Intermittent resources create unique challenges for 21st Century Utilities, RTO's and System Operators. The now infamous "Duck Chart" highlights a key element of the problem -- central station thermal plants cannot ramp efficiently, leading to "worst of all" scenarios where the benefits of renewables are not fully utilized and central station plants operate inefficiently for extended periods.
By contrast, fast-ramping distributed generation creates a path to the opposite result. With fast-ramping support, central station plants remain at an efficient "steady state" while intermittent renewables operate at maximum output, providing emission-free generation with no variable fuel costs. These efficiencies result in substantial and quantifiable economic benefits.
The U.S. Defense Department (DOD) seeks to procure renewable energy at or below market prices, and is not considering fast ramping generation in its current procurement plans. Because there is no economic incentive for DOD to invest in such resources, and because markets for fast-ramping generation and ancillary services are largely non-existent, the current policy framework lacks a vehicle for attracting investment in fast-ramping distributed energy and related technologies.
Manufacturers of fast-ramping generation equipment are studying issues relating to intermittent energy resources. Among other initiatives, they have developed economic models that demonstrate system-wide efficiencies produced by fast-ramping technologies. The models have been vetted by credible public and private sector organizations and found to be both accurate and insightful.
With their policy expertise and purchasing power, the Department of Energy and DOD can play a role in developing policies and markets that allow such technologies to take hold and proliferate.
California's Pacific Gas and Electric Company (“PG&E”) announced today that it plans to issue an Energy Storage Request for Information (“RFI”) to obtain information on utility-scale, dispatchable, and operationally flexible storage resources through a solicitation of interest from technology providers, owners, and developers of energy storage resources. PG&E said that it plans to issue the RFI and to ask for responses from RFI participants this year.
PG&E explained that the RFI will help it to learn about different storage technologies and their costs, to understand which storage technologies could bid into a future RFO, and to identify and value the various attributes of those technologies. The company plans to open up its Energy Storage RFI website later this week--the new website will list the types of questions that PG&E plans to ask in the RFI. PG&E invites feedback on its proposed questions in the form of comments or questions to EnergyStorage@pge.com.
Persons who want to to subscribe to PG&E's general RFO distribution list should go to www.pge.com/rfo to fill out theregistration form and submit the Excel form as an attachment to the Renewable RFO mailbox. Registrants will receive notices about this energy storage RFI and other PG&E long-term procurement solicitations.
The Pacific Northwest Economic Region (PNWER) Energy Storage Coaliation (ESC) will be holding an important energy storage conference at the Portland Convention Center on October 8, 2012. ESC has worked with the Oregon and Washington public utility commissions to bring together a diverse mix of developers, utilities and regulators to share their perspectives on opportunities and barriers to deploying energy storage in the Pacific Northwest. You can find the draft agenda for the event here and register for the conference here.
Following the PNWER event, Pivotal Leaders will hold an Energy Storage Panel from 4-6 PM at the Portland offices of Perkins Coie, 1120 NW Couch Avenue, 10th Floor. I will be joinging the panel with Dave Curry of Demand Energy, Praveen Kathpal of AES Corporation, and Lee Kosla of SAFT . Guests are welcome, but an RSVP is required. Contact firstname.lastname@example.org. I hope to see you at both of these events.
For those interested in energy storage, I regularly follow the topic on Twitter, @BillHolmesStoel. The PNWER Energy Storage Coalition can also be found on Twitter, @PNWERESC. Finally, www.stationarystoragenews.com is an excellent energy storage news aggregator that offers daily news and a weekly newsletter on the topic.
In October 2011, the Federal Energy Regulatory Commission (FERC) issued Order No. 755, which requires regional transmission organizations (RTOs) and independent system operators (ISOs) to pay for frequency regulation services based on the actual amount of service provided in response to actual or expected frequency deviations or interchange power imbalances. The order directs RTOs and ISOs to implement a two-part payment for frequency regulation services consisting of (1) a capacity payment that includes the marginal unit's opportunity costs, and (2) a performance payment that reflects the quantity of frequency regulation service that a resource provides when it is accurately following the dispatch signal. In February 2012, FERC issued Order 755-A, denying a motion for rehearing filed by Southern California Edison.
