NEPGA filed a Protest and supporting Affidavit from Paul Sotkiewicz in response to the ISO-NE/Internal Market Monitor proposal to reduce the Dynamic De-List Bid Threshold from $5.50/kW-month in FCA 12 to $4.30/kW-month in FCAs 13-15 (No. ER18-619).  NEPGA argues that the Dynamic De-List Bid Threshold proposed by ISO-NE and the IMM is unjust and unreasonable […]

NEPGA filed Comments and a Limited Protest of ISO-NE’s proposal to create a second auction – a Substitution Auction – to allow certain subsidized clean, renewable and alternative energy resources the opportunity to acquire a Capacity Supply Obligation when they are not economic in the Forward Capacity Auction (No. ER18-619).  NEPGA offered its support for […]

On December 20, 2-17, Calpine Corporation and LS Power Associates (the Complainants) filed a complaint asking FERC to order ISO-NE to adopt a Tariff provision that would cause ISO-NE to not offer Unit 1 of the Clear River Energy Center (Clear River) as supply in FCA 12 and to not compensate Unit 1 during the […]

NEPGA filed comments with FERC in response to ISO-NE’s filing of a Net Installed Capacity Requirement for effect in FCA 12 (No. ER18-263-000).  NEPGA explains that the NICR methodology employed by ISO-NE overstates the contribution of behind the meter solar pv resources to ISO-NE’s resource adequacy needs, but notes that ISO-NE has committed to work […]

NEPGA filed a Request for Rehearing of the FERC order accepting the Net CONE value and Offer Review Trigger Price values proposed by ISO-NE for effect beginning in FCA 12 (No. ER17-795-000). In its order, FERC accepted ISO-NE’s proposal to base the Net CONE value on a greenfield development, simple-cycle frame combustion turbine reference technology, […]

NEPGA and the Independent Power Producers of New York (IPPNY) jointly filed comments in response to the FERC Notice of Proposed Rulemaking initiated by the U.S. Department of Energy (DOE) regarding “reliability and resiliency” (No. RM18-1).  The NOPR proposed by DOE would, if adopted, require RTO/ISO wholesale markets to provide cost of service rates to […]

NEPGA filed the a response to a “notice of further developments” FERC filed with the U.S. Court of Appeals for the D.C. Circuit on September 19 in NEPGA’s appeal of the 2014 and 2015 FERC orders denying NEPGA relief from the Peak Energy Rent (PER) Adjustment (D.C. Cir. Nos. 16-1023 and 16-1024). In its notice, FERC […]

NEPGA and several parties to the Peak Energy Rent hearing and settlement conference filed a reply to comments filed by the New England States Committee on Electricity (NESCOE) (Nos. EL16-120 and ER17-2153).  In a settlement filed in July, the parties (including NEPGA and NESCOE) agreed to an increase in the Peak Energy Rent (PER) Strike […]

On August 24, 2017, NEPGA filed an Answer to Public Citizen Inc.’s protest of the ISO-NE filing of Permanent and Retirement De-List Bids (together, De-List Bids) for FCA 12 (No. ER17-2110).  Consistent with its obligations under the ISO-NE Tariff, on July 19 ISO-NE filed with FERC a confidential and public version of all Permanent and […]

NEPGA filed comments asking the Commission to approve the unopposed Offer of Settlement NEPGA and several other parties jointly filed on July 28, 2017, resolving the Peak Energy Rent (PER) Strike Price increase ordered by FERC in its order granting NEPGA’s complaint on the PER mechanism (Docket Nos. EL16-120 and ER17-2153).  NEPGA asks the Commission […]