ESA Motion of Leave to Answer

Posted: June 5, 2017 - 15:23 / FERC Order 755 / ESA Filings
Pursuant to Rules 212 and 213 of the Federal Energy Regulatory Commission’s (“FERC” or “Commission”) Rules of Practice and Procedure,1 the Energy Storage Association (“ESA”)2 hereby submits this Answer to Motion to Consolidate and Motion for Leave to Answer and Answer, in response to: (i) the Motion to Consolidate filed by PJM Interconnection L.L.C. (“PJM”) on May 15, 2017 (“Motion to Consolidate”); (ii) the Answer filed by PJM on May 15, 2017 (“PJM Answer”); and (iii) the Comments filed by the Independent Market Monitor (“IMM”) on May 25, 2017 (“IMM Comments”). Each of the foregoing pleadings was filed in Docket No. EL17-64-000 and Docket No. EL17-65-000.
 
Although the Commission’s Rules do not permit answers to answers or protests as a matter of right, the Commission routinely allows such answers where they will aid the Commission’s decision-making process, clarify the issues before the Commission, or assure a complete record in the proceeding.3 Accepting this answer will aid the Commission’s decision-making process by addressing and correcting errors and omissions in the PJM Answer and IMM Comments. Moreover, accepting the answer will promote administrative efficiency by allowing ESA to address the Motion to Consolidate filed by PJM in a single pleading.  ESA thus respectfully requests the Commission grant this motion for leave to answer.
 
II. ANSWER
Through its Complaint, ESA requests that the Commission direct PJM to comply with the filing requirements of the Federal Power Act by submitting revisions to the Tariff or Operating Agreement5 setting forth the methodology by which PJM calculates the benefits factor used in clearing resources in the Regulation market and the parameters governing the design of the dynamic Regulation (“RegD”) signal. The concerns underlying this request were stated clearly: the various changes to the Regulation market implemented by PJM without Commission review are resulting in limited-energy RegD resources being called upon to operate at full raise or full lower position for extended periods of time. These changes have fundamentally altered the Regulation product for RegD resources, significantly affecting the rates, terms, and conditions of Regulation service.
 
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