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 […]

NEPGA filed a Limited Protest of the cost-of-service (COS) agreement for the Mystic Units (No. ER18-1639), asking FERC to correct for certain terms in the proposed COS agreement that could cause energy and capacity market price suppression, including the limit on Mystic Unit energy offers to not exceed Energy Market Reference Levels (which are set […]