Advanced Energy Economy and Sustainable FERC Project submitted at FERC regarding what the petitioners said is the, "the retroactive application of new performance standards for energy efficiency resources that do not appear in those resources’ approved Measurement and Verification Documents in ISO New England, Inc."

Petitioners also sought a FERC order regarding the appropriate process to change energy efficiency’s terms of eligibility in the markets operated by Regional Transmission Organizations/Independent System Operators

The petitioners alleged in their filing that, "This Petition stems from a series of recent phone calls made by staff of ISO-NE to Forward Capacity Market ('FCM') participants with qualified capacity of energy efficiency resources. During those calls, ISO-NE staff indicated that the ISO intends to change its longstanding practice regarding how it measures the demand reduction value of energy efficiency resources for purposes of participation in the FCM. ISO-NE staff indicated that the ISO may potentially do so retroactively and without seeking Commission approval for these changes, even though the contemplated changes could significantly change the quantity of the resources that have already qualified for, and cleared, the most recent Forward Capacity Auction ('FCA'), FCA 13."

The petitioners alleged in their filing that, "Specifically, ISO-NE staff have indicated that the ISO may apply new 'net-to-gross' conversion factors to re-value energy efficiency resources. These new conversion factors 1) were never previously required of, nor imposed on, market participants; 2) are not defined or described in the ISO-NE Tariff ('Tariff') or Manuals; and 3) are not included in most market participants’ ISO-NE-approved FCA 13 Measurement and Verification Documents—the qualification determinations which were filed with, and have been accepted by, the Commission for participation in FCA 13."

The petitioners said in their filing that the ISO-NE Forward Capacity Market has traditionally defined and valued energy efficiency resources based on their total reduction to energy consumption from the baseline federal standards (e.g. gross reductions)

The petitioners alleged in their filing that, "ISO-NE is now claiming it has the legal authority to require energy efficiency resources to offer in (and be compensated for) only the net energy savings achieved by their resources."

"[I]mposition of such a requirement would, in turn, result in energy efficiency resource providers having to reduce their qualified resources to those they can prove were installed by consumers only because of the providers’ efficiency programs," petitioners said

See the petition here for more details

Docket EL19-43.

Tags:
Energy efficiency   Capacity market  

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