R.15-03-011, Track 1: Overview of Storage Policy Gaps/BarriersJuly 28, 2015

Alex J Morris, CESA Director, Policy and Regulatory Affairs

© 2015 California Energy Storage Alliance

What’s Next for Development of Energy Storage Rules ?

While much progress has been made, much additional development of rules is necessary to allow full deployment of energy storage solutions, supporting state goals and a greener

grid.

• Numerous areas of rule development need to be addressed and resolved in coming years. • CESA recommends prioritization of the following:

• Any remaining LCR Track 1 barriers for storage solutions• Fundamental business case/planning barriers, e.g., charging rate expectations• Long-term planning barriers• Barriers that “prevent contracts from being signed”, e.g. new technology “caps”

© 2015 California Energy Storage Alliance3

CESA’s comprehensive lists of Storage Barriers and Policy/Rule Gaps should inform the record in this proceeding:• CESA identified 41 Policy/Rule Gaps or Barriers in 2014, many of which are

multi-faceted.• See, “CESA’s Comments Energy Storage Road Map” (Sept, 18, 2014)

Top energy storage rule barriers/gaps include:• Charging rate design• Interconnection/Rule 21 challenges, e.g. load-studies• Multiple-Use Storage Applications • Interim Alternative CAISO Metering structure (to PDR Baseline)• CAISO Distributed Energy Resources Provider (DERP) enhancements• Lack of long-term pumped hydro contracting process• Limitations on 3rd party storage for distribution solutions

Top Storage Barriers and Gaps in Policies/Rules