June 26, 2019
ESA Files Complaint on ISO-NE Approach to Surplus Interconnection Service in Order 845 Compliance
ESA filed a complaint today at FERC regarding ISO-NE’s proposed approach to surplus interconnection service in its proposed compliance with Order 845 & 845-A. Specifically, ESA argues that ISO-NE’s proposal to require surplus interconnection service remain continuously available represents a violation of FERC’s clear directive that such surplus interconnection service vary with the intermittency of co-located generation. ESA also argues that ISO-NE’s proposed implementation does not set up a process outside of the generation interconnection queue, per Order 845’s requirements.