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RTO Insider: FERC: ISO-NE Won’t Change EE Rules Without Stakeholder Talks

Posted by Robert Mullin on Apr 18, 2019

This RTO Insider (subscription) article highlights the positive outcome from AEE's petition to FERC to ensure ISO-NE will not alter energy efficiency performance standards outside of appropriate stakeholder process. AEE's Jeff Dennis' reaction was included. See excerpts below and the entire RTO Insider story here:

In rejecting a request for a declaratory order on Tuesday, FERC provided the petitioners exactly what they were seeking: assurance that ISO-NE will not alter its energy efficiency performance standards outside the stakeholder process.

In February, Advanced Energy Economy (AEE) and the Sustainable FERC Project petitioned FERC to issue a declaratory order that would prevent ISO-NE from retroactively revising Forward Capacity Auction 13 qualification packages to include new measurement and verification (M&V) standards not previously applied to EE resources. They also asked FERC to clarify that the RTO must seek commission approval to make any such changes.


In their initial filing, the groups said their petition arose from reports that ISO-NE staff had made a series of phone calls to Forward Capacity Market participants with qualified EE capacity resources. During those calls, staffers said the RTO intended to change how it measures the demand reduction value of EE resources for participation in the FCM.

The petition alleged the changes could include new “net-to-gross” conversion factors to revalue EE resources, meaning the resources could only offer into the FCM their net energy savings, rather than their gross reduction to load from baseline federal standards. The petitioners noted the factors were “never previously required of, nor imposed on, market participants” nor defined or described in the RTO’s Tariff or manuals...

The petition garnered widespread support, including from public interest organizations, the Massachusetts attorney general and Eversource, which asked that ISO-NE follow the New England Power Pool stakeholder process before making any changes.

FERC on Tuesday dismissed the petition as “premature,” citing ISO-NE’s own statements in response to the petition and its lack of action on the issue (EL 19-43)...

The commission’s order included comments reassuring to the petitioners. “In particular, in its second answer [to the petition], ISO-NE committed that it would only implement a gross-to-net savings methodology for determining the capacity value of energy efficiency resources through a Section 205 filing.”

AEE said it was happy with the outcome.

“As the commission states in its order, ISO New England has committed that it will not make changes to the measurement and verification standards for energy efficiency resources without engaging stakeholders and making a filing with FERC,” Jeff Dennis, AEE managing director, said in a statement. “We appreciate this commitment by ISO-NE in its answer to our petition, and the commission’s recognition of it, which brings needed clarity and certainty for energy efficiency resource providers.”

See excerpts and the entire RTO Insider story here. 

Topics: United In The News