Center for Renewables Integration Welcomes Rao Konidena as New Board President

Center for Renewables Integration (CRI) is excited to welcome a new Board President as of January 2024, Rao Konidena. Rao, who has been a valuable partner with CRI since 2018, brings a wealth of experience and a fresh perspective to the role. Kerinia Cusick, the former Board President, has transitioned to the position of Board Vice President, where she will continue to contribute her expertise and leadership to CRI.

Kerinia recruited Rao to lead CRI and was excited he accepted the challenge. “It has been a delight building CRI from a concept to an organization that is working at the leading edge of clean energy policy, and a privilege to partner with some of the leading companies and experts in the industry on specific projects,” said Kerinia.

Rao leverages his experience working for 15 years at Midcontinent Independent System Operator (MISO) for clients. Before he left MISO, he was the Principal Advisor for Policy Studies, working on energy storage and distributed energy resources. At MISO, Rao worked in management and non-management roles focused on issues of resource adequacy, economic planning, business management and policy functions.

With CRI, Rao has collaborated with other specialists on several projects. This includes helping the world’s largest buyer of renewable energy investigate solutions to mitigate interconnection delays in PJM, working in every ISO on the development of new rules to allow distributed energy resources to participate in ISO/RTO markets, and providing expert testimony on the use Grid Enhancing Technologies (GETs) and Non-Transmission Alternatives (NTAs) in a MISO transmission siting case.

“It is an honor to be the CRI Board President,” said Rao. “There is more work to be done in advancing renewables and distributed energy resources on the transmission and distribution grids. Our state and federal policymakers are looking for specific solutions, moving beyond general goals, and CRI has done excellent foundational work in the past 7 years. I am excited to build on this foundation and thank Kerinia and the rest of the CRI Board for this opportunity to lead CRI’s work in the years ahead.”

Center for Renewables Integration experts work at the state, ISO/RTO, and federal levels to develop and implement policies that enable the transition to clean energy cost effectively and without impacting reliability.

Half Time Report: DER in ISO Markets (Order 2222)

All ISO/RTOs have submitted their Order 2222 compliance proposals to FERC. What’s in the proposals and what happens next?

Big, complex FERC Orders can take years to implement. FERC Order 745, which required demand response (DR) to be paid like generators, was issued in 2011 only to be overturned in 2014 and finally reinstated by the Supreme Court in 2016. Will Order 2222 go through a similar complex journey? Before we tackle that question, let’s review why we need Order 2222, which allows distributed energy resources (DER) to participate in markets.

Why do we need Order 2222?

The industry already has demand response, so why does it need this new Order? At a high level, Order 745 is limited to reducing load and Order 2222 includes the both the ability to reduce load and inject energy beyond the meter onto the distribution grid.

What are the problems that Order 2222 is trying to solve? The first is reliability. DER are, generally speaking, invisible to grid operators. It’s not a problem when the amount of DER on the grid is less than a rounding error for the ISO/RTO, but as more homes and businesses choose to install these assets it becomes more difficult for the grid operator to do their job if they can’t see how these assets are changing load or the amount of electricity generated. However, it isn’t a given that the new rules proposed by the ISO/RTOs will encourage this visibility. It is still up to the DER to choose to participate, and there must be value to offset the cost. The second is cost. If homes and business are already installing these assets, doesn’t it make sense to try to access this energy if it can be done cost effectively? If a homeowner installs solar + storage because they want to ensure they have power in the case of a grid outage, does it make sense to allow that generation to become a grid asset during times of peak load instead of building a new peaker plant? The conclusion of Order 2222 was yes. However, the complexity lies in developing new rules to ensure these assets aren’t paid twice for the same service.

Where do we stand when it comes to implementation of Order 2222?

The Order was issued in September 2020. As of April 28, 2022, all the ISO/RTOs have submitted their compliance filing to FERC. CAISO and NYISO submitted early since they didn’t hold stakeholder sessions. PJM and ISO-NE submitted in early 2022, MISO and SPP submitted recently.

What’s Next?

