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 […]

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 […]

On April 21, 2022, NEPGA filed Comments in support of the ISO-NE and NEPOOL joint proposal to apply a 700 MW Renewable Technology Resource (RTR) exemption from the Minimum Offer Price Rule (MOPR) in FCAs 17 and 18, and to eliminate the existing MOPR for effect in FCA 19 (Docket No. ER22-1528-000). NEPGA asks FERC […]

On March 8, 2022, NEPGA filed Comments in support of ISO-NE’s request that FERC accept Tariff changes that would allow ISO-NE to re-set the FCA 17 schedule (No. ER22-1053-000). The Tariff establishes the many deadlines and steps Market Participants and ISO-NE must take over the course of the year leading up to each Forward Capacity […]

On February 22, 2022, NEPGA filed an Unopposed Motion to Intervene or in the Alternative Brief Amicus Curiae in support of ISO-NE’s February 18 motion to dissolve the U.S. Court of Appeals for the D.C. Circuit’s stay of FERC’s January order accepting ISO-NE’s disqualification of the Killingly Energy Center from participating in FCA 16. In […]

On February 22, 2022, NEPGA filed comments in support of ISO-NE’s motion to temporarily waive the Tariff requirement that ISO-NE publish certain information following the running of FCA 16 (No. ER22-1060-000). On February 15, ISO-NE filed a motion with FERC asking for a waiver of its obligation to public de-list bid and capacity zone information […]

On January 18, 2022, NEPGA filed an Answer to NTE Connecticut LLC’s (owner and developer of the Killingly Energy Center (KEC)) Emergency Motion to Stay and Request for Rehearing in response to FERC’s order accepting ISO-NE’s termination of the KEC Capacity Supply Obligations (CSOs) and qualification for FCA 16 (Docket No. ER22-355-001). On January 4, […]

On October 12, 2021, NEPGA filed an Amended Protest and Comments on the Participating Transmission Owners’ (PTOs) and ISO-NE’s joint response to a deficiency letter served on those parties in response to their original filing proposing to amend the definition of Monthly Regional Network Load (MRNL) to newly allow Network Customers to not reconstitute their […]