NEPGA answered the Indicated Electric Distribution Companies’ (EDCs) Motion for Clarification, in which the EDCs ask FERC to find that the “central purpose” of its order directing ISO-NE to file improvements to its market design to address fuel security needs is to “add new infrastructure” to New England (Nos. ER18-1509 and EL18-182). In order to achieve this, the EDCs propose that ISO-NE enter into long-term contracts for incremental natural gas pipeline capacity. NEPGA responds first by arguing that the EDCs request is outside of the scope of FERC’s order, where FERC decidedly declined to direct any type of market improvement, much less declaring a “central purpose.” NEPGA further explains that the EDCs motion is more properly styled as a procedurally improper request for rehearing or complaint. In the event the EDCs motion is within the scope of the proceeding, NEPGA argues that the EDCs request contradicts FERC’s directive to develop a market design improvement rather than authorize the out-of-market contracts the EDCs propose. NEPGA also argues that the EDCs, who propose that ISO-NE collect these pipeline capacity contract costs through its Tariff and rates, do not establish that their proposal is legal under the Federal Power Act.