NEPGA Comments on NERC Freeze Protection Measures Proposal (No. RD23-1-000).

On December 8, 2022, NEPGA filed Comments on the North American Reliability Council’s (NERC) proposed standards requiring the adoption of freeze protection measures at generation units (No. RD23-1-000). The standards NERC proposes includes a requirement that an existing generating unit have sufficient freeze protection measures such that it can operate continuously for one hour at […]

NEPGA Comments on New England Winter Gas-Electric Forum – No. AD22-9-000

On November 7, 2022, NEPGA filed Comments in response to the FERC Commissioner-led New England Winter Gas-Electric forum held on September 8, 2022 (Docket No. AD22-9-000). NEPGA explains that it drew three conclusions from the Forum: (1) New England may be at risk of involuntary load shed in the winter months because its reliability needs […]

NEPGA Files Answer in MOPR Elimination Proceeding – No. ER22-1528-000

On May 5, 2022, NEPGA filed an Answer to several comments and protests filed earlier in the FERC proceeding concerning the ISO-NE and NEPOOL joint proposal to eliminate the Minimum Offer Price Rule (MOPR) (Docket No. ER22-1528-000). NEPGA first recounts the diverse set of stakeholders who, like NEPGA, filed comments in support, including Shell (a […]

NEPGA Files Comments in Support ISO-NE Waiver Request (No. ER22-1060-000)

On February 22, 2022, NEPGA filed comments in support of ISO-NE’s motion to temporarily waive the Tariff requirement that ISO-NE publish certain information following the running of FCA 16 (No. ER22-1060-000). On February 15, ISO-NE filed a motion with FERC asking for a waiver of its obligation to public de-list bid and capacity zone information […]

NEPGA Answers NTE Connecticut LLC Motion to Stay – Docket No. ER22-355-001

On January 18, 2022, NEPGA filed an Answer to NTE Connecticut LLC’s (owner and developer of the Killingly Energy Center (KEC)) Emergency Motion to Stay and Request for Rehearing in response to FERC’s order accepting ISO-NE’s termination of the KEC Capacity Supply Obligations (CSOs) and qualification for FCA 16 (Docket No. ER22-355-001). On January 4, […]

NEPGA Answer – Monthly Regional Network Load Proceeding (Docket No. ER21-2337)

On August 12, NEPGA filed an Answer challenging the Participating Transmission Owners’ (TOs) proposal to amend the definition of Monthly Regional Network Load (MRNL) to newly require Network Customers to not reconstitute their load profiles to account for the energy delivered by unregistered behind-the-meter resources (Docket No. ER21-2337). The Tariff currently requires that in calculating […]