CAISO-WECC California Independent System Operator (CAISO) Energy Storage ER19-460 ER19-465 ER19-467 ER19-468 ER19-469 ER19-470 Federal Energy Regulatory Commission (FERC) FERC & Federal FERC Order 841 ISO New England (ISO-NE) ISO-NE Latest Major Issues Midcontinent Independent System Operator (MISO) MISO New York Independent System Operator (NYISO) NYISO PJM PJM Interconnection LLC (PJM) Public Policy Resources RTOs-ISOs Southwest Power Pool (SPP) SPP

FERC asks RTO for more information on storage rules

FERC asks RTO for more information on storage rules

With the assistance of RTO insiders

FERC employees final week posted a letter to all six RTOs and ISOs about their proposed power storage rules, burdened definitions, tariff labels and detailed information on issues comparable to measurement, full cost and [19659002] The network operators have a December deadline for compliance with regulation 841, in line with which they need to assessment their market share models to be able to provide capacity, power and ancillary providers to 100kW and above, in accordance with their technical functionality.

Lacking letters from the Energy Era Division ranged from eight to 11 pages.

US power storage by phase | Wood Mackenzie US Power Storage Monitor 2018

Jeff Dennis, Advisor to Advanced Power Financial system, stated that detailed questions show that FERC is wanting for an actual [requirements] requirement to open the market for storage, not just paper compliance. All in all, I feel this can be a constructive improvement. "

" They’ve some robust questions concerning the particular points raised by commentators, "said Kim Smaczniak, a lawyer at Earthjustice.

Below is a summary of the questions raised by the staff. Network operators have 30 days to respond.


FERC Challenges CAISO Minimum Warehouse

FERC mentioned seven major concerns about CAISO's proposal (ER19-468).

The staff wanted ISO to explain, for example, how it could reconcile its minimum requirement of 500 kW of storage capacity, as stated in the Customs Tariff Appendix, with a minimum order size of 100 kW for order 841.

The Commission also asked ISO to explain whether "CAISO's position that each of the three Participation Fashions – Non Generator Assets (NGR) Model, Pumped Storage Hydropower Model and Demand Response Mannequin – is taken into account alone, meets all requirements of Order No. 841." "[19659002] FERC then asked ISO to elucidate the eligibility necessities for its storage assets with a view to receive" all other services that CAISO procures on its market, including the CAISO backstop capacity acquisition mechanism. "

Next, FERC asked CAISO to elucidate how “NGRs may be despatched in accordance with demand or supply, set marginal worth, self-pricing schedule, and in any other case absolutely take part in CAISO market… [and] that pumped water assets may be sent to request provide and supply, set wholesale market clearing prices and submit bids and schedules. "

| SDG & E

It asked ISO to further describe its mechanisms for handling conflicting transmission signals and for including bid parameters.

It then referred to the CAISO a reference to a tariff warehouse to ensure that "LMP is" later resold to the market "and that the" charging of resources is considered a negative generation ", as required by regulation 841.

Charging power measurement and calculation practices considerations

References to the proposed tariff language, indicating whether or not the NGR and pumped water reservoir participation models forestall electrical energy stock assets from paying wholesale and retail fees for the identical charging power,

– Hudson Sangree

Questions about ISO-NE reservations

When FERC, in February, adopted amendments to the ISO-NE rule that reach power storage capacity to offer capability, power, and ancillary providers on April 1, the Commission announced that it will handle the Power Storage Affiliation's complaints about how RTO intends to reserve stocks when e responded to RTO's software 841 for compliance. (See FERC approves amendments to the ISO-NE storage tariff.)

The Commission's insufficient letter (ER19-470) asked RTO to elucidate whether or not there’s continued storage, if it is sent to reserves and not to power, and thus the potential prices can be misplaced

. FERC asked RTO to elucidate its "modified mechanism to supply electricity with one hour or less of energy consumption, only energy and no reserves" and in addition how RTO "will implement such a mechanism before 3 December 2019, ISO-NE

FirstLight Power Resources owns the largest pumped storage hydropower plant in New England, the 1,143 MW Northfield Mountain Project in Connecticut, Massachusetts. | FirstLight Power Resources

As regards physical and functional properties, the Commission questioned the use of the term "maximum discharge time" by RTO, saying that "shouldn’t be a function outlined by the Fee or outlined by ISO-NE." RTO either defines the term or "confirms that ISO-NE is intended to write down the utmost driving time as outlined in Order No. 841."

