Creating a system that disfavors behind-the-meter energy storage does not serve the needs of consumers. Urban consumers are often located far away from the point of generation, meaning they are especially vulnerable in the event of a natural disaster or cybersecurity attack cutting off their supply of electricity. Attempting to place large-scale storage in the center of a city would mitigate this issue, but would be extremely costly due to the need to obtain land that would both be prime real estate and fraught with hidden underground obstacles. In 2014, ConEd estimated a single new substation near Brooklyn and Queens would cost over one billion dollars.
Additionally, behind-the-meter storage allows holistic solutions that encapsulate renewable generation and personal consumption. In 2018, Duke Energy worked with the University of South Florida in St. Petersburg to install a Tesla storage battery in a parking garage that is connected to a solar system on the roof of the garage. The battery can either sell that power back to the grid or power the garage’s elevator, lights and electric vehicle charging stations.
Important requirements from other standards should simply be incorporated into a single, unified standard. Specialized standards that are tailormade for a specific location such as the NYC outdoor guidelines, should not also then incorporate other standards such as UL 9540A as that convolutes the process. Also, the spatial requirements and mandatory clearances certainly need to be reevaluated in light of the practical considerations of a densely populated, already built-up, urban environment.
For any standard to be useful, it must be timely. From a process standpoint, the NFPA standard was first drafted in 2017 and the final standard is expected to be published in 2020. Despite it going through revisions during that period, this is still a significant time delay—which cannot be afforded considering the rapid development of the technology. Similarly, NYC still has not released indoor guidelines after at least two years of development. Until the technology has fully matured, standards should be updated yearly.
Finally, likely the most egregious issue with the current guidelines is the silence as to the likely effects of climate change and increased flooding. DNV GL performed a case study of how much damage another Sandy would do to NYC at three points in the future based on sea level rise estimates from the United Nations Intergovernmental Panel on Climate Change. In all of the simulated future “Sandys,” the flooding reached two or three feet higher in coastal substations meaning a significant increase in damage to critical electrical infrastructure. This is especially concerning considering that Sandy was actually downgraded to a tropical storm before making landfall—meaning far stronger and deadlier hurricanes are actually likelier.
With higher and more damaging flooding likely in the future, storage guidelines need to consider where storage will be allowed and how it will be encased. Depending on the type of battery and chemistry, a battery that is touched by flooding can short and spark—and then continue to burn even when wet. Therefore, if storage is placed in a low-lying area susceptible to flooding, then maybe it needs a waterproof container. However, in the event of thermal runaway, the container needs to be accessible to water or whatever other method is employed to manage the fire. This is a complicated issue that cannot be simply ignored in the storage guidelines.
While safety in densely populated areas is obviously paramount, there must be consideration to the needs of consumers as well. Energy storage is necessary in order for renewable energy to become the future of the United States and also to protect consumers against unnecessarily high utility bills and devasting human losses stemming from power outages. Therefore, the codes and standards that are being drafted and implemented now must keep both the consumer’s needs and safety at the forefront.
We are already surrounded by hazards of which we’ve learned to live. Many homes have natural gas; cars contain flammable gasoline. Storage guidelines need to be ever evolving to provide consumers with a similar baseline of certainty and safety, and yet also acknowledge that risk is a part of living well. The energy storage approval process should be affordable and streamlined. Storage standards should be appropriate to the technology, the urban setting, and the immediate need, as well as to potential future climate change. They should offer choice, instead of regulating to the point of prohibition.