ESA Filings

  • 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.

  • ESA Comments to MISO on AGC Enhancement

    Posted: September 8, 2017 - 16:03 / ESA Filings

    ESA will best be able to understand and provide useful input to MISO with provision of more information on its AGC Enhancement proposal. AGC Enhancement is a necessary and important step to enabling greater grid flexibility, and at a general level, we favor MISO’s intent to enable faster response of all resources.

  • ESA Motion of Leave to Answer

    Posted: June 5, 2017 - 15:23 / FERC Order 755 / ESA Filings

    Pursuant to Rules 212 and 213 of the Federal Energy Regulatory Commission’s (“FERC” or “Commission”) Rules of Practice and Procedure,1 the Energy Storage Association (“ESA”)2 hereby submits this Answer to Motion to Consolidate and Motion for Leave to Answer and Answer, in response to: (i) the Motion to Consolidate filed by PJM Interconnection L.L.C. (“PJM”) on May 15, 2017 (“Motion to Consolidate”); (ii) the Answer filed by PJM on May 15, 2017 (“PJM Answer”); and (iii) the Comments filed by the Independent Market Monitor (“IMM”) on May 25, 2017 (“IMM Comments”). Each of the foregoing pleadings was filed in Docket No. EL17-64-000 and Docket No. EL17-65-000. Although the Commission’s Rules do not permit answers to answers or protests as a matter of right, the Commission routinely allows such answers where they will aid the Commission’s decision-making process, clarify the issues before the Commission, or assure a complete record in the proceeding.3 Accepting this answer will aid the Commission’s decision-making process by addressing and correcting errors and omissions in the PJM Answer and IMM Comments. Moreover, accepting the answer will promote administrative efficiency by allowing ESA to address the Motion to Consolidate filed by PJM in a single pleading. ESA thus respectfully requests the Commission grant this motion for leave to answer.

  • ESA Comment on ER17-1376-000

    Posted: April 26, 2017 - 16:26 / MISO / ESA Filings

    Pursuant to Sections 212 and 214 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“FERC” or the “Commission”), 18 C.F.R. §385.212 and §385.214, 18 U.S.C., and the Combined Notice of Filings #2 issued on April 3, 2017, the Energy Storage Association (“ESA”) respectfully submits its Motion to Intervene and Comments in the captioned matter. For the reasons delineated herein, it is clear that the Midcontinent Independent System Operator, Inc.’s (“MISO”) April 3, 2017 compliance filing (the “Compliance Filing”) does not meet the requirements that the Commission set forth in its February 1, 2017, Order.

  • Joint Comments of Advanced Energy Economy, Americans For A Clean Energy Grid, The American Council On Renewable Energy, The American Wind Energy Association, The Energy Storage Association, And The Solar Energy Industries Association

    Posted: April 13, 2017 - 17:08 / Interconnection / ESA Filings

    Advanced Energy Economy (“AEE”), Americans for a Clean Energy Grid (“ACEG”), American Council on Renewable Energy (“ACORE”), American Wind Energy Association (“AWEA”), Energy Storage Association (“ESA”), and Solar Energy Industries Association (“SEIA”)1 hereby respectfully submit these limited comments to the Commission’s December 15, 2016, Notice of Proposed Rulemaking (“NOPR”) in the RM17-8-000 proceeding.

  • ESA Comments on Docket no. RM17-8-000

    Posted: April 13, 2017 - 17:03 / Interconnection / ESA Filings

    ESA submitted attached Comments in response to the notice of proposed rule issued December 15, 2016 pertaining to the above- captioned docket. ESA generally supports the Commission’s proposed rule and appreciates the Commission’s initiative to better enable electric storage resources to participate in wholesale markets.

  • ESA Comments to Docket No. RM16-23

    Posted: February 14, 2017 - 11:24 / FERC / ESA Filings

    ESA submitted the attached Comments in response to the Notice of Proposed Rulemaking that was issued by the Federal Energy Regulatory Commission (“FERC”) on November 17, 2016 pertaining to above-captioned docket. ESA is appreciative that FERC continues to recognize the importance of installing energy storage facilities on our nation’s grid and, as detailed herein, is in general agreement with FERC’s proposals that would direct organized wholesale market operators to create affirmative participation models for electric storage.

  • ESA Comments to Docket No. RM16-6

    Posted: January 24, 2017 - 16:38 / ESA Filings

    The Energy Storage Association (“ESA”) submitted the attached Comments in response to the notice of proposed rule issued on November 17, 2016 pertaining to above-captioned docket. While ESA does not oppose the requirement of primary frequency (“PFR”) response capability as a condition of interconnection, it is critical that FERC refrain from mandating a PFR provision. As detailed herein, mandating provision of PFR would create undue or discriminatory burdens on electric storage resources. Accordingly, ESA respectfully asks FERC to modify its proposal and direct RTOs/ISOs to make provision of primary frequency response a compensated service.

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