Comments of the ESA re: PJM Capacity Performance Proposal

Posted: September 17, 2014 - 19:30 / PJM / ESA Filings

The Energy Storage Association (ESA) appreciates this opportunity to submit comments on PJM’s Capacity Performance proposal. The ESA fully supports PJM’s goal of enhancing reliability during peak power and extreme weather conditions, and believes that energy storage can play a valuable role in meeting PJM’s objectives.

Adding energy storage to the RPM resource mix will allow PJM to meet its reliability goals at a lower cost and with more flexibility than simply increasing the amount of traditional generation. Storage can directly meet peak demand, especially during double-peaked winter days. Beyond that, storage provides PJM operators the ability to rapidly respond to unit outages, manage system ramp rates, and reduce uplift costs created by the lack of flexibility of other resources on the system. However, PJM proposes to treat storage much as a traditional generator, instead of recognizing its unique operational characteristics and the flexibility it adds to the system. For all of these reasons, the ESA recommends that PJM revisit the storage requirements suggested in the Capacity Performance proposal, and, instead, proceed with rules that recognize storage resources’ full reliability contributions to the system. Such an approach will prove to be both operationally superior and lower cost than PJM’s proposed approach.

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