The Commission also asked whether some continuous storage sites could have start-ups or non-loaded costs, such as costs incurred online, but not from sent stores. "Might such costs be taken under consideration in the start-up or charging value parameters that weren’t zero values, just like different assets in the ISO-NE market?" , which show that binary storage and continuous storage modes do not get conflicting transmission signals to load and unload at the same time.

– Michael Kuser

The staff is looking for more information on MISO phased participation [19659031] FERC said in a letter of April 1 asking for more information about the plan not to process MISO's 841 compliance application before it clarify a number of steps concerning its step-by-step approach, proposed commitment states, the complexity of distribution network storage resources, offers and bids, and full payments (ER19-465). MISO has 30 days to respond

MISO and its stakeholders used a better part of last year's negotiating rules, culminating in a 1300-page archive. (See MISO offers storage proposal, promises to exceed order 841.) RTO said it "anticipates vital uncertainty and risks associated with the power of MISO's system and software program to deal with numerous very small" energy storage resources ". small storage amenities, which might limit the supply of small storage amenities to 50 in the first yr of compliance and 150 within the second yr. "Storage Media

Harding Street Energy Storage at MISO | AES

But FERC directed MISO to determine which year it intends to provide market access to all storage resources that meet the 100kW threshold.

MISO will also have to explain how its mandatory offer requirement will affect when the media is selected to use the "no part" station proposed by RTO or other binding stations, the Commission said. MISO's application suggested that stockholders could choose between a number of commitment states, including payments, discharges, ongoing, available, non-participating, emergency calls, emergency response and downtime. MISO has said that its dismantling, loading and continuous modes of transport carry mandatory names.

FERC said that MISO needs to clarify whether it will charge shipping charges for storage media when they charge to resell energy later. MISO also needs to explain how it will help the distribution system to store double charges – both retail and wholesale – for charging energy.

The Commission also asked whether MISO would have proposed measurement methods to control the "complexity" of energy sales.

The MISO proposal requires stockholders to secure agreements with distribution companies that can supply stored energy to the transmission network. FERC asked whether MISO would require the same contracts when energy is transferred from the transmission network to storage level storage, and it asked RTO to explain the rule prohibiting distribution level storage resources from pseudo-binding to another balancing authority. 19659002] The Commission also informed MISO that it mentions the provisions of the Customs Tariff which allow stockholders to manage their own debit status

. provide the Commission with references to applicable market rules and pseudo-road requirements for transfer-level resources. MISO must also describe how its archiving provides access to reserve resources for all capacity, energy, and ancillary services as well as non-market services such as black start, primary frequency response, and reactive power.

The Commission told MISO to explain how its archiving prevents the same resource from supplying conflicting supply and demand prices to the same market. Its purpose is also to know whether the participation model is allowed for full payments when the resource is sent as a load and the wholesale price is higher than the Offer Price and when the resource is shipped as a delivery and the wholesale price is lower than the Offer Price. It also asked whether the resources available for manual transmission are eligible for full payment.

Finally, FERC asked MISO to mention how it allows supply and demand to be sent to the wholesale market for the storage market and as a wholesaler. and buyer, as stated in Rule 841. The Commission also asked for references to support the fact that storage resources could set the price on the capacity market, that MISO would accept the wholesale prices of stockholders and that independent storage media could participate in the market as price providers.

– Amanda Durish Cook

NYISO, which asked to explain only the delivery model

In December, the New York regulatory authorities doubled the state's current 2025 storage target to 3,000 MW by 2030. -0130) adopting amendments to the State's six largest utility programs for "hybrid tariffs" for storage systems connected to eligible electrical equipment. (See NYPSC Expands Storage, Energy Efficiency Programs.)

The Commission's letter asked NYIS to explain how its sole transmission model enables energy storage resources to be reflected in commitment costs for other producers and whether there are circumstances that could prevent such resource from effectively managing its ability to fulfill its obligations through competitive bidding (ER19-467). .

NYISO said that energy storage assets are not eligible for double participation before ISO develops and implements additional tariff changes of unspecified

The Commission services also asked whether it would be forbidden to participate in resources with "restricted business obligations" on the ISO market, such as: seasonal retail commitments or other parts of resource capacity. The staff also questioned whether the resource could only register part of its capacity on storage with ISO and allocate the remaining capacity to other customers.

