RENSSELAER, N.Y. — NYISO on Wednesday said it plans to file a motion with FERC for an extension on the compliance deadline for Order 2023, according to a presentation given to stakeholders.
Thinh Nguyen, NYISO senior manager of interconnection projects, told the Transmission Planning Advisory Subcommittee (TPAS) and Electric System Planning Working Group (ESPWG) meeting that the ISO has 90 days to make its request to the commission, following the order’s publication in the Federal Register that day.
Nguyen added that NYISO plans to hold meetings focused on the interconnection queue and Order 2023 compliance that will be held after regular TPAS sessions and be potentially named the Interconnection Issues Task Force.
NYISO’s presentation also noted how, though it and several other RTOs have already asked FERC for a rehearing on Order 2023, the ISO might still comply with the order, as it is unclear if the commission will grant a rehearing (RM22-14). (See FERC Order 2023 Gets Rehearing Requests from Around the Industry.)
The ISO has been actively working to streamline its congested interconnection queue, and while it believes Order 2023 could improve efficiencies, it also cautioned stakeholders that it believes some of FERC’s directives may be legally inconsistent or counterproductive to the order’s goals.
Stakeholders probed NYISO staff for detailed information about the transition process and its potential implications.
Doreen Saia, an attorney with Greenberg Traurig, asked whether much of the transition was still to be determined or if the ISO could share some specifics.
Nguyen acknowledged that many of the specific details are to be determined but added that “for us to make a meaningful transition, we may need to sit down and figure out what this new process will look like and come up with a transition rule that will complement our own study process.”
Mark Reeder, representing the Alliance for Clean Energy New York, asked about the frequency of the newly proposed task force’s meetings and the expected outcomes.
“It’s too early to decide whether these will be biweekly or monthly meetings, but we want to make sure that when we host these meetings that we are coming to stakeholders with meaningful information rather than just general updates,” Nguyen said.
NYISO promised to return to stakeholders with more details on how it proposes to comply with Order 2023 and how proposed revisions might impact current interconnection processes.
Comprehensive Reliability Plan
NYISO also presented an updated draft of the Comprehensive Reliability Plan, with additional sections for dispatchable emission-free resources (DEFRs) and other developing technologies, as well as the short-term reliability needs recently identified in New York City.
The newly added “Beyond the CRP — Road to 2040” section, featuring DEFRs, was included in response to stakeholder requests. (See “Comprehensive Reliability Plan,” NYISO Proposes 48 Market Projects for 2024.) The CRP, which is the last part of the reliability planning process, is conducted every two years and evaluates the future risks to reliability and the viability of proposed solutions identified in earlier Reliability Needs Assessments.
Mark Younger, president of Hudson Energy Economics, and Kevin Lang, partner at Couch White, questioned NYISO’s reliance on NERC data for reliability assessments, rather than using New York-specific data. Younger said New York City certainly has a reliability need in the short term but argued that using state data might lead to a more accurate accounting of potential shortfalls.
ISO staff said they are discussing the subject internally, though they emphasized that confidentiality concerns are a main reason New York data is not used.
NYISO aims to release its final CRP draft by late September and will seek committee approval in October.
Class Year & Expedited Deliverability Study Update
NYISO reported that 84 projects are officially part of Class Year 2023 and released a list of the 16 projects that have executed their expedited deliverability study (EDS) agreements.
The CY study assesses the feasibility of new projects looking to enter NYISO’s grid, while the EDS process is a more fast-tracked grid feasibility assessment for prioritized energy projects.
NYISO Manager of Facility Studies Wenjin Yan said the ISO must first finalize the EDS base case and estimated the study would finish next January.
Reeder suggested the ISO should consider tariff changes to allow for later entry into the EDS and consider starting another study after the current one is completed in early 2024 to enable projects to move ahead more quickly.
Yan said NYISO anticipates presenting CY23 for committee approval in July and August 2024.
NYC PPTN
NYISO gave a quick update on the New York City public policy transmission needs assessment, stating that the ISO is finalizing the baseline case and will share the data with developers upon completion.
The ISO reminded stakeholders, however, that the information would only be given to developers who have completed the requisite Critical Energy Infrastructure Information Non-Disclosure Agreement. According to both staff and stakeholders present, there is no set deadline for completing a CEII agreement.