On April 21, 2022, NEPGA filed Comments in support of the ISO-NE and NEPOOL joint proposal to apply a 700 MW Renewable Technology Resource (RTR) exemption from the Minimum Offer Price Rule (MOPR) in FCAs 17 and 18, and to eliminate the existing MOPR for effect in FCA 19 (Docket No. ER22-1528-000). NEPGA asks FERC to accept the filing on four bases. First, the proposal is the product of deliberations between ISO-NE and NEPOOL stakeholders, supported by a 70% vote in favor from the NEPOOL Participants Committee, and unopposed by five of the six New England states. Second, to eliminate MOPR for effect in FCA 17 (rather than in FCA 19) would create significant risks to resource adequacy, system reliability, and market efficiency. Third, the proposal allows ISO-NE and NEPOOL the time to develop two necessary changes to the wholesale markets prior to the elimination of the MOPR, namely, a new capacity accreditation methodology and day-ahead reserves or call-option products. Lastly, NEPGA explains that during the two-year transition to MOPR elimination (i.e., the application of the RTR exemption in FCAs 17 and 18) state-sponsored and favored resources will continue to enjoy the opportunities currently afforded by the Forward Capacity Market, and thus the proposal will not interfere with the New England state policy goals.