United States of America Before the Federal Energy Regulatory Commission
ISO New England Inc., New England Power Pool Participants Committee | Docket No. ER19-444-000
Comments of the New England States Committee on Electricity
Pursuant to the Federal Energy Regulatory Commission’s (“Commission” or “FERC”) November 30, 2018 Notice of Filings #1, the New England States Committee on Electricity (“NESCOE”) hereby files these comments in the above-captioned proceeding. On
November 30, 2018, ISO New England Inc. (“ISO-NE” or the “ISO”) and the New England Power Pool Participants Committee (“NEPOOL”) jointly filed with the Commission proposed revisions to ISO-NE Market Rule 1 related to implementation of the ISO’s Competitive Auctions with Sponsored Policy Resources (“CASPR”) rules (the “CASPR-Related Changes”). Among other things, the CASPR-Related Changes clarify that eligibility for the Renewable Technology Resource (“RTR”) exemption to the Minimum Offer Price Rule (“MOPR”) extends to certain renewable resources located in federal waters. NESCOE supports this change.
ISO-NE proposes several market rule changes intended to further accommodate the requirements of state energy and environmental laws. ISO-NE’s CASPR rules, effective for the first time in the next Forward Capacity Auction (“FCA”), offer Sponsored Policy Resources an additional means to obtain a Capacity Supply Obligation from existing resources that wish to permanently exit the market. To qualify for CASPR’s Substitution Auction, Sponsored Policy Resources must, inter alia, be a “renewable, clean or alternative energy resource” under a renewable, clean, or alternative energy portfolio standard or goal as of January 1, 2018. The majority of the CASPR-Related Changes propose Tariff revisions that reflect the ongoing implementation of CASPR: clarifying the mechanics of participation, settlement, and financial assurance; attempting to curb uneconomic bidding behavior; and clarifying the treatment of CASPR results in resource adequacy and planning studies. NESCOE has no objection to these changes that conform the Tariff with CASPR’s ongoing implementation.
Consistent with ISO-NE’s implementation of CASPR, it proposes to clarify eligibility for the RTR exemption to the MOPR. Through the CASPR-Related Changes, ISO-NE clarifies that off-shore wind resources located in Federal waters, with a Point of Interconnection to the ISO-NE grid, are eligible for the RTR exemption. As confirmed in stakeholder discussions, this treatment is consistent with the original intent of the RTR exemption to capture off-shore wind resources and no market participant or stakeholder disputed this intent. — Given these market expectations, as well as the active renewable energy development on the Outer Continental Shelf, the timely clarification of the Tariff with regard to RTR exemption eligibility is imperative to minimize disruption to the marketplace.
For the reasons stated herein, NESCOE respectfully requests that the Commission consider the above comments in this proceeding.
/s/ Benjamin S D’Antonio
Benjamin S D’Antonio
Counsel and Analyst
New England States Committee on Electricity
655 Longmeadow Street
Longmeadow, MA 01106
Tel: (603) 828-8977
Date: December 21, 2018