On May 15, NEPGA filed Comments in support of ISO-NE’s Energy Security Improvements proposal (ESI Proposal) (Docket No. ER20-1567-000), arguing that it is just and reasonable and, in its entirely, compliant with FERC’s Section 206 directive to file “permanent,” long-term market design changes to meet ISO-NE’s “fuel security” needs. NEPGA also asked FERC to reject NEPOOL’s request that it order ISO-NE to adopt three NEPOOL-approved amendments to the ESI Proposal.