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    Stationary Grid-level Energy Storage in the U.S.Major Issues and Policy Options

    Faaez Ul Haq

    Professor Harold Feiveson

    WWS 402: Renewable Energy and the Electric Grid in the U.S.

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    Executive Summary

    To adequately meet the reliability needs introduced by integration of renewable

    resources and smart grid technologies into the U.S. grid, a careful planning of bulk and

    distributed energy storage systems into the electric grid is necessary. These storage systems

    will provide better, more economically efficient ancillary services that ensure quality of

    electricity supply, mitigate the stress on the national grid by time and load shifting energy

    capacity and allow greater penetration of renewable energy resources into the national grid.

    Energy storage systems can be broadly categorized into bulk and distributed systems.

    While large-scale bulk storage systems like pumped hydro and Compressed Air Energy

    Storage (CAES) are better suited to providing long-term load shifting services, which do not

    require a fast response time, distributed sources with a short response time, such as batteries

    and flywheels are best suited for short-term services such as Frequency regulation. Each of

    these resource categories has several issues of interest, discussed in detail in this paper, that

    finally inform the following set of policy recommendations:

    1) FERC should identify and eliminate systemic opportunities for discriminationagainst storage systems by transmission providers: FERC should ensure that there is noopportunity for undue discrimination against storage systems by transmission providers, by reviewing tariff structures and mechanisms used by transmission providers and BAs tocompensate independent providers of electricity. FERC has already proposed rules thatallow storage devices to compete fairly with generating sources in frequency and voltageregulation markets and standardized the way Available Transfer Capability (ATC) metric,

    which directly affects prices, is calculated1, but the same rules should be extended to non-regulation, wholesale electricity markets as well.

    2) FERC should mandate that quality of electricity supply be factored intopricing: Quality of electric supply should be incorporated into compensation for regulationservice, instead of compensating the operator purely on the basis of energy output and theopportunity cost of foregone sales from the generation capacity reserved for regulation.

    1 Docket Nos. RM05-17-000 and RM05-25-000, http://www.ferc.gov/whats-new/comm-meet/2007/021507/E-1.pdf , accessed on Apr 28th 2011

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    Currently, only the NYISO adjusts its compensation according to the accuracy of a systemsresponse by maintaining an index that tracks the accuracy of a regulating resource infollowing AGC dispatch signals.2

    3) FERC should mandate that the cost of additional regulation service be borne

    by the party introducing supply variability: The cost of additional regulation servicesrequired due to the variability in a systems output should be shifted to the system operator,to accurately reflect the real cost of the energy produced. Operators of wind farms, e.g.,could be required to install regulation capacity to offset the variability of their systemsoutput, or the compensation provided to the operator be adjusted according to thevariability of their output.

    4) Tax and/or Energy Credits should be provided for Storage Systems: Theimportance of storage technologies to the successful integration of ERG and smart gridtechnologies into the grid should be recognized and tax and/or energy credits, similar to theones extended to renewable resources should be introduced. This will encourage investment

    in the high-risk area of cutting edge grid-level storage technologies, especially considering theinherently risk-averse nature of these technologies primary customer, i.e., the utilities.

    5) DOEs Loan Guarantee Program should be continued: Department of EnergysLoan Guarantee Program for renewable resources has been instrumental in starting upseveral high-risk, high-return projects. NYISOs 20 MW flywheel plant is one example of the same. As of November 2010, the Obama administration was considering abandoning theDOE loan guarantee program and shifting the remaining funds to a pool for Section 1603investment credits3. While this may benefit some players in the renewable resource market,such as wind generator operators, it may prejudice the position of others, who depend onloan guarantees to undertake high-risk projects that are crucial to the evolution of the grid

    in the U.S.

    2 FERC, Frequency Regulation in the Organized Wholesale Power Markets, Docket Nos.RM11-7-000, AD10-11-000, http://www.ferc.gov/whats-new/comm-meet/2011/021711/E-4.pdf , accessed on Mar 20th 2011, pp.73 Lane, Jim, Obama May Kill Key DOE Loan Guarantee Program,http://www.renewableenergyworld.com/rea/news/article/2010/11/obama-may-kill-key-doe-loan-guarantee-program, accessed on Mar 26th 2011

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    Introduction

    It is hard to imagine the future of the electrical industry in the U.S. without viable

    grid-level4

    energy storage options. While the sophistication of these storage systems can vary

    from a simple (yet expensive) pumped hydro system, to high-capacity batteries based on

    breakthroughs in advanced materials science, the degree to which these will be critical to the

    future of the electrical grid is undisputed. Some of the most critical issues that face the

    electrical industry today are inextricably tied to the ability (or inability) to store electricity at

    the grid level.