It’s possible that FERC will hold a technical conference to discuss some of the trickier elements of the Order before they start issuing deficiency letters or decisions, that hasn’t been decided yet. Regardless, except for CAISO and NYISO, which were already well down the path of implementing portions of Order 2222, the Order won’t be implemented until 2024+. It is possible the states, utilities, or other parties will contest elements of Order 2222 relating to opt in/opt out and injection, but they will need to pick different arguments than those used in contesting Order 745.

One-Page Synopsis

Source: Voltus, Inc. protest filing submitted in response to ISO-NE’s Order 2222 compliance proposal

CRI Helps Negotiate Smart Inverter Settlement In Pennsylvania Testing Autonomous Capability versus Utility Control of Solar Inverters

A proposed settlement before the Pennsylvania Public Utilities Commission would pave the way for a first-of-its-kind pilot on smart inverter deployment. PPL Electric Utilities had petitioned the PUC to require all new DER to install communications hardware and to allow control over their inverters by PPL’s distributed energy resource management system (DERMS). In a near-unanimous settlement filed on October 5, 2020, however, parties agreed to implement a 3-year pilot program during which some DER will operate under the autonomous control modes of new IEEE 1547-2018 inverters, while other DER operate under PPL’s external control. The pilot will study the impacts of both approaches on distribution system operation and cost, and analyze the incremental benefits of external control over autonomous operation. CRI’s Harry Warren provided expert witness testimony to the Natural Resources Defense Council in the case and helped craft the settlement. The settlement still needs to be approved by the Commission.

 Learn more about smart inverter deployment in CRI’s publication “It’s Time for States to Get Smart About Smart Inverters”, and read more about the settlement in this UtilityDive article.  GTM Squared subscribers can also access an article on the settlement.

Catch CRI Working to Advance Offshore Wind Transmission

From Virginia to New York, current state goals for offshore wind add up to almost 23 GW of generation. Back in 2010, Google announced plans to invest in a 350 mile offshore backbone underwater transmission line to enable wind. Today, most companies are looking at radial transmission lines, connecting each wind farm back to backbone transmission lines on land. As regulators consider solutions to enable offshore wind, it’s important to understand the merits and challenges of both options. Catch CRI working to advance this issue at two upcoming events:

-       August 7, 2020: CRI will participate in an information gathering meeting on offshore wind transmission alternatives, sponsored by the New Jersey Board of Public Utilities.  The NJBPU is gathering perspectives on the relative merits of coordinated offshore transmission infrastructure vs. project specific, radial transmission lines.

-       November 4, 2020: CRI’s Harry Warren will lead a panel discussion on East Coast offshore wind at the Annual Conference of the Maryland Society of Professional Engineers.

CRI Helps Improve Cost Effectiveness of Battery Storage in Virginia

On May 1, Dominion Energy Virginia filed their 2020 proposed Integrated Resource Plan (IRP) with the State Corporation Commission. It is their first IRP since the enactment of the Virginia Clean Economy Act (VCEA) which requires the utility to install 2.7 GW of energy storage by 2035, in addition to transitioning to 100% clean energy. This proposed IRP is bound to gather a lot of attention, particularly with the utility’s statement that achieving VCEA may increase the average residential monthly bill by $18.94, or 15%, in 2030 (pg 33).

 Any long-term decisions for battery storage in the state will be informed by Dominion’s battery pilot program which CRI helped shape, acting as an expert witness for Southern Environmental Law Center (SELC).

 There are numerous cost effective use cases for energy storage including transmission and distribution deferral, ancillary services (frequency regulation, spinning reserve), capacity, and energy. As is true for any infrastructure investment, batteries need to be fully utilized in order to be cost effective. In the case of batteries, that means finding ways for the batteries to provide a service 24/7/365 (8,760 hours), or at least as close as feasible taking into account maintenance and other considerations.

 Dominion Virginia initially proposed pilots that significantly underutilized the batteries, in some cases using the battery less than 100 hours per year. Additionally, the proposed pilots excluded front-of-meter batteries from participating in PJM markets, a potentially significant revenue stream, and omitted metrics that would allow parties to evaluate the cost effectiveness of the utility’s pilots.

