BEFORE THE STATE OF NEW YORK DEPARTMENT OF PUBLIC SERVICE PROCEEDING ON MOTION OF THE COMMISSION IN REGARD TO REFORMING THE ENERGY VISION

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1 BEFORE THE STATE OF NEW YORK DEPARTMENT OF PUBLIC SERVICE PROCEEDING ON MOTION OF THE COMMISSION IN REGARD TO REFORMING THE ENERGY VISION CASE NO. 14-M-0101 DRAFT GENERIC ENVIRONMENTAL IMPACT STATEMENT COMMENTS OF THE ENERGY STORAGE ASSOCIATION Respectfully submitted on behalf of the ENERGY STORAGE ASSOCIATION By its Policy Director, Katherine Hamilton 38 North Solutions, LLC 777 North Capitol St, NE Suite 803 Washington, DC December 5,

2 BEFORE THE STATE OF NEW YORK DEPARTMENT OF PUBLIC SERVICE PROCEEDING ON MOTION OF THE COMMISSION IN REGARD TO REFORMING THE ENERGY VISION CASE NO. 14-M-0101 DRAFT GENERIC ENVIRONMENTAL IMPACT STATEMENT COMMENTS OF THE ENERGY STORAGE ASSOCIATION Pursuant to the New York State Department of Public Service ( Commission ) Proceeding on Motion to the Commission in Regard to Reforming the Energy Vision ( REV ) and the associated Draft Generic Environmental Impact Statement ( DGEIS ), the Energy Storage Association ( ESA ) appreciates the opportunity to submit the following comments and information for the Board s consideration. I. INTRODUCTION ESA is supportive of the New York REV process and has provided comments at key points throughout the proceeding. In the matter of the DGEIS, ESA has specific comments on the conclusions the PSC draws concerning the environmental impact of energy storage systems. The opinions stated in this filing represent the views of ESA, not necessarily the views of any individual member of the association. ESA supports the general notion of the DGEIS that on a large scale, the use of storage as part of a larger strategy to increase the responsiveness of demand will facilitate greater 2

3 development of low-carbon energy generation. 1 More troubling are statements such as energy storage devices may result in increased electricity demand from the existing grid, which may result in greater emissions 2, as well as charts and assertions that indicate that energy storage has minimal impact on reducing summer peaks and negative impact on grid-based generation. 3 In fact, energy storage operation data show that these technologies can provide a number of key environmental benefits that need consideration. II. COMMENTS ESA believes that the DGEIS treats energy storage technologies in broad strokes, combining characteristics of widely different technologies into simplified categories. For example, the statement energy storage technologies are designed to store excess electric energy generated during overnight hours when demand is low, as well as energy from intermittent resources. The stored energy can be released and used during peak demand hours 4 ignores the use of storage for fast regulation and spinning reserves, where storage can reduce the overall procurement of regulation resources and can enable generation to operate more efficiently, with lower emissions per megawatt hour of output. ESA recommends that the PSC provide consistency in analysis such that all resources generation and distributed--are evaluated with the same underlying assumptions. Another benefit that does not appear to be taken into consideration in the DGEIS is the 1 Draft Generic Environmental Impact Statement In CASE 14-M Reforming the Energy Vision and CASE 14-M Clean Energy Fund, October 24, 2014, page Ibid. 3 Ibid, page ES-5. 4 Ibid, page

