NEPGA filed an Answer to ISO-NE’s answer to NEPGA’s Protest of its proposal to re-price resources made eligible for a cost-of-service agreement to meet a demonstrated fuel security need (No. ER18-2364). ISO-NE proposes to allow a resource that would otherwise retire from the FCA to enter into a cost-of-service agreement (or in some cases receive its Retirement De-List Bid price) if it meets a fuel security need in FCAs 13-15. A resource is deemed needed for fuel security under the ISO-NE proposal if, with the subject resource assumed out-of-service, ISO-NE’s modeling of future system conditions produces at least one hour of predicted load shedding or two hour-long periods of predicted reductions in operating reserves. ISO-NE also proposes to re-price a resource held for fuel security as a price-taker in the FCA. NEPGA and several other parties have protested the re-pricing proposal, arguing that it will cause uncompetitive FCA clearing prices and exacerbate the need to hold additional resources out-of-market for fuel security. In its answer to NEPGA’s Protest, ISO-NE did not challenge the price suppression and other evidence NEPGA offered (through the supporting affidavit from Dr. Paul Sotkiewicz), nor did it raise any new substantive arguments. In its Answer, NEPGA highlights the shortcomings in ISO-NE’s answer, including its failure to challenge NEPGA’s record evidence.