WASHINGTON — More than 100 stakeholders gathered at the law offices of Morgan, Lewis & Bockius for Raab Associates’ Energy Policy Roundtable in the PJM Footprint. Panelists discussed the potential for storage resources in the RTO’s markets and the state of climate change politics in the U.S.

10 Hours of Providing Energy in PJM as Storage

Scott Baker, senior business analyst for PJM, had to fend off criticism from some of his fellow panelists of the RTO’s compliance filing for FERC Order 841, particularly its requirement that storage offering capacity would have to be capable of continuously supplying electricity for 10 hours.

At first, panelists were careful about what they said about the proceeding to avoid making ex parte comments, as a FERC staff member was in attendance. Once that staffer left the room, however, their consternation over the requirement became apparent.

“We see the 10-hour qualification requirement in PJM, regardless of the foundation, doesn’t correspond with what we see the [resource adequacy] contribution being,” said Jason Burwen, vice president of policy for the Energy Storage Association. “I think that’s the question: Do we have a rule that actually accords with the reliability contribution of the assets?”

Burwen acknowledged that “PJM has been in the lead on a lot of energy storage issues for quite some time” but that the 10-hour requirement, if approved, “is going to certainly delay the entry of energy storage into capacity markets in PJM.” He said Order 841 “sought to give storage incredible flexibility to be able to do the operations that it can to be the most valuable.”

“The 10-hour restriction makes it extremely difficult for small storage assets that we’re aggregating,” said Anne Hoskins, chief policy officer for Sunrun and a former Maryland Public Service Commissioner. “And it wasn’t found to be necessary in” ISO-NE, which proposed a two-hour requirement for storage participating in its capacity market. She touted her company’s Brightbox battery, which she said has helped manage California’s infamous duck curve by storing excess residential distributed solar and flattening load during the evening hours. “These resources can be aggregated and used very effectively … in places like PJM that has some high summer peaks at times.”

Acknowledging that PJM was an “outlier” among the RTOs/ISOs with regards to Order 841, Baker responded, “Simply put, our position has always been that dispatchable resources have a 10-hour requirement, and we operate a capacity market that has a single product today. … In order for resources to compete, to provide the same level of service in that market, there’s a single product that has a single set of requirements. … I would assume that if we were to have some sort of lesser-duration requirement for one resource type, we’d have to evaluate all resource types.”

Hoskins also lamented the stakeholder process in all RTOs, not just PJM. “All of these RTO processes are so complicated and time-consuming and expensive that you’re not going to hear these ideas,” she said. She advised PJM to “keep in mind that many competitive providers, they don’t have recovery from ratepayers for the costs that they spend on this, and this whole issue of governance with RTOs is really, really important right now so that you can actually get all these voices at the table and … have those in-depth conversations about 10 versus eight versus four versus what we can do.”

GOP Beginning to Shift on Climate Change

A second panel featured representatives of two D.C.-based think tanks — one from each side of the political spectrum — to explore the common ground Republicans and Democrats can find on clean energy policy.

Josh Freed, senior vice president for clean energy at the center-left Third Way, and Jeremy Harrell, managing director for policy at the conservative ClearPath, talked about each of their organizations’ preferred policies to reduce emissions and prevent the dreaded 2-degree Celsius increase in average global temperatures.

Freed said Third Way would like to see the federal government set clear emissions targets across all sectors for states and industry and then provide funding to help meet them. Harrell said ClearPath focuses on policies related to the power sector that would reduce the costs of building clean energy resources, such as carbon capture and energy storage, and increase R&D funding for the public and private sectors.

But they also expressed openness to other policies in service to the ultimate goal.

“We have our preferred approach at Third Way, but there are multiple approaches being debated right now that we’d be happy with,” Freed said. “We are skeptical that a carbon tax is a feasible pathway over the next four or five years, but if somehow magic happened and that was able to pass through Congress and get signed into law, great, we’d be thrilled.”

“In the end, both of our organizations want to see deep emission reductions,” Harrell said. “We want to see a clean American grid and ultimately a cleaner global electricity footprint.”

They also strongly agreed on the importance of advanced nuclear technologies.

Besides the implications for the climate, Freed said the U.S. has “a competitive and economic imperative to invest in” advanced nuclear. “There is [also] a safety and security imperative. Because on nuclear, if we don’t do it, the Russians and the Chinese will, and we don’t have faith that they will follow the same safety, security and proliferation protocols there.”

Harrell said ClearPath spends a third of its time each on nuclear, carbon capture, and renewables and storage. But “I would be lying to you if I didn’t say that, as an organization that works with Republican members of Congress, it’s easier to work with Republicans on advanced nuclear and carbon capture technologies. It just happens to have a significant climate imperative as well.”

And while they both agreed that there has been progress among the GOP in accepting the science of climate change, Freed said the Trump administration is the biggest obstacle, at least in the short term, to large-scale emissions reductions. He ticked off the list of environmental regulations the administration has rolled back, starting with the then-impending revocation of California’s authority to set auto emissions rules that are stricter than federal standards.

He lauded, however, the Department of Energy, “which has been fantastically able to continue on support of the innovation goals that we support and others support.” But “the broader, more comprehensive goals that we need to see set by the federal government that drive demand for clean energy … are being hacked away very quickly and aggressively.”

Harrell was more optimistic and did not directly dispute Freed’s criticism of the administration. But he did say a long-term challenge is the “piecemeal system in place across the country”: different state regulations, different wholesale market structures and different utility goals. “Our regulatory structures are not really well-suited to make those happen, and it’s tough to have a cohesive policy in place even if there was a political environment where we could do a major climate bill,” he said. “I think there will be some type of major federal legislation in the next decade or so, but how do we put forth a policy that makes sense in all these different segmented areas? It’s kind of the beauty and the struggle of federalism.”

– Michael Brooks