FERC's questions ranged from basics – to energy-storing resources with start-up costs

For example: "By stating that only the transmission model reduces the time it takes for the Safety Know-how Unit (SCUC) to develop an answer, which a part of the extra time is required to resolve the SCUC in comparison with managing these parameters? In different phrases, might the time saved by managing these parameters permit SCUC to make dedication selections inside a suitable timeframe?

– Michael Kuser

PJM asked about pump storage, a minimal of 10 hours

Within the PJM proposal, the Fee mentioned 10 shortcomings that mainly surrounded the present tariff language supported by its proposed power storage mannequin (ER19-469).

The RTO must first confirm how the saved water assets meet the necessities of regulation 841. and whether or not the "capacity storage medium" is included in the definition of "production capacity resource" and whether or not one unit is able to appearing as each

Earthjusticen Smaczniak stated the query exhibits that FERC "drives back" to the PJM requirement that the capability of the stock provide should constantly provide power 10 for the hours that critics have been demanding. ISO-NE requested for a two-hour supply, while NYISO advised a minimum of 4 hours.

"That's why I read this as a very positive development in order 841!" Smaczniak stated.

The Fee also needs references to the prevailing customs tariff, which describe in detail how RTO manages electrical energy storage belongings, including eligibility for non-synchronous reserves; release of the day by day timetable for the reserve course of; participation in Degree I synchronized reserves;

The 31.5 MW Grand Ridge Power Storage Venture by Invenergy is 80 kilometers southwest of Chicago. | Invenergy

The RTO additionally must clarify whether the capacity retention resource is included in the definition of the production capacity resource in Annex 9 to the Trustworthiness Agreement. The Commission needs to know more about "rules and procedures" [that]particularly recognizing the unique properties and capabilities of capacity storage assets and their relative potential to "keep manufacturing with a specified property for a sure time period." "

PJM also has to elucidate why storage assets which are thought-about to be" free "are not considered to be a disruption. Definition of loading, unloading and continuous mode of operation

The PJM must also specify the annual energy storage resources to be used when selecting the participation model and corresponding tariff changes.

FERC is also looking for information on how PJM determines which energy storage resources are eligible to receive payments in full, and how the model proposed by RTO represents the minimum maximum charging time, minimum reserve time, maximum charging time, minimum run time and maximum time for current bidding procedures.

The PJM must also explain how operators use telemetered charging mode in daily and real-time markets and why RTO believes that market vendors do not need to provide a minimum payment time, maximum charge time, minimum run time, and maximum driving time in the context of the situation. FERC wants to know whether resources are able to manage their own reservations and sanctions due to deviations from the transmission schedules

The Commission also seems skeptical about PJM's view that the measurement requirements in manual 14D apply to energy storage resources, as mentioned

– Christen Smith

SPP Queried is the LSE rules

SPP's first response to order 841 stated that it did not have a capacity market, but that load serving units are a resource sufficiency requirement. It said that LSEs can determine capacity resources, including storage resources, to meet this requirement if the resource fulfills the "requirement for continuous resource operating of all useful resource varieties".

The Commission asked the SPP to define a "continuous driving requirement" and, in order to identify and describe any technical, operational or performance requirements, resources must be met in order to be considered as a capacity resource "assembly LSE resource adequacy requirements" (ER19-460) .

SPP also told FERC that it was not "immediately on the premises of the meter that the storage reserve would resell the power again to the market in the wholesale market. As an alternative, RTO said that the measuring instruments would deliver the clearing values ​​directly to the SPP and prompt that" pseudo-bound In accordance with resource management, the actual metrics of the distribution site's storage resources can be distributed both in real-time and in the solution of the retail and metric agent. FERC also asked how the handling of measuring instruments and the accounting of distribution stocks would be "in line with the handling of pseudo-road assets."

deficiencies in the three other areas, including the simultaneous involvement of supply and demand on the market. The tariff changes proposed by the SPP would have funds that are not continuously sent between 0 MW, providing supply or demand for a given market gap.

FERC asked SPP to define market resources that are not continuously transmitted between 0 MW "and explains why the inclusion of resource launch time constraints in its bid parameters doesn’t permit RTO to regulate the simultaneous supply and demand prices of assets within a given market range.

The Commission requested the SPP to learn how the "storage resource" would "independently" charge in the integrated market, as RTO stated it didn’t have a mechanism to explicitly control their potential to pay and didn’t propose "such a mechanism." designed to take away self-committed cost assets to deal with insufficient capability in daytime and day-to-day reliability – dedication processes apply to all storage assets or solely "market storage" assets. [196590] 19] – Tom Kleckner