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 […]

On January 21, 2021, NEPGA filed a Protest of ISO-NE’s proposed Net CONE value for effect beginning in FCA 16 (No. ER21-787-000). ISO-NE proposed a Net CONE value of $7.024/kW-month, a significant reduction for the FCA 15 Net CONE value of $8.707/kW-month. NEPGA challenges several aspects of ISO-NE’s proposal. NEPGA first argues that ISO-NE has […]

On December 11, 2020. NEPGA filed a complaint against ISO-NE alleging that ISO-NE violated its Tariff by recalculating and reviewing with NEPOOL stakeholders a new Net CONE value based on a methodology not on file with the Commission and in conflict with the Tariff definition of Net CONE (Docket No. EL21-26-000). ISO-NE and its consultants […]

On September 30, 2020, NEPGA filed a Motion to Intervene in the appeal jointly filed by several parties with the U.S. Court of Appeals for the D.C. Circuit, including the Sierra Club, Natural Resources Defense Council, RENEW Northeast, and Conservation Law Foundation (Joint Appellants), challenging the FERC order accepting the Competitive Auctions and Sponsored Policy […]

On June 29, 2020, NEPGA filed a Protest of the complaint brought by Constellation against ISO-NE alleging that ISO-NE has improperly amended its planning procedures, and acted inconsistent with its Tariff in conducting local transmission reliability reviews for the FCA 15 Capacity Commitment Period (No. EL20-52-000). NEPGA makes several counter-arguments in its Protest, including that […]

On May 15, NEPGA filed Comments in support of ISO-NE’s Energy Security Improvements proposal (ESI Proposal) (Docket No. ER20-1567-000), arguing that it is just and reasonable and, in its entirely, compliant with FERC’s Section 206 directive to file “permanent,” long-term market design changes to meet ISO-NE’s “fuel security” needs. NEPGA also asked FERC to reject […]

On December 6, 2019 NEPGA filed two pleadings in response to the companion ISO-NE proposals to change the financial assurance requirements for non-commercial capacity (NCC) resources. First, NEPGA filed Comments in support of ISO-NE’s proposes to create a Trading FA value for any NCC resource that sheds a CSO (through an annual or monthly reconfiguration […]