Grid Energy Storage: Policies

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1 Grid Energy Storage: Policies John Martin, P. Eng. Senior Tariff and Special Projects Advisor Alberta Electric System Operator (AESO) IEEE Northern Canada Section PES/IAS Chapter Seminar, 21 Nov 2017, Edmonton, Alberta

2 Topics Electric industry framework Existing policies applicable to energy storage Current activities to revise existing policies and develop new policies Please ask questions during slides! Public 2

3 Alberta s electricity regulations and policies do not specifically address energy storage Public 3

4 You re wondering where existing policies are sufficient and where more clarity is needed Public 4

5 The existing electric industry framework does provide some guidance Public 5

6 The existing framework is evolving to more directly address energy storage Public 6

7 Opportunities exist for you to participate in changes to address energy storage Public 7

8 Energy storage doesn t clearly fit within today s electric industry framework Public 8

9 The existing framework reflects a traditional electric system structure Public 9

10 In Alberta, the current electric industry structure was created in the late 1990s 1996 Wholesale competition Legislated hedges and unit obligation prices Transmission Administrator 2001 Retail competition Auction of power purchase arrangements 2004 Independent system operator Public 10

11 Today s structure reflects traditional electric industry functions Generation Transmission Distribution Retail $2.6 billion $2.1 billion $1.5 billion $0.4 billion Competitive Market Cost-of-Service Regulation Performance-Based Regulation Competitive Market Public Costs estimated for

12 A set of interrelated acts and regulations establish the industry structure Alberta Utilities Commission Act Fair, Efficient and Open Competition Regulation Hydro and Electric Energy Act Transmission Regulation Micro-Generation Regulation Electric Utilities Act Public 12

13 The two-directional flows associated with energy storage do not align with the one-directional flows underlying the electric industry structure Public 13

14 In a traditional electric industry structure, electricity flows from generators to loads Direct Connected Consumers Generators Transmission Facility Owners Distribution System Owners Distribution Connected Consumers Public 14

15 Money flows in the opposite direction, from loads to generators AESO Retailers Direct Connected Consumers Generators Transmission Facility Owners Distribution System Owners Distribution Connected Consumers Public 15

16 Energy storage doesn t clearly fit this onedirectional structure Public 16

17 Energy storage must comply with existing requirements even if applicability is unclear Public 17

18 Legislation sets general requirements, although not specifically for energy storage Hydro and Electric Energy Act requires approval of the Commission to construct and operate a power plant Battery storage facility was found to be a power plant in Commission Decision , Installation of a Battery System at ENMAX Place Electric Utilities Act establishes the AESO as the sole provider of system access service on the transmission system to exchange electric energy and ancillary services Public 18

19 Alberta Utilities Commission Rule 007 sets out requirements for facility applications AUC Rule 007 Applications for Power Plants, Substations, Transmission Lines, Industrial System Designations and Hydro Developments Public 19

20 AESO connection process sets out requirements for system access service Market participants must identify the requirements of their projects and assist the AESO in placing the projects into an appropriate project category Market participants must apply to the AESO to be registered as a pool participant for the provision of energy or ancillary services or for the purchase of energy Public 20

21 Limitations of policies are being addressed and new policies are being developed Public 21

22 Legislation can provide some policy guidance Public 22

23 A market participant is generally able to act freely on owned property Requirements for construction and operation of a power plant do not apply to a person generating or proposing to generate electric energy solely for the person s own use, unless the Commission otherwise directs. Hydro and Electric Energy Act, section 13(1) The Commission may designate the whole or any part of an electric system as an industrial system. Hydro and Electric Energy Act, section 4(1) Public 23

24 Regulated functions must be separated from competitive functions There would appear to be no barriers to deployment of energy storage facilities as a non-regulated generation asset that could provide energy and ancillary services. Legislative or policy changes may be required to clarify whether energy storage technologies would be regulated as transmission or distribution assets or be left unregulated and deployed in the competitive generation market. Alberta Smart Grid Inquiry, 31 Jan 2011, page 15 Public 24

25 Costs must be attributed in accordance with legislation and rate design principles The rates must reflect the prudent costs that are reasonably attributable to each class of system access service. Electric Utilities Act, section 30(2) Costs of the transmission system must be wholly charged to loads and exporters Transmission Regulation, section 47(a)(i) Rate design must satisfy principles of economic efficiency, equity, stability, and practicality Commission Decision , section 5 Public 25

26 ISO rules set out requirements for participation of energy storage in competitive energy and ancillary services markets Public 26

