ESA Filings

  • ESA Letter to Arizona Commission Supports Distribution Interconnection Changes

    Posted: November 28, 2018 - 09:22 / Arizona / ESA Filings

    The Energy Storage Association filed a letter in docket number RE-00000A-07-0609 in support of revisions to the distribution interconnection rules proposed by Commission Staff. ESA anticipates that these revisions will be considered in the Commission’s December meeting. ESA’s letter reiterates comments ESA has made in previous filings on the key elements needed to support energy storage interconnection. Specifically, ESA lends support for the Maximum Capacity definition in the draft regulations but underscores the importance that it be applied to all customers rather than in instances where the utility and customer agree to use it.

  • ESA Reply Comments Advocate for Nevada Energy Storage Target

    Posted: November 14, 2018 - 16:33 / Nevada / ESA Filings

    ESA filed reply comments today in response to a request for comments by the Public Utilities Commission of Nevada on the implement of Senate Bill 204 (2017), which calls on the Commission to set energy storage targets if it is determined that energy storage is in the public interest. In our comments, ESA directly addresses concerns articulated in other parties’ opening comments about whether energy storage targets are in the public interest, noting that their concerns can be addressed in the development of a target and do not in themselves suggest a target is not in the public interest. Additionally, ESA reiterates the importance for a long-term policy signal in the form of an energy storage target to achieve the public interest and agrees with parties who suggest that the IRP and DRP processes are the appropriate mechanism by which to procure energy storage in a way that is aligned with the system’s needs.

  • ESA Comments in Support of Nevada Energy Storage Target

    Posted: October 31, 2018 - 14:51 / Nevada / ESA Filings

    ESA filed comments today in response to a request for comments by the Public Utilities Commission of Nevada on the implement of Senate Bill 204 (2017), which calls on the Commission to set energy storage targets if it is determined that energy storage is in the public interest. In our comments, ESA demonstrates that the recently released Brattle Group study on the cost benefit of energy storage supports the creation of a 1,000 MW energy storage target by 2030. ESA recommends the target must contain several key elements that should be developed through a robust stakeholder process and proposes a framework for such a discussion. Those elements include how to set the target, review of existing procurement and incentive programs and consideration of developing new procurement programs, eligibility, competition, and reporting considerations.

  • 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.

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