NEPGA and EPSA joint limited protest of the ISO-NE and NEPOOL winter reliability program proposals, pursuant to which NEPGA and EPSA ask the Commission to order ISO-NE to make future market design changes rather than rely on assurances the changes will come, and to order ISO-NE to add the program payment rate formula to the ISO-NE Tariff. NEPGA-and-EPSA-Mot-to-Interv-and-Lmtd-Protest-ER15-22081.pdf