u.s. federal and state regulations - brattle...
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Copyright © 2017 The Brattle Group, Inc.
U.S. Federal and State RegulationsOpportunities and Challenges for Electricity Storage
Dr. Romkaew P. Broehm
Nov ember 2 , 2017
PRESENTED BY
BIT’s 7th World Congress of Smart Energy - 2017
PRESENTED TO
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DisclaimerThe analysis and projections that we provide in this document are necessarily based on assumptions with respect to conditions which may exist or events which may occur in the future. No one can give you any assurance that the assumptions used will prove to be correct or that the forecasts will match actual results of operations. Our analysis, and the assumptions used, are also dependent upon future events that are not within our control or the control of any other person, and do not account for certain regulatory uncertainties. Actual future results may differ, perhaps materially, from those presented here.
All results and any errors are the responsibility of the author and do not represent the opinion of The Brattle Group, Inc. or its clients.
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Electricity Storage Projects Are All Over the World
Source: DOE Global Energy Database
As of September 2017, there are 998 advanced electricity storage (ES) projects operating across the world, totaling approximately 6,823 MW.
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Where Is the Fast Growing ES Area?Number of Advanced Electricity Storages (without Hydro Pumped Storage Projects)
Source: DOE Global Energy Database and The Brattle Group
0 100 200 300 400 500 600 700
Israel
Denmark
Portugal
South Africa
Chile
Ireland
Switzerland
India
France
Canada
Netherlands
United Kingdom
Italy
Australia
Spain
Japan
Germany
China
Korea, South
United States
No. of Projects
Operational
Under Construction
Contracted
Announced
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How Has ES Flourished When ES Capital Cost is Still Too High?
0
500
1,000
1,500
2,000
2,500
3,000
3,500
4,000
0
100
200
300
400
500
600
700
800
900
1,000
8 10 12 14 16 18 20
4‐Hou
r Battery Cost ($/kW
)
4‐Hou
r Battery Cost ($/kW
h)
Battery Lifetime (Years)Sources: EIA AEO (2017). NREL (2015). Peaker Replacement Values from Lazard December 2016 Report (Page 14). Brattle Assumptions .
CT $1,092/kW
Adv. CT $672/kW
Zinc Peaker Replacement $648/kWh
Lithium Ion Peaker Replacement $949/kWh
Lithium Ion Peaker Replacement $417/kWh
Zinc Peaker Replacement $258/kWh
To break even with advanced CT, ES capital cost needs to be around $922/kW (or $230/kWh) or $1,408/kW (or $310/kWh) for CT.
Installed project costs of behind‐the‐meter projects are even higher than the cost of CT, according to California’s 2017 SGIP
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Agenda 1. Federal Initiatives
2. State Initiatives
3. Opportunities and Challenges: Lessons Learned
4. Conclusions
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Key Regulators Oversee U.S. Electricity Markets Federal Energy Regulatory Commission (FERC) regulates wholesale electricity markets while state regulatory commissions oversee their retail electricity markets ▀ 50 State Regulatory Commissions, examples include:
New York Public Service Commission
Public Utility Commission of Texas
California Public Utility Commission
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Federal Initiatives
FERC
Question: Do the policymakers’ initiatives lead ES into a heathy and sustainable investment?
