Policy Update Webinar
March 23, 2015
Agenda
I. FERC/ISO Updates
Andrew Kaplan
II. ERCOT Update
Suzi McClellan
III. Congressional Update
Katherine Hamilton
IV. State Update
Jeff Cramer
V. ESA Update
Matt Roberts
FERC/ISO Update
Andrew Kaplan
FERC: Resolved Dockets
NYISO Regulation Movement Modifier
• FERC approved NYISO change to Regulation
Movement Modifier from 10-13
• ESA submitted motion to intervene without
comments
FERC: Pending Dockets
PJM Capacity Market (ER15-623)
• PJM submitted reforms to capacity market to
ensure resources would perform when called
(resulting from Polar Vortex issues)
• PJM proposed new category of Capacity
Performance Resources--would be first time
energy storage allowed to participate in
Reliability Pricing Market
• ESA filed supporting comments January 20
• FERC ruling may be made this week
FERC: Pending Dockets (cont’d)
ComEd Rehearing (ER15-3)
• ComEd claims Energy Vault battery would
place demand on system and should incur
wholesale distribution charges
• FERC initially ruled in favor of ComEd
• ESA submitted request for rehearing; FERC
did not reject outright and ruling is pending
• Could be damaging precedent for industry if
not overturned
FERC: Pending Dockets (cont’d)
Uplift Price Formation (AD14-14)
• ESA responded March 6 to FERC request for
comments on price formation in energy and
ancillary services markets
• ESA stressed need for transparency of uplift
charges
• ESA also noted FERC need to send
appropriate signals to drive investment in
new innovative technologies that add
flexibility (currently only generators are paid)
FERC: Upcoming Dockets
Frequency Response
• FERC opened rulemaking with NOPR
• Proposes to revise regulations to foster
competition in sale of primary frequency
response
• Would mean frequency response separate
and distinct ancillary svc. at market-based
rates
• Comments due April 27; ESA plans to file
ERCOT Update
Suzi McClellan
ERCOT Activities
Ancillary Services Redesign
• ERCOT filed NPRR 667 in November 2014
• 2 workshops held- January 30 and March 11
• ERCOT favorable pricing and procurement
Proposal for fast services is under attack
• All pricing proposals will be presented to the
Technical Advisory Committee March 26 –
seeking direction from TAC on how to
proceed
AS Pricing Proposals
ERCOT Proposed Pricing
• Most favorable to energy storage
• Primary Frequency and Fast Frequency clear
in one stack with one price
• All resources are paid MCPC which includes
opportunity costs
• During certain times an equivalency ratio is
applied
• New Development - ERCOT has agreed to
remove its proposed price cap from FFR
Alternative Pricing Proposals
Alternative 1
•
FFR and PFR are cleared in the same stack with different
prices
•
FFR is paid the higher of the MCPC for PFR or the clearing
price for FFR which would not include opportunity costs
Alternative 2
• FFR and PFR clear in the same stack with different prices
• PFR receives MCPC for PFR and FFR receives MCPC for FFR
minus opportunity costs
Alternative Pricing Proposals
(cont’d)
Luminant Proposal
• FFR receives the higher of the PFR MCPC or the
cleared FFR price without opportunity costs
(effectively capped at PFR)
• No equivalency ratio for pricing
IMM Pricing Proposal
• Essentially the same as Alternative 2 but with
opportunity costs linked to offers in the market
• Crafted with Load Resources in mind/not sure
how it would apply to energy storage
Upcoming ERCOT/PUC Activities
HSL Test
•
Current test is inappropriate for storage
•
May limit quantity of AS provided
FRRS Cap Removal
•
Cap was put in as part of pilot
•
ERCOT has committed to study and address
Multi-interval SCED
•
allow resources to bid for 5 minute increments 30
minutes ahead
Distributed Generation provision of AS
•
No streamline mechanism for DG to provide AS
•
PUC rulemaking on DG interconnection
Texas Legislature
• Oncor bill based on Brattle report was not
pursued in this session
• ESA may consider initiating legislation for
2017
• ESA could host annual Texas ESA
conference
Congressional Update
Katherine Hamilton
Tax Reform Process
• Senate Working Groups (comments due 4/15)
• Community Development &
Infrastructure
• Business Income Tax
• Individual Income
• Savings and Investment
• International Tax
• House Process
• Stand-alone Credit (STORAGE Act)
• MLP Parity Act
• R&D Credit
Energy Policy Authorization
• House Hearing 3/4/15
•
21st C Electricity Challenge: Ensuring a Secure
Reliable and Modern Electricity System
• Senate Listening Tour
• Infrastructure
• Energy Efficiency
• Supply
• Accountability
• Senate Hearing 3/17/15
•
The State of Technological Innovation Related
to the Electric Grid
• Senate QER Hearing 3/26/15
ESA Recommendations
• Tax Policies
• STORAGE Act
• MLP Parity Act
• R&D Credit
• Energy Policies
• Stafford Act Revision
• Federal Energy Management
• QER Recommendations
• Funding Recommendations
• Additional funds for modeling at DOE
• Transportation R&D Title
State Update
Jeff Cramer
New York
• PSC REV Order APSC REV Order—February 26
• ESA submitted numerous filings w comments reflected
• Utilities not allowed to own distributed energy resources,
serve as operators/facilitators of distribution system
• Exception — utilities can own storage systems located on
utility property that:
• Integrate into distribution system architecture
• Enhance grid reliability
• Utilities provide information on locations/levels of storage.
• No utility ownership of storage on customer property.
Oregon
• Storage RFP: result of ESA comments/engagement in 2014
Oregon Energy Office to release storage RFP this spring
• HB 2193 — Storage bill introduced intro Oregon Legislative
Assembly
• Requires all utilities serving 3% of retail
customers (PacificCorp and PGE) procure one or more
storage systems >5 MW (capped at 1% 2014 load) by
2020
• Procured systems entitled to full cost recovery
• PUC required to complete their analysis 2016; utilities
required to submit plans 2017.
• ESA testimony and advocacy— staff, Members, stakeholders
Colorado
• Commissioners Vaad, Patton, State Energy Office
engagements
• COSEIA energy storage effort and panel
• State PUC hearing April 23 to discuss roll of storage in
distribution system and current net metering policy
• Colorado REV: Introduction of bill in CO House — HB
1250 — to require state PUC to open “investigatory
proceeding to explore alternative utility revenue
models” towards “performance-based utility
regulation”
New Mexico
• NM Energy Office inquiry into the potential
for energy storage
• ESA staff and members to meet with NM
Regulation Commission staff April 13
ESA Organizational Update
Matt Roberts
Questions?