    In this paper, the need for grid-level energy storage is established, followed by an

    assessment of the different kinds of energy storage available, an analysis of how the storage

    could be used, and finally a presentation of the main findings and policy options.

    Why Storage?

    The following graph shows that electricity demand in the country is projected to

    increase at 1% every year through 20355, when the country is expected to consume over 5

    trillion kWh of electricity per year6.

    4 Grid-level, in this context means 1 MW and above5 U.S. Department of Energy, Energy Information Administration, Annual Energy Outlook2010 with Projections to 2035 (May 2010),http://www.eia.doe.gov/oiaf/aeo/electricity.html , accessed on Mar 1st 2011

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    Fig. 1) U.S. Net Electricity Consumption7

    To meet this need, an additional 250 gigawatts of generating capacity will have to be

    put in place.8 At the same time, the expansion of and shifts in national cultural imperatives,

    especially as they relate to distributed grid capacity and electrical vehicles, growth of

    embedded renewable energy sources in the grid and the evolution of the smart grid, which

    will further stress the electrical grids generation, distribution and transmission capacity.

    Reliable and cost-effective grid-level energy storage can help address these concerns

    in the following four broad categories:

    1) Ancillary Services at Scale:To maintain reliability and quality of service in

    electricity transmission, several Regional Transmission Organizations (RTOs)/Independent

    System Operators (ISOs) maintain wholesale electricity markets where about 130 Balancing

    Authorities (BAs) provide ancillary services such as Frequency and Voltage regulation, Load

    Following or Ramping and redundant capacity for reliability control (See Appendix A for a

    list of ancillary services provided by energy storage systems).

    7 U.S. Department of Energy, Electric Power Industry Needs for Grid-Scale StorageApplications, http://www.oe.energy.gov/DocumentsandMedia/Utility_12-30-10_FINAL_lowres.pdf , accessed on Mar 15th 20118 Ibid., the generation capacity was 813 gigawatts (GW) as of 2001

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    The most important of these services is Frequency regulation, whereby real power is

    injected or withdrawn from a system depending on its frequency deviations or power

    interchange imbalance over a scale of 10 seconds to several minutes. This is done with a view

    to providing steady power without significant frequency deviations. Both of these factors are

    measured by a single metric, the Area Connection Error (ACE), which is a measure of i) the

    offset between a BAs scheduled and actual interchange9 and ii) the BAs share in correcting

    the frequency of the interconnection. ACE is then used as the basis of Automatic Generation

    Control (AGC) signals that are sent to service providers (SPs) who can then bid on portions

    of the advertised load requirement10

    . Upon a successful bid, the SPs must inject or withdraw

    energy from the grid at the specified time. It must be noted that Frequency regulation is

    different from Frequency response, which is the automatic and autonomous action of both

    generating sources and technically capable demand response consumers to respond to

    frequency shifts in the transmission. Frequency response does not require the BA to send out

    AGC signals, as is the case in Frequency regulation.

    While historically, generators have been used to provide most ancillary services, grid-

    level energy storage systems are increasingly being deployed in RTOs and ISOs across the

    country to do the same. Not only are many of these systems more responsive to AGC signals

    from BAs than conventional generators, but under the right regulatory framework, they are

    more economically efficient too. In situations where generators are used to provide these

    ancillary services, they must be able to ramp up and ramp down by changing the output

    9 Energy transfers that cross Interchange boundaries10 At least in the case of ISOs and RTOs that maintain a wholesale market for electricity

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    of real power from a generating unit per time (usually measured as megawatt/minute)11 .

    Energy storage systems do the same by discharging and recharging, to ramp up and down,

    respectively. Flywheels and large-scale batteries, in particular, provide ACE correction

    rapidly 12 . Fig.1 shows the dramatic difference in the responsiveness of conventional

    generators as compared to advanced energy storage systems. The green line is the required

    level of output, while the red line shows the resources actual response. It is important to

    note that further value is lost due to a mismatch between the AGC signal dispatched by the

    BA and the subsequent response by the operator, because the BA may have to solicit

    additional resources to balance the offset introduced by slow/inaccurate ramping energy

    resources.

