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 […]

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, […]

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 […]

On April 12, NEPGA filed a Protest of ISO-NE’s FCA 13 Results Filing, specifically with respect to the failure of ISO-NE to include testimony from its Internal Market Monitor (IMM) attesting to the competitiveness of the FCA 13 outcome (Docket No. ER19-1166). The Tariff requires that ISO-NE file, under Section 205 of the Federal Power […]

NEPGA Answers Vineyard Wind Emergency Motion – On Tuesday, NEPGA filed an Answer to the Emergency Motion filed by Vineyard Wind on Monday (just hours before the commencement of FCA 13) in which Vineyard Wind asked FERC to stay, or in the alternative “re-run” FCA 13 following its conclusion (Docket No. ER19-570). Vineyard Wind’s request […]

On February 4, 2019, NEPGA filed Comments asking FERC to conditionally grant an ISO-NE Motion for Extension of Time to file certain market design changes (Docket No. ER18-182). FERC previously ordered ISO-NE to file by July 1, 2019, a market-based solution to New England’s winter energy security concerns (the so-called Chapter 3). In its Motion, […]

On January 4, 2019, NEPGA filed Comments objecting to FERC granting Vineyard Wind LLC’s request that FERC waive several sections of the Tariff to allow Vineyard Wind to participate as a Renewable Technology Resource (RTR) in FCA 13 (No. ER19-570). On December 14, Vineyard Wind filed the request seeking waiver of Tariff deadlines to elect […]