Energy storage project restrictions

What are the operational limitations of energy storage?

Operating Limitations: Energy storage resources may be subject to operational constraints that do not affect traditional generation projects. For example, certain battery technologies will degrade more quickly if the state of charge is not actively managed within a certain range.

What are the safety requirements for energy storage technologies?

Safety: Minimum safety and operating requirements are common considerations for energy projects. Energy storage resources present additional safety concerns given their unique technological profiles. For battery storage technologies in particular, safety requirements should adequately address fire risks.

What are the different types of energy storage policy?

Approximately 16 states have adopted some form of energy storage policy, which broadly fall into the following categories: procurement targets, regulatory adaption, demonstration programs, financial incentives, and consumer protections. Below we give an overview of each of these energy storage policy categories.

Are energy storage projects exempt from prevailing wage and apprenticeship requirements?

Two exemptions from the prevailing wage and apprenticeship requirements exist: Smaller-scale energy storage projects (under 1MW of storage capacity) qualify for the 30% bonus rate regardless of compliance with the prevailing wage and apprenticeship requirements.

Are energy storage projects eligible for a refundable ITC?

Energy storage projects owned by taxable entities are not eligible for a refundable ITC, but instead can take advantage of the new transferability rules. The IRA added a provision to permit project owners (other than tax-exempt entities) to make an election to transfer the ITC to an unrelated third party.

Do energy storage projects qualify for a bonus rate?

Energy storage projects (i) not in service prior to Jan. 1, 2022, and (ii) on which construction begins prior to Jan. 29, 2023 (60 days after the IRS issued Notice 2022-61), qualify for the bonus rate regardless of compliance with the prevailing wage and apprenticeship requirements.