    Fig. 2) A comparison of a slow-ramping generators response with that of advanced energy

    storage

    11 FERC, Frequency Regulation in the Organized Wholesale Power Markets, Docket Nos.RM11-7-000, AD10-11-000, http://www.ferc.gov/whats-new/comm-meet/2011/021711/E-4.pdf , accessed on Mar 20th 2011, pp.212 Ibid.

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    Electrical plants use spinning reserves13 to provide redundant capacity, in case

    another generator fails, to prevent unscheduled fluctuations in output. However, this

    requires the backup generators to be running at all times, without contributing to

    production. Using energy storage systems instead of conventional generators to provide

    ancillary grid services can potentially free up 1-3% generation capacity 14 , which would be

    significant given the linear increase in electricity consumption in the U.S. through 2035.

    Some Balancing Authorities (BAs) in RTO and ISO markets provide unit-specific

    opportunity cost payments to independent sellers of electricity, who maintain generation

    capacity to specifically keep the ACE under acceptable limits15

    . Compensation structures for

    ancillary services at the ISO/RTO level are biased against storage systems providing the

    same services (as compared to conventional generation sources). While new Federal Energy

    Regulatory Commission (FERC) initiatives, such as FERC Order 890, have opened

    regulation markets to non-generation energy technologies by categorizing them as (Limited)

    Energy Storage Resource (LESR or ESR), tariff structures in most ISO/RTOs disadvantage

    fast-ramping energy storage devices against conventional spinning reserves by including the

    opportunity cost of foregone sales from generation capacity set aside for frequency regulation

    in the compensation paid to the operators, while ignoring the speed of ramp up/down. This

    is problematic because a slow ramping, high-capacity regulating resource may put in a high

    amount of energy into the system, but still not provide useful regulation because of slow

    13 Unloaded generation that is synchronized and ready to serve additional demand.14 Beacon Power, Application of Fast-Response Energy Storage in NYISO for FrequencyRegulation Services. Retrieved March 25th, 2011, fromhttp://www.beaconpower.com/files/UWIG-presentation-April2010.pdf 15 FERC, Frequency Regulation in the Organized Wholesale Power Markets, Docket Nos.RM11-7-000, AD10-11-000, http://www.ferc.gov/whats-new/comm-meet/2011/021711/E-4.pdf , accessed on Mar 20th 2011, pp.2

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    ramp up, thereby needlessly increasing the cost of frequency and voltage regulation. Because

    advanced storage systems are more accurate in their response, service providers could have

    incentive to install them even with their higher installation cost per megawatt (MW) output

    capacity, if compensation structures at the ISO/RTO level are changed to accurately reflect

    the useful frequency regulation provided by the operator. In fact, tariff and compensation

    structures revisions proposed by FERC in 2009 and 2010 incorporated the accuracy of

    performance16 for balancing services into the compensation structure, instead of purely

    relying on the net energy input into the system, and NYISO has already adopted these

    revisions.

    2) Embedded Renewable Generation (ERG) and Climate Change Initiatives

    (CCI): Recent climate change regulations and commitments, such as the Clean Air Act,

    Energy Independence and Security Act of 2007 and the Copenhagen Accords, which require

    or recommend carbon emission reductions, imply that there will be a significant shift in the

    resource mix of U.S. electricity generation.17 As the proportion of fossil fuels in the resource

    mix makeup decreases, renewable sources of energy will account for an increasing amount of

    the U.S. electricity generation capacity. Although under current policies, renewable sources

    are anticipated to contribute only about 14% of U.S.s totalelectricity output in 2035, up

    from 10% in 200918 , this still implies that the electricity generated from renewable sources

    16 Accuracy in this context means the speed of ramp up/down. Cf. Fig 217 NERC, Reliability Impacts of Climate Change Initiatives: Technology Assessment andScenario Development. Retrieved March 20th, 2011, fromhttp://www.nerc.com/files/RICCI_2010.pdf .18 U.S. Department of Energy, Energy Information Administration, Annual Energy Outlook2010 with Projections to 2035 (May 2010),http://www.eia.doe.gov/oiaf/aeo/electricity.html , accessed on Mar 1st 2011