On Tuesday April 10, 2012, 11 am to 12:30 pm Eastern time (8 am to 9:30 am Pacific), I'll be moderating a Webinar produced by that Infocast to discuss the implications and effect of Order No. 755. We'll review the Order itself, the process that is underway in the RTOs and ISOs to implement the Order, and the Order's implications for energy storage, demand response and other aspects of the frequency regulation market.
Infocast has assembled an excellent panel for this Webinar. Jacqueline DeRosa, Director of Regulatory Affairs, California, Customized Energy Solutions and Rahul Walawalkar, PhD, CEM, CDSM, Vice President, Emerging Technologies Markets, Customized Energy Solutions, will jointly provide a cross-market overview of the current approaches and proposed responses to Order No. 755 in key ISOs and RTOs (i.e., PJM, NYISO and CAISO) . Eric Hsieh, Regulatory Affairs Manager, A123 Systems, Inc., (which participated actively in the Order No. 755 docket) will offer a technology provider's perspective on the order and the ongoing process. Praveen Kathpal, Director of Marketing and Regulatory Affairs, The AES Corporation, will provide the perspective of a technology-neutral independent energy storage developer.
You can register for the Order No. 755 conference here. Use the Stoel Rives discount code (“128505”) to reduce the tuition to $150.
Oregon Governor John Kitzhaber announced today that he has named Margi Hoffman to serve as his Energy Policy Advisor. She will join the Governor's office on April 2.
Ms. Hoffman has served as Senior Vice President and Director of Oregon Operations with Strategies360, a strategic consulting firm, and has also worked closely with Renewable Northwest Project (RNP) . The news release from the Governor's office can be found here.
I'll be moderating Energy Storage for the Grid: Watchful Waiting or the Perfect Storm? at the MIT Enterprise Forum Northwest's May 8, 2012 program at Seattle's Museum of History and Industry (MOHAI) , 2700 24th Ave East. The event, which includes a networking reception, will be held from 5:00 to 8:30 pm.
The evening's panelists will be:
- Terry Oliver, Chief Technology Innovations Officer, Bonneville Power
- Alexander H. Slocum, Professor, Massachusetts Institute of Technology
- Chris Wheaton, Chief Operating & Financial Officer, EnerG2
- Nathan Adams, Manager of Development and Emerging Technologies, Puget Sound Energy
Among other topics, the panel will address:
- The most promising energy storage strategies
- How different storage methods could work together with the grid in the Northwest and nationally
- How entrepreneurs, the changing energy marketplace, grid operators, and utilities are responding to the call to build the foundation for a clean energy economy
For more information about this event, visit MITEF Northwest's web site.
I hope to see you there! In the meantime, for those who are following energy storage, I'm "tweeting" regularly on that topic as well as Department of Defense renewables procurement at @BillHolmesStoel (#energystorage).
The CUB Policy Center, in partnership with the University of Oregon School of Law, will be holding its inaugural policy conference: Smart Grid: Today's Regulation and Tomorrow's Technology, on Friday, October 21, 2011, at the University of Oregon White Stag Block (70 NW Couch St., Portland, OR 97209). The luncheon keynote speaker will be former FERC Commissioner Nora Mead Brownell, who is the co-founder of ESPY Energy Solutions.
The conference is designed to educate utility analysts, policy analysts, attorneys, industry professionals, stakeholders and others on the current regulatory environment in Oregon and the region and to provide a forum for investigating the opportunities and challenges of integrating the Smart Grid into that environment. The CUB Policy Center notes that space for this conference, which promises to be well attended, is limited and encourages attendees to register early.
I'll be participating in the Closing Panel to recap and discuss lessons learned during the day, and I hope to see you there.
For those who like to pay close attention to developments in the energy storage industry, take a look at Stationary Electricity Storage, which collects and presents articles about storage industry news, noteworthy projects, and other topics. It's well organized (with articles filtered by category, storage provider, organization and location), offers a free daily newsletter and looks like a good way to stay on top of developments in this expanding sector. (Thanks to Greg DelSesto for introducing me to this new site.)
On a related note, I'll be chairing Infocast's Developing Grid Storage Projects in Dallas from October 5 through October 6. Stoel Rives partner John Thompson will be speaking on "Intellectual Property Protection for Grid Storage," and Dave Hattery, a partner in our Seattle office, will be speaking on "Negotiating the Terms and Navigating the Risk of a Procurement Contract and Other Financial Documents." The conference features an impressive list of speakers who are very active in the energy storage industry, and I hope to see you there!
