On June 29, 2020, NEPGA filed a Protest of the complaint brought by Constellation against ISO-NE alleging that ISO-NE has improperly amended its planning procedures, and acted inconsistent with its Tariff in conducting local transmission reliability reviews for the FCA 15 Capacity Commitment Period (No. EL20-52-000). NEPGA makes several counter-arguments in its Protest, including that the Tariff grants ISO-NE the authority it is now exercising in conducting the local transmission reliability reviews, and that its amendments to its planning procedures properly provides the details of those reliability reviews.