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Regulatory Developments and Impacts Involving Electricity Storage in Texas Elizabeth Drews 31st USAEE/IAEE North American Conference Austin TX, November 4-7, 2012
The usual disclaimers • This is not legal advice or legal services • This is no one’s opinion but mine, & might not stay mine • This is a summary • Laws & facts change
Why storage could especially benefit ERCOT • ERCOT’s • Electrical isolation from other grids • > 11,000 MW wind (# 1 in US, # 6 in world, > 2,000 MW coastal) 12,277 MW by 2014 • Growing demand • Potential capacity shortfalls • Nodal market design 3
Where would storage fit in ERCOT?Capacity, Demand, Reserves Report (May 2012)
Generation under study in ERCOT * Peak demand 68,379 MW Wind record 8,368 MW (17.64% of 47,452 MW load) of which 7,381 non-coastal * No firm commitment to build + Calculated at 8.7% of nameplate capacity
Some IPP storage development in Texas Source: filings in Public Utility Commission of Texas (PUCT) Projects 39764, 39917, 41026
Some uses of electricity storage • Energy time-shift • Peak shave • Ancillary services • Reliable power in outage • Address voltage, frequency variations • Transmission support • ↓ transmission congestion • Defer T&D upgrades 7 Adapted from PUCT 2011 Scope of Competition Report
Generalized attributes of storage technologies Must be near cavern or similar, TX has Attributes/capabilities vary by project & technologies are evolving 8
Regulatory limits on uses of ERCOT storage • In non-retail choice areas, utility, coop, muni can own G&T • Can own storage that serves both functions • In retail choice areas, utility owns T&D, power generation company owns generation • Protects competition • Keeps storage from supplying & being paid for all its uses 9
Storage as transmission • PUCT Docket 35994, ETT • Transmission/distribution utility owns 4 MW battery to help voltage & delay transmission in remote area, does not own or sell energy from the battery • PUC: transmission asset, can put in rate base • Operational since 2010 10
Storage as generation • 2011 statute (SB 943) – Texas storage: • Intended to sell energy or ancillary services at wholesale is generation • May interconnect, obtain transmission service, sell electric energy & ancillary services at wholesale consistent w/ TX law re: power generation company or EWG • Must register as power • generation company 11
PUCT pricing rule on storage(2012, Project 39917) 3 main decisions • Electricity purchases by storage for charging are wholesale, not retail (same as FERC) • Such electricity purchases are settlednodally (at bus that connects the storage facility), not zonally like a load • Retail transmission&ancillary service charges do not apply to such electricity purchases 12
ERCOT rule changes, integration issues • ERCOT’s Emerging Technologies Working Group • IDs & proposes changes to ERCOT requirements that preclude market participation of emerging technologies • Has addressed # issues relating to storage • Is developing a list of operations issues relating to storage 13
PUCT ERCOT pilot project rule(2012, Project 40150) • Allows ERCOT pilot projects for storage/other ET • ERCOT may temporarily exempt pilot participants from specific ERCOT requirements • ERCOT board must approve pilot project; board decision appealable to PUCT • Rule leaves many issues, e.g. cost allocation & post-pilot transition if any, to ERCOT pilot review process to resolve 14
Pilot projects at ERCOT • ERCOT posts documents for each pilot project on its website • ERCOT has been working on a pilot project for a Fast Responding Regulation Service (similar to FERC Order 755, “pay for performance”) 15