California’s AB 2514 directs the California Public Utility Commission (CPUC) to determine appropriate targets, if any, for load-serving entities to procure viable and cost-effective energy storage systems. If the CPUC decides that targets are appropriate, it is supposed to set dates for achieving those targets.
As a follow up to an AB 2514 workshop held on June 28, 2011, Administrative Law Judge Amy C. Yip-Kikugawa issued a ruling asking for comments on the presentations made at the workshop by the California Energy Commission, the California Independent System Operator, Southern California Edison, the California Energy Storage Alliance, AES Energy Storage, Beacon Power Corporation and KS Engineers, all of which were attached to the ruling. The ruling asks the parties to comment on whether they agree or disagree with the presentations.
In addition, the ruling seeks comments from parties on the following questions:
- Which barrier(s), either identified by the presenters or the CPUC, do you believe present the greatest impediment to more widespread usage of energy storage and development of ESS in California?
- Are there other barriers that were not identified during theworkshop? Please explain how these other barriers impede theusage or development of energy storage and whether they needto be resolved at the Commission or other forums.
- To whatextent can the Commission assist in removing these barriers?In your opinion, are there certain barriers that need to beresolved first, and therefore have higher priority?
The deadline for comments is August 29, 2011, and reply comments will be due September 16, 2011. Your can find a copy of the ruling and attachments here.
EPRI Project to Develop Functional Requirements for Customer Energy Storage System (CESS) Launched - Public Webcast July 22
The Electric Power Research Institute (EPRI) is developing a new report to define functional requirements for customer energy storage systems (CESS). The project is engaging energy storage stakeholders to collaborate on the development of the functional requirements through a public process.
EPRI's effort is designed to create an understanding between electric utilities and their storage needs, the manufacturers and suppliers of customer energy storage systems, and customers of the systems.
A webcast open to all stakeholders will take place on Friday, July 22, 1:30 PM – 3 PM ET. During that webcast, attendees will be asked to help refine the draft document, and provide comments. Registration is required at https://www2.gotomeeting.com/register/855889739.
This new EPRI report will builld on last year’s efforts to develop functional requirements for utility systems that support Distributed Energy Storage Systems (DESS), substation grid support and renewable energy integration.
Questions, comments and any feedback can be directed to email@example.com. A copy of the CESS functional requirement document will be circulated among registrants a couple of days before the webcast.
Thanks to Emanuel Wagner, EPRI's Project Coordinator at Technology Transition Corporation, for the tip about this webcast.
On Tuesday, June 28, 2011, the CPUC will hold an “Electric Energy Storage Workshop” as part of its R10-12-007 proceeding for AB 2514, which defines the process by which the CPUC will consider electric energy storage standards for California’s investor owned utilities. The workshop will be held at in the Golden Gate Room at CPUC’s headquarters from 9:30 am to 4:00 pm.
According to a draft agenda circulated by the CPUC, the theme of the workshop will be addressing barriers to entry facing Electric Energy Storage (EES). The workshops goals are to identify actions that the CPUC should consider, as well as whether and how it should participate in other forums.
The morning will feature presentations from several different perspectives, with each presentation to be followed by Q&A:
- Presentation from UC Berkeley and California Energy Commission (CEC) team on “2020 Vision Project”
- Presentation from CAISO about recent storage-related activities at the Independent System Operator, including findings from recent studies.
- Presentation from Southern California Edison (SCE) discussing a white paper entitled Moving Energy Storage from Concept to Reality.
- Presentation from California Energy Storage Alliance about developer’s perspectives
The afternoon will feature a facilitated presentation about a staff straw proposal concerning potential CPUC actions. The CPUC will allow parties to provide post-workshop comments on both the presentations and the staff straw proposal.
The CPUC is willing to accommodate short presentations (five minutes or less) or share prepared material pertinent to the workshop. Any party who wishes to do so may contact Michael Colvin at firstname.lastname@example.org. For reference (or inspiration), a series of energy storage presentations made to the CPUC as part of its 2011 IEPR process can be found here.
