Nescoe

Limited Protest of ICR for Annual Reconfiguration Auctions for 2019/20, 2020/21, and 2021/22 Periods

Legal Document

Dated: December 21, 2018

Posted in: ,

Authored by:

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
ISO New England Inc. |  Docket No. ER19-447-000
LIMITED PROTEST OF THE NEW ENGLAND STATES COMMITTEE ON ELECTRICITY

Pursuant to Pursuant to Rule 211 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“Commission”), 18 C.F.R. § 385.211, and the Commission’s November 30, 2018 Combined Notice of Filings #1, the New England States Committee on Electricity (“NESCOE”) hereby files this limited protest in the above-captioned proceeding.1 On November 30, 2018, ISO New England Inc. (“ISO-NE”) filed with the Commission the Installed Capacity Requirement (“ICR”) and other values for annual reconfiguration auctions corresponding with the 2019-2020, 2020-2021, and 2021-2022 Capacity Commitment Periods (the “ARA Filing”).2 The ARA Filing follows ISO-NE’s November 6, 2018 filing with the Commission of the ICR and other values for the 2022-2023 Capacity Commitment Period (the “ICR Filing”).3

NESCOE filed a limited protest to the ICR Filing due to a material change ISO-NE made to its system reserve assumption for the determination of the ICR.4 In its protest, which is attached hereto as Attachment 1, NESCOE explained that ISO-NE failed to provide sufficient information in support of its change to this long-standing assumption and, therefore, had not demonstrated that its filing is just and reasonable. The ARA Filing contains the same change to the system reserve assumption and is likewise unjust and unreasonable. NESCOE incorporates by reference and adopts in this proceeding its limited protest of the ICR Filing and respectfully requests that the Commission consider this protest with respect to the ARA Filing.

Respectfully submitted,

/s/ Jason Marshall
Jason Marshall
General Counsel
New England States Committee on Electricity
655 Longmeadow Street
Longmeadow, MA 01106
Tel: (617) 913-0342
jasonmarshall@nescoe.com

Date: December 21, 2018

Document Source Citations

1 On December 3, 2018, NESCOE filed a motion to intervene in this proceeding.

2 Capitalized terms not defined in this filing are intended to have the meaning given to such terms in the ISO-NE Transmission, Markets and Services Tariff (the “Tariff”).

3 ISO New England Inc., Filing of Installed Capacity Requirement, Hydro Quebec Interconnection Capability Credits and Related Values for the Thirteenth FCA (Associated with the 2022-2023 Capacity Commitment Period), Docket No. ER19-291-000 (filed Nov. 6, 2018).

4 Limited Protest of the New England States Committee on Electricity, Docket No. ER19-291-000 (filed Nov. 27, 2018).