On January 2, 2019, NEPGA filed a Request for Rehearing of FERC’s order accepting ISO-NE’s proposal to, inter alia, re-price as price-takers in the FCA a resource made eligible for a cost-of-service agreement to meet a demonstrated fuel security need (Fuel Security Resource) (Docket Nos. EL18-182 and ER18-2364). This holding will apply to the Mystic […]

On December 21, NEPGA filed a Limited Protest of one part of a series of largely “conforming” changes to the Competitive Auction and Sponsored Policy Resource (CASPR) design (Docket No. ER19-444). Among the CASPR changes proposed by ISO-NE is the creation of “test price” mitigation methodology that serves to disqualify certain resources from offering as […]

On December 20, NEPGA filed an Answer to ISO-NE’s answer in the FERC proceeding concerning the Installed Capacity Requirement (ICR) and associated demand curve values for FCA 13 (together, FCA 13 Values) (No. ER19-291). On November 27 and December 12, respectively, NEPGA filed a Conditional Protest and Supplemental Protest of the FCA 13 Values.  NEPGA […]

On December 12, NEPGA filed a Supplemental Protest of the Installed Capacity Requirement and MRI Demand Curve values ISO-NE proposes to apply in FCA 13 (commencing in February 2019) (No. ER19-291). On November 27, NEPGA filed a Conditional Protest, conditioned on FERC accepting ISO-NE’s proposal to re-price to $0/kW-month the Retirement De-List Bid offers of […]

On December 10, NEPGA filed a Request for Rehearing of FERC’s November 9 order (a 2-1 decision, with Chairman Neal Chatterjee dissenting) granting ISO-NE’s and its Internal Market Monitor’s (IMM) request to change the mitigation methodology for Retirement De-List Bids (RDL) effective for FCA 13 (Docket No. ER18-1770). The IMM’s RDL mitigation review methodology requires […]

On November 27, 2018, NEPGA filed a Motion to Intervene and Conditional Protest of ISO-NE’s proposed Installed Capacity Requirement (ICR) and MRI Demand Curve values for effect in FCA 13 (Docket No. ER19-291).  As NEPGA explains, ISO-NE uses a different, more relaxed reliability standard for purposes of calculating the ICR and Demand Curve values than […]

NEPGA filed an Answer to ISO-NE’s answer to NEPGA’s Protest of its proposal to re-price resources made eligible for a cost-of-service agreement to meet a demonstrated fuel security need (No. ER18-2364). ISO-NE proposes to allow a resource that would otherwise retire from the FCA to enter into a cost-of-service agreement (or in some cases receive […]

On October 1, 2018, NEPGA filed a Supplemental Protest of ISO-NE’s and its Internal Market Monitor’s proposal to change the economic life calculation for purposes of Retirement De-List Bid mitigation beginning in FCA 13.  NEPGA filed an initial Protest of the proposal in July, following which FERC’s Office of Energy Market Regulation issued a deficiency […]

On September 21, 2018, NEPGA filed a protest of ISO-NE’s proposal to re-price resources held for fuel security as price-takers in the Forward Capacity Auction (No. ER18-2364).  ISO-NE’s re-pricing proposal is one part of its compliance filing seeking to satisfy FERC’s directive that ISO-NE file Tariff changes allowing for a resource to be held out-of-market […]