March 29, 2019

ESA Responds to SPP Request for Delay and ISO-NE & NYISO Answers Regarding Order 841 Complaints

ESA filed responses to the Answers of ISO-NE and NYISO to ESA’s original complaint on Order 841 compliance, as well as SPP’s request for delay. In response to ISO-NE’s stated willingness to revisit its redeclaration method for storage energy output, ESA asked FERC to condition acceptance of ISO-NE’s compliance plan on implementation of a solution by the December 2019 implementation deadline. In response to NYISO’s dismissals of complainants’ requests, ESA provided counterarguments and discussed further ways NYISO could ensure compliance with Order 841 on topics associated with dual participation, state of charge management, and buyer-side mitigation rules. In response to SPP’s request for delay of implementation, ESA asked FERC to set a backstopping deadline of December 2020 in line with SPP’s estimated time needed to finish software upgrades and then implement Order 841.

Comments filed in response to New York Independent System Operator, Inc. Docket No. ER19-467-000

Comments filed in response to ISO New England, Inc. Docket No. ER19-470-000

Comments filed in response to Southwest Power Pool, Inc. Docket No. ER19-460-002 Request for Deferral of Effective Date for Order No. 841 Compliance Filing

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