ESA Responds to Order 841 Compliance Filings

Posted: February 7, 2019 - 14:07 / ESA Filings

Today, ESA will submit responses at FERC to the plans filed by each RTO (PJM, NYISO, ISO-NE, MISO, SPP, and CAISO) to comply with Order 841. While ESA is generally supportive of the filings and seeks implementation of most provisions to regularize storage participation in wholesale markets, ESA identified various concerns across the six RTOs. In response to PJM, ESA protests a proposed method to use a 10-hour duration test to qualify energy storage for capacity market participation. In response to NYISO, ESA focuses its complaint on prohibitions against energy storage providing both wholesale and retail services and rules that bias against self-management of state of charge. In MISO, ESA asserts that transmission service charges are being inappropriately applied to storage when it charges at the instruction of the grid operator. In CAISO, ESA seeks clarification that transmission services charges will not be applied; and in SPP, ESA notes the importance of the role of the grid operator in qualifying storage for load-serving entities’ resource adequacy. ESA looks forward to continuing its dialogue and providing feedback in the FERC process. Through these efforts, ESA is eager to ensure that storage can undertake market operations that fully realize the value of their flexibility to the electric system and fulfill FERC’s intent in Order 841.