RENEW Northeast is asking FERC to shift the burden of network upgrade operations and maintenance costs in ISO-NE off of interconnection customers.
In a complaint filed this week, the organization argued that the policy, contained in schedules 11 and 21 of Part II of ISO-NE’s tariff, is unjust and unreasonable.
“ISO-NE is the only region in the United States in which interconnection customers are directly assigned all capital cost and all ongoing O&M costs for network upgrades, regardless of who causes the network upgrades or who benefits from the network upgrades,” RENEW wrote in its complaint.
Since Order 2003 nearly 20 years ago, FERC’s policy has been to require interconnection customers to initially fund the cost of network upgrades that would not have been required without that specific interconnection, but not to let transmission owners assign customers ongoing O&M costs.
“There was never any rationale behind this exemption from the commission’s O&M policy other than it having been a transitional measure included in New England Power Pool’s transition to an ISO and its Order No. 2003 compliance filing,” RENEW wrote. “Continued direct assignment of O&M costs to interconnection customers is not just and reasonable and should be rejected.”
RENEW sees it as an issue especially for its members — renewable generators — because the process of interconnection can be especially unwieldy for new generation projects, and the direct assignment of O&M costs adds another burden and barrier to entry.
It’s one of the factors that could cause projects to withdraw late in the interconnection process, according to RENEW.
“Since network upgrades provide a systemwide benefit, expenses associated with owning, maintaining, repairing and replacing them should be recovered from all transmission customers rather than being directly assigned to the generator,” said Francis Pullaro, the group’s executive director.
RENEW tried to bring a change to address the problem through the NEPOOL process, but it missed the two-thirds vote required to advance through the Transmission Committee. In the complaint, it’s asking for FERC to issue an expedited order finding those portions of the tariff unjust and unreasonable.
