{"document":{"slug":"filing-20260807-5196","title":"Answer of the New England States Committee on Electricity in Response to Joint Motion for Abeyance filed by ISO New England, Inc. et al","issued":"2026-08-07","accession":"20260807-5196","docket":"EL26-72-000","group":"ISO-NE filings","filer":"New England States Committee on Electricity","kind":"answer","file":"sources/originals/20260807-5196_01.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260807-5196","sha256":"934d6705f3d9a8a61386b45c34e3f5625c56d7bb225269bca07dbf42085a6c2c","pages":6,"tokens":1142,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":211,"text":"- 1 - \n \nUNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n \n \nISO New England Inc.  \n \n \n \n) \nCentral Maine Power Company \n \n \n) \n \nThe Connecticut Light and Power Company  \n) \nFitchburg Gas and Electric Light Company  \n) \nGreen Mountain Power Corporation  \n \n) \nMaine Electric Power Company \n \n \n) \nThe Narragansett Electric Company  \n \n) \n \nDocket No. EL26-72 \nNew England Power Company \n \n \n) \nNew Hampshire Transmission, LLC  \n \n) \nNSTAR Electric Company \n \n \n \n) \nPublic Service Company of New Hampshire  \n) \nThe United Illuminating Company \n \n \n) \nUnitil Energy Systems, Inc.  \n \n \n) \nVermont Electric Power Company, Inc. \n \n) \nVermont Transco LLC \n \n \n \n) \nVersant Power \n \n \n \n \n) \n \n \nANSWER IN RESPONSE OF THE NEW ENGLAND STATES COMMITTEE ON  \nELECTRICITY TO THE MOTION OF ISO NEW ENGLAND, INC.  \nAND THE PARTICIPATING TRANSMISSION OWNERS  \nADMINISTRATIVE COMMITTEE TO HOLD  \nPROCEEDING IN ABEYANCE \n \nPursuant to the Federal Energy Regulatory Commission’s (the “Commission”) Notice \nEstablishing Answer Period, the New England States Committee on Electricity (“NESCOE”)1 \nhereby submits this answer in response to the Joint Motion of ISO New England, Inc. (“ISO-\nNE”) and the Participating Transmission Owners Administrative Committee (“PTOAC”) on \nBehalf of the Participating Transmission Owners to Hold Proceeding in Abeyance (the “Joint \n \n1  On June 23, 2026, NESCOE filed a doc-less motion to intervene in this proceeding.  \nNESCOE is the Regional State Committee for New England, representing the collective \npositions of the six New England states in regional electricity matters."},{"page":2,"startToken":211,"endToken":523,"text":"- 2 - \n \nMotion”).  For the reasons described below, NESCOE supports the Joint Motion and respectfully \nrequests that the Commission grant it.   \nI. \nDESCRIPTION OF COMMENTER \nNESCOE is the Regional State Committee (“RSC”) for New England.  It is governed by \na board of managers appointed by the Governors of Connecticut, Maine, Massachusetts, New \nHampshire, Rhode Island, and Vermont and is funded through a regional tariff that ISO-NE \nadministers.2  NESCOE’s mission is to represent the interests of the citizens of the New England \nregion by advancing policies that will provide electricity at the lowest possible price over the \nlong term, consistent with maintaining reliable service and environmental quality.3  This answer \nin response represents the collective view of the six New England states.      \nII. \nBACKGROUND \nOn June 18, 2026, the Commission issued an order instituting the above-captioned \nproceeding pursuant to Section 206 of the Federal Power Act (the “Show Cause Order”).4  The \nShow Cause Order directed ISO-NE and the Participating Transmission Owners to show cause \nthat ISO-NE’s existing Transmission, Markets and Services Tariff (the “Tariff”) remains just and \nreasonable and not unduly discriminatory or preferential without provisions addressing certain \ndelineated issues related to large and co-located loads.5  Although the Commission directed ISO-\nNE and the PTOs to respond within 60 days of the Show Cause Order, the Commission also \n \n2 ISO New England Inc., 121 FERC ¶ 61,105 (2007).   \n3 See Sept. 8, 2006 NESCOE Term Sheet that was filed for information as Exhibit A to the \nMemorandum of Understanding among ISO-NE, the New England Power Pool (“NEPOOL”), \nand NESCOE (the “NESCOE MOU”).  Informational Filing of the New England States \nCommittee on Electricity, Docket No. ER07-1324-000 (filed Nov. 21, 2007).  Pursuant to the \nNESCOE MOU, the Term Sheet is the binding obligation of ISO-NE, NEPOOL, and NESCOE.   \n4 ISO New England Inc., 195 FERC ¶ 61,215 (2026). \n5 Id. at P. 32."},{"page":3,"startToken":523,"endToken":798,"text":"- 3 - \n \nstated that it would consider requests to hold all or certain aspects of the Show Cause Order in \nabeyance for up to 90 days for the responding parties to work through the stakeholder process to \ndevelop FPA Section 205 filings to revise the Tariff.6   \nOn August 3, 2026, ISO-NE and the PTOAC filed the Joint Motion.  