When FERC issued Order 2023 requiring an overhaul to interconnection processes, clean energy advocates lauded it as a crucial first step in addressing overdue reforms. Inefficient interconnection processes for integrating new clean energy resources onto the grid present arguably the biggest current bottleneck in the energy transition, threatening both grid reliability, affordability, and states’ abilities to meet their climate and energy policy requirements. While a lot of work to fully rectify interconnection in New England will remain even after Order 2023 reforms are implemented, compliance with this Order marks a crucial milestone towards a more efficient, equitable, and expedient interconnection process. 

Once FERC handed down the ruling in July 2023, each Regional Transmission Organization (RTO) and public utilities outside of RTO regions set out to assess how they would comply with FERC’s requirements. New England’s RTO, ISO-NE, arguably had more work to do to reach compliance on the 1500-page Order relative to any other RTO when it began outlining its compliance approach in September 2023 (ISO-NE still operated a first-in, first-out serial queue, and scored a D+ on a recent interconnection scorecard report). The compliance proceeding in New England proved to be a rushed but robust stakeholder process, with discussion of a range of critical issues, diverse stakeholder engagement, and a remarkable turnaround from ISO-NE in an act of compromise and collaboration.  

To ensure ISO-NE’s proposed compliance actually improved interconnection outcomes for clean energy resources, Advanced Energy United worked closely with RENEW Northeast, a regional clean energy trade association, to build a coalition of developers (with huge credit to New Leaf Energy) to scrutinize, issue spot, and offer alternative solutions. Throughout the proceeding, a number of concerns emerged at NEPOOL (New England Power Pool), the regional forum for energy industry stakeholders to engage with ISO-NE. In response, United, its members, RENEW Northeast, and other NEPOOL participants altogether submitted over 25 alternative proposals on items improving aspects of ISO-NE’s compliance proposal. United presented four times at monthly committee meetings on the record, raising awareness about key issues and advocating for solutions. Themes from these proposals included shortening excessively long timelines, addressing the lack of optionality in interconnection service, and providing interconnection customers with flexibility to mitigate or avoid prohibitively expensive network upgrade costs. While United and its coalition convinced ISO-NE to adopt many of these proposals along the way, many key issues were left unresolved as the compliance deadline approached, and ISO-NE began to assert the remaining stakeholder proposals were not feasible or needed.  

With the window to rectify ISO-NE’s compliance proposal rapidly narrowing, United concentrated its efforts by strengthening its coalition, conducting outreach, and elevating five of the highest priority proposals for NEPOOL stakeholders and ISO-NE to focus on.  As a result of these efforts, ISO-NE ultimately adopted four of the five priority proposals in part or in full. With ISO-NE’s modified compliance proposal now including most aspects of the coalition’s priority proposals, United recommended NEPOOL participants vote in support of ISO’s modified proposal, delivering ISO-NE the support it needed to pass the final vote. On March 7, 2024, NEPOOL voted unanimously in favor of ISO-NE's compliance proposal, which was filed at FERC in May. On June 4th, United, joined by the American Clean Power Association, Natural Resources Defense Council, and Solar Energy Industries Association, filed comments at FERC, reiterating overall support for ISO-NE’s proposal, while highlighting areas for further improvements.

This proceeding illustrated that not only can clean energy advocates unite to have their voices heard and concerns addressed, but that ISO-NE has a commitment to engage with stakeholders and earn their support. While there is a lot left to do on interconnection beyond Order 2023 reforms, this compliance effort exemplified how a functional stakeholder process can and should work and showcases a collaborative approach for enacting other important reforms in the region to ensure a reliable, equitable, and affordable clean energy future. 

Advanced Energy United commissioned Daymark Energy Advisors to identify the critical actions–both immediate and longer-term–that New England must take to unlock the interconnection process. Released in October 2023, the report found that for New England to achieve the lowest cost energy transition that maintains reliability, ISO-NE must work with stakeholders to improve the interconnection process by (1) maximizing the opportunity for reforms in its FERC Order 2023 compliance filing and (2) addressing forward-looking reforms necessary for efficient interconnection. Read the full report here.