On July 22, 2021, NEPGA filed a Protest of the Participating Transmission Owners’ and ISO-NE’s joint proposal to amend the definition of Monthly Regional Network Load (“MRNL”) providing that Network Customers shall not reconstitute their load profiles to account for the energy delivered by unregistered behind-the-meter resources (both with respect to retail meter and Pool Transmission Facilities) for purposes of calculating their MRNL (which in turn dictates its share of Regional Network Service costs) (No. ER21-2337). The Tariff currently requires the opposite, i.e., that in calculating load designated by a Network Customer, the load shall not “be credited or reduced for any behind-the-meter generation.” NEPGA asks FERC to reject the proposed changes on the basis that they are unduly discriminatory, in that they discriminate against similarly situated resources (behind-the-meter registered Generator Assets, whose energy delivery under the TO/ISO-NE proposal is not credited against Network Customer load) without any reasoned basis for the discrimination. In the alternative, NEPGA asks FERC to direct the TOs to remedy the undue discrimination by requiring a Network Customer to net both registered and unregistered assets behind-the-meter for purposes of calculating a Network Customers’ MRNL.