On January 4, 2019, NEPGA filed Comments objecting to FERC granting Vineyard Wind LLC’s request that FERC waive several sections of the Tariff to allow Vineyard Wind to participate as a Renewable Technology Resource (RTR) in FCA 13 (No. ER19-570). On December 14, Vineyard Wind filed the request seeking waiver of Tariff deadlines to elect […]

On January 6, 2019, NEPGA filed a Motion to Lodge the U.S. Court of Appeals for the D.C. Circuit’s (the Court) recent opinion in Exelon Corporation v. FERC into the pending FERC proceeding concerning the mitigation “test price” methodology (No. ER19-444). In Exelon, the Court remanded to FERC its orders accepting the Retirement De-List Bid […]

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 […]