NEPGA Answers NEPOOL and ISO-NE in ORTP Proceeding – No. ER21-1637-000

On May 20, 20201, NEPGA answered NEPOOL and ISO-NE.  In its Answer, NEPOOL argues that the Commission should reject NEPGA’s assertions of the Joint Filers’ violation of the filed rate doctrine because they are simply “legal arguments” and the Commission is not “constrained by such principles.”[2]  Compliance with the filed rate doctrine and the corollary […]

NEPGA Files Protest of NEPOOL-Proposed Offer Review Trigger Price

On April 28, 2021, NEPGA filed a Protest of NEPOOL’s proposed Offer Review Trigger Price (ORTP) for off-shore wind resources and a related NEPOOL proposal to base the ORTP for off-shore wind resource on a 25 year, versus the current 20 year discounted cash flow model (Docket No. ER21-1637-000). ISO-NE filed these proposals as part […]

NEPGA Files Comments in Support of Energy Efficiency Proposal – Docket No. ER21-943-000

On February 16, 2021, NEPGA filed Comments in support of ISO-NE’s proposal to exempt energy efficiency resources for Pay for Performance charges and payments due to a Capacity Scarcity Condition that occurs in a peak load hour (Docket No. ER21-943-000). Energy efficiency resources are presently exempt from such charges and payments for Capacity Scarcity Conditions […]

NEPGA Intervenor Brief – Inventoried Energy Program Appeal – DC Cir No 19-1224

On February 16, NEPGA filed an Intervenor Brief in the appeal of the Inventoried Energy Program (IEP) currently before the U.S. Court of Appeals for the D.C. Circuit (No. 19-1224). NEPGA raised several issues for the court to consider, including that ISO-NE developed the IEP as an interim measure to ensure system reliability until a […]

NEPGA Answers ISO-NE in Net CONE Proceeding – Docket No. ER21-787-000

On February 16, 2020, NEPGA filed an answer to ISO-NE’s answer to NEPGA’s protest of ISO-NE’s proposed Net CONE value for effect beginning in FCA 16 (No. ER21-787). On December 31, 2020, ISO-NE filed its Net CONE proposal with FERC. On January 21, NEPGA protested the proposal though a 50-page protest supported by affidavits challenging […]

NEPGA Protests ISO-NE Net CONE Value Proposal – Docket No. ER21-787-000

On January 21, 2021, NEPGA filed a Protest of ISO-NE’s proposed Net CONE value for effect beginning in FCA 16 (No. ER21-787-000). ISO-NE proposed a Net CONE value of $7.024/kW-month, a significant reduction for the FCA 15 Net CONE value of $8.707/kW-month. NEPGA challenges several aspects of ISO-NE’s proposal. NEPGA first argues that ISO-NE has […]

NEPGA Files Complaint Against ISO-NE for Net CONE Methodology – No. EL21-26-000

On December 11, 2020. NEPGA filed a complaint against ISO-NE alleging that ISO-NE violated its Tariff by recalculating and reviewing with NEPOOL stakeholders a new Net CONE value based on a methodology not on file with the Commission and in conflict with the Tariff definition of Net CONE (Docket No. EL21-26-000). ISO-NE and its consultants […]