On February 25, 2019, FERC issued an order accepting proposed revisions to the ISO New England Inc. (“ISO-NE”) Transmission, Markets and Services Tariff (“Tariff”) that would enable electric storage resources (“ESRs”) to more fully participate in ISO-NE’s markets (“Storage Revisions”). FERC found that the Storage Revisions reduce barriers to entry for ESRs by enabling them to provide services they are capable of providing, which would enhance competition, thus helping to ensure just and reasonable rates in the ISO-NE markets. ISO-NE submitted these changes as essentially an interim step on its road to becoming fully compliant with Order No. 841’s generic requirements regarding Regional Transmission Operators (“RTOs”) and Independent Service Operators (“ISOs”) enabling storage participation in competitive markets.
ISO-NE proposed the Storage Revisions as a way to enable ESRs to be dispatched in ISO-NE’s real-time energy market in a manner that recognizes their operational ability to quickly transition between their charging and discharging states. ISO-NE further stated that the Storage Revisions would allow the resources to participate in its energy, reserves, and regulation markets.
Among other changes updating terminology and clarifying provisions, ISO-NE stated that the “heart” of the Storage Revisions was a new section that defined the term “Electric Storage Facility” and provided that such a facility must be registered as either a “Binary” or “Continuous” Storage Facility. A Binary Storage Facility is more akin to traditional pumped-storage hydroelectric units, whereas a Continuous Storage Facility is a facility that can transition between maximum output and maximum consumption in ten minutes or less, like a battery storage resource. ISO-NE noted that the Storage Revisions will bring ISO-NE nearer to compliance with Order No. 841, which required RTOs and ISOs to revise their respective tariffs to better enable ESRs to participate in their markets (see February 20, 2018 edition of the WER for more detail on Order No. 841).
FERC also noted that, to the extent that aspects of ISO-NE’s filing relate more generally to compliance with Order No. 841, FERC will determine whether ISO-NE’s Tariff complies with the requirements of Order No. 841 in a separate docket and will address any concerns regarding ISO-NE’s compliance in that proceeding.
FERC’s February 25 order is available here.