NEPGA filed comments with FERC in response to ISO-NE’s filing of a Net Installed Capacity Requirement for effect in FCA 12 (No. ER18-263-000).  NEPGA explains that the NICR methodology employed by ISO-NE overstates the contribution of behind the meter solar pv resources to ISO-NE’s resource adequacy needs, but notes that ISO-NE has committed to work with NEPGA Members on potential corrections to the methodology for the FCA 13 NICR calculation.  NEPGA also reserves the right to protest the FCA 13 NICR filing should the necessary changes to the methodology not occur prior to then.