4 avoidance of transmission and distribution ( T&D ) losses. A storage resource located in a congested area will avoid on-peak T&D losses that could be roughly equal to its round-tripefficiency losses. In such a case, the emissions-reduction potential for the energy storage system would come down to a straight comparison of the emissions associated with the charging energy compared to those of the avoided peaking generation. The report does acknowledge that because the simplifications in the analysis are more likely to under-value the avoided costs for all resources, particularly those that operate for relatively short periods of time to offset very expensive peak power needs, it is anticipated that even those resources with positive net costs [like storage] represent viable contributions to the peak reduction alternatives. 5 ESA recommends that the PSC consider the entire range of benefits that energy storage technologies can bring to the system. Relative to the chart in the report of environmental impacts 6 that indicates negative impacts noted for storage in Land Use and Biological Resources and Water Quality, it should be noted that these impacts may be associated with pumped hydropower but are not relevant or applicable to compressed air energy storage, batteries, or flywheels. ESA recommends that those technologies be more specifically identified rather than combined into one category of impacts. An Indian Point Contingency Plan impact statement developed by the PSC in July of 2013, asserted that, for battery energy storage, cumulative impacts would be negligible 7 based on geographic location and avoided impact on urban and residential communities. 5 Draft Generic Environmental Impact Statement In CASE 14-M Reforming the Energy Vision and CASE 14-M Clean Energy Fund, October 24, 2014, page Ibid, Exhibits ES-3, page Indian Point Contingency Plan Draft Generic Environmental Impact Statement, New York State Public Service Commission, July 2013, page

5 Energy storage technologies produce no new emissions and are able to respond rapidly and dynamically to ensure efficient use of electricity when it is needed the most, regardless of the energy source. To that end, ESA submitted comments on December 1, 2014, to the draft 111(d) rule, Clean Power Plan, issued by the U.S. Environmental Protection Agency (EPA). ESA made the point in every Building Block that energy storage should be considered as a carbon mitigation tool for state regions. Those comments are included as Attachment A to this filing. These comments explain and document case studies and operational data that can serve as evidence to the PSC that advanced energy storage has a positive rather than negative impact on reducing greenhouse gas emissions, no matter the charging generation source and application on the grid. ESA recommends that these comments be taken into consideration when finalizing the DGEIS. VII. CONCLUSION ESA is generally supportive of the REV process and looks forward to serving as a resource to the Commission and staff. We urge the PSC to take the above recommendations into consideration when finalizing the DGEIS to more accurately and appropriately characterize the significant environmental benefits of energy storage systems. These technologies have an important role to play in enabling the clean distributed system that the REV process seeks to incentivize. In addition, ESA would like to associate with comments provided to the PSC by the New York Battery and Energy Storage Technology Consortium (NY-BEST). ESA appreciates the opportunity to offer recommendations in this case and looks forward to continuing to work with the Commission, staff, and the stakeholder process by offering additional comments or testifying before the Commission as the REV is enacted in New York. 5

6 Respectfully submitted on behalf of the ENERGY STORAGE ASSOCIATION By its Policy Director, Katherine Hamilton 38 North Solutions, LLC 777 North Capitol St, NE Suite 803 Washington, DC

7 ATTACHMENT A BY U.S. Environmental Protection Agency EPA Docket Center (EPA/DC) Docket ID No. OAR , Mailcode 28221T 1200 Pennsylvania Avenue, N.W. Washington, D.C Re: Energy Storage Association ( ESA ) Comments in Docket ID No. EPA-HQ- OAR Dear Administrator McCarthy: The Energy Storage Association ( ESA ) greatly appreciates the opportunity to present Comments to the United States Environmental Protection Agency ( EPA ) regarding EPA s Proposed Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units (the Proposed Rule ). I. ABOUT THE ENERGY STORAGE ASSOCIATION The ESA is an industry association that was established over 25 years ago to foster development and commercialization of energy storage technologies. Since then its mission has been the promotion, development and commercialization of competitive and reliable energy storage delivery systems for use by electricity suppliers and their customers. ESA members represent a diverse group of entities, including electric utilities, energy service companies, independent power producers, research institutions and technology developers involved with advanced energy storage. ESA members are committed to advancing 7

