EL26-72-000 · 2026-08-03 · ISO New England Inc.PTO AC

ISO-NE requests more time to answer the June 18 show cause order

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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 
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  
Docket No.
 
EL26-72-000 
 
 
JOINT MOTION OF ISO NEW ENGLAND INC. AND THE PARTICIPATING 
TRANSMISSION OWNERS ADMINISTRATIVE COMMITTEE ON BEHALF OF 
THE PARTICIPATING TRANSMISSION OWNERS TO HOLD PROCEEDING IN 
ABEYANCE AND REQUEST FOR SHORTENED COMMENT PERIOD  
AND EXPEDITED TREATMENT 
 
Pursuant to Rule 212 of the Rules of Practice and Procedure1 of the Federal Energy 
Regulatory Commission (“Commission” or “FERC”),2 and the Commission’s Order Instituting 
Proceeding Under Section 206 of the Federal Power Act3 (“FPA”) issued on June 18, 2026 in the 
above-captioned proceeding, ISO New England Inc. (“ISO-NE”) and the Participating 
Transmission Owners Administrative Committee (“PTO-AC”) on behalf of the Participating 
 
1 18 C.F.R. §§ 385.209, 385.213 (2026). 
 
2 Capitalized terms used but not defined in this filing are intended to have the meaning given to such terms in the 
ISO New England Transmission, Markets and Services Tariff (“Tariff”). 
 
3 ISO New England Inc., 195 FERC ¶ 61,215 (2026) (“Show Cause Order”).

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Transmission Owners (“PTOs”)4 submit this motion to request that the Commission hold the 
Section 206 proceeding initiated by the Show Cause Order in abeyance for 90 days, starting 
on the Show Cause Order’s compliance deadline, August 17, 2026.  Since the issuance of the 
Show Cause Order, ISO-NE and the PTOs have been working diligently to consider the design 
of Tariff updates that will address the Commission’s concerns and facilitate the integration of 
large loads and co-located loads in a manner consistent with the needs of the New England 
region.  The abeyance will allow ISO-NE and the PTOs to work through the stakeholder 
process to develop and refine a FPA Section 205 filing that will address the issues raised in 
the Show Cause Order.  ISO-NE and the PTOs will submit the FPA Section 205 filing to the 
Commission on or before November 16, 2026. 
Because the response to the Show Cause Order is due on August 17, 2026, ISO-NE 
and the PTO-AC respectfully request that the Commission shorten the comment period for this 
motion to five days and grant expedited treatment to rule on this motion within 10 days of its 
submission (i.e., by August 13, 2026). 
 
 
 
4 The PTOs include: Town of Braintree Electric Light Department; Central Maine Power Company; Chicopee 
Municipal Lighting Plant; Connecticut Municipal Electric Energy Cooperative; Connecticut Transmission 
Municipal Electric Energy Cooperative; Eversource Energy Service Company on behalf of The Connecticut Light 
and Power Company, Public Service Company of New Hampshire and NSTAR Electric Company; Fitchburg Gas 
and Electric Light Company; Green Mountain Power Corporation; The City of Holyoke Gas and Electric 
Department; Town of Hudson Light and Power Department; Maine Electric Power Company; Massachusetts 
Municipal Wholesale Electric Company; Town of Middleborough Gas & Electric Department; The Narragansett 
Electric Company d/b/a Rhode Island Energy; New England Power Company d/b/a National Grid; New Hampshire 
Electric Cooperative, Inc.; New Hampshire Transmission, LLC; Town of Norwood Municipal Light Department; 
Town of Reading Municipal Light Department; Shrewsbury Electric and Cable Operations; Town of Stowe Electric 
Department; Taunton Municipal Lighting Plant; The United Illuminating Company; Unitil Energy Systems, Inc.; 
Vermont Electric Cooperative, Inc.; Vermont Electric Power Company, Inc.; Vermont Public Power Supply 
Authority; Vermont Transco LLC; Versant Power; and Town of Wallingford, CT, Department of Public Utilities, 
Electric Division.

