On January 21, 2021, NEPGA filed Comments in support of ISO-NE’s and NEPOOL’s joint proposed change to the Dynamic De-List Bid Threshold methodology (Docket No. ER21-782-000). Under the proposal, the DDBT is set, preliminarily, to the average (mean) of: (1) the prior FCA’s actual system-wide capacity clearing price; and (2) the price at which the […]
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 […]
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 […]
On November 4, 2020, NEPGA filed Comments in support of NextEra Seabrook’s Petition for Declaratory Order, asking FERC to confirm NextEra’s declarations that it is not required to incur financial losses (actual or through lost opportunities) or be liable for consequential damages in accommodating the interconnection of Avangrid’s New England Clean Energy Connect (NECEC) project […]
On September 30, 2020, NEPGA filed a Motion to Intervene in the appeal jointly filed by several parties with the U.S. Court of Appeals for the D.C. Circuit, including the Sierra Club, Natural Resources Defense Council, RENEW Northeast, and Conservation Law Foundation (Joint Appellants), challenging the FERC order accepting the Competitive Auctions and Sponsored Policy […]
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 […]
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 […]