ESA Filings

  • ESA Seeks Remedy of ISO-NE Proposal to Constrain Storage Participation in Energy Markets

    Posted: October 31, 2018 - 14:47 / ISO-NE / ESA Filings

    In response to Enhanced Storage Participation Revisions filed by ISO-NE in FERC Docket No. ER19-84, ESA expresses its support for the tariff filing with the exception of ISO-NE's intention to automatically redeclare the maximum MW of storage resources participating in the energy market at lower states of charge. Doing so will limit the amount of energy that storage can sell in energy markets in ISO-NE. Automatic redeclaration of the energy output of CSFs to meet ISO-NE’s assigned reserve requirement is thereby unjust and unreasonable, as it does not allow those market participants to earn the full energy revenues for the amount of energy they are capable of providing. Moreover, automatic redeclaration of energy storage resources’ output is a violation of Order 841—and one that ESA believes can be remedied without compromising ISO-NE’s ability to comply with reliability requirements. ESA asks that ISO-NE notify FERC of a means to remedy this issue. Should ISO-NE not do so, ESA asks FERC to remedy or otherwise remove those provisions related to automatic redeclaration in approving ISO-NE’s tariff filing.

  • ESA, NY-BEST, and Industry Letter to NYISO CEO Brad Jones Seeks More Thorough Review of Storage Capacity Value

    Posted: October 16, 2018 - 11:53 / NYISO / ESA Filings

    ESA, NY-BEST, and other industry members yesterday sent a letter to NYISO CEO Brad Jones requesting immediate and further consideration on the capacity value of energy storage resources. The letter is a response to a study, Valuing Capacity for Resources with Energy Limitations, and resulting NYISO capacity market design proposals discussed at the October 9-10 stakeholder meetings, where NYISO also indicated its intention to finalize recommendations on a short timeline. Given the significant proposed changes to capacity market participation of storage premised on the study, letter signatories ask NYISO to separate this capacity market study and proposed changes from consideration in the Distributed Energy Resource (DER), Special Case Resource (SCR), Energy Storage Resource (ESR), or Intermittent Resource market design efforts under the DER Roadmap, Order 841 Compliance, or any other related effort. ESA, NY-BEST, and industry members believe a more thorough review of the capacity value study is warranted before discussing significant capacity market changes that will change the business case for energy storage in New York, particularly in light of the state's Energy Storage Roadmap and forthcoming deployment target.

  • ESA Comments on Participation of DER Aggregations in Markets Operated by RTOs and ISOs

    Posted: June 26, 2018 - 14:17 / FERC / ESA Filings

    ESA will file comments today in response to FERC’s Notice Inviting Post-Technical Conference Comments on the Participation of Distributed Energy Resources (DER) Aggregations. In our comments, ESA reiterates the importance of facilitating multiple use frameworks and the full participation of DERs in the wholesale market, and makes the case that the same DER asset should be able to provide both retail and wholesale services. ESA recommends that any deviation from full participation should be on a case-by-case basis, for specific combination of services.

  • ESA Answer to PJM and IMM on Rehearing Requests

    Posted: June 5, 2018 - 14:10 / PJM / ESA Filings

    The Energy Storage Association recently submitted an answer to the Request for Rehearing of PJM Interconnection and the Request for Rehearing of the Independent Market Monitor for PJM (IMM). The response states that FERC did not err by rejecting PJM's proposal for frequency regulation compensation.

  • Protest of the Clean Energy Industry Associations of ISO-NE's Request for Waiver of Tariff Provisions

    Posted: May 23, 2018 - 10:53 / ISO-NE / ESA Filings

    Pursuant to Rule 211 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“Commission” or “FERC”), the American Council on Renewable Energy, American Wind Energy Association, Energy Storage Association, RENEW Northeast, and Solar Energy Industries Association (collectively, “Clean Energy Industry Associations”) respectfully submit this protest to ISO New England’s (“ISO-NE”) Petition for Waiver of Tariff Provisions (“Petition”).

  • ESA Comments: Grid Resilience in RTOs and ISOs (AD18-7)

    Posted: May 10, 2018 - 10:10 / FERC / ESA Filings

    In response to the Federal Energy Regulatory Commission’s (“FERC” or “Commission”) January 8, 2018, order in Docket No. RM18-1-000 opening Docket No. AD18-7-000, the Energy Storage Association (“ESA”) submits the following Comments pursuant to section 403 of the Department of Energy Organization Act.

  • Comments from ESA and GPI on MISO’s ESTF Charter & Management Plan

    Posted: December 11, 2017 - 16:38 / MISO / ESA Filings

    The Energy Storage Association and Great Plains Institute appreciate the opportunity to submit comments on the final revisions to the Energy Storage Task Force Charter and priorities for the group’s Management Plan.

  • ESA Protest of the Proposed Tariff Revisions to Implement Regulation Market Enhancements

    Posted: November 16, 2017 - 09:08 / Regulation / ESA Filings

    Pursuant to Sections 211 and 214 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“FERC” or the “Commission”), 18 C.F.R. §§ 385.211 and 385.214 and the Commission’s Notice of Complaints, the Energy Storage Association (“ESA”) hereby protests the Proposed Tariff Revisions to Implement Regulation Market Enhancements (“Proposed Changes”) filed in the above-captioned docket by PJM Interconnection, L.L.C. (“PJM”) to its Open Access Transmission Tariff (“Tariff”) and Amended and Restated Operating Agreement of PJM Interconnection, L.L.C (Operating Agreement).

  • ESA RM16-6 Supplemental Comments | Docket No. RM16-6-000

    Posted: November 3, 2017 - 15:19 / Frequency Response / ESA Filings

    The Energy Storage Association (“ESA”) submits these Comments in response to the supplemental notice for comment issued on August 18, 2017, following the notice of proposed rule issued on November 17, 2016 pertaining to above-captioned docket. ESA acknowledges FERC for its request for supplemental comments on the impact of PFR requirements on electric storage resources.

  • ESA Comments on DOE NOPR

    Posted: October 23, 2017 - 21:10 / Notice of proposed rulemaking / ESA Filings

    Grid Reliability and Resiliency Pricing Docket No. RM18-1-000 Pursuant to the Federal Energy Regulatory Commission’s (“FERC” or “Commission”) October 2, 2017, Notice Inviting Comments,1 the Energy Storage Association(“ESA”) submits the following comments in response to the Secretary of Energy’s September 28, 2017, proposal of a rule for final action by the Commission (“DOE’s proposed rule”)2 under section 403 of the Department of Energy Organization Act.3 For the reasons described herein, the ESA recommends that FERC should not adopt the Department of Energy’s (“DOE”) proposed rule.

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