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I. 
BACKGROUND 
The Show Cause Order is one of six show cause orders that the Commission 
simultaneously issued to all six Regional Transmission Organizations/Independent System 
Operators to address large and co-located load issues.  In the Show Cause Order, the Commission 
directed ISO-NE and the PTOs, within 60 days of the order, to either:  
(1) show cause as to why the Tariff remains just and reasonable and not unduly 
discriminatory or preferential without provisions addressing:   
 
(a) the application process, study procedures, and ongoing operational requirements 
that apply to Eligible Customers seeking transmission service on behalf of large 
loads;  
 
(b) additional transparency concerning the network upgrade costs to provide 
transmission service to Eligible Customers on behalf of large loads, a pro forma 
cost recovery agreement between ISO-NE, the relevant transmission owner and 
Eligible Customer taking transmission service on behalf of the large load to 
mitigate the risk of cost shifting among transmission customers, and a mechanism 
to ensure such payments are appropriately credited towards transmission owners’ 
transmission revenue requirements consistent with the Commission’s cost-of-
service regulations;  
 
(c) the rates, terms, and conditions of service that apply to co-location arrangements;  
 
(d) transmission services that reflect Eligible Customers taking transmission service 
on behalf of co-located loads, load with behind the meter generation, and flexible 
large loads that are willing and able to limit their use of the transmission system 
under certain conditions; and 
 
(e) the rates, terms, and conditions of service applicable to interconnection 
customers serving electrically proximate large load or co-located load; or  
 
(2) explain what changes to the Tariff would remedy the identified concerns if the 
Commission were to determine that the Tariff has in fact become unjust and unreasonable 
or unduly discriminatory or preferential and, therefore, proceeds to establish a 
replacement Tariff.5 
 
 
The Commission also recognized that ISO-NE and/or the PTOs (to the extent the matters 
addressed in the Show Cause Order implicate aspects of the Tariff over which the PTOs have 
 
5 Show Cause Order at P 32.

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the filing rights) may elect to address some or all of the issues discussed in the Show Cause 
Order by proposing revisions to the Tariff pursuant to their applicable FPA Section 205 filing 
rights.6  The Commission strongly encouraged this.7  The Commission stated that it would 
consider requests to hold, for up to 90 days, all or certain aspects of the Show Cause Order 
proceeding in abeyance, including the deadline to respond to the Show Cause Order to provide 
ISO-NE and the PTOs time to work through the stakeholder processes to develop FPA Section 
205 filings to revise the Tariff to address the issues raised in the Show Cause Order.8 
Although ISO-NE and the PTOs have been actively discussing New England-specific 
Tariff revisions that will address the concerns that the Commission identified in the Show Cause 
Order, additional time is needed to develop those proposals and present them for stakeholder 
review.  ISO-NE and the PTOs respectfully request a 90-day abeyance of all aspects of the Show 
Cause Order proceeding for the purpose indicated, i.e., sufficient time to work through the New 
England stakeholder process to develop and refine a FPA Section 205 filing to revise the Tariff 
to address all the issues raised in the Show Cause Order.  This request is consistent with the long-
standing history of stakeholder engagement in New England.  As required in the Show Cause 
Order, Section II of this request for abeyance includes: (1) a robust description of the content of 
a future filing under FPA Section 205; and (2) a reasoned and specific explanation of when the 
FPA Section 205 filing is expected to be made. 
 
 
 
6 Id. at P 35. 
 
7 Id.  
 
8 Id. at P 36.

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II. 
REQUEST FOR ABEYANCE OF ALL ASPECTS OF THE SHOW CAUSE 
ORDER PROCEEDING 
 
