{"document":{"slug":"motion-el26-72-isone-abeyance","title":"ISO-NE requests more time to answer the June 18 show cause order","issued":"2026-08-03","accession":"20260803-5083","docket":"EL26-72-000","group":"ISO-NE filings","filer":"ISO New England Inc.PTO AC","kind":"motion for abeyance","file":"sources/originals/20260803-5083_01.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260803-5083","sha256":"6eef8772c27ded458bc7a34c196e0d6a34732faf43c77114102c0915f07871a6","pages":14,"tokens":3353,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":233,"text":"1 \n \n \n \nUNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n \nISO New England Inc. \n \n \n \n) \nCentral Maine Power Company  \n \n \n \nThe Connecticut Light and Power Company  \nFitchburg Gas and Electric Light Company \nGreen Mountain Power Corporation  \nMaine Electric Power Company  \nThe Narragansett Electric Company \nNew England Power Company \nNew Hampshire Transmission, LLC  \nNSTAR Electric Company \nPublic Service Company of New Hampshire \nThe United Illuminating Company  \nUnitil Energy Systems, Inc.  \nVermont Electric Power Company, Inc. \nVermont Transco LLC  \nVersant Power  \nDocket No.\n \nEL26-72-000 \n \n \nJOINT MOTION OF ISO NEW ENGLAND INC. AND THE PARTICIPATING \nTRANSMISSION OWNERS ADMINISTRATIVE COMMITTEE ON BEHALF OF \nTHE PARTICIPATING TRANSMISSION OWNERS TO HOLD PROCEEDING IN \nABEYANCE AND REQUEST FOR SHORTENED COMMENT PERIOD  \nAND EXPEDITED TREATMENT \n \nPursuant to Rule 212 of the Rules of Practice and Procedure1 of the Federal Energy \nRegulatory Commission (“Commission” or “FERC”),2 and the Commission’s Order Instituting \nProceeding Under Section 206 of the Federal Power Act3 (“FPA”) issued on June 18, 2026 in the \nabove-captioned proceeding, ISO New England Inc. (“ISO-NE”) and the Participating \nTransmission Owners Administrative Committee (“PTO-AC”) on behalf of the Participating \n \n1 18 C.F.R. §§ 385.209, 385.213 (2026). \n \n2 Capitalized terms used but not defined in this filing are intended to have the meaning given to such terms in the \nISO New England Transmission, Markets and Services Tariff (“Tariff”). \n \n3 ISO New England Inc., 195 FERC ¶ 61,215 (2026) (“Show Cause Order”)."},{"page":2,"startToken":233,"endToken":616,"text":"2 \n \n \n \nTransmission Owners (“PTOs”)4 submit this motion to request that the Commission hold the \nSection 206 proceeding initiated by the Show Cause Order in abeyance for 90 days, starting \non the Show Cause Order’s compliance deadline, August 17, 2026.  Since the issuance of the \nShow Cause Order, ISO-NE and the PTOs have been working diligently to consider the design \nof Tariff updates that will address the Commission’s concerns and facilitate the integration of \nlarge loads and co-located loads in a manner consistent with the needs of the New England \nregion.  The abeyance will allow ISO-NE and the PTOs to work through the stakeholder \nprocess to develop and refine a FPA Section 205 filing that will address the issues raised in \nthe Show Cause Order.  ISO-NE and the PTOs will submit the FPA Section 205 filing to the \nCommission on or before November 16, 2026. \nBecause the response to the Show Cause Order is due on August 17, 2026, ISO-NE \nand the PTO-AC respectfully request that the Commission shorten the comment period for this \nmotion to five days and grant expedited treatment to rule on this motion within 10 days of its \nsubmission (i.e., by August 13, 2026). \n \n \n \n4 The PTOs include: Town of Braintree Electric Light Department; Central Maine Power Company; Chicopee \nMunicipal Lighting Plant; Connecticut Municipal Electric Energy Cooperative; Connecticut Transmission \nMunicipal Electric Energy Cooperative; Eversource Energy Service Company on behalf of The Connecticut Light \nand Power Company, Public Service Company of New Hampshire and NSTAR Electric Company; Fitchburg Gas \nand Electric Light Company; Green Mountain Power Corporation; The City of Holyoke Gas and Electric \nDepartment; Town of Hudson Light and Power Department; Maine Electric Power Company; Massachusetts \nMunicipal Wholesale Electric Company; Town of Middleborough Gas & Electric Department; The Narragansett \nElectric Company d/b/a Rhode Island Energy; New England Power Company d/b/a National Grid; New Hampshire \nElectric Cooperative, Inc.; New Hampshire Transmission, LLC; Town of Norwood Municipal Light Department; \nTown of Reading Municipal Light Department; Shrewsbury Electric and Cable Operations; Town of Stowe Electric \nDepartment; Taunton Municipal Lighting Plant; The United Illuminating Company; Unitil Energy Systems, Inc.; \nVermont Electric Cooperative, Inc.; Vermont Electric Power Company, Inc.; Vermont Public Power Supply \nAuthority; Vermont Transco LLC; Versant Power; and Town of Wallingford, CT, Department of Public Utilities, \nElectric Division."