Post Technical Conference Comments of the re: FERC Docket AD13-7-000

Posted: January 8, 2014 - 19:38 / AD13-7-000 / ESA Filings

The Energy Storage Association ("ESA") appreciates the opportunity to submit comments in the above-captioned matter and to provide details on how the current centralized capacity markets rules and structures in the regions served by ISO New England Inc. ("ISO-NE"), New York Independent System Operator, Inc. ("NYSIO") and PJM Interconnection, L.L.C. ("PJM") could be modified so as to support the procurement of energy storage. Adding energy storage resources into the capacity markets will help to ensure the grids' future reliability and operational needs.

Integrating storage resources into the existing capacity markets will provide needed operational flexibility and enhanced resource diversity to the system operators as the make-up of the grid continues to change, either through the addition of variable energy resources or the implementation of economic and/or environmental restrictions on grid resources.

The addition of storage to the capacity markets can be accomplished most efficiently by developing rules specific to energy storage resources, similar to what has been done for energy storage resources in the ancillary services markets.

Energy storage resources are capable of operating in the capacity markets in a cost-effective and environmentally-friendly manner. To ensure that grids benefit from the value that storage resources have to offer, rules must be established that allows energy storage to participate in the capacity markets and to be paid for the value they provide.