 Ultimately Virginia’s State Corporation Commission agreed with issues raised by SELC, with the support of CRI witness, and ordered changes to the pilots that will improve their effectiveness and set storage on the right path in VA.

 In the coming months, it will be important to ensure Dominion’s IRP doesn’t make similar assumptions that limit effectiveness of energy storage, thereby artificially increasing costs.

CRI leads successful effort to prepare Maryland for the widespread use of smart inverters

CRI’s leadership of the smart inverter work group in Maryland’s grid modernization docket has resulted in the adoption of important new interconnection regulations in the State.  Regulations adopted on March 31, 2020 require Maryland’s utilities to propose standard approaches to voltage control and ride-through for smart inverters, and require all inverters installed after January 1, 2022 to comply with the new IEEE 1547-2018 standard.  The new requirements will boost distribution system hosting capacity, help assure the safe and stable operation of the distribution grid, and allow PJM to operate more reliably as distributed generation expands. 

Read more about CRI’s efforts and the new Maryland regulations here, and download CRI’s comments summarizing the new smart inverter requirements here.

CRI’s white paper, It’s Time for States to Get Smart About Smart Inverters, with recommendations for state regulators, can be downloaded free here.

Webinar recording link: The Electron Superhighway: Modernizing the US Transmission Infrastructure

CRI thanks NARUC for organizing a webinar to discuss solutions for improving the US transmission infrastructure that can be implemented quicker and cheaper than traditional poles and wires. Some technologies have been called “Waze for the transmission grid” while others are the equivalent to reversible traffic lanes. As Congress considers economic recovery and infrastructure investments, solutions to improve our electricity infrastructure and enable clean, low cost renewable generation should be at the top of the list. This webinar discusses the technologies, regulatory barriers, and actions that FERC as well as state regulators can take to enable these solutions.

https://www.naruc.org/cpi/cpi-past-events/

The following is a reprint from the NARUC Website:

March 19, 2020: The Electron Superhighway: Modernizing U.S. Transmission Infrastructure

Increasing the capacity and performance of electric transmission is key to achieving state goals, from increased resilience to integrating renewables. On this webinar, experts discussed improvements in advanced transmission technologies and regulatory options for deploying these solutions.

Moderator: Chairman Sally Talberg, Michigan Public Service Commission

Speakers: 

  • Jennie Chen, Senior Counsel, Federal Energy Policy, Duke University Nicholas Institute for Environmental Policy Solutions

  • Bruce Tsuchida, Principal, The Brattle Group

  • Kerinia Cusick, Co-Founder, Center for Renewables Integration

  • Jon Wellinghoff, CEO, GridPolicy Inc., and former Chairman, Federal Energy Regulatory Commission 

Link to slides

Link to recording

CRI Provides Expert Witness Testimony in Smart Inverter Docket

The Center for Renewables Integration is supporting the Natural Resources Defense Council, providing expert testimony in Pennsylvania on smart inverter deployment. PPL Electric Utilities filed a petition with the Pennsylvania Public Utilities Commission in 2019, requesting authorization to require all new DERs equipped with inverters to install communications equipment linked to PPL’s distributed energy resource management system (DERMS). PPL’s request would also authorize the utility to control the inverters remotely at its discretion. CRI witness educates the Commission on risks of that approach and recommends establishing a statewide stakeholder process to determine new smart inverter standards, in line with the National Association of Regulatory Utility Commissioners’ recent resolution, and advocates taking maximum advantage of IEEE-1547-2018 compliant inverters’ autonomous capabilities. Link to the NARUC resolution here, and to CRI’s white paper “It’s Time for States to Get Smart About Smart Inverters” here.

CRI submits comments in MISO Storage as a Transmission Only Asset (SATOA) Filing at FERC

Center for Renewable Integration (CRI) teamed with Environmental Law and Policy Center (ELPC) to submit comments opposing MISO’s SATOA filing at FERC. MISO’s proposal sets up an uneven playing field, essentially baring non-transmission owners from even proposing solutions. CRI & ELPC ask FERC to reject MISO’s filing and require the ISO to refile with the following guidance: 1) ensure both transmission owners and non-transmission owners can compete on a level playing field; 2) require the ISO to remove any restrictive language from their tariff that constrains energy storage to a “non transmission alternative” classification; 3) ensure the ISO includes all technologies included in the Federal Power Act as advanced transmission technologies (e.g. energy storage, distributed generation, load control, power flow, load control and others).

