On December 6, 2023, NEPGA filed Comments in support of ISO-NE’s proposal to increase the Net Cost of New Entry (Net CONE) value for effect beginning in FCA 19 (No. ER24-401-000). Specifically, ISO-NE proposes to increase the cost of debt and cost of equity values that dictate the after-tax weighted cost of capital (ATWACC), itself an input to the Net CONE value. ISO-NE proposes the increases to account for the increased risk to investors from the elimination of the Minimum Offer Price Rule (also effective in FCA 19). NEPGA explained that it supported the increase to the ATWACC as a reasonable adjustment to reflect this incremental risk, while also asking ISO-NE and the Commission to take note that there may be an improved (and likewise just and reasonable) methodology to update the ATWACC cost of capital when ISO-NE next fully recalculates the Net CONE value for effect in FCA 21.