ESA Filings: FERC

  • 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.

  • FERC Order 784

    Posted: July 18, 2013 - 09:18 / FERC / ESA Filings

    The Federal Energy Regulatory Commission (Commission) is revising its regulations to foster competition and transparency in ancillary services markets. The Commission is revising certain aspects of its current market-based rate regulations, ancillary services requirements under the pro forma open-access transmission tariff (OATT), and accounting and reporting requirements. Specifically, the Commission is revising Part 35 of its regulations to reflect reforms to its Avista policy governing the saleof ancillary services at market-based rates to public utility transmission providers. The Commission is also requiring each public utility transmission provider to add to itsOATT Schedule 3 a statement that it will take into account the speed and accuracy of regulation resources in its determination of reserve requirements for Regulation and Frequency Response service, including as it reviews whether a self-supplying customer has made “alternative comparable arrangements” as required by the Schedule. The final rule also requires each public utility transmission provider to post certain Area Control Error data as described in the final rule. Finally, the Commission is revising the accounting and reporting requirements under its Uniform System of Accounts for public utilities and licensees and its forms, statements, and reports, contained in FERC Form No. 1, Annual Report of Major Electric Utilities, Licensees and Others, FERC Form No. 1-F, Annual Report for Non-major Public Utilities and Licensees, and FERC Form No. 3-Q, Quarterly Financial Report of Electric Utilities, Licensees, and Natural Gas Companies, to better account for and report transactions associated with the use of energy storage devices in public utility operations.

  • ESA Motion to Intervene and Comments re: FERC Docket No. ER13-1748

    Posted: July 12, 2013 - 14:15 / FERC / ESA Filings

    ESA supports Soutwest Power Pools, Inc's (SPP) filing as it complies with Order No. 755. The Tariff, as proposed provides for a two-part payment, including both a capacity and a performance payment that should ensure just and reasonable frequency regulation rates. However, SPP’s market rules have barriers that could preclude advanced energy storage resources from entering SPP’s market. Thus, in addition to approving SPP’s Compliance Filing, ESA respectfully requests that FERC encourage SPP to work with storage providers to ensure that its market rules are modified to remove barriers to advanced energy storage resources.

  • ESA Comments re: FERC RM13-2

    Posted: June 3, 2013 - 15:53 / FERC / ESA Filings

    The Energy Storage Association d/b/a Electricity Storage Association (“ESA”), on behalf of its Advocacy Council,appreciates the opportunity to submit comments in the above-captioned matter wherein the Federal Energy Regulatory Commission (“FERC” or the “Commission”) proposes to revise the pro forma Small Generator Interconnection Procedures (“SGIP) and the pro forma Small Generator Interconnection Agreement (“SGIA”) to ensure that the Commission’s jurisdictional interconnections are administered in a just and reasonable and not unduly discriminatory manner.

  • ESA Comments re: ISO New England FERC Order No. 755 Compliance Filing

    Posted: March 1, 2013 - 16:59 / FERC / ESA Filings

    Pursuant to Rules 211 and 212 of the Federal Energy Regulatory Commission’s (“FERC” or the “Commission”) Rules and Regulations, 18 CFR §385.211 and §385.212, and the Combined Notice of Filings #1 dated February 6, 2013, the Energy Storage Association d/b/a Electricity Storage Association (“ESA”), on behalf of its Advocacy Council, hereby submits its Comments in response to ISO New England, Inc.’s (“ISONE”) proposed Regulation Market Changes that were submitted on February 6, 2013 to comply with FERC’s Order No. 755.

  • ESA Comments Supporting PJM FERC Order No. 755 Compliance

    Posted: February 5, 2013 - 16:12 / FERC / ESA Filings

    Pursuant to Rule 211 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“FERC” or the “Commission”), 18 C.F.R. § 385.211 and the Commission’s Combined Notice of Filings #1 dated January 16, 2013, the Energy Storage Association d/b/a Electricity Storage Association (“ESA”), on behalf of its Advocacy Council, hereby offers comments in support of PJM Interconnection, LLC’s (“PJM”) January 15, 2013 compliance with FERC’s November 16, 2012 Order.

  • ESA Comments re: FERC NOPR Docket Nos. RM11-24/AD10-13

    Posted: September 7, 2012 - 16:07 / FERC / ESA Filings

    ESA appreciates FERC’s undertaking an evaluation of what market reforms are necessary for implementation in non-RTO/ISO regions to enable fast accurate storage technologies to compete to provide service and to send appropriate market signals to encourage investment in new energy storage facilities.

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