Regulation


DESCRIPTION
ESA Comments re: ISO New England FERC Order 755 Compliance Filing
ESA respectfully requests that the Commission (1)accept these Comments for consideration in this docket, (2) approve ISO-NE’s February 6, 2013 filing as compliant with Order No. 755 and (3) mandate that ISO-NE effectuate the tariffs within 180 days.
ESA Comments re: PJM FERC Order 755 Compliance Filing
ESA Supports PJM’s modifications to its tariff as it complies with Order No. 755 ensuring that regulation resources will be paid in a manner based on the amount of regulation up and regulation down that the resource provides in response to the system operator’s dispatch signal.
ESA Comments re: NYISO FERC Order 755 Compliance Filing
ESA respectfully requests that the Commission approve NYISO’s proposed market mitigation measures for compliance filing with Order No. 755. However, ESA requests that the Commission mandate that NYISO implement an effective date of its new tariffs earlier than the proposed date of June 2013.
ESA Comments re: CA OIR Pursuant to AB 2514 to Consider Procurement Targets for Energy Storage Systems
ESA supports the adoption of procurement goals as a means to ensure the economic, operational and environmental benefits of energy storage are realized.In order to adequately value the economic, operational and economic benefits of the full range of energy storage resources, the PUC is correct that new procurement mechanisms should be implemented. Because ESA’s Advocacy Council members primarily provide transmission-connected energy storage resources in the bulk storage or ancillary services, these Comments are focused on those specific use cases. However, many of the comments apply to the distributed peaker use case as well.
FERC Order Approving CAISO Order 755 Complaince Filing
On April 27, 2012, the California Independent System Operator Corporation (CAISO) submitted a compliance filing and proposed tariff changes to establish a revised compensation methodology governing the provision of frequency regulation service, as required by Order No. 755. FERC accepts CAISO’s compliance filing, subject to conditions, to become effective January 1, 2013. We also require CAISO to make an additional compliance filing within thirty (30) days of the date of this order and an informational report within 14 months of the effective date of the proposed tariff revisions, as discussed herein.
FERC Order Approving MISO Order 755 Compliance Filing
In this order, FERC finds that MISO’s proposal is generally compliant with Order No. 755, and we conditionally accept it, subject to certain conditions outlined below, to become effective on December 17, 2012, as requested. We also require MISO to make an additional compliance filing within 30 days of the date of this order and an informational report within 14 months of the effective date of the proposed Tariff revisions, as discussed herein.
ESA Motion to Intervene and Comments re: FERC Order 755 Compliance Filing
ESA respectfully recommends that FERC approve the Tariff with the Markets-Based Pricing Option by May 18, 2012, as it will eliminate Make-Whole Payments entirely and will comply with Order No. 755. Correcting the shortage pricing problem in PJM’s current tariff is imperative and will result in economically efficient dispatch of Frequency Regulation resources and send appropriate market signals to investors looking to finance new regulation technologies in the region.
FERC Order #755
Pursuant to section 206 of the Federal Power Act, the Commission is revising its regulations to remedy undue discrimination in the procurement of frequency regulation in the organized wholesale electric markets and ensure that providers of frequency regulation receive just and reasonable and not unduly discriminatory or preferential rates. Frequency regulation service is one of the tools regional transmission organizations (RTOs) and independent system operators (ISOs) use to balance supply and demand on the transmission system, maintaining reliable operations.
ESA and AWEA Joint Statement re: RM11-24 and AD10-13
The Energy Storage Association d/b/a Electricity Storage Association (“ESA”), on behalf of its Advocacy Council, and the American Wind Energy Association (“AWEA”) submits this joint statement to demonstrate our common interests in ancillary service market reform.
FERC Pay for Performance NOPR
FERC’s Notice of Proposed Rulemaking (NOPR) on “Pay for Performance” attempts to reduce unnecessary barriers to the participation of all resource types in the wholesale ancillary services markets by requiring regional RTOs and ISOs to compensate based on performance, rather than technology type.
FERC PJM Docket - Regulation Market Clearing Price
In June 2010, FERC began considering the need to have a uniform Regulation Market Clearing Price (“RMCP”) inclusive of opportunity cost after PJM submitted its proposal to calculate a RMCP every five minutes during real-time dispatch to incorporate the marginal unit’s opportunity cost.
FERC Notice of Inquiry for Ancillary Services
FERC is seeking comment on ways to develop robust competitive markets for ancillary services and other energy storage technologies. FERC is seeking both general comments, and more specific comments on how electricity storage should be compensated for the full range of services it provides under the Federal Power Act.