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 […]

On November 1, NEPGA filed a Motion to Intervene and Comments in support of ISO-NE’s proposal to eliminate the ability of a resource held in the Forward Capacity Market (FCM) for fuel security to thereafter be held in the FCM to meet a local transmission-related reliability need (Docket No. ER20-89). At present, the Tariff provides […]

On August 8, NEPGA filed an Answer to the New England States Committee on Electricity’s (NESCOE) Motion for Extension of Time pursuant to which NESCOE asks FERC to extend the deadline by which ISO-NE must file market design changes to address New England’s winter energy security needs (the Energy Security Improvements (ESI), or so-called Chapter […]

On August 6, NEPGA filed a Motion for Expedited Action on NEPGA’s Request for Rehearing of FERC’s 2018 order accepting, inter alia, ISO-NE’s proposal to re-price as a price-taker a resource operating under a cost-of-service agreement to meet a fuel security-related reliability need (Docket Nos. EL18-182 and ER18-2364). NEPGA filed its Request for Rehearing on […]

On July 9, NEPGA filed Comments in advance of the July 15 FERC Staff-led public meeting to receive information regarding the Energy Security Improvements (ESI) design ISO-NE is developing to comply with FERC’s directive that it file by October 15 improvements to the wholesale market design to address winter energy security issues (Docket No. EL18-182, […]

On April 15, 2019, NEPGA filed a protest in response to ISO-NE’s Inventoried Energy Program (IE Program) proposal pending before FERC (Docket No. ER19-1428). ISO-NE intends for the IE Program to provide “incremental revenue” to resources that contribute to firm winter fuel and energy in the FCA 14 and 15 winter months, believing that it […]

On April 12, NEPGA filed a Protest of ISO-NE’s FCA 13 Results Filing, specifically with respect to the failure of ISO-NE to include testimony from its Internal Market Monitor (IMM) attesting to the competitiveness of the FCA 13 outcome (Docket No. ER19-1166). The Tariff requires that ISO-NE file, under Section 205 of the Federal Power […]