8 the state-of-the-art in energy storage solutions. See Attachment 1 for a full list of ESA members. The opinions stated in this filing represent ESA, not necessarily the views of any individual member of the association. ESA engages in regulatory, legislative and policy efforts and includes among its membership leaders in the energy storage marketplace. Member companies have firsthand knowledge of the regulatory challenges that need to be overcome to finance and operate commercial-scale energy storage facilities and are working to promote the development and commercialization of competitive and reliable energy storage systems within the United States. ESA looks forward to serving as a resource to EPA as the Clean Power Plan is finalized and the rule implemented. II. BACKGROUND ESA believes that energy storage technologies and applications can provide greenhouse gas emission reductions in each of the four Building Blocks proposed by EPA. Energy storage technologies produce no new emissions and are able to respond rapidly and dynamically to ensure efficient use of electricity when it is needed the most, regardless of the energy source. Storing energy creates system-wide benefits for the electricity grid, building greater efficiency, smoothing demand, and optimizing grid performance giving planners and grid operators a powerful tool to increase reliability and create a more flexible platform to deploy even greater amounts of carbon-free generation. 8

9 Storage reduces the need for additional transmission and distribution system upgrades and fossil-based peaking plants. 8 Because energy storage systems can be sited nearly anywhere on the grid, energy load and supply can be managed effectively at both the transmission and distribution level, and system planners can relieve congestion and avoid the need for expensive grid infrastructure upgrades to manage peak demands. The Energy Information Administration ( EIA ) projects that approximately 40 gigawatts of peak generation will be needed over the next 15 years (see Figure 1). Current planning for peak capacity is often limited to fossil fuels; ESA believes that this poses an opportunity for energy storage to fill that role. Storage enables strategies like peak time shifting, demand response, and microgrid islanding replacing inefficient peak generation on the system and avoiding time of use rates and demand charges. Figure 1. EIA Graph of Peak Generation Needs 8 In Presidio, Texas, for example, a utility scale battery was installed to defer transmission backup on an aging and unreliable radial line: 9

10 ESA believes that as we move to a lower carbon future, energy storage will be a key tool throughout the electric grid from increasing the efficiency of current power plants, to reducing the need for additional generation, to easing the integration of cleaner resources, and to providing a distributed energy tool for states. III. KEY POINTS In determining how energy storage can fit into the Clean Power Plan, the following points should be considered: Energy storage can provide solutions in all four buckets. Energy storage increases the reliability of the system as a whole. Energy storage when deployed throughout the grid can avoid emissions and reduce overall emissions on the system. Energy storage technologies provide both capacity and location flexibility, allowing for use where services are needed most on the grid. Numerous ownership models for energy storage ensure that technologies are competitively procured and deployed on the system, whether through utility rate base or independently owned. States should be able to use energy storage to develop their plans and help meet their emissions goals established in the rule. IV. BUILDING BLOCK 1: Power Plant Efficiency Improvements Energy storage can enhance the capacity factor and efficiency of existing power plants by enabling higher productivity, more efficient ramping, and even providing black start capability, 10

11 allowing these plants to operate more efficiently and mitigating the increases in O&M and downtime from having to supply ancillary services. The PJM Independent Market Monitor submits that coal units on average provided only 15.5 percent of regulation in This is a significant decline from the 30.1 percent of regulation provided by coal units in Coal and other traditional generators simply cannot be used most effectively to manage variability and provide regulation services to the grid; energy storage is particularly adept at responding quickly and with high degree of accuracy in ways that other generators are unable. Energy storage has near-instantaneous response time and is able to follow grid signals more accurately than traditional resources. The California Energy Storage Alliance released a white paper, Energy Storage a Cheaper, Faster, & Cleaner Alternative to Conventional Frequency Regulation, that analyzes several case studies that demonstrate that even with frequency regulation services, energy storage can reduce CO2 emissions by displacing fossil fuel plants and enhancing integration of renewable energy resources. 10 Figure 2 illustrates how valuing speed and accuracy in the market with a fast-responding grid signal leads to an almost immediate reduction in regulation requirement. Traditionally this role would be filled by fossil generation with limited flexibility, systems that can take minutes rather than fractions of seconds to respond. With energy storage, current power plants can run at peak efficiency, and variability between supply and demand can be efficiently and accurately managed. 9 State of the Market Report for PJM, March 13, 2014, page 299: 10 Energy Storage a Cheaper, Faster, & Cleaner Alternative to Conventional Frequency Regulations, Strategen, February 16, 2011: 11

