March 22, 2021
ESA Responds to NYISO Arguments Regarding Proposed Administrative Fees for Co-located Storage Resources
ESA jointly submitted a filing at FERC on March 19th 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), in response to in New York Independent System Operator’s (NYISO) reply to the Clean Energy Intervenors initial protest in February about pancaked administrative fees proposed in NYISO’s co-located storage resources filing with FERC in January.
NYISO’s reply justifies proposed pancaked rates by stating that if NYISO does not apply administrative fees to co-located resources (both the NYISO and FERC fees), co-located resources would be given an unfair advantage over standalone storage and intermittent resources. In our comments, we clarify that co-located resources–unlike standalone storage that must withdraw energy from the grid and standalone intermittent resources that inject all of their energy into the NYSO grid–do not always inject energy into the NYISO grid, and thus should not have to pay transmission charges in these circumstances. Additionally, NYISO’s reply provides no substantive response as to the fact that the inclusion of this charge to co-located resources appears to violate FERC’s regulations. The Clean Energy Intervenors, thus, assert that NYISO failed to justify applying these pancaked fees to co-located resources.