Eastern New England Consumer-Owned Systems submit Complaint against Mystic and ISO-NE challenging the unjust and unreasonable pass-through to ISO-NE
customers of firm pipeline transportation costs under the 2nd Amended and Restated Cost-of-Service Agreement (COSA), which ENECOs claim are associated
with pipeline facilities that are neither used nor usable to supply fuel to Mystic 8 and 9, and therefore should not be charged to ISO-NE and its customers
under the COSA.  ENECOS ask that all references to “Pipeline Transportation Agreements” be stricken from the COSA, remove from the true-up methodology template Line No. 7 “Fixed Pipeline Transportation,” and preclude Mystic from recovering the dollar amounts associated with that line item.