On January 4, 2019, NEPGA filed Comments objecting to FERC granting Vineyard Wind LLC’s request that FERC waive several sections of the Tariff to allow Vineyard Wind to participate as a Renewable Technology Resource (RTR) in FCA 13 (No. ER19-570). On December 14, Vineyard Wind filed the request seeking waiver of Tariff deadlines to elect and receive RTR treatment in FCA 13, as well as to a rule that would require ISO-NE to prorate the MWs of eligible RTRs in FCA 13 if, as would be the case if Vineyard Wind were to participate as an RTR in FCA 13, the quantity of total eligible MWs exceeds the FCA 13 RTR MW cap of 481 MW. NEPGA explained in its Comments that Vineyard Wind impermissibly seeks a waiver of the pro-rationing rule because it does so solely to avoid the undesirable consequences of the remainder of its waiver request (and thus of Vineyard Wind’s participation as an RTR in FCA 13). NEPGA also explains that Vineyard Wind is effectively asking for a change to the RTR definition (that FERC has yet to be accept) to apply retroactively to precede the RTR election and ISO-NE determination deadlines, an unprecedented and unjustified request. NEPGA explicitly confirms that it is not challenging the RTR definition change, only the way in which Vineyard Wind impermissibly seeks to retroactively apply the RTR definition change via a request for waivers.