Comments to the Massachusetts Department of Energy Resources Regarding Whether to Adopt Targets for a Utility Energy Storage Mandate

Clean Energy Group submitted these comments to the Massachusetts Department of Energy Resources (DOER) in support of its consideration to adopt targets for a binding energy storage utility procurement mandate.

Clean Energy Group’s position is that an ambitious utility mandate for energy storage procurement should be adopted, along with regulation to create a robust competitive energy storage market in the state, to provide for multiple social benefits from energy storage, and to guard against negative outcomes from such a mandate.

The following bullets provide a short summary of key points:

• DOER should establish a utility procurement mandate for energy storage.
• Utility procurement targets should be in the 600 MW – 1.16 GW range (assuming the 600 MW to result from other policies and programs is not counted toward utility targets; if that 600 MW is to be counted, then utility procurement targets should add up to the 1,766 MW identified as optimal in State of Charge).
• Utility ownership should be limited, to encourage the development of a vibrant private sector storage market.
• Sub-targets for behind-the-meter and front-of-meter systems should be established.
• Social benefits should be required from utility-owned storage including LMI benefits, resilience, public health benefits, peaker and baseload displacement, and collocation with renewables.
• An ACP mechanism and fund should be established.
• Complimentary policy mechanisms to support storage deployment should be established.
• DOER should consider a consensus process rather than traditional rulemaking, including workshops to explore rulemaking provisions.