ISO – Global Power Law & Policy

What to Know About ISO/RTO Annual Certification Requirements

Nov 30 2023

By: Ruta Skučas, Stephanie Staska (Director of Trade and Risk Products at Yes Energy), and Chimera Thompson

Explore an overview of the annual certification requirements in each of the organized wholesale electricity markets operated by the independent system operators and regional transmission organizations (ISO/RTOs) in the United States. Each year, market participants must certify ongoing compliance through an officer’s certification stating that they meet requirements to participate in the market.

Reactive Power Compensation for Renewable Energy Facilities: Opportunity Amidst Change

Jan 23 2023

By: Ruta Skučas, Maria Faconti, and Kimberly Frank

Originally published in the Oil, Gas & Energy Resources Law Section Report – Volume 47, Number 1 / January 2023.

Reactive power provides synchronous and non-synchronous generators, as well as other forms of non-generation resources capable of providing reactive power, with a potential additional revenue stream. The provision of voltage support to the grid is an ancillary service, compensated in various ways in the various wholesale electricity markets. Renewable developers should familiarize themselves with the opportunities provided by reactive power compensation, even as some of the compensation models may be shifting.

The Energizer – Volume 90

Jun 03 2021

By: Buck B. Endemann, Daniel S. Cohen, Molly K. Barker, Natalie J. Reid, Matthew P. Clark, Nathan C. Howe, Maeve C. Tibbetts, Oretha A. Manu

There is a lot of buzz around clean technology, distributed energy resources (DERs), microgrids, and other technological innovations in renewable energy and clean transport industries, and how these developments can contribute to solving longstanding environmental justice issues. As these innovations develop, energy markets will undergo substantial changes to which consumers and industry participants alike will need to adapt and leverage. Every other week, K&L Gates’ The Energizer will highlight emerging issues or stories relating to the use of DERs, energy storage, emerging technologies, hydrogen, and other innovations driving the energy industry forward.

IN THIS ISSUE:

Twinning Nuclear Reactors with Machine Learning
FERC Invites Post-Technical Conference Comments on RTO/ISO Credit Practices
University of Illinois Will Soon Complete Final Phase of Solar Farm 2.0 Project
Spain Passes Carbon Neutrality Legislation that Bans Fossil Fuel Vehicles from Circulation within Nation’s Borders by 2050

READ VOLUME 90

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FERC Issues Landmark Order No. 2222 To Facilitate the Participation of Distributed Energy Resources in Wholesale Markets

Sep 23 2020

Authors: Buck Endemann, Kimberly Frank, Elias Hinckley, and Patrick Metz

In a landmark order issued on September 17, 2020, the Federal Energy Regulatory Commission (FERC) adopted rules aimed at removing barriers to the participation of distributed energy resources (DERs) in the organized markets for electric energy, capacity, and ancillary services operated by Regional Transmission Organizations and Independent System Operators (RTOs). Order No. 2222 builds on reforms previously undertaken by FERC and, once fully implemented, should be a major step toward opening up RTO markets to competition, facilitating new entry of resources, and fostering business model innovation.

Order No. 2222 envisions “aggregations,” which are groups of small DERs participating in the RTO markets as a single resource represented by their aggregators. According to FERC, these aggregations will permit DERs to provide a variety of products and services that will compete with more conventional resources in the RTO markets. FERC expects that this will, in turn, ensure that rates remain just and reasonable.

FERC Announces Conferences on Carbon Pricing and Offshore Wind in RTOs/ISOs

Jun 18 2020

By: William Keyser, David Hattery, Buck Endemann, and Abraham Johns

On June 18, 2020, the Federal Energy Regulatory Commission (“FERC”) announced that it will hold two separate technical conferences later this year. First, FERC will hold a Commissioner-led technical conference on September 30, 2020 to discuss issues related to carbon dioxide emission pricing (i.e., “carbon pricing”) as adopted by states in FERC-jurisdictional wholesale electricity markets (“Carbon Pricing in Organized Wholesale Electricity Markets”). Second, FERC staff will hold a technical conference on October 27, 2020 to discuss whether existing frameworks for transmission, interconnection, and merchant transmission facilities can incorporate the growing offshore wind generation efficiently and effectively (“Offshore Wind Integration in RTOs/ISOs”).

Making Room for Electric Storage: RTOs/ISOs Propose Changes to Their Market Rules to Comply with FERC Order 841

Dec 04 2018

By Abraham F. Johns, William M. Keyser, and Toks A. Arowojolu

On December 3, 2018, the Regional Transmission Organizations (RTOs) and Independent System Operators (ISOs) filed proposed market rule changes to provide energy storage resources with greater opportunities to participate in the wholesale markets as required by Federal Energy Regulatory Commission (FERC) Order No. 841. These widely anticipated FERC filings will likely provide the framework for how energy storage resources will be developed and used in the coming years.

In February 2018, FERC released Order No. 841, which requires each regional grid operator to revise its tariff to establish a participation model that allows energy storage resources to participate in the organized wholesale markets and sell the relevant products offered by each market. K&L Gates covered the details of this Order in a blog post and in the Energy Storage Handbook.

FERC set a deadline for each RTO/ISO to submit a compliance filing including tariff revisions by December 3, 2018. We have provided links to the compliance filings for each RTO/ISO below. The deadline for public comments on the filings is December 24, 2018 by 5 p.m. Each RTO/ISO has until December 3, 2019 to implement the changes. Considering the holiday season, some commenters may request an extension on this comment deadline. We will continue to monitor the development of these proceedings.

Midcontinent Independent System Operator (MISO) ER19-465-000
Independent System Operator New England (ISO-NE) ER19-470-000
New York Independent System Operator (NYISO) ER19-467-000
PJM Interconnection (PJM) ER19-469-000
California Independent System Operator (CAISO) ER19-468-000
Southwest Power Pool (SPP) ER19-460-000

FERC Rule Seeks to Expand Energy Storage Participation in Wholesale Electricity Markets

Feb 16 2018

By William Keyser, Buck Endemann, Mike O’Neill and Jim Wrathall

On February 15, 2018 the Federal Energy Regulatory Commission (“FERC”) issued a Final Rule addressing participation of energy storage resources in electricity markets operated by Regional Transmission Organizations (“RTOs”) and Independent System Operators (“ISOs”). Largely adopting the proposal issued in November 2016, the Final Rule seeks to remove barriers for energy storage participation in wholesale capacity, energy, and ancillary services markets. The ultimate impact of FERC’s directive will be determined over the next few years as RTOs and ISOs implement the standards through their respective stakeholder processes, compliance filings, and (potentially) litigation. FERC deferred ruling on a companion proposal addressing participation of distributed energy resources (“DERs”) in wholesale markets. In the coming months, stakeholders should carefully consider these measures as there will continue to be opportunities to shape the final outcomes. Read More

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