Docket No. ER26-2577-000
Today’s order accepts NYISO’s revised interconnection study rules. I write separately to commend NYISO for reforming its generator interconnection process to more accurately reflect actual grid conditions, avoid unneeded transmission upgrades, and get new electrons on the grid faster. While NYISO’s process has unique regional attributes, I call on other grid operators to consider similar solutions.
Currently, NYISO’s interconnection studies do not fully consider demand for electricity within zones (i.e., geographic regions within the ISO) when assessing a generator’s ability to deliver electricity. With today’s reforms, NYISO will now study generation and demand within a zone before assessing whether transmission upgrades are needed to make supply deliverable across zones.
NYISO’s initial cluster analysis conducted under its old rules identified 24 system deliverability upgrades, including new and rebuilt transmission lines, terminal upgrades, and series reactors, but as a result of this package of reforms, only 3 of these upgrades will ultimately be required, which will save over $1 billion in upgrade costs.[1] It is well documented that high upgrade costs are a significant barrier to building new generation,[2] so I continue to encourage other regions to consider whether similar changes would increase the efficiency and speed with which new generation can connect to the grid.
For these reasons, I respectfully concur.
[1] New York Indep. Sys. Operator, Inc., Transition Cluster Study 2024 Preliminary Deliverability Study, at 48-49 (Mar. 26, 2026), https://www.nyiso.com/documents/
20142/57510547/03a_C24_PrelimiaryDIS_Presentation_TPAS_clean.pdf/b1b31558-21ce-ced6-7da5-a28daf0c7c65.
[2] See, e.g., RWE Clean Energy, LLC v. PJM Interconnection, L.L.C., 194 FERC ¶ 61,212 (2026) (Rosner, Comm’r, Chang, Comm’r, concurring).