Motion to Intervene and Protest of the ESA re: ISO New England Regulation Market Changes re: Docket No. ER14-1537

Posted: April 10, 2014 - 19:01 / ISO-NE / 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 March 20, 2014, the Energy Storage Association (“ESA”) hereby submits its Motion to Intervene in the above-captioned matter and its Protest of ISO New England Inc.'s ("ISO-NE") proposed tariff for Regulation Market Changes.

As explained below, ISO-NE's proposed tariff fails to incorporate the dispatch method that was tested and implemented successfully for advanced storage resources during ISO-NE’s five year Alternative Technology Regulation Pilot Program (“Pilot Program”). As a result, ISO-NE has created unjust and unreasonable barriers to entry to ISO-NE’s regulation market for batteries and flywheels. If approved, the tariffs will preclude alternative storage technologies from participating in the regulation market on a comparable basis with other regulation providers. Despite the successful Pilot Program, ISO-NE is proposing to revert back to a dispatch method that only accommodates the operational characteristics of traditional generator resources, as if the Pilot Program never existed. Such a proposal, particularly when there are over 130 MW of batteries and flywheels providing frequency regulation on the US power grid today, is simply beyond comprehension and lacks common sense. Furthermore, it is discriminatory, unjust and unreasonable.

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