ESA Comments on DOE NOPR

Posted: October 23, 2017 - 21:10 / Notice of proposed rulemaking / ESA Filings

Grid Reliability and Resiliency Pricing
Docket No. RM18-1-000

Comments of the Energy Storage Association

Pursuant to the Federal Energy Regulatory Commission’s (“FERC” or “Commission”) October 2, 2017, Notice Inviting Comments,1 the Energy Storage Association(“ESA”) submits the following comments in response to the Secretary of Energy’s September 28, 2017, proposal of a rule for final action by the Commission (“DOE’s proposed rule”)2 under section 403 of the Department of Energy Organization Act.3 For the reasons described herein, the ESA recommends that FERC should not adopt the Department of Energy’s (“DOE”) proposed rule.

Instead, ESA recommends that FERC work with the North American Electric Reliability Corporation (“NERC”) and other stakeholders to first establish a framework for defining and measuring the grid’s resilience. ESA recommends that, subsequent to that effort, FERC initiate a proceeding to identify and value the full range of electric system resilience attributes that are inadequately compensated or uncompensated, as well as technology-neutral approaches to compensating any desired resilience attributes.

Click below for full comments.