Motion for Leave to Answer and Answer of the Energy Storage Association Docket No. ER15-3-000

Posted: February 23, 2015 - 10:00 / ComEd / ESA Filings

Motion for Leave to Answer and Answer of the Energy Storage Association

Pursuant to Rules 212 and 213 of the Federal Energy Regulatory Commission’s (“FERC” or “Commission”) Rules of Practice and Procedure, 18 C.F.R. §§ 385.212-213 (2014), The Energy Storage Association (“ESA”) submits this Motion for Leave to Answer and Answer to Commonwealth Edison Company’s (“ComEd”) Motion for Leave to Answer and Answer (“ComEd’s Response”).


The Commission is respectfully requested to reject ComEd’s Response because it fails to present new arguments or evidence to assist the Commission in its decision-making process. Moreover, the repetitive information included in the Response mischaracterizes how energy storage batteries operate.