Comment of the Energy Storage Association on the Implementation of Senate Bill 146 (2017)

Posted: October 31, 2017 - 16:17 / Nevada / ESA Filings

Before the Public Utilities Commission of Nevada
Rulemaking to implement the provisions of Senate Bill 146 (2017)

Docket No. 17-08022

The Energy Storage Association (“ESA”) respectfully submits these comments1 in response to the Public Utilities Commission of Nevada’s (“Commission”) request for comments on implementation related to Senate Bill (“SB”) 146 (2017) in Docket Number 17-08022.

In these comments, ESA proposes initial thoughts around the development of a regulatory framework for considering distributed energy resources, and energy storage more specifically, into the State of Nevada’s resource planning process. Specifically, ESA provides guidance on how these distribution resource plans should be incorporated into broader utility processes, including generate rate cases and integrated resource plans, and underscores the importance of ensuring that the plans are evaluated based on their cost-benefit analysis of distributed energy resources (“DERs”) and proposals for tariffs, contracts or other mechanisms to contract with DERs.

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