Comments of the ESA re: IUB Docket No. NOI-2014-001 on Distributed Generation, Net Metering and Interconnection

Posted: June 23, 2014 - 09:00 / 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 additional comments and information for the Board’s consideration. 

The ESA believes that energy policies should incentivize diversification of energy sources, including alternative energy and innovative technologies. Utility as well as third-party ownership models for energy storage deployment should be considered as viable; preferring one particular construct over another can limit access to markets and restrict innovation.

For utility projects, energy storage should be included in prudency reviews of rate filings as well as in the utility planning process. As Iowa utilities develop annual reports  detailing their planning process to meet future load requirements, energy storage technologies and applications should be on the “menu” of options that can meet system needs.  With any planning exercise, non-wires alternatives like energy storage should be explicitly included, assessed, and compared to traditional generation resources. These analyses, modeling tools, and evaluation processes should be transparent and include the full scope of benefits and all value streams that energy storage can provide. 

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 additional comments or testifying before the Board as distributed generation policy is considered in the State of Iowa.

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