On June 16, 2011, the Federal Energy Regulatory Commission (FERC) issued a Notice of Inquiry (NOI) seeking comments on what it described as two separate but related issues, both of which apply to electric energy storage (EES).
First, because FERC is interested in facilitating the development of robust competitive markets to provide ancillary services from all resources types, it seeks comment on “existing restrictions on third-party provision of ancillary services, irrespective of the technologies used for such provision.” In soliciting these comments, FERC noted the growing interest in rate flexibility among sellers of ancillary services, and a desire from those obligated to purchase those services to increase the available supply. Although a variety of resources can provide ancillary services, FERC believes that many are discouraged from doing so by the Commission’s restrictions on market-based pricing coupled with a lack of access to information that could help satisfy the requirements of those policies. Access to information is particularly difficult outside of areas served by RTOs/ISOs, which areas are often with the greatest need for an ancillary services market.
FERC pointedly invites comments on whether it should revise or replace the restriction set forth in Avista Corp., 87 FERC ¶ 61,223, order on reh’g, 89 FERC ¶ 61,136 (1999), which prohibits, absent a study showing lack of market power, third-party market-based sales of ancillary services to transmission providers seeking to meet their ancillary services obligations under the Open Access Transmission Tariff (OATT). Assuming that FERC revises or replaces the Avista restriction to facilitate the provision of ancillary services, it also seeks input on how it should contemporaneously ensure just and reasonable rates. In a related inquiry, the Commission is seeking comments on whether the various cost-based compensation methods for frequency regulation that exist in regions outside of organized markets can be adjusted to address the speed and accuracy issues identified in FERC’s recent Frequency Regulation Notice of Proposed Rulemaking for organized wholesale energy markets. See Frequency Regulation Compensation in the Organized Wholesale Power Markets, 76 FR 11177 (March 1, 2011), Notice of Proposed Rulemaking, FERC States & Regs ¶ 32,672 (2011). The June 16 NOI, when considered in context with this year’s NOPR on Frequency Regulation and last year’s NOI on EES, could signal that a broader rulemaking regarding EES is on the horizon.
Recognizing that “the role of electric storage and other new market entrants play in competitive markets is still evolving,” the Commission seeks comments on whether it should revise “current accounting and reporting requirements as they pertain to the oversight of jurisdictional entities using electric storage technologies” other than pumped storage hydro (for which FERC has established methods of accounting, reporting and rate recovery). Current utility accounting requirements do not appropriately fit EES due to the technology’s abilities to act like generation, transmission, and distribution assets. Accordingly, FERC is soliciting “specific details regarding whether and, if so, how to amend the current accounting and reporting requirements to specifically account for and report energy storage operations and activities.”
The NOI was published in the Federal Register on June 22, 2011, and comments are due sixty (60) days from that date.
Thanks to my colleague Jason Johns for his comments on this posting!
This week I attended the 21st Annual Meeting of the Energy Storage Association in San Jose, California. The meeting broke its attendance record by attracting over 420 attendees, including representatives from electric energy storage (“EES”) technology companies, utilities, venture capital funds, consultancies and government agencies. Key note speakers included Dr. Imre Gyuk of the U.S. Department of Energy, Assemblywoman Nancy Skinner of the California Assembly, Fan Wong of Pacific Gas & Electric, and Vinod Khosla of Khosla Ventures. Over 50 other distinguished speakers presented lectures and materials on various topics including flow battery applications, advanced storage technologies, smart grid interface, lithium ion battery applications, economics and policy, and venture capital markets.
The record attendance at the meeting and reports of successful pilot projects were strong indicators that the EES industry has matured over the past years. The general sense at the meeting was that the EES industry is poised to emerge from the product development stage and move into the commercialization and deployment stage. In order to successfully make that leap, the EES industry must first overcome several hurdles.
Prospective EES customers, including utility representatives, contended that, except for pumped hydro, EES applications are not yet cost competitive and that EES systems must achieve significant price reductions before they can be competitive. Various utility representatives encouraged the EES industry to continue to bring down costs with the goal of becoming cost competitive with gas peaker plants.
