Comments of the ESA re: IUB Docket No. NOI-2014-001

Posted: February 24, 2014 - 19:47 / Iowa Utilities Board / ESA Filings

Pursuant to the Notice of Inquiry on Distributed Generation in the above-referenced Docket by The State of Iowa Department of Commerce Utilities Board (“Board”), the Energy Storage Association (“ESA”) appreciates the opportunity to submit the following comments and information for the Board’s consideration.

ESA believes that energy storage technologies and applications enable all generation sources on the grid to operate more efficiently, flexibly, and resiliently; facilitate integration of renewable energy resources on the grid; reduce greenhouse gas emissions; and lower costs for consumers. Energy storage resources are currently operating on the nation’s grid and are used in a variety of applications to balance generation and load in an efficient and cost-effective manner. Energy storage technologies are ideally suited to assist with grid resiliency and increased reliability.

ESA asserts that, as the Board considers distributed generation policy, energy storage technologies and applications should be included in the “menu” of resources. Energy storage can provide generation services as well as benefits on the transmission and distribution (T&D) system. By establishing an approved budget and framework for procuring new technologies such as energy storage, state regulatory models could provide utilities the regulatory certainty they need to invest in energy storage technologies and reap the full value of those benefits. We also believe states should consider policies that benefit consumers and end users of distributed energy storage technologies.

ESA recommends five main policies for the Board to consider in developing distributed generation policies that include energy storage.

  1. Establish policies for multi-purpose energy storage uses.
  2. Allow utilities to contract with third-party energy storage developers.
  3. Provide utilities with flexibility to procure energy storage through demonstration programs.
  4. Implement time-of-use rate structures.
  5. Develop energy settlement rules for energy storage projects connected at distribution.

ESA appreciates the opportunity to offer recommendations in this inquiry and looks forward to continuing to work with the Board and its stakeholders by offering additionalcomments or testifying before the Board as distributed generation policy is considered in the State of Iowa.

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