NEPGA filed comments asking the Commission to approve the unopposed Offer of Settlement NEPGA and several other parties jointly filed on July 28, 2017, resolving the Peak Energy Rent (PER) Strike Price increase ordered by FERC in its order granting NEPGA’s complaint on the PER mechanism (Docket Nos. EL16-120 and ER17-2153).  NEPGA asks the Commission to approve the Offer of Settlement without delay or condition. The Offer of Settlement leaves for FERC’s decision-making whether the Strike Price increase will apply to capacity payments beginning on June 1, 2018, i.e., the beginning of the FCA 9 Capacity Commitment Period. NEPGA asks FERC to approve the Offer of Settlement expeditiously, if necessary without first or contemporaneously resolving the applicability of the Strike Price increase to the FCA 9 Capacity Commitment Period, in order to ensure just and reasonable rates during the period preceding June 1, 2018.