Charging Ahead; An Energy Storage Guide For Policymakers
Sky Stanfield1 Joseph “Seph” Petta, and Sara Baldwin Auck, April 2017 (Interstate Renewable Energy Council)
Energy storage technologies—capable of capturing usable energy for use at another time, particularly when it is needed most and/ or more valuable—provide flexible solutions to serve energy needs and address existing and emerging challenges. Energy storage technologies also provide an array of grid services and can offer multiple services interchangeably. Integrating energy storage strategically across the electricity system can result in more efficient utilization of other grid resources, defer more costly upgrades or investments, and increase the range of operational possibilities for the electric system.
The very characteristics that make energy storage valuable and attractive also make it challenging to address in policy and regulatory contexts. Despite the game-changing potential of energy storage to transform the electricity system, energy storage is vastly underutilized in the United States’ electricity sector. Its deployment remains hampered by the current features of regional, state and federal regulatory frameworks, traditional utility planning and decision-making paradigms, electricity markets, and aspects of the technology itself.
The Interstate Renewable Energy Council's (IREC) Charging Ahead: An Energy Storage Guide for State Policymakers is intended to provide state policymakers and regulators with systematic, foundational information on advanced energy storage—a new generation of technologies characterized by flexible operating capabilities and diverse applications—as well as more specific guidance on key issues for consideration in the policymaking context. Advanced energy storage technologies have matured rapidly in recent years and installations are quickly gaining momentum in states across the country. While beyond the scope of this guide, there are untapped opportunities to expand the role and function of traditional forms of storage, particularly cost-effective thermal storage for demand management and integration of high penetrations of renewable energy on the grid (see Additional Resources for more information). While differences exist among the available storage forms and technologies, policy and regulatory solutions designed to address energy storage barriers more holistically, with a technology neutral framework, will help set a glide path for all energy storage technologies.
Deploying energy storage at scale and optimizing its benefits will require innovative and forward-thinking policies (and the political and societal will) to integrate it into existing electric system operations and state regulatory frameworks. To date, state policymakers and electric system stakeholders have navigated energy storage issues without the benefit of a roadmap of key regulatory and policy pathways to support the economic deployment of energy storage. With more storage being deployed and leading states gaining more experience, foundational policy actions and informative lessons learned are emerging. The foundational actions and solutions presented at the end of the guide reflect the reality that certain issues have more clearly defined paths to address identified barriers, while others are still under development and/or ripe for further policy innovation.
State leadership and innovation on landmark energy policy issues, including energy storage and its more robust integration on the grid, will help expedite and optimize the electricity sector transformation already underway. By proactively integrating energy storage technologies into today’s policy and regulatory decisions, states can lead the charge to enhance the cost-effectiveness, reliability, quality and functionality of the energy sector. The intent with this guide is to provide an array of possible actions and pathways for further exploration, but more work remains to develop a more comprehensive road map for energy storage in the United States. IREC hopes this guide will serve as a valuable navigational tool and can serve all states well on their energy storage journey.
About The Guide
The guide is organized into six sections, plus supplementary sections for additional resources and appendices. Each section concludes with a summary of key takeaways for state policymakers, which are provided below for quick reference:
• Section I. Introduction provides context for the guide and opportunity for policy leadership on energy storage.
• Section II. The Current State of Advanced Energy Storage provides a brief overview of advanced energy storage technologies, their performance characteristics, applications and their services.
• Section III. How States Can Approach Assessing the Cost and Value of Storage provides an overview of the economics of energy storage, offers a snapshot of existing tools to assess energy storage costs and benefits, and provides additional insights on evaluating the value of storage.
• Section IV. State Regulatory Approaches to Energy Storage provides illustrative examples of state policy and regulatory actions occurring in four identified stage(s) of storage actions (Investigate, Clarify, Energize, Plan), as well as key insights from state efforts.
• Section V. Foundational State Policy Actions to Address Primary Energy Storage Barriers discusses the state policy and regulatory barriers that limit or impair storage deployment and provides some recommended foundational policy actions to help states begin to overcome those barriers. This discussion of barriers and foundational policies is not exhaustive, but rather, reflects the most commonly identified barriers and thus the actions likely to have the broadest impact on the energy storage market. Similarly, market rules established by ISOs and RTOs are not covered in this guide, although they are equally critical to the successful deployment of energy storage. At a high level, the guide recommends the following foundational actions to advance energy storage:
Classification & Ownership
Clarify How Energy Storage Systems are Classified to Enable Shared Ownership and Operation Functions in Restructured Markets. In restructured markets, state policymakers and regulators may need to reconsider the current limitations on asset ownership that may prevent “wires-only” utilities from cost-effectively owning storage as assets and, thus, from being able to recover costs through rates. Any approaches seeking to address this issue will likely require the implementation of appropriate regulatory safeguards to protect the competitiveness of energy markets, while still ensuring that the grid and ratepayers can benefit from advanced energy storage technologies.
Require Proactive Consideration of Energy Storage in Utility Planning Efforts. States should consider requiring utilities to evaluate energy storage side-by-side with those of traditional wires and resource solutions as a part of integrated resource and distribution planning efforts. State policymakers and regulators will need to be specific about how they want energy storage to be evaluated and modeled (including requiring the use of up-to-date, accurate cost and performance data) in these proceedings if they want to see the most useful and effective results. These proceedings can produce new tools that enable grid transparency that can help identify locations where storage can offer the greatest benefits to customers and the grid.
Ensure Fair, Streamlined, and Cost Effective Grid Access for Energy Storage Systems. Energy storage customers, like all customers seeking to connect to the grid, need a process that is transparent, non-discriminatory, timely and cost effective just like any other type of generator. While storage systems can be reviewed using the basic framework of traditional state jurisdictional interconnection procedures, certain modifications could be made to more effectively and efficiently review their impacts on the electric system.
Create Mechanisms to Capture the Full Value Stream of Storage Services. States can consider adopting or modifying mechanisms to help create markets for energy storage and capture the full value stream of energy storage services, namely through monetizing the benefits.
• The Conclusion offers some brief insights on outstanding policy issues and opportunities ripe for further investigation.
• The Additional Resources section provides a list of other valuable sources for storage information. Appendix A provide a deeper dive on energy storage applications and services, and Appendix B contains an overview of existing modeling tools for energy storage valuation.
Charting A Course For Energy Storage
With this navigational tool and resource guide in hand, state policymakers and regulators should begin to chart a course to address energy storage in their respective markets. The starting point for each state will necessarily be different, based on where you are and what your goal is. While a step-by-step action plan is outside the scope of the guide, the key takeaways and insights offered in Charging Ahead should help more states establish a robust framework to charge ahead on energy storage.
Beyond taking proactive steps on storage, continued policy leadership will ensure identified challenges are met with innovative, yet practical solutions that set the stage for market growth. Indeed, the policy and regulatory frameworks are the foundation upon which future growth will be built. Peer-to-peer sharing among states and leveraging the wealth of information gleaned to date from pilot projects and active programs will ensure replication of successful approaches can occur more swiftly.