On December 8, 2023, NEPGA filed Comments in support of ISO-NE’s proposal to allow a Market Participant offering a Retirement or Permanent De-List Bid in the Forward Capacity Auction to reduce the offer price within a certain range and under certain conditions (Docket No. ER24-420-000). Specifically, ISO- NE proposes to allow a Market Participant to reduce its Internal Market Monitor (“IMM”)-approved offer price by up to 25% between the time the IMM approves the offer price and the de-list bid finalization window. NEPGA explains in its Comments that this allowance is just and reasonable, primarily in that it allows for more competitive capacity offers, is consistent with the purpose of supplier-side offer mitigation, and contributes to the orderly on-going transition in New England’s capacity supply and energy demands.  NEPGA thus asks the Commission to accept the Tariff changes proposed by ISO-NE.