27 Technical and operating requirements apply to facilities connected to the transmission system Public 27

28 Market rules govern participation in the energy and ancillary services markets The AESO has a duty to facilitate the operation of markets for electric energy in a manner that is fair and open and that gives all market participants wishing to participate in those markets and to exchange electric energy a reasonable opportunity to do so. Electric Utilities Act, section 17(b) Rule amendments to facilitate the integration of energy storage facilities are in final stage of consultation Public 28

29 Rules governing participation in competitive markets continue to be reviewed for technology neutrality Defined term added in 2016 energy storage facility means a facility with technologies capable of storing and releasing electric energy References to generating unit and load in operating reserve rules are being replaced with technology-neutral definitions for resources Public 29

30 ISO tariff governs a connection to the transmission system for the exchange of energy and ancillary services Public 30

31 From an operating perspective, different facilities can have a similar Impact on the transmission system Generator Load (5) (10) Generator and Load Storage (5) (5) Public 31

32 Modelling suggests energy storage systems can withdraw from the transmission system to charge at any time 30% Percentage of Hours Discharging (Charging) at 95% of Rated Capacity 20% 10% 0% (10%) (20%) (30%) (40%) (50%) Hour of Day Frequency of Discharge at 95% of Rated Capacity Frequency of Charge at 95% of Rated Capacity Public 32

33 AESO comparability study found similarities between storage and load-generation sites Net Supply to (Withdrawal From) Transmission System (MW) (50) (100) Energy Storage (left axis) (150) Load-Generation Site (right axis) Day 0 Public 33

34 Industry participants can help with existing policy revision and new policy development Public 34

35 Participate in AESO tariff development Public 35

36 ISO tariff proceeding provides opportunity to examine rate treatment [C]ost causation supports the application of Rate DTS [Demand Transmission Service] to energy storage facilities, in hours in which the energy storage facilities are withdrawing electricity from the transmission system (charging). In hours in which the energy storage facilities are supplying electricity to the transmission system, Rate STS [Supply Transmission Service] would apply. Public 36

37 Many of the components of Rate DTS can be avoided or reduced through managed operation of an energy storage facility Average 20 MW Load-Only 100% Avoid System Peak 37% Own Your Substation 22% Contract for Both DTS and STS 21% Hold Charge to 10 MW 12% Connection Charge Ancillary Services Charges $0 $50,000 $100,000 $150,000 $200,000 $250,000 $300,000 $350,000 Monthly Rate DTS Charges Public 37

38 Energy storage projects in the connection process accelerate identification of issues Identify project Connection study scope Connection proposal NID and facility application Application filings and Commission approvals Construct and prepare to energize Energize, commission and close Public 38

39 Participate in AESO rule development Public 39

40 AESO is in final stage of amending operating reserve rules Section 205.3, Restatements for Operating Reserve Section 205.4, Regulating Reserve Technical Requirements and Performance Standards Section 205.5, Spinning Reserve Technical Requirements and Performance Standards Section 205.6, Supplemental Reserve Technical Requirements and Performance Standards Public 40

41 AESO has formal consultation process for rules and standard development AESO creates new ISO rules or amends existing ISO rules as needed To facilitate the safe, reliable and economic operation of the Alberta Interconnected Electric System To promote a fair, efficient and openly competitive wholesale market for electricity in Alberta Rules consultation process will be inclusive, transparent, fair and efficient and will be understood and accepted by all parties Public 41

42 Opportunities also exist to engage in consultation on capacity market development and other market initiatives Public 42

43 Continue to explore and advocate for integration of energy storage in the Alberta context Public 43

44 Energy storage may deliver stacked value but must be within legislated boundaries Market Benefit System Benefit Provider Benefit Energy Market Price Ancillary Services Market Price Renewable Generation Integration Generation Infrastructure Wires Infrastructure Adapted from State of Charge: Massachusetts Energy Storage Initiative Study (Sep 2016) Capacity Market Price Cost of Storage Revenue to Storage Provider Public 44

45 Declining costs suggest storage will become more economically feasible Decline From Previous Year, % 0% -5% -10% -15% -20% -25% -30% -35% Adapted from Large-Scale Energy Storage Systems report by GTM Research (Oct 2017) Storage Battery Balance of Storage System Public 45

46 Some studies suggest optimal storage capacity is 10% of system load 10% 1,200 MW in Alberta Hossein Safaeia and David W. Keith, How much bulk energy storage is needed to decarbonize electricity?, Energy & Environmental Science (Sep 2015) Mark Z. Jacobsen, et al., Low-cost solution to the grid reliability problem with 100% penetration of intermittent wind, water, and solar for all purposes, Proceedings of the National Academy of Sciences (Dec 2015) Public 46

47 The existing electric industry framework does provide some guidance Public 47

48 The existing framework is evolving to more directly address energy storage Public 48

49 Opportunities exist for you to participate in changes to address energy storage Public 49

50 Thank you John Martin

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