ESA Policy Update - Energy storageenergystorage.org/system/files/resources/esa_15_policyupdatewebin... · ESA Policy Update October 28, 2015. 1. Agenda • Federal ... • Would affect

ESA Policy UpdateOctober 28, 2015

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Agenda• Federal

• IRS• FERC• Congress

• Wholesale markets• PJM• SPP• ERCOT

• States• Policy in Focus:

Distribution Planning Frameworks & Storage

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IRS Guidance on ITC Eligibility• Explicit Qs in IRS Notice 2015-70

• What is the definition of storage?• Is storage qualifying energy property under Section 48?• Is solar-paired storage charged from another source (“dual-use”)

eligible under section 48? Under what circumstances? How should it be credited?

• Other Qs• Is storage added to solar already placed-in-service (“retrofit”)

eligible for ITC? How should it be credited?• Is storage owned by a separate party from paired solar PV

eligible? How should it be treated?• How does eligible dual-use storage affect crediting of shared

components (e.g., BoS)?• ESA planning filing; comments due Feb 16, 2016

• Expected implementation 2018 – after current ITC expiration date

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FERC NOPR on 5-Min Settlements• Requires 5-minute settlement intervals in real-

time markets of all ISOs• Harmonizes with dispatch intervals• Would affect PJM, MISO, ISO-NE• 1 year to implement

• Requires shortage pricing during dispatch intervals with insufficient energy or operating reserves• 4 months to implement

• ESA planning filing; comment due Nov 30• Generally supportive; studying issues specific to

energy storage (e.g., impact on SoC)

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Congress• ESA launches Battery Energy Storage Caucus

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• House E&C Committee passed H.R. 8• Sec 1107 requires utility IRPs to consider resiliency

technologies, including storage• Some controversial provisions—conflicts with Senate

ENR• Floor vote potentially December

PJM Current Issues• Deadline for Capacity Injection Rights 10/31

• Required for participation in Capacity Performance 2019/20 Base Residual Auction, scheduled for May 2016

• Markets and Reliability Committee voted to implement RegD cap

• Regulation Market Issues Senior Task Force (RMISTF) underway to review Regulation market• Monthly meetings; next meeting 11/11

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PJM RMISTF Staff Interests• PJM priorities

• Ensure regulation mix meets operational needs• Meet Tariff mandates to procure least cost combination of

resources• Minimize operator workload• Arrive at a solution that can be implemented with

reasonable cost and effort• IMM priorities

• Ensure the benefits factor (BF) is calculated in a way that properly measures value of RegD

• Use the BF consistently across market clearing and settlement

• Correct errors they see in calculation details of clearing process

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PJM RMISTF Stakeholder Interests• Thermal generators

• Goal: maximize RegA (slow + long)—oppose RegD

• Pumped hydro• Goal: establish & maximize RegB

(fast + long)• Load interests

• Goal: minimize total costs of Regulation—neutral on RegD

• Non-generating resources• Goal: ensure market access—

support RegD• EPCs

• Goal: unknown• Transmission

• Not engaged

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Company affiliates each have a vote at RMISTF Any solution will require support of pumped hydro

Largest number of votes

ESA Engagement at PJM RMISTFESA principles, in order of priority:

1. Promote competitive markets for storage2. Preserve (or expand) existing storage market

value3. Set good precedent for Regulation at other

ISOs – SPP to visit PJM on Dec 1 re: storage

Concerns to address• Fate of short-duration resources• Expected prices/revenues

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SPP Market Working Group• SPP considering Revision Request 114

• Restores previously-existing classification of Storage Energy Resources

• First step to market participation, opens conversation on Fast Regulation

• Follow-up expected at 12/15-16 MWG meeting• Expected timing of approval would be April

2016

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SPP Discussion Qs on Storage

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ERCOT / PUCT• DREAM Task Force focused on defining DERs

• Storage registers as both generation & load and settles nodally, by PUC rule; proposed definition of DER excludes load

• ESA engaging on including storage in DER definition• Next meeting to focus on registration, interconnection, metering

• DG Interconnection straw proposal at PUCT• Deals with ability of 3rd parties to sign interconnection

agreements• Workshop 10/29; ESA to discuss further aspects relevant for

storage• Forthcoming info on Ancillary Services Redesign (NPRR667)

• Waiting on Brattle Report on pricing issues for AS products and NPRR revised language

• Nov 9 workshop to discuss NPRR

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ERCOT / PUCT• DREAM Task Force focused on defining DERs

• Storage registers as both generation & load and settles nodally, by PUC rule; proposed definition of DER excludes load

• ESA engaging on including storage in DER definition• Next meeting to focus on registration, interconnection, metering

• DG Interconnection straw proposal at PUCT• Deals with ability of 3rd parties to sign interconnection

agreements• Workshop 10/29; ESA to discuss further aspects relevant for

storage• Forthcoming info on Ancillary Services Redesign (NPRR667)

• Waiting on Brattle Report on pricing issues for AS products and NPRR revised language

• Nov 9 workshop to discuss NPRR

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States• CALIFORNIA: changes to SGIP eligibility (by GHG

intensity) under consideration—likely to favor storage• OREGON: request for storage grant applications

($300K available) due 10/30• NEW JERSEY: $3MM to be made available for BTM

renewables-paired storage FY16• NEW MEXICO: Governor’s state energy plan focuses

on storage for economic development• MASSACHUSETTS: stakeholder engagement session

10/30 on two-part study of energy storage landscape and policies

• HAWAII: net energy metering ended; expedited interconnection for BTM storage

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Policy in Focus:Distribution Planning Frameworks and Storage

10 states now in various types of proceedings on distribution planning frameworks / grid modernization

New York: Reforming Energy VisionCalifornia: Distributed Resource PlansHawaii: DER Docket 2014-0192Massachusetts: Grid Modernization PlansTexas: Distributed Resource in Energy and Ancillary Services Markets Task

ForceConnecticut: Public Act 15-05 ProceedingDistrict of Columbia: Formal Case 1130Minnesota: e21 InitiativeNew Hampshire: Case IR 15-296Maryland: PC40 technical workshops

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Recent Activities• NEW YORK: PSC guidance on DSIP filings

details list of data to release, discusses role of storage in plans

• CONNECTICUT: ESA made filings on storage in grid-side enhancements

• MARYLAND: ESA provided storage view at hearings on value of DERs

• DC PSC: ESA provided storage view at workshop on DERs

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Thank you

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Jason [email protected]