Some Rules Needed for Storage, DER

By Denise R. Foster, vice president, State and Member Services

PJM expects electric storage and distributed energy resources to continue growing on the grid, both in their role in keeping the system reliable and in providing new options for wholesale and retail consumers. However, managing this growth and integration into the grid requires some clear rules of the road to be established by the Federal Energy Regulatory Commission.

PJM has filed comments largely supportive of the FERC’s Notice of Public Rulemaking on electric storage participation in wholesale markets. FERC is seeking to address the growing integration and treatment of electric storage, such as batteries and distributed energy resources.  PJM believes the current framework in PJM’s market rules for demand response participation can be leveraged to advance DER participation.

However, in determining its final rule, PJM is asking the commission to consider PJM’s successful current practices integrating front-of-the-meter resources into the wholesale market while providing additional clarification on injections of power into the grid from behind-the-meter resources.

PJM asserts that the final rule should define when storage or DER is a retail/state jurisdiction transaction or a wholesale/federal jurisdiction transaction or if and when it can alternate between the two.

Electric storage and distributed energy resources already have flourished in a number of PJM markets, such as capacity, energy and ancillary services.  Our markets have had more than 1,100 megawatts of demand response capability supported by batteries, reciprocating engines, combustion turbines and other technologies at the customer site.  In addition, there are more than 100 generators and electric storage resources totaling over 700 MW, participating in the PJM wholesale market connected to distribution systems across 10 states.

Currently, PJM is working through the stakeholder process to expand market rules to allow for additional opportunities for electric storage and distributed energy resources.

Moving forward, we believe the FERC should allow regional grid operators to require metering, telemetry and other necessary requirements for behind-the-meter DERs that seek to inject power to be utilized in the wholesale market.  These requirements should be consistent with those for front-of the-meter generation resources of comparable size and similar operational characteristics.

Additionally, we ask that FERC establish criteria for information sharing between the grid organizations and electric distribution companies to ensure greater visibility into DERs that are not within the commission’s jurisdiction. By doing so, it would best support reliable bulk system operations as an increasing number of behind-the-meter DERs are installed.

PJM also thinks FERC’s rule should offer flexibility on any requirements needed to ensure that battery resources are optimally charged and discharged during the operating day.

PJM recognizes the complexity of sorting through all of the aspects of electricity storage and DER participation into wholesale markets. This is a wide open frontier that will require structure, however, not without regarding the inroads already made in the marketplace.