Comments on FERC Technical Conference on State Policies & Electricity Markets
NEPGA post-technical conference comments to FERC on the interaction of state policies and wholesale electricity markets (Docket No. AD17-11).
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NEPGA post-technical conference comments to FERC on the interaction of state policies and wholesale electricity markets (Docket No. AD17-11).
NEPGA’s filed an Answer to the Limited Protest filed by the ISO-NE Internal Market Monitor in Exelon’s Section 205 cost recovery filing proceeding (No. ER17-933). NEPGA objects only to the IMM’s request that FERC decide whether Exelon’s contracted fuel costs may be included in an energy market Reference Level. NEPGA explains that to grant the […]
NEPGA filed an Answer and Surrebuttal Testimony in the FERC proceeding addressing the Net CONE value for effect beginning in the twelfth Forward Capacity Auction (No ER17-795). NEPGA responds to the answer ISO-NE filed on February 24, in which ISO-NE sought to refute the arguments NEPGA made in its February 3 Protest. In its Protest, […]
NEPGA filed a Motion for Clarification, and in the alternative a Request for Rehearing, of FERC’s order granting NEPGA’s complaint on the Peak Energy Rent Adjustment mechanism (No. EL16-120). NEPGA asks FERC to confirm that Peak Energy Rent Adjustment payments made by suppliers after September 30, 2016 (the refund effective date) are subject to refund. […]
NEPGA filed a Motion to Intervene and Protest, and supporting testimony from Tanya Bodell (Energyzt), opposing ISO-NE’s proposal to base the Net Cost of New Entry value for effect beginning in FCA 12 on a greenfield development, simple-cycle combustion turbine technology (No. ER17-795). NEPGA argues that ISO-NE’s proposal will cause resource adequacy and market efficiency […]
NEPGA moved to intervene in the Utility Workers Union of America’s appeal before the U.S. Court of Appeals for the D.C. Circuit of the FERC orders approving the results of the tenth Forward Capacity Auction.
NEPGA filed Post-Technical Conference Comments in response to FERC’s November 9 Technical Conference regarding the utilization of electric storage resources as transmission assets compensated through transmission rates (No. AD16-25). NEPGA takes the position that FERC should not adopt a rule granting all new energy storage resources transmission rate cost recovery.
NEPGA filed a Reply Brief to reply briefs filed by the Federal Energy Regulatory Commission and intervenors in NEPGA’s appeal before the U.S. Court of Appeals for the District of Columbia Circuit of the FERC orders denying NEPGA relief from the Peak Energy Rent Adjustment mechanism (D.C. Cir. Nos. 16-1023 and 16-1024).
NEPGA and Exelon (Petitioners) filed a Reply Brief in their joint appeal of several FERC orders approving the Forward Capacity Market treatment of newly cleared resources that elect the seven-year price lock (D.C. Cir. Nos. 15-1071 and 16-1042). Over several proceedings, NEPGA protested and Exelon and Calpine complained that pricing new entry (that elects the […]
The Independent Power Producers of New York (IPPNY) and NEPGA jointly answered a protest filed by NYISO in response to an ISO-NE proposal to modify the rules governing the Forward Capacity Market. NYISO protests that part of the rule changes that would allow certain generators in the constrained capacity zones in the New York Control Area […]