NEPGA Files Post-Technical Conference Comments – No. AD21-10-000

On July 19, 2021, NEPGA filed Post-Technical Conference comments following the May 25 FERC Technical Conference on resource adequacy and ISO-NE’s wholesale markets, with a particular emphasis on the potential elimination of the Minimum Offer Price Rule (MOPR) (Docket No. AD21-10-000). NEPGA explains that ISO-NE proposes to eliminate the MOPR and is considering other associated Tariff changes necessary for the FCA to produce competitive clearing prices, but has left little time for it to announce its proposal (which it has not to date) and properly consider the potential consequences and risks of eliminating the MOPR prior to its self-imposed Q1 2022 deadline to file its MOPR-elimination proposal with FERC. NEPGA further explains the need to duly consider the risks to system reliability and market efficiency should ISO-NE eliminate the MOPR, similar to the several months to years of due consideration given to prior major market design changes (e.g., the Pay for Performance design). NEPGA argues that once properly considered, the risks to reliability and efficiency will compel additional Tariff changes necessary to guarantee competitive FCA clearing prices. FERC does not act, per se, in administrative dockets such as this one, and thus NEPGA makes no specific request for relief from FERC, but instead asks that ISO-NE, NEPOOL stakeholders, and the New England states take the time necessary to fully consider the risks and necessary solutions before proposing to eliminate the MOPR, rather than make a filing on a self-imposed deadline that is incomplete in that if fails to adequately account for and remedy the consequences of eliminating the MOPR.  Several other parties also filed comments on Monday, including  NESCOE, EPSA, Eversource, Dominion, Vistra, Advanced Energy Economy, NRG, Calpine, NextEra, and Renew Notheast, among others.

Posted in Document Archive, Federal Filings, Recent Filings.