On Thursday, February 20, 2014, FERC issued a partial clarification of Order No. 784, the final rule on third-party provision of ancillary services and the accounting and financial reporting for new electric storage facilities (“Order No. 784-A”). The clarification addressed concerns related to transmission scheduling practices required with regard to the provision of reserves, filing requirements, application to non-public utilities, deadlines for implementing data reporting, and how accounting requirements are applied.
Additionally, FERC issued a notice of workshop to be held April 22, 2014, stating that “Staff would like to receive input from interested persons regarding the technical, economic and market issues concerning the provision of Schedule 2 and Schedule 3 services.”
In Order No. 784, released July 13, 2013, FERC revised its regulations to reform its “Avista” policy in order to provide additional rate flexibility for purchasers and sellers of ancillary services, as well as increase transparency and competition in ancillary services markets. FERC provided new means by which sellers can demonstrate a lack of market power in third-party sales of ancillary services in order to obtain expanded market-based rate authority for sales of such services. FERC made requirements for public utility transmission providers to take into account the speed and accuracy of regulation resources in its determination of reserve requirements for Regulation and Frequency Response service, and to post additional Area Control Error (“ACE”) data onto its open access same-time information system (“OASIS”). Additionally, FERC revised its accounting and reporting requirements to add new electric plant and operation and maintenance accounts in order to better account for, and report, transactions associated with the use of energy storage devices in public utility operations. See July 29, 2013 edition of the WER.
Specifically, Order No. 784-A explains that:
- Intra-hour transmission scheduling practices, including both 15-minute and 30 minute scheduling, are sufficient to meet the requirements for sales of Energy Imbalance and Generator Imbalance services;
- The section 205 filing requirement for sales of ancillary services made pursuant to a competitive solicitation applies only to sales not otherwise authorized in Order No. 784;
- Nothing in Order No. 784 is intended to permit transmission providers to limit the quantity or percentage of total reserve obligations of Regulation and Frequency Response service a customer may self-supply;
- Avista has not historically applied to public utility transmission providers and Order No. 784 has not changed this;
- Historical one-minute and ten-minute ACE data must be posted to OASIS by public utility transmission providers by March 24, 2014;
- Account 555.1, Power Purchased for Storage Operations, is intended to include all costs of power purchased for energy storage operations without regard to the classification of the associated energy storage device used in operations; and
- The new accounting and reporting requirements must be implemented as of January 1, 2013 and therefore included in the 2013 forms that must be filed with the Commission by April 18, 2014.
To view the order, click here.
FERC will convene a workshop to obtain additional input on third-party provision of reactive supply and voltage control and regulation and frequency response services. The workshop will be held in the FERC Meeting Room on April 22, 2014. Parties who would like to participate in the program for this event should nominate themselves through the on-line registration form by March 14, 2014. The Commission stated that the proceeding will consider, among other things, the ease and cost effectiveness of relevant equipment upgrades, the need for and availability of appropriate special arrangements such as dynamic scheduling or pseudo-tie arrangements, and other technical requirements related to the provision of Schedule 2 and Schedule 3 services.
For more detail on FERC’s specific questions, view the full notice by clicking here.