ESA submitted comments in response to the notice of proposed rule issued on November 17, 2016. While ESA does not oppose the requirement of primary frequency (“PFR”) response capability as a condition of interconnection, it is critical that FERC refrain from mandating a PFR provision. As detailed herein, mandating provision of PFR would create undue or discriminatory burdens on electric storage resources. Accordingly, ESA respectfully asks FERC to modify its proposal and direct RTOs/ISOs to make provision of primary frequency response a compensated service.

ESA agrees with FERC that reservation of headroom for the provision of PFR should not be required. ESA interprets the following proposed tariff language as an explicit prohibition against requiring reserving headroom as a condition of interconnection.