On April 15, 2019, NEPGA filed a protest in response to ISO-NE’s Inventoried Energy Program (IE Program) proposal pending before FERC (Docket No. ER19-1428). ISO-NE intends for the IE Program to provide “incremental revenue” to resources that contribute to firm winter fuel and energy in the FCA 14 and 15 winter months, believing that it will prevent the retirement of resources that are economic but for the lack of value placed on winter energy security in the wholesale markets. ISO-NE must file with FERC by October 15 market design changes to allow the markets to value winter energy security services and attributes. ISO-NE intends for the IE Program to serve as a “bridge” until those market design changes take effect. NEPGA does not take a position on the IE Program itself, but asks that if FERC accepts the IE Program that it find other provisions of the Tariff unjust and unreasonable, namely the re-pricing of Forward Capacity Auction offers from resources operating under a cost-of-service agreement to meet a demonstrated fuel security need. NEPGA argues that this “price-taker” treatment exacerbates the problem the IE Program is intended to mitigate and that the fuel security form of cost-of-service agreement would no longer be necessary with the IE Program in effect, among other arguments. NEPGA also asks FERC, upon acceptance of the IE Program if any, to find that the Tariff does not require a capacity resource to reduce its de-list bid by an amount equal to its expected net revenues earned in the IE Program. The IMM filed comments earlier in the proceeding announcing its belief that the Tariff so requires.