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Highly Anticipated FERC Rule Removes Barriers to Electric Storage

On February 15, the Federal Energy Regulatory Commission (FERC) issued a much-anticipated order designed to remove barriers to electric storage resource participation in organized wholesale electricity markets. The order—dubbed Order No. 841—creates new rules that require each regional transmission operator (RTO) and independent system operator (ISO) to revise its tariff to establish a “participation model” consisting of market rules that facilitate the participation of electric storage resources in the RTO/ISO markets. Order No. 841 will make it easier for electric storage resources to participate in wholesale power markets and access the accompanying revenue streams.

Each RTO/ISO must file its tariff changes to implement Order No. 841 within 270 days (i.e., by November 12, 2018). FERC will review the filings and must approve all tariff changes. Each RTO/ISO will have an additional one year from the filing date to implement its new tariff provisions.

FERC defined an electric storage resource as “a resource capable of receiving electric energy from the grid and storing it for later injection of the electric energy back to the grid.” This definition encompasses a variety of technologies including batteries, flywheels, compressed air and pumped hydro. It also explicitly includes resources located on a distribution system or behind the meter, as well as resources located on the interstate transmission grid, and opens the door to participation in RTO/ISO markets for smaller storage resources.


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Trump Administration Imposes Tariffs on Foreign Solar

Yesterday, the US Trade Representative announced that President Trump approved recommendations to impose a safeguard tariff on imported solar cells and modules under Section 201 of the Trade Act of 1974. The tariff will be in effect for the next four years at the following rates:

This tariff is the result of petitions filed in May 2017 by two US solar cell manufacturers at the (ITC under Section 201 of the Trade Act of 1974. The petitions alleged that a global imbalance in supply and demand in solar cells and modules and a surge of cheap imports caused serious injury to the domestic solar manufacturing industry. In September, the ITC found injury to the US solar equipment manufacturing industry and, in October, released its recommendations to the White House to impose tariffs. The President’s final decision was in line with the ITC’s recommendations.The first 2.5 gigawatts (GW) of imported solar cells will be exempt from the safeguard tariff in each of those four years. According to the International Trade Commission (ITC), the United States imported approximately 12.8 GW of solar cells in 2016, which was expected to grow in 2017.

Supporters hope the tariff will encourage increased domestic solar manufacturing. Reports are circulating that a solar manufacturer is considering opening a new module factory in Florida. However, critics of the tariff like the Solar Energy Industries Association (SEIA) say that the tariff will result in a loss of 23,000 domestic jobs this year, including many in manufacturing, and will result in the delay or cancellation of billions of dollars in solar investments. The U.S. solar energy industry currently employs 260,000 Americans in jobs ranging from installation to manufacturing racking systems and inverters. The industry created 1 out of every 50 new US jobs in 2016. According to SEIA, only 2,000 people in the United States are employed manufacturing solar cells and panels.

The tariff is also expected to increase solar module costs, with early estimates predicting an increase of 10 to 12 cents per watt based on current US import prices of 35 to 40 cents per watt.

The US Trade Representative’s press release and fact sheet took clear aim at China, singling it out as a major cause of injury to the domestic solar manufacturing industry: “Today, China dominates the global supply chain and, by its own admission, is looking to increase its capacity to account for 70 percent of total planned global capacity expansions announced in the first half of 2017.” The US Trade Representative also stated that it will “engage in discussions among interested parties that could lead to positive resolution of the separate antidumping and countervailing duty measures currently imposed on Chinese solar products and U.S. polysilicon.” Despite the aggressive rhetoric, the tariff will not be limited to Chinese imports.

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Italian Register for Large PV Plants Closed for 2012

by Carsten Steinhauer

On January 20, 2012, Gestore dei Servizi Energetici (GSE), the publicly-owned company that promotes renewable energy sources in Italy, announced that the budget for the second half of 2012 for large solar photovoltaic (PV) plants has already been used up by excessive demand in 2011. Consequently, there will be no registration procedure for the second half of 2012, and large PV solar plants that have not been registered previously with the GSE will only be eligible for the 2013 feed-in tariff.

The Fourth Italian Feed-In Tariffs system (the so called “Fourth Conto Energia”) established the following budgets for large solar PV plants between June 2011 and December 2012:

  1/06/2011 – 31/12/2011 1st Half 2012 2nd Half 2012


Feed-in Premium Budget 300M 150M 130M 580M Indicative Cumulative Nominal Power 1.200MW 770MW 720MW 2.690MW

In order to ensure the fair distribution of the budgets for 2011–2012, the Fourth Conto Energia introduced a procedure of registration, and subsequent ranking by the GSE of the registered plants for each of the three periods, based on certain priority criteria.

The Fourth Conto Energia affirmed that the budget for the second half of 2012 will be reduced by the excess amount awarded to large PV plants that began operating between June 1 and August, 31, 2011, or registered with the GSE between September 2011 and December 2011. Accordingly, the budget for the second half of 2012 has been reduced to zero, and the GSE will not start the procedure for new registrations.

As a consequence of this development, PV projects that are defined as “large PV plants” that have not obtained a favorable ranking in one of the GSE registers in 2011, or in the first half of 2012, will now only be eligible for the 2013 feed-in tariff. In fact, the GSE has clarified that those PV plants that started operations in 2012 without being ranked in a GSE register will be deemed to have started operations on January 1, 2013, and will therefore obtain the 2013 feed-in tariff for the 20 years starting January 1, 2013.

Unlike the 2012 feed-in premium, the 2013 feed-in tariff will already include the price for the sale of electricity. For, instance, the all-inclusive feed-in tariff for PV plants with nominal peak power above 1 MW will be as follows:


PV Plants Installed on Buildings

Other PV Plants

1000<P<5000 kWp

0.227 /kWh

0.205 /kWh

P>5000 kWp

0.218 /kWh

0.199 /kWh

“Small PV plants” (i.e. <1000 kWp on rooftops / ground mounted <200 kWp using net-metering system / placed on buildings or areas owned by the public sector) are not subject to the budget restrictions and will be eligible for the incentive.

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