On February 4, 2019, NEPGA filed Comments asking FERC to conditionally grant an ISO-NE Motion for Extension of Time to file certain market design changes (Docket No. ER18-182). FERC previously ordered ISO-NE to file by July 1, 2019, a market-based solution to New England’s winter energy security concerns (the so-called Chapter 3). In its Motion, ISO-NE asks for an extension until November 15, to afford it and NEPOOL stakeholders more time to consider and develop ISO-NE’s proposal and alternative stakeholder proposals. ISO-NE asserts that an extension will not cause a delay to what ISO-NE targets as an effective date, i.e., the FCA 15 Capacity Commitment Period (beginning June 1, 2024). In its Comments, NEPGA supports ISO-NE’s Motion but asks that FERC order ISO-NE to fully vet one of the three components of ISO-NE’s design to date – the forward market component – with NEPOOL stakeholders prior to filing on November 15 (if the extension is in fact granted). Several parties offered their support for the Motion, including NEPOOL, NESCOE, the Massachusetts Attorney General and the Massachusetts DPU.