FERC Staff Seeks Information from RTOs/ISOs on Energy Storage Participation in Wholesale Markets
On April 11, 2016, the Federal Energy Regulatory Commission’s (FERC) Office of Energy Policy and Innovation (OEPI) sent identical data requests to each of the nation’s six grid operators, requesting information on potential barriers to the participation of energy storage resources1 in capacity, energy and ancillary service markets operated by the Regional Transmission Organizations (RTOs) and Independent System Operators (ISOs). To aid in OEPI’s examination, a letter requesting comments from market participants and the public was concurrently issued. If the RTO/ISO responses and public comments indicate that potential barriers exist, OEPI notes that it will further investigate “whether any tariff changes are warranted.”
OEPI’s two requests seek input on five parameters: (i) the eligibility of electric storage resources to be market participants, (ii) qualification criteria and performance requirements, (iii) bid parameters for electric storage resources, (iv) distribution-connected and aggregated electric storage resources, and (v) when electric storage resources are receiving electricity. Regarding eligibility parameters, OEPI states that it wants to identify potential market rules that might prohibit energy storage resources from participating, even if they are otherwise “technically capable of providing services.” If such barriers to participation exist, OEPI urges commenters to propose “potential tariff revisions in specific markets or general rules for all markets that would help clarify the eligibility of electric storage resources as market participants and remove any undue barriers to their participation.”
OEPI specifically asked the RTOs/ISOs to identify “any forthcoming or pending proposals or ongoing stakeholder processes that could change or contemplate changing the rules by which electric storage resources” can buy or sell electricity in their respective markets. Only CAISO 2, NYISO 3 and MISO 4 have initiated ongoing stakeholder processes exploring the role of energy storage resources within their markets, though ISO-NE recently issued a paper to stakeholders on energy storage participation in its markets, and PJM’s Markets & Reliability Committee recently approved a problem statement5 on distributed resources, including battery storage, – in PJM markets.
