[co-author: Alex Taylor]

On January 19, 2021, FERC directed Regional Transmission Organizations (“RTOs”) and Independent System Operators (“ISOs”) to submit informational reports regarding four hybrid resources issues: (1) terminology; (2) interconnection; (3) market participation; and (4) capacity valuation. Specifically, FERC directed that each RTO or ISO file a report within 180 days from the order providing: (1) a description of its current practices related to these four issues; (2) an update on the status of any ongoing efforts to develop reforms related to the four issues; and (3) responses to the specific requests for information contained in the January 19, 2021 order. FERC’s request for reports follows a technical conference focusing on technical and market issues raised by hybrid resources (see April 14, 2020 edition of the WER) and a Notice Inviting Post-Technical Conference Comments.

In the specific requests of the January 19, 2021 order, FERC directed each RTO or ISO to include information on:

1. Its definition of hybrid resources in its tariff or in a business practice manual and, if it does not have a definition, how it categorizes any hybrid resources and how they have been participating in the markets to date;
2. The interconnection process for both a hybrid resource newly entering the interconnection queue and a resource adding a storage component to an existing interconnection request;
3. How hybrid resources are currently participating in its wholesale energy, ancillary services, and capacity markets, and any changes to its tariff or business practice manuals that relate to the market participation of hybrid resources and that it is planning in the stakeholder process; and
4. How the capacity value of hybrid resources is currently determined in its markets.

FERC’s January 19, 2021 order acknowledged that, during the technical conference and in post-technical conference comments, most RTOs and ISOs “reported that they are currently undertaking work to address the increase in hybrid resources,” and several RTOs and ISOs “requested that the Commission either allow such work to continue before taking additional action, or provide for flexibility in any such action.” FERC explained that it would not direct specific reforms at this time.

Accordingly, to determine whether further action is appropriate, FERC directed RTOs and ISOs to file reports within 180 days from the date of the January 19, 2021 order focusing on the above four categories of issues related to the integration of hybrid resources in wholesale markets. Public comment in response to the reports may be submitted within 30 days of the filing of the reports.

FERC’s January 19, 2021 order is available here.