On August 12, NEPGA filed an Answer challenging the Participating Transmission Owners’ (TOs) proposal to amend the definition of Monthly Regional Network Load (MRNL) to newly require Network Customers to not reconstitute their load profiles to account for the energy delivered by unregistered behind-the-meter resources (Docket No. ER21-2337). The Tariff currently requires that in calculating load designated by a Network Customer, the load shall not “be credited or reduced for any behind-the-meter (BTM) generation” – thus requiring the reconstitution of load profiles to account for BTM generation. NEPGA earlier filed a Protest, asking FERC to reject the proposed changes on the basis that they are unduly discriminatory against similarly situated resources (behind-the-meter registered Generator Assets, whose energy delivery under the proposal is not credited against Network Customer load) without any reasoned basis for the discrimination. In the alternative, NEPGA asks FERC to institute a requirement to net both registered and unregistered assets BTM for purposes of calculating a Network Customers’ MRNL. The TOs filed an answer on Aug 6, and NEPGA answered on August 12, in part rejecting the TO claim that Tariff compliance would be unduly burdensome by requiring the metering of every BTM resource (NEPGA explains that estimation, rather than actual metering, is reasonable given that ISO-NE estimates BTM generation in calculating the Installed Capacity Requirement and in its real-time operations. The IMM as well protested and answered the TOs, asking FERC to reject the filing, to direct the TOs to comply with the Tariff on file, and to require the TOs to initiate a NEPOOL stakeholder process to consider Tariff changes, if any.