ESA Motion to Leave to Answer and Answer re: PJM FERC Order No. 755 Compliance

Posted: September 4, 2013 - 16:20 / FERC / ESA Filings

Pursuant to Rules 212 and 213 of the Federal Energy Regulatory Commission (“FERC” or the “Commission”) Rules of Practice and Procedure, 18 CFR § 385.212, 18 CFR § 385.213 and Commission precedent that allows such filings under specific conditions, Electricity Storage Association d/b/a the Energy Storage Association (“ESA”) on behalf its Advocacy Council respectfully moves for Leave to Answer, and submits this Answer, in response to the Request for Clarification or, in the Alternative, Request for Rehearing PJM Interconnection, L.L.C. (“PJM”) For the reasons detailed below, ESA supports PJM’s request for clarification.

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