12 Figure 2. Fast Responding Storage Reducing Ancillary Demand 11 By creating a more competitive marketplace that rewards performance, commercial energy storage systems are already demonstrating cost-savings and emissions reductions in PJM. Beacon Power s Stephentown, NY project is a 20-megawatt flywheel energy storage plant that has been providing frequency regulation services to Independent System Operator New England since June 2011 along with an estimated 82% reduction in CO2 emissions over its lifetime compared with a traditional power plant. 12 Using fast-responding energy storage to manage variations in load and demand across the grid in milliseconds rather than minutes makes best use of electricity from all types of generation, regardless of where the storage system is deployed. This allows for more efficient operation of the grid s existing coal-fired assets, and when 11 Chart from PJM as cited in article: Recovery Act Projects That Are Changing America report, September 2010, page 24: 12

13 combined with solutions like demand response and broader energy efficiency programs, we would expect compounded results. 13 Energy storage allows for more efficient operation of existing plants providing actual emissions reductions as Alevo has found in analyzing battery performance in conjunction with coal plants. 14 In their statement launching a manufacturing plant in North Carolina, Alevo states, coal plants like to run within a narrow operating band. If you ramp the plant up and down to meet changes in demand, it operates less efficiently, costs more and emits more greenhouse gas. By using batteries to meet those variations in demand, a utility can keep its coal plants running only at optimal speeds and thus reduce costs and emissions. 15 In a presentation in May 2014 to the White House Office of Management and Budget, Alevo described a simulation with Western Electricity Coordination Council ( WECC ) that featured energy storage co-located with coal plants. In this study, coal plants with capacity factors of 70% increased to an average of 85% with the addition of energy storage to offset ramping, peak capacity, and reserve requirements. 16 Energy storage companies like Alevo continue to develop and deploy cost-effective technologies that can reduce greenhouse gases from fossil fuel resources while ensuring the grid remains stable with increased penetration from renewables. V. BUILDING BLOCK 2: Redispatch 13 Combination of energy storage with demand response yields benefits greater than both, Valuing Storage in RPM, July 2, 2014,slide 18: item-04-esa-presentation.ashx. 14 Information on Alevo greenhouse gas reduction technology can be found here: 15 Alevo website: 16 GHG Reductions Through Energy Storage, Alevo, May 6, 2014: 13

14 The second building block is focused on increased utilization of natural gas to replace the capacity of retiring coal-fired generation. Energy storage technology is able to not only enhance the capacity factor and efficiency of fossil generation, but by storing and releasing energy when the grid needs it most it can replace most inefficient peaking capacity all together. While ESA identifies broad system-wide efficiency, energy storage can specifically augment the output of natural gas turbines through thermal energy technology. Turbines are rated at sea level and intake temperatures of 68 degrees Fahrenheit, impacting their use regionally and seasonally. When temperatures rise in the summer, turbine capacity factor is reduced because of lower air density - as much as 15-20% of rated capacity. 17 Higher ambient temperatures also increase load from air conditioning, HVAC systems, and refrigeration. TAS (Thermal Air Systems) found that by storing energy in the form of chilled water during off-peak and low demand hours, and injecting chilled air into turbine inlets with the fuel, gas turbine output increased from 86% to 104% of their rated capacity. 18 Energy storage can also substitute for spinning reserves entirely, thus reducing the need for additional peaker plants and preventing increased CO2 emissions. Energy storage creates system-wide efficiency, enabling more efficient ramping of existing plants, smoothing integration of renewable energy facilities, and shifting of peak load to off peak hours (see Figure 3), all of which increase the efficiency of the entire system. These values are provided wherever a storage system is installed on the grid, whether at the transmission or distribution level. 17 Effects of Ambient Temperature on the Performance of Gas Turbines Power Plant, IJCSI, 2013: 18 Combined-Cycle Cogeneration Power Plant, TAS Project Profile: Cycle%20Cogeneration%20Power%20Plant%20Project%20Prof...pdf. 14

