ESA Filings

  • 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 re: NYISO FERC Order No. 755 Compliance Filing

    Posted: February 12, 2013 - 16:54 / FERC Order 755 / 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 23, 2013, the Energy Storage Association d/b/a Electricity Storage ("ESA") hereby submits these Comments on behalf of its Advocacy Council in the above-referenced docket.

  • 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.

  • FERC NOPR RM13-2-000 re: Small Generator Interconnection Agreements and Procedures

    Posted: January 17, 2013 - 12:31 / Ferc 792 / ESA Filings

    The Federal Energy Regulatory Commission (Commission) is proposing to revise the pro forma Small Generator Interconnection Procedures (SGIP) and pro forma Small Generator Interconnection Agreement (SGIA) originally set forth in Order No. 2006. The pro forma SGIP and SGIA establish the terms and conditions under which public utilities must provide interconnection service to Small Generating Facilities of no more than 20 megawatts (MW).

  • FERC Order Approving CAISO Order 755 Compliance Filing

    Posted: September 20, 2012 - 11:46 / FERC Order 755 / ESA Filings

    The Commission finds CAISO’s proposed tariff revisions to be just and reasonable and in compliance with the Commission’s final rule concerning compensation for frequency regulation in organized wholesale power markets, subject to the compliance filing directed below. Consistent with Order No. 755, CAISO’s tariff revisions address the requirement that a capacity payment at a uniform clearing price that includes opportunity costs be made to a resource to keep its capacity in reserve in the event that it is needed to provide real-time frequency regulation service. CAISO’s tariff revisions also address the requirement that performance payments reflect the amount of work each resource performs in real-time in response to the system operator’s dispatch signal.

  • 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.

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