ESA comments that feasible pathways exist for enabling electric storage to provide multiple services while respecting the institutional design of organized wholesale markets. Within the scope of the instant docket, there are several fundamental principles that FERC can establish in short order that would support greater system flexibility and resource efficiency. Those changes would remove further barriers to storage in most markets.

The comments highlight paths forward for participation for electric storage resources in multiple services and recommend actions that FERC is respectfully requested to take, including but not limited to: establishing foundational guidance for RTOs/ISOs to allow electric storage providing transmission services to receive market revenues for generator services under certain circumstances; incorporating electric storage into RTO/ISO transmission planning processes; and establishing foundational guidance for RTOs/ISOs to allow electric storage providing wholesale market services to also provide distribution or end-user services.