ESA Comment on Docket RM16-12 Review of Generator Interconnection Agreements and Procedures

Posted: July 1, 2016 - 10:40 / Interconnection / ESA Filings

ESA appreciates the opportunity to offer Comments as part of the Commission’s evaluation of interconnection issues that pertain to electric storage. FERC’s interconnection process was originally devised to address the technical and operating characteristics of generator technologies to ensure that the grid operated reliably at a just and reasonable cost. While FERC’s goals remain the same, the technologies, such as for energy storage -- that are designed to make the grid operate more efficiently -- differs significantly from generators in technical and operational characteristics. Thus, FERC has determined, accurately, that interconnecting new technologies onto the grid using the existing interconnection agreements and procedures present barriers to electric storage resources. In particular, the high controllability of storage input and output, the wide range of use cases of storage, and the ability to pair storage with existing generation resources at the same point of interconnection are key reasons for different interconnection rules and procedures for storage than are applied to generators or loads.