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Series of Policies to Remove ES Market Barriers
2011
Order 764
Integrating Varia
ble En
ergy
Resources through Intra‐
hour transm
ission
Sche
duling Re
form
Order 784Third‐Party Provision of Ancillary Services; Reporting for New Electric Storage Technologies
Order 792 Small Generator Interconnection Agreements and Procedures
2013
Note: The orders can be downloaded at https://ferc.gov/legal/maj‐ord‐reg.asp
NOPR RM16‐23Electric Storage Participation in Markets Operated by Regional Transmission Organizations and Independent System Operators
2016
Order 755Frequency Regulation Compensation in Organized Wholesale Power Markets
2012 2017
PL17‐2Utilization of Electric Storage Resources for Multiple Services When Receiving Cost‐Based Rate Recovery
RM17‐8Reform of Generator Interconnection Procedures and AgreementsNOPR
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Generators in a wholesale organized market (ISO/RTO) who provided their regulation (or load following) services received:▀ Capacity Payment▀ Energy Payment▀ Some ISO/RTOs did not compensate regulation up or regulation down services
To recognize quality of response, generators in ISO/RTOs receive compensation for their regulation services:▀ Capacity for Reg. Up▀ Capacity for Reg. Down▀ Mileage Payment▀ Performance Payment
Order 755 (2011) Increases Revenues for ES
Before After
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January 2016 to June 2017 Regulation PricesAn Illustration of Regulation Mileage and
Accuracy Rate
$0
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Price ($/M
Wh)
RTH Regulation Performance RTH Regulation Capability
RTH Mileage Ratio
12
13 14
No change
AGC Set point
Up
Down
Instructed Regulation Mileage (IRM) isthe absolute sum of + + . When there is nochange in the instructed movement, there is no mileage.
11
12 1411
1A
1B
AGC Set pointActual Response
Up
Down
+ = Total Deviation1A 1B
A resource that can reach, say, 20 MW of its certified capacity in 1 minute will have ten times more mileage than a resource that can only reach the same 20 MW in 10 minutes.
$0
$10
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Price ($/M
Wh)
RT15AVG Down RegulationRT15AVG Regulation Mileage DownRT15AVG Regulation Mileage UpRT15AVG Up Regulation
PJM
California ISO Examples of Regulation prices in PJM and CAISO wholesale power markets
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An Example of Battery Performance
Blue areas represent DA energy payment to CAISO for charging and revenues from discharging
Orange areas represent RT revenues or payments due to uninstructed deviation from DA award schedule due to the battery curtailing charge as a result of SOC near 100% and parasitic electric loads in the ES system
CAISO instructed energy
ES RT Energy
Source: PG&E
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▀ Some treat ES like demand response resources, i.e., with limited energy resources per day
▀ Can only participate in Ancillary Services markets*
▀ Focuses on bidding parameters of traditional generators, such as pumped storage
* PJM and CAISO allow ES to participate in all wholesale markets
Establish ES participation model:▀ ES can provide capacity, energy, and AS services (P.48‐50)
▀ Bidding parameters must reflect ES op. constraints, e.g., state of charge.
▀ Min size must not exceed 100 kW▀ ES’s charging cost is a locational marginal price
Optimize ES dispatch according to its physical capabilities
RM16-23 (2016) Reduces Market Barriers
Current NOPR
To improve the ISOs’ ES integration, FERC proposed to require ISOs to revise their market rules and tariffs to provide clarity and recognition of ES’s physical capabilities and benefits.
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Energy Storage Can Perform Many Applications A user’s ES choice therefore depends on his/her application need.
Energy
Capacity
Grid Support
Environment
Energy
Grid Support• Regulation and frequency responses• Spinning Reserves• Voltage Support
Capacity/Reliability• Renewable Capacity Firming• Transmission Upgrade Deferral• Distribution Upgrade Deferral
• Energy Time Shifting
Environment• Reduction in CO2 and air pollutants
Resilience• Emergency preparation• Improve customer outage recovery
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FERC understood that ES is capable of providing multiple services, and thereby should earn multiple revenue streams, even though some services may be offered via markets and others via a system operator’s control.
PL17-2 Allows ES to Serve Multiple Services
0
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80
0
500
1000
1500
2000
2500
3000
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
Market P
rice (
$/MWh)
(Cha
rge) Disc
harge (
MW)
Discharge Charge Market Prices
Discharge during peak prices
Charge during low prices
‐
10,000
20,000
30,000
40,000
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
Load
(MW)
Hour
ES’ Energy Shifting
ES’ Voltage Control
ES’ Regulation Service
Source: PG&E
Source: SDGE
Source: The Brattle Group
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RM16-23 (2016) Allows DER/Aggregators To reach higher market efficiency from growing excess energy of Distributed Energy Resources (DERs), FERC proposed to allow DERs and Aggregators of DERs to bid into ISOs directly.▀ Reduce uncertainties in load forecasts by allowing them to participate in a day‐ahead market.
