Comments on Cost Recovery Proposal for Interconnection Reliability Operating Limit Critical Infrastructure Proposal

January 27, 2020 | Posted in: System Planning & Expansion, Regional Planning Process & Technical Information, Reliability

United States of America Before the Federal Energy Regulatory Commission
ISO New England Inc. | Docket No. ER20-739-000
Comments of the New England States Committee on Electricity 
Pursuant to the Federal Energy Regulatory Commission’s (“Commission” or “FERC”) January 6, 2020 Notice of Filings #1, the New England States Committee on Electricity (“NESCOE”) hereby submits these comments in the above-captioned proceeding.[1]
I.              BACKGROUND
On January 6, 2020, ISO New England Inc. (“ISO-NE”) filed pursuant to Federal Power Act (“FPA”) Section 205[2] proposed revisions to its Open Access Transmission Tariff (“OATT”)[3] to incorporate a mechanism to facilitate the recovery of certain specified Critical Infrastructure Protection (“CIP”) costs by facilities that ISO-NE designates as critical to the derivation of Interconnection Reliability Operating Limits (“IROL”) (such costs are referred to as “IROL-CIP Costs”).