NEPGA filed a Protest and supporting Affidavit from Paul Sotkiewicz in response to the ISO-NE/Internal Market Monitor proposal to reduce the Dynamic De-List Bid Threshold from $5.50/kW-month in FCA 12 to $4.30/kW-month in FCAs 13-15 (No. ER18-619).  NEPGA argues that the Dynamic De-List Bid Threshold proposed by ISO-NE and the IMM is unjust and unreasonable for several reasons, including that it is based on non-cost based offers in prior auction and that it will send a price signal to the market creating incentives to offer below cost, which ultimately will impact system reliability.  NEPGA asks FERC to deny the ISO-NE/IMM proposal and order ISO-NE and the IMM to set the Dynamic De-List Bid Threshold based on the cost-based offer methodology used in prior Forward Capacity Auctions.