Docket No. ER25-866-000
I concur only because the states in New England unanimously agreed for their consumers to bear the costs of this project using a cost allocation formula to which they all agreed.[1] These costs will include the costs of the Abandoned Plant Incentive.
This project is a public policy project, not a reliability or an economic project, even if there are some ancillary reliability and congestion benefits as there always are with any project. This project is designed to support state public policies in New England mandating renewable power.[2] Accordingly, I concur only because the states in the region have explicitly agreed to cost allocation.
As we move into the Order No. 1920-A compliance process, I note that this project represents an example of states in a multi-state ISO unanimously agreeing on cost allocation for a public policy-driven project. This is an excellent example of the opportunity and authority granted to states in that rule to agree to jointly share costs of such projects.
For these reasons, I respectfully concur.
[1] Term Sheet at 2 (“[Transmission Owners] will seek regional cost allocation as endorsed by the New England states and will propose to spread the allocated revenue requirements across all regional network load in New England on a load ratio basis.”).
[2] Transmittal at 8 (“[T]he need for [the Project] is driven in part by the States’ desire to fulfill their respective renewable energy/decarbonization policies and targets.”).