ESA Protest of the Proposed Tariff Revisions to Implement Regulation Market Enhancements

Posted: November 16, 2017 - 09:08 / Regulation / ESA Filings

PJM Interconnection, L.L.C.

Docket No. ER18-87-000, ER18-87-001

PROTEST OF THE ENERGY STORAGE ASSOCIATION


Pursuant to Sections 211 and 214 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“FERC” or the “Commission”), 18 C.F.R. §§ 385.211 and 385.214 and the Commission’s Notice of Complaints, the Energy Storage Association (“ESA”) hereby protests the Proposed Tariff Revisions to Implement Regulation Market Enhancements (“Proposed Changes”) filed in the above-captioned docket by PJM Interconnection, L.L.C. (“PJM”) to its Open Access Transmission Tariff (“Tariff”) and Amended and Restated Operating Agreement of PJM Interconnection, L.L.C (Operating Agreement). For the reasons set forth below, FERC should reject the proposed revisions to the Tariff and Operating Agreement as deficient in satisfying the filing requirements of the Federal Power Act (“FPA”), unduly discriminatory in its Proposed Changes to settlement, leading to unjust and unreasonable rates, and inconsistent with prior Commission directives to PJM on compliance with Order No. 755.

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