Project developers and technology companies acknowledged this reality, but stressed that when comparing EES applications to gas peakers, it is imperative that the market recognize the broad range of combined value streams and utility benefits that EES applications offer. These benefits include:
- Ancillary services and frequency regulation
- Reactive power, voltage, and power quality
- Renewable integration and smoothing
- Multiple hour peak shifting
- Demand response
- Deferred T/D upgrades
- Minimizing spinning reserves
In addition to these benefits, various speakers emphasized the siting and permitting advantages EES enjoys over gas plants. From a land use perspective, EES applications are relatively low impact. Many EES projects can obtain required permits based on a negative declaration and thereby avoid the lengthy siting proceedings that can drag on for years for some thermal generation projects. These siting and permitting advantages that EES applications enjoy translate into reduced costs and quicker development timelines and give EES a distinct advantage over gas peakers.
The future of EES will in part hinge on the development of supportive federal and state regulations. Accordingly, ongoing proceedings at the Federal Energy Regulatory Commission and the California Public Utilities Commission are critical to the future of EES.
Further, EES system providers will face challenges in structuring transactions to finance and build EES projects. Consultants and legal advisors, including Stoel Rives attorneys, are currently wrestling with various options to solve these challenges.
The EES industry will meet again in San Diego for Infocast’s Storage Week on July 11-14, and several Stoel Rives attorneys will be presenting and attending.
The 2011 IEPR Committee Workshop on Energy Storage for Renewable Integration was held Thursday, April 28th at the California Energy Commission (CEC) offices in Sacramento. The Workshop was presented in a three panel format, with each panel addressing specific topics, including (1) the need for energy storage in light of California’s renewable portfolio standard, greenhouse gas goals, smart grid and demand response, (2) the costs, benefits and revenues from energy storage applications, and (3) utility perspectives on energy storage. The full agenda, which describes the topics and the questions addressed at the Workshop, can be found here.
The CEC is not planning any further workshops on energy storage, but it will be making recommendations about the topic in its 2011 Integrated Energy Policy Report (IEPR). We understand that the CEC is seeking input on energy storage from all arenas, including developers and owners of gas-fired peaker plants. Among other things, the CEC wants to understand the economic and environmental benefits and impacts of peakers (i.e., facilities that have the ability to ramp up in ten minutes, generate for a full hour, then be taken off line) compared to the cost and benefits of various energy storage technologies. The CEC will use the information it gathers to determine if it makes sense economically to recommend a lower or a higher target for energy storage in its 2011 IEPR.
The CEC’s report will be taken into account by the California Public Utility Commission (CPUC), which is conducting a separate proceeding under AB 2514 to determine appropriate energy storage targets for California’s investor-owned utilities. You can find our previous descriptions of the AB 2514 process here , here and here. A report on last year's CPUC staff whitepaper describing energy storage technologies and their potential use in the California market can be found here.
Parties who want to weigh in on energy storage in California must submit their comments to the CEC by 5 p.m. on May 16, 2011. The comments must include the docket number “11-IEP-1N” and indicate “Energy Storage for Renewable Integration” in the subject line or first paragraph of the comments. All filings in the IEPR proceeding are now accomplished electronically and can be submitted in either Microsoft Word format or as a PDF by e-mail to email@example.com.
Thanks to Kimberly Hellwig in our Sacramento office for her help in preparing this Blog!
California Public Utilities Commission Holds Prehearing Conference on Energy Storage Procurement Targets
As we’ve previously discussed, California’s AB 2514 requires the CPUC and municipal utilities in California to open proceedings by March 1, 2012 to determine appropriate targets, if any, for the procurement of viable and cost-effective energy storage systems by load-serving entities. Over a year before that deadline, the CPUC opened Rulemaking 10-12-007 in December of last year to both implement AB 2514 and “on [the CPUC’s] own motion to initiate policy for California utilities to consider the procurement of viable and cost effective storage systems.” In early March, the CPUC held an initial workshop on the scope of the rulemaking proceeding.
On April 21, the Commission held a prehearing conference to determine the scope and schedule for the proceeding. Stoel Rives partner Seth Hilton attended the conference. Among the issues discussed at the prehearing conference, led by Administrative Law Judge Yip-Kikugawa, was whether to conduct the proceeding in phases (e.g., first examining how storage might be applied, and then in a subsequent proceeding setting what the mandate will be for storage procurement), the issues to be covered in each phase , and whether evidentiary hearings would be necessary.
