This RTO Insider (subscription) story covers deficiency letters FERC sent to all six jurisdictional RTOs and ISOs requesting more details on their plans to implement the new FERC energy storage rules. AEE's General Counsel Jeff Dennis shares his perspective. See excerpts below and the entire RTO Insider story here:

FERC staff last week issued deficiency letters to all six jurisdictional RTOs and ISOs over their proposed energy storage rules, pressing for definitions, tariff citations and details on issues including metering, make-whole payments, and self-scheduling.

 The grid operators are facing a December deadline for compliance with Order 841, which requires them to revise their market participation models to allow storage resources 100 kW and larger to provide capacity, energy and ancillary services within their technical ability.

The deficiency letters by the Division of Electric Power Regulation ranged from eight to 11 pages.

Jeff Dennis, general counsel of Advanced Energy Economy, said in a tweet that the detailed questions “demonstrate that FERC is looking for real compliance with the [requirements] to open the markets to storage, and not just paper compliance. Overall, I think this is a positive development…”

See the complete RTO Insider (subscription) story here.