ESA Filings

  • 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.

  • ESA AD16-25 Comments

    Posted: December 15, 2016 - 11:07 / FERC / ESA Filings

    ESA submitted the attached Comments in response to the directives issued by the Federal Energy Regulatory Commission’s (“FERC” or the “Commission”) Office of Energy Policy and Innovation dated November 14, 2016 pertaining to above-captioned docket. As documented below, feasible pathways exist for enabling electric storage to provide multiple services while respecting the institutional design of organized wholesale markets. Within the scope of the instant docket, there are several fundamental principles that FERC can establish in short order that would support greater system flexibility and resource efficiency. Those changes would remove further barriers to storage in most markets.

  • ESA Motion to Intervene and Comments - EL17-8-000

    Posted: November 14, 2016 - 10:29 / ESA Filings

    Pursuant to Sections 206(f) and 214 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“Commission”), the ESA moved to intervene in the Docket no. EL 17 -8-000 proceeding and submitted the attached comments regarding the complaint filed on October 21, 2016 (“Complaint”), by Indianapolis Power & Light Company (“IPL”) seeking reforms to the Open Access Transmission, Energy and Operating Reserve Markets Tariff (“Tariff”) of the Midcontinent Independent System Operator, Inc. (“MISO”).

  • ESA Comment on MIWG Energy Storage Integration project

    Posted: November 4, 2016 - 11:30 / NYISO / ESA Filings

    ESA appreciates the opportunity for ongoing dialog with NYISO on its Energy Storage Integration initiative and thanks NYISO for its effort to work with industry stakeholders to develop market modifications that will facilitate better utilization of advanced energy storage technologies in wholesale markets. In response to the latest update on the initiative at the September 29 Market Issues Working Group meeting, ESA has comments on several elements of the plans for Energy Storage Integration.

  • ESA Comment on DER Roadmap

    Posted: November 4, 2016 - 11:29 / NYISO / ESA Filings

    ESA appreciates the opportunity to provide NYISO with feedback on the ongoing DER Roadmap effort and provide the perspective of the energy storage industry. With the understanding that the DER Roadmap is still evolving and a number of upcoming meetings of the Market Issues Working Group will further examine specific details of the Roadmap, the follow points constitute initial feedback on some of the most pressing implications of the Roadmap’s plans.

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