},{"page":3,"startToken":616,"endToken":948,"text":"3 \n \n \n \nI. \nBACKGROUND \nThe Show Cause Order is one of six show cause orders that the Commission \nsimultaneously issued to all six Regional Transmission Organizations/Independent System \nOperators to address large and co-located load issues.  In the Show Cause Order, the Commission \ndirected ISO-NE and the PTOs, within 60 days of the order, to either:  \n(1) show cause as to why the Tariff remains just and reasonable and not unduly \ndiscriminatory or preferential without provisions addressing:   \n \n(a) the application process, study procedures, and ongoing operational requirements \nthat apply to Eligible Customers seeking transmission service on behalf of large \nloads;  \n \n(b) additional transparency concerning the network upgrade costs to provide \ntransmission service to Eligible Customers on behalf of large loads, a pro forma \ncost recovery agreement between ISO-NE, the relevant transmission owner and \nEligible Customer taking transmission service on behalf of the large load to \nmitigate the risk of cost shifting among transmission customers, and a mechanism \nto ensure such payments are appropriately credited towards transmission owners’ \ntransmission revenue requirements consistent with the Commission’s cost-of-\nservice regulations;  \n \n(c) the rates, terms, and conditions of service that apply to co-location arrangements;  \n \n(d) transmission services that reflect Eligible Customers taking transmission service \non behalf of co-located loads, load with behind the meter generation, and flexible \nlarge loads that are willing and able to limit their use of the transmission system \nunder certain conditions; and \n \n(e) the rates, terms, and conditions of service applicable to interconnection \ncustomers serving electrically proximate large load or co-located load; or  \n \n(2) explain what changes to the Tariff would remedy the identified concerns if the \nCommission were to determine that the Tariff has in fact become unjust and unreasonable \nor unduly discriminatory or preferential and, therefore, proceeds to establish a \nreplacement Tariff.5 \n \n \nThe Commission also recognized that ISO-NE and/or the PTOs (to the extent the matters \naddressed in the Show Cause Order implicate aspects of the Tariff over which the PTOs have \n \n5 Show Cause Order at P 32."},{"page":4,"startToken":948,"endToken":1236,"text":"4 \n \n \n \nthe filing rights) may elect to address some or all of the issues discussed in the Show Cause \nOrder by proposing revisions to the Tariff pursuant to their applicable FPA Section 205 filing \nrights.6  The Commission strongly encouraged this.7  The Commission stated that it would \nconsider requests to hold, for up to 90 days, all or certain aspects of the Show Cause Order \nproceeding in abeyance, including the deadline to respond to the Show Cause Order to provide \nISO-NE and the PTOs time to work through the stakeholder processes to develop FPA Section \n205 filings to revise the Tariff to address the issues raised in the Show Cause Order.8 \nAlthough ISO-NE and the PTOs have been actively discussing New England-specific \nTariff revisions that will address the concerns that the Commission identified in the Show Cause \nOrder, additional time is needed to develop those proposals and present them for stakeholder \nreview.  ISO-NE and the PTOs respectfully request a 90-day abeyance of all aspects of the Show \nCause Order proceeding for the purpose indicated, i.e., sufficient time to work through the New \nEngland stakeholder process to develop and refine a FPA Section 205 filing to revise the Tariff \nto address all the issues raised in the Show Cause Order.  