ESA Comments re: NYISO FERC Order No. 755 Compliance Filing

Posted: February 12, 2013 - 16:54 / FERC Order 755 / ESA Filings

Pursuant to Rule 211 of the Rules of Practice and Procedure of the Federal Energy
Regulatory Commission ("FERC" or the "Commission"), 18 C.F.R. § 385.211 and the
Commission’s Combined Notice of Filings #1 dated January 23, 2013, the Energy Storage Association d/b/a Electricity Storage ("ESA") hereby submits these Comments on behalf of its Advocacy Council in the above-referenced docket. Collectively, the ESA members provide 28 MWs of Regulation to NYISO. While the ESA supports NYISO’s proposed modifications of its Market Administrative and Control Area Services Tariff ("Services Tariff") as compliant with Order No. 755,2 the proposed date for implementation of these tariffs is discriminatory against our members who operate in NYISO. For the reasons detailed below, the ESA respectfully requests that FERC approve the tariffs with an effective date earlier than June 2013.

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