Making more use of an electric storage asset can be a sensible goal without making every revenue arrangement fair. FERC's February 6 policy statement allows storage to seek cost-based recovery for certain services and market revenue for separate services. The ethical issue is how additional use respects the people already paying for the asset's promised service. [2017-02421][2016-28194]

The guidance puts that promise into operational terms. Technical capability is necessary, and demand for the cost-based service must be predictable enough to manage charge around it. When the need arises, that service takes priority. Market offers should remain with the owner or operator, while the regional system operator performs its normal market role. More uses cannot simply erase the original obligation. [2017-02421][2016-28194]

Financial stewardship requires similar care. Crediting market revenue to cost-based ratepayers is one possible protection against duplicate recovery of the same costs, not a universal guaranteed payment. On competitive effects, the majority defended concurrent revenues; Commissioner Cheryl LaFleur dissented from its reasoning and timing. A fair account should preserve that disagreement instead of presenting administrative approval as moral consensus. [2017-02421][2016-28194]

A separate November proposal sought participation rules recognizing storage characteristics and distributed-resource aggregations. Opening a market and sharing the costs of an asset answer different questions. Our judgment is that responsible utilization must examine both: who may participate, and whose prior claim on service or funding remains. The documents establish neither a particular project's success nor an observed benefit to customers. [2017-02421][2016-28194]

Source documents

  1. Utilization of Electric Storage Resources for Multiple Services When Receiving Cost-Based Rate Recoveryhttps://www.govinfo.gov/content/pkg/FR-2017-02-06/html/2017-02421.htm
  2. Electric Storage Participation in Markets Operated by Regional Transmission Organizations and Independent System Operatorshttps://www.govinfo.gov/content/pkg/FR-2016-11-30/html/2016-28194.htm