RENSSELAER, N.Y. — NYISO on Feb. 6 presented the Interconnection Issues Task Force (IITF) with its plan for transitioning to its new generator interconnection procedures under FERC Order 2023, including a nearly three-month pause on accepting new interconnection requests.
The pause would begin April 4, one day after NYISO’s deadline to file its full Order 2023 compliance proposal with FERC. The commission last month approved a partial compliance filing that allows developers to opt in to certain studies that will be eliminated under the new rules. (See FERC Approves NYISO Waiver on Interconnection Study Requirements.)
The ISO would then begin accepting applications into a transitional cluster July 1, until Oct. 15; work on processing the projects would begin Jan. 15, 2025, with a goal of finishing by April 20, 2026.
The “first official study” under Order 2023 would then begin on May 1, said Sara Keegan, NYISO’s assistant general counsel, “but we’re still looking at this start date and how to actually tie it into the end of the [transitional study], so this is still a bit of an unknown.”
Keegan highlighted the possibility of changes to the proposed transition timeline because of the “inherent risks” associated with any FERC filing. She said FERC “does not have a deadline by which they have to act,” so should the commission not issue a timely ruling or require additional compliance requirements, “things could unravel” and necessitate adjustments to the proposed dates.
NYISO is “approaching this filing carefully,” Keegan said, and it “appreciates the frustration” from developers who are apprehensive about the transition, especially those either with projects already in the interconnection queue as part of class year 2023 or considering having their projects participate in the transitional cluster.
Keegan discussed other adjustments to NYISO’s interconnection procedures during the IITF meeting, which will eventually be in tariff Attachment HH. This proposed attachment will consolidate existing interconnection requirements from Attachment S (rules to allocate responsibility for the cost of new interconnection facilities), Attachment X (standard large facility interconnection procedures) and Attachment Z (small generator interconnection procedures), along with the new processes. The attachments will remain in NYISO’s tariff for the limited purpose of completing CY23 projects and facilitating the transition.
The ISO also posted a redline of Attachment HH, incorporating stakeholder feedback since the last IITF meeting.
NYISO will return to IITF stakeholders multiple times before the April 3 filing deadline to review and finalize the proposed tariff language.
