In a complaint filed with the Federal Energy Regulatory Commission (FERC) on March 15, 2022, the American Clean Power Association (ACPA) and RENEW Northeast argue that ISO New England (ISO-NE) gives some natural gas-fired power plants an unfair advantage in the grid operator’s capacity and operating reserves markets by assuming that these resources will always have fuel supplies and be able to operate.[1] By comparison, ISO-NE considers how much capacity other resource types can consistently deliver, resulting in renewable resources having accredited capacity below their nameplate capacity. The complaint says that about 9.2 GW of pipeline-supplied gas-fired capacity in New England lacks a backup fuel source. This equals about 28% of the capacity that cleared the grid operator’s most recent capacity auction. The renewable energy trade groups claimed that the grid operator’s preferences for natural gas-fired generators lowers capacity, real-time reserve, and real-time energy prices, thereby creating barriers to renewable energy and energy storage facilities.

ISO-NE is starting a stakeholder process to consider how Effective Load Carrying Capability (ELCC) techniques could be used in quantifying resource capacity contributions to regional resource adequacy, which could address some of the complaint’s concerns. However, the new methodology would be in place until June 2028, so the complaint requests that FERC require ISO-NE to change its capacity accreditation rules by mid-2027.

[1] https://cleanpower.org/wp-content/uploads/2022/03/2022-03-15-Full-complaint-FINAL.pdf