November 3, 2017
ESA filed supplemental comments before FERC in the matter of Primary Frequency Requirements for energy storage resources
The Energy Storage Association submitted comments in response to the supplemental notice for comment issued on August 18, 2017, following the notice of proposed rule issued on November 17, 2016 pertaining to above-captioned docket. In the comments, ESA asks FERC to modify its proposed rule to avoid disproportionate burdens on electric storage resources for providing primary frequency response (“PFR”) and to ensure market participants can effectively manage electric storage resources for greatest value to the grid. Additionally, ESA recommends that FERC allow each RTO/ISO to choose to make PFR a compensated service as an alternative to requiring PFR capability as an unpriced condition of interconnection agreement.
