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FERC Approves ISO-NE Market Design Changes for Battery Storage Resources

On Monday, February 25, 2019, the Federal Energy Regulatory Commission (FERC) approved tariff changes to the ISO-New England, Inc.’s (ISO-NE) Transmission, Markets, and Services Tariff (Tariff) designed to better enable battery storage resources’ full participation in ISO-NE’s markets effective April 1, 2019.

ISO-NE’s tariff revisions account for the physical and operational differences between a battery storage resource (Continuous Storage Facility) and pumped-storage hydroelectric facilities, and will allow owners or developers of battery storage facilities to:

  • Avoid the commitment process, where the resource is capable of transitioning between energy consumption and generation in ten minutes or less

  • Better manage the risk of clearing more MWhs in the day-ahead market than its energy storage capacity would allow it to deliver

  • Provide regulation while consuming or supplying energy and providing reserves

  • Request a self-dispatch 30 minutes prior to providing service

FERC’s order also ensures that Continuous Storage Facilities will be subject to telemetry and settlement calculation requirements as set forth in the Tariff, and implements steps for calculating real-time reserves for a battery storage facility reflecting the fact that such resources may consist of multiple inverters, thus better enabling ISO-NE to determine the synchronized capability of the resources to provide spinning reserves.

©2020 Pierce Atwood LLP. All rights reserved.National Law Review, Volume IX, Number 58


About this Author

Andrew Kaplan Energy Attorney

Andrew Kaplan focuses his practice on providers of energy storage, demand response, ancillary services, and electricity and gas transmission and supply, both in the wholesale and retail markets. He regularly represents clients before the Federal Energy Regulatory Commission (FERC) and Independent System Operators/Regional Transmission Operators (NYISO, ISO-NE, PJM, Midcontinent ISO, California ISO, SPP and ERCOT), and many state public utility commissions. Andrew has won significant rulings before FERC that helped to pave the way for growth among leaders in the energy storage industry....

Liam J. Paskvan, litigation lawyer, Pierce Atwood

Liam is an energy and energy infrastructure attorney focusing on both litigation and transactional matters. He represents solar farm developers and on- and offshore wind developers, electric and natural gas local distribution companies (LDCs), crude oil shippers, energy market financial traders, telecommunications providers, and others before state public utilities commissions throughout New England and the Federal Energy Regulatory Commission (FERC). He also represents clients in a variety of other settings, including in regional and state-sponsored requests for proposals (RFPs) for renewable energy and associated transmission infrastructure, compliance and enforcement matters, and open seasons. 

Liam has a deep understanding of state renewable energy law and policy, including Massachusetts’s SMART Program, as well as New England’s wholesale energy market, administered by ISO-NE.  He works diligently to understand client objectives and to implement sound legal strategies that best achieve client goals. 

Liam is dedicated to providing pro bono legal services, and works on a variety of matters, including representing individuals in proceedings before the U.S. Citizenship and Immigration Services. In 2017, Liam was recognized by the Katahdin Counsel Recognition Program for his commitment to community service. 

(207) 791-1306
Lisa Gilbreath, Pierce Atwood, Environmental lawyer

Lisa Gilbreath is an associate in the Environmental & Land Use and Energy Infrastructure Development, Acquisition & Financing practice groups. Lisa works on a wide variety of environmental and energy matters, offering clients strategic advice in regulatory, legislative, and judicial proceedings.

In her environmental practice, Lisa assists clients with numerous issues including energy project development permitting, energy and environmental litigation, air quality legislative and regulatory activities, air quality enforcement, hazardous substances and...

(207) 791-1397