Comments on CT Ozone Regulations

On May 10, NEPGA filed comments with the Connecticut Department of Energy and Environmental Protection (DEEP) regarding proposed NOx regulations.

NEPGA Files Comments in Support of Cost Recovery

On April 4, 2023, NEPGA filed Comments in support of Dynegy Marketing Trading’s (DMT) (non-confidential, public filing) request that FERC accept its request for cost recovery for the operation of their resources on December 24, 2022 (on which day reserve deficiencies caused a Capacity Shortage Condition) (Docket No. ER23-1261). DMT asserts that its resources incurred […]

NEPGA Answers SATOA Pleadings – Docket Nos. ER23-739-000 and ER23-743-000

On February 6, 2023, NEPGA filed an Answer to the comments filed by National Grid and Vermont Electric Power Company and Vermont Transco (“VELCO”) in response to ISO-NE’s storage as transmission-only assets (SATOAs) proposal (Docket Nos. ER23-739-000 and ER23-743-000). National Grid asks FERC to either “clarify” or direct changes to ISO-NE’s proposal that would allow […]

NEPGA Comments on Storage As Transmission-Only Asset – FERC Docket Nos. ER23-739-000 and ER23-743-000

On January 19, 2022, NEPGA filed Comments on ISO-NE’s proposal to allow electric storage facilities to compete to meet certain transmission reliability needs (so-called Storage as Transmission-Only Assets or SATOAs) and to allow ISO-NE to dispatch SATOAs under certain proscribed conditions. (Nos. ER23-739-000 and ER23-743-000). ISO-NE proposes to limit the locational and cumulative quantities of […]

NEPGA Files Joint Answer on NERC Standards – Docket No. RD23-1-000

On December 20, 2022, NEPGA, EPSA and P3 (the Competitive Generators) jointly filed an Answer to comments filed by the ISO/RTO Council in the FERC proceeding concerning new generator freeze protection standards proposed by the North American Electric Reliability Organization (NERC) (Docket No. RD23-1-000). On October 28, 2022, NERC filed for FERC approval a set […]

NEPGA Comments on NERC Freeze Protection Measures Proposal (No. RD23-1-000).

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 […]

NEPGA Comments on New England Winter Gas-Electric Forum – No. AD22-9-000

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 […]