October 11, 2019 VIA ELECTRONIC FILING Honorable Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, DC 20426 Re: ISO New England Inc. and New England Power Pool, Docket No. ER20-___-000; Transmission Planning Improvements Dear Secretary Bose: Pursuant to Section 205 of the Federal Power Act, 1 ISO New England Inc. (the “ISO”) joined by the New England Power Pool (“NEPOOL”) Participants Committee2 (together, the “Filing Parties”), hereby jointly3 submit proposed tariff revisions to enhance the competitive transmission solicitation process and make other improvements to the ISO’s transmission planning process (collectively, “Transmission Planning Improvements”). The Filing Parties are joined by the Participating Transmission Owners Administrative Committee (the “PTO AC”) on behalf of the Participating Transmission Owners (the “PTOs”).4 The PTO AC joins in the revisions to Localized Costs in Section III.B.3 of this transmittal letter. The Tariff changes 1 16 U.S.C. § 824d (2006 and Supp. II 2009). 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 Inc. Transmission, Markets and Services Tariff (the “Tariff”). Section II of the Tariff is the Open Access Transmission Tariff (“OATT”). 3 Under New England's Regional Transmission Organization arrangements, except as noted below, the rights to make this filing of changes to the OATT under Section 205 of the Federal Power Act are the ISO's. NEPOOL, which pursuant to the Participants Agreement provides the sole market participant stakeholder process for advisory voting on ISO matters, supported the changes reflected in this filing and accordingly, joins in this Section 205 filing. 4 The rights under Section 205 of the FPA to modify terms, conditions and rates in the definition of Localized Costs and Schedules 12 and 12C of the OATT are held jointly by the PTOs and the ISO pursuant to Section 3.04 of the Transmission Operating Agreement (“TOA”). The PTO AC joins this filing on behalf of the PTOs in New England based on a vote of the PTO AC in support of Section III.B.3 of this filing. Honorable Kimberly D. Bose October 11, 2019 Page 2 proposed in this filing are supported by the testimony of Mr. Brent Oberlin (the “Oberlin Testimony”), 5 sponsored solely by the ISO. The ISO is preparing to issue the region’s first competitive transmission solicitation under Section 4.3 of Attachment K to the ISO’s OATT (“Transmission RFP”) in December 2019. The Transmission RFP will seek transmission solutions to the non-time sensitive needs6 identified by the ISO in its 2028 Boston Needs Assessment Update and the Boston 2028 Needs Assessment Addendum. In preparation for the Transmission RFP, the Filing Parties, and the PTO AC for the revisions involving Localized Costs, propose several Tariff changes to improve the competitive transmission process. These enhancements, which are more fully described in Mr. Oberlin’s testimony, consist of: • Revisions to Sections 4.3 and 4A Attachment K to the OATT; • Addition of new term Selected Qualified Transmission Project Sponsor (“Selected QTPS”) in Section I.2.2 of the Tariff; • Addition of new term Selected Qualified Transmission Project Sponsor Agreement (“SQTPSA”) in Section I.2.2 of the Tariff; • The addition of a new Attachment P to the OATT, a pro forma Selected Qualified Transmission Project Sponsor Agreement; • Revisions to the definition of Localized Costs in Section I.2.2 of the Tariff; • Revisions to Schedule 12C of the OATT to add language relating to the determinations of Localized Costs; • Addition of new Section III.12.6.4 of the Tariff to reflect the project in-service date in the SQTPSA to include the project in the Forward Capacity Market network model; and • Revisions to Section I.3.9 of the Tariff Additionally, the Filing Parties propose improvements to the transmission planning process in Sections 4.1 and 4.2 of Attachment K and are joined by the PTO AC with respect to revisions to Schedule 12 of the OATT to add language relating to the determinations of 5 The Oberlin Testimony is Attachment 3 to this transmittal letter and is sponsored solely by the ISO. 6 Time-sensitive needs are those that are needed within three years or less from the completion of the Needs Assessment. See Section 4.1(i) of Attachment K, “[w]here the ISO forecasts that a solution is needed to solve reliability criteria violations in three years or less from the completion of a Needs Assessment … the ISO will evaluate the adequacy of proposed regulated solutions by performing Solutions Studies, as described in Section 4.2 of this Attachment.” Accordingly, non-time sensitive needs are those that are needed in greater than three years from completion of the Needs Assessment. Honorable Kimberly