RENEW Northeast and American Clean Power Association Complaint Seeks to Level the Playing Field By Eliminating Preferences Given to New England Gas-Only Power Generators

Press Release

Mar 15 2022

RENEW Northeast, Inc. (RENEW) and the American Clean Power Association (ACP) today filed a complaint calling on the Federal Energy Regulatory Commission (FERC) to find ISO New England Inc.’s (ISO) rules and practices concerning capacity accreditation and designation of operating reserves provide undue preferences to natural gas-fired generators. Generators that do not have dual-fuel capability or a dedicated natural gas supply and delivery arrangements (gas-only resources) face uncertain access to fuel on cold winter days. Existing ISO-NE rules do not account for the uncertainty of natural gas supply in New England particularly in winter peak conditions.  The complaint alleges that this creates a market disadvantage for renewable energy sources, and it increases costs to consumers.

“Current rules improperly place gas-only resources on par with resources with known, dedicated fuel inventories by basing their capacity accreditation upon an incorrect assumption of 100 percent fuel availability. Conversely, solar, wind and run-of-river resources have their capacity ratings significantly lowered because of the variable nature of their energy source,” said Francis Pullaro, Executive Director of RENEW.

Recent ISO Winter Outlooks raised concerns that 3,700 to 4,500 megawatts of gas-only resources in New England were at risk of not being able to be supplied with natural gas, and therefore unable to operate, at winter peak conditions. New England’s gas-only resources in the winter total approximately 9,000 megawatts.

Pullaro added, “Simply put, a gas-only resource that cannot find gas is the same as a wind resource without wind or a solar resource without sun.  There is no justification to treat gas-only resources in a different manner.”

“A diverse array of clean energy resources can supply reliable capacity to New England, but wind, solar, and storage are clearly disadvantaged by current market rules favoring gas generators.  ACP and RENEW are seeking a level playing field, in which all resources receive credit consistent with the capacity they are actually able to provide to the New England grid.  We look forward to timely action from FERC to address the long-acknowledged issues with the ISO-NE capacity market,” said Gabe Tabak, counsel for ACP.

Gas-only resources are at significant risk of being unable to secure gas in severe cold weather conditions when the limited pipeline capacity serving New England is largely committed to local utilities holding firm pipeline capacity to serve their gas heating customers. While some individual gas-fired resources may make firm gas supply and transportation arrangements in advance, they are not obligated to make such advance arrangements to qualify as operating reserves or capacity, or to meet their real-time energy offers under the ISO rules.

By contrast, resources such as dual-fuel, oil, nuclear and hydroelectric resources all have dedicated near-term fuel input that can be measured and known, at the specific resource level, for purposes of real-time energy dispatch to honor their real-time energy offer.

About RENEW: RENEW Northeast ( unites environmental advocates with developers and operators of the region’s largest clean energy projects to coordinate their ideas and resources with the goal of increasing environmentally sustainable power generation in New England from the region’s abundant renewable energy resources.

ACP Contact: Jason Ryan, 202-412-7005 

RENEW  Contact: Francis Pullaro, 646-734-8768,

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