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    will increase by 73% over the next 25 years.19 Nearly 50% of this added renewable capacity

    would be met by variable energy sources like wind and photovoltaic solar. (See Appendix D

    for the complete makeup of U.S. renewable energy portfolio in 2035). Because these energy

    sources rely on weather-based fuel (wind and sunlight, respectively), there is great

    fluctuation in their electricity output across time, and they are categorized into a separate

    class of resource called Variable Generation (VG). VG resources further accentuate the

    endemic frequency and load fluctuations in transmission systems and require buffer storage

    capacity to be feasible.20 In fact, in a seminal study sanctioned by the National Renewable

    Energy Laboratory (NREL) on the embedding of wind and solar resources into the electric

    grid found that with better utilization of existing pumped hydro storage systems, wind could

    provide 35% and solar 5% of the energy in the WestConnect group of utilities in the U.S.21

    Weather-based fluctuation in output over time is especially problematic for wind

    generation: firstly because peak production for wind turbines usually occurs during off-peak

    hours of the day and secondly because large-scale integration of geographically diverse

    resources does not guarantee a sufficient decrease in output variability over time: while

    aggregate frequency variation over such resources may go down, operating experience in

    areas with large amount of wind resources such as the Columbia basin and western part of

    the ERCOT system has shown that variability and fluctuation of individual plants can

    correlate with that of others over distances of a few hundred miles for large weather

    19 Ibid.20 North American Electric Reliability Corporation (NERC), Potential Reliability Impacts ofEmerging Flexible Resources, November 2010,http://www.nerc.com/docs/pc/ivgtf/IVGTF_Task_1_5_Final.pdf , accessed on March 16th2011, pp.121 NREL, Western Wind and Solar Integration Study, May 2010,http://www.nrel.gov/wind/systemsintegration/pdfs/2010/wwsis_final_report.pdf ,accessed on March 25 th 2011, pp. 277-280

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    systems.22 Given that wind energy constitutes the fastest growing energy source in the U.S.,

    with capacity growing 30% per year over the last five years alone23 and another 200 GW

    projected in the next ten years24 , large scale, inexpensive storage systems, such as pumped

    hydro or CAES will be necessary to accommodate the high volume of VG capacity

    embedded in the grid.

    3) Smart Grid and Demand-Response (DR): Commenting on the importance of

    energy storage to smart grid technologies, a particularly imaginative blogger likened the

    smart grid to a computer: neither is particularly useful without storage.25 In any market with

    variability in supply and demand, an economically efficient outcome requires some level of

    elasticity in the supply and demand curves: in the face of higher prices, consumers scale back

    their consumption and suppliers ramp up their supply, and vice versa, until an economically

    efficient outcome is reached. In the wholesale electricity market, however, elasticity of

    electricity supply is severely limited by the fact that electricity produced needs to be

    consumed almost immediately and output of energy sources is relatively fixed either because

    they rely on time-dependent fuels, such as in the case of VGs, or because it is not

    economically feasible to completely shut down operating resources at times of low demand.

    An essential component of the smart grid and proposed DR programs is a variable pricing

    feature that would make the demand curve more elastic by letting consumers vary their

    22 North American Electric Reliability Corporation (NERC), Potential Reliability Impacts ofEmerging Flexible Resources, November 2010,

    http://www.nerc.com/docs/pc/ivgtf/IVGTF_Task_1_5_Final.pdf , accessed on March 16th2011, pp.223 Ibid. pp. 3424 Estimates of proposed and conceptual sources, according to a NERC report. Much of thiscapacity is likely not to actually materialize, but the figure gives an idea of the scale ofinterest in VG resources25 Katie Fehrenbacher, Energy Storage for the Smart Grid,http://gigaom.com/cleantech/faq-energy-storage-for-the-smart-grid/ , accessed on Mar 21st 2011

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    electricity consumption according to the price. However, for the smart grid and proposed

    DR programs to be truly successful, the supply curve needs to be made more elastic as well.

    This can be achieved through existing tools that BAs use for load management, specifically

    called Load Following and Electric Energy Time Shift.26

    Load Following is the practice of changing power output in response to the changing

    balance between electricity supply and demand in the system. As in the case of Frequency

    regulation, spinning reserve generators are typically used to provide these services, but

    advanced storage systems, especially short-term distributed storage with a faster response-

    time such as large-scale batteries and flywheels are better suited to provide Load Following

    services. Electric Energy Time Shift is the practice of storing energy when the demand, and

    therefore price is low, and selling the stored electricity back to the grid when consumption

    peaks in the day and prices are higher. For this purpose, long-term, more centralized storage,

    such as pumped hydro and compressed air energy systems (CAES) are more useful, because

    response time is not an issue and input/output can be scheduled along observed patterns

    over time.

