UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
ISO New England Inc. New England Power Pool Participants Committee } Docket No. ER22-1528-000
COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION
These comments detail that the ISO’s proposal is acceptable as long as it is paired with the additional reforms that ISO-NE outlines in its filing. EPSA notes that the 2-year transition period will afford ISO-NE and NEPOOL stakeholders the time needed to focus efforts on developing and filing with the Commission two key market enhancements (capacity accreditation and day-ahead ancillary services). EPSA views these two market mechanisms as critical aspects of any transition away from MOPR as and deployment of these policies will provide capacity market participants with an opportunity to earn just and reasonable rates for their services when the MOPR is removed while helping to provide market revenues to resources that the region needs to keep the lights on.