IEEE Electrification Magazine - September 2015 - 46

because much of the value of these technologies to the grid
is dependent upon where they are located. In addition, early
studies are demonstrating that the value of individual DERs
may be less than the value that can be captured when the
DERs are evaluated together. In light of these factors, states
are likely to get the greatest benefit from distributed energystorage deployment where it is facilitated through a well
thought-out distribution planning effort. While there is probably no one right approach at this time, the following topics
would be particularly valuable to include in a distribution
planning reform proceeding:
xx
Starting with an assessment of the existing system
capabilities requires utilities to identify locations
where distributed energy storage (and other DERs)
may be most valuable and to develop a method for
sharing this information with customers and developers in a readily accessible format.
xx
Develop a methodology for evaluating the benefits of distributed energy storage so that this valuation can be used
to help determine rates, incentives, and other market
tools to help facilitate optimal siting of energy storage.
xx
Develop rates and tariffs that can provide economic
signals to help direct distributed energy-storage systems to the most beneficial locations.

Oversight of Energy-Storage System Safety
As with any new technology, and particularly ones that
are installed in customers' homes, there is a need for clear
codes and standards that ensure the technology can be
installed and operated safely. The nation's electric, building, and fire codes generally provide the standards for
installations at homes and businesses, and in most places
local government officials are responsible for ensuring
compliance with those codes. When it comes to technologies that are interconnected to the electrical grid, however,
there is an added level of technical review imbedded in
the interconnection standards that are usually overseen
by state public utility commissions.
The question of who is overseeing the safety of these
systems is important to consider. The U.S. Department of
Energy's SunShot Initiative has highlighted the importance of lowering the soft costs associated with permitting
and interconnection for solar PV systems to make them
more cost-competitive. The same scrutiny of the permitting and interconnection process should also be applied to
energy-storage systems to enable these systems to provide economically competitive benefits to both customers
and grid operators.
This does not mean that safety should be ignored or
undermined. Rather, it points to a need to ensure that
such processes are managed efficiently. Thus, when it
comes to ensuring the safety of energy-storage system
installations, regulators should be cautious about imposing duplicative or burdensome safety requirements and
should instead focus on ensuring that the right codes and
standards are in place and that the bodies responsible for

46

I E E E E l e c t r i f i cati o n M agaz ine / SEPTEMBER 2015

overseeing compliance with those codes and standards is
clearly defined.
Since public utility commissions are the state bodies
that will be most closely overseeing the market for energy-storage systems, commissioners may want to ask the
state energy office to facilitate the conversation about
energy-storage safety across state regulatory agencies.
Convening a conversation with the commission, state
code officials, and the energy-storage industry will provide an opportunity to ensure that the necessary safety
requirements are in place and that the authority for
overseeing their compliance is clearly defined so that it
does not have to be duplicated. States can now also look
to the Department of Energy's recently issued guidance
on energy-storage safety for an identification of key
issues for consideration.

The Need for Regulatory Guidance
The potential of distributed energy storage to lower costs
and improve the quality of electric service is considerable.
However, since the market for distributed energy storage
is still emerging, regulatory guidance and proactive policies are needed to ensure a smooth rollout of this technology. State regulators are beginning to explore and take initial steps to address some of the immediate barriers, but
best practices have yet to emerge.
IREC hopes that the ideas presented in this article will
help regulators in identifying the critical steps that need to
be taken in the early stages of addressing the promise-and
the challenge-of accelerating the deployment of distributed energy storage. As states begin to take action, IREC will
continue to keep stakeholders informed about the lessons
learned by other states and will help to identify best practices as they emerge to ease states' learning curves.

Authors' Note: This article is an excerpt from a longer
report available for free at www.irecusa.org. For supporting
citations, please see the full report. The report was prepared
as an account of work sponsored by an agency of the U.S.
government and is based upon work supported by the U.S.
Department of Energy under Award Number DE-EE0005352.
The views and opinions of authors expressed herein do not
necessarily state or reflect those of the U.S. government or
any agency thereof.

Biographies
Sky Stanfield (sstanfield@kfwlaw.com) is an attorney with
Keyes, Fox & Wiedman LLP and represents the Interstate
Renewable Energy Council, Inc. in regulatory proceedings
across the United States regarding energy storage, interconnection, and disturbution system planning.
Amanda Vanega (avanega@kfwlaw.com) is director of
operations at EQ Research. Her areas of expertise
include solar policy, state regulatory and legislative
research, energy-efficiency incentives, and the emerging area of energy storage.


http://www.irecusa.org

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