October 12, 2021

ESA & ACP Jointly Recommend FERC Reduce Storage Interconnection Costs, Include Storage in Transmission Planning

ESA and the American Clean Power Association (ACP) jointly submitted comments to FERC in response to the aNOPR (RM21-17-000) on transmission planning, cost allocation, and generator interconnection, including recommendations on storage. Our overarching recommendations ask FERC to (1) reform certain aspects of generator interconnection procedures that are demonstrably unjust and unreasonable; and (2) shift transmission planning and cost allocation to a holistic and proactive process that simultaneously addresses key drivers, including – but not limited to – economic, reliability, public policy, and future generation needs.
In our joint comments, we make two storage-specific recommendations. First, we ask FERC to require interconnection studies of energy storage to be based on anticipated use, since current study assumptions for energy storage are often inconsistent with real-world operation. Second, we ask FERC to include energy storage in transmission planning by requiring ISO/RTOs and transmission owners in all balancing authorities to evaluate energy storage as a transmission solution under certain criteria; require transmission planners to consider a wider range of benefits of energy storage in cost/benefit analysis; update energy storage modeling to accurately reflect these resources’ capabilities and operations; and make transmission facility utilization data more accessible to enable optimal planning of storage solutions.
Additionally, we recommend moving away from the paradigm of participant funding in RTOs/ISOs, whereby generators are required to fully pay network upgrades to the transmission system. This is a practice that applies to all supply resources, including energy storage. We propose to modify FERC’s Order No. 2003 crediting policy to require that interconnecting generators be credited back the costs of all network upgrades located beyond the interconnection substation, which would significantly reduce interconnection cost burdens for interconnecting resources.

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