FERC Filings
EPSA's Motion to Intervene Out of Time and Protest New England NESCO
INTRODUCTION
While EPSA supports the development of RSCs and their role in ensuring resource adequacy, infrastructure and reliability across regions, there are several flaws in the Petitioners’ filing that are insurmountable as proposed.
1. NESCOE requests the right to require RTO-NE and the Transmission Owners (TOs) to make Section 205 filings on its behalf.
2. NESCOE retains the ability to expand its scope and responsibility based on a unanimous vote of the six state members.
3. NESCOE reserves the right to review and make determinations on any proposal, market rule revision or tariff change contemplated by RTO-NE and the TOs.
As discussed in several protests filed in the instant proceeding, these requested rights overreach the purview of an RSC and require that the Commission reject these aspects of the petition. EPSA urges the New England stakeholders and states to continue discussion on an RSC proposal that institutes an adequate and proper RSC process for the region.
