NEPGA’s filed an Answer to the Limited Protest filed by the ISO-NE Internal Market Monitor in Exelon’s Section 205 cost recovery filing proceeding (No. ER17-933).  NEPGA objects only to the IMM’s request that FERC decide whether Exelon’s contracted fuel costs may be included in an energy market Reference Level.  NEPGA explains that to grant the IMM’s request would violate other market participant due process interests, given that parties were not on notice that Exelon’s cost recovery proceeding would include the substantive question the IMM asks FERC to decide, and that FERC’s decision (if any) would have potential impacts on other market participants.  NEPGA further explains that FERC need not answer the question the IMM poses in order to decide if Exelon’s cost recovery request is just and reasonable, and that the moving party (Exelon) has not itself asked FERC to answer the IMM’s question.