On February 22, 2022, NEPGA filed an Unopposed Motion to Intervene or in the Alternative Brief Amicus Curiae in support of ISO-NE’s February 18 motion to dissolve the U.S. Court of Appeals for the D.C. Circuit’s stay of FERC’s January order accepting ISO-NE’s disqualification of the Killingly Energy Center from participating in FCA 16. In […]

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 […]

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, […]

On October 12, 2021, NEPGA filed an Amended Protest and Comments on the Participating Transmission Owners’ (PTOs) and ISO-NE’s joint response to a deficiency letter served on those parties in response to their original filing proposing to amend the definition of Monthly Regional Network Load (MRNL) to newly allow Network Customers to not reconstitute their […]

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 […]

On July 22, 2021, NEPGA filed a Protest of the Participating Transmission Owners’ and ISO-NE’s joint proposal to amend the definition of Monthly Regional Network Load (“MRNL”) providing that Network Customers shall not reconstitute their load profiles to account for the energy delivered by unregistered behind-the-meter resources (both with respect to retail meter and Pool […]

On July 19, 2021, NEPGA filed Post-Technical Conference comments following the May 25 FERC Technical Conference on resource adequacy and ISO-NE’s wholesale markets, with a particular emphasis on the potential elimination of the Minimum Offer Price Rule (MOPR) (Docket No. AD21-10-000). NEPGA explains that ISO-NE proposes to eliminate the MOPR and is considering other associated […]

On June 28, NEPGA and EPSA jointly filed a Request for Rehearing of FERC’s Order accepting ISO-NE’s proposed Net Cost of New Entry (CONE) value for effect beginning FCA 16, and its Order denying NEPGA’s related complaint (Docket No. ER21-787 and EL21-26). FERC conditioned its acceptance on ISO-NE adding the cost of on-site gas compression […]

On May 20, 20201, NEPGA answered NEPOOL and ISO-NE.  In its Answer, NEPOOL argues that the Commission should reject NEPGA’s assertions of the Joint Filers’ violation of the filed rate doctrine because they are simply “legal arguments” and the Commission is not “constrained by such principles.”[2]  Compliance with the filed rate doctrine and the corollary […]