United States of America Before the Federal Energy Regulatory Commission
Constellation Mystic Power, LLC ) Docket Nos. ER18-1639-001, ER18-1639-002
MOTION FOR LEAVE TO ANSWER AND ANSWER OF
THE NEW ENGLAND STATES COMMITTEE ON ELECTRICITY
Pursuant to Rules 212 and 213 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“Commission” or “FERC”), 18 C.F.R. §§ 385.212 and 385.213, the New England States Committee on Electricity (“NESCOE”) files this Motion for Leave to Answer and Answer in the above-captioned proceeding. On January 22, 2019, NESCOE filed a Request for Clarification or, in the Alternative, Rehearing of the Commission’s December 20, 2018 order in this proceeding regarding the Commission’s directive to Mystic to include a clawback mechanism in the Mystic Agreement (“NESCOE Clarification Request”).