On November 27, 2018, NEPGA filed a Motion to Intervene and Conditional Protest of ISO-NE’s proposed Installed Capacity Requirement (ICR) and MRI Demand Curve values for effect in FCA 13 (Docket No. ER19-291).  As NEPGA explains, ISO-NE uses a different, more relaxed reliability standard for purposes of calculating the ICR and Demand Curve values than the standard that forms the basis of its fuel security reliability criteria (pursuant to which ISO-NE proposes to qualify certain resources for a cost-of-service rate to meet a demonstrated fuel security need).  NEPGA therefore asks FERC to order ISO-NE to either develop ICR and Demand Curve values based on the stricter fuel security reliability standard, or to price any resources afforded the cost-of-service rate at their competitive offer price in the Forward Capacity Auction.