Proposed tariff changes, intended to update how ISO-NE assigns capacity rights to resources not subject to its interconnection processes, were introduced at the NEPOOL Transmission Committee meeting Oct. 28.
Alex Rost, director of transmission services, said ISO-NE proposes to “formalize the concept of equivalent capacity network resource capability (CNRC) and address how equivalent CNRC is established, managed and reduced.”
CNRC values define the capacity interconnection rights of resources that are subject to ISO-NE’s interconnection procedures. Before FERC Order 2023, resources established CNRC by obtaining capacity supply obligations (CSOs). In the new interconnection framework, those resources gain CIRs via the cluster study processes.
The Order 2023 changes have created a need “to clarify how equivalent CNRC is assigned, managed and reduced” under the new interconnection framework, Rost said.
Resources not subject to the RTO’s interconnection procedures that could receive equivalent CNRC values include those connected to the distribution system, aggregations of distributed resources and active demand resources, he noted.
“For consistency with resources subject to the ISO interconnection procedures, the process to establish equivalent CNRC … should be supported by clear and trackable commitments related to a resource achieving commercial operation,” Rost said.
To establish equivalent CNRC, resources would need to prove their deliverability in an “all-or-nothing deliverability analysis screen,” which would be coordinated with the similar deliverability analyses performed in ISO-NE interconnection cluster studies.
Deliverability analyses for resources seeking equivalent CNRC would be performed “right after the conclusion of a cluster study” and would be adjusted “as needed” following cluster restudies, Rost said.
After proving deliverability, resources could achieve equivalent CNRC by obtaining a CSO or by “locking-in” equivalent CNRC prior to participating in a capacity auction, Rost said.
The rules for the CSO pathway to achieving equivalent CNRC would be “very similar to the pre-Order No. 2023 approach used to establish CNRC,” Rost noted. CNRC values would “equal the highest amount of CSO obtained in a capacity market activity,” with seasonal adjustments to account for varying winter or summer capabilities.
To achieve equivalent CNRC prior to auction participation, developers would need a commercial operations date within the following two years and would need to demonstrate adequate financial commitment to the resource.
For resources following this path, ISO-NE would rely on winter and summer qualified capacity estimates “consistent with capacity market qualification.”
“‘Locked-in’ equivalent CNRC must be assigned to a specific project and will be withdrawn if the specific project has its interconnection agreement (or equivalent) terminated or fails to achieve commercial operation within two years from the date that equivalent CNRC is requested,” Rost said.
ISO-NE plans to maintain its existing methods for reducing or retiring equivalent CNRC; resources could request deactivation or would be automatically retired if they are inactive for three years.
Rost said the RTO plans to implement the changes prior to the 2026 interim Reconfiguration Auction qualification process. ISO-NE will discuss the proposal with stakeholders in the coming months and is targeting a TC vote in January.