▀ Send price signals to where investment is needed. ▀ ISO must remove any unnecessary limitations on how DERs must be operated, such as minimum size and performance requirements.
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Proposed DER/Aggregators Participation in Wholesale Market Proposed Participation Requirement:
▀ Size requirement but no limit on DER technologies ▀ Location requirement to be as broad as technically feasible▀ Bidding requirement—submit bidding parameters that cover distribution factors and operational constraints
Importantly, DERs cannot participate in the wholesale market if they already receive a net‐metering compensation or participate in another wholesale power market program.
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ES Can Earn Higher Revenues When Usages Are Co-optimized
Trans. CapacityDist. CapacitySpin
Regulation
Gen. Capacity
Energy Arbitrage
There is significantly more system benefit if the battery can be utilized to capture multiple value streams rather than just individual use cases.
Note: Results shown for San Diego location.
Hledik, et. al, The Brattle Group, Stacked Benefits: Comprehensively Valuing Battery Storage in California, Prepared for Eos Energy Storage, August, 2017.
Cost‐based
Market‐based
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But FERC required the following conditions:▀ Avoid double recovery of costs borne by ratepayers− Credit market revenue to cost‐based ratepayers according to its cost‐of‐service allocation. E.g., 50% market revenue credit if 50% of the ES cost is assigned under cost‐of‐service.
▀ FERC Order 784 et.al. on reporting requirements will allow FERC to have effective oversight of just and reasonable rates.
▀ Technical feasibility and predictability of the cost‐based service needs. Otherwise, ES will be strictly served as a regulatory asset only. Priority is given to cost‐based services.− This would therefore depend upon the ES’s state of charge requirement.
PL17-2 Allows ES to Capture Its Full Value
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State Initiatives
Question: Do the policymakers’ initiatives lead ES into a heathy and sustainable investment?
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States’ ES Policy Initiatives We can separate state policy initiatives into three main groups:
▀ Set ES targets that distribution companies must meet▀ Establish ES Deployment Program ▀ Explicitly include ES as a utility’s resource option in Integrated Resource Plan (IRP)
Some states are now assessing which policy initiatives are best suited for them.
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California (CPUC D. 13‐10‐040, October 2013)
By 2020, distribution companies are required to procure 1,325 MW of energy storage devices. Storage projects must address at least one of the policy objectives:▀ Grid optimization (peak reduction, reliability needs, or T&D
deferrals) ▀ Integration of renewable energy sources; and ▀ Reduction of GHG emissions
Above the targets, they can have ES installed at T, D, or Behind‐the‐Meter (Customer) levels
In addition, CPUC provides funding for R&D and pilot programs, including Self Generation Incentive Program (SGIP), which provides incentive payments to behind‐the‐meter storage.
Goals: In support of statewide strategy of reducing carbon emissions(1) Drive market transformation(2) Eliminate barriers(3) Gain development and operational exp.
Setting ES Targets
Distribution Company
Target
Pacific Gas & Electric
580 MW
Southern California Electric
580 MW
San Diego Gas & Electric
165 MW
Other Non‐Utilities
1% of Peak Load
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Other Examples of Setting ES Targets Oregon: Oregon House Bill 2193 It requires Oregon utilities to have a minimum of 5 MWh of energy storage in service by January 1, 2020. Oregon utilities must install a minimum of 5 MWh of ES by January 2020. ▀ Oregon Public Utility Commission (OPUC) issued guidelines to encourage utilities to procure ES via Request for Proposals (RFPs).
▀ ES continues to be subject to cost‐effectiveness tests. ▀ The OPUC encourages maximizing the value of ES by having it serve multiple applications so that its value can be “stacked.”
