Brian Orion and Sarah Kozal: 5 Key Takeaways from FERC’s Recent Energy Storage Order

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Energy attorneys Brian Orion and Sarah Kozal contributed an article to POWER magazine titled “5 Key Takeaways from FERC’s Recent Energy Storage Order,” published June 1, 2018. The article discusses FERC’s Order 841, which was issued in February and requires RTOs and ISOs to establish new market participation rules for energy storage that recognize the physical and operational characteristics of those resources.

FERC has delayed implementation of the order to address questions raised by several ISOs and RTOs. In the article Orion and Kozal provide an overview of key points of the order as it stands as of this date, which include:

  • New Revenue Opportunities for Storage.
  • Market Access Does Not Always Lead to More Storage Projects.
  • The ISOs/RTOs Are Generally Supportive of the Order, But Have Sought Further Guidance.
  • Compliance Filings Are Due in December, But Expect Some Delays.
  • Individual ISO/RTO Stakeholder Processes Will Be More Important to Track.

The authors conclude: “As the Order stands now, we can expect compliance filings on December 3 of this year with implementation due 365 days after that. FERC’s tolling order provides for additional time for consideration of motions for clarification and requests for rehearing, and thus the 30-day timeframe in which FERC has to respond has been extended without deadline. In the meantime, storage companies and policy makers will continue to digest the new Order and plan for what comes next.”

“5 Key Takeaways from FERC’s Recent Energy Storage Order” was adapted from a post on Stoel Rives’ Renewables + Law® blog.

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Sarah E. Kozal
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