According to ALJ Yip-Kikugawa, a scoping memo should issue in the next two to three weeks. The scoping memo will set out the issues to be considered in the proceeding and a schedule for their resolution.
We'll be posting further information on Renewable + Law Blog when the scoping memo comes out, so stay tuned for further developments.
Having first reported to our readers in February that LexisNexis had nominated the Stoel Rives Renewable + Law Blog for its Top 50 Environmental Law & Climate Change Blogs for 2011 award, we are pleased to announce we made the list of winners! In publishing its Top 50 list, LexisNexis declared that our Renewable + Law bloggers’ “avowed passion for solar energy, wind energy, biofuels, ocean and hydrokinetic energy, biomass, waste-to-energy, geothermal and other clean technologies is evident in the care they take with this blog-the posts are frequent, the topics are interesting and cutting edge, and the writing is top notch.”
Thanks again to all our readers who make regular use of Renewable + Law Blog and those who wrote in to support us for this award. We're honored and inspired, and we plan to keep those Blogs and letters coming.
Electric Power Research Institute (EPRI) and Technology Transition Corporation recently issued a request for information (RFI) to prepare for multiple demonstrations and the market introduction of 1MW / 2MWh lithium ion battery energy storage systems (ESS) for electric utility grid management solutions. EPRI and TTC have assembled a utility team for this project, and they encourage manufacturers of Li-ion systems and energy storage system integrators to respond to the RFI. The utility team will evaluate the responses to determine which ESS suppliers should be invited to a 2-day utility-manufacturer workshop to be held in June 2011 to discuss the project’s technical specification and demonstration plans. The responses to the RFI will also influence the forthcoming Request for Proposals and the technical specification for approximately three demonstrations scheduled for 2012.
To be considered for participation in the proposed ESS project, including receipt of the resulting RFP in Q3 2011, responses must be received electronically, by 8 pm (20:00) Eastern Time, Monday, May 2, at firstname.lastname@example.org. A detailed description of the RFI process and the RFI response form can be found on the Technology Transition Corporation's website, here.
Thanks to Emanuel Wagner, Project Coordinator for TTC, for bringing this RFI to my attention. According to Emanuel, this would be the first Li-ion storage project of this size in the US, if not the world.
California’s AB 2514 requires the CPUC and municipal utilities in California to open proceedings by March 1, 2012 to determine appropriate targets, if any, for the procurement of viable and cost-effective energy storage systems by load-serving entities. By October 1, 2013, the CPUC must (1) determine whether a procurement target for energy storage is appropriate and, if so, (2) adopt a procurement target for each load-serving entity under its jurisdiction to be achieved by December 31, 2015 and a second target to be achieved by December 31, 2020. Municipal utilities have an additional year to meet these requirements.
In December of last year, the CPUC opened Rulemaking 10-12-007 both to implement AB 2514 and “on [the CPUC’s] own motion to initiate policy for California utilities to consider the procurement of viable and cost-effective energy storage systems.” Order Instituting Rulemaking (“OIR”) at 1, R.10-12-007.
On March 9, 2011, a workshop was held to address the scope of the rulemaking proceeding. The workshop included discussions of current and emerging energy storage technologies, the goals and applications of energy storage, existing barriers to storage implementation, and whether a unified storage policy would work or whether the policy should be written to address specific barriers to entry. The workshop also considered how the CPUC could and should work with other agencies addressing energy storage or related issues, including the California Energy Commission, the California Independent System Operator, and the Federal Energy Regulatory Commission. You can find Seth Hilton’s report about the March 9 workshop here.
The CPUC has scheduled a pre-hearing conference in the rulemaking proceeding for April 21, 2011. The conference will be held before ALJ Amy C. Yip-Kikugawa, beginning at 10 am, in the Commission Courtroom, State Office Building, 505 Van Ness Avenue, San Francisco, California. Stoel Rives partner Seth Hilton will attend the conference.
In addition, as part of its 2011 Integrated Energy Policy Report (IEPR) Schedule, the California Energy Commission has scheduled a committee workshop on energy storage for renewable integration, which will begin at 9:30 on April 28 in Hearing Room A, CALIFORNIA ENERGY COMMISSION, 1516 Ninth Street, First Floor, Sacramento, California. Stoel Rives attorneys are planning to attend the workshop.