October 31, 2018
ESA Seeks Remedy of ISO-NE Proposal to Constrain Storage Participation in Energy Markets
In response to Enhanced Storage Participation Revisions filed by ISO-NE in FERC Docket No. ER19-84, ESA expresses its support for the tariff filing with the exception of ISO-NE’s intention to automatically redeclare the maximum MW of storage resources participating in the energy market at lower states of charge. Doing so will limit the amount of energy that storage can sell in energy markets in ISO-NE. Automatic redeclaration of the energy output of CSFs to meet ISO-NE’s assigned reserve requirement is thereby unjust and unreasonable, as it does not allow those market participants to earn the full energy revenues for the amount of energy they are capable of providing. Moreover, automatic redeclaration of energy storage resources’ output is a violation of Order 841—and one that ESA believes can be remedied without compromising ISO-NE’s ability to comply with reliability requirements. ESA asks that ISO-NE notify FERC of a means to remedy this issue. Should ISO-NE not do so, ESA asks FERC to remedy or otherwise remove those provisions related to automatic redeclaration in approving ISO-NE’s tariff filing.