On August 8, NEPGA filed an Answer to the New England States Committee on Electricity’s (NESCOE) Motion for Extension of Time pursuant to which NESCOE asks FERC to extend the deadline by which ISO-NE must file market design changes to address New England’s winter energy security needs (the Energy Security Improvements (ESI), or so-called Chapter 3)(Docket No. EL18-182). At present, ISO-NE must file “improvements” to the existing market design by October 15. NESCOE asks FERC to extend that deadline to April 15, 2020. According to NESCOE, “it has become increasingly clear that additional time is needed to resolve the many outstanding issues surrounding ISO-NE’s [ESI proposal].” Among the issues NESCOE cites to are the potential cost impacts of the ESI proposal and the mitigation rules that will apply to the day-ahead ancillary service products (financial energy call options) ISO-NE proposes. NESCOE asserts that a six month extension will give ISO-NE the time to develop, and NEPOOL stakeholders the time to consider, a full year of potential cost impacts (ISO-NE has thus produced a Winter-only cost and revenue analysis) and mitigation rules. NESCOE acknowledges that a six month extension would place the filing deadline a month after the FCA 15 Retirement De-List Bid deadline of March 13, 2020, but takes the position that the extension will give market participants contemplating a retirement more information about the potential future market design than if ISO-NE were to file by the October 15 deadline. In its Answer, NEPGA asks FERC to limit an extension, if granted, to no later than December 20, 2019, in order to allow FERC sufficient time to consider and decide on the filing prior to the FCA 15 Retirement De-List Bid deadline. As NEPGA explains in its Answer, to allow for a filing after the Retirement De-List Bid deadline would increase the risk of an uneconomic retirement decision, which in turn increases the risk that ISO-NE may seek to retain a resource (that would otherwise retire) through a cost-of-service agreement.