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 […]

NEPGA Answers Vineyard Wind Emergency Motion – On Tuesday, NEPGA filed an Answer to the Emergency Motion filed by Vineyard Wind on Monday (just hours before the commencement of FCA 13) in which Vineyard Wind asked FERC to stay, or in the alternative “re-run” FCA 13 following its conclusion (Docket No. ER19-570). Vineyard Wind’s request […]

On February 4, 2019, NEPGA filed Comments asking FERC to conditionally grant an ISO-NE Motion for Extension of Time to file certain market design changes (Docket No. ER18-182). FERC previously ordered ISO-NE to file by July 1, 2019, a market-based solution to New England’s winter energy security concerns (the so-called Chapter 3). In its Motion, […]

On January 4, 2019, NEPGA filed Comments objecting to FERC granting Vineyard Wind LLC’s request that FERC waive several sections of the Tariff to allow Vineyard Wind to participate as a Renewable Technology Resource (RTR) in FCA 13 (No. ER19-570). On December 14, Vineyard Wind filed the request seeking waiver of Tariff deadlines to elect […]

On January 6, 2019, NEPGA filed a Motion to Lodge the U.S. Court of Appeals for the D.C. Circuit’s (the Court) recent opinion in Exelon Corporation v. FERC into the pending FERC proceeding concerning the mitigation “test price” methodology (No. ER19-444). In Exelon, the Court remanded to FERC its orders accepting the Retirement De-List Bid […]

On January 2, 2019, NEPGA filed a Request for Rehearing of FERC’s order accepting ISO-NE’s proposal to, inter alia, re-price as price-takers in the FCA a resource made eligible for a cost-of-service agreement to meet a demonstrated fuel security need (Fuel Security Resource) (Docket Nos. EL18-182 and ER18-2364). This holding will apply to the Mystic […]

On December 21, NEPGA filed a Limited Protest of one part of a series of largely “conforming” changes to the Competitive Auction and Sponsored Policy Resource (CASPR) design (Docket No. ER19-444). Among the CASPR changes proposed by ISO-NE is the creation of “test price” mitigation methodology that serves to disqualify certain resources from offering as […]

On December 20, NEPGA filed an Answer to ISO-NE’s answer in the FERC proceeding concerning the Installed Capacity Requirement (ICR) and associated demand curve values for FCA 13 (together, FCA 13 Values) (No. ER19-291). On November 27 and December 12, respectively, NEPGA filed a Conditional Protest and Supplemental Protest of the FCA 13 Values.  NEPGA […]