NEPGA filed a Motion to Intervene and Comments in the grid resilience administrative docket open before FERC (No. AD18-7).  NEPGA asks FERC to take notice that the Operational Fuel Security Analysis produced by ISO-NE, which ISO-NE offers as a “framework” for understanding the “fuel security risk” in New England, does not define that risk because the Analysis is a deterministic analysis and fails to account for market responses to price signals.  NEPGA opines that the “fuel security risk” must first be properly defined, taking into account factors such as price signals, before ISO-NE and NEPOOL stakeholders develop a market design to meet the defined reliability need.