American Wind Energy Association (“AWEA”) and the Solar Council submit this protest in response to the December 3, 2018, compliance filing of PJM Interconnection, L.L.C. to Commission Order No. 841. Specifically, AWEA and the Solar Council protest PJM’s practice of determining electric storage resources’ capacity value (in installed capacity MWs) “based on their discharge/output capability over ten hours of sustained continuous operation.”

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