NETOs file supplemental brief that addresses what they assert is the inability of the FERC’s order on an ROE methodology for MISO TOs to satisfy the mandate of the Court of Appeals in this proceeding, the requirements of FPA Section 206 (including the 15-month limitation on refunds) and the need to promote transmission investment in New England.  NETOs assert that the FERC cannot merely apply the MISO approach to the NETOs, as much of the MISO approach is legally invalid, and for the FERC to meet its legal obligations under the FPA and promote
good public policy, it must address fully the NETOs’ case-specific facts and record evidence, utilizing current data and market conditions to evaluate the NETOs’ ROE.