UNITED STATES OF AMERICA
BEFORE THE

FEDERAL ENERGY REGULATORY COMMISSION

Electric Storage Participation in

Markets Operated by Regional

Transmission Organizations andDocket No.  RM16-23-000

Independent System Operators

COMMENTS OF THE ISO/RTO COUNCIL

IN SUPPORT OF MOTIONS TO EXTEND THE COMMENT PERIOD

Pursuant to Rule 212 of the Rules of Practice and Procedure of the Federal Energy

Regulatory Commission (“Commission”), 18 C.F.R. § 385.212 (2016), the ISO/RTO Council (“IRC”)1 respectfully submits these Comments in support of motions to extend the period for filing comments in response to the Notice of Proposed Rulemaking (“Notice”) in the abovecaptioned dockets to February 28, 2017.2

I.COMMENTS

The IRC believes that an extended comment period will enable better preparation of more detailed responses to the myriad issues the Commission raised in its Notice.  The Notice addresses two emerging and complex areas of interest to the industry: energy storage

1

The IRC is comprised of the Alberta Electric System Operator (“AESO”), the California Independent

System Operator Corporation (“CAISO”), the Electric Reliability Council of Texas, Inc. (“ERCOT”), the

Independent Electricity System Operator (“IESO”), ISO New England Inc. (“ISO-NE”), the Midcontinent

Independent System Operator, Inc. (“MISO”), the New York Independent System Operator, Inc. (“NYISO”), PJM Interconnection, L.L.C. (“PJM”), and the Southwest Power Pool, Inc. (“SPP”). ERCOT, AESO, and IESO are not FERC-jurisdictional and are not joining in these Comments.

2

The IRC supports the motions for extension of time filed by: (1) National Hydropower Association

(“NHA”), and (2) American Public Power Association, and the Edison Electric Institute, Large Public Power Council, National Rural Electric Cooperative Association, and the National Association of Regulatory Utility Commissioners (“the Trade Associations”).

participation and the aggregation of distributed energy resources to participate in wholesale markets.  In each of these topics, the Commission poses a number of complicated questions for which the IRC’s members need more time to respond adequately.  These topics are of critical importance to the future of the energy industry, and therefore warrant additional consideration by all commenters.  The IRC also notes that the comment period currently includes the holiday and end-of-the-year season.

The extension will ensure that the IRC, its members, and all other commenters have sufficient time to prepare and coordinate reasoned comments to address these complex and important issues that will inform the Commission in developing any final rule.  The 29-day extension is relatively short and will not delay the exploration and resolution of the issues presented in the Notice unduly, nor will any parties be prejudiced.

II.CONCLUSION

For the foregoing reasons, the IRC respectfully requests that the Commission grant

the Motions submitted by the NHA and the Trade Associations to extend the period for filing comments in this docket to February 28, 2017.

Respectfully submitted,

/s/ Anna McKenna/s/ Carl Patka

Roger E. Collanton, General CounselRobert E. Fernandez, General Counsel

Anna McKennaRaymond Stalter, Director of Regulatory

Assistant General Counsel, RegulatoryAffairs Carl Patka, Assistant General

California Independent System OperatorCounsel

CorporationNew York Independent System Operator,

250 Outcropping WayInc.

Folsom, California 9563010 Krey Boulevard

amckenna@caiso.comRensselaer, NY  12144

cpatka@nyiso.com

/s/ Margoth Caley/s/ Craig Glazer

Raymond W. HepperCraig Glazer

Vice President, General Counsel, andVice President-Federal Government Policy

SecretaryJames M. Burlew Senior Counsel

Theodore J. ParadisePJM Interconnection, L.L.C.

Assistant General Counsel, Operations andSuite 600

Planning1200 G Street, N.W.

Margoth CaleyWashington, D.C. 20005

Senior Regulatory Counsel202-423-4743

ISO New England Inc.Craig.Glazer@pjm.com

One Sullivan RoadJames.Burlew@pjm.com

Holyoke, Massachusetts 01040

mcaley@io-ne.com

/s/ Stephen G. Kozey/s/ Joseph W. Ghormley

Stephen G. KozeyPaul Suskie

Senior Vice PresidentSenior Vice President, Regulatory Policy and

Midcontinent Independent SystemGeneral Counsel

Operator, Inc.Joseph W. Ghormley

720 City Center DriveSenior Attorney

Carmel, Indiana 46032Southwest Power Pool, Inc.

stevekozey@misoenergy.org201 Worthen Drive

Little Rock, Arkansas 72223

jghormley@spp.org

December 20, 2016

CERTIFICATE OF SERVICE

I hereby certify that I have this day e-served a copy of this document upon all parties listed on the official service list compiled by the Secretary in the above-captioned proceeding, in accordance with the requirements of Rule 2010 of the Commission’s Rules of Practice and Procedure (18 C.F.R. § 385.2012).

Dated this 20th day of December, 2016 in Folsom, California.

/s/Martha Sedgley

Martha Sedgley