ESA Policy Update. October 28, 2015

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1 1 ESA Policy Update October 28, 2015

2 Agenda Federal IRS FERC Congress Wholesale markets PJM SPP ERCOT States Policy in Focus: Distribution Planning Frameworks & Storage 2

3 IRS Guidance on ITC Eligibility Explicit Qs in IRS Notice What is the definition of storage? Is storage qualifying energy property under Section 48? Is solar-paired storage charged from another source ( dual-use ) eligible under section 48? Under what circumstances? How should it be credited? Other Qs Is storage added to solar already placed-in-service ( retrofit ) eligible for ITC? How should it be credited? Is storage owned by a separate party from paired solar PV eligible? How should it be treated? How does eligible dual-use storage affect crediting of shared components (e.g., BoS)? ESA planning filing; comments due Feb 16, 2016 Expected implementation 2018 after current ITC expiration date 3

4 FERC NOPR on 5-Min Settlements Requires 5-minute settlement intervals in realtime markets of all ISOs Harmonizes with dispatch intervals Would affect PJM, MISO, ISO-NE 1 year to implement Requires shortage pricing during dispatch intervals with insufficient energy or operating reserves 4 months to implement ESA planning filing; comment due Nov 30 Generally supportive; studying issues specific to energy storage (e.g., impact on SoC) 4

5 Congress ESA launches Battery Energy Storage Caucus House E&C Committee passed H.R. 8 Sec 1107 requires utility IRPs to consider resiliency technologies, including storage Some controversial provisions conflicts with Senate ENR Floor vote potentially December 5

6 PJM Current Issues Deadline for Capacity Injection Rights 10/31 Required for participation in Capacity Performance 2019/20 Base Residual Auction, scheduled for May 2016 Markets and Reliability Committee voted to implement RegD cap Regulation Market Issues Senior Task Force (RMISTF) underway to review Regulation market Monthly meetings; next meeting 11/11 6

7 PJM RMISTF Staff Interests PJM priorities Ensure regulation mix meets operational needs Meet Tariff mandates to procure least cost combination of resources Minimize operator workload Arrive at a solution that can be implemented with reasonable cost and effort IMM priorities Ensure the benefits factor (BF) is calculated in a way that properly measures value of RegD Use the BF consistently across market clearing and settlement Correct errors they see in calculation details of clearing process 7

8 PJM RMISTF Stakeholder Interests Thermal generators Goal: maximize RegA (slow + long) oppose RegD Pumped hydro Goal: establish & maximize RegB (fast + long) Load interests Goal: minimize total costs of Regulation neutral on RegD Non-generating resources Goal: ensure market access support RegD EPCs Goal: unknown Transmission Not engaged Largest number of votes Company affiliates each have a vote at RMISTF Any solution will require support of pumped hydro 8

9 ESA Engagement at PJM RMISTF ESA principles, in order of priority: 1. Promote competitive markets for storage 2. Preserve (or expand) existing storage market value 3. Set good precedent for Regulation at other ISOs SPP to visit PJM on Dec 1 re: storage Concerns to address Fate of short-duration resources Expected prices/revenues 9

10 SPP Market Working Group SPP considering Revision Request 114 Restores previously-existing classification of Storage Energy Resources First step to market participation, opens conversation on Fast Regulation Follow-up expected at 12/15-16 MWG meeting Expected timing of approval would be April

11 11 SPP Discussion Qs on Storage

12 ERCOT / PUCT DREAM Task Force focused on defining DERs Storage registers as both generation & load and settles nodally, by PUC rule; proposed definition of DER excludes load ESA engaging on including storage in DER definition Next meeting to focus on registration, interconnection, metering DG Interconnection straw proposal at PUCT Deals with ability of 3 rd parties to sign interconnection agreements Workshop 10/29; ESA to discuss further aspects relevant for storage Forthcoming info on Ancillary Services Redesign (NPRR667) Waiting on Brattle Report on pricing issues for AS products and NPRR revised language Nov 9 workshop to discuss NPRR 12

13 ERCOT / PUCT DREAM Task Force focused on defining DERs Storage registers as both generation & load and settles nodally, by PUC rule; proposed definition of DER excludes load ESA engaging on including storage in DER definition Next meeting to focus on registration, interconnection, metering DG Interconnection straw proposal at PUCT Deals with ability of 3 rd parties to sign interconnection agreements Workshop 10/29; ESA to discuss further aspects relevant for storage Forthcoming info on Ancillary Services Redesign (NPRR667) Waiting on Brattle Report on pricing issues for AS products and NPRR revised language Nov 9 workshop to discuss NPRR 13

14 States CALIFORNIA: changes to SGIP eligibility (by GHG intensity) under consideration likely to favor storage OREGON: request for storage grant applications ($300K available) due 10/30 NEW JERSEY: $3MM to be made available for BTM renewables-paired storage FY16 NEW MEXICO: Governor s state energy plan focuses on storage for economic development MASSACHUSETTS: stakeholder engagement session 10/30 on two-part study of energy storage landscape and policies HAWAII: net energy metering ended; expedited interconnection for BTM storage 14

15 Policy in Focus: Distribution Planning Frameworks and Storage 10 states now in various types of proceedings on distribution planning frameworks / grid modernization New York: Reforming Energy Vision California: Distributed Resource Plans Hawaii: DER Docket Massachusetts: Grid Modernization Plans Texas: Distributed Resource in Energy and Ancillary Services Markets Task Force Connecticut: Public Act Proceeding District of Columbia: Formal Case 1130 Minnesota: e21 Initiative New Hampshire: Case IR Maryland: PC40 technical workshops 15

16 Recent Activities NEW YORK: PSC guidance on DSIP filings details list of data to release, discusses role of storage in plans CONNECTICUT: ESA made filings on storage in grid-side enhancements MARYLAND: ESA provided storage view at hearings on value of DERs DC PSC: ESA provided storage view at workshop on DERs 16

17 Thank you Jason Burwen 17