Comments can be downloaded here.

CRI Co-Founder, Harry Warren, named Visiting Fellow at Princeton University

Beginning September 1, 2019, Harry Warren began a six-month resident fellowship at Princeton University’s Andlinger Center for Energy and the Environment. The Andlinger Center supports research and teaching in the areas of sustainable energy technology development, energy efficiency, and environmental protection and remediation.

“Andlinger is an important institution in energy research, nationally and internationally, and as a Princeton alum it’s especially exciting to be part of its efforts”, Harry said. As a visiting fellow Harry is studying how distributed energy resources and building energy systems can be designed and operated to help meet the challenges of incorporating more variable, renewable energy supplies into the power system. Harry is also collaborating on the Center’s Rapid Switch project, which is examining paths to decarbonize the U.S. energy system broadly and the Mid-Atlantic power grid in particular.

Read more about the Andlinger Center and Harry’s Appointment here: https://acee.princeton.edu/acee-news/energy-industry-veteran-and-top-climate-advisor-appointed-visiting-fellows/


CRI is part of coalition asking FERC to rethink how transmission is incentivized and planned

A coalition of nineteen companies collaborated to ask FERC to rethink transmission incentives as part of the Commission’s Electric Transmission Incentives Policy docket. The companies outlined areas of common agreement for FERC, and provided three recommendations:

  • Adopt policies to encourage implementation of low-cost, high-benefit new transmission technologies and other methods to improve the operational efficiency the existing transmission system;

  • Expand the integrated transmission grid to access and deliver low-cost energy resources, and initiate a proceeding to remedy the significant issues serving as a barrier to expanding and integrating the grid to access low-cost remote resources and improve bulk power markets on a national basis.

  • Encourage independent operation of the transmission system.

The coalition companies are: Advanced Energy Economy, Alliance for Clean Energy New York, American Council on Renewable Energy, American Wind Energy Association, Americans for a Clean Energy Grid, Center for Renewables Integration, Citizens for Responsible Energy Solutions, CTC Global Corporation, Enel Green Power North America, Enel X North America, Inc., ITC Holdings Corp., Natural Resources Defense Council, National Electrical Manufacturers Association, NW Energy Coalition, R Street Institute, Sustainable FERC Project, Union of Concerned Scientists, and the WATT Coalition.

Comments can be found here.

New report available, The Role of Distributed Energy Resources in New Jersey's Clean Energy Transition

CRI teamed with Gridworks and GridLabs to develop four specific recommendations for wisely integrating distributed energy resources (DER) in New Jersey and ensuring they are a key part of the state’s solution to reach 100% clean energy. New Jersey policy makers are charged with developing a plan and working to finalize the state’s draft energy master plan. Download the report at https://www.center4ri.org/new-jersey-der.

CRI Supporting District of Columbia Department of Energy and Environment in Evaluating Options for Increasing Procurement of Renewable Energy

CRI is providing ongoing support to the District of Columbia Department of Energy and Environment (DOEE), evaluating options for cost effective renewable electricity purchases in the District. CRI’s feasibility study, “Increasing the Renewable Energy Content of Standard Offer Service” has been submitted and filed by the DOEE in an ongoing proceeding before the District’s Public Service Commission.  CRI’s Harry Warren was the study’s author.  

Primer: Impact of FERC Order 845 on Energy Storage

As ISO/RTOs start to get ready to submit initial Order 845 compliance filings at FERC, more questions are coming up about the order, and how it impacts energy storage. Here’s a quick primer.

The primary intent of Order 845, Reform of Generator Interconnection Procedures and Agreements, is to improve the interconnection process for generators over 20 MW by removing uncertainty, promoting more informed interconnection decisions and greater transparency, improving the interconnection process, and modifying the pro forma Large Generation Interconnection Procedures (LGIP) and Large Generation Interconnection Agreement (LGIA). Embedded in the Order are concepts and clarifications that impact energy storage.

