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 eligible SATOAs to, respectively, 30 MW and 300 MW, in recognition of the novelty of SATOAs on the ISO-NE system and the consequential risks to system reliability and to economic price-formation in the wholesale energy markets, among other limits and conditions. In its Comments NEPGA explains that it does not oppose the proposal, specifically on the basis that ISO-NE intends for several of the conditions and limits to mitigate the risk of uneconomic price suppression in the Real-Time Energy Market. NEPGA further explains that though these limits and conditions may mitigate this risk, experience is needed to ensure whether the conditions and limitations proposed will be effective in practice. NEPGA thus asks FERC, if it accepts the proposal, to request in the body of the order that ISO-NE’s Internal and External Market Monitors evaluate and report (in their annual reports on the wholesale markets) on the measure of price-suppression and any adverse operational events the consequence of the pricing and operation of SATOAs, as well as the competitiveness of ISO-NE’s solicitation of SATOAs in consideration of FERC’s Order No. 1000 governing transmission service competition.

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