    4) Alleviating Pressure on the Current Grid: As electricity demand and

    sophistication of regulatory mechanisms increases, additional transmission and distribution

    infrastructure is required to deliver electricity to consumers and make wholesale electricity

    markets work. However, building transmission lines is a costly and time-consuming

    undertaking and even existing transmission lines experience very low capacity utilization

    26 U.S. Department of Energy, Electric Power Industry Needs for Grid-Scale StorageApplications, http://www.oe.energy.gov/DocumentsandMedia/Utility_12-30-10_FINAL_lowres.pdf , accessed on Mar 15th 2011, pp. 18-20

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    because they are built for high reliability during peak conditions.27 Building a mile of high

    voltage transmission lines can now cost several million dollars and obtaining rights-of-way

    and the necessary permits can take 5-7 years.28 In this context, a more time- and cost-

    efficient solution would be to use grid-level storage to mitigate the effect of higher

    consumption on the grid.

    Relatively small amounts of grid-level energy storage can help alleviate pressure on

    the current grid by storing power during times of low demand and dispensing it during peak

    conditions. E.g., according to an Electric Power Research Institute (EPRI) report, a 15-

    minute energy storage device can provide continuous Frequency regulation, given that it can

    dynamically charge up and down in response to AGC signals.29 By building storage systems

    closer to the point of use, grid congestion is reduced during peak periods as well. Therefore,

    instead of building long transmission lines across interchanges to fulfill Load Shifting and

    Frequency regulation needs, distributed storage can be used to provide the same services and

    thereby defer or substitute the upgrade of transmission and distribution systems.

    Principal Findings: Various Storage Systems and Related Issues of Interest

    All electricity storage systems are not equal: to meet the spectrum of energy storage

    needs in the grid, storage systems vary by power ratings (from kW to MW) and energy

    discharge ratings (millisecond to hour scale) and each of them is better suited to a particular

    grid storage application than another. These storage systems can be broadly categorized into

    27 U.S. Department of Energy, Electric Power Industry Needs for Grid-Scale StorageApplications, http://www.oe.energy.gov/DocumentsandMedia/Utility_12-30-10_FINAL_lowres.pdf , accessed on Mar 15th 2011, p. 1828 Schainker, Robert B., Energy Storage Options For A Sustainable Energy Future, IEEE, p.529 Application of Fast-Response Energy Storage in NYISO for Frequency Regulation Services.Retrieved March 25th, 2011, from http://www.beaconpower.com/files/UWIG-presentation-April2010.pdf , p.8

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    Bulk and Distributed systems, and in this section, two of the more important ones in each

    category are assessed for their suitability to different applications.30 (See Appendix B for an

    overview of more storage technologies and Appendix C for the criteria used). Bulk storage

    systems are better suited to energy applications, which include long-term services like

    Load Shifting because they have higher capacity but slower response time, whereas

    distributed systems are better suited for power applications, which include short-term

    services that require fast-responding storage systems, such as Frequency regulation.

    Fig. 4) Categorization of different storage systems

    Compressed Air Energy Storage (CAES): With the lowest capital cost of storage, on

    a per kW-basis, and an AC-AC roundtrip efficiency of 85%, CAES is well-suited for large-

    scale storage needs for providing services in the energy applications category. CAES plants

    30 U.S. Department of Energy, Electric Power Industry Needs for Grid-Scale StorageApplications, http://www.oe.energy.gov/DocumentsandMedia/Utility_12-30-10_FINAL_lowres.pdf , accessed on Mar 15th 2011

    StorageSystems

    Mobile Storage

    Electric/HybridVehicles

    StationaryStorage

    Bulk Storage

    CAES

    Pumped Hydro

    DistributedStorage

    Flywheels

    Batteries

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    use off-peak electricity to pump air into underground reservoirs or surface vessel/piping

    systems and then use the compressed air to drive expansion turbines after heating the air

    with conventional fossil fuels. This process is three times more efficient than a plant that

    would use the fossil fuel directly in combustion turbines.31

    To date, only one large-scale CAES plant has been built in the U.S., which is

    operated by Alabama Electric Cooperative. However, recent EPRI studies have shown that

    three-fourths of the U.S. has geology suitable for reliable underground storage of compressed

    air32 and therefore more companies are venturing into this space. One such company is

    SustainX, a GE-investee, which focuses exclusively on CAES systems.

