Genbright LLC on July 26 asked FERC for a limited waiver of sections of ISO New England’s (ISO-NE) Transmission, Markets and Services Tariff to facilitate the qualification of an aggregation of Distributed Energy Resources (DERs), including solar and battery storage, for ISO-NE’s eleventh Forward Capacity Auction (FCA 11).
Genbright asked for a waiver of the 60 day notice requirement so that the waiver of certain requirements can be effective on April 22, 2016, which was the deadline for ISO-NE’s Show of Interest for FCA 11. Genbright also requested that the commission issue an order on this request in 60 days, i.e., by Sept. 25, which is five days prior to when the ISO notifies new capacity of acceptance or denial for FCA 11.
Genbright is a privately-owned, for-profit company based in Hingham, Mass., that provides demand response and energy brokerage services to end use customers and commercial asset management services to owners of DERs, primarily in New England. Genbright is a voting member of ISO-NE.
Genbright is seeking to enroll a portfolio of small-scale (i.e., under 5 MW) solar PV projects that are classified as generators in the ISO-NE forward capacity market. For some of these projects, Genbright is also working with the solar asset owners to develop battery storage assets that will be co-located on the solar sites. Both the solar assets and battery storage assets are included in Genbright’s Show of Interest and Qualification Package for FCA 11.
Currently, the ISO-NE allows similar projects to qualify as a capacity resource in the FCM as either a Generator or a Demand Resource. Solar PV facilities co-located with energy storage systems are similarly treated by the ISO-NE as either a Generator or Demand Resource. Energy storage projects installed behind the meter and designed to serve at least some portion of a customer’s load are treated as Demand Response resources. By contrast, energy storage projects co-located with solar PV facilities and designed solely to export power to the local distribution grid are treated as Generators.
The qualification process for Generators and Demand Resources is very different, Genbright noted. Although the ISO-NE Tariff does facilitate the aggregation of multiple DER projects to be part of a single Demand Resource, the ISO-NE Tariff does not include rules that facilitate the aggregation of small scale DERs when they are classified as Generators. Qualifying dozens or hundreds of DERs is therefore the same, from an administrative perspective, as qualifying dozens or hundreds of Generators, because these small scale DERs are subject to the same Tariff provisions as all other Generators.
Genbright said this administrative burden can create an unintended barrier to entry for an aggregation of DERs to qualify in ISO-NE FCM markets. Beginning with the Show of Interest and continuing through the qualification process, the ISO-NE and market participants have between two and four months to submit and review information, including satisfying any deficiencies in the Qualification Package. Given the amount of documentation and necessary consultation that may be required to resolve deficiencies in Tariff language that describes “documentation” and “information” requirements, this can make it difficult to qualify dozens or hundreds of small scale generation projects within the required timeframe. By contrast, if projects of the same scale and technology were located behind the meter, they would be subject to the sections of the tariff that address the qualification process for Demand Resources, which have far fewer and more precisely defined administrative requirements that the requirements for Generators.