On April 12, NEPGA filed a Protest of ISO-NE’s FCA 13 Results Filing, specifically with respect to the failure of ISO-NE to include testimony from its Internal Market Monitor (IMM) attesting to the competitiveness of the FCA 13 outcome (Docket No. ER19-1166). The Tariff requires that ISO-NE file, under Section 205 of the Federal Power Act (FPA), the results of each FCA including “documentation regarding the competitiveness of the [FCA].” NEPGA explains that ISO-NE has after each FCA, except now after FCA 13, satisfied that obligation by filling the IMM’s testimony, and that FERC has relied on the IMM testimony in discharging its obligation under FPA Section 205 to ensure just and reasonable rates. NEPGA also explains that in addition to ISO-NE’s FCA results filing obligations, the IMM has an independent obligation to report on the impact ISO-NE actions may have had on the competitiveness of the wholesale markets. ISO-NE took a significant administrative action in FCA 13 by re-pricing the competitive offers from two resources, Mystic Units 8 and 9 (Mystic Units) – for a total of 1,415 MW – to $0/kW-month. NEPGA thus asks the Commission to direct its Office of Energy Market Regulation to issue a deficiency letter requiring the IMM to file testimony that explains how and to what extent the re-pricing of the Mystic Units in FCA 13 caused the clearing price to be lower than it would have been had the Mystic Units been offered into the auction at their FERC-accepted competitive Retirement De-List Bid offer prices, how many otherwise economic capacity resources did not clear FCA 13 as a result of ISO-NE’s administrative re-pricing actions, and whether in the IMM’s opinion these actions impacted the competitiveness of FCA 13.