On December 12, NEPGA filed a Supplemental Protest of the Installed Capacity Requirement and MRI Demand Curve values ISO-NE proposes to apply in FCA 13 (commencing in February 2019) (No. ER19-291). On November 27, NEPGA filed a Conditional Protest, conditioned on FERC accepting ISO-NE’s proposal to re-price to $0/kW-month the Retirement De-List Bid offers of […]

On December 10, NEPGA filed a Request for Rehearing of FERC’s November 9 order (a 2-1 decision, with Chairman Neal Chatterjee dissenting) granting ISO-NE’s and its Internal Market Monitor’s (IMM) request to change the mitigation methodology for Retirement De-List Bids (RDL) effective for FCA 13 (Docket No. ER18-1770). The IMM’s RDL mitigation review methodology requires […]

On November 27, 2018, NEPGA filed a Motion to Intervene and Conditional Protest of ISO-NE’s proposed Installed Capacity Requirement (ICR) and MRI Demand Curve values for effect in FCA 13 (Docket No. ER19-291).  As NEPGA explains, ISO-NE uses a different, more relaxed reliability standard for purposes of calculating the ICR and Demand Curve values than […]

NEPGA filed an Answer to ISO-NE’s answer to NEPGA’s Protest of its proposal to re-price resources made eligible for a cost-of-service agreement to meet a demonstrated fuel security need (No. ER18-2364). ISO-NE proposes to allow a resource that would otherwise retire from the FCA to enter into a cost-of-service agreement (or in some cases receive […]

On October 1, 2018, NEPGA filed a Supplemental Protest of ISO-NE’s and its Internal Market Monitor’s proposal to change the economic life calculation for purposes of Retirement De-List Bid mitigation beginning in FCA 13.  NEPGA filed an initial Protest of the proposal in July, following which FERC’s Office of Energy Market Regulation issued a deficiency […]

On September 21, 2018, NEPGA filed a protest of ISO-NE’s proposal to re-price resources held for fuel security as price-takers in the Forward Capacity Auction (No. ER18-2364).  ISO-NE’s re-pricing proposal is one part of its compliance filing seeking to satisfy FERC’s directive that ISO-NE file Tariff changes allowing for a resource to be held out-of-market […]

NEPGA answered the Indicated Electric Distribution Companies’ (EDCs) Motion for Clarification, in which the EDCs ask FERC to find that the “central purpose” of its order directing ISO-NE to file improvements to its market design to address fuel security needs is to “add new infrastructure” to New England (Nos. ER18-1509 and EL18-182). In order to […]

NEPGA responded to challenges to the evidence it offered in its complaint showing the significant price-suppressing effect of re-pricing the Mystic Units and distinguished the re-pricing of the Mystic Units from the re-pricing of certain reliability resources FERC has previously found to be just and reasonable, among other arguments (No. EL18-154-000).

NEPGA filed an Answer to an answer ISO-NE filed in the proceeding concerning ISO-NE’s request for waivers from its Tariff to make Mystic Units 8 and 9 eligible for a cost of service agreement for FCAs 13 and 14 (No. ER18-1509-000).  NEPGA responded to ISO-NE’s belief that the Tariff will be amended – specifically sections […]