D. Bose October 11, 2019 Page 3 Localized Costs for reconstruction/replacment projects. Finally, the Transmission Planning Improvements include various clean-up changes in Attachment K, as detailed below. Since several of the Transmission Planning Improvements will impact the Transmission RFP, the Filing Parties respectfully request that the Commission issue an order accepting the proposed Transmission Planning Improvements by no later than December 10, 2019, which is sixty days from the date of this filing. The ISO plans to issue the Transmission RFP shortly after receiving an order from the Commission in this proceeding. I. DESCRIPTION OF THE FILING PARTIES AND COMMUNICATIONS The ISO is the independent, private, non-profit entity that serves as the Regional Transmission Organization (“RTO”) for New England. The ISO operates the New England bulk power system and administers New England’s organized wholesale electricity market pursuant to the ISO New England Transmission, Markets and Services Tariff and the Transmission Operating Agreement with the New England Participating Transmission Owners. In its capacity as an RTO, the ISO has the responsibility to protect the short-term reliability of the New England Control Area and to plan and operate the system according to reliability standards established by the Northeast Power Coordinating Council, Inc. (“NPCC”) and the North American Electric Reliability Corporation (“NERC”). NEPOOL is a voluntary association organized in 1971 pursuant to the New England Power Pool Agreement, and it has grown to include more than 500 members. The participants include all of the electric utilities rendering or receiving service under the ISO Tariff, as well as independent power generators, marketers, load aggregators, brokers, consumer-owned utility systems, end users, developers, demand resource providers, and a merchant transmission provider. Pursuant to revised governance provisions accepted by the Federal Energy Regulatory Commission (“FERC” or “Commission”),7 the participants act through the NEPOOL Participants Committee. The Participants Committee is authorized by Section 6.1 of the Second Restated NEPOOL Agreement and Section 8.1.3(c) of the Participants Agreement to represent NEPOOL in proceedings before the Commission. Pursuant to Section 2.2 of the Participants Agreement, “NEPOOL provide[s] the sole Participant Processes for advisory voting on ISO matters and the selection of ISO Board members, except for input from state regulatory authorities and as otherwise may be provided in the Tariff, TOA and the Market Participant Services Agreement included in the Tariff.” The PTOs8 are Transmission Providers providing Local Service over Non-Pool Transmission Facilities on an open-access basis under Schedule 21 of the OATT. Pursuant to the 7 ISO New England Inc., 109 F.E.R.C. ¶ 61,147 (2004). 8 The PTOs include: Town of Braintree Electric Light Department; Central Maine Power Company; Maine Electric Power Company; Chicopee Municipal Lighting Plant; Connecticut Municipal Electric Energy Cooperative; Connecticut Transmission Municipal Electric Energy Cooperative; Emera Maine (Bangor Hydro Division); The City of Holyoke Gas and Electric Department; Green Mountain Power Corporation; Town of Hudson Light and Honorable Kimberly D. Bose October 11, 2019 Page 4 terms of the TOA among the PTOs and the ISO, the PTOs own, physically operate and maintain Transmission Facilities in New England and the ISO has Operating Authority (as defined in Schedule 3.02 of the TOA) over all of the Transmission Facilities of the PTOs, including those used to provide Local Service under Schedule 21. Section 3.04 of the TOA also grants the PTOs authority under Section 205 of the FPA to submit filings to the Commission in matters affecting the rates, terms and conditions of Local Service under Schedule 21 and rates and charges, including cost allocation, for Regional Transmission Service under the OATT. Correspondence and communications in this proceeding should be addressed to: To the ISO: To NEPOOL: Kevin Flynn, Esq.* Eric K. Runge* ISO New England Inc. Day Pitney LLP One Sullivan Road One International Place Holyoke, MA 01040-2841 Boston, MA 02110 Tel: (413) 535-4177 Tel.: (617) 345-4735 Fax: (413) 535-4379 Fax: (617) 345-4745 E-mail: [email protected] E-mail: [email protected] Robert Stein Jose Rotger NEPOOL Reliability Committee, Vice NEPOOL Transmission Committee, Vice Chair Chair c/o Signal Hill Consulting Group ESAI Power, LLC 110 Merchants Row, Suite 16 401 Edgewater Place, Suite 640 Rutland, VT 05701 Wakefield, MA 01880 Tel: (802) 236-4139 Tel: (781) 245-2036 Email: [email protected] E-mail: [email protected] Power Department; Massachusetts