ISO-NE outlined how FERC’s time extension for Order 2023 compliance will affect its proposal, at a meeting of the NEPOOL Transmission Committee on Nov. 9.
The RTO plans to file on April 1 with a proposed effective date of May 31, upon which it would issue study agreements to interconnection customers that are due 60 days later, followed by the beginning of the cluster study. Customers with valid interconnection requests as of May 1 would be able to enter the transitional cluster.
“Interconnection requests that are not valid and have not been assigned [a] queue position as of [May 1] will be withdrawn by the ISO without further opportunity to cure any deficiencies,” said Graham Jesmer, ISO-NE regulatory counsel. “The ISO will not accept any interconnection requests submitted after [May 1] until the first cluster entry window opens in 2025.”
Interconnection requests in the system impact study (SIS) phase as of May 1 will continue through the May 31 effective date. “Results of those studies will be provided for information purposes only and will not affect a project’s status with respect to the transitional cluster study,” Jesmer said.
Alex Rost, ISO-NE manager of resource qualification, discussed how Order 2023, along with the delay of Forward Capacity Auction 19, will affect new resources looking to establish capacity network resource capability (CNRC) and capacity network import capability (CNIC). Complying with Order 2023 means moving the process for gaining CNRC and CNIC from the Forward Capacity Market to the cluster study process.
Rost noted that under ISO-NE’s proposal to delay FCA 19, resources lacking a capacity supply obligation (CSO) would be able to submit their qualification materials using the original capacity qualification schedule, referred to as “supplemental qualification.” (See NEPOOL Votes to Delay FCA 19.) The current process for achieving CNRC and CNIC would apply until Sept. 1, 2024.
“After Sept. 1, 2024, resources subject to the ISO’s interconnection procedures can still obtain a CSO in FCM auctions but will not be able to establish CNRC/CNIC by obtaining CSO in FCM auctions,” Rost said.
Stakeholder Proposals
Representatives of the clean energy development companies New Leaf Energy and Cypress Creek Renewables also presented recommendations to ISO-NE on its Order 2023 compliance at the meeting.
Cypress recommended the RTO require complete site control for interconnection and generator facilities at the time of executing interconnection agreements to reduce speculative projects.
The company also said ISO-NE should take steps to preserve flexibility around “electrically proximate” points of interconnection, allow interconnection customers to make transition study deposits via letter of credit, and stagger the start of subsequent clusters to increase the amount of information available to interconnection customers.
New Leaf expanded upon the recommendations it made to the MC in October, stressing the importance of allowing late-stage interconnections studies to proceed for as long as possible to prevent project delays and limit the number of projects in the transitional cluster study. (See ISO-NE Provides More Detail on Order 2023 Compliance.)
“We respectfully ask ISO-NE to provide the committee with an assessment of which queue positions with an SIS in-progress have an estimated SIS completion date prior to the commencement of the transitional studies … and whether ISO-NE could somehow ‘commit’ to completing those studies,” New Leaf said.
