February 14, 2017

ESA Comments to Docket No. RM16-23, FERC NOPR

ESA submitted Comments in response to the Notice of Proposed Rulemaking that was issued by FERC on November 17, 2016. ESA is appreciative that FERC continues to recognize the importance of installing energy storage facilities on our nation’s grid and, as detailed herein, is in general agreement with FERC’s proposals that would direct organized wholesale market operators to create affirmative participation models for electric storage. A rule such as the one now under consideration is necessary for to ensure that all electric storage facilities can operate in organized wholesale markets. ESA respectfully requests that FERC issue a rule that directs regional transmission organizations (“RTOs”) and independent system operators (“ISOs”) to enable electric storage participation in all RTO/ISO markets, effective utilization of electric storage in RTO/ISO market operations, and participation of multiple storage configurations.

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