On November 4, 2020, NEPGA filed Comments in support of NextEra Seabrook’s Petition for Declaratory Order, asking FERC to confirm NextEra’s declarations that it is not required to incur financial losses (actual or through lost opportunities) or be liable for consequential damages in accommodating the interconnection of Avangrid’s New England Clean Energy Connect (NECEC) project (Docket No. EL21-3). According to ISO New England’s NECEC Electric Upgrade System Impact Study, the NECEC project will have an adverse effect on Seabrook Station’s existing Generation Breaker, requiring its replacement if NECEC is to interconnect into the New England grid. NEPGA offered its support for NextEra’s request, explaining that no generator, transmission owner, or other Market Participant should be required to incur costs, lose revenue opportunities, or assume potential liabilities when improving infrastructure solely for the benefit of another Market Participant. NEPGA further notes that all Market Participants would benefit from Commission confirmation of these rights and obligations not only for Seabrook and NECEC, but also for other parties similarly situated.