Federated Battery Grid-Services Tariff

Program announcement · source context

The Hawaiʻi PUC’s VPP design proceeding is an active policy context, not a final tariff. Its opening material discusses remote dispatch, performance compensation, customer-sited batteries and flexible devices. Hawaiian Electric’s customer-resource reports also show a substantial enrolled base while warning that export-only analysis does not measure all behind-the-meter behavior.

Sources: Order 42488 — VPP design proceeding (Hawaiʻi PUC) · 2026 Annual CER Program Review, Table 4 (Hawaiian Electric) · 2025 Annual CER Program Goals, pp. 18–19 (Hawaiian Electric)

PMF recommendation

PMF recommendation: a Commission-supervised tariff or procurement should specify the service by island and feeder—availability window, required kW, duration, response time, local deliverability, outage reserve, and rebound limit—before selecting technology. A battery, heat-pump water heater, cooling control, electric vehicle, or efficiency measure may compete only for the service it can measure and contractually deliver.

Eligibility should turn on verified equipment, safe installation, customer consent, communications, and the ability to maintain a customer-selected or protected outage reserve. A provider may aggregate eligible assets, but it should bear platform, installation, maintenance, cybersecurity, and under-performance risk. The utility or program administrator should pay distinct rates for verified availability and delivered service; customers should not become guarantors of an aggregator’s capacity promise.

Procurement should be open and technology-neutral. Bidders should state installed cost, expected dispatchable kW and kWh, degradation assumptions, reserve policy, warranty support, customer payment, local labor plan, and transition procedure if the platform fails. A standardized customer agreement should say who owns each device, what happens on sale or exit, whether a hardware provider may remove equipment, and which party pays to replace a failed communications or storage component.

A credible fleet record needs separate views of device power, usable energy, net site load, export where relevant, state of charge, dispatch receipt, override use, and post-event rebound. PMF recommends independent measurement and verification using interoperable telemetry, time-synchronized event records, and audit access. Public reporting should aggregate results by feeder without publishing a household’s load profile or location.

Customers should receive a dashboard that explains each dispatch, payment, protected reserve, communication fault, and data permission. They must retain plain-language storm, health, safety, and public-safety-shutoff override rights. No retail sale of device or usage data should be permitted without separate informed consent, and loss of connectivity should fail safely into the customer’s reserve setting rather than silently create a penalty.

PMF recommends a staged sequence: device and cybersecurity qualification; a feeder-limited pilot with published reserve and payment rules; independent validation through actual events; then competitive expansion only where delivered service, customer bill effects, and distribution value meet the pre-set threshold. Low- and moderate-income participation should include enablement support rather than require households to surrender emergency energy to get basic affordability help.

Before capacity is treated as an alternative to a central asset, planners should compare same-service portfolios under chronological weather, outage, communications, distribution, N-1, and multi-day low-renewable conditions. A federated fleet can reduce a defined peak, reserve, or feeder need. It does not create primary energy and should not be represented as a blanket replacement for generation, protection, transmission, black-start, or long-duration adequacy.