New FERC Rules Open the Door Wider for Electric Storage Participation in Wholesale Electricity Markets, and Establish Primary Frequency Response Requirements

by Morrison & Foerster LLP

Morrison & Foerster LLP

On February 15, 2018, the Federal Energy Regulatory Commission (FERC) voted unanimously to issue a highly anticipated final rule that directs regional grid operators to remove barriers to the participation of electric storage resources in wholesale electricity markets. Lauded by storage proponents and environmental groups, the new rule provides a degree of regulatory certainty for energy sector stakeholders gauging the trajectory of energy storage resources across the U.S.

The same day, FERC also issued a final rule that will incorporate new requirements in generator interconnection agreements, making clear that facilities have the ability to provide primary frequency response.

This client alert describes the new FERC rules and provides insights into the road ahead for energy storage.

Energy Storage Rule

Early FERC Action

Over the past several years, FERC has taken steps to understand the potential of energy storage and its associated regulatory needs. In July 2013, FERC issued an order on energy storage directing wholesale market operators to monetize “fast response” resources (e.g., batteries and flywheels).[1] Concurrently in an informational docket on the participation of electric storage resources in organized wholesale electric markets, FERC requested comments and data on “the applicability of Regional Transmission Organization (RTO) and Independent System Operator (ISO) market rules to electric storage resources.”[2] FERC opened another informational docket in September 2016 examining energy storage as an asset in the organized markets.[3]

November 2016 Notice of Proposed Rulemaking

Because energy storage can be categorized as generation, load, or both generation and load, determining how to define energy storage has been challenging in the past, and has created uncertainty for potential investors and developers. FERC sought to address this puzzle by issuing a Notice of Proposed Rulemaking (NOPR) in November 2016 to remove barriers to the participation of electric storage resources and distributed energy resource aggregations in the organized wholesale electric markets. [4]

FERC issued the NOPR pursuant to its authority under Section 206 of the Federal Power Act to ensure that RTO/ISO tariffs are just and reasonable and not unduly discriminatory or preferential. FERC preliminarily determined that barriers to participation in the organized wholesale electric markets by electric storage resources and by distributed energy resources through distributed energy resource aggregations “may, in some cases, unnecessarily restrict competition, which could lead to unjust and unreasonable rates.” Removing these barriers will enhance the competitiveness and efficiency of the organized wholesale electric markets “and thereby help to ensure just and reasonable and not unduly discriminatory or preferential rates for wholesale electric services.”

Final Rule

Opening the door wider for energy storage participation in capacity, energy, and ancillary service markets across the U.S., the Final Rule in Order No. 841 directs RTOs and ISOs to develop tariffs and market rules that properly recognize the “physical and operational characteristics of electric storage resources,” including their capability to provide capacity, energy, and ancillary services in the RTO/ISO markets. FERC found that existing RTO/ISO market rules are unjust and unreasonable in light of the barriers they present to the participation of electric storage resources in the RTO/ISO markets, thereby reducing competition and failing to ensure just and unreasonable rates.

FERC Issues New Rule on Energy Storage Infographic

FERC established a broad definition of electric storage resources that is technology—neutral, in that it applies regardless of the storage medium (e.g., batteries, flywheels, compressed air, and pumped hydro). It also stated that electric storage resources “must fulfill certain responsibilities set forth in the Federal Power Act and the Commission’s rules” (which may “potentially” include obtaining market-based rate authority).

Under the new rule, RTO and ISO tariffs must:

  • Contain a participation model that ensures electric storage resources are eligible to provide all capacity, energy, and ancillary services they are technically capable of providing in the organized wholesale electric markets;
  • Ensure that storage resources can be dispatched and can set the wholesale market clearing price as both a wholesale seller and wholesale buyer consistent with market rules governing conditions under which a resource can set the wholesale price;
  • Establish a minimum size requirement that does not exceed 100 kilowatts;
  • Incorporate bidding parameters that reflect and account for the physical and operational traits of storage resources; and
  • Specify that the sale of energy from the RTO/ISO to an electric storage resource that the resource then resells back to those markets must be at the wholesale locational marginal price.

