ESA Comments on Docket no. RM17-8-000

Posted: April 13, 2017 - 17:03 / Interconnection / ESA Filings

ESA submitted attached Comments in response to the notice of proposed rule issued December 15, 2016 pertaining to the above- captioned docket. ESA generally supports the Commission’s proposed rule and appreciates the Commission’s initiative to better enable electric storage resources to participate in wholesale markets. Reducing backlogged interconnection queues will increase the ability of electric storage to interconnect, both as stand-alone facilities and as resources co-located with generation. The Commission’s proposed rule will also broadly improve the certainty, transparency, and process for interconnecting electric storage technologies. Moreover, transparency about constrained flowgates and congestion will allow storage developers to better identify opportunities for solving congestion problems.

These comments focus on proposed changes particularly pertinent to the  interconnection of electric storage. The high controllability of storage input and output, the wide range of use cases of storage, and the ability to co-locate storage with existing generation resources are key reasons for different interconnection rules and procedures for storage than are applied to generators or loads. ESA strongly supports enabling interconnection of facilities at levels of service below installed capacity rating, provided appropriate controls and protections are installed. The Commission can reduce the cost and time of interconnection if operational assumptions and conditions of storage interconnection are driven by an interconnection customer’s request and proven capability of performance within those parameters, rather than the inapplicable assumptions of generating technologies. Additionally, ESA strongly supports the establishment of Surplus Interconnection Service to make efficient utilization of existing interconnection capacity of generating facilities through an expedited process. ESA also supports the establishment of provisional interconnection service, as doing so will enable grid operators to benefit from the short deployment timelines of storage facilities, which generally outpace regular interconnection processes. Finally, ESA recommends foundational principles for modeling electric storage for interconnection be implemented across RTOs/ISOs, recognizing that each RTO/ISO will use a method integrated with its existing practice.
Read the full comments here.