15 Figure 3. Energy Storage for Peak Shaving Chet Lyons of Energy Strategies Group recently published a paper titled Guide to Procurement of Flexible Peaking Capacity: Energy Storage or Combustion Turbines? making the case that most of the peaking capacity projected by EIA can be provided by energy storage. 19 Lyons states, by providing energy balancing services at both a regional (transmission) and local (distribution) level with the same storage asset, the locational value and capacity utilization of storage can be much higher compared to CTs [combustion turbines] interconnected at transmission voltage and operated as a central station resource. 20 The paper makes the argument that flattening system load with energy storage synergistically reduces the need for all major categories of utility asset investment, including generation, transmission, and distribution. In Arizona, the utility Arizona Public Service agreed on a settlement to include energy storage in the planning and procurement process as a replacement for additional peak capacity, 19 Lyons, Chet. Energy Strategies Group. Guide to Procurement of Flexible Peaking Capacity: Energy Storage or Combustion Turbines? 20 Ibid, page 1. 15

16 recognizing the ability of storage to provide peaking services comparable to natural gas. 21 In another case, Southern California Edison awarded energy storage over 260 MW of capacity in their Load Capacity Requirements Request for Offer. 22 This decision that only required 50 megawatts of storage in the LA Basin but ended up in the purchase of 260 megawatts of energy storage was further affirmation that not only can energy storage provide these services, but can do so cost-effectively in a competitive procurement process. VI: BUILDING BLOCK 3: Nuclear and Renewable Energy storage allows for fuel and resource diversity and enhances the integration of renewable resources by supporting renewable energy during periods when variable resources like wind and solar are not available. A study by Carnegie Mellon in October 2008 estimated that 20% of the CO2 emission reduction and up to 100% of the NOX emission reduction expected from introducing wind and solar power will be lost because of the additional ramping requirements these resources impose on traditional generation. 23 Storage provides the flexibility to integrate renewables into the electric grid without consuming additional fossil fuels needed to meet the ramping requirements of renewable energy generation resources. While generating resources can only inject power into the grid, energy storage provides the ability to either inject or absorb power, allowing variable resources to be used more efficiently and effectively. Energy storage technologies are resource-neutral, taking a charge 21 Settlement with Arizona Public Service and RUCO: 22 SCE Load Capacity Offer results here: IpZE7IX0RJooejB-v5jgUdzbJG8mK7zohZ_CK47hGe9TuH6yV0PFBSV2t- UmTwzIcVaY0sA1agaXGeDHEf71z8KvkX2tFpBklkp2YKS1BufHk9GdllkqF6AtTFk1YNu1EixbHByRBL4LK08 -bj0ij5s3_aa9eq!!/dl4/d5/l2dbisevz0fbis9nqseh/. 23 Katzenstein, W., and Jay Apt. Air Emissions Due To Wind And Solar Power, Environmental Science & Technology, 2009, pages

