Order No. 825, on Settlement Intervals and Shortage Pricing in Markets Operated by Regional Transmission Organizations and Independent System Operators, was issued yesterday. It brings about a shortage pricing requirement that is expected to encourage greater investment in storage.

Ten days earlier, on June 6, comments were due in the proceeding on Electric Storage Participation in Regions with Organized Wholesale Electric Markets proceeding (Docket No. AD16-20-000), following RTO responses to Staff data requests, submitted mid-May. A common theme among the RTO responses, noted by, e.g., PJM, is that most rules are technology neutral, so any market rule could impact storage, though certain stakeholder processes are more applicable than others (e.g., NYISO’s fuel constrained bidding design). There are storage-specific rules, however, like ISO-NE’s Alternative Technology Regulation Resource categorization for participation in its regulation market, which is echoed in SPP’s Short-term Stored Energy Resource proposal. Another example is found in Docket No. ER16-1735, where CAISO has proposed tariff amendments to allow batteries to self-manage their state of charge and energy limits.

June 6 responsive comments tended to support a technology-neutral approach to rules and definitions of market products (e.g. EEI’s comments), and Tesla called for eschewing market product design based on “operation parameters that were designed for conventional generators” in favor of design based on the needs of the electric system. Tesla also asked whether energy storage customers could accept charging restrictions in lieu of expensive interconnection upgrades.

There is still time to comment on storage interconnection issues raised in the May 13, 2016, technical conference: the comments deadline in Dockets RM16-12-000 and RM15-21-000 has been extended to June 30.