On January 2, 2019, NEPGA filed a Request for Rehearing of FERC’s order accepting ISO-NE’s proposal to, inter alia, re-price as price-takers in the FCA a resource made eligible for a cost-of-service agreement to meet a demonstrated fuel security need (Fuel Security Resource) (Docket Nos. EL18-182 and ER18-2364). This holding will apply to the Mystic Units 8 and 9 beginning in FCA 13. NEPGA largely focuses on FERC’s failure to address in any meaningful way NEPGA’s unchallenged evidence that the pricing treatment of Fuel Security Resources will cause unjust and unreasonable capacity price suppression, uneconomic retirements, the potential for further cost-of-service agreements, and adverse impacts on fuel security in New England. In this respect, NEPGA argues that FERC has failed to meet its burden to meaningfully address material evidence, to qualify the price suppressing effects of its decision, to engage in reasoned decision-making, and to guarantee that rates are just and reasonable. NEPGA also argues that FERC improperly extended its precedent addressing the pricing treatment of resources held to meet local transmission reliability to the present case, which concerns a system-wide winter energy reliability.