NEPGA filed a Request for Rehearing of the FERC order accepting the Net CONE value and Offer Review Trigger Price values proposed by ISO-NE for effect beginning in FCA 12 (No. ER17-795-000). In its order, FERC accepted ISO-NE’s proposal to base the Net CONE value on a greenfield development, simple-cycle frame combustion turbine reference technology, resulting in a $8.04/kW-month Net CONE value. This represents a $3.80/kW-month reduction in Net CONE from the $11.84/kW-month value in effect in FCA 11. NEPGA protested, asking that FERC find that the $8.04/kW-month value is unjust and unreasonable, and order ISO-NE to base Net CONE on a combined-cycle reference technology, which would result in a $10.00/kW-month value (according to ISO-NE’s calculations). On rehearing, NEPGA raised several deficiencies in FERC’s order, including its failure to balance investor interests in sufficient capacity revenues and a relatively consistent market design against the significant benefit to load, its lack of consideration of relevant record evidence, and it failure to properly balance the record evidence in making its findings.