June 3, 2021
ESA Asks Washington Regulators to Value Storage Flexibility, Avoid Onerous Accounting
ESA submitted comments to the Washington Utilities and Transportation Commission (“UTC”) on 6/2 in response to the Commission’s Notice seeking input on the treatment of energy storage for compliance with the recently-passed Clean Energy Transformation Act (“CETA”). The Commission’s notice proposed that energy storage facilities be treated as a generating resource that retires renewable energy credits (RECs) upon charging and creates them upon discharge. In our comments, ESA emphasized that energy storage is not a source of energy and therefore accounting for storage charging energy inputs is inappropriate for compliance with CETA requirements. Instead, ESA suggested that the Commission consider other measures to ensure that energy storage is valued for the flexibility that it provides to support the clean energy transition mandated by CETA through measures such as integrated resource planning reforms, compensation programs for customer-sited energy storage, an energy storage procurement target, and/or an exploration of new mechanisms to value and compensate resource flexibility.