NEPGA filed a Motion to Intervene and Comments in in support of NextEra’s and PSEG’s (Complainants) joint Complaint at FERC, in which the Complainants allege that state efforts to require or allow electric distribution companies (EDCs) to contract for incremental natural gas pipeline capacity into New England will, if left unmitigated in the wholesale electricity markets, cause unjust, unreasonable and unduly discriminatory rates, and may constitute market manipulation (Docket No. EL16-93-000). The Complainants allege that the primary, if not sole purpose of the EDC contracts is to suppress wholesale electricity prices through an artificial, out of market decrease in natural gas prices. The Complainants ask FERC to order ISO-NE to: (1) file Tariff changes by October 2016 to “fully mitigate” the effect of the EDC contracts on wholesale electricity rates; (2) convene a Technical Conference to consider the proposed Tariff changes; and (3) approve Tariff changes by January 31, 2017, i.e., prior to the next Forward Capacity Auction. In its Comments, NEPGA agrees with the Complainants that the EDC contracts will cause unjust and unreasonable rates, are unduly discriminatory, and may constitute market manipulation, and therefore asks FERC to grant appropriate relief, including fully mitigating the energy market price suppression the EDC contracts are intended to create.