NEPGA comments submitted to the New Hampshire Office of Strategic Initiatives on the 2021 update to the State Energy Strategy.
On May 20, 20201, NEPGA answered NEPOOL and ISO-NE. In its Answer, NEPOOL argues that the Commission should reject NEPGA’s assertions of the Joint Filers’ violation of the filed rate doctrine because they are simply “legal arguments” and the Commission is not “constrained by such principles.” Compliance with the filed rate doctrine and the corollary […]
On May 11, 2021, NEPGA filed an Answer to North East Offshore, LLC’s (NEO) (a partnership between Orsted and Eversource) comments in support of NEPOOL’s proposal to set the Offer Review Trigger Price (ORTP) for off-shore wind (OSW) resources at $0/kWm beginning in FCA 16 (Docket No. ER21-1637-000). NEPGA filed a Protest of the NEPOOL […]
On April 28, 2021, NEPGA filed a Protest of NEPOOL’s proposed Offer Review Trigger Price (ORTP) for off-shore wind resources and a related NEPOOL proposal to base the ORTP for off-shore wind resource on a 25 year, versus the current 20 year discounted cash flow model (Docket No. ER21-1637-000). ISO-NE filed these proposals as part […]
NEPGA post-technical conference comments on FERC Modernizing Electricity Market Design March 23 technical conference.
On February 16, 2021, NEPGA filed Comments in support of ISO-NE’s proposal to exempt energy efficiency resources for Pay for Performance charges and payments due to a Capacity Scarcity Condition that occurs in a peak load hour (Docket No. ER21-943-000). Energy efficiency resources are presently exempt from such charges and payments for Capacity Scarcity Conditions […]
On February 16, NEPGA filed an Intervenor Brief in the appeal of the Inventoried Energy Program (IEP) currently before the U.S. Court of Appeals for the D.C. Circuit (No. 19-1224). NEPGA raised several issues for the court to consider, including that ISO-NE developed the IEP as an interim measure to ensure system reliability until a […]
On February 16, 2020, NEPGA filed an answer to ISO-NE’s answer to NEPGA’s protest of ISO-NE’s proposed Net CONE value for effect beginning in FCA 16 (No. ER21-787). On December 31, 2020, ISO-NE filed its Net CONE proposal with FERC. On January 21, NEPGA protested the proposal though a 50-page protest supported by affidavits challenging […]
NEPGA Files Comments in Support of Dynamic De-List Bid Threshold Methodology – Docket No. ER21-782-000
On January 21, 2021, NEPGA filed Comments in support of ISO-NE’s and NEPOOL’s joint proposed change to the Dynamic De-List Bid Threshold methodology (Docket No. ER21-782-000). Under the proposal, the DDBT is set, preliminarily, to the average (mean) of: (1) the prior FCA’s actual system-wide capacity clearing price; and (2) the price at which the […]
On January 21, 2021, NEPGA filed a Protest of ISO-NE’s proposed Net CONE value for effect beginning in FCA 16 (No. ER21-787-000). ISO-NE proposed a Net CONE value of $7.024/kW-month, a significant reduction for the FCA 15 Net CONE value of $8.707/kW-month. NEPGA challenges several aspects of ISO-NE’s proposal. NEPGA first argues that ISO-NE has […]