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Independent regulatory commissions

Dry Land Prairie Energy Storage Seeks Exempt Wholesale Generator Status

Strategic Insights

— 2 min read

Dry Land Prairie Energy Storage, LLC has submitted an application to the Federal Energy Regulatory Commission (FERC) for exempt wholesale generator (EWG) status, which would allow the company to sell electric energy, capacity, and ancillary services at wholesale rates without being subject to FERC's standard market design. The company plans to own and operate a 250 MW battery energy storage system in Cheyenne County, Colorado, which will interconnect with the Public Service Company of Colorado (PSCO) transmission system.

Key Takeaways:

  • Dry Land Prairie Energy Storage, LLC is a Delaware limited liability company seeking EWG status for its 250 MW battery energy storage system in Cheyenne County, Colorado.
  • The company's Facility will interconnect with the Public Service Company of Colorado (PSCO) transmission system and engage in wholesale sales of electric energy, capacity, and ancillary services.
  • In connection with operating the Facility, the company may engage in incidental activities such as trading emission allowances, selling "green" power certificates, and engaging in other activities incidental to the sale of electric energy at wholesale.
  • Applicant makes the following representations in order to certify that it satisfies the requirements for EWG status: (a) The Facility will satisfy the definition of Eligible Facilities as defined in Section 32(a)(2) of the Public Utility Holding Company Act of 1935; (b) The Facility includes no transmission or distribution facilities other than those interconnection facilities necessary to permit the Facility to engage in sales at wholesale; (c) Applicant will not make sales of power at retail; (d) No rate or charge for the construction of the Facility or for electric energy produced by the Facility was in effect under the laws of any State on October 24, 1992; and (e) There are no existing leasing arrangements involving the Facility that violate exclusivity requirements consistent with the Commission's EWG precedent.
  • The company has four layers of corporate structure: (1) Dry Land Prairie Energy Storage, LLC; (2) Northern Colorado Holdings, LLC; (3) ESI Energy, LLC; and (4) NextEra Energy Resources, LLC.

Statistics:

  • The Facility will have a nameplate capacity of 250 MW.
  • The Facility will interconnect with the Public Service Company of Colorado (PSCO) transmission system within the PSCO balancing authority area.
  • The company plans to trade emission allowances consistent with the Commission's limitation on such trading.
  • The company expects to sell "green" power certificates or credits consistent with the Commission's limitation on such sales.

Sources:

  • Public Utility Holding Company Act of 2005, enacted pursuant to the Energy Policy Act of 2005, SSSS 1261-77, Pub. L. No. 109-58, 119 Stat. 594 (2005)
  • Section 366.7, 18 C.F.R. SS 366.7 (2024) of the regulations of the Federal Energy Regulatory Commission ("Commission")
  • UGI Development Co., 89 FERC P 61,192 (1999)
  • Madison Windpower, LLC, 93 FERC P 61,270 (2000)
  • Notice of Self-Certification of Exempt Wholesale Generator Status of Dry Land Prairie Energy Storage, LLC, Docket No. EG25-____-000
  • Quarterly Compliance Filing for Q1 of 2025, Docket No. EC19-57-002
  • VESI 12, LLC, 186 FERC P 61,137 at P 16 (2025)

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