On October 1, 2018, NEPGA filed a Supplemental Protest of ISO-NE’s and its Internal Market Monitor’s proposal to change the economic life calculation for purposes of Retirement De-List Bid mitigation beginning in FCA 13.  NEPGA filed an initial Protest of the proposal in July, following which FERC’s Office of Energy Market Regulation issued a deficiency letter on ISO-NE requiring ISO-NE to supplement its original filing by answering several questions posed. As with its original Protest, NEPGA asks FERC to not accept the changes for effect in FCA 13, but to require ISO-NE top bring its proposal through the NEPOOL process and file at a later for effect in FCA 14, if at all.