Tag:Regulation D

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Trade Group Complains that PJM’s Frequency Regulation System Unduly Discriminates Against Energy Storage Resources

Trade Group Complains that PJM’s Frequency Regulation System Unduly Discriminates Against Energy Storage Resources

By William M. Keyser, Molly Suda, and Michael L. O’Neill                     

The Energy Storage Association (ESA) filed a complaint with the Federal Energy Regulatory Commission (FERC or Commission) alleging that PJM Interconnection, L.L.C. (PJM) has adjusted its system operations to unduly discriminate against certain market participants.  ESA argues that PJM changed the rules of its frequency regulation market, without prior FERC approval, and that those rule changes unduly discriminate against limited energy resource participants, such as energy storage providers.

FERC has set May 15, 2017, as the deadline for parties to comment, intervene, or protest ESA’s complaint.  Commenting and/or intervention are important procedural tools that allow interested parties to protect and advocate for their interests.  Given the potentially broad impact of this complaint on PJM’s energy and frequency regulation market design, numerous entities may seek to participate in this proceeding.  K&L Gates will continue to follow this proceeding closely.

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