On September 5, 2025, NEPGA filed an Answer in response to ISO-NE’s, the Internal Market Monitor’s (IMM) and Vitol’s answers to NEPGA’s complaint pursuant to which NEPGA seeks relief from a Pay for Performance design that under certain conditions imposes a charge on a capacity resource that delivers its full Capacity Supply Obligation quantity in the form of energy and/or reserves during a Capacity Scarcity Condition (No. EL25-106). In its complaint, NEPGA asks the Commission to: (1) find that the current Tariff is unjust and unreasonable in that it allows “fully performing” resources to be penalized under the PfP second-settlement; and (2) to direct ISO-NE to adopt a replacement rate that: (a) caps the Balancing Ratio at 1.0; and (b) sums all under-collections caused by capping the BR at 1.0, all under-collections caused by any resources hitting its stop-loss, and all over-collections inherent in the PfP design (a consequence of the reserve deficiency), and to assess or distribute (as the case may be) that sum to all resources due a performance payment following a Capacity Scarcity Condition (which in turn will cause the effective payment rate to “overperformers” to be either higher or lower than the nominal $9,337/MWh Performance Payment Rate. In its Answer, NEPGA first highlights the nearly unanimous support for all or aspects of NEPGA’s complaint among parties to the proceeding. NEPGA also answers challenges to NEPGA’s explanation that the stop-loss related under-collections and the over-collections inherent in the PfP design must be included in the overall settlement of under and over collections in order for suppliers to actually realize relief from a Balancing Ratio exceeding 1.0. Lastly, NEPGA responds to other party arguments that to include stop-loss related under-collections in NEPGA’s proposed allocation methodology violates the beneficiary pays/cost-causation principle. RENEW Northeast also filed an answer on Friday, further supporting NEPGA’s complaint and answer (RENEW filed an original set of comments supporting NEPGA’s complaint).