Motion for Leave to Answer and Answer of the Energy Storage Association re: FERC Docket No. ER15-3-000 - Modifications to Customers Identified to Attachment H-13 from Commonwealth Edison Company

Posted: November 7, 2014 - 17:00 / FERC / ESA Filings

Pursuant to Rules 212 and 213 of the Federal Energy Regulatory Commission’s (“Commission” or “FERC”) Rules of Practice and Procedure, 18 C.F.R. §§ 385.212 and 385.213, the Energy Storage Association (“ESA”) hereby requests leave to file this limited response to the October 31, 2014 “Motion for Leave to Answer and Answer of Commonwealth Edison Company” (“Answer”) filed by Commonwealth Edison Company (“ComEd”) in the above-referenced proceeding. ComEd’s Answer merits a response to clarify the record so that the Commission will have correct and complete information regarding the resources and market functions in question regarding load charges assessed to wholesale energy storage resources.

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