NEPGA comments filed to the U.S. International Trade Commission’s (USITC) on their investigation: Renewable Electricity: Potential Economic Effects of Increased Commitments in Massachusetts (Investigation No. 332-574).
On June 29, 2020, NEPGA filed a Protest of the complaint brought by Constellation against ISO-NE alleging that ISO-NE has improperly amended its planning procedures, and acted inconsistent with its Tariff in conducting local transmission reliability reviews for the FCA 15 Capacity Commitment Period (No. EL20-52-000). NEPGA makes several counter-arguments in its Protest, including that […]
NEPGA Answer filed at FERC on the NESCOE Protest and NEPOOL Answer (Docket No. ER20-1567).
On May 15, NEPGA filed Comments in support of ISO-NE’s Energy Security Improvements proposal (ESI Proposal) (Docket No. ER20-1567-000), arguing that it is just and reasonable and, in its entirely, compliant with FERC’s Section 206 directive to file “permanent,” long-term market design changes to meet ISO-NE’s “fuel security” needs. NEPGA also asked FERC to reject […]
NEPGA Files in Support and With a Limited Protest of Non-Commercial Capacity Financial Assurance Changes (Nos. ER20-395 and ER20-395)
On December 6, 2019 NEPGA filed two pleadings in response to the companion ISO-NE proposals to change the financial assurance requirements for non-commercial capacity (NCC) resources. First, NEPGA filed Comments in support of ISO-NE’s proposes to create a Trading FA value for any NCC resource that sheds a CSO (through an annual or monthly reconfiguration […]
On November 1, NEPGA filed a Motion to Intervene and Comments in support of ISO-NE’s proposal to eliminate the ability of a resource held in the Forward Capacity Market (FCM) for fuel security to thereafter be held in the FCM to meet a local transmission-related reliability need (Docket No. ER20-89). At present, the Tariff provides […]
On August 8, NEPGA filed an Answer to the New England States Committee on Electricity’s (NESCOE) Motion for Extension of Time pursuant to which NESCOE asks FERC to extend the deadline by which ISO-NE must file market design changes to address New England’s winter energy security needs (the Energy Security Improvements (ESI), or so-called Chapter […]
On August 6, NEPGA filed a Motion for Expedited Action on NEPGA’s Request for Rehearing of FERC’s 2018 order accepting, inter alia, ISO-NE’s proposal to re-price as a price-taker a resource operating under a cost-of-service agreement to meet a fuel security-related reliability need (Docket Nos. EL18-182 and ER18-2364). NEPGA filed its Request for Rehearing on […]
NEPGA Files Comments Pre-Energy Security Improvements FERC Public Meeting (Docket Nos. EL18-182-000, et al.)
On July 9, NEPGA filed Comments in advance of the July 15 FERC Staff-led public meeting to receive information regarding the Energy Security Improvements (ESI) design ISO-NE is developing to comply with FERC’s directive that it file by October 15 improvements to the wholesale market design to address winter energy security issues (Docket No. EL18-182, […]
NEPGA Files Protest of Existing Tariff Rules Under Acceptance of Inventoried Energy Program – No. ER19-1428
On April 15, 2019, NEPGA filed a protest in response to ISO-NE’s Inventoried Energy Program (IE Program) proposal pending before FERC (Docket No. ER19-1428). ISO-NE intends for the IE Program to provide “incremental revenue” to resources that contribute to firm winter fuel and energy in the FCA 14 and 15 winter months, believing that it […]