On December 11, 2020. NEPGA filed a complaint against ISO-NE alleging that ISO-NE violated its Tariff by recalculating and reviewing with NEPOOL stakeholders a new Net CONE value based on a methodology not on file with the Commission and in conflict with the Tariff definition of Net CONE (Docket No. EL21-26-000). ISO-NE and its consultants have recalculated Net CONE in part based on the assumption that the quantity of energy available to the system in each of the twenty years of the forecast period will equal the Net Installed Capacity Requirement, rather than basing it on “reasonable expectations” of first-year and future year revenues. ISO-NE’s methodology has the effect of inflating forecast LMPs above those observed historically, which in turn has the effect of decreasing Net CONE below its competitive, Tariff-based price. NEPGA asks the Commission to find that ISO-NE has violated its Tariff and to direct ISO-NE to recalculate Net CONE according to the Tariff definition. The Comment Date is December 21.