NEPGA filed comments in support of ISO-NE’s compliance filing of tariff changes defining the Winter Reliability Program payment rate formula (No. ER15-2208-002), thanking the Commission for ordering the compliance filing in response to NEPGA’s and EPSA’s joint request to do so, and emphasizing the need to reflect material practices and conditions in the ISO-NE Tariff, rather than relying on ISO-NE to apply and make changes to its practices outside of the notice provisions of Section 205 of the Federal Power Act.   NEPGA-Comments_ER15-2208-002.pdf