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 […]

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 […]

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 […]

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 […]

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 […]

On April 21, 2022, NEPGA filed Comments in support of the ISO-NE and NEPOOL joint proposal to apply a 700 MW Renewable Technology Resource (RTR) exemption from the Minimum Offer Price Rule (MOPR) in FCAs 17 and 18, and to eliminate the existing MOPR for effect in FCA 19 (Docket No. ER22-1528-000). NEPGA asks FERC […]

On March 8, 2022, NEPGA filed Comments in support of ISO-NE’s request that FERC accept Tariff changes that would allow ISO-NE to re-set the FCA 17 schedule (No. ER22-1053-000). The Tariff establishes the many deadlines and steps Market Participants and ISO-NE must take over the course of the year leading up to each Forward Capacity […]