Where RTOs/ISOs already have separate participation models that electric storage resources may use (such as pumped hydro or demand response), FERC is not requiring that those participation models be consolidated with the participation model established pursuant to the new rule.

In a nod to the Commission’s recent action terminating the DOE NOPR and establishing a new docket on grid resilience,[5] FERC declared that, “due to electric storage resources’ unique physical and operational characteristics—including their ability to both inject energy into the grid and receive energy from it—our actions here will help support the resilience of the bulk power system.”

FERC declined to adopt the proposed reforms in the NOPR on issues related to distributed energy resource aggregations (e.g., microgrids, rooftop solar). FERC instead issued a Notice of Technical Conference (RM18-9-000) that identifies questions that will help gather additional information on the subject. The technical conference is scheduled for April 10‒11.

The final rule will take effect 90 days after publication in the Federal Register. RTOs/ISOs have 270 days after the effective date to submit tariff filings, with an additional 365 days after such submissions to implement the tariff and market rule revisions.

Primary Frequency Response Rule

FERC also finalized a broader rule with significant implications for energy storage. Order No. 842, Essential Reliability Services and the Evolving Bulk-Power System—Primary Frequency Response, finalizes modifications and additions to FERC’s pro forma Large Generator Interconnection Agreement (LGIA) and Small Generator Interconnection Agreement (SGIA) (collectively, GIAs) that will require newly interconnecting generating facilities, as well as certain existing facilities that take action that requires submission of a new interconnection request, to install, maintain, and operate equipment capable of providing primary frequency response.

The modifications address the Commission’s concerns that the existing pro forma GIAs contain limited primary frequency response requirements that apply only to synchronous generating facilities and do not account for recent technological advancements that enable new non-synchronous generating facilities to have primary frequency response capabilities.

As explained by FERC, “[p]rimary frequency response actions are intended to arrest abnormal frequency deviations and ensure that system frequency remains within acceptable bounds.” In North America, frequency must stay within predetermined boundaries, or “deadbands,” above and below 60 Hertz. Changes in frequency—due to events such as sudden, large generation outages or loss of significant load—above or below these “deadbands” can cause significant reliability issues on the bulk power system. “Primary” frequency response actions are usually the automatic engagement of a “governor” or equivalent control mechanisms. The governor will have “droop” and “deadband” settings, each of which impacts the generating facility’s primary frequency response.  

The pro forma GIAs will include new provisions that require an Interconnection Customer to “ensure the primary frequency response capability” of its generating facility by “installing, maintaining and operating a functioning governor or equivalent controls.” The governor or equivalent controls must comply with specific “droop” characteristics and “deadband” parameters. Most significantly, the Interconnection Customer must ensure that it is capable of providing “timely and sustained” primary frequency response, with exceptions for certain operational constraints.

FERC recognized that electric storage resources have “unique physical and operational characteristics,” and crafted specific accommodations as well as “limitations on when electric storage resources will be required to provide primary frequency response consistent with the conditions set forth in” the Final Rule. The state of charge of a storage resource must be considered in order to avoid “depths of discharge that could accelerate the degradation of an electric storage resource” and “disproportionate harm from the proposed requirements in some circumstances.” 

As it relates to energy storage, the Rule: 

  • Requires electric storage resources to specify an operating range in their GIAs that specifies a minimum state of charge and a maximum state of charge between which the electric storage resource will be required to provide primary frequency response;  
  • Specifies that the requirements to provide primary frequency response that is “timely and sustained” apply to electric storage only when the storage resource is online and dispatched to inject electricity to the transmission system and/or receive electricity from the transmission system. Electric storage is not required to satisfy the requirements for a “timely and sustained” primary frequency response in circumstances when the electric storage resource is not dispatched either to inject electricity into the system or to receive electricity from the transmission system;
  • Provides that if an electric storage resource is charging at the time of a frequency deviation outside of its “deadband” parameter, it must increase (for over-frequency deviations) or decrease (for under-frequency deviations) the rate at which it is charging in accordance with its droop parameter; and
  • Does not require an electric storage resource to change from charging to discharging, or from discharging to charging, unless the response necessitated by its applicable “droop” and “deadband” parameters requires it to do so and it is technically capable of making such a transition.

