December 19, 2018

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December 17, 2018

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

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.

Copyright 2018 K & L Gates

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About this Author

Abraham Johns, KL Gates Law Firm, Washington DC, Environmental and Energy Law Attorney
Associate

Abraham Johns is an associate at the firm’s Washington, D.C. office. He is a member of the oil & gas practice group.

*Admission is pending in Washington, D.C. / Supervised by David Wochner

202-778-9430
William Keyser, KL Gates Law Firm, Energy Law Attorney
Partner

William Keyser, a partner in Washington, D.C., focuses his practice on regulatory litigation and transactions involving the nation’s electricity and capacity markets. Will represents clients before the Federal Energy Regulatory Commission (FERC), the Department of Energy, federal and state courts and state public utility commissions. His clients include electric utilities, transmission providers, independent power providers, hydro electric power producers, power marketers, public utility holding companies, and debt and equity investors. Will has represented and counseled clients on matters including mergers and acquisitions, transmission rates and cost allocation, interconnection procedures and agreements, market-based and cost-based sales of energy, renewable portfolio standards, interlock issues, FERC’s e-Tariff requirements, and participation in regional transmission organizations.

202-661-3863
Toks A. Arowojolu, KL Gates Law Firm, Washington DC, Environmental and Energy Law Attorney
Associate

Toks Arowojolu is an associate in the Washington, D.C. office where she is a member of the oil & gas and power practice groups. She focuses her practice on energy regulatory law and assists clients with navigating the FERC process. She also conducts regulatory due diligence for clients exploring M&A opportunities.

*Admitted only in Maryland / Not Admitted in D.C.
Supervised by David Wochner, member of the D.C. Bar

202-778-9016