NEPGA is protesting the ISO-NE/Internal Market Monitor compliance filing in the FERC proceeding addressing changes to the Forward Capacity Market rules for resource retirements (Docket No. ER16-551-002). FERC ordered ISO-NE and the IMM to propose a “materiality threshold,” a test that would protect certain retirement bids against IMM mitigation. As ordered by FERC, if a market participant’s bid is within a certain percentage of the IMM’s mitigated price, ISO-NE will accept the market participant’s unmitigated price and file it with FERC under Section 205 of the Federal Power Act. ISO-NE and the IMM propose a 10% threshold. NEPGA asks FERC to deny the ISO-NE/IMM proposal and instead order a materiality threshold expressed as the greater of 15% or $1.00/kW-month.