    SustainXs technology is novel in that unlike conventional CAES systems, it does not

    use fuel to heat the air up before compression, relying instead on its isothermal

    compression technology, which is more energy-efficient and uses thermodynamic and

    hydraulic control mechanisms to achieve the same results.33 In an interview, Adam

    Rauwerdink, a Business Development Executive at SustainX commented that despite

    limited rollout of CAES systems in the U.S., significant growth in the sector is expected

    because of improvements in technology and regulatory frameworks under which CAES falls.

    Specifically, he believed that In addition to the existing CAES system in Alabama, another

    one is being installed at the Iowa Compressed Air Storage Park and more are in the planning

    phase, to be implemented in NY and CA.

    Pumped Hydro: Pumped hydro is the oldest form of energy storage system

    considered in this paper: its usage dates back almost a hundred years and the technology

    31 Interview with Adam Rauwerdink, Business Development Executive, SustainX32 Schainker, Robert B., Energy Storage Options For A Sustainable Energy Future, IEEE, p.233 Interview with Adam Rauwerdink, Business Development Executive, SustainX

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    relies on the simple idea that water can be pumped to a higher reservoir and the stored

    potential energy used to generate electricity at a later time by driving turbines. With about

    38 plants in operation in the U.S., it is also the most widespread form of large-scale energy

    storage in the country.34

    Despite its widespread use, however, pumped hydro has recently fallen into relative

    disfavor due to various reasons. Thanks to high total costs of building (even though it is

    relatively cheap on a per kW basis), long project completion times (10 years on average,

    with 5 years waiting-time for permits35) and unavailability of suitable sites, environmental

    concerns and the fact that the Department of Energy discontinued its own Hydropower

    program in 2006 (although it was re-started three years later with a focus on storage)36 ,

    private companies are turning to other forms of large-scale storage instead.

    Nevertheless, pumped hydro remains the second-cheapest form of energy-storage

    after CAES, on a cost per kW-basis and is ideally suited to provide grid-level Electric Energy

    Time Shift services, where the scale, and not the responsiveness of the system is the more

    important factor. Further innovations in siting capabilities, such as using closed-loop

    pumped hydro, where two off-stream reservoirs are used so that natural ecosystem of rivers

    and natural water bodies is not disturbed, and underground pumped hydro, where the lower

    reservoir is excavated from subterranean rock have also made it possible to consider situating

    pumped hydro at sites which would have been deemed unsuitable in the past. While the

    34 Ibid.35 DOE Promotes Pumped Hydro as Option for Renewable Power Storage - NYTimes.com..Retrieved March 26 th , 2011, fromhttp://www.nytimes.com/gwire/2010/10/15/15greenwire-doe-promotes-pumped-hydro-as-option-for-renewa-51805.html.36 Ibid.

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    latter siting approach would provide more flexibility in siting, currently the cost is too

    prohibitive and the approach remains a project of EPRI and DOE R&D.37

    Battery Storage: While the specific characteristics of a battery depend on its

    electrochemical makeup, which can vary significantly among different battery technologies,

    all batteries have the advantage of being modular, quiet, non-polluting and quick to respond

    to changes in demand. For this reason, they make excellent storage systems for services in the

    power application category. However, unlike flywheel storage, CAES and pumped hydro,

    batteries span the energy and power application category: while they have traditionally

    provided services in the power application category, breakthroughs in battery design have

    meant that they can be feasibly used for energy applications as well.

    Batteries can be broadly categorized into Solid and Liquid Electrode batteries.

    While the former are appropriate for power applications, where fast charge-up/discharge is

    required but discharge duration is not an issue, the latter use liquid electrolytes as the active

    materials in place of solid electrodes and are better suited to long-term services in the energy

    applications category.38

    Another battery that does not fit into either of these categories is the metal-air

    battery. Instead of using two solid electrodes, the battery uses only one solid electrode and

    oxygen in the air as the other active material in its electrochemical reactions. These have

    traditionally not been serious contenders for grid-level deployment since they are not

    rechargeable and are prohibitively expensive, a PA firm, Grid Storage Technologies (GST), is

    37 Ibid.38 North American Electric Reliability Corporation (NERC), Potential Reliability Impacts ofEmerging Flexible Resources, November 2010,http://www.nerc.com/docs/pc/ivgtf/IVGTF_Task_1_5_Final.pdf , accessed on March 16th2011, pp.13

