ESA submitted comments in support of PJM’s Effective Load Carrying Capability (ELCC) framework filing on 3/1, in response to FERC’s information request issued on 12/22/20 associated with PJM’s initial ELCC proposal to FERC (Docket No. ER21-278-000). ESA disagrees with protests filed on 3/22 requesting that FERC delay implementation of the ELCC construct until further evaluation of the ELCC methodology is done. Specifically, ESA stresses that modifying the ELCC transitional framework further and refiling it with FERC for additional comment and evaluation is both not necessary at present and is contrary to the imperative to imminently rectify long-standing and ongoing deficiencies in PJM’s capacity market design that systematically disadvantage energy storage resources. In light of PJM’s extensive consultation and broad stakeholder support to date, ESA urges FERC to approve the ELCC filing to imminently enable full participation of storage resources in PJM without further delay.