POSITION PAPERS NEPGA issued a paper highlighting its concerns with the special treatment sought in the development of the Northern Pass Transmission Project. The paper may be viewed here. REPORTS CRA International prepared a report at NEPGA's request regarding the ISO New England Internal Market Monitoring Unit's review of the forward capacity market auction results and design elements. To view the report click here. Executive Summary based on the report of Robert Stoddard of CRA International available here. PRESS RELEASES/OP-EDs "Tax on Energy Sends Wrong Message" (NEPGA Op-Ed), April 2, 2012, VTDigger.org"NEPGA Commends Signing of New Hampshire Eminent Domain Bill." "NEPGA Supports Legislation to Complete New Hampshire Restructuring."(NEPGA press release) (NEPGA Testimony on HB 1238), February 2, 2012 "NEPGA Releases Independent Report on Northern Pass Employment Impacts in New Hampshire." (NEPGA press release) (PolEcon Report), January 23, 2012 "NEPGA Announces Dan Dolan as President." (NEPGA press release), October 3, 2011 "Governor Malloys Proposed Generator Tax to Cause Electric Rates to Soar." (NEPGA press release), February 16, 2011 "NEPGA Reacts to Proposed Northern Pass Project." (NEPGA press release), January 29, 2011 "NU-NSTAR Merger as Proposed Will Harm Competitive Energy Markets in New England." (NEPGA press release), January 5, 2011
Regional/Federal:
NEPGA submitted comments under FERC Docket No. AD12-12
regarding the coordination between natural gas and
electricity markets.
(March 30, 2012) NEPGA submitted an answer to ISO-NE's response to FERC's Information Request under Docket No. ER12-757. NEPGA's answer argued that ISO-NE failed to appropriately address FERC's questions regarding potential reliability implications. (February 22, 2012)
NEPGA submitted a protest of ISO-NE's Informational Filing
for the sixth Forward Capacity
Auction under FERC Docket No. ER12-757. NEPGA's protest asserted that
certain MWs located in NEMA would not be available for the FCA 6
Capacity Commitment Period and, as such, ISO-NE should be required to model
NEMA modeled as a separate zone for the sixth auction. NEPGA
submitted a protest under FERC Docket No. ER12-229 regarding
ISO-NE's
proposed Base Capacity Cost Rate for resourcesproviding VAR service
effective January 1, 2012. NEPGA filed a Request for Rehearing and Clarification in FERC Docket No. ER10-787, et al regarding FCM revisions. The filing is in response to FERC's April 13, 2011 order. NEPGA
filed a Motion to Intervene Out-of-Time and Comments in FERC Docket No.
ER 11-3034, regarding ISO-NE's informational filing for qualification
in the fifth Forward Capacity Auction. NEPGA
filed a protest in FERC Docket No. ER11-2377 regarding the transmission
service agreement between Nothern Pass Transmission, LLC and H.Q. Hydro
Renewable Energy, Inc. NEPGA
filed its third brief and supplemental testimony from Professor David
McAdams in the paper hearing set in FERC Docket No. ER 10-787, et al regarding FCM revision. NEPGA filed a Request for Rehearing in FERC Docket No. ER10-787, et al regarding FCM revisions. The
rehearing request was on the issue of revisiting past ISO-NE Internal
Market Monitor determinations that new entry from the first three
Forward Capacity Auctions was not out-of-market. NEPGA filed its second brief in the paper hearing set in FERC Docket No. ER10-787, et al regarding FCM revisions. NEPGA filed its opening brief in the paper hearing set in FERC Docket No. ER10-787, et al regarding FCM revisions. Included with the filing was supporting
testimony from Dr. Roy Shanker, Robert Stoddard of CRA International,
Professor David McAdams and Chris Ungate of Sargent & Lundy LLC. NEPGA
filed comments in FERC Docket No. RM10-17-000 in response to the Notice
of Proposed Rulemaking on demand response compensation in organized
energy markets. Included with the filing was an affidavit from Dr. Roy
Shanker. NEPGA
filed an answer to various comments, protests and answers in
response to NEPGA's March 15, 2010 protest in FERC Docket No.