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    currently working on a rechargeable utility-scale metal-air battery that is scheduled for

    production next year39 . In an interview, the CEO, Michael Oster explained that having one

    electrode significantly reduced the physical footprint of the battery and enabled distributed

    storage to be deployed close, in proximity to the major points of consumption, thereby

    reducing congestion on the transmission lines at peak capacity. GSTs technology would also

    have 1/5 the cost/MW of traditional battery storage and be safer due to being water-based

    and therefore, not prone to chemical runaways.40

    The stimulus bill of 2009 set aside $2 billion in grants for manufacturing advanced

    batteries41

    . Understandably, this has led to much R&D being carried out at universities,

    national labs, such as DOEs Sandia Laboratories and well-capitalized private labs42 .

    However, there are several issues that still need to be addressed by government regulatory

    agencies, especially FERC, for battery storage to become a viable large-scale storage option.

    According to Mr. Oster, storage systems need to be treated on an equal footing to

    energy production resources, because they essentially perform the same basic function:

    provide electricity at a price that a consumer is willing to pay. Despite having the technical

    capacity to do so, battery storage is prevented from providing much of the same services that

    energy resources provide because of prohibitive policy that favors energy production sources

    over storage systems. Mr. Oster expressed concern that while ERG sources imposed

    additional cost on the grid by introducing variability in supply, they did not have to bear the

    39 Interview with Grid Storage Technologies CEO, Michael Oster, March 28th 201140 In Chemistry, refers to a situation where an increase in temperature changes theconditions in a way that causes a further increase in temperature, often leading to adestructive result. It is a kind of uncontrolled positive feedback.41 Bullis, Kevin, Stimulus Big Winner: Battery Manufacturing, Technology Review,http://www.technologyreview.com/energy/22188/?a=f , accessed on March 27th 201142 Interview with Michael Oster, CEO, Grid Storage Technologies, March 28th 2011

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    cost of ancillary services that corrected for this variability. This unduly disadvantages storage

    systems like batteries, which provide high-quality regulated supply to the grid and do not

    impose additional cost on the grid by requiring corrective ancillary services but nevertheless

    had to compete with ERG sources on a similar pricing structure. His contention was that

    quality of electricity supply be factored into the compensation structure, so that batteries

    can compete more effectively against other grid technologies.

    Similarly, ERG resources get tax and energy credits, which offsets the high

    installation costs of the systems, whereas battery storage does not- even though it arguably

    adds societal environmental value to the system by reducing the load on generating resources

    that utilize fossil fuels and emit greenhouse gases.

    Lastly, he believes that the biggest challenge facing emerging battery technologies

    was the risk-aversion of utility companies. Since cutting edge technology has usually not had

    sufficient testing deployed at the grid-level, utility companies are wary of installing it in their

    systems.

    Flywheels

    Flywheel storage relies on the angular momentum of a rotating mass in vacuum. To

    charge up, the flywheel is spun up to the right speed by a generator run by electricity and

    the same generator is then used in a discharging cycle to translate the momentum of the

    flywheel into electricity. Due to the short discharge capacity (most are between 1MW-

    5MW) and high efficiency (around 90% AC-AC translation)43 flywheels are usually only

    used to provide short-term power applications.

    43 North American Electric Reliability Corporation (NERC), Potential Reliability Impacts ofEmerging Flexible Resources, November 2010,

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    The 2009 FERC approval of market rules that allowed energy storage systems to

    provide regulation services sparked an interest in flywheels as fast, efficient sources of short-

    term regulation capacity. The first 20 MW flywheel regulation plant was installed in

    Stephentown, NY to provide regulation services in the NYISO.44 The facility, operated by

    Beacon Power, stores excess electricity at times of low electricity demand, and sells it back

    at times of high demand.

