Primer: Impact of FERC Order 845 on Energy Storage

As ISO/RTOs start to get ready to submit initial Order 845 compliance filings at FERC, more questions are coming up about the order, and how it impacts energy storage. Here’s a quick primer.

The primary intent of Order 845, Reform of Generator Interconnection Procedures and Agreements, is to improve the interconnection process for generators over 20 MW by removing uncertainty, promoting more informed interconnection decisions and greater transparency, improving the interconnection process, and modifying the pro forma Large Generation Interconnection Procedures (LGIP) and Large Generation Interconnection Agreement (LGIA). Embedded in the Order are concepts and clarifications that impact energy storage.

·      The definition of Generating Facility was amended to include energy storage.[1]

·      While it isn’t specific to energy storage, facilities can now request interconnection service below the generation facility nameplate capacity (or the aggregate capacity), as long as control system and penalties are in place to ensure the facilities do not inject above requested level. 

·      Enables generation owners to add energy storage to an existing generation facility. If a generation owner has “surplus interconnection”[2] it can request a fast-track interconnection process to utilize the surplus, by adding storage for example, or transfer that surplus to an affiliate. However, the Order falls short of the NOPR, and FERC did not include a concept which they advanced in the NOPR which would have allowed non-affiliated parties to buy and sell surplus interconnection.  

FERC declined to act on a number of requests related to energy storage, specifically:

·      The Commission declined to set standards for modeling energy storage in the interconnection process, either stand alone or co-located, at this time. Therefore, it remains up to each ISO to model energy storage as deemed appropriate.

·      The Commission determined the definition of generation does not need to be amended to specify that an asset can withdraw energy from the grid, as requested by NYISO.

·      The Commission declined to clarify that energy storage being used as a transmission asset does not need to go through the LGIP and execute an LGIA as requested by a few stakeholders. FERC based their decision on the fact that changes made in this order will not affect whether energy storage operates as transmission.  

·      The Commission declined to extend the Order to make similar changes to the Small Generator Interconnection Process (SGIP), citing the processes are significantly different.


[1] New definition: Generating Facility shall mean Interconnection Customer’s device for the production and/or storage for later injection of electricity identified in the Interconnection Request, but shall not include the interconnection customer’s Interconnection Facilities.

[2] Surplus interconnection is the unused portion of interconnection amount requested and reflected in the interconnection service agreement

Catch CRI at the following upcoming conferences

CRI co-founder, Kerinia Cusick, will be presenting at two upcoming conferences in California, discussing the implications of changes to FERC regulations on distributed assets, and the ongoing CAISO stakeholder process to develop regulations on the use of energy storage as transmission assets.

  • DER World Forum, Oct 16 & 17 in Costa Mesa, CA. A copy of the presentation can be downloaded here.

  • ACORE Renewable Energy Grid Forum, Nov 8th in San Francisco, CA.

We look forward to seeing you there!

Helping the Delaware Public Service Commission Understand Smart Inverters

CRI's Harry Warren was invited by the Delaware Public Service Commission to deliver a primer on Smart Inverters and share information on the work being done in Maryland to start preparing the state to take advantage of this new type of inverter, which will increasingly be used with solar, or storage, systems installed in homes and businesses.

Smart Inverters have the ability to provide voltage and reactive power (VAR) support on distribution lines, provide two-way communications, can "island" when the electric grid goes down and continue to provide power, and "ride through" (i.e. keep operating) when a change in frequency occurs on the electricity grid and help grid operators avoid cascading a problem further. However, to implement this technology, state commissions will have to make critical decisions to allow the inverters to be smart. Inverters must comply with IEEE 1547, which recently under went a significant rewrite to allow the functions that Smart Inverters can perform. However, contrary to previous standards, this one requires specific decisions to be made to allow, or not, inverters to perform the functions they can. 

A copy of Harry Warren's presentation given to the DE PSC can be found here

CRI Enabling Smart Inverters in Maryland

The Maryland Public Service Commission has scheduled a hearing to approve updated Small Generator Interconnection Standards on September 5, 2018.   CRI is co-chairing the Smart Inverter Subgroup in the Maryland Public Conference 44 (PC44) grid modernization docket, and the updated standards include Subgroup recommendations on the use of smart inverter features to support economical DER deployment.   The Subgroup is now developing a “roadmap” for timely adoption of the new IEEE-1547-2018 smart inverter standard statewide.


CRI Identifying How to Increase Procurement of Renewable Energy for DC

CRI has been retained by the District of Columbia Department of Energy & Environment to evaluate increasing the renewable energy content of Standard Offer Service by entering into long-term PPAs.  “SOS” is the default service provided to customers not served by a competitive supplier in the City’s restructured electricity market.  The final report is due September 30, 2018.

The NY Energy Storage Roadmap is published

CRI congratulates NYSERDA and the NY PSC on the publication of the NY Energy Storage Roadmap. It is a significant analysis of the value that energy storage can provide ratepayers and the electricity grid and the regulatory hurdles that need to be removed to allow energy storage to participate. We thank NYSERDA for turning to CRI to provide insight on regulatory hurdles at the bulk system level and develop recommendations. It was a pleasure and privilege to be part of the talented and dedicated team that developed this report. 

Download the NY Energy Storage Roadmap here.

CRI Submits Recommendations to NYSERDA for the NY Energy Storage Roadmap

CRI is concluding a multi-month effort to advise the NY State Energy Research & Development on regulatory barriers to including energy storage in bulk markets, as well as the relevant FERC Orders and NERC reliability requirements that will dictate the allowable market changes that NYSERDA, the NY PSC and NYISO can make moving forward. CRI included a set of recommendations to market structure and tariffs that will enable energy storage to be used cost effectively, and to its full potential. CRI appreciates the opportunity to be a part of the NY Energy Storage Roadmap. 

"Virtual Transmission Lines" highlighted by Greentech Media

"Virtual Transmission Lines" highlighted by Greentech Media

"...virtual transmission lines, centers on using DERs like rooftop solar or battery storage, stepping in when power is needed -- and getting paid for it. Though distributed energy can’t shuttle electrons through a system in the same way traditional transmission lines can, it can help shore up the grid in certain areas so that electricity doesn’t need to be dispatched from elsewhere."

CRI White Paper: Energy Storage Misconceptions

CRI White Paper: Energy Storage Misconceptions

Cost-competitive energy storage is viewed as a "game changer" in the electricity generation, transmission and distribution industries. As such, grid-connected storage is getting an increasing amount of attention from legislators and regulators. At the same time, there’s a lot of confusion surrounding energy storage. CRI works with policy makers and we frequently find ourselves answering questions about technological maturity of energy storage, its applicability, and economic competitiveness. This white paper is designed to clarify a few of the common misperceptions that we’ve encountered, specifically questions surrounding cost, commercial availability, cost competitiveness.

CRI Files Comments Regarding DC's Modernizing the Energy Delivery System for Increased Sustainability (MEDSIS)

The District of Columbia Commission launched an effort in 2015 to modernize the distribution energy delivery system for increased sustainability (MEDSIS). Commission Staff issued a report in 2017, identifying potential barriers requiring Commission action and laying out recommendations for the use of the MEDSIS Pilot Project Fund ($21.55M). CRI's filing suggests changes to a few definitions, priorities for the use of MEDSIS fund resources, and identifies additional issues for Commission consideration in order to host high levels of Distributed Energy Resources (DER) on the DC grid. Download CRI's comments here