FERC on Friday accepted Tariff revisions filed in May by ISO-NE and the New England Power Pool Participants Committee, effective Monday, to make clean-up changes and enhancements to the RTO’s billing policy (ER20-1862).

The changes to the RTO’s Financial Assurance Policy:

• revise the definition of “non-hourly charges” to explicitly include any pass-through charges for which ISO-NE acts as agent;
• change the timing of when the monthly non-hourly charges bill is issued from the first Monday after the 10th of each month to the first Monday after the ninth of each month;
• replace a number of references from “sending” remittance advice or invoices to “issuing” the same to reflect electronic, rather than physical, transmission; and
• moving forward the deadline for instructions for alternate payments.

The commission found the updated definition of “non-hourly charges” improves transparency for all stakeholders.

But it said it was “not persuaded” by the arguments of a Canadian-owned entity, Plant-E Corp., which contested the revision to limit of prepayments to five in any rolling 365-day period.

Plant-E said it was told that Canadian covered entities are not allowed to have shareholder collateral accounts under the FAP because investment management firm BlackRock does not offer such accounts to Canadians.

NEPOOL opposed Plant-E’s comments on process grounds because the corporation proposed revisions to the filing for the first time in the proceeding without the benefit of any prior stakeholder consideration or review.

ISO-NE argued that Plant-E’s request for special flexibility to manage its collateral through the prepayment mechanism ignores the reason its proposal limits the number of times that a participant may prepay an invoice, i.e., to maintain adequate financial assurance.

The commission ruled that “although Plant-E, as a Canadian entity, does not have access to the collateral accounts that are available to U.S. entities, it does have access to letters of credit, which are used by other market participants to meet financial assurance obligations.”

In addition, the commission found Plant-E’s concern that ISO-NE does not enable Canadian covered entities to have a shareholder collateral account pursuant to the FAP to be “outside the scope of this proceeding.”

In 2015, the commission accepted Tariff revisions that put this limitation in place, and “Plant-E’s concern is therefore an impermissible collateral attack on that commission order,” it said.