United States of America Before the Federal Energy Regulatory Commission
ISO New England Inc. and New England Power Pool Participants Committee
Docket No. ER22-727-000
Comments of the New England States Committee on Electricity
Pursuant to the Federal Energy Regulatory Commission’s (“Commission” or “FERC”) December 27, 2021 Combined Notice of Filings #1 and December 30, 2021 Errata Notice, the New England States Committee on Electricity (“NESCOE”) hereby submits these comments in the above-captioned proceeding.[1] On December 27, 2021, ISO-NE and the New England Power Pool (“NEPOOL”) Participants Committee jointly filed with the Commission proposed Tariff revisions “to incorporate a supplementary, transmission planning mechanism for the ISO to perform state-requested, scenario-based transmission analysis as a permanent feature” of the regional transmission planning process (“Longer-Term Planning Changes”).[2]
NESCOE strongly supports the Longer-Term Planning Changes. As discussed in the December 2021 Filing, these revisions effectuate one of the key visions that the New England states set out to realign our regional electric system to meet current and emerging needs.[3] NESCOE’s Vision Statement expressed that our region “cannot effectively plan for integrating clean energy resources and decarbonization of the electricity system required by certain states’ laws without having a clear understanding of the investments needed in regional transmission infrastructure.”[4] The Vision Statement further noted that the “need for such planning has become paramount” and that the Tariff currently lacks a routine planning process to identify potential cost-effective transmission investments to integrate resources across the region to meet states’ clean energy requirements.[5] NESCOE’s subsequent report to the New England Governors in July 2021, Advancing the Vision, recommended continued work with ISO-NE and stakeholders to “implement a state-led, proactive scenario-based planning process for long-term analysis of state mandates and policies as a routine planning practice.”[6]
The Longer-Term Planning Changes create this process. In so doing, the Tariff revisions implement a flexible, state-led transmission planning tool—consistent with Commission precedent[7]—to provide critical visibility into future public policy-driven transmission needs and facilitate consideration of transmission options that seek to integrate “clean energy resources at the lowest possible cost.”[8]
NESCOE greatly appreciates ISO-NE’s efforts in translating the Vision Statement’s transmission planning framework into Tariff revisions. This work culminated in broad regional consensus for this enhancement to the planning process, with market participants and stakeholders unanimously supporting the Longer-Term Planning Changes at the NEPOOL Participants Committee.[9]
For the reasons stated herein, NESCOE respectfully requests that the Commission accept the Longer-Term Planning Changes.
Respectfully Submitted,
/s/ Jason Marshall
Jason Marshall
Deputy Executive Director & General Counsel
New England States Committee on Electricity
424 Main Street
Osterville, MA 02655
Tel: (617) 913-0342
Email: jasonmarshall@nescoe.com
Date: January 18, 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 Cambridge, Massachusetts this 18th day of January, 2022.
/s/ Jason Marshall
Jason Marshall
General Counsel
New England States Committee on Electricity
424 Main Street
Osterville, MA 02655
Tel: (617) 913-0342
Email: jasonmarshall@nescoe.com