November 21, 2025

On October 23, 2025, ISO-NE issued a request for comments on the development of the Asset Condition Reviewer Role and process.[1] NESCOE submitted the following response via ISO-NE’s online feedback form on November 21, 2025.

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ISO-NE Feedback Form

“To further inform the development of the Asset Condition Reviewer (ACR) role and process, ISO New England welcomes additional stakeholder feedback. The purpose of this feedback form is to understand stakeholders’ objectives for the permanent ACR function.

Earlier stakeholder feedback, which does not need to be resubmitted, has been synthesized into categories; this feedback form is formatted based on these categories.

Please review the categories listed below and provide your feedback where appropriate.”

1. Objectives for the Role (impartial project reviews, expertise, advisory role)

NESCOE acknowledges ISO-NE’s interest in feedback tailored to the questions presented and in avoiding duplication of prior comments. Accordingly, NESCOE provides brief comments in connection with each question, with links to NESCOE’s prior comments for reference.

NESCOE appreciates ISO-NE’s work to establish a permanent asset condition reviewer role and associated processes, subject to ISO-NE’s preconditions that NESCOE has indicated are reasonable. Ratepayers, states, consumer advocates, and stakeholders more broadly will benefit from ISO-NE’s system planning expertise and analysis of asset condition projects, which represent a significant and continually growing portion of the region’s transmission investment. It would be difficult and extremely costly for states, consumer advocates, or other stakeholders to develop or retain comparable expertise, and so NESCOE appreciates the time and effort ISO-NE is taking to establish an effective asset condition reviewer role that meets the region’s needs.

NESCOE expects an asset condition reviewer will benefit consumers by providing an independent, objective, expert review of asset condition proposals. This must include an assessment of asserted needs, the base proposal, potential alternatives, and importantly, whether project costs are reasonable and justified. Recognizing that ISO-NE’s asset condition reviewer output will be purely advisory, it is imperative that the review ultimately provide information of sufficient detail to enable states, consumer advocates and others to rely upon it to challenge or support the asserted need, the project option selected and/or costs, as needed. Given that one ISO-NE precondition is that it not step into the role of a regulator and make prudency determinations but that it will review project costs, it is important for ISO-NE to explain clearly the cost analysis it will provide.

More detailed information on NESCOE’s perspective on objectives for an asset condition reviewer is included in prior comments at the links below:

• Asset Condition Reviewer Priorities. June 9, 2025, available at https://nescoe.com/wp-content/uploads/2025/06/Asset-Condition-Reviewer-Priorities.pdf
• Asset Condition Reviewer. May 16, 2025, available at https://nescoe.com/wp-content/uploads/2025/05/NESCOE-Statement-on-ACP-Reviewer.pdf

2. Possible Governance Structures

This is a novel role for ISO-NE and, indeed, for any RTO. For that reason, NESCOE especially appreciates ISO-NE gathering views on possible governance options that both ensure independence in the execution of the ACR duties and that capture the value of the asset condition reviewer’s expertise in the context of ISO-NE’s holistic system planning duties. Confidence in the ACR’s independence is critical to gaining confidence in asset condition projects.

Governance options present trade-offs. For example, assigning the asset condition reviewer duties to an existing internal ISO-NE division may not provide, or have the appearance of providing, complete independence given the nature of the ACR’s work and ISO-NE’s contractual relationship with transmission owners. On the other hand, a governance construct more akin to an Independent Market Monitor could result in the reviewer being relatively disconnected from ISO-NE planning staff and their duties, when a connection would add value to the system and ultimately for consumers, especially in the context of holistic system planning or rightsizing (see Question 6).

NESCOE suggests that ISO-NE explore a hybrid structure to balance these trade-offs. As one example of several possible structures, ISO-NE should consider structuring the asset condition reviewer as an internal division to enable it to regularly interact with and contribute to other ISO-NE planning departments in the regular course of business, together with an incremental reporting path to the Board or a Board Committee to safeguard its independence as needed.

NESCOE is interested in understanding how ISO-NE and others have evaluated potential governance structures, and assessments of the tradeoffs that various options present.

3. Defined Criteria for How ACPs Are Submitted, Reviewed, and Presented

The asset condition reviewer should review all types of asset condition projects, regardless of the primary driver (i.e., asset deterioration, telecommunications, NERC/NPCC compliance).