Public utility transmission providers will have 70 days following publication of the primary frequency response final rule in the Federal Register to file proposed revisions to the generator interconnection procedures and forms of GIA in their open access transmission tariffs that implement the new requirements. RTOs/ISOs will have the ability to propose “independent entity” variations from the pro forma provisions adopted in the Final Rule. 

The Road Ahead for Energy Storage

The U.S. electricity system is going through dramatic change—more digitized, more decentralized, and more decarbonized. Energy storage technology helps enable and empower that future.

Bloomberg New Energy Finance analysts project that the global capacity of advanced energy storage will double six times between 2016 and 2030. Unprecedented expansion will likely mobilize over $100 billion during that same period of time, and roughly one-fourth of that growth is expected to take place in the United States.

Proponents often highlight electric storage’s array of grid services, including voltage support, black start, spinning reserves, frequency response, and electric capacity. Storage is often considered a key step in mitigating the intermittency challenges of renewable power resources such as wind and solar. Storage advocates are hopeful that the new rule will continue to support energy storage’s growth across the nation’s electric grid, potentially improving grid resilience in the process. 

Three factors will influence how quickly and fully energy storage’s potential is unlocked:

  • Intelligent public policy;
  • Technology cost reductions; and
  • Reduced transaction costs.

First, intelligent regulatory and legislative policy can be an accelerator of progress. From tax credits to renewable portfolio standards, from regulations at EPA to promoting wholesale market competition at FERC, public policy has transformed the U.S. electricity system in many ways.

FERC’s energy storage rule will facilitate storage being able to provide all the wholesale services it is technically capable of providing, further catalyzing the growth of energy storage. The rule is market-driven and technology-neutral, consistent with FERC’s termination of the DOE NOPR and the long arc of FERC technology and fuel-neutral policies with respect to wholesale competition. The rule thus provides a degree of regulatory certainty for energy sector stakeholders seeking to gauge the trajectory of energy storage resources across the U.S.

States, too, are taking a leading role on energy storage policy implementation. New York Governor Cuomo, for example, recently set a goal of 1,500 MW of energy storage in New York by 2025, proposed that the New York Green Bank commit $200 million to drive down energy storage costs and deploy storage, and directed the New York State Energy & Research Development Authority to apply at least $60 million to activities that will reduce barriers to energy storage.

Second, as we saw with solar and wind, progress in the energy storage market will likely be spurred by reductions in technology costs. Reductions in “soft costs” such as permitting will also aid energy storage expansion. Technology and software development and commercialization will also drive down the cost curve for energy storage technology.

Third, transaction costs for energy storage technology also need to come down to fully tap the potential this technology represents for the economy, consumers, and the environment. Standardization of energy storage contracts and related materials may not be as exciting an innovation as the next battery chemistry in the lab, but it will be essential to tapping the full potential of energy storage.


[1] Order No. 784, Third-Party Provision of Ancillary Services; Accounting and Financial Reporting for New Electric Storage Technologies, Docket Nos. AD10-13-000, RM11-24-000, 144 FERC ¶ 61,056 (July 2013).

[2] Data Requests and Request for Comments, Electric Storage Participation in Regions with Organized Wholesale Electric Markets,  Docket No. AD16-20-000 (April 2016).

[3] Utilization in the Organized Markets of Electric Storage Resources as Transmission Assets Compensated Through Transmission Rates, for Grid Support Services Compensated in Other Ways, and for Multiple Services,  Docket No. AD16-25-000 (September 2016).

[4] Notice of Proposed Rulemaking, Electric Storage Participation in Markets Operated by Regional Transmission Organizations and Independent System Operators, Docket Nos. AD16-20-000, RM16-23-000, 157 FERC ¶ 61,121 (November 2016).

[5] Grid Reliability and Resilience Pricing, Docket No. RM18-1-000, and Grid Resilience in Regional Transmission Organizations and Independent System Operators, Docket No. AD18-7-000, Order Terminating Rulemaking Proceeding, Initiating New Proceeding, and Establishing Additional Procedures (January 8, 2018).

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