17 from any resource on the grid and releasing the charge to off-set the units with less efficiency, providing double the nameplate capacity as traditional grid resources as they can absorb and release power. In many cases, these charging windows of maximum grid efficiency will absorb more and more renewable supply, as variable resources operate at highest capacities at these times. Energy storage can be considered a flexible capacity resource that provides both injection and absorption of energy, as in Figure 4. Figure 4. Energy Storage as Flexible Capacity as Compared with Gas Peaker While ESA does not take the position that energy storage is required for integration of renewables, energy storage can enhance the capacity and enable increased utilization and additional deployment of renewables. In Compensating for Wind Variability Using Co-Located Natural Gas Generation and Energy Storage, Hittinger, Whitacre and Apt find that the use of energy storage to smooth the sharpest fluctuations, allowing a gas turbine to provide the remaining fill-in energy, is a cost-effective application. 24 In addition, a report by DOE and EPRI from 2013 supports the concept of using storage to balanced fluctuations in RE generation 24 E. Hittinger, J.F. Whitacre and J. Apt, Compensating for Wind Variability Using Co-Located Natural Gas Generation and Energy Storage. Energy Systems, (4), pages

18 output. 25 Another example of renewables coupled with energy storage is in the case of Concentrating Solar Power (CSP), a set of technologies that uses mirrors to concentrate the sun s thermal energy to produce steam to a turbine that generates electricity. CSP combined with thermal energy storage allows that electricity to be stored and used later for grid operators, providing a flexible dispatchable resource. These facilities, such as the Ivanpah BrightSource Energy concentrating solar power project in California 26, generate large quantities of renewable electricity that can be stored as thermal energy, then used as baseload, providing price, fuel, and operational stability to utilities and grid operators. VII. BUILDING BLOCK 4: Demand Side Energy storage enables distributed energy resources to operate more effectively and efficiently, allowing for more efficient energy use and lowering the resulting net carbon emissions. Distributed energy storage can support higher penetrations of distributed renewable generation by transforming as-available renewable resources into fully dispatchable assets, maximizing their value on the grid by delivering energy when its most valuable to the system (e.g. during peak periods). This can reduce demand on power plants and spinning reserves, but also reduces line losses from transmission. While producing electricity at the point of demand is potentially the most efficient solution for the grid, energy storage can play an important role in facilitating higher penetrations of distributed resources. Energy storage technologies on the demand side include substation and community level resources as well as behind-the-meter 25 Link to report: 26 Ivanpah website: 18

19 applications (thermal as well as battery storage). Solar City 27 and Solar Grid Storage are two companies that are making investments in and currently offering demand side energy storage solutions. A report by Rocky Mountain Institute analyzed the point at which solar plus storage becomes cost effective for consumers to even opt out of being connected to the grid altogether. 28 ESA is not suggesting grid defection, but the report is instructional in citing the continued downward trajectory of pricing for energy storage demand side applications. An additional value for energy storage on the demand side is its ability to facilitate consumer participation in demand response programs, key tools for addressing peak demand and reducing reliance on carbon emitting peaker plants. Energy storage can serve to eliminate the opportunity cost associated with participating in demand response events, potentially greatly increasing consumer ability to participate in these programs. Further considerations of using energy storage on the demand side include: energy storage allows for alignment of load with optimal fleet dispatch and reduction in the need to build additional conventional peaking capacity; adding energy storage to distributed generation can mitigate the impact of high penetration of solar rooftop PV, making distributed generation more cost effective and reducing the costs for network upgrades; demand side energy storage is able to serve a similar role as supply side resources in ancillary services markets and demand response programs; energy storage can reduce the need for diesel generation backup power for grid reliability. Most importantly, the combination of these characteristics should be considered when assessing the potential value of including energy storage in the grid. 27 Solar City offers residential and commercial energy storage solutions: Rocky Mountain Institute, The Economics of Grid Defection, June 2014: 19