This request is consistent with the long-\nstanding history of stakeholder engagement in New England.  As required in the Show Cause \nOrder, Section II of this request for abeyance includes: (1) a robust description of the content of \na future filing under FPA Section 205; and (2) a reasoned and specific explanation of when the \nFPA Section 205 filing is expected to be made. \n \n \n \n6 Id. at P 35. \n \n7 Id.  \n \n8 Id. at P 36."},{"page":5,"startToken":1236,"endToken":1548,"text":"5 \n \n \n \n \nII. \nREQUEST FOR ABEYANCE OF ALL ASPECTS OF THE SHOW CAUSE \nORDER PROCEEDING \n \nA. \nContent of Future FPA Section 205 Filing \n \nAs detailed below, ISO-NE’s/the PTOs’ future FPA Section 205 filing will address all \nof the Commission’s concerns in each of the five categories of reform of the Show Cause Order \n(i.e., efficient study processes, cost transparency, co-location rules, flexible load service, and \ngeneration studies).9  The details of the future FPA Section 205 filing will be subject to \ndevelopment and input received in the stakeholder process.  Additionally, the filing will contain \nanswers to the briefing questions that the Commission posed in the Show Cause Order.10 \n1. \nEfficient Study Processes \nTo address this category of reform, the FPA Section 205 filing will address the need for \na transmission service application process and study procedures, including the evaluation of \nalternative transmission technologies.11  The filing will encompass:  \na. \nDefinition of large load.  This definition will be based on the \ncharacteristics of ISO-NE’s transmission system and will include load \nsize and an interconnection voltage threshold. \nb. \nApplication process that applies to Eligible Customers seeking \ntransmission service on behalf of large loads.  This process will address \n \n9 Pursuant to the Show Cause Order, ISO-NE’s/the PTOs’ future FPA Section 205 filing will address requests for \nunbundled retail transmission service requests by end-use large load customers (as allowed by state law or voluntary \nutility rules) as well as by Eligible Customers on behalf of large loads.  Show Cause Order at note 119. \n \n10 See Show Cause Order at P 124, stating that any filings or Tariff changes submitted in response to the Show \nCause Order should address the Commission’s briefing questions. \n \n11 As part of the stakeholder process, ISO-NE and the PTOs will identify the respective roles of ISO-NE and the \nPTOs at each stage of the application process and study procedures."},{"page":6,"startToken":1548,"endToken":1776,"text":"6 \n \n \n \naccepting Eligible Customers’ applications for transmission service on \nbehalf of large loads, requiring a non-refundable application fee, and \nsufficient readiness requirements to deter duplicative or speculative \nrequests for transmission service, as well as information and data \nrequirements that Eligible Customers must submit to ISO-NE and/or the \nPTOs regarding the characteristics of the large load on behalf of which \nthe Eligible Customer is taking transmission service (including \ndisclosure to ISO-NE of substantially similar pending transmission \nservice requests on behalf of the same large load customer).  The FPA \nSection 205 filing will also address the specific financial assurance, \nreadiness, and information requirements applicable to  entities serving \nas Eligible Customers (including the large load itself, where permitted). \nc. \nStudy procedures that apply to Eligible Customers seeking transmission \nservice on behalf of large loads.  Consistent with the Show Cause Order, \nthe study procedures will address (1) evaluating whether a large load may \nbe interconnected to the transmission system and served by the Eligible \nCustomer, and (2) determining whether network upgrades are necessary \nto provide transmission service.  The studies will  contemplate \nevaluation of the transmission system’s ability to withstand risks \nobserved from analyzed large load behavior created by the large load at \nthe point of interconnection.  