ISO-NE answers in response to Jul 28, 2022 Show Cause Order.  ISO-NE suggests that the FERC should find that the ISO’s existing FAP FTR
financial assurance calculations are just and reasonable; to the extent it does not, ISO-NE suggests that it should be allowed to follow the established stakeholder  process to propose revisions to the FAP to incorporate an FTR volumetric minimum financial assurance requirement.