ESA RM16-6 Supplemental Comments | Docket No. RM16-6-000

Posted: November 3, 2017 - 15:19 / Frequency Response / ESA Filings

UNITED STATES OF AMERICA
BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION

Essential Reliability Services and the Evolving Bulk-Power System - Primary Frequency Response | Docket No. RM16-6-000

Comments of the Energy Storage Association

The Energy Storage Association (“ESA”) submits these Comments in response to the supplemental notice for comment issued on August 18, 2017, following the notice of proposed rule issued on November 17, 2016 pertaining to above-captioned docket. ESA acknowledges FERC for its request for supplemental comments on the impact of PFR requirements on electric storage resources. In light of the unique operational characteristics of electric storage resources, ESA respectfully asks FERC to modify its proposed rule to avoid disproportionate burdens on electric storage resources for providing primary frequency response (“PFR”) and to ensure market participants can effectively manage electric storage resources for greatest value to the grid. Additionally, ESA recommends that FERC allow each RTO/ISO to choose to make PFR a compensated service as an alternative to requiring PFR capability as an unpriced condition of interconnection agreement.

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