EL26-72-000 · 2026-08-07 · New England States Committee on Electricity

Answer of the New England States Committee on Electricity in Response to Joint Motion for Abeyance filed by ISO New England, Inc. et al

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UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
 
ISO New England Inc.  
 
 
 
) 
Central Maine Power Company 
 
 
) 
 
The Connecticut Light and Power Company  
) 
Fitchburg Gas and Electric Light Company  
) 
Green Mountain Power Corporation  
 
) 
Maine Electric Power Company 
 
 
) 
The Narragansett Electric Company  
 
) 
 
Docket No. EL26-72 
New England Power Company 
 
 
) 
New Hampshire Transmission, LLC  
 
) 
NSTAR Electric Company 
 
 
 
) 
Public Service Company of New Hampshire  
) 
The United Illuminating Company 
 
 
) 
Unitil Energy Systems, Inc.  
 
 
) 
Vermont Electric Power Company, Inc. 
 
) 
Vermont Transco LLC 
 
 
 
) 
Versant Power 
 
 
 
 
) 
 
 
ANSWER IN RESPONSE OF THE NEW ENGLAND STATES COMMITTEE ON  
ELECTRICITY TO THE MOTION OF ISO NEW ENGLAND, INC.  
AND THE PARTICIPATING TRANSMISSION OWNERS  
ADMINISTRATIVE COMMITTEE TO HOLD  
PROCEEDING IN ABEYANCE 
 
Pursuant to the Federal Energy Regulatory Commission’s (the “Commission”) Notice 
Establishing Answer Period, the New England States Committee on Electricity (“NESCOE”)1 
hereby submits this answer in response to the Joint Motion of ISO New England, Inc. (“ISO-
NE”) and the Participating Transmission Owners Administrative Committee (“PTOAC”) on 
Behalf of the Participating Transmission Owners to Hold Proceeding in Abeyance (the “Joint 
 
1  On June 23, 2026, NESCOE filed a doc-less motion to intervene in this proceeding.  
NESCOE is the Regional State Committee for New England, representing the collective 
positions of the six New England states in regional electricity matters.

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Motion”).  For the reasons described below, NESCOE supports the Joint Motion and respectfully 
requests that the Commission grant it.   
I. 
DESCRIPTION OF COMMENTER 
NESCOE is the Regional State Committee (“RSC”) for New England.  It is governed by 
a board of managers appointed by the Governors of Connecticut, Maine, Massachusetts, New 
Hampshire, Rhode Island, and Vermont and is funded through a regional tariff that ISO-NE 
administers.2  NESCOE’s mission is to represent the interests of the citizens of the New England 
region by advancing policies that will provide electricity at the lowest possible price over the 
long term, consistent with maintaining reliable service and environmental quality.3  This answer 
in response represents the collective view of the six New England states.      
II. 
BACKGROUND 
On June 18, 2026, the Commission issued an order instituting the above-captioned 
proceeding pursuant to Section 206 of the Federal Power Act (the “Show Cause Order”).4  The 
Show Cause Order directed ISO-NE and the Participating Transmission Owners to show cause 
that ISO-NE’s existing Transmission, Markets and Services Tariff (the “Tariff”) remains just and 
reasonable and not unduly discriminatory or preferential without provisions addressing certain 
delineated issues related to large and co-located loads.5  Although the Commission directed ISO-
NE and the PTOs to respond within 60 days of the Show Cause Order, the Commission also 
 
2 ISO New England Inc., 121 FERC ¶ 61,105 (2007).   
3 See Sept. 8, 2006 NESCOE Term Sheet that was filed for information as Exhibit A to the 
Memorandum of Understanding among ISO-NE, the New England Power Pool (“NEPOOL”), 
and NESCOE (the “NESCOE MOU”).  Informational Filing of the New England States 
Committee on Electricity, Docket No. ER07-1324-000 (filed Nov. 21, 2007).  Pursuant to the 
NESCOE MOU, the Term Sheet is the binding obligation of ISO-NE, NEPOOL, and NESCOE.   
4 ISO New England Inc., 195 FERC ¶ 61,215 (2026). 
5 Id. at P. 32.

