ESA Comment on ER17-1376-000

Posted: April 26, 2017 - 16:26 / MISO / ESA Filings

Pursuant to Sections 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 §385.214, 18 U.S.C., and the Combined Notice of Filings #2 issued on April 3, 2017, the Energy Storage Association (“ESA”) respectfully submits its Motion to Intervene and Comments in the captioned matter. For the reasons delineated herein, it is clear that the Midcontinent Independent System Operator, Inc.’s (“MISO”) April 3, 2017 compliance filing (the “Compliance Filing”) does not meet the requirements that the Commission set forth in its February 1, 2017, Order.

First, in contravention of the Commission’s Order, the Compliance Filing restricts the list of services that can be provided by SER Type II resources. Second, in its Compliance Filing MISO includes requirements that contravene with the unique technical and operational characteristics of electric storage resources. Thus, ESA respectfully requests that the Commission direct MISO to modify its proposed tariff to comply with FERC’s Order. Lastly, for the reasons detailed below, ESA respectfully requests that FERC grant ESA’s Motion to Intervene in this docket.

Read full comments here