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 […]

On May 11, 2021, NEPGA filed an Answer to North East Offshore, LLC’s (NEO) (a partnership between Orsted and Eversource) comments in support of NEPOOL’s proposal to set the Offer Review Trigger Price (ORTP) for off-shore wind (OSW) resources at $0/kWm beginning in FCA 16 (Docket No. ER21-1637-000). NEPGA filed a Protest of the NEPOOL […]

On April 28, 2021, NEPGA filed a Protest of NEPOOL’s proposed Offer Review Trigger Price (ORTP) for off-shore wind resources and a related NEPOOL proposal to base the ORTP for off-shore wind resource on a 25 year, versus the current 20 year discounted cash flow model (Docket No. ER21-1637-000). ISO-NE filed these proposals as part […]

On February 16, 2021, NEPGA filed Comments in support of ISO-NE’s proposal to exempt energy efficiency resources for Pay for Performance charges and payments due to a Capacity Scarcity Condition that occurs in a peak load hour (Docket No. ER21-943-000). Energy efficiency resources are presently exempt from such charges and payments for Capacity Scarcity Conditions […]

On February 16, NEPGA filed an Intervenor Brief in the appeal of the Inventoried Energy Program (IEP) currently before the U.S. Court of Appeals for the D.C. Circuit (No. 19-1224). NEPGA raised several issues for the court to consider, including that ISO-NE developed the IEP as an interim measure to ensure system reliability until a […]

On February 16, 2020, NEPGA filed an answer to ISO-NE’s answer to NEPGA’s protest of ISO-NE’s proposed Net CONE value for effect beginning in FCA 16 (No. ER21-787). On December 31, 2020, ISO-NE filed its Net CONE proposal with FERC. On January 21, NEPGA protested the proposal though a 50-page protest supported by affidavits challenging […]

On January 21, 2021, NEPGA filed Comments in support of ISO-NE’s and NEPOOL’s joint proposed change to the Dynamic De-List Bid Threshold methodology (Docket No. ER21-782-000). Under the proposal, the DDBT is set, preliminarily, to the average (mean) of: (1) the prior FCA’s actual system-wide capacity clearing price; and (2) the price at which the […]