On December 21, NEPGA filed a Limited Protest of one part of a series of largely “conforming” changes to the Competitive Auction and Sponsored Policy Resource (CASPR) design (Docket No. ER19-444). Among the CASPR changes proposed by ISO-NE is the creation of “test price” mitigation methodology that serves to disqualify certain resources from offering as demand in the CASPR Substitution Auction (SA). A resource may offer as demand in the SA only if it first obtains a Capacity Supply Obligation (CSO) in the associated FCA. ISO-NE believes that this condition may create an incentive for a resource to offer below its FCA competitive offer price in order to assure it acquires the CSO and can therefore participate in the SA. ISO-NE intends for its proposal to eliminate that incentive. Under the ISO-NE proposal, both the Market Participant and the internal market monitor (IMM) would develop a proposed test price reflecting their respective estimates of the lowest competitive price for a Retirement De-List Bid (regardless of whether the resource has, in fact, offered a Retirement De-List Bid in that FCA). If those values differ, the IMM would file its proposed price (and not the Market Participant’s) for acceptance by FERC under FPA Section 205. The IMM would then reduce the FERC-accepted test price by 10% to arrive at a “final test price” for the FCA, which if higher than the FCA clearing price would render the resource ineligible to participate as demand in the SA. NEPGA protests the proposal on the basis that it requires the Market Participant to involuntarily forgo its right to file its rates, terms and conditions of service under FPA section 205, in this case the term or condition being the test price. NEPGA thus asks that if FERC otherwise accepts the test price proposal, it order ISO-NE to file the Market Participant-submitted Test Price for acceptance under FPA Section 205.