Furthermore, the study process will \nconsider the unique operational characteristics of large loads that are \nwilling and able to limit their energy withdrawals under certain"},{"page":7,"startToken":1776,"endToken":1996,"text":"7 \n \n \n \nconditions, which may thereby lessen or potentially avoid the need for \ncertain network upgrades.  Proposed rules will also consider requiring \naccurate models, including Electromagnetic Transient (“EMT”) studies, \nas well as  the evaluation of alternative transmission technologies as \npotential solutions to accommodate an Eligible Customer’s request for \ntransmission service on behalf of a large load (with the results of such \nevaluation included in the report to the Eligible Customer with a \ndemonstration of why they are not feasible or would not result in lower \ncosts or a faster timeline for accommodating the transmission service \nrequest). \nd. \nOngoing operational requirements that apply to Eligible Customers \nseeking transmission service on behalf of large loads.  These \nrequirements will address the need for hourly forecasts, telemetry data \nand other data to ensure sufficient visibility, as well as maintaining \ncommunication channels.  The requirements will contemplate the \ninstallation of equipment to enable ISO-NE to monitor large loads for \nimpacts of, for example, fast-ramping load that may impact the \ntransmission system too quickly to be captured by conventional data \nacquisition systems (e.g., phasor measurement units or similar \nequipment).  The requirements will also address the need for ISO-NE to \nremotely disconnect a large load to maintain reliability of the \ntransmission system.  In addition, the rules will contemplate ramp-rate or \nride-through requirements, as well as requirements for control"},{"page":8,"startToken":1996,"endToken":2232,"text":"8 \n \n \n \ntechnologies and/or protection systems that may be necessary to limit \nwithdrawals from the transmission system as appropriate. \ne. \nPro forma transmission service agreement.  This agreement will \nmemorialize the definition of large load, application process, study \nprocess, and operational requirements. \n2. \nCost Transparency \nTo address this category of reform, ISO-NE and the PTOs will develop rules that prevent \ncost shifting and require transparency into transmission costs.  These will include: \na. \nRules for transparency concerning the network upgrade costs to provide \ntransmission service to Eligible Customers on behalf of large loads.  The \nrules will address requiring robust, accurate, and systematic provision of \ndata on the ISO-NE website in a single location and in an easily accessible \nformat that is searchable and allows users to filter the data, regarding the \nneed for network upgrades to provide transmission service to Eligible \nCustomers on behalf of large loads, as well as the costs of those network \nupgrades.  Specifically, the rules will establish the posting of information \nsuch as: (i) aggregate amounts of proposed large load additions in ISO-\nNE's footprint, including the aggregate amounts in each load zone; (ii) \nthe planned network upgrades needed to provide transmission service to \nEligible Customers on behalf of large loads, identified by type of \nequipment and network upgrades (e.g.,  new substation, reconductoring, \na new high-voltage transmission line) for each transmission service \nrequest; and (iii) cost estimates for those network upgrades. The amount"},{"page":9,"startToken":2232,"endToken":2478,"text":"9 \n \n \n \nof information that ISO-NE and the PTOs can share may be limited by \ndata confidentiality.  Any such concerns will be mitigated to the extent \npossible. \nb. \nPro forma cost recovery agreement between ISO-NE, the relevant \ntransmission owner, and Eligible Customer taking transmission service \non behalf of the large load.  This pro forma agreement will be consistent \nwith the Show Cause Order and the Commission’s cost-causation and \nbeneficiary-pays principles. \n3. \nCo-location Rules \nAs part of their FPA Section 205 filing, ISO-NE and the PTOs will submit rules that \naccommodate co-location agreements between load and behind-the-meter generation \n(“BTMG”). The rules will ensure that BTMG, as defined in part by a MW threshold, cannot be \nnetted with load behind the same point of interconnection for the purpose of determining \nRegional Network Service charges for co-located loads configured in a BTMG arrangement.  \nISO-NE plans to develop transmission services available to Eligible Customers on behalf of co-\nlocated loads that recognize the ability of co-located loads to limit withdrawal from the \ntransmission system under certain conditions, as discussed below.  \n4. \nFlexible Load Service \nTo address this category of reform, ISO-NE and the PTOs will develop rules for flexible \ntransmission services, such as: (i) interim non-firm network transmission service (i.e., \ntransmission service to be provided while network upgrades are being constructed); (ii) \npermanent firm contract demand transmission service (i.e., transmission service up to a specified \nMW quantity – the contract level – on a firm basis); and (iii) permanent non-firm contract"},{"page":10,"startToken":2478,"endToken":2674,"text":"10 \n \n \n \ndemand transmission service (i.e., transmission service up to a specified MW quantity – the \ncontract level – on a non-firm basis).   \n5. \nGeneration Studies \nTo address this category of reform, ISO-NE and the PTOs will develop a process to study \ngenerating facilities serving electrically proximate and co-located large loads.  This will include: \na. \nDefinition of electrically proximate large load, which will be \nappropriately tailored to New England’s transmission system.  \nb. \nGenerator \ninterconnection \nstudy \nprocess \nand/or \ngenerator \ninterconnection service.  The rules will address allowing an \ninterconnection customer to seek the generation interconnection \nservice(s) that reflects the operational dynamics of serving either an \nelectrically proximate large load, or a co-located load that has a high peak \nload.  In the development of these rules, the following will be considered: \n(i) an interconnection customer’s commitment in an interconnection \nagreement to limit a generating facility’s output to match the hourly \nforecast of an electrically proximate large load or large co-located load; \nand/or (ii) a generating facility with necessary control technologies \nand/or protection systems, which may include a special protection \nscheme, that ensure that the injection does not exceed the limit in the \nexisting or new interconnection agreement."},{"page":11,"startToken":2674,"endToken":2965,"text":"11 \n \n \n \n6. \nAdditional Content of FPA Section 205 Filing Related to Resource \nAdequacy \n \nIn order to address the Commission’s concerns related to resource adequacy, as explained \nin ISO-NE’s Informational Filing submitted in this docket on July 20, 2026,12 ISO-NE \nanticipates including statements in the FPA Section 205 filing that will put Eligible Customers \non notice that large loads must “bring your own new generation” and that large loads will be \nexcluded from the capacity market’s Installed Capacity Requirement.  Following a robust \nstakeholder process and resolution of operational issues, ISO-NE anticipates filing the detailed \nsupporting rules implementing these concepts in 2027.  \nB. \nTiming for Filing of FPA Section 205 Filing \nIf granted, the 90-day abeyance period would end on November 15, 2026, which is a \nSunday.  Accordingly, ISO-NE and the PTOs will submit the FPA Section 205 filing on Monday, \nNovember 16, 2026.  This filing date will allow ISO-NE and the PTOs to present a proposed \ndesign and Tariff provisions, as needed, to the New England Power Pool (“NEPOOL”) \nTransmission Committee13 and Markets Committee.  ISO-NE and the PTOs anticipate \npresenting their proposals at the following regularly scheduled NEPOOL committee meetings: \nCOMMITTEE/MONTH \nAUGUST \nSEPTEMBER \nOCTOBER \nNOVEMBER \nMarkets Committee \n11-12 \n9-10 \n6-7 \n4-5 \nTransmission Committee \n18-19  \n15 \n14 \n \nParticipants Committee \n \n \n \n12 \n \nAdditional Transmission Committee and/or Markets Committee meetings may be \nscheduled, if needed, in the months of September, October, or November 2026.  The PTO-AC \n \n12 Available at https://www.iso-ne.com/static-\nassets/documents/100037/ferc_informational_rpt_resource_adequacy_large_loads.pdf \n \n13 On July 16, 2026, ISO-NE made an initial presentation to the Transmission Committee in which it described this \nrequest for abeyance and the stakeholder process for the Section 205 filing to be submitted on November 16, 2026."