ER-10-787-000 and March 23, 2010 complaint against ISO-NE in FERC
Docket No. EL10-50-000. Included with the filing were affidavits from Dr. Roy Shanker and
Robert Stoddard of CRA International on behalf of NEPGA. NEPGA
filed a complaint against ISO-NE in FERC Docket EL10-50-000. The
complaint
alleges that ISO-NE's existing tariff governing the Forward Capacity
Market and the changes proposed in the ISO-NE February 22nd filing are
unjust and unreasonable. NEPGA
filed Reply Comments in FERC Docket AD10-5-000 regarding RTO/ISO
Performance Metrics. NEPGA's comments supported the comments of the
Electric Power Supply Association (EPSA), encouraging a
standardized set of metrics for all RTOs/ISOs to properly
evaluate RTO/ISO performance. NEPGA
filed a Motion to Intervene and Protest in FERC Docket ER10-787-000 in
response to several revisions to the tariff governing the Forward
Capacity Market filed by ISO-NE and NEPOOL on February 22, 2010.
Included with the filing were affidavits from Dr. Roy Shanker and
Robert Stoddard of CRA International on behalf of NEPGA. NEPGA
filed a Motion for Leave to Answer and Answer in FERC Docket ER09-1282 in response
to NECPUC's request for mediation of potential reforms to the FCM. NEPGA
filed comments in FERC Docket ER09-1282 regarding ISO-NE's Market
Monitor Unit Report. The comments were submitted with a report on the
Forward Capacity Market by CRA International. NEPGA filed a Petition for Rehearing in FERC Docket No. EL09-20, NU/NStar's Petition for Declatory Order. NEPGA filed Reply Comments in FERC Docket ER09-1051, ISO-NE's Order 719 Compliance Filing. NEPGA
filed a Motion for Leave to Answer and Answer in FERC Docket No.
EL09-20, NU/NStar's Petition for Declatory Order. The filing was a
joint submission with EPSA and IEPM in response to the answers provided
by NU/NStar and HQ Energy. NEPGA filed a Motion to Intervene,
Protest and Alternative Request for Conditions in FERC Docket No.
EL09-20, NU/NStar's Petition for Declatory Order. Connecticut: NEPGA
filed a petition to intervene and comments in DPUC Docket 10-12-05
regarding whether the proposed merger of Northeast Utilties and NSTAR
requires approval by the DPUC.
NEPGA gave testimony to the Committee on
Energy and Technology in opposition to HB 5508 which establishes the
Division of Electricity Policy and Procurement. NEPGA expressed
specific opposition to Section 4 of the bill which allows the newly
formed Division to own and operate generation. NEPGA gave testimony to the Committee on
Energy and Technology in opposition to HB 5505. NEPGA expressed
opposition to the creation of a state power authority, as well as
a provision within the bill which would impose a windfall profits tax
on generators in the state. NEPGA gave testimony to the Committee on
Energy and Technology in opposition to the current drafts of HB 5362
and HB 5365. NEPGA submitted comments to the CEAB regarding the 2009 Integrated Resource Plan. NEPGA testimony to the Committee on
Energy and Technology regarding a proposed "windfall profits tax" bill
and a bill that would enact a Power Authority in the state. Maine NEPGA submitted testimony in opposition to Maine LD 1863. As
drafted, LD 1863 proposes to remove the 100 MW cap
on eligible renewable resources
qualifying for Maine's RPS. NEPGA
filed a petition to intervene in MPUC Docket Nos. 2002-676 and 2006-543
regarding Emera Inc.'s increased ownership in Algoquin Power &
Utilities Corp. NEPGA
filed comments in MPUC Docket No. 2008-255 in opposition to the May 7,
2010 proposed Maine Power Reliability Program settlement agreement
between Central Maine Power and the Office of the Public Advocate,
GridSolar, Industrial Energy Consumers Group and the Conservation Law
Foundation. NEPGA
filed a Petition to Intervene in MPUC Docket No. 2010-289 regarding the
purchase of Maine & Maritimes, the parent company of Maine Public
Service Co., by Emera US Holdings, Inc. NEPGA filed its initial brief in the appeal
