Motion to Intervene and Comments of ESA FERC Docket No. ER15-623-000 and Docket No. EL15-29

Posted: February 9, 2015 - 04:45 / PJM / ESA Filings

Pursuant to Rules 212 and 214 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“FERC” or the “Commission”), 18 C.F.R. § 385.212 and 18 C.F.R. § 385.214 and the Commission’s Combined Notice of Filings #1 dated December 12, 2014 and the Notice Granting Extension of Time to submit Comments in the above-captioned dockets, the Energy Storage Association (“ESA”) hereby submits its Motion to Intervene and Comments in support of the Reforms to the Reliability Pricing Market and Related Rules in the PJM Interconnection, L.L.C. (“PJM”) Open Access Transmission Tariff and Reliability Assurance Agreement Among Load Serving Entities (“Capacity Performance Filing”).