ESA Comments re: FERC Docket No. RM15-2 - Third Party Provision of Primary Frequency Response Service

Posted: April 27, 2015 - 17:00 / FERC / ESA Filings

The Energy Storage Association (“ESA”) is pleased to provide these Comments in support of the Notice of Proposed Rulemaking (“NOPR”) that was initiated by the Federal Energy Regulatory Commission (“FERC” or the “Commission”) in the above-captioned matter. FERC has consistently been pro-active in its approach to ensure that ancillary services markets are open to competition in a non-discriminatory manner and that all resources, including energy storage, are paid just and reasonable rates for the services they provide. 

Designing a market where Frequency Response Services can be provided efficiently, cost-effectively and in an environmentally-friendly manner will encourage additional energy storage developers to fund and construct facilities to better service the nation’s grid. Storage technologies can also help to create the conditions for competitive markets in ancillary services where conventional generation could have excessive market power. Thus, as detailed below, with a few recommended tweaks to the proposed rules, the ESA supports Frequency Response as an ancillary service that should be provided by resources with market-based rates.