UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
ISO New England Inc. | Docket Nos. ER16-446-000
Comments of the New England States Committee on Electricity
Pursuant to the Federal Energy Regulatory Commission’s (“Commission” or “FERC”) December 2, 2015 Combined Notice of Filings #1, the New England States Committee on Electricity (“NESCOE”) hereby files these comments in the above-captioned proceeding.1 On December 1, 2015, ISO New England Inc. (“ISO-NE” or the “ISO”) filed with the Commission the Installed Capacity Requirement (“ICR”) and other values for annual reconfiguration auctions corresponding with the 2016/2017, 2017/2018, and 2018/2019 periods (the “ARA Filing”).2 The ARA Filing follows ISO-NE’s November 10, 2015 filing with the Commission of the ICR and other values for the 2019/2020 Capacity Commitment Period (the “November 10 Filing”).3 Both the ARA Filing and the November 10 Filing describe how ISO-NE has reflected its solar photovoltaic forecast (the “Solar PV Forecast”) into the ICR calculation for those respective capacity commitment periods.
NESCOE filed comments regarding the November 10 Filing that expressed NESCOE’s strong support for including the Solar PV Forecast as an input into the load forecast used to calculate the ICR.4 In its comments, which are attached hereto as Attachment 1, NESCOE underscored that the ICR “represents the level of consumer investment in the ISO-NE markets that is necessary for resource adequacy, and that level of investment must consider in a timely manner the rapid development of solar PV resources that are affecting system demand.”5 NESCOE also discussed how “any attempt to link the Solar PV Forecast with the [Renewable Technology Resource] exemption or other capacity market elements misses” fundamental points about the Solar PV Forecast.6
NESCOE incorporates by reference and adopts in this proceeding its comments concerning the November 10 Filing and respectfully requests that the Commission consider these comments with respect to the ARA Filing.
Respectfully submitted,
/s/ Jason R. Marshall
Jason R. Marshall
General Counsel
New England States Committee on Electricity
655 Longmeadow Street
Longmeadow, MA 01106
Tel: (617) 913-0342
jasonmarshall@nescoe.com
Date: December 22, 2015