On September 21, 2018, NEPGA filed a protest of ISO-NE’s proposal to re-price resources held for fuel security as price-takers in the Forward Capacity Auction (No. ER18-2364).  ISO-NE’s re-pricing proposal is one part of its compliance filing seeking to satisfy FERC’s directive that ISO-NE file Tariff changes allowing for a resource to be held out-of-market if needed to meet a demonstrated fuel security need.  ISO-NE proposes to allow a resource that would otherwise retire from the FCA to enter into a cost-of-service agreement (or in some cases receive its Retirement De-List Bid price) if it is needed to meet a demonstrated “fuel security need” in FCAs 13-15. A resource is deemed needed for fuel security under the ISO-NE proposal if, with the subject resource assumed out-of-service, ISO-NE’s modeling of future system conditions produces at least one hour of predicted load shedding or two hour-long periods of predicted reductions in operating reserves. NEPGA argues that the re-pricing proposal will cause uncompetitive FCA clearing prices and therefore exacerbate the need to hold additional resources out-of-market for fuel security.