In our previous blog post, introductory information about the Federal Energy Regulatory Commission (FERC) Order 841 was addressed. This article describes the key features of how each region has preliminarily proposed to implement Order 841.
Each grid operator has submitted a participation model for storage resources, detailing the services of which they are capable of providing. Nevertheless, requirements vary depending on the region, allowing for flexibility in implementation strategies.
Be advised that proposed compliance plans are currently being revised, per Energy Storage Association (ESA) and FERC comments, and there may be changes to implementation details in the coming months.
- California Independent System Operator (CAISO) – The region has existing legislation requiring the procurement of storage resources; thus, its filing saw the fewest changes among all grid operators. However, it has proposed a reduction to its minimum size requirement from 500 kW to 100 kW, which is a significant change for the region.
- Below are links to the original compliance plan filing by CAISO, the deficiency notice from FERC, and the CAISO response to the deficiency notice.
- ISO New England (ISO-NE) – The region has proposed a process that allows suppliers to dispatch energy storage resources in the Real-Time Market, ensuring recognition of their operational ability to transition between charging and discharging states quickly. The changes would, according to ISO-NE, allow such resources to participate in the energy, reserves, and regulation markets. The region has also proposed a definition for “Electric Storage Facility”, as well as a requirement that such facilities be registered as either a “Binary” or “Continuous” Storage Facility. While a “Binary” Storage Facility is one that has traditional pumped-storage hydroelectric resources, a “Continuous” Storage Facility is able to transition between maximum output and maximum consumption in ten minutes or less.
- Below are links to the original compliance plan filing by ISO-NE, the deficiency notice from FERC, and the ISO-NE response to the deficiency notice.
- Midcontinent Independent System Operator (MISO) – The region has proposed the usage of eight “commitment statuses”, including four primary statuses (discharge, charge, continuous, and outage) and four additional statuses (emergency discharge, emergency charge, available, and not participating). Any electric storage withdrawals from the grid will be treated as negative generation, with categorization as wholesale electric storage withdrawals. Any electric storage injections will be handled under existing injection protocol.
- Below are links to the original compliance plan filing by MISO, the deficiency notice from FERC, and the MISO response to the deficiency notice.
- New York Independent System Operator (NYISO) – The region has proposed the usage of four modes: ISO-committed fixed, ISO-committed flexible, self-committed fixed, and self-committed flexible. Within ISO-committed modes, NYISO would determine optimal dispatch times for suppliers’ resources. Within the flexible mode, NYISO would dispatch resources in the Real-Time Market based on Locational Marginal Pricing (LMPs). Within the fixed mode, NYISO would schedule resources in the Day-Ahead Market and dispatch at a frequency of no more than every 15 minutes in the Real-Time Market. Within the self-committed modes, it would be the responsibility of the supplier to determine dispatch times and frequency. Additionally, the region proposed a minimum offer size of 100 kW for Energy Storage Resources to participate in the NYISO markets.
- Below are links to the original compliance plan filing by NYISO, the deficiency notice from FERC, and the NYISO response to the deficiency notice.
- PJM Interconnection (PJM) – The region has proposed the usage of three modes: continuous, charge, or discharge. In continuous mode, resources can both charge and discharge, and there would be no limitations on start-ups or ramp rate. A 10-hour discharge requirement for storage to participate in the region’s capacity market has also been proposed, though it has drawn heavy criticism. To participate, most resources would need to significantly derate capacity, but this would not prove to be cost-effective for participation. Additionally, for resources that are not owned by a load-serving entity, the newly proposed accounting framework would not allow for the sale of energy to other participants or the use of stored power for themselves; instead, the resources would need to sell back their energy to PJM.
- Southwest Power Pool (SPP) – The region has created a registration type of “Market Storage Resources (MSR)”, which is distinct from Electric Storage Resources (ESRs). SPP will allow its storage resources the opportunity to continue utilizing the existing model as an ESR or participate in the participation model as a registered MSR. The region has proposed the use of aggregation of storage, limited to the nodal delivery point, to accommodate generation that is less than 100 kW.
As compliance plans evolve and implementation progress details emerge, Power Settlements will continue to monitor this important initiative, and will incorporate updates into the SettleCoreTM system to ensure our customers are able to seamlessly adhere to the revised RTO and ISO market rule changes for energy storage resources.