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Comments to Connecticut on Energy Storage and Emissions

The Connecticut Public Utilities Regulatory Authority (PURA) issued a straw program design for electric storage. In January 2021, we submitted comments that support PURA's efforts to make energy storage part of its overarching decarbonization agenda and provide feedback. It is important, as we explain, that PURA take into account the potential emissions consequences of energy storage operations in designing its performance-based incentive.

In September 2022, we submitted joint comments with WattTime to the Connecticut Public Utility Regulatory Authority (PURA) regarding the second year annual review of its energy storage program. Energy storage will be critical as the grid transitions to more intermittent sources and, in the meantime, can offer improved reliability and resilience, as well as an opportunity for emissions reductions. Emissions reductions are possible if the storage is charged with low-emission sources and displaces high-emissions sources when discharged. Ill-timed charging and discharging, however, can lead to increases in emissions. We urged PURA to adopt small changes to its energy storage program that would ensure that its energy storage program reduces emissions as much as possible. We also advised PURA to directly include societal benefits - such as reductions in greenhouse gas emissions and air pollution - in its benefit-cost analysis process.