markets to an electric storage resource that the resource then resells back to those markets must be at the wholesale locational marginal price.

Storage providers now have a unique opportunity to work with each of the RTOs/ISOs to develop favorable rules that will allow for your specific technologies to fully operate on the grid and be compensated appropriately for the benefits provided to ratepayers throughout the United States. But ISOs have less than nine months to design these new rules to comply with FERC’s Order.

 

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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