ESA Filings

  • 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.

  • 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.

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