    Policy Recommendations

    Increase in energy consumption, integration of ERG and smart grid technologies into

    the grid and the subsequent impact that each will have on the reliability of the grid, will

    require more bulk and distributed storage capacity. To this end, the following policy options

    are proposed:

    1) FERC should identify and eliminate systemic opportunities for discrimination

    against storage systems by transmission providers: FERC should ensure that there is no

    opportunity for undue discrimination against storage systems by transmission providers, by

    reviewing tariff structures and mechanisms used by transmission providers and BAs to

    compensate independent providers of electricity. FERC has already proposed rules that

    allow storage devices to compete fairly with generating sources in frequency and voltage

    regulation markets and standardized the way Available Transfer Capability (ATC) metric,

    which directly affects prices, is calculated45 , but the same rules should be extended to non-

    http://www.nerc.com/docs/pc/ivgtf/IVGTF_Task_1_5_Final.pdf , accessed on March 16th2011, pp.1444 Beacon Power, Application of Fast-Response Energy Storage in NYISO for FrequencyRegulation Services. Retrieved March 25th, 2011, fromhttp://www.beaconpower.com/files/UWIG-presentation-April2010.pdf , pp. 1145 Docket Nos. RM05-17-000 and RM05-25-000, http://www.ferc.gov/whats-new/comm-meet/2007/021507/E-1.pdf , accessed on Apr 28th 2011

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    regulation, wholesale electricity markets as well. When interviewed, representatives from

    both SustainX and Grid Energy Storage expressed similar concerns, claiming that the

    disparity between regulation of storage and production systems puts the former at a

    disadvantage and inhibits investment and R&D in the area.

    2) FERC should mandate that quality of electricity supply be factored into

    pricing: Quality of electric supply should be incorporated into compensation for regulation

    service, instead of compensating the operator purely on the basis of energy output and the

    opportunity cost of foregone sales from the generation capacity reserved for regulation.

    Currently, only the NYISO adjusts its compensation according to the accuracy of a systems

    response by maintaining an index that tracks the accuracy of a regulating resource in

    following AGC dispatch signals.46

    3) FERC should mandate that the cost of additional regulation service be borne

    by the party introducing supply variability: The cost of additional regulation services

    required due to the variability in a systems output should be shifted to the system operator,

    to accurately reflect the real cost of the energy produced. Operators of wind farms, e.g.,

    could be required to install regulation capacity to offset the variability of their systems

    output, or the compensation provided to the operator be adjusted according to the

    variability of their output.

    4) Tax and/or Energy Credits should be provided for Storage Systems: The

    importance of storage technologies to the successful integration of ERG and smart grid

    technologies into the grid should be recognized and tax and/or energy credits, similar to the

    46 FERC, Frequency Regulation in the Organized Wholesale Power Markets, Docket Nos.RM11-7-000, AD10-11-000, http://www.ferc.gov/whats-new/comm-meet/2011/021711/E-4.pdf , accessed on Mar 20th 2011, pp.7

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    ones extended to renewable resources should be introduced. This will encourage investment

    in the high-risk area of cutting edge grid-level storage technologies, especially considering the

    inherently risk-averse nature of these technologies primary customer, i.e., the utilities.

    5) DOEs Loan Guarantee Program should be continued: Department of Energys

    Loan Guarantee Program for renewable resources has been instrumental in starting up

    several high-risk, high-return projects. NYISOs 20 MW flywheel plant is one example of

    the same. As of November 2010, the Obama administration was considering abandoning the

    DOE loan guarantee program and shifting the remaining funds to a pool for Section 1603

    investment credits47

    . While this may benefit some players in the renewable resource market,

    such as wind generator operators, it may prejudice the position of others, who depend on

    loan guarantees to undertake high-risk projects that are crucial to the evolution of the grid

    in the U.S.

    47 Lane, Jim, Obama May Kill Key DOE Loan Guarantee Program,http://www.renewableenergyworld.com/rea/news/article/2010/11/obama-may-kill-key-doe-loan-guarantee-program, accessed on Mar 26th 2011

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    Appendix A: List of Ancillary Services provided by Energy Storage Systems

    Source:U.S. Department of Energy, Electric Power Industry Needs for Grid-Scale StorageApplications, http://www.oe.energy.gov/DocumentsandMedia/Utility_12-30-10_FINAL_lowres.pdf , accessed on Mar 25thth 2011

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    Appendix B: Overview of Various Storage Technologies

    Source:U.S. Department of Energy, Electric Power Industry Needs for Grid-Scale StorageApplications, http://www.oe.energy.gov/DocumentsandMedia/Utility_12-30-10_FINAL_lowres.pdf , accessed on Mar 25thth 2011

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    Appendix D: Composition of non-hydropower renewable generation per year

    Source: U.S. Department of Energy, Energy Information Administration, Annual Energy Outlook 2010 with Projections to 2035 (May 2010),http://www.eia.doe.gov/oiaf/aeo/electricity.html, accessed on Mar 1st 2011