July 1, 2019
ESA Responds to PJM’s Critique of ESA Argument Regarding Storage Capacity Value in Order 841 Compliance
ESA will file comments today responding to PJM’s most recent Answer defending its rules on the qualification of storage capacity its Order 841 compliance plan. Specifically, ESA describes how our prior complaint and commissioned study on capacity value of storage in PJM is within the scope of Order 841, contrary to PJM’s argument to the Commission that our arguments are out of scope. Additionally, ESA corrects several misunderstandings of our arguments and connects our arguments to the underlying rationale for Order 841 to not only allow energy storage to participate in wholesale markets but also to allow them to do so in a manner that increases efficient operation of the grid and markets.