Massachusetts: Utilities must achieve 200 megawatt‐hours of ES by January 1, 2020.
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Establish ES Deployment Program New York: In June 2017, the New York legislature directed the NY PSC (SB 5190 and AB 6571) to develop an Energy Storage Deployment Program by December 2017. ▀ In a separate proceeding, through New York’s Reforming the Energy Vision (REV), NYPSC allows ES to pair with DER and be compensated based on the “Value Stack” tariff. ES can receive revenue streams from energy, capacity, and environmental values
for 25 years. The values are not fixed, but will vary based on New York’s wholesale energy
(NYISO’s LMPs), capacity, and environmental markets. The capacity values will be based on their performance to meet the system peak
load, taking into account location.
▀ New York City set energy goals, including a goal of installing 100 MWh of storage by 2020, aiming to reduce GHG emissions by 80% by 2050.
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Inclusion of ES in IRP New Mexico: New Mexico Public Regulation Commission included ES among resources that must be considered in NM utilities’ IRPs.
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Assessing ES Initiatives Nevada (S.B. 204) ‐ By October 2018, Nevada PSC must:
▀ Determine whether Nevada utilities must procure ES for the following purposes: Renewable integration into T&D system; Improvement in the reliability of the electric grid; Reduction in the emission of greenhouse gases; Reduction in the need for building generation to serve peak demand; Avoid T&D expansion
▀ Quantify costs and benefits of procuring ES▀ If ES has net benefits, the PSC shall establish: Annual procurement requirement Business model (e.g., who should own ES?)
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Opportunities and Challenges
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Opportunities There are 418 advanced ES projects totaling approximately 1,675 MW
Most are located in states with policy initiatives like California and New York.
Many projects are also in PJM due to market pricing signals. The numbers of ES projects are likely to grow due to a projected higher level of renewables.
Source: DOE Global Energy Storage DatabaseSource: Energy Information Administration, Annual Energy Outlook, 2017.
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Credit: MA State of Charge Report
ES Applications in All Parts of the Grid
Third‐Party‐Owned24%
Utility‐Owned31%
Customer‐Owned45%
In the US, ES has applications across the entire electricity system, both in front and behind‐the‐meter.
Source: DOE Global Energy Storage Database & The Brattle Group
Approximately 45% of advanced ES were installed by customerSource: SCE 2016 Energy Storage Procurement Plan
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Hours o
f Ene
rgy
Response Time
Seconds
10 Minutes
30 Minutes
1 Hour
1 <Hour<24
> 1 Day
> 1 Year
Power Quality
Second
s15
Mins
1 Hou
r8 Hou
rs
Ancillary ServicesRegulation, Frequency Response, Operating Reserves, Voltage Support
Time Shifting
Capacity Reserve/Back‐up
Which Functions Does ES Perform?
0
5
10
15
20
25
30
0 1000 2000 3000 4000 5000 6000
Discharge Tim
e (hou
r)
Capacity (kW)
0.00.51.01.52.02.53.03.54.04.5
0 5000 10000 15000 20000 25000
Discharge Tim
e (hou
r)
Capacity (kW)
Flywheel
Thermal
Lithium
Source: DOE Global Energy Storage Database
Microgrid
Energy Bill Management
Frequency Responses
Frequency Responses
Peak Shaving
ApplicationsTotal MW Count
Renewables Capacity Firming 2539 107Frequency Regulation 1156 147On‐Site Power 864 43Electric Energy Time Shift 676 125Renewables Energy Time Shift 545 29Electric Supply Capacity 432 49Electric Bill Management 376 215Black Start 366 26Onsite Renewable Generation Shifting 231 47Electric Supply Reserve Capacity ‐ Spinning 212 41
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Frequency Regulation and Ramping Services Growth of renewables creates a need for new grid support services that allow the system to be much more flexible in order to maintain system reliability.
Ramp Need
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Peak Shifting/Renewable Capacity Firming The pattern of Solar PV generation may not necessarily coincide with load. PV owners install ES to maximize unused energy solar. ▀ They can store excess solar energy for use during their peak load hours.
