The NEPOOL Transmission and Markets Committees voted April 17 to support an ISO-NE proposal to adjust several key dates and deadlines in its compliance proposal for FERC Order 2023, which the commission approved April 4. The committees also voted to support an amendment by RENEW Northeast to extend the deadline for late-stage projects to complete their system impact studies (SISs).
FERC’s ruling accepting ISO-NE’s Order 2023 compliance filing did not alter the RTO’s proposed timeline for its transition process, which includes dates and deadlines that have passed and no longer are viable. (See FERC Approves ISO-NE Order 2023 Interconnection Proposal.) To amend these issues, ISO-NE plans to file “narrowly tailored tariff revisions to only adjust transition related dates in the compliance proposal by approximately one year.”
These changes would allow the RTO to align its transitional capacity network resource (CNR) group study with the 2025 Interim Reconfiguration Auction Qualification Process — a necessary step to run the CNR study in 2025 — and start the transitional cluster study (TCS) in October.
The transitional CNR study is intended to enable interconnection customers with complete SISs to achieve capacity interconnection rights, while the TCS will be open to all other projects with valid interconnection requests. ISO-NE will use the results of the CNR study as an input to the TCS.
The RTO plans to make a Section 205 filing with the timeline changes “immediately following the May 2025 Participants Committee meeting, and request a next day effective date for the revisions to adjust the dates,” said Alex Rost, director of transmission services at ISO-NE.
Rost said ISO-NE has closed the queue again after opening it briefly on April 1 and noted that only resources with valid interconnection requests as of June 13, 2024, will be eligible to enter the TCS. The next opportunity for resources to enter the interconnection queue will be the initial cluster request window, which will open after ISO-NE completes the TCS. If the TCS begins in October 2025, the queue would be slated to reopen in late 2026.
Because the new interconnection rules already are in place — and technically took effect Aug. 12, 2024, despite FERC not ruling until April 4, 2025 — ISO-NE has stopped work on all ongoing interconnection studies under the prior rules, Rost said. He noted that “any on-hand deposits associated with an [interconnection request] that is eligible for the transition can be applied to transition studies.”
He said ISO-NE will honor any SISs completed between the official effective date and the date ISO-NE received the ruling, as these studies were completed under the rules that were in place at the time.
Abigail Krich of Boreas Renewables, speaking on behalf of RENEW Northeast, proposed to amend the expedited filing to allow late-stage requests to continue their SISs until Aug. 29, 2025.
“The only component of the ISO’s originally proposed transition that they do not propose to shift forward by [about] one year is the late-stage SIS completion deadline,” Krich wrote in a memo prior to the meeting. She noted that ISO-NE initially proposed to continue working on late-stage SISs through Aug. 30, 2024.
Krich said late-stage projects already could have spent “on the order of $250,000” on interconnection studies, which would be invalidated if the studies are not completed prior to the TCS. She said there appears to be 10 or fewer projects that could be eligible for this late-stage treatment.
“These [interconnection requests] remain eligible to enter the TCS this fall, but doing so will cost them more money, delay their interconnection and put them at risk of larger withdrawal penalties,” Krich said. She added that completing the system impact studies for as many projects as possible prior to the TCS would reduce the size, complexity and withdrawal risks of the study.
“Continuing work on the few interconnection requests that would potentially be identified as ‘late-stage’ would be a relatively small amount of work for the ISO’s interconnection team and should not take away from the ability to implement the remainder of the Order 2023 transition,” Krich added.
Developers with late-stage interconnection requests have expressed a strong interest in continuing their studies and argued it is in the region’s best interest to complete these studies to help bring new resources online as quickly as possible.
ISO-NE expressed concern about potential issues associated with reintroducing the old interconnection rules for late-stage requests, and that incorporating RENEW’s proposal into its filing could complicate the approval of its proposed timing changes.
The committee voted to support both RENEW’s amendment and ISO-NE’s proposal without the amendment. ISO-NE said it will consider its options before bringing the proposal to the NEPOOL Participants Committee on May 1.
ISO-NE also plans to work with stakeholders to make a second filing to address the series of relatively minor issues that FERC identified with its Order 2023 compliance proposal. This filing is due in early June.