On April 28, 2021, NEPGA filed a Protest of NEPOOL’s proposed Offer Review Trigger Price (ORTP) for off-shore wind resources and a related NEPOOL proposal to base the ORTP for off-shore wind resource on a 25 year, versus the current 20 year discounted cash flow model (Docket No. ER21-1637-000). ISO-NE filed these proposals as part of a joint ORTP “jumpball” Section 205 filing at FERC. NEPGA challenges only the NEPOOL-proposed $0/kWm ORTP for off-shore wind (compared to ISO-NE’s proposed ORTP for off-shore wind equal to the FCA Starting Price) on two primary grounds. First, NEPGA argues that the filed rate doctrine and rule against retroactive ratemaking bar the ORTPs filed by ISO-NE (NEPOOL’s and ISO-NE’s alike) from taking effect in FCA 16, because the filing (i.e., legal notice) and the proposed values themselves (i.e., actual notice in the NEPOOL process) were not completed until after the deadline for Market Participants to submit Retirement or Permanent De-List Bids for FCA 16, and thus must be rejected.  NEPGA asks that FERC allow for the ORTPs on file (i.e., those that applied in FCA 15) to remain in effect for FCA 16. Second, NEPGA substantively addresses the NEPOOL-proposed ORTP for off-shore wind, explaining that it suffers from at least three fundamental flaws: (1) capital costs based on a flawed cost model: (2) a commercially implausible financing structure; and (3) an unjustified 25 year discounted cash flow model.