Load peak between hours 16‐20
Solar peak between hours 10‐14
Source: The Brattle Group
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ES Participation in Wholesale PG&E’s ES pilot project bid into the CAISO regulation market. Revenues received are primarily from the day‐ahead regulation capacity market.
Source: PG&E ‘s EPIC 1.01
Sample Month
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Multiple Use Applications of Behind-the-Meter ES PowerTree serves residential customers in apartment buildings in Northern California. Its applications include:▀ Integrating batteries to firm up energy generated from solar PV;▀ Directing electric vehicles to charge and discharge to serve load and sell in the CAISO markets; and
▀ Participating in a wholesale market by selling regulation services to the CAISO
Source: PowerTree
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Trend: WSJ Headline on October 15, 2017
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Latest Buzz—Lithium-ion Battery Cost Decline Lithium‐ion battery prices have been dropping sharply, and projected to decrease from $273/kWh in 2016 to $109/kWh by 2025▀ $73/kWh by 2030—approximately 75% drop from the 2016 price▀ Big driver is the economies of scale from Electric Vehicles
The question is whether lithium prices will increase, given this growing demand.
Source: WSJ, October 14, 2017.
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Technical Challenges Remain▀ ES has limited energy and cannot participate in all hours.▀ ES participating in the AS markets must minimize risks of having to charge during high prices.When providing the AS capacity, ES is subjected to ISO’s dispatch instructions. In some circumstances, the ISO can call ES to provide regulation down in the real‐time energy market, i.e., charging energy, but the LMP can be very high, e.g., $1,000/MWh.
Illustrative Example 1 MW Battery with 5 MWh Energy
Day‐ahead Reg Up Capacity Payment 4,446$ Day‐ahead Reg Down Capacity Paymen 42$ Reg Mileage Up ‐$ Reg Mileage Down 141$ RT Energy Charging Cost (5,005)$ Net Revenue (376)$
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Interconnection Costs Experience from pilot programs raised issues of high interconnection costs as a barrier:▀ Telemetry is required for AS added costs.▀ Interconnection process is complicated, time consuming, and costly. ▀ Some ES that participates in both wholesale and retail markets needs dual meters.
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Retail Rate Design for ES Unlike traditional generation, behind‐the‐meter ES uses station power when ES is charging power or when not generating (sitting idle but air‐conditioning or SCADA still need to be on). ES pays for the power based on retail rates.▀ This is new! The challenge is what type of tariff rate design is reasonable for ES?
Distribution Utility ES Owner
Retail Rate Net from Total Generation
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Takeaway Policy initiatives for ES must lead to sustainability of the ES.
▀ Not over‐compensating or under‐compensating ES▀ Not creating cost shifting
Accurately compensating ES values will encourage wide‐scale ES development in a way that:▀ Fulfills a clean energy goal▀ Incentivizes the location, design, and operation of ES that maximizes overall value to all utility customers
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Presenter Information
ROMKAEW P. BROEHMPrincipal │ [email protected] +1.617.864.7900
Dr. Romkaew Broehm is an economist whose practice is focused on the electric utility industry. She specializes in the areas of market deregulation and oversight, market power analyses, studies of bulk power markets, renewable integration, utility cost structures, and cost‐benefit analyses.
She has submitted testimony and comments before the Federal Energy Regulatory Commission (FERC) on market‐based rates (MBR), market manipulation, and merger and acquisition (M&A) matters. She has analyzed potential competitive impacts of M&A transactions on wholesale power markets for both horizontal and vertical market power aspects in various power markets, such as ISO‐NE, NYISO, PJM, SERC, FRCC, SPP, Entergy System, and WECC, including the CAISO Energy Imbalance Market. She co‐authored Market Power and Market Manipulation in Energy Markets from the California Crisis to the Present (2015).
The views expressed in this presentation are strictly those of the presenter(s) and do not necessarily state or reflect the views of The Brattle Group, Inc.
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