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 EDCs Motion for Clarification in Fuel Security Proceeding – Nos. ER18-1509 and EL18-182
NEPGA answered the Indicated Electric Distribution Companies’ (EDCs) Motion for Clarification, in which the EDCs ask FERC to find that the “central purpose” of its order directing ISO-NE to file improvements to its market design to address fuel security needs is to “add new infrastructure” to New England (Nos. ER18-1509 and EL18-182). In order to […]
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 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 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 […]
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 […]
On May 23, 2018, NEPGA filed two related pleadings at FERC: A Complaint (with a request for fast-track processing) asking for relief from ISO-NE’s proposal to re-price the Mystic 8 and 9 Units, or any other resources subsequently retained for fuel security, as price-takers in the FCA, and offering a remedy that would require such […]
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 Answer to NESCOE Request for Clarification in Peak Energy Rent Settlement- Nos. EL16-120, et al.
NEPGA filed an Answer to the Motion for Clarification filed by the New England States Committee on Electricity (NESCOE) in the Peak Energy Rent (PER) settlement proceeding (Nos. EL16-120, et al.). In its Motion, NESCOE asks the Commission to find that the terms agreed to the in the PER settlement do not apply to capacity […]
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 […]