ESA Answer to PJM and IMM on Rehearing Requests

Motion to Leave to Answer and Answer of the Energy Storage Association to Requests for Rehearing

Pursuant to Rules 212 and 213 of the Federal Energy Regulatory Commission’s (“FERC” or “Commission”) Rules of Practice and Procedure, the Energy Storage Association (“ESA”) submits this Answer in response to the Request for Rehearing of PJM Interconnection L.L.C. (“PJM”) (“PJM Request”) and the Request for Rehearing of the Independent Market Monitor for PJM (“IMM”) (“IMM Request”) in response to the Commission’s March 30, 2018 Order in the above-referenced docket.

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