of the DPU's ruling on the Cape Wind/National Grid PPA with the MA
Supreme Judicial Court. NEPGA filed a petition to intervene in DPU Docket 10-170 regarding the proposed merger of Northeast Utilities and NSTAR. NEPGA filed an appeal of the MA DPU's
November 22, 2010 order approving a power purchase agreement ("PPA-1")
between National Grid and Cape Wind, LLC. NEPGA filed a reply brief in MA DPU
Docket No. 10-54 regarding the National Grid and Cape Wind, LLC
proposed long-term contract. NEPGA filed its initial brief in MA DPU
Docket No. 10-54 regarding the National Grid and Cape Wind, LLC
proposed long-term contract. NEPGA sent a letter to Ian Bowles, Secretary
of the Executive Office of Energy and Environmental Affairs, in
response to the July 7th letter from Secretary Bowles to Phil Giudice,
DOER Commissioner. Prior to receiving public or stakeholder input, the
EOEEA letter proposed a minimum criteria and deadline for the
consideration of biomass as an eligible fuel source under the state's
RPS going forward. NEPGA submitted comments regarding the Global
Warming Solutions Act Draft Implementation Plan and Proposed 2020
Emissions Reduction Target. NEPGA filed a Motion to Answer and Answer in
MA DPU Docket No. 10-54 in response to National Grid and Cape Wind.
NEPGA's filing objects to the request from both National Grid and Cape
Wind that the DPU limit NEPGA's participant status in the proceeding. NEPGA filed a Petition to Intervene in MA DPU
Docket No. 10-54 regarding the proposed long-term contracts between
Cape Wind and National Grid. NEPGA requested full-party status in the
proceeding. NEPGA provided comments regarding the MA DEP proposed 1990 greenhouse gas baseline and 2020 business as usual projection. NEPGA gave
testimony on four bills in front of the Joint Energy and
Telecommunications Committee. Included within the testimony was NEPGA's
support of An Act Relative to Comprehensive Wind Reform. NEPGA submitted comments to the DEP regarding newly proposed regulations on stormwater management. New Hampshire: NEPGA
submitted comments regarding the Department of Revenue Administration's
proposed revisions to the state's Utility Property Tax rules. NEPGA
filed a Petition to Intervene in PUC Docket No. DE10-195, Petition for
Approval of PPA Between PSNH and Laidlaw Berlin BioPower, LLC. NEPGA
filed a Petition to Intervene in PUC Docket No. DE10-160, Investigation
into the Effect of Customer Migration on PSNH Energy Service
Rates. NEPGA provided testimony to the House Ways
and Means Committee on SB 450. NEPGA testified in opposition to
repealing an electricity consumption tax and replacing it with a tax on
electric generation in the state. NEPGA provided testimony to the Science, Technology
and Environment Committee on SB 334. NEPGA testified against the
provision that would allow PSNH to retain up to $5 million of its
Alternative Compliance Funds for use in building a rate-based solar
photovoltaic project. NEPGA
submitted testimony to the Energy, Environment and Economic Development
Committee on SB 334. NEPGA supported the current version of the bill,
but addressed concerns to a proposed amendment to the bill. NEPGA filed a Petition to Intervene in Docket DE09-180, PSNH Proposed 2010 Default Energy Service Rate. NEPGA provided testimony on behalf of NEPGA to the Science, Technology and Environment Committee on
HB 496 and SB 85. NEPGA provided testimony on behalf of NEPGA to the Energy,
Environment and Economic Development Committee on SB
152. The bill would have given the PUC authority to investigate whether the Merrimack Scrubber project was in
the consumers best interest. NEPGA sent a letter to Representative Arthur Handy, Chair of the Rhode
Island House Committee on Environment and Natural Resources, regarding
House Bill 7592, East Bay Consortium Act. NEPGA wrote a letter to Senator Walaska asking that he make a minor change to language within SB 488, An Act Relating to Health and Safety-Energy Independence. |
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