RENSSELAER, N.Y. — NYISO on Monday presented another reformulated proposal to enhance its interconnection study processes and align with the new directives set forth in FERC Order 2023.
During the Interconnection Issues Task Force’s first meeting, NYISO said it will adhere to FERC’s proposed study format but introduce some ISO-specific variations, such as a two-phase cluster study, a rolling optional pre-application and an altered customer engagement window with a physical infeasibility screening. The IITF was established to investigate, refine and implement these directives.
NYISO argues that its proposal strikes a balance between FERC’s guidelines and the unique needs of New York’s energy landscape. FERC’s directive accommodates such variations, recognizing that each RTO and ISO faces its own set of challenges and policies.
The most significant difference between NYISO’s and FERC’s proposals lies in the structure of the cluster studies.
Unlike FERC’s single cluster study that is followed by individual facility studies, the ISO uses a two-phase approach in which routine interconnection studies, like the system reliability impact study or system upgrade study, would be conducted in the second phase.
A new window would be initiated every 18 months, sticking to the commission’s overall timeline but incorporating elements from NYISO’s previous interconnection queue changes. There would be a slight overlap between each cluster study window, but the ISO does not expect this to necessitate any rework.
Thinh Nguyen, NYISO senior manager of interconnection projects, explained that the ISO also wants to include several pre-work phases within the study window to “help organize and provide the appropriate information at the start of each phase to developers and” the ISO.
NYISO would transition directly to the new cluster study process, bypassing a yearlong transitional study. The move aims to minimize the transition impacts and allow the next cohort of projects sufficient time to adapt to the new procedures.
Stakeholders at the IITF meeting were generally receptive to NYISO’s proposals but urged the ISO to ensure clarity in its revisions to avoid future confusion.
Mark Reeder, representing the Alliance for Clean Energy New York, worried about the window overlap and if conducting project feasibility studies at the end of one window when another starts was the best way to go about things.
Sara Keegan, an attorney with NYISO, responded that conducting these studies later has proved more efficient in other RTO and ISOs interconnection studies and the ISO does not think it would cause any issues.
Howard Fromer, who represents Bayonne Energy Center, expressed concern for how Class Year 2021 projects currently seeking interconnection would be affected. NYISO clarified that because these projects finished class year processes, they are now subject to different standards, but it promised further details in the future.
Doreen Saia, an attorney with Greenberg Traurig, inquired about the treatment of new interconnection requests during this transition period, saying the ISO should try and get ahead of this potential issue to avoid “having a whole bunch of requests coming in because [projects] are afraid of missing out.”
NYISO staff assured Saia that new requests would continue to be accepted and promised to provide a clearer timetable soon.
NYISO, along with other RTOs, filed Order 2023 compliance extension requests with FERC, but if its request is denied, then it must file its compliance by Dec. 5. (See NYISO to Ask FERC for Order 2023 Compliance Extension.)
The IITF will reconvene to discuss the proposal in greater detail Oct. 20.
