On December 8, 2022, NEPGA filed Comments on the North American Reliability Council’s (NERC) proposed standards requiring the adoption of freeze protection measures at generation units (No. RD23-1-000). The standards NERC proposes includes a requirement that an existing generating unit have sufficient freeze protection measures such that it can operate continuously for one hour at a very low ambient temperature (for the location of the unit) based on historical low winter temperatures. A generating unit owner may “declare” that a “constraint” (e.g., technical, commercial or economic) precludes it from adopting or modifying such freeze protection measures. NEPGA raises two issues in its Comments.  First, NEPGA explains that generating units subject to these standards must be allowed to recover compliance costs and asks FERC to direct ISO-NE to develop with effected parties a cost recovery market design or mechanism for effect by the effective date of the proposed standards (NERC asks for an effective date 18 months following FERC acceptance). Second, NEPGA explains that the right to declare a constraint (essentially exempting a generating unit owner from the standards) is ambiguous and requires clarification.