A. 
Content of Future FPA Section 205 Filing 
 
As detailed below, ISO-NE’s/the PTOs’ future FPA Section 205 filing will address all 
of the Commission’s concerns in each of the five categories of reform of the Show Cause Order 
(i.e., efficient study processes, cost transparency, co-location rules, flexible load service, and 
generation studies).9  The details of the future FPA Section 205 filing will be subject to 
development and input received in the stakeholder process.  Additionally, the filing will contain 
answers to the briefing questions that the Commission posed in the Show Cause Order.10 
1. 
Efficient Study Processes 
To address this category of reform, the FPA Section 205 filing will address the need for 
a transmission service application process and study procedures, including the evaluation of 
alternative transmission technologies.11  The filing will encompass:  
a. 
Definition of large load.  This definition will be based on the 
characteristics of ISO-NE’s transmission system and will include load 
size and an interconnection voltage threshold. 
b. 
Application process that applies to Eligible Customers seeking 
transmission service on behalf of large loads.  This process will address 
 
9 Pursuant to the Show Cause Order, ISO-NE’s/the PTOs’ future FPA Section 205 filing will address requests for 
unbundled retail transmission service requests by end-use large load customers (as allowed by state law or voluntary 
utility rules) as well as by Eligible Customers on behalf of large loads.  Show Cause Order at note 119. 
 
10 See Show Cause Order at P 124, stating that any filings or Tariff changes submitted in response to the Show 
Cause Order should address the Commission’s briefing questions. 
 
11 As part of the stakeholder process, ISO-NE and the PTOs will identify the respective roles of ISO-NE and the 
PTOs at each stage of the application process and study procedures.

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accepting Eligible Customers’ applications for transmission service on 
behalf of large loads, requiring a non-refundable application fee, and 
sufficient readiness requirements to deter duplicative or speculative 
requests for transmission service, as well as information and data 
requirements that Eligible Customers must submit to ISO-NE and/or the 
PTOs regarding the characteristics of the large load on behalf of which 
the Eligible Customer is taking transmission service (including 
disclosure to ISO-NE of substantially similar pending transmission 
service requests on behalf of the same large load customer).  The FPA 
Section 205 filing will also address the specific financial assurance, 
readiness, and information requirements applicable to  entities serving 
as Eligible Customers (including the large load itself, where permitted). 
c. 
Study procedures that apply to Eligible Customers seeking transmission 
service on behalf of large loads.  Consistent with the Show Cause Order, 
the study procedures will address (1) evaluating whether a large load may 
be interconnected to the transmission system and served by the Eligible 
Customer, and (2) determining whether network upgrades are necessary 
to provide transmission service.  The studies will  contemplate 
evaluation of the transmission system’s ability to withstand risks 
observed from analyzed large load behavior created by the large load at 
the point of interconnection.  Furthermore, the study process will 
consider the unique operational characteristics of large loads that are 
willing and able to limit their energy withdrawals under certain

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conditions, which may thereby lessen or potentially avoid the need for 
certain network upgrades.  Proposed rules will also consider requiring 
accurate models, including Electromagnetic Transient (“EMT”) studies, 
as well as  the evaluation of alternative transmission technologies as 
potential solutions to accommodate an Eligible Customer’s request for 
transmission service on behalf of a large load (with the results of such 
evaluation included in the report to the Eligible Customer with a 
demonstration of why they are not feasible or would not result in lower 
costs or a faster timeline for accommodating the transmission service 
request). 
d. 
Ongoing operational requirements that apply to Eligible Customers 
seeking transmission service on behalf of large loads.  These 
requirements will address the need for hourly forecasts, telemetry data 
and other data to ensure sufficient visibility, as well as maintaining 
communication channels.  The requirements will contemplate the 
installation of equipment to enable ISO-NE to monitor large loads for 
impacts of, for example, fast-ramping load that may impact the 
transmission system too quickly to be captured by conventional data 
acquisition systems (e.g., phasor measurement units or similar 
equipment).  The requirements will also address the need for ISO-NE to 
remotely disconnect a large load to maintain reliability of the 
transmission system.  In addition, the rules will contemplate ramp-rate or 
ride-through requirements, as well as requirements for control

