Comments on: The Energy Storage Story

By: Matthew Shapiro

Matthew Shapiro — Thu, 02 Dec 2010 05:02:33 +0000

Jim – thanks for this. I’d agree with the interpretation that unless the Gravity Power project was to use surplus water from a federal dam for its charging, or be located on public lands, then it would indeed be exempt from FERC regulation.

By: Jim

Jim — Thu, 02 Dec 2010 01:06:04 +0000

Here are the requirements for FERC jurisdiction:

Unless a project has a valid pre-1920 federal permit, non-federal hydroelectric projects are subject to the Commission’s jurisdiction if:
1. The project is located on navigable waters of the United States.
2. The project occupies public lands or reservations of the United States.
3. The project utilizes surplus water or waterpower from a federal dam.
4. The project is located on a body of water over which Congress has Commerce Clause jurisdiction, project construction occurred on or after August 26, 1935, and the project affects the interests of
interstate or foreign commerce.

Since the Gravity Power Module does not fall under any of these categories, it seems unlikely it will be subject to FERC regulation.

By: Jim

Jim — Wed, 01 Dec 2010 23:49:48 +0000

Here are FERC’s guidelines for jurisdiction determination:

Unless a project has a valid pre-1920 federal permit, non-federal hydroelectric projects are subject to the Commission’s jurisdiction if:
1. The project is located on navigable waters of the United States.
2. The project occupies public lands or reservations of the United States.
3. The project utilizes surplus water or waterpower from a federal dam.
4. The project is located on a body of water over which Congress has Commerce Clause jurisdiction, project construction occurred on or
after August 26, 1935, and the project affects the interests of interstate or foreign commerce.

Since the Gravity Power Module does not fall under any of these categories, it seems unlikely that FERC regulation applies.

By: Chris

Chris — Wed, 01 Dec 2010 18:38:24 +0000

Matthew, no, we’ve not inquired for a ruling or judgement from FERC. The U.S. will be most likely not be an early adopter of the GPM technology from what we’re seeing, thus the FERC Licensing process does not concern me that much in terms of our business plan. Good point though for U.S.-focused developers.

By: Matthew Shapiro

Matthew Shapiro — Tue, 30 Nov 2010 21:10:30 +0000

Are you absolutely sure that FERC will exempt you from its licensing rules? Remember that even closed-loop pumped storage projects that have no impact on waterways fall under FERC regulation (even though they shouldn’t) – simply because they (a) involve water, and (b) affect, directly or indirectly, interstate commerce. You will need to prove to any investors that FERC will agree to let you off the hook – and if they do, then every developer of a closed-loop pumped storage project will also sue to get off the hook. So it’s a bit of a can of worms there. You may have already consulted with FERC on the question, of course, but it won’t be tested until you begin development on a particular site. I don’t see anything come up in the FERC archives on Gravity Power, so I’m assuming you have not asked for an official ruling from them yet.

By: Chris

Chris — Tue, 30 Nov 2010 14:17:36 +0000

Matthew,

Good comments. Gravity Power uses the proven principles of PSH, but eliminates the traditional issues of siting, environmental permitting and the long lead time and huge capital to revenue. It is a totally closed system, mostly underground, save for the powerhouse – which is at ground level, and can provide anciallary services and eventually, peaker plant services (better than open cycle gas turbines someday). As each GPM comes on line, each starts to produce revenue and modules in close proximity act to amortize many elements of the construction process. This installation process, once staged at an appropriate site, takes months, not a decade and does not require a billion $ or more. Gravity Power also does not need a new factory (batteries and flywheels do) to begin installing its modules globally (key partnerships). Also, done correctly, Gravity Power Modules will have a life more equivalent to PSH – which, as you have mentioned, is nothing like one can or should reasonably expect from batteries. The third next story from David will contain the details…..

By: Matthew Shapiro

Matthew Shapiro — Tue, 30 Nov 2010 03:44:30 +0000

I’m glad the article alluded to the lifetime issue when making comparisons. I have seen figures of potentially 15 years for batteries (remains to be seen), whereas pumped storage can last for 50 years, maybe 100. I would also note that pumped storage technology has not been static, but has been advancing as well; there are new designs (particular the adjustable speed variety) that can respond extremely quickly to grid fluctuations and even compete with batteries on the speed front. But they are challenging to site. So the “porfolio” concept is probably most fruitful: every approach has a fit – from “demand response” on the user side to batteries and flywheels in the short-term response to CAES and pumped-storage (where sitable) on the longer storage value.

By: David Anthony

David Anthony — Sun, 28 Nov 2010 16:45:17 +0000

Dear Abhi, same comment as put to Eric; if there are better, verified numbers, let’s discuss them openly. As for your comment that there are a number of companies on the verge of breaking through the distributed energy storage game, that would be a very good thing. But this is not necessarily Gravity Power’s proposition, the proposition of mainstream PSH or CAES, nor is it the proposition of RUBENIUS’ energy warehouses. In my line of business, there are always several companies just about ready with the breakthrough/epiphany; most fail. Having players like GE involved is only a good thing. David

By: David Anthony

David Anthony — Sun, 28 Nov 2010 16:40:58 +0000

Eric, you are correct that I hint at Gravity Power providing a solution that has vexed the industry to date; this being a true, grid-scale energy storage technology that can be sited flexibly, not entail hundreds of millions or even billions of USD investment in factories or reservoirs and penstocks and many, many years to revenue and one that lasts as long as industry demands. I quoted the 2009 EPRI battery numbers, which may or not be the most recent, publicly available and accepted numbers. If you or the experts you speak of have better/newer numbers, let’s by all means discuss them openly. You are correct; I “might” be less than informed…..This is a war to find a viable economic solution to a major problem globally and I am in this daily. Your own article and public releases on NAS, including those regarding RUBENIUS, whom you wrote about in October: http://www.greentechmedia.com/articles/read/4-billion-1-gigawatt-energy-storage-warehouse/, show functional solutions yes, but at costs that are at least in equivalent to EPRI’s numbers I sited. If my and EPRI’s math are wrong and the economical production capacity exists to supply several GW of grid-scale energy storage from batteries that last 20 – 30 years, then let’s openly compare solutions. If Li-Ion is suitable from a cost and life (and safety) perspective, then it should be being widely deployed in Ancillary Services now; as there is a readily verifiable market today (e.g., Frequency Regulation).

By: James

James — Thu, 25 Nov 2010 13:28:07 +0000

John, for flow batteries like ZBB, there are commonly two costs associated with them, as they separate out cost of capital per kW and the cost/kWh. To compare solutions apples to apples, one needs to account for the all-in costs, which Mr. Anthony was doing on a fair basis. To Eric and Abhi, batteries will likely never be suitable for true, grid-scale storage. NaS is way too expensive, even higher “all-in” than the EPRI numbers listed. This is readily available public information and Eric has written about this before, so his comment surprises me. Li-ion (very expensive on a $/kW basis) can provide Regulation and so can flywheels; I’d suggest a better fact-check by the both of you on the suitability (cost, life, safety, etc.) before making such critical statements. For the power market like Regulation, it is the cost/kW that matters (not energy on a $/kWh basis). Li-Ion won’t last for decades without replacement. So, PSH works, batteries work, flywheels work – the point is finding something that works the best for utilities, project developmers, the environment, customers and investors…provide better facts and discuss them openly.