ESA Filings: FERC

  • 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 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.

  • 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 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 Comments on FERC Docket AD16-20 Electric Storage Participation in Regions with Organized Wholesale Electric Markets

    Posted: June 6, 2016 - 17:43 / FERC / ESA Filings

    The Energy Storage Association (“ESA”) submitted the attached Comments in response to the directives issued by J. Arnold Quinn, Director of the Federal Energy Regulatory Commission’s (“FERC” or the “Commission”) Office of Energy Policy and Innovation dated April 27, 2016 pertaining to above-captioned docket

  • ESA Comment on FERC Docket RM16-6 on Frequency Response

    Posted: April 25, 2016 - 19:17 / FERC / ESA Filings

    The Energy Storage Association (“ESA”) submitted these Comments in response to the February 18, 2016, Notice of Inquiry issued by the Federal Energy Regulatory Commission (“FERC” or the “Commission”) on the need for reform to its rule and regulations regarding the provision and compensation of primary frequency response.

  • FERC Order 792

    Posted: November 22, 2013 - 15:49 / FERC / ESA Filings

    In this Final Rule, the Federal Energy Regulatory Commission (Commission) is amending the pro forma Small Generator Interconnection Procedures (SGIP) and pro forma Small Generator Interconnection Agreement (SGIA) to: (1) incorporate provisions that provide an Interconnection Customer with the option of requesting from the Transmission Provider a pre-application report providing existing information about system conditions at a possible Point of Interconnection; (2) revise the 2 megawatt (MW) threshold for participation in the Fast Track Process included in section 2 of the pro forma SGIP; (3) revise the customer options meeting and the supplemental review following failure of the Fast Track screens so that the supplemental review is performed at the discretion of the Interconnection Customer and includes minimum load and other screens to determine if a Small Generating Facility may be interconnected safely and reliably; (4) revise the pro forma SGIP Facilities Study Agreement to allow the Interconnection Customer the opportunity to provide written comments to the Transmission Provider on the upgrades required for interconnection; (5) revise the pro forma SGIP and the pro forma SGIA to specifically include energy storage devices; and (6) clarify certain sections of the pro forma SGIP and the pro forma SGIA. The reforms should ensure interconnection time and costs for Interconnection Customers and Transmission Providers are just and reasonable and help remedy undue discrimination, while continuing to ensure safety and reliability.

  • Pre Technical Conference Statement of ESA re: FERC Docket AD13-7-000

    Posted: September 25, 2013 - 19:49 / FERC / ESA Filings

    On behalf of the Electricity Storage Association, thank you for the invitation to address the panel as it contemplates how best to integrate electricity storage into centralized capacity markets. The below statement will first introduce you to the Electricity Storage Association and its representative members. Second, we will provide an overview of how electricity storage can be used to benefit the centralized capacity markets.

  • ESA Motion for Extension of Time to Submit Comments re: FERC AD13-8/RM13-11

    Posted: September 24, 2013 - 12:17 / FERC / ESA Filings

    Pursuant to Rule 212 of the Federal Energy Regulatory Commission’s (“FERC” or the “Commission”) Rules of Practice and Procedure, 18 C.F.R. § 385.212, the Energy Storage Association d/b/a Electricity Storage Association (“ESA”), on behalf of its Advocacy Council submits this Motion for an additional three weeks, until October 18, 2013, to file Comments in response to the Notice of Request for Comments (“Notice”) that was issued by the Commission on July 18, 2013 in the above-captioned matters. The request for expedited treatment of this Motion is necessary due to the September 27, 2013 deadline for submission of Comments as outlined in the Commission’s Notice.

  • ESA Motion to Leave to Answer and Answer re: PJM FERC Order No. 755 Compliance

    Posted: September 4, 2013 - 16:20 / FERC / ESA Filings

    Pursuant to Rules 212 and 213 of the Federal Energy Regulatory Commission (“FERC” or the “Commission”) Rules of Practice and Procedure, 18 CFR § 385.212, 18 CFR § 385.213 and Commission precedent that allows such filings under specific conditions, Electricity Storage Association d/b/a the Energy Storage Association (“ESA”) on behalf its Advocacy Council respectfully moves for Leave to Answer, and submits this Answer, in response to the Request for Clarification or, in the Alternative, Request for Rehearing PJM Interconnection, L.L.C. (“PJM”) For the reasons detailed below, ESA supports PJM’s request for clarification.

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