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technologies and/or protection systems that may be necessary to limit 
withdrawals from the transmission system as appropriate. 
e. 
Pro forma transmission service agreement.  This agreement will 
memorialize the definition of large load, application process, study 
process, and operational requirements. 
2. 
Cost Transparency 
To address this category of reform, ISO-NE and the PTOs will develop rules that prevent 
cost shifting and require transparency into transmission costs.  These will include: 
a. 
Rules for transparency concerning the network upgrade costs to provide 
transmission service to Eligible Customers on behalf of large loads.  The 
rules will address requiring robust, accurate, and systematic provision of 
data on the ISO-NE website in a single location and in an easily accessible 
format that is searchable and allows users to filter the data, regarding the 
need for network upgrades to provide transmission service to Eligible 
Customers on behalf of large loads, as well as the costs of those network 
upgrades.  Specifically, the rules will establish the posting of information 
such as: (i) aggregate amounts of proposed large load additions in ISO-
NE's footprint, including the aggregate amounts in each load zone; (ii) 
the planned network upgrades needed to provide transmission service to 
Eligible Customers on behalf of large loads, identified by type of 
equipment and network upgrades (e.g.,  new substation, reconductoring, 
a new high-voltage transmission line) for each transmission service 
request; and (iii) cost estimates for those network upgrades. The amount

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of information that ISO-NE and the PTOs can share may be limited by 
data confidentiality.  Any such concerns will be mitigated to the extent 
possible. 
b. 
Pro forma cost recovery agreement between ISO-NE, the relevant 
transmission owner, and Eligible Customer taking transmission service 
on behalf of the large load.  This pro forma agreement will be consistent 
with the Show Cause Order and the Commission’s cost-causation and 
beneficiary-pays principles. 
3. 
Co-location Rules 
As part of their FPA Section 205 filing, ISO-NE and the PTOs will submit rules that 
accommodate co-location agreements between load and behind-the-meter generation 
(“BTMG”). The rules will ensure that BTMG, as defined in part by a MW threshold, cannot be 
netted with load behind the same point of interconnection for the purpose of determining 
Regional Network Service charges for co-located loads configured in a BTMG arrangement.  
ISO-NE plans to develop transmission services available to Eligible Customers on behalf of co-
located loads that recognize the ability of co-located loads to limit withdrawal from the 
transmission system under certain conditions, as discussed below.  
4. 
Flexible Load Service 
To address this category of reform, ISO-NE and the PTOs will develop rules for flexible 
transmission services, such as: (i) interim non-firm network transmission service (i.e., 
transmission service to be provided while network upgrades are being constructed); (ii) 
permanent firm contract demand transmission service (i.e., transmission service up to a specified 
MW quantity – the contract level – on a firm basis); and (iii) permanent non-firm contract

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demand transmission service (i.e., transmission service up to a specified MW quantity – the 
contract level – on a non-firm basis).   
5. 
Generation Studies 
To address this category of reform, ISO-NE and the PTOs will develop a process to study 
generating facilities serving electrically proximate and co-located large loads.  This will include: 
a. 
Definition of electrically proximate large load, which will be 
appropriately tailored to New England’s transmission system.  
b. 
Generator 
interconnection 
study 
process 
and/or 
generator 
interconnection service.  The rules will address allowing an 
interconnection customer to seek the generation interconnection 
service(s) that reflects the operational dynamics of serving either an 
electrically proximate large load, or a co-located load that has a high peak 
load.  In the development of these rules, the following will be considered: 
(i) an interconnection customer’s commitment in an interconnection 
agreement to limit a generating facility’s output to match the hourly 
forecast of an electrically proximate large load or large co-located load; 
and/or (ii) a generating facility with necessary control technologies 
and/or protection systems, which may include a special protection 
scheme, that ensure that the injection does not exceed the limit in the 
existing or new interconnection agreement.

