March 8, 2021

ESA Protests Inappropriate Proposed Administrative Fees in NYISO’s Co-located Storage Resources Model

ESA jointly submitted a limited protest on February 9th with The American Clean Power Association, The Alliance for Clean Energy, and The New York Battery and Energy Storage Technology Consortium (collectively the “Clean Energy Intervenors), highlighting concerns about pancaked administrative fees that are proposed in New York Independent System Operator’s (NYISO) co-located storage resources filing with FERC on January 29. The filing proposes enhancements that will enable a storage and an intermittent resource sharing a common point of interconnection to participate in NYISO’s market as a co-located resource, with two separate IDs. While the co-located storage resource model improves the interconnection process for certain co-located resources, it would assess fees on energy transfers between co-located intermittent and storage resources, even when no megawatt-hours are injected to or withdrawn from NYISO’s grid. ESA argues it is inappropriate to collect such fees since NYISO provides no transmission services in these cases. Additionally, FERC’s regulations do not address the collection of these fees for generation transmitted and consumed solely within interconnection customer interconnection facilities. Thus, NYISO’s inclusion of charging by co-located resources in its computation of annual charges, and subsequent assessment of the fee to a CSR, would appear to violate FERC’s regulations. The Clean Energy Inervenors propose instead that FERC ask NYISO to net out the energy produced by the intermittent resource that is used to charge a co-located storage resource, and not charge the storage resource for the associated negative injections from the intermittent resource.

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