On February 6, 2023, NEPGA filed an Answer to the comments filed by National Grid and Vermont Electric Power Company and Vermont Transco (“VELCO”) in response to ISO-NE’s storage as transmission-only assets (SATOAs) proposal (Docket Nos. ER23-739-000 and ER23-743-000). National Grid asks FERC to either “clarify” or direct changes to ISO-NE’s proposal that would allow […]
On January 23, 2023, NEPGA filed Comments in support of RENEW Northeast’s complaint alleging that ISO-NE’s Tariff is unjust, unreasonable and unduly discriminatory in imposing on generators, for the duration of 20 to 40-year interconnection agreements, the operating and maintenance (O&M) costs of certain transmission infrastructure put in service to enable a new generator to […]
On January 19, 2022, NEPGA filed Comments on ISO-NE’s proposal to allow electric storage facilities to compete to meet certain transmission reliability needs (so-called Storage as Transmission-Only Assets or SATOAs) and to allow ISO-NE to dispatch SATOAs under certain proscribed conditions. (Nos. ER23-739-000 and ER23-743-000). ISO-NE proposes to limit the locational and cumulative quantities of […]
On December 20, 2022, NEPGA, EPSA and P3 (the Competitive Generators) jointly filed an Answer to comments filed by the ISO/RTO Council in the FERC proceeding concerning new generator freeze protection standards proposed by the North American Electric Reliability Organization (NERC) (Docket No. RD23-1-000). On October 28, 2022, NERC filed for FERC approval a set […]
On December 8, 2022, NEPGA filed Comments on the North American Reliability Council’s (NERC) proposed standards requiring the adoption of freeze protection measures at generation units (No. RD23-1-000). The standards NERC proposes includes a requirement that an existing generating unit have sufficient freeze protection measures such that it can operate continuously for one hour at […]
On November 7, 2022, NEPGA filed Comments in response to the FERC Commissioner-led New England Winter Gas-Electric forum held on September 8, 2022 (Docket No. AD22-9-000). NEPGA explains that it drew three conclusions from the Forum: (1) New England may be at risk of involuntary load shed in the winter months because its reliability needs […]
NEPGA comments on the ISO New England and NEPOOL Pathways analysis on meeting state decarbonization and clean energy requirements. NEPGA reiterates its strong support for a meaningful price on carbon emissions as the most efficient path forward to drive necessary investments, while maintaining a market-based reliability design in New England.
On May 5, 2022, NEPGA filed an Answer to several comments and protests filed earlier in the FERC proceeding concerning the ISO-NE and NEPOOL joint proposal to eliminate the Minimum Offer Price Rule (MOPR) (Docket No. ER22-1528-000). NEPGA first recounts the diverse set of stakeholders who, like NEPGA, filed comments in support, including Shell (a […]
NEPGA comments to Massachusetts Clean Energy & Climate Plan 2025 and 2030 interim updates.