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stated that it would consider requests to hold all or certain aspects of the Show Cause Order in 
abeyance for up to 90 days for the responding parties to work through the stakeholder process to 
develop FPA Section 205 filings to revise the Tariff.6   
On August 3, 2026, ISO-NE and the PTOAC filed the Joint Motion.  The Joint Motion 
seeks a 90-day abeyance of the Show Cause Order.7  The Joint Motion anticipates that the parties 
will develop a Section 205 filing that will “address all of the Commission’s concerns in each of 
the five categories of reform of the Show Cause Order….”8  As described in the Joint Motion, 
the abeyance will allow ISO-NE and the PTOs to present a proposed design and Tariff 
provisions, as needed, to the New England Power Pool (“NEPOOL”) Transmission Committee 
and Markets Committee.9  The Joint Motion further represents that the NEPOOL Participants 
Committee would vote on the Section 205 proposal at its November 12, 2026 meeting and that 
the parties would make their Section 205 filing with the Commission on November 16, 2026.10   
III. 
ANSWER IN RESPONSE 
NESCOE supports ISO-NE and the PTOAC’s request for an abeyance to allow for them 
to develop a Section 205 filing through New England’s stakeholder process.  As the Joint Motion 
notes, “the request is consistent with the long-standing history of stakeholder engagement in 
New England.”11  The large load and co-location issues raised by the Show Cause Order are 
 
6 Id. at PP. 32, 36.   
7 Joint Motion, at 2.   
8 Id., at 5.   
9 Id., at 11.   
10 Id., at 11–12.   
11 Joint Motion, at 4.

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significant and complex, and ISO-NE and the PTOAC’s expected Section 205 filing would likely 
be made much stronger if developed through New England’s robust stakeholder process.   
The issues raised in the Show Cause Order are important to NESCOE, and NESCOE 
plans to fully participate in the regional stakeholder process that the Joint Motion contemplates.  
Indeed, NESCOE has offered its preliminary input on ISO-NE and the PTOAC’s response to the 
Show Cause Order, identifying certain foundational principles against which it will assess any 
proposed Section 205 filing.12  In brief, NESCOE believes that any new regulatory construct 
should seek to mitigate the ratepayer cost impacts of new large load projects, preserve traditional 
state authority to regulate large and co-located loads, prioritize reliability, and promote 
transparency.13  NESCOE looks forward to participating in the stakeholder process that will be 
made possible by the Joint Motion’s requested abeyance. 
 
 
12 NESCOE, Preliminary Input on ISO-NE’s Response to the Large and Co-Located Loads Show 
Cause Order (July 30, 2026), available at https://nescoe.com/wp-
content/uploads/2026/08/NESCOE-Large-Load-Advanced-Feedback-7-30-26.pdf (last checked 
Aug. 7, 2026).   
13 Id. at 2.

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IV. 
CONCLUSION 
Therefore, for the reasons stated herein, NESCOE respectfully requests that the 
Commission grant the Joint Motion.     
 
 
 
 
 
Respectfully Submitted, 
/s/ Nathan Forster 
Nathan Forster, General Counsel 
Shannon Beale, Assistant General Counsel 
New England States Committee on Electricity 
P.O. Box 322 
Osterville, MA 02655 
Tel: (617) 431-0462 
Email: nathanforster@nescoe.com 
Email: shannonbeale@nescoe.com 
Date: August 7, 2026

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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 Osterville, Massachusetts this 7th day of August, 2026.   
 
/s/ Nathan Forster 
Nathan Forster, General Counsel 
Shannon Beale, Assistant General Counsel 
New England States Committee on Electricity 
P.O. Box 322 
Osterville, MA 02655 
Tel: (617) 431-0462 
Email: nathanforster@nescoe.com 
Email: shannonbeale@nescoe.com