ESA Filings: FERC

  • 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.

  • ESA Comments Supporting PJM's Proposed Tariff Revisions re: FERC Order No. 755

    Posted: September 5, 2012 - 16:23 / FERC / ESA Filings

    ESA supports the Operating Agreement and Tariff revisions proposed by PJM in the August 15, 2012 filing, but notes that because the August 15th tariff provisions are interdependent with revisions proposed by PJM in its Section 205 filing, dated August 2, 2012, and docketed as Docket No. ER12-2391, ESA recommends that the Commission accept both filings to be implemented concurrently on October 1, 2012.

  • ESA Comments re: PJM FERC Order No. 755 Compliance Filing

    Posted: March 26, 2012 - 16:05 / FERC / ESA Filings

    Pursuant to Rules 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 18 C.F.R. § 385.214 and the Commission’s Combined Notice of Filings #1 dated March 6, 2012, the Energy Storage Association d/b/a Electricity Storage Association (“ESA”), on behalf of its Advocacy Council, hereby moves to intervene in the above-referenced docket and to offer comments in response to PJM Interconnection, LLC’s (“PJM”) compliance with FERC’s Order No. 755 wherein PJM seeks approval to initial the Commission’s “pay-for-performance” goals as well as its elimination of its uplift payments.

  • FERC Order 755

    Posted: October 20, 2011 - 09:12 / FERC / ESA Filings

    Pursuant to section 206 of the Federal Power Act, the Commission is revising its regulations to remedy undue discrimination in the procurement of frequency regulation in the organized wholesale electric markets and ensure that providers of frequency regulation receive just and reasonable and not unduly discriminatory or preferential rates. Frequency regulation service is one of the tools regional transmission organizations (RTOs) and independent system operators (ISOs) use to balance supply and demand on the transmission system, maintaining reliable operations. In doing so, RTOs and ISOs deploy a variety of resources to meet frequency regulation needs; these resources differ in both their ramping ability, which is their ability to increase or decrease their provision of frequency regulation service, and the accuracy with which they can respond to the system operator’s dispatch signal.

  • ESA Comments re: FERC NOI RM11-24/AD10-13

    Posted: August 22, 2011 - 11:32 / FERC / ESA Filings

    The Energy Storage Association d/b/a Electricity Storage Association (“ESA”) appreciates the opportunity to submit comments on behalf of its Advocacy Council in response to the Federal Energy Regulatory Commission’s (“FERC” or the “Commission”) Notice of Inquiry (“NOI”) as issued in the above-captioned matter. ESA commends FERC for its proactive approach to ensure that ancillary services markets are open to competition from storage resources and result in just and reasonable rates for the services provided. As detailed below, ESA recommends that FERC implement several changes to its policies pertaining to ancillary services markets in order to facilitate the provision of ancillary services from all resources, including storage technologies. The reforms recommended herein will facilitate the participation of new advanced storage resources (such as flywheels and batteries) that have the potential to improve the operational and economic efficiency of the transmission system and to lower costs to consumers in regions that are outside the current organized markets.

  • ESA Comments re: FERC RM 11-7/AD10-11

    Posted: May 2, 2011 - 11:37 / FERC / ESA Filings

    The Energy Storage Association d/b/a Electricity Storage Association (“ESA”) appreciates the opportunity to submit comments in support of the compensation mechanism proposed by the Federal Energy Regulatory Commission (“FERC” or the “Commission”) in its Notice of Proposed Rulemaking (“NOPR”) as issued in the abovecaptioned matter. As proposed, FERC would require all ISO/RTOs to adopt a Regulation compensation formula that pays resources based on two components: (1) a uniform capacity payment that includes marginal regulatory resource’s opportunity costs (i.e., the amount of megawatts (“MW”) that a resource makes available to provide Regulation); and (2) a performance payment based on the amount of up and down movement (in MWs) that the resource provides in response to a control signal.2 Paying resources based on these two components will ensure that fast-ramping regulation resources, such as batteries and flywheels, are justly and reasonably compensated for their ability to quickly and accurately correct the Area Control Error (“ACE”).