The ISO/RTO Council (IRC), including ISO-NE, protests proposed EOP-012-2 (Freeze Protection Standard), detailing its specific issues and concerns with the effectiveness of the
proposed Standard proposing specific language that would resolve the issues it raises and to ensure the Standard’s ’s effectiveness as a winterization standard; NEPGA comments on EOP-012-2, strongly supporting the goals of improving power plant reliability and system performance in the winter months, in particular through competitive market designs, and not protesting or challenging the Freeze Protection Standards.