In particular, there should be a process to ensure that projects addressing NERC CIP-014 standards or any other standards that may require confidential handling of materials beyond the CEII level are thoroughly reviewed. This is important because states, consumer advocates, and stakeholders will not have sufficient access to project details to perform such assessments and will necessarily need to rely on the asset condition reviewer’s review and conclusions.

Additionally, there should also be a process for the thorough review of all programmatic asset management approaches (i.e., system-wide replacement of certain assets or technologies, such as the UCMP). Such review of transmission owners’ programs should occur and be communicated to stakeholders before a transmission owner brings forward individual projects within the program so that the individual project review has the benefit of the programmatic review.

Overall, the process should enable the review to occur early enough so as not to unnecessarily delay projects while also allowing the TOs the opportunity to incorporate feedback from the reviewer. The TOs should make any change to a proposed project that is responsive to reviewer feedback visible to the PAC. Similarly, project presentations must be timed in a way that would allow the TOs and the reviewer to consider stakeholder feedback.

We look forward to hearing from ISO-NE and other stakeholders in connection with specific criteria, proposed timelines and associated details.

4. Actionable, Cost-Focused Review Outputs

NESCOE has indicated that ISO-NE’s precondition that it not step into the role of a regulator and make prudency findings is reasonable. Respecting that precondition, the asset condition reviewer outputs must be sufficiently detailed, including in connection with analysis of project costs, to be of use to states, consumer advocates or stakeholders who may wish to challenge or support projects, as appropriate.

With respect to costs, a key function of the reviewer will be to illuminate and clarify cost drivers for projects as well as how different design considerations affect costs. The reviewer should also help states, consumer advocates and stakeholders understand why seemingly similar projects may have significantly different unitized costs (i.e., due to design preferences, variations in siting or permitting costs, access considerations, etc.).

In this phase of establishing the asset condition reviewer duties and outputs, it is imperative that ISO-NE, states, consumer advocates, transmission owners, and stakeholders have a clear and common understanding of project cost-related information and analyses the reviewer will provide.

5. Stakeholder Involvement, Understanding, and Confidence in Asset Development Needs

The urgent need for states, consumer advocates, stakeholders and ISO-NE to have far better understanding of, and confidence in, asset condition projects has been at the heart of NESCOE’s requests to transmission owners since February 2023. NESCOE’s previous comments provide greater detail on NESCOE’s perspective of possible ways to address this need. We look forward to hearing from others their views on how best to achieve these outcomes.

• Asset Condition Projects and Process Improvements. February 8, 2023, available at https://nescoe.com/wp-content/uploads/2023/02/Asset_Condition_Ltr_2-8-23.pdf.
• Asset Condition Process Improvements – Next Steps. July 14, 2023, available at https://nescoe.com/wp-content/uploads/2023/07/Asset-Cond-NETO-Requestsf-7.14.23-.pdf
• NETOs’ Asset Condition Process Guide in Lieu of a Guidance Document. June 5, 2024, available at https://nescoe.com/wp-content/uploads/2024/06/Feedback-on-Process-Guide.pdf
• Asset Condition Reviewer Priorities. June 9, 2025, available at https://nescoe.com/wp-content/uploads/2025/06/Asset-Condition-Reviewer-Priorities.pdf
• Asset Condition Reviewer. May 16, 2025, available at https://nescoe.com/wp-content/uploads/2025/05/NESCOE-Statement-on-ACP-Reviewer.pdf

6. Holistic System Planning With Other Regional Upgrades

Carefully structured holistic system planning has the potential to benefit consumers and to minimize overall system costs by identifying the most efficient way to simultaneously address various system needs. Such a holistic approach should include processes to identify whether and to what extent to right-size transmission to account for broader potential needs. However, as NESCOE has emphasized repeatedly, a rightsizing approach requires confidence in the first instance that the underlying project is warranted and reasonable. A robust asset condition review process that is transparent and provides oversight and scrutiny of asset condition projects can help bring the confidence necessary to develop a rightsizing approach. ISO-NE’s establishment of a permanent asset condition review process, coupled with the transparency improvements made over the last two years, put the region in a position to begin considering a right-sizing approach.

Rightsizing will be a component of the upcoming FERC Order 1920 compliance discussions. Accordingly, it is sensible for the region to begin right-sizing approach discussions in 2026 so as not to be unnecessarily rushed by the FERC Order 1920 compliance deadline.  Scheduling rightsizing discussions to occur in parallel with the development of the permanent asset condition reviewer role should also create the opportunity to align the two processes efficiently, as appropriate.