NEPGA filed Comments and a Limited Protest of ISO-NE’s proposal to create a second auction – a Substitution Auction – to allow certain subsidized clean, renewable and alternative energy resources the opportunity to acquire a Capacity Supply Obligation when they are not economic in the Forward Capacity Auction (No. ER18-619).  NEPGA offered its support for the proposal as a compromise, while noting that in the long-run the proposal will impact competitive pricing in the Forward Capacity Auction.  NEPGA also asked FERC to order a relatively minor change to the proposal, to allow a resources to offer into the Substitution Auction with a “spread bid” allowing the resource to signal what price it would need to receive in order to clear the auction.