January 21, 2020
ESA Asks FERC for Greater Examination of Storage-as-Transmission Beyond MISO Proposal
In response to a filing by Midwest Independent System Operator (MISO) in Docket No. ER20-588 on rules for the storage-as-a-transmission-only asset (SATOA), ESA will file comments today at FERC seeking a larger proceeding to examine updates to rules and processes to enable storage-as-transmission. As ESA believes that the Commission’s decisions may be precedent-setting outside of MISO, along with the complex nature of the issues raised in MISO’s proposal, ESA recommends that FERC convene a technical conference to further explore these issues and, if appropriate, to pursue a rulemaking on storage-as-transmission. Additionally, ESA provides its set of Board-approved policy recommendations for storage-as-transmission in regional planning for consideration in both this MISO docket and any new docket that may be opened.