NEPGA Comments on Storage As Transmission-Only Asset – FERC Docket Nos. ER23-739-000 and ER23-743-000

On January 19, 2022, NEPGA filed Comments on ISO-NE’s proposal to allow electric storage facilities to compete to meet certain transmission reliability needs (so-called Storage as Transmission-Only Assets or SATOAs) and to allow ISO-NE to dispatch SATOAs under certain proscribed conditions. (Nos. ER23-739-000 and ER23-743-000). ISO-NE proposes to limit the locational and cumulative quantities of […]

NEPGA Files Joint Answer on NERC Standards – Docket No. RD23-1-000

On December 20, 2022, NEPGA, EPSA and P3 (the Competitive Generators) jointly filed an Answer to comments filed by the ISO/RTO Council in the FERC proceeding concerning new generator freeze protection standards proposed by the North American Electric Reliability Organization (NERC) (Docket No. RD23-1-000). On October 28, 2022, NERC filed for FERC approval a set […]

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 […]

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What on earth is going on with energy in New England?

New Englanders are pretty good at braving winter. They know which shovel to use for which kind of snow, which neighbor will need some help, and which grocery store sells out of milk first. But this coming winter feels different, and it’s shaking the confidence of even some of the hardiest Yankees because — from […]

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 […]