FERC Filings

MOTION OF ELECTRIC POWER SUPPLY ASSOCIATION FOR LEAVE TO INTERVENE AND EXTENSION OF TIME TO COMMENT ON THE NEW ENGLAND STANDARD MARKET DESIGN PROPOSAL

MOTION FOR EXTENSION OF TIME

The New England Power Pool (NEPOOL) Participants’ Committee and ISO New England, Inc. (ISO-NE) jointly filed Market Rule changes to implement SMD for New England to replace all of the existing NEPOOL Market Rules currently on file with the Commission. While EPSA fully supports an aggressive timeline for the implementation of regional Standard Market Design, a well-reasoned and meaningful response cannot be developed within the three-week comment period provided by the Commission in light of the complexity of the filing and the imminent issuance of FERC’s own SMD (with possible impact to regional seams issues).

While the FERC’s SMD development should not restrain New England from developing and implementing important market design changes in a timely manner, the New England SMD includes over 440 pages of details that must be analyzed in the context of FERC’s proposal. Because the timeframe on these two proposals is so close, EPSA respectfully requests a brief amount of additional time to review the New England SMD alongside the Commission’s proposal. Neither FERC nor parties want to see New England develop a market design that may inadvertently conflict with the FERC’s SMD, causing New England to backtrack on its proposal in order to facilitate both the FERC policy and resolution of regional seams issues. Further, EPSA does not intend to delay the process in New England, but to take an additional two weeks to enable parties and stakeholders to prepare and submit comprehensive, meaningful responses to better aid the Commission in its own deliberations and help the New England ISO to move quickly to a workable SMD.

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