February 5, 2019
ESA Advocates for Standalone Storage Eligibility, Tech-Neutrality in Massachusetts Clean Peak Standard
The Energy Storage Association filed comments to the Massachusetts Department of Energy Resources in response to questions on the implementation of the Clean Peak Standard program as required by the energy omnibus bill that was signed into law in 2018. In our comments, ESA responds to questions on technology eligibility, determination of peak periods, and minimum standard requirements. ESA proposes a technology-neutral path to demonstrating resource eligibility, and we aim to capture the benefits of a straightforward program design while meeting the policy objectives of the CPS program. Specifically, ESA provides three pathways to demonstrate eligibility in order to facilitate the inclusion of standalone energy storage systems. ESA also provides initial comments on the process for determining the CPS program targets.