On December 8, 2023, NEPGA filed Comments in support of ISO-NE’s proposal to allow a Market Participant offering a Retirement or Permanent De-List Bid in the Forward Capacity Auction to reduce the offer price within a certain range and under certain conditions (Docket No. ER24-420-000). Specifically, ISO- NE proposes to allow a Market Participant to […]

On December 6, 2023, NEPGA filed Comments in support of ISO-NE’s proposal to increase the Net Cost of New Entry (Net CONE) value for effect beginning in FCA 19 (No. ER24-401-000). Specifically, ISO-NE proposes to increase the cost of debt and cost of equity values that dictate the after-tax weighted cost of capital (ATWACC), itself […]

On November 21, 2023, NEPGA filed Comments in support of ISO-NE’s proposal to price and procure four types of reserves co-optimized with energy in the day-ahead energy market – its so-called Day-Ahead Ancillary Services proposal (Docket No. ER24-275-000). The proposal creates day-ahead ten-minute spinning, ten-minute non-spinning, thirty-minute operating, and energy imbalance reserves, while retiring the […]

On November 16, 2023, NEPGA filed comments in support of ISO-NE’s and NEPOOL’s joint filing of Tariff changes eliminating the potential for “upward mitigation” in the Real-Time Energy Market (Docket No. ER24-324). ISO-NE’s proposal responds to FERC’s May 5, Show Cause Order granting a Vistra request for the recovery of costs incurred but not recovered […]

On April 4, 2023, NEPGA filed Comments in support of Dynegy Marketing Trading’s (DMT) (non-confidential, public filing) request that FERC accept its request for cost recovery for the operation of their resources on December 24, 2022 (on which day reserve deficiencies caused a Capacity Shortage Condition) (Docket No. ER23-1261). DMT asserts that its resources incurred […]

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 […]