20 VIII. STATE IMPLEMENTATION PLANS Based on experiences with state policies in Arizona, New York, and California, energy storage should be an intrinsic part of the energy mix and the state implementation plans. ESA can work with state agencies and clean energy stakeholders to assist in embedding energy storage into those plans in a way that meets the criteria set forth for reliable, cost-effective, clean technologies. Several credible third parties have studied the energy storage market that continues to grow with states increasingly choosing to incentivize storage applications. Pacific Northwest National Laboratory published a National Assessment of Energy Storage for Grid Balancing and Arbitrage 29 ; the National Renewable Energy Laboratory published The Value of Energy Storage for Grid Applications 30 ; Electric Power Research Institute published a study on costeffectiveness of energy storage in California 31 ; and several independent consultancies like Navigant 32 and DNV GL have also issued reports on energy storage. In comments to EPA submitted by the Solar Energy Industries Association (SEIA), SEIA states that: the use of solar storage affects the calculation of carbon emission reductions. With thermal energy storage, solar energy is able to displace EGUs operating at the margin during non-peak hours, and even potentially cut into base load EGU supply. With the development of all types of storage, solar can substantially displace natural gas and coal EGUs, and play an even more significant role in reducing carbon emissions. Any methods used to quantify the carbon emission reductions from solar must be able to account for solar storage. This poses a problem for those models and methods that use resource availability (i.e. sunlight) as the assumed proxy for solar energy generation but 29 National Assessment of Energy Storage for Grid Balancing and Arbitrage, PNNL, June 2012: 30 The Value of Energy Storage for Grid Applications, NREL, May 2013: 31 Cost-Effectiveness of Energy Storage in California: Application of the EPRI Energy Storage Valuation Tool to Inform the California Public Utility Commission Proceeding R , June 2013: 32 Navigant Energy Storage Research can be found on: 20

21 should not be difficult for dispatch models and other approaches that rely on plant operating characteristics. 33 Given the recognition that solar coupled with storage in behind the meter applications is already being deployed and can have additive impacts on reducing emissions, ESA recommends that methodologies be developed for states to account for benefits provided by storage that increase solar utilization and offset additional carbon emitting resources. The first phase of The California 2030 Low-Carbon Grid Study (LCGS) found that the California electric sector could reduce greenhouse gas emissions (by 2030) more than 50% below 2012 cost-competitively and reliably with a combination of renewables, energy efficiency, optimized natural gas generation, and flexible resources like energy storage. 34 Hawaii and Texas have looked closely at energy storage to resolve issues with managing high penetrations of renewables on their essentially islanded grids. ESA is ready to assist state agencies to collaborate with industry and third party resources to develop and use appropriate models when considering energy storage as a key component to their greenhouse gas reduction strategies. IX. ADDITIONAL CONSIDERATIONS In addition to including energy storage solutions in all of the Building Blocks and in the state implementation plans, ESA recommends that EPA and the states periodically revisit the applications and models in the plan to account for new technologies and improved valuation curves. While energy storage has been shown to be cost-effective in many situations already, ESA fully expects those costs to continue to come down with additional scale. According to market research firm IHS, energy storage growth will explode from.34 GW in to 6 33 Comments by Solar Energy Industries Association to EPA, page The California Low-Carbon Grid Study (LCGS), Phase 1 Results, September

22 GW by 2017 and over 40 GW by This growth will lead to significant scaling, increased manufacturing, and decreasing costs of development. In addition, continual research by the Department of Energy (DOE) and the private sector will lead to lowered costs for technologies, increased benefits and additional value streams as technologies are further demonstrated and deployed. ESA also agrees with evaluating solutions based on technological and economic potential; energy storage would fit well into that mode of analysis. In fact, accounting for development and deployment of storage will serve to strengthen the methodology EPA chooses that in turn affirms the ability for energy storage to impact all four building blocks set forth in the rule. X. CONCLUSION ESA appreciates the opportunity to comment on EPA s Clean Power Plan and is hopeful that energy storage will be included throughout the building blocks as a solution that can lower the greenhouse gas emissions of existing power plants; reduce the need for future generation build out; enhance the ability for variable and cleaner resources to be increased; and provide a distributed energy tool for state and local carbon reductions. ESA looks forward to continuing to work with EPA and to serve as a resource as the rule is made final and implemented. Respectfully submitted. ENERGY STORAGE ASSOCIATION Katherine Hamilton, Policy Director th Street, NW, Suite 500 Washington, DC k.hamilton@energystorage.org The Future of Grid-Connected Energy Storage report, HIS, December 2013: 22

