January 10, 2020
ESA Asks FERC to Defer Ruling on PJM’s Revised Tariff for Capacity Qualification Until Dispute is Resolved
In its ruling on PJM’s Order 841 compliance plan in October 2019, FERC (1) directed PJM to submit tariff provisions detailing the standard for capacity qualification applicable to all resources and (2) initiated a Section 206 proceeding in Docket No. EL19-100 to determine whether such requirements for capacity qualification are just and reasonable and not unduly discriminatory. PJM subsequently filed a formalization of its proposed 10-hour duration standard for capacity qualification of energy storage resources in Docket No. ER20-584.
In comments to be filed today, ESA requests that FERC defer ruling on PJM’s tariff amendment until the Section 206 proceeding is resolved. ESA suggests alternatively that FERC could deny the specific tariff provision that would require a 10-hour duration requirement for capacity storage resources and require submission of a new tariff filing after FERC issues a decision in Docket No. EL19-100.