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