·      The definition of Generating Facility was amended to include energy storage.[1]

·      While it isn’t specific to energy storage, facilities can now request interconnection service below the generation facility nameplate capacity (or the aggregate capacity), as long as control system and penalties are in place to ensure the facilities do not inject above requested level. 

·      Enables generation owners to add energy storage to an existing generation facility. If a generation owner has “surplus interconnection”[2] it can request a fast-track interconnection process to utilize the surplus, by adding storage for example, or transfer that surplus to an affiliate. However, the Order falls short of the NOPR, and FERC did not include a concept which they advanced in the NOPR which would have allowed non-affiliated parties to buy and sell surplus interconnection.  

FERC declined to act on a number of requests related to energy storage, specifically:

·      The Commission declined to set standards for modeling energy storage in the interconnection process, either stand alone or co-located, at this time. Therefore, it remains up to each ISO to model energy storage as deemed appropriate.

·      The Commission determined the definition of generation does not need to be amended to specify that an asset can withdraw energy from the grid, as requested by NYISO.

·      The Commission declined to clarify that energy storage being used as a transmission asset does not need to go through the LGIP and execute an LGIA as requested by a few stakeholders. FERC based their decision on the fact that changes made in this order will not affect whether energy storage operates as transmission.  

·      The Commission declined to extend the Order to make similar changes to the Small Generator Interconnection Process (SGIP), citing the processes are significantly different.

—————————-

[1] New definition: Generating Facility shall mean Interconnection Customer’s device for the production and/or storage for later injection of electricity identified in the Interconnection Request, but shall not include the interconnection customer’s Interconnection Facilities.

[2] Surplus interconnection is the unused portion of interconnection amount requested and reflected in the interconnection service agreement

Catch CRI at the following upcoming conferences

CRI co-founder, Kerinia Cusick, will be presenting at two upcoming conferences in California, discussing the implications of changes to FERC regulations on distributed assets, and the ongoing CAISO stakeholder process to develop regulations on the use of energy storage as transmission assets.

  • DER World Forum, Oct 16 & 17 in Costa Mesa, CA. A copy of the presentation can be downloaded here.

  • ACORE Renewable Energy Grid Forum, Nov 8th in San Francisco, CA.

We look forward to seeing you there!

Helping the Delaware Public Service Commission Understand Smart Inverters

CRI's Harry Warren was invited by the Delaware Public Service Commission to deliver a primer on Smart Inverters and share information on the work being done in Maryland to start preparing the state to take advantage of this new type of inverter, which will increasingly be used with solar, or storage, systems installed in homes and businesses.

Smart Inverters have the ability to provide voltage and reactive power (VAR) support on distribution lines, provide two-way communications, can "island" when the electric grid goes down and continue to provide power, and "ride through" (i.e. keep operating) when a change in frequency occurs on the electricity grid and help grid operators avoid cascading a problem further. However, to implement this technology, state commissions will have to make critical decisions to allow the inverters to be smart. Inverters must comply with IEEE 1547, which recently under went a significant rewrite to allow the functions that Smart Inverters can perform. However, contrary to previous standards, this one requires specific decisions to be made to allow, or not, inverters to perform the functions they can. 

A copy of Harry Warren's presentation given to the DE PSC can be found here. 

CRI Enabling Smart Inverters in Maryland

The Maryland Public Service Commission has scheduled a hearing to approve updated Small Generator Interconnection Standards on September 5, 2018.   CRI is co-chairing the Smart Inverter Subgroup in the Maryland Public Conference 44 (PC44) grid modernization docket, and the updated standards include Subgroup recommendations on the use of smart inverter features to support economical DER deployment.   The Subgroup is now developing a “roadmap” for timely adoption of the new IEEE-1547-2018 smart inverter standard statewide.

 

CRI Identifying How to Increase Procurement of Renewable Energy for DC

CRI has been retained by the District of Columbia Department of Energy & Environment to evaluate increasing the renewable energy content of Standard Offer Service by entering into long-term PPAs.  “SOS” is the default service provided to customers not served by a competitive supplier in the City’s restructured electricity market.  The final report is due September 30, 2018.