May 18, 2021
ESA Submits Recommendations on PJM’s Battery Hybrid Resource Proposal
ESA submitted feedback and recommendations today on PJM’s 4/17 version of the Solar Battery Hybrid Resources Proposal. In our comments, we expressed strong support for: (1) the definitions of these resources to operate as a single resource or as two distinct resources; (2) the exemption of hybrid resources from must-offer requirements; and (3) the proposal that would enable solar battery hybrids to provide synchronized and day-ahead scheduling reserves as the default option when these resources are qualified (rather than having to opt-in for this eligibility).
ESA shared two concerns about the Proposal:
- ESA recommended that resources be allowed an annual option to change registration from co-located to hybrid or alter ELCC, rather than restrict a resource’s ability to change registration only once every five years.
- ESA also recommended allowing DC-coupled hybrids to be modeled as capable of operating components independently, since a DC-coupled hybrid can operate subcomponents independently and charge from the grid with bi-directional inverters (“open-loop”).
Lastly, we requested clarification about open-loop hybrids related to energy and ancillary services as well as how market rules differ for closed-loop resources (i.e., resources that cannot charge from the grid) and open-loop hybrid resources.