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6. 
Additional Content of FPA Section 205 Filing Related to Resource 
Adequacy 
 
In order to address the Commission’s concerns related to resource adequacy, as explained 
in ISO-NE’s Informational Filing submitted in this docket on July 20, 2026,12 ISO-NE 
anticipates including statements in the FPA Section 205 filing that will put Eligible Customers 
on notice that large loads must “bring your own new generation” and that large loads will be 
excluded from the capacity market’s Installed Capacity Requirement.  Following a robust 
stakeholder process and resolution of operational issues, ISO-NE anticipates filing the detailed 
supporting rules implementing these concepts in 2027.  
B. 
Timing for Filing of FPA Section 205 Filing 
If granted, the 90-day abeyance period would end on November 15, 2026, which is a 
Sunday.  Accordingly, ISO-NE and the PTOs will submit the FPA Section 205 filing on Monday, 
November 16, 2026.  This filing date 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 Committee13 and Markets Committee.  ISO-NE and the PTOs anticipate 
presenting their proposals at the following regularly scheduled NEPOOL committee meetings: 
COMMITTEE/MONTH 
AUGUST 
SEPTEMBER 
OCTOBER 
NOVEMBER 
Markets Committee 
11-12 
9-10 
6-7 
4-5 
Transmission Committee 
18-19  
15 
14 
 
Participants Committee 
 
 
 
12 
 
Additional Transmission Committee and/or Markets Committee meetings may be 
scheduled, if needed, in the months of September, October, or November 2026.  The PTO-AC 
 
12 Available at https://www.iso-ne.com/static-
assets/documents/100037/ferc_informational_rpt_resource_adequacy_large_loads.pdf 
 
13 On July 16, 2026, ISO-NE made an initial presentation to the Transmission Committee in which it described this 
request for abeyance and the stakeholder process for the Section 205 filing to be submitted on November 16, 2026.

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plans to take action on Tariff revisions in October 2026.  As shown in the table, the NEPOOL 
Participants Committee would vote on the Section 205 proposal at its November 12, 2026 
meeting. 
III. 
REQUEST FOR SHORTENED COMMENT PERIOD AND EXPEDITED 
TREATMENT 
 
ISO-NE and the PTO-AC respectfully request that the Commission establish a 
shortened comment period of five days for this motion and act on this motion within 10 days 
of its submission (i.e., by August 13, 2026).14    Good cause exists to grant these requests.  A 
shortened comment period and expedited Commission action on this motion will provide ISO-
NE and the PTOs certainty regarding the need to submit a response to the Show Cause Order 
on August 17, 2026, which in turn will facilitate a more efficient allocation of resources between 
ISO-NE, the PTOs, and stakeholders.  Without expedited Commission action, ISO-NE and the 
PTOs will be required to spend critical time and resources preparing a response to the Show 
Cause Order that may be unnecessary, as opposed to further advancing the FPA Section 205 
proposal discussed herein.  
 
 
 
14 The Commission directed that requests for a full or partial abeyance be submitted prior to the deadline to respond 
to the Show Cause Order, specifically within 45 days of the issuance of the Show Cause Order, to allow time for the 
Commission to act on the abeyance request.  See Show Cause Order at P 36.

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IV. 
CONCLUSION 
For the foregoing reasons, ISO-NE and the PTO-AC respectfully request that the 
Commission grant their motion to hold the instant Section 206 proceeding in abeyance for 90 
days.   
 
Respectfully submitted, 
 
/s/ Margoth Caley 
Margoth Caley, Esq. 
Chief Regulatory Compliance Counsel 
ISO New England Inc. 
One Sullivan Road  
Holyoke, MA 01040-2841 
Tel: (413) 387-2408 
mcaley@iso-ne.com 
 
 
 
 
 
 
 
/s/ Mary Grover 
Mary E. Grover, Esq. 
Chair, PTO AC Legal Working Group  
c/o Eversource Energy 
247 Station Drive, SE100 
Westwood, MA 02090 
Tel: (781) 441-8696 
E-mail: mary.grover@eversource.com

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CERTIFICATE OF SERVICE 
I hereby certify that I have this day served the foregoing document upon each person 
designated on the official service list compiled by the Secretary in this proceeding. 
 
Dated at Holyoke, Massachusetts this 3rd day of August 2026. 
 
 
 
/s/ Julie Horgan 
Julie Horgan 
eTariff Coordinator 
ISO New England Inc. 
One Sullivan Road 
Holyoke, MA 01040 
(413) 540-4683