On November 7, 2022, NEPGA filed Comments in response to the FERC Commissioner-led New England Winter Gas-Electric forum held on September 8, 2022 (Docket No. AD22-9-000). NEPGA explains that it drew three conclusions from the Forum: (1) New England may be at risk of involuntary load shed in the winter months because its reliability needs are not fully reflected (and consequently not fully valued) in the wholesale markets; (2) considering how to address any “energy gap” that may exist first requires a more precise definition that is currently lacking; and (3) addressing any energy gap lies not in continuing the decade-long practice of out-of-market programs but in refined or new wholesale electricity markets and products and in regional cooperation. NEPGA further explains that it supports the on-going Resource Capacity Accreditation and Day-Ahead Ancillary Service market design change proposals, but that those design changes alone are unlikely to entirely address New England’s winter reliability needs. NEPGA asks the Commission to provide leadership by conveying to ISO-NE that it must develop new market designs and modify the existing designs further to resolve the long-standing New England winter reliability issues rather than ISO-NE continuing to apply temporary out-of-market measures. NEPGA explains that the New England States must decide their risk tolerance for load shed during the winter months – i.e., what level of “insurance” they wish to buy – in order for the region to develop the market solutions necessary to satisfy that standard. NEPGA also explains that current assumptions underlying the Forward Capacity Market design (e.g., tie benefits) undermine the ability of the markets to meet the target reliability standard, and that several changes to those assumptions would better align the wholesale markets with New England winter (and other season) reliability needs.