FERC to Convene Technical Conference on Generation Resources Paired with Energy Storage

By William H. Holmes, William M. Keyser, Michael L. O’Neill

On April 7, 2020, the Federal Energy Regulatory Commission (“FERC”) announced that its staff will host a technical conference in July 2020 to discuss so-called “hybrid resources.”  In its notice, FERC explained that it is using the term “hybrid resources” to refer to projects that are comprised of more than one resource type at the same plant location.  For this summer’s technical conversation, FERC states that it will focus on scenarios where a “generation resource and an electric storage resource [are] paired together as a hybrid resource.”

FERC’s interest in this topic does not appear out of nowhere.  FERC has been focused on facilitating emerging technologies and the integration of new technologies into the grid and the wholesale markets, as evidenced by recent orders such as FERC Order No. 841 (concerning participation by energy storage resources in U.S. wholesale power markets).  In response to filings by the California Independent System Operator’s and PJM Interconnection for compliance with FERC Order No. 841, FERC received comments from the Energy Storage Association (“ESA”) and others raising the possibility of hybrid resources that would include energy storage.[1]  ESA highlighted the hybrid resource issue and requested that FERC convene a separate proceeding or technical conference to consider the matter.  Although FERC determined that ESA’s suggestion for a separate review of hybrid resources was beyond the scope of those Order No. 841 compliance proceedings,[2] it is convening this technical conference to learn more about the issue.

FERC’s technical conferences are not adjudicatory proceedings and will not create immediate obligations for FERC-regulated parties or projects.  But technical conferences provide an opportunity for industry experts to educate FERC commissioners and staff on emerging trends in the industry.  Because this generation plus storage topic is receiving more and more attention among energy industry participants (and indeed was the topic of a panel discussion at K&L Gates’ third annual Energy Storage Conference in November 2019), it is a timely topic.

The technical conference is scheduled for July 23, 2020.  Depending on FERC’s operating status in light of the COVID-19 pandemic, FERC will host the conference either in person in Washington, DC, or via teleconference.  FERC requests self-nominations for speakers by May 15, 2020.  Interested parties will want to monitor this discussion as it evolves at FERC and may want to nominate speakers to participate in the conference to ensure that FERC receives their views as the Commission refines its approach to hybrid resources.

[1] See, e.g., Cal. Independent System Operator Corp., FERC Docket No. ER19-468-000, Comments of the Energy Storage Ass’n at 4-5 (Feb. 7, 2019).  See also PJM Interconnection, L.L.C., FERC Docket No. ER19-469-000, Protest and Comments of the Energy Storage Ass’n at 16 (Feb. 7, 2019).

[2] Cal. Independent System Operator Corp., 169 FERC ¶ 61,126 at P 33 (Nov. 21, 2019); PJM Interconnection, L.L.C., 169 FERC ¶ 61,049 at P 39 (Oct. 17, 2019).

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