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FERC Urged to Reject ISO-NE Proposal

Two power groups have called on FERC to reject ISO New England Inc.'s (ISO-NE) proposal to share real-time information on individual natural gas-fired power generators with interstate gas pipelines serving the region. The ISO has asked the Federal Energy Regulatory Commission (FERC) to approve its proposal quickly to head off concerns about unreliable generation dispatch this winter in an increasingly gas-dependent region.

In separate filings at the Commission, the Electric Power Supply Association (EPSA) and the New England Power Generators Association.(NEPGA) said that a nondisclosure agreement (NDA) that is among the proposed tariff changes to ISO-NE's Information Policy is "unjust, unreasonable and unduly discriminatory and should be rejected by the Commission." When it filed its proposal last month, ISO-NE warned FERC that stakeholders said they would fight the proposal on the basis of a single issue: "that the generators whose information is being shared should be third-party beneficiaries to the nondisclosure agreement between ISO-NE and the gas pipelines (see NGI, Nov. 19).

Prompting the request is a history of generation resources falling short of what was requested of them in times of need, ISO-NE told FERC. The ISO is particularly concerned because the region is relying increasingly on gas-fired resources. If approved by FERC, the proposed tariff revisions, which seek to address reliability concerns and gas-electric coordination in New England, would take effect Dec. 7 on an interim basis.

There are "several significant concerns" with the ISO's NDA proposal, "including: 1) that the generators whose information is being shared are not (but should be) third-party beneficiaries to the NDA, between the ISO and the pipelines; and 2) the CI provided to a pipeline must only be maintained as such for six months, after which the pipeline has no obligation to maintain the confidentiality of the CI," EPSA said [ER13-356].

As an alternative to the ISO's proposal, the two groups urged FERC to adopt the NDA that was overwhelmingly approved in early November by the New England Power Pool (NEPOOL), which they said recognized the rights of power generators. "Under the NEPOOL preferred NDA...both of these flaws are addressed and the Commission should require it to be adopted," the EPSA said.

The proposed revisions to the Information Policy would allow ISO-NE to share CI concerning the day-ahead forecast and real-time output of individual gas-fired generators, as opposed to aggregated data on the region's market, subject to a pipeline executing a pipeline NDA. To date, the ISO has provided gas pipeline operators with aggregate generator output schedule information. ISO-NE said by sharing expected generation output schedules confidentially with pipelines, pipeline operators may be able to provide ISO operators with confidential gas availability information that would allow the ISO to anticipate and address potential reliability problems in cases where there is insufficient fuel for all gas-fired generators to meet their schedules.

If the Commission should issue an interim order making the pipeline NDA effective Dec. 7 (Friday), the NEPGA said it should be subject to refund and a final order issued as soon as practicable. "For so long as the pipeline NDA is effective, affected generators will be denied their rights to enforce the confidentiality of their CI absent a refund provision in the Commission's interim order," said the group, which represents about 27,000 MW of installed generation capacity in the New England region.

Concerns around coordinating the scheduling activities of natural gas pipelines and power generators in the Northeast have gained in prominence this year. PJM Interconnection and the New York Independent System Operator also are wrestling with scheduling issues, and a study is underway to assess threats to system reliability.

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