NEPGA Files Comments in Support of ISO-NE Cost of Service Limit Proposal – No. ER20-89

On November 1, NEPGA filed a Motion to Intervene and Comments in support of ISO-NE’s proposal to eliminate the ability of a resource held in the Forward Capacity Market (FCM) for fuel security to thereafter be held in the FCM to meet a local transmission-related reliability need (Docket No. ER20-89). At present, the Tariff provides that a resource may be held in the FCM for fuel security (FCAs 13-15) for up to two years, and that a resource may thereafter be eligible to be held in the FCM for “another reliability reason,” i.e., for local transmission-related reliability. ISO-NE finds eligibility for a third year of cost-of-service agreement to be “contrary to the ISO’s preferred approach of procuring reliability services through competitive solutions.” NEPGA supported the proposal on the bases that it will avoid: (1) further FCM price-suppression from the re-pricing of cost-of-service resources in the FCM; and (2) using what FERC, ISO-NE and NEPGA consider a “last resort” as a instrument to meet ISO-NE’s reliability needs. NEPGA also encouraged FERC to grant NEPGA’s request for rehearing in the Section 206 fuel security proceeding (Docket No. EL18-182, et al.) pursuant to which NEPGA asks FERC to find that re-pricing cost-of-service resources as price-takers in the FCM is unjust and unreasonable. At its October meeting, the NEPOOL Participants Committee overwhelmingly approved the changes by a show of hands.



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