RENEW Northeast submitted comments to the Federal Energy Regulatory Commission in support of ISO New England’s filing requesting approval of Interconnection Process Improvements that will reduce the time needed to complete the Interconnection Studies for wind and inverter-based generators and should improve curtailment and performance issues in system operations for these types of generators.

Since 2012, RENEW, its members, and the ISO have engaged in a series of workshops to share information about wind turbine technology and the New England transmission system, and to exchange ideas for reforms to the ISO’s interconnection process.

While RENEW is supportive of the Interconnection Process Improvements, it also agreed with the ISO and NEPOOL that deeper reforms are needed than those proposed in the filing if the queue backlog and other concerns raised in the stakeholder process are to be resolved. A group study process, infrastructure identification and cost allocation are topics to be considered in the second phase to address the significant queue backlog that exists. RENEW looks forward to working with ISO New England through the stakeholder process this year to develop solutions to meet these additional needs.

The current serial study process, which identifies the least-cost solution for each studied project, may not cumulatively result in the least-cost or most beneficial set of upgrades for a series of interconnections planned in the same area in a common timeframe. In addition, the serial process is lumpy, with a first-mover often paying the cost for building infrastructure that will benefit later developers without any reimbursement. As a result, the system encourages developers to seek solutions or construction designs that do not provide expandability or headroom, resulting in cumulative costs that are unnecessarily high and/or cumulative designs that result in a less operable system.

In addition to interconnection process changes, significant transmission infrastructure is needed to integrate new renewable energy generators in northern New England. In response to demand driven by state renewable energy and greenhouse gas reduction laws, developers are proposing thousands of megawatts of wind energy facilities largely in western and northern Maine due to their excellent wind resources. In the historic three-state Request for Proposals (RFP) now pending, project developers offered large-scale projects including eight bids for Power Purchase Agreements (PPAs) for new wind projects and six bids for various combinations of wind, hydro, solar, energy storage, and transmission. Those projects- including proposals for new transmission lines in their bids- reflected this need for additional infrastructure to tap the region’s clean energy resources.

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