NEPGA Files Protest of ISO-NE Fuel Security Resource Re-Pricing Proposal (No. ER18-2364)

On September 21, 2018, NEPGA filed a protest of ISO-NE’s proposal to re-price resources held for fuel security as price-takers in the Forward Capacity Auction (No. ER18-2364).  ISO-NE’s re-pricing proposal is one part of its compliance filing seeking to satisfy FERC’s directive that ISO-NE file Tariff changes allowing for a resource to be held out-of-market […]

NEPGA Answers ISO-NE and Other Party Protests to NEPGA Complaint – No. EL18-154

NEPGA responded to challenges to the evidence it offered in its complaint showing the significant price-suppressing effect of re-pricing the Mystic Units and distinguished the re-pricing of the Mystic Units from the re-pricing of certain reliability resources FERC has previously found to be just and reasonable, among other arguments (No. EL18-154-000).

NEPGA Files Answer to ISO-NE in Waiver Request Proceeding – No. ER18-1509

NEPGA filed an Answer to an answer ISO-NE filed in the proceeding concerning ISO-NE’s request for waivers from its Tariff to make Mystic Units 8 and 9 eligible for a cost of service agreement for FCAs 13 and 14 (No. ER18-1509-000).  NEPGA responded to ISO-NE’s belief that the Tariff will be amended – specifically sections […]

NEPGA Files Limited Protest of Mystic COS Agreement – ER18-1639-000

NEPGA filed a Limited Protest of the cost-of-service (COS) agreement for the Mystic Units (No. ER18-1639), asking FERC to correct for certain terms in the proposed COS agreement that could cause energy and capacity market price suppression, including the limit on Mystic Unit energy offers to not exceed Energy Market Reference Levels (which are set […]

NEPGA Answers NESCOE Motion for Extension of Complaint Comment Period

On May 25, the New England States Committee on Electricity’s (NESCOE) filed a motion to extend the comment period in NEPGA’s fuel security resource pricing complaint proceeding (No. EL18-154), asserting that a two-week extension is necessary due to the “complex” issues raised by NEPGA’s complaint, the existence of other “interrelated” proceedings, and a common comment […]

NEPGA Files Comments in Grid Resilience Proceeding – No. AD18-7

NEPGA filed a Motion to Intervene and Comments in the grid resilience administrative docket open before FERC (No. AD18-7).  NEPGA asks FERC to take notice that the Operational Fuel Security Analysis produced by ISO-NE, which ISO-NE offers as a “framework” for understanding the “fuel security risk” in New England, does not define that risk because […]

NEPGA Files Protest of Proposed Change to the Dynamic De-List Bid Threshold – ER18-620

NEPGA filed a Protest and supporting Affidavit from Paul Sotkiewicz in response to the ISO-NE/Internal Market Monitor proposal to reduce the Dynamic De-List Bid Threshold from $5.50/kW-month in FCA 12 to $4.30/kW-month in FCAs 13-15 (No. ER18-619).  NEPGA argues that the Dynamic De-List Bid Threshold proposed by ISO-NE and the IMM is unjust and unreasonable […]