On February 16, NEPGA filed an Intervenor Brief in the appeal of the Inventoried Energy Program (IEP) currently before the U.S. Court of Appeals for the D.C. Circuit (No. 19-1224). NEPGA raised several issues for the court to consider, including that ISO-NE developed the IEP as an interim measure to ensure system reliability until a long-term solution is developed and accepted by FERC, and that as a result the measure of evidence upon which FERC accepted the IEP was sufficient to meet FERC’s obligation to render a decision that is neither arbitrary, capricious, nor an abuse of discretion. ISO-NE also filed an Intervenor brief in support of FERC, explaining that FERC correctly relied on the ISO-NE’s evidence of a reliability need, and that the Petitioners misconstrue the cost estimate evidence offered by ISO-NE. The Petitioners must file reply briefs by March 30. Oral argument has not yet been scheduled.