Nescoe

Answer in Support of Time Extension for Long-Term Energy Security Proposal

Legal Document

Dated: January 23, 2019

Posted in: ,

Authored by:

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
ISO New England Inc. ) Docket No. EL18-182-000

ANSWER OF THE NEW ENGLAND STATES COMMITTEE ON ELECTRICITY
IN SUPPORT OF THE MOTION FOR EXTENSION OF TIME

Pursuant to Rule 213 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“Commission” or “FERC”), 18 C.F.R. § 385.213, the New England States Committee on Electricity (“NESCOE”) files this answer in support of the January 18, 2019 Motion for Extension of Time that ISO New England Inc. (“ISO-NE”) filed the above-captioned proceeding (“Extension Request”).
The Extension Request asks the Commission to grant a brief extension of time—from July 1, 2019 to November 15, 2019—for ISO-NE’s filing of a long-term, market-based solution to address winter energy security concerns. ISO-NE states that the request “will not adversely impact or jeopardize” the 2024-2025 implementation schedule, which corresponds with the fifteenth Forward Capacity Auction.
Based on ISO-NE’s representation that the additional time will not affect ISO-NE’s implementation date, NESCOE supports the requested filing extension to November 15, 2019. The Extension Request sets forth ISO-NE’s conceptual approach to energy security over the longer-term horizon, explaining that the proposal includes multiple components and interrelated market rule changes. As ISO-NE notes, NESCOE and others have requested information regarding the proposed approach and have raised a number of questions. The time extension will enable ISO-NE to provide the analysis that states and stakeholders need to better understand the proposal’s implications for system reliability, wholesale market structures and operations, and consumer costs, as well as any alternatives. NESCOE emphasizes that these matters are of critical importance to the region. Accordingly, NESCOE urges ISO-NE to work with states and stakeholders during the extension period toward developing solutions that can be implemented without further delay.
For the reasons discussed herein, NESCOE respectfully requests that the Commission grant ISO-NE’s requested extension of time for filing without implications on implementation timeframes.

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
Email: jasonmarshall@nescoe.com