The Joint Motion \nseeks a 90-day abeyance of the Show Cause Order.7  The Joint Motion anticipates that the parties \nwill develop a Section 205 filing that will “address all of the Commission’s concerns in each of \nthe five categories of reform of the Show Cause Order….”8  As described in the Joint Motion, \nthe abeyance will allow ISO-NE and the PTOs to present a proposed design and Tariff \nprovisions, as needed, to the New England Power Pool (“NEPOOL”) Transmission Committee \nand Markets Committee.9  The Joint Motion further represents that the NEPOOL Participants \nCommittee would vote on the Section 205 proposal at its November 12, 2026 meeting and that \nthe parties would make their Section 205 filing with the Commission on November 16, 2026.10   \nIII. \nANSWER IN RESPONSE \nNESCOE supports ISO-NE and the PTOAC’s request for an abeyance to allow for them \nto develop a Section 205 filing through New England’s stakeholder process.  As the Joint Motion \nnotes, “the request is consistent with the long-standing history of stakeholder engagement in \nNew England.”11  The large load and co-location issues raised by the Show Cause Order are \n \n6 Id. at PP. 32, 36.   \n7 Joint Motion, at 2.   \n8 Id., at 5.   \n9 Id., at 11.   \n10 Id., at 11–12.   \n11 Joint Motion, at 4."},{"page":4,"startToken":798,"endToken":984,"text":"- 4 - \n \nsignificant and complex, and ISO-NE and the PTOAC’s expected Section 205 filing would likely \nbe made much stronger if developed through New England’s robust stakeholder process.   \nThe issues raised in the Show Cause Order are important to NESCOE, and NESCOE \nplans to fully participate in the regional stakeholder process that the Joint Motion contemplates.  \nIndeed, NESCOE has offered its preliminary input on ISO-NE and the PTOAC’s response to the \nShow Cause Order, identifying certain foundational principles against which it will assess any \nproposed Section 205 filing.12  In brief, NESCOE believes that any new regulatory construct \nshould seek to mitigate the ratepayer cost impacts of new large load projects, preserve traditional \nstate authority to regulate large and co-located loads, prioritize reliability, and promote \ntransparency.13  NESCOE looks forward to participating in the stakeholder process that will be \nmade possible by the Joint Motion’s requested abeyance. \n \n \n12 NESCOE, Preliminary Input on ISO-NE’s Response to the Large and Co-Located Loads Show \nCause Order (July 30, 2026), available at https://nescoe.com/wp-\ncontent/uploads/2026/08/NESCOE-Large-Load-Advanced-Feedback-7-30-26.pdf (last checked \nAug. 7, 2026).   \n13 Id. at 2."},{"page":5,"startToken":984,"endToken":1045,"text":"- 5 - \n \n \nIV. \nCONCLUSION \nTherefore, for the reasons stated herein, NESCOE respectfully requests that the \nCommission grant the Joint Motion.     \n \n \n \n \n \nRespectfully Submitted, \n/s/ Nathan Forster \nNathan Forster, General Counsel \nShannon Beale, Assistant General Counsel \nNew England States Committee on Electricity \nP.O. Box 322 \nOsterville, MA 02655 \nTel: (617) 431-0462 \nEmail: nathanforster@nescoe.com \nEmail: shannonbeale@nescoe.com \nDate: August 7, 2026"},{"page":6,"startToken":1045,"endToken":1142,"text":"- 6 - \n \nCERTIFICATE OF SERVICE \nIn accordance with Rule 2010 of the Commission’s Rules of Practice and Procedure, I \nhereby certify that I have this day served by electronic mail a copy of the foregoing document \nupon each person designated on the official service list compiled by the Secretary in this \nproceeding.  \nDated at Osterville, Massachusetts this 7th day of August, 2026.   \n \n/s/ Nathan Forster \nNathan Forster, General Counsel \nShannon Beale, Assistant General Counsel \nNew England States Committee on Electricity \nP.O. Box 322 \nOsterville, MA 02655 \nTel: (617) 431-0462 \nEmail: nathanforster@nescoe.com \nEmail: shannonbeale@nescoe.com"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":2,"endAt":146,"startToken":0,"endToken":231},{"p":2,"at":146,"title":"I. DESCRIPTION OF COMMENTER","method":"PDF bookmark","endPage":2,"endAt":814,"startToken":231,"endToken":332},{"p":2,"at":814,"title":"II. BACKGROUND","method":"printed heading","endPage":2,"endAt":819,"startToken":332,"endToken":333},{"p":2,"at":819,"title":"BACKGROUND","method":"printed heading","endPage":3,"endAt":1087,"startToken":333,"endToken":707},{"p":3,"at":1087,"title":"III. ANSWER IN RESPONSE","method":"printed heading","endPage":5,"endAt":11,"startToken":707,"endToken":985},{"p":5,"at":11,"title":"IV. CONCLUSION","method":"printed heading","endPage":5,"endAt":16,"startToken":985,"endToken":986},{"p":5,"at":16,"title":"CONCLUSION","method":"printed heading","endPage":6,"endAt":9,"startToken":986,"endToken":1046},{"p":6,"at":9,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":6,"endAt":650,"startToken":1046,"endToken":1142}]}