Romany M. Webb

Distributed Energy Resource Participation in Wholesale Markets: Lessons from the California ISO

Synopsis: The California Independent System Operator (CAISO) aims to “support” and “facilitate” wholesale market participation by aggregations of distributed energy resources (DERs)—solar panels, batteries, and other energy technologies installed in small quantities at scattered locations. This reflect CAISO’s recognition that “[t]he number and diversity of these resources are growing and represent an increasingly important part of the future grid.” However, CAISO has also recognized that system operators can only draw on DERs if they perform reliably, their operation is predictable and transparent, and their contributions are large enough to be economical both to their owners and the grid as a whole. While the aggregation of multiple DERs can support each of these conditions, providing for such aggregation will require adjustments to existing wholesale market rules. CAISO is not alone in recognizing the potential contributions to market performance of aggregated DERs, but it was the first wholesale market operator to begin exploring how to make the adjustments necessary to enable their participation. Similar programs for the aggregation of demand response have existed in markets operated by CAISO and other independent system operators and regional transmission organizations (ISO/RTOs) for several years. Those programs do not, however, allow energy exports to the bulk power grid. To address this limitation, CAISO adopted a new program, which allows DERs to provide energy and ancillary services to the grid. At the time of writing, CAISO’s program had attracted just four participants—DER providers or “DERPs”—none of which had yet begun operating in the energy or ancillary services markets. Meanwhile, the other ISO/RTOs and the Federal Energy Regulatory Commission (FERC or the Commission) that oversees them are following CAISO into the fray. The FERC is considering requiring all ISO/RTOs to adopt their own programs for DER aggregation, which may be modeled on the one currently used by CAISO. Despite this, however, there has been

Policy Readiness for Offshore Carbon Dioxide Storage in the Northeast

Reducing the amount of carbon dioxide in the atmosphere is vital to mitigate climate change. To date reduction efforts have primarily focused on minimizing the production of carbon dioxide during electricity generation, transport, and other activities. Going forward, to the extent that carbon dioxide continues to be produced, it will need to be captured before release. The captured carbon dioxide can then be utilized in some fashion, or it can be injected into underground geological formations – e.g., depleted oil and gas reserves, deep saline aquifers, or basalt rock reservoirs – where, it is hoped, it will remain permanently sequestered (“carbon capture and storage” or “CCS”). Research is currently being undertaken into the possibility of injecting carbon dioxide into the seabed. One study, involving researchers from Columbia’s Lamont-Doherty Earth Observatory, aims to identify possible injection sites in the seabed along the northeast coast of the U.S. It is anticipated that, following identification of suitable sites, a demonstration project will be undertaken to assess the feasibility of offshore CCS. This paper outlines key regulatory requirements for the demonstration project and any subsequent commercial operations.

Protecting Species or Hindering Energy Development? How the Endangered Species Act Impacts Energy Projects on Western Public Lands

Since it was enacted in 1973, the ESA has been one of the most celebrated environmental laws, but also one of the most reviled. Industry groups argue that the consultation process frequently delays and sometimes halts much needed energy, transportation, water supply, and other projects and often dramatically increases project costs. Environmentalists disagree with this view, contending that the process actually rarely stops anything and that the FWS lacks the backbone to impose meaningful conservation requirements that would be costly or inconvenient for the project developer. In 2015, the authors decided to delve deeply into ESA §7 to analyze how it actually works in practice and to assess the validity of various parties’ claims about the consultation process. They focused on the impact of §7 consultation on energy development on public land. This Comment is an overview of that study and key findings. In a nutshell, the authors learned that only a small fraction of energy projects developed on public land are reviewed at all under §7. When it applies, the consultation process appears to go quickly and smoothly for the vast majority of oil and gas projects, for a variety of reasons. On the other hand, consultation on solar energy and wind energy projects tends to be lengthy and complicated.