On May 11, 2021, NEPGA filed an Answer to North East Offshore, LLC’s (NEO) (a partnership between Orsted and Eversource) comments in support of NEPOOL’s proposal to set the Offer Review Trigger Price (ORTP) for off-shore wind (OSW) resources at $0/kWm beginning in FCA 16 (Docket No. ER21-1637-000). NEPGA filed a Protest of the NEPOOL proposal on April 28, the same day on which NEO and several other parties filed protests and comments (in varying degrees in response to the several ISO-NE and NEPOOL ORTP proposals included within this “jumpball” proceeding). NEO asks FERC to find not only that the NEPOOL OSW resource proposal is just and reasonable because it is consistent with NEO’s (and other parties’) expectations about future OSW capital costs, but that the ORTP for OSW would be unjust and unreasonable without accounting for future expectations. NEPGA responds first by explaining NEO’s expectations are not material to the question before FERC, specifically whether NEPOOL’s methodology to “infer” OSW capital costs is just and reasonable. NEPGA further explains that basing OSW capital costs on current expectations of future capital costs is duplicative with the Tariff requirement that ISO-NE adjust the ORTP values annually. The Tariff requires that ISO-NE base these annual adjustments on the most recent available capital cost information (industry-wide), and thus already provides for adjustments based on changed capital costs. NEO’s speculation about future capital costs is thus not only less reliable than the mechanism the Tariff requires, but redundant to it.