FERC Issues Storage Rule

UPDATED 2.16.2018 with link to Order No. 841 and further information on the upcoming technical conference in Docket Nos. RM19-9-000 and AD18-10-000. 

At today’s Open Meeting, the Federal Energy Regulatory Commission approved unanimously a final rule concerning electric storage resource participation in RTO/ISO capacity, energy, and ancillary service markets. Order No. 841 directs each RTO/ISO to file tariff revisions implementing a “participation model” to facilitate and govern the participation of storage resources in the markets, and requires that the tariff revisions be filed with FERC within 270 days of the rule’s publication in the Federal Register. The RTOs/ISOs will have 365 days thereafter to implement their proposed tariff provisions.

According to the staff presentation, the new Rule requires that each RTO/ISO’s participation model:

  1. ensure that an electric storage resource using the model is eligible to provide all capacity, energy, and ancillary services that it is technically capable of providing;
  2. ensure that an electric storage resource using the model can be dispatched and can set the wholesale market clearing price as both a wholesale seller and wholesale buyer, consistent with rules that govern the conditions under which a resource can set the wholesale price;
  3. account for the physical and operational characteristics of electric storage resources through bidding parameters or other means; and
  4. establish a minimum size requirement for participation in the markets that does not exceed 100 kW.

The Rule further requires that the resale of energy from an electric storage resource back to the RTO/ISO markets be at the wholesale locational marginal price.

Order No. 841 takes no action on earlier proposed reforms related to distributed energy resource aggregations. As to those reforms, the Commission and Commission staff will be convening a technical conference on April 10 and 11, 2018 in Docket Nos. RM18-9-000 and AD18-10-000. The technical conference notice states that the conference will cover seven different panels. Parties wishing to participate in this conference should submit a nomination form by 5:00 p.m. on March 15, 2018. Though not required, those planning to attend in person are encouraged to register by April 3, 2018.

Commissioners LaFleur, Chatterjee, Powelson, and Glick each issued a separate statement on Order No. 841.

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