Tesla Asks, 'Where’s Storage in Perry’s NOPR?'

Many people with their finger on the pulse of the U.S. energy industry read the Notice of Proposed Rulemaking (NOPR) on grid resiliency from Energy Secretary Rick Perry and wondered why energy storage didn’t merit more attention.  Tesla, in its comments to the Federal Energy Regulatory Commission (FERC) on the NOPR, made its surprise about the omission very clear.

In its Oct. 23 comments, Tesla said:  “Based on the ability of energy storage and distributed energy resources to contribute to reliability and especially resiliency,  Tesla urges [FERC] to dismiss the Proposal, which completely excludes the benefits of energy storage and distributed energy resources, which can be co-located with load in order to provide power even when the transmission and distribution grids are completely demolished; which can island to provide power to additional loads; and whose fuel supply requires no transportation whatsoever.”

In addition Tesla said that the attributes of energy storage, which centralized generators "lack entirely," make onsite storage perfectly suited to support what Perry claims are his goals of reliability and resiliency of the power grid.

In September Perry released the NOPR directing FERC to issue a final rule requiring its organized markets to develop and implement rules that accurately price generation resources necessary to maintain the reliability and resiliency of the U.S. bulk power system.  FERC opened a docket—RM18-1-000—for the NOPR, and on Oct. 2, it issued a notice inviting comments on the proposed rule.

As proposed, the final market rules would allow for the recovery of costs for what is called “fuel-secure” resources that provide “reliable capacity, resilient generation, frequency, and voltage support and on-site fuel inventory.”  Eligible units would be required to have a 90-day fuel supply on site in the event of supply disruption.

Tesla recommended that FERC reprioritize its efforts to improve the ability of energy storage to participate in wholesale markets.  Last year, FERC issued a proposed rule that would direct U.S. transmission system operators to establish market rules to accommodate energy storage participation in organized wholesale electric markets.

“To the extent that [FERC] does want to pursue broader market reforms to support reliability and resiliency, Tesla recommends that [FERC] focus on defining the attributes required to support the grid and developing new, technology-neutral market products to ensure sufficient levels of those attributes,” Tesla said.

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