},{"page":12,"startToken":2965,"endToken":3201,"text":"12 \n \n \n \nplans to take action on Tariff revisions in October 2026.  As shown in the table, the NEPOOL \nParticipants Committee would vote on the Section 205 proposal at its November 12, 2026 \nmeeting. \nIII. \nREQUEST FOR SHORTENED COMMENT PERIOD AND EXPEDITED \nTREATMENT \n \nISO-NE and the PTO-AC respectfully request that the Commission establish a \nshortened comment period of five days for this motion and act on this motion within 10 days \nof its submission (i.e., by August 13, 2026).14    Good cause exists to grant these requests.  A \nshortened comment period and expedited Commission action on this motion will provide ISO-\nNE and the PTOs certainty regarding the need to submit a response to the Show Cause Order \non August 17, 2026, which in turn will facilitate a more efficient allocation of resources between \nISO-NE, the PTOs, and stakeholders.  Without expedited Commission action, ISO-NE and the \nPTOs will be required to spend critical time and resources preparing a response to the Show \nCause Order that may be unnecessary, as opposed to further advancing the FPA Section 205 \nproposal discussed herein.  \n \n \n \n14 The Commission directed that requests for a full or partial abeyance be submitted prior to the deadline to respond \nto the Show Cause Order, specifically within 45 days of the issuance of the Show Cause Order, to allow time for the \nCommission to act on the abeyance request.  See Show Cause Order at P 36."},{"page":13,"startToken":3201,"endToken":3292,"text":"13 \n \n \n \nIV. \nCONCLUSION \nFor the foregoing reasons, ISO-NE and the PTO-AC respectfully request that the \nCommission grant their motion to hold the instant Section 206 proceeding in abeyance for 90 \ndays.   \n \nRespectfully submitted, \n \n/s/ Margoth Caley \nMargoth Caley, Esq. \nChief Regulatory Compliance Counsel \nISO New England Inc. \nOne Sullivan Road  \nHolyoke, MA 01040-2841 \nTel: (413) 387-2408 \nmcaley@iso-ne.com \n \n \n \n \n \n \n \n/s/ Mary Grover \nMary E. Grover, Esq. \nChair, PTO AC Legal Working Group  \nc/o Eversource Energy \n247 Station Drive, SE100 \nWestwood, MA 02090 \nTel: (781) 441-8696 \nE-mail: mary.grover@eversource.com"},{"page":14,"startToken":3292,"endToken":3353,"text":"14 \n \n \n \nCERTIFICATE OF SERVICE \nI hereby certify that I have this day served the foregoing document upon each person \ndesignated on the official service list compiled by the Secretary in this proceeding. \n \nDated at Holyoke, Massachusetts this 3rd day of August 2026. \n \n \n \n/s/ Julie Horgan \nJulie Horgan \neTariff Coordinator \nISO New England Inc. \nOne Sullivan Road \nHolyoke, MA 01040 \n(413) 540-4683"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":3,"endAt":9,"startToken":0,"endToken":617},{"p":3,"at":9,"title":"I. BACKGROUND","method":"printed heading","endPage":3,"endAt":13,"startToken":617,"endToken":618},{"p":3,"at":13,"title":"BACKGROUND","method":"printed heading","endPage":5,"endAt":11,"startToken":618,"endToken":1237},{"p":5,"at":11,"title":"II. REQUEST FOR ABEYANCE OF ALL ASPECTS OF THE SHOW CAUSE","method":"printed heading","endPage":5,"endAt":91,"startToken":1237,"endToken":1250},{"p":5,"at":91,"title":"A. Content of Future FPA Section 205 Filing","method":"printed heading","endPage":11,"endAt":702,"startToken":1250,"endToken":2775},{"p":11,"at":702,"title":"B. Timing for Filing of FPA Section 205 Filing","method":"printed heading","endPage":12,"endAt":202,"startToken":2775,"endToken":2998},{"p":12,"at":202,"title":"III. REQUEST FOR SHORTENED COMMENT PERIOD AND EXPEDITED","method":"printed heading","endPage":13,"endAt":10,"startToken":2998,"endToken":3202},{"p":13,"at":10,"title":"IV. CONCLUSION","method":"printed heading","endPage":13,"endAt":15,"startToken":3202,"endToken":3203},{"p":13,"at":15,"title":"CONCLUSION","method":"printed heading","endPage":14,"endAt":10,"startToken":3203,"endToken":3293},{"p":14,"at":10,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":14,"endAt":404,"startToken":3293,"endToken":3353}]}