July 30, 2021

ESA Continues Rebuttal of NYISO Transmission Owners’ Proposal for Self-Funding Upgrades

ESA submitted comments yesterday with the American Clean Power Association (“ACP”), Alliance For Clean Energy-New York (“ACE-NY”), Independent Power Producers Of New York (“IPPNY”), and New York Battery and Energy Storage Technology Consortium (“NY-BEST”), collectively “NY Interconnection Customers,” in response to the New York transmission owners’ (TOs) responses to FERC’s deficiency letter, in response the TO’s Tariff filing requesting that they have the right to finance network upgrades required by interconnection customers.

In these comments, the NY Interconnection Customers request that FERC deny the TOs’ complaint and reject their tariff filing. Specifically, we argue that the NYTOs’ proposal will pose a significant threat of violating the “no undue discrimination” standard of the Federal Power Act, since TO funding would reduce incentives to control costs and could dramatically increase the cost for independent entities to develop new generation in New York. The filing also rebuts assertions by NYTOs that customer-financed upgrades present uncompensated risks and that network upgrades are a significant portion of TOs’ business.

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