ISO-NE reviewed changes to its Order 2023 compliance redlines with stakeholders at the NEPOOL Transmission Committee (TC) on Jan. 23 as the committee prepares for a vote on compliance in February. Multiple clean energy organizations, meanwhile, proposed compliance amendments. 

Al McBride, director of transmission services and resource qualification at ISO-NE, first summarized the tariff redlines at the December meeting of the TC. (See ISO-NE Details Order 2023 Tariff Changes.) At the January meeting, McBride detailed redline changes largely intended to clarify and clean up aspects of ISO-NE’s compliance proposal.  

McBride also provided an update on the status of the interconnection queue, which consists of 203 active projects totaling 39,563 MW. Of those projects, 68 accounting for 11,423 MW have completed their system impact studies, which means they will not need to enter initial transitional cluster study.  

System impact studies for 5,573 MW worth of late-stage interconnection requests are expected to be completed before the current cutoff point for these projects to avoid needing to enter the transitional cluster.  

Representatives from Advanced Energy United, RENEW Northeast, New Leaf Energy, Cypress Creek Renewables and Glenvale Solar provided updates on their compliance amendments and outlined the proposals they will offer for a TC vote in February. 

New Leaf’s first proposal, supported by Advanced Energy United, would have the RTO extend the cutoff date for system impact studies that are expected to be completed prior to the start of the transitional cluster study but are not completed by the currently proposed cutoff point.  

McBride told the TC that nine projects amounting to 1,485 MW are on track to complete their system impact studies after the current cutoff point but prior to the first cluster study.  

New Leaf also proposed to calculate withdrawal penalties for the transitional cluster study strictly based on study costs incurred within this cluster, excluding any study costs from before the cluster from the penalties, to “fairly calculate withdrawal penalties for all projects in the transitional cluster.” 

The company’s third proposal would require ISO-NE to determine during the customer engagement window whether interconnection customers will be included in a cluster subgroup. The RTO said it “does not intend to use subgroups in the clustering process,” but would have the option to create subgroups. 

Cypress Creek, a solar and storage company, said three of its four previously proposed amendments have been adequately addressed by ISO-NE, and has withdrawn the fourth amendment related to site control because the issue is subject to an ongoing rehearing request with FERC.  

Advanced Energy United, which previously expressed concern about the extended length of the cluster timeline compared to the process proposed by FERC, is proposing to create an “Interconnection Reforms Working Group” aimed at reducing cluster study timelines. 

“At the heart of Order 2023 was a resolve to accelerate interconnection study and processing timeframes, and we must strive to meet the order’s requirements even if we cannot commit right now,” said Alex Lawton of United.  

The clean energy industry association also proposed to increase guidance and transparency around the selection of alternative transmission technologies as upgrade solutions, including the explicit consideration of dynamic line ratings.  

United and RENEW jointly proposed to provide an opportunity for interconnection customers to reduce project size if ISO-NE determines a restudy is needed. This opportunity would extend only to modifications that do not affect the cost or timing of another project. 

“Order 2023 provides a clear and firm basis for allowing reductions that are not material,” United said. 

RENEW also proposed that ISO-NE separately calculate costs for Capacity Network Resource (CNR) Interconnection Service and Network Resource (NR) Interconnection Service. The clean energy nonprofit also proposed to “allow CNR Interconnection Requests to downgrade their requested service to NRIS” in response to the results of a cluster study, restudy, or facilities study, with some limitations.  

The organization also proposed changes to let new resources with completed SIS and a commercial operation date prior to June 1, 2028, to participate in reconfiguration auctions in 2024. 

Glenvale Solar proposed a series of amendments that would incentivize cash deposits over letters of credit for commercial readiness deposits (CRDs), reduce the first posting of CRDs and reduce CRDs for modifications of existing generation that do not add capacity. 

The TC will vote on the ISO-NE compliance proposal and stakeholder amendments on Feb. 15. 

Longer-term Transmission Planning

Brent Oberlin of ISO-NE provided additional information on the RTO’s efforts to create a new process for transmission projects that address needs identified in its longer-term transmission studies. (See ISO-NE Details Order 2023 Tariff Changes.) 

The new process is being developed in coordination with the New England States Committee on Electricity (NESCOE), which represents the interests of all six New England states. The process is intended to establish “the rules that enable the states to achieve their policies through the development of transmission to address anticipated system concerns and the associated cost allocation method,” Oberlin said.  

For project bids to be eligible for selection, a quantitative comparison of benefits and costs must show net benefits. Oberlin told the TC that this analysis will include production cost and congestion savings, avoided transmission and local resources needed to meet demand, and reductions in losses. 

The factors considered do not explicitly include climate or public health benefits, which several stakeholders expressed an interest in including as considerations.  

NEPOOL also proposed the creation of a supplemental process that would enable it to select projects that do not meet the cost-benefit threshold.  

“This supplemental process would allow one or more states to fund costs if the [benefit-cost ratio, BCR] threshold was not met in order to move the project forward,” said Sheila Keane of NESCOE, who noted this process would be used only if no project proposals meet the threshold. 

“Costs commensurate with the BCR tariff criteria will be regionalized with one or more states agreeing to cover the remaining costs,” Keane added. “If the NESCOE selected project has BCR = .95, the region pays for 95% of project costs on a load-share basis and one or more states fund the remaining 5% of costs.”