ESA Motion to Intervene and Protest to Request for Limited Waiver of Tariff Provisions re: Docket No. ER14-971-000

Posted: January 31, 2014 - 19:57 / CAISO / ESA Filings

Pursuant to Rules 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 18 C.F.R. §385 §214, the Energy Storage Association (“ESA”) submits this Motion to Intervene and Protest to the Petition of the California Independent System Operator Corporation ("CAISO") requesting a waiver of ISO tariff sections that apply a minimum performance threshold to resources certified to provide regulation up and regulation down services for the period from June 1, 2013 up to and including December 31, 2014.

As explained below, the minimum performance threshold is an important component of CAISO’s overall Order 755 market design by encouraging resources to follow the system operator’s dispatch instructions and ensuring just and reasonable compensation for accuracy. Waiving this portion of the CAISO’s tariff for a one and a half year time period will have negative consequences to CAISO ratepayers whom FERC found benefit from the use of faster more accurate resources for regulation. The extended delay will hinder the development and investment in fast-responding, environmentally-friendly storage technologies that are ready to enter California's market.

Moreover, because ESA's members consist of frequency regulation providers looking to develop facilities in California, the ESA will be substantially and directly impacted by FERC's decision in this matter. Accordingly, the ESA respectfully requests that it be allowed to intervene in this proceeding.

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