April 12, 2019
ESA Files Response at FERC to PJM’s Arguments on Storage Capacity Accreditation in Order 841 Compliance Plan
ESA submitted to FERC a response to PJM’s Answer to complaints by ESA and other stakeholders regarding its compliance plan with Order 841. Specifically, ESA argues that PJM’s proposal to limit capacity offers of storage resources to output levels that can be maintained over 10 hours is inconsistent with the intent of Order 841. ESA also highlights that PJM proposes to unilaterally change the terms and conditions of capacity market participation of electric storage resources, contrary to FERC’s “rule of reason” policy that requires such terms and conditions to be filed in PJM’s tariff and approved by FERC. Additionally, ESA provides new analysis commissioned from Astrape Consulting to demonstrate that PJM’s 10-hour duration requirement for capacity accreditation of storage conflicts with the actual capacity contributions of shorter-duration resources, which are found to provide full capacity value equivalent to other generators even at significant, multi-GW deployment levels.