ESA Filings

  • ESA Advocates Storage in New Jersey's 2019 Energy Master Plan

    Posted: October 12, 2018 - 13:09 / New Jersey / ESA Filings

    ESA is submitting comments today to the the New Jersey Board of Public Utilities in response to a request for stakeholder input on the state's 2019 Energy Master Plan. In our comments, ESA recommends a set of policy actions over the next ten years that are needed to ensure a more resilient grid, specifically focusing on policies to unlock the energy storage market in the State of New Jersey. ESA calls for the BPU and Murphy administration to initiate a robust and long-term review of the rules and regulations that govern the electricity system. Specifically, ESA recommends the BPU develop programs for behind-the-meter and front of meter resources to provide grid benefits and non-wires solutions, place greater consideration of energy storage in resource planning, develop a dual-participation framework for DER storage, and engage PJM to ensure wholesale market rules align with the guidance of FERC Order 841 and New Jersey's storage goals.

  • ESA Comments on Colorado PUC's Implementation of House Bill 18-1270

    Posted: September 21, 2018 - 13:57 / Colorado / ESA Filings

    ESA will file comments today in response to the Colorado Public Utilities Commission’s Notice of Proposed Rulemaking to implement House Bill 18-1270, which passed the state legislature this year. In our comments, ESA calls for additional revisions to the Electric Resource Planning (ERP) rules to facilitate effective consideration of energy storage in procurement, including use of up-to-date cost estimates and forecasts, modeling tools that employ sub-hourly intervals, and instituting a “net cost” analysis to better capture flexibility benefits. Additionally, ESA submits that in addition to updating the ERP rules, additional rules governing Certificate of Public Convenience and Necessity and Distribution Resource Planning require updating to reflect the full guidance of the legislation.

  • ESA files Comments Supportive of the NY Energy Storage Roadmap

    Posted: September 10, 2018 - 16:25 / New York / ESA Filings

    ESA will file comments today on the New York Storage Roadmap at the New York Public Service Commission. In our comments, ESA supports the steps recommended in the Roadmap to achieve the State of New York’s storage deployment program and provides additional details and suggestions.

  • ESA Files Comments on Updating Integrated Resource Planning to Indiana Utility Regulatory Commission

    Posted: September 7, 2018 - 08:00 / Indiana / ESA Filings

    ESA today is filing comments in response to the Indiana Utility Regulatory Commission’s request for comments (Docket RM15-06) on proposed revisions to the Commission's rule requiring electric utilities to prepare and submit integrated resource plans (IRPs). In our comments, ESA calls for additional revisions to facilitate effective consideration of energy storage, including use of up-to-date cost estimates and forecasts, modeling tools that employ sub-hourly intervals, and instituting a “net cost” analysis to better capture flexibility benefits.

  • ESA Comments on Colorado PUC 17M-0694E ERP

    Posted: September 6, 2018 - 11:54 / Colorado / ESA Filings

    Pursuant to the Public Utilities Commission of the State of Colorado (“Commission”) Decision Opening a Repository Proceeding and Soliciting Input from Interested Participants issued on October 26, 2017, the Energy Storage Association (“ESA”) respectfully submits these comments for the Commission’s consideration in the matter of the Commission’s review of its rules governing electric resource planning, implementing Colorado’s renewable energy standard, and enabling new technology integration.

  • NECEC Initial Comments - DPU 17-146

    Posted: September 6, 2018 - 09:33 / Massachusetts / ESA Filings

    Dear Hearing Officers Rubin and Tohme: The Northeast Clean Energy Council (NECEC), on behalf of its member companies and the Solar Energy Industries Association (SEIA), Vote Solar, the Solar Energy Business Association of New England (SEBANE), and the Energy Storage Association (ESA),1 appreciates the opportunity to submit written comments in response to the Department of Public Utilities’ (“Department” or “DPU”) inquiry in D.P.U. 17-146, relative to the eligibility of energy storage systems to net meter. The issues raised in this docket have far-reaching implications for the deployment of both net metering technologies and energy storage in Massachusetts. Customers are increasingly pursuing combined net metering+storage installations, which can maximize the value of the component parts not only for customers but also for the distribution system, and our member company solar and storage providers are developing packages of solutions to meet customer needs. Capturing the value of net metering+storage will be critical for achieving the Commonwealth’s goals for energy storage and net metering technologies, as well as necessary to enable customers to choose these resources to meet their energy needs.

  • ESA Comments on WA UTC U-161024: In the Matter of Rulemaking for Integrated Resource Planning

    Posted: May 21, 2018 - 13:47 / Washington / ESA Filings

    The Energy Storage Association (“ESA”) appreciates the opportunity to submit these comments in response to the Notice of Opportunity to File Written Comments on as requested by the Washington Utilities and Transportation Commission (“Commission”) in Docket U-161024 on April 17, 2018. In our comments below, ESA provides recommendations for implementation of a distribution resource planning process to enable competitive, cost-effective solutions and for input on designing a Proof of Regulatory Concept program to pilot new regulatory constructs.

  • ESA Comments on Maryland Interconnection (RM 61)

    Posted: May 10, 2018 - 10:00 / Maryland / ESA Filings

    In the Matter of Revisions to COMAR 20.50.02 and 20.50.09 – Small Generator Facility Interconnection Standards (RM 61)

  • ESA Comments: Review, Modernization and Expansion of the Arizona Renewable Energy Standard and Tariff Rules and Associated Rules

    Posted: April 26, 2018 - 15:48 / Arizona / ESA Filings

    Pursuant the Arizona Corporate Commission’s (“Commission”) Notice of Inquiry filed in Docket Number E-00000Q-160289 on February 22, 2018, ESA respectfully submits these comments for the consideration of the Commission.

  • ESA Comments - PURA INVESTIGATION INTO DISTRIBUTION SYSTEM PLANNING OF THE ELECTRIC DISTRIBUTION COMPANIES

    Posted: April 3, 2018 - 16:12 / Connecticut / ESA Filings

    Pursuant the Public Utilities Regulatory Authority (“Authority”) Notice of Request for Written Comments in the matter of Investigation into Distribution System Planning of the Electric Distribution Companies, issued on March 9, 2018, the Energy Storage Association (“ESA”) respectfully submits these comments. ESA’s comments focus on providing an initial template for the Authority’s consideration for new rules for Distribution Resource Planning (DRP).

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