23 Corporate Members (87) 1Energy Systems, Inc. 24M Technologies, Inc. ABB, Inc. AES Energy Storage AltaLink Ambri American Vanadium Amperex Technology Limited Aquion Energy ARPA-E Argonne National Laboratory Axion Power International, Inc. Beacon Power LLC. Black &Veatch Corporation Bosch Energy Storage California ISO CALMAC Manufacturing Corporation CODA Energy, LLC. Customized Energy Solutions DNV GL Energy Duke Energy Dynapower Company LLC EaglePicher Technologies, LLC. East Penn Manufacturing Co., Inc. Energy and Environmental Economics, Inc. Energy Power Systems, LLC EnerSys EnerVault Corporation Eos Energy Storage EPRI Exelon Generation FIAMM FirstEnergy Service Company GE Energy Storage Greensmith Energy Management Systems HDR Engineering, Inc. Highview Power Storage Hitachi Chemical Co. America Hydrogenics Corporation Hyosung Corporation Ice Energy Imergy Power Systems INABENSA Nubenergy Wind Energy Institute of Canada Attachment 1 ESA Members (October 17, 2014) INGETEAM INC. Innovation Core SEI, Inc. K&L Gates Kilpatrick Townsend & Stockton LLP Landis+Gyr LG Chem Power MCV Energy Systems, Inc. Mitsubishi Electric Power Products, Inc. Morrison & Foerster LLP Nation-E National Rural Electric Cooperative Association (NRECA) Navigant Consulting NEC Energy Solutions NextEra Energy Resources, LLC. NGK Insulators, LTD. Oncor Pacific Northwest National Laboratory Panasonic Parker Hannifin Energy Grid Tie Division Pierce Atwood LLC PJM Interconnection, LLC Prudent Energy Corporation Public Service Co. of New Mexico Recurrent Energy RedFlow Limited RES Americas S&C Electric Company Saft America, Inc. San Diego Gas & Electric Sandia National Laboratories SkyPower Services Southern Company Steffes Corporation Stoel Rives LLP Strategen Consulting, LLC SunEdison, Inc. SustainX Sutherland Asbill & Brennan LLP TAS Energy Temporal Power Ltd. UniEnergy Technologies ViZn Energy Systems Younicos Inc. ZBB Energy Corporation Individual Members (20) Individuals/Students John Goatcher Glenn Skutt Richard Baxter, Mustang PrairieJeff Blais, Independent Consultant John Boyes, John Boyes Consulting Bill Capp, Grid Storage Consulting James M. Eyer, E&I Consulting Pete Hamilton, Better Energies, LLC William V. Hassenzahl, Advanced Energy Analysis Darrell Hayslip, Narrow Gate Energy, LLC Udi Helman, Independent Consultant Michael Kepros, Kepros Battery Consulting Matt Lazarewicz, Energy Storage Solutions, LLC. Robert Lockhart, Acuity Power Group Bob Mango, Independent Consultant Jeff Pierson, Bethesda Capital LLC Anthony Price, Swanbarton Limited Charles Ricker, Ricker Strategic Advisors William Riley, Aquifer Based Hydroelectric Systems Susan Schoenung, Longitude 122 West, Inc. Jim Staudt, Andover Technology Partners H. Chandler Williamson, HCW Consulting Associate Members (14) Companies Advanced Emissions Solutions CARNOT 2G, Inc. Eneridge, LLC Halotechnics ICL Industrial Products Microvast Power Solutions National Electrical Contractors Association (NECA) North Carolina Sustainable Energy Association (NCSEA) Carl Williams Zach Taylor 23