PJM Reply to FERC Provides Support (with Caveats) for New Storage NOPR
An instructive example of the depth of nuances required to successfully roll out policies and detailed regulations from more general initial rulemakings is to be found in the comments provided by PJM Interconnection, LLC, recently with regard to the Federal Energy Regulatory Commission (FERC) Notice of Proposed Rulemaking (NOPR).
The FERC NOPR concerns removal of “barriers to the participation of electric storage resources and distributed energy resource aggregations in the organized wholesale electric markets.”
PJM has already enabled approximately 300 MW of energy storage resources (ESRs) to flourish in a number of its markets. In its detailed comments dated Feb. 13, it seeks clarification regarding market rules to enable greater expansion of ESRs and related distributed energy resources (DERs).
The key threshold issues PJM highlighted in its reply include potential jurisdictional matters, e.g. related to the charging and discharging of behind the meter resources. Such issues must comprehensively address considerations which vary as a function of the entities involved—whether those entities are states, electric distribution companies, asset owners, or Regional Transmission Organizations and Independent System Operators (collectively, “RTOs/ISOs”). In addition, PJM highlighted the need for sufficient flexibility on key implementation details to accommodate for various distinct RTO/ISO characteristics.
DERs can include demand response, which PJM currently has integrated to a great depth and include more than “1,100 MW of nameplate capacity demand response resources consisting of batteries, reciprocating engines, combustion turbines, and other technologies that are physically capable of producing electric power.” Of these DR resources, fully 700 MW are involved with Wholesale Market Participation Agreement (“WMPA”).
