FERC Order 841-A affirms electric storage market participation

On May 16, 2019, the Federal Energy Regulatory Commission issued an order generally affirming an earlier order which established reforms to remove barriers to the participation of electric storage resources in certain organized wholesale markets. The Commission's Order No. 841-A denied various requests for rehearing of last year's Order No. 841.

In 2018's Order No. 841, the Commission found that existing rules for electricity markets operated by regional transmission organizations and independent system operators were unjust and unreasonable in light of barriers that they present to the participation of electric storage. Based on this finding, the Commission ordered wholesale market makers to revise their tariffs to "establish a participation model consisting of market rules that, recognizing the physical and operational characteristics of electric storage resources, facilitates their participation in the RTO/ISO markets." Order No. 841 required each regional organization's participation model to (1) ensure that a resource using the participation model for electric storage resources is eligible to provide all capacity, energy, and ancillary services that it is technically capable of providing in the RTO/ISO markets; (2) ensure that a resource using the participation model for electric storage resources can be dispatched and can set the wholesale market clearing price as both a wholesale seller and wholesale buyer consistent with existing market rules that govern when 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 RTO/ISO markets that does not exceed 100 kW. Order No. 841 also required that the sale of electric energy from the RTO/ISO markets to an electric storage resource that the resource then resells back to those markets must be at the wholesale locational marginal price.

In Order No. 841-A, the Commission generally affirmed these findings, while clarifying a handful of relatively limited points. The ruling ends for now some of the uncertainty over the scope and applicability of Order No. 841.

As regional wholesale markets develop tariff revisions to integrate electric storage resources, there could be significant opportunities to develop and benefit from electric storage. Reports have suggested significant potential for electric storage deployment -- with one 2018 study suggesting the U.S. could be home to between 7 and 50 gigawatts of storage, if costs continue to decline and sufficient policy support is available.