United States of America Before the Federal Energy Regulatory Commission
RENEW Northeast, Inc., Complainant,
ISO New England Inc. and New England Participating Transmission Owners, Respondents
Docket No. EL23-16-000
Answer of the New England States Committee on Electricity In Support of the Motion for Extension of Time
Pursuant to Rule 213[1] of the Federal Energy Regulatory Commission’s (“Commission”) Rules of Practice and Procedure, the New England States Committee on Electricity (“NESCOE”)[2] submits this answer to the Motion for Extension of Time and Request for Expedited Action by the Participating Transmission Owners Administrative Committee (“PTO AC”) filed on December 16, 2022.[3] For the reasons stated herein, NESCOE agrees that an extension of time to answer the Complaint filed by RENEW Northeast, Inc. (“RENEW”) [4] in this proceeding would be reasonable and supports the PTO AC’s request. Likewise, NESCOE supports the PTO AC’s request that the Commission expedite its consideration of this motion by acting no later than December 23, 2022.[5]
In the Extension Request, the PTO AC seeks a brief extension of the deadline for responses to the Complaint from January 3, 2023 to January 23, 2023.[6] The PTO AC states that RENEW does not oppose the request for a 20-day extension.[7] The PTO AC explains that coordination among the 31 separate entities named in the complaint will be a significant undertaking.[8] The PTO AC also notes, among other things, that the Complaint relates to a complicated area of the ISO-New England Inc. tariff with numerous likely interested parties representing various stakeholder groups. [9]
Issues concerning transmission cost allocation are of critical importance to New England. NESCOE agrees that additional time to respond to the Complaint is needed and, ultimately, an extension would provide the Commission with a more thorough record. A 20-day extension of time will not prejudice RENEW—which does not oppose the request according to the Extension Request[10]—or otherwise unduly delay the resolution of any issues raised in the Complaint. NESCOE supports the request for the extension of time to answer the Complaint.\
For the reasons discussed herein, NESCOE respectfully requests that the Commission grant the PTO AC’s requested extension of time to answer the Complaint and expedite its consideration of this motion by acting no later than December 23, 2022.
Respectfully Submitted,
/s/ Shannon Beale
Shannon Beale
Assistant General Counsel
New England States Committee on Electricity
P.O. Box 322
Osterville, MA 02655
Tel: (781) 400-9000
Email: shannonbeale@nescoe.com
Dated: December 21, 2022
Certificate of Service
In accordance with Rule 2010 of the Commission’s Rules of Practice and Procedure, I hereby certify that I have this day served by electronic mail a copy of the foregoing document upon each person designated on the official service list compiled by the Secretary in this proceeding.
Dated at Natick, Massachusetts this 21st day of December, 2022.
/s/ Shannon Beale
Shannon Beale
Assistant General Counsel
New England States Committee on Electricity
P.O. Box 322
Osterville, MA 02655
Tel: (781) 400-9000
Email: shannonbeale@nescoe.com