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Electric Storage Participation in Markets: FERC Order No. 841 Compliance

Learn about three additional tariff changes required by ISO-NE to demonstrate compliance with FERC Order No. 841. These changes align with the market design discussed with stakeholders.

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Electric Storage Participation in Markets: FERC Order No. 841 Compliance

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  1. April 23,2019| NEPOOL Markets Committee Catherine McDonough 413.535.4027| cmcdonough@iso-ne.com Electric Storage Participation in Markets FERC Order No. 841 Compliance

  2. FERC Order No. 841 Compliance WMPP ID: 129 Response to FERC: May 1, 2019 FERC Order No. 841 Compliance changes were approved by the Participants Committee last November and jointly filed with FERC by NEPOOL/ISO with an effective date of December 3, 2019 On April 1, 2019, FERC issued a letter requesting clarification on certain items in the filing and additional tariff changes as needed to demonstrate that New England’s market rules fully comply ISO is working to develop responses to FERC’s questions and has identified a need for three additional tariff changes to comply with Order No. 841; changes that fully align with the market design already discussed with stakeholders The tariff changes may be further refined and augmented in the days aheadas the ISO develops a final response to FERC’s request for clarification regarding how New England’s market rules comply with specific directives in Order No. 841

  3. Scope of Today’s Session Describe three additional tariff charges required to demonstrate that New England’s market rules comply with FERC Order No. 841

  4. Additional Tariff Changes Required for Compliance Three Changes Identified All three changes modify the Electric Storage Section of the tariff (III.1.10.6) to better align with the market design already discussed with participants: Electric Storage Facilities: May comprise one or more storage facilities at the same point of interconnection Shall be directly metered Will not receive conflicting dispatch instructions to charge or discharge simultaneously

  5. Additional Tariff Changes Required for Compliance An ESF May Comprise One or More Storage Facilities at the POI FERC Request: Please explain and provide citations to the relevant proposed tariff language that clarify whether electric storage resources smaller than 100 kW may be aggregated to meet ISO-NE’s 100 kW participation threshold for Electric Storage Facilities.. Summary of ISO Response: An Electric Storage Facility (like a Generator Asset) cannot consist of an aggregation across multiple points of interconnection. At each point of interconnection, an Electric Storage Facility must be 100 kW or greater. However, as for Generator Assets, an aggregation of storage facilities behind the same point of interconnection (POI) is permissible; proposing a tariff change to Section III.1.10 (a) to codify this point (See slide 7)

  6. Additional Tariff Changes Required for Compliance ESFs Shall Be Directly Metered FERC Request: Please provide specific citations to the relevant existing and/or proposed Tariff sections that demonstrate that ISO-NE requires Generator Assets, and therefore Electric Storage Facilities, to be directly metered Summary of ISO Response: In its discussion with stakeholders and in its filing with the Commission, ISO indicated that an Electric Storage Facility needs to be directly metered but this requirement was not added to the tariff; proposing Section III.1.10.6(a)(iv)) to codify this requirement (See slide 7)

  7. Additional Tariff Changes Required for Compliance Proposed Changes Regarding Aggregation and Metering

  8. Additional Tariff Changes Required for Compliance No Conflicting Dispatch Instructions for Binary Storage Facilities FERC Request: Please provide specific citations to the relevant existing and/or proposed Tariff sections that demonstrate that Binary Storage Facilities and Continuous Storage Facilities will not receive conflicting dispatch signals to charge and discharge simultaneously Summary of ISO Response: Section III.1.10.6(c)(viii) already states that a Continuous Storage Facility (CSF) will “be issued a combined dispatch control signal” so there is no potential for a conflicting signal ISO-NE real-time commitment process will not commit a Binary Storage Facility’s Generator Asset and DARD at the same time so there is also no potential for a conflicting signal; proposing a tariff change to codify this point (See slide 9)

  9. Additional Tariff Changes Required for Compliance No Conflicting Dispatch Instructions for Binary Storage Facilities

  10. Summary & Proposed Schedule • Proposing three tariff changes to comply with Order No. 841 • All three tariff changes fully align with the market design already discussed with stakeholders • Tariff changes will be filed with FERC on May 1, 2019 along with responses to FERC’s requests for clarification as to how New England’s market rules comply with the specific directives in Order No. 841 • Effective date of the tariff changes is December 3, 2019

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