To: Dr. David Patton, Potomac Economics
Date: October 23, 2019
Subject: ISO-NE Energy Security Improvements: NESCOE’s Mitigation Concerns
In the near term, ISO New England (“ISO-NE”) will look to you, in your capacity as External Market Monitor, for a conceptual framework for market power mitigation compatible with the proposed Energy Security Improvements (“ESI”) design. As you know, one of NESCOE’s chief concerns about ESI has been the mitigation of market power.
The purpose of this memo is to explain NESCOE’s concerns about the potential for the exercise of market power under ESI, and to suggest some possible measures for your consideration and reaction. This memo largely follows and expands on our comments and proposed ESI ideas discussed at the NEPOOL Markets Committee.