Comments to NYISO’s Interconnection Issues Task Force (IITF) regarding the completion of Small Generation Facilities Studies. These are part of our continuing interconnection reform efforts. Submitted by ACE NY, March 11, 2024.

Comments to NYISO’s Interconnection Issues Task Force (IITF) providing extensive stakeholder feedback and requesting additional clarification on items from the NYISO’s presentations and draft tariff proposals. These are part of the ongoing interconnection reform efforts. Submitted by ACE NY, March 7, 2024.

Comments to NYISO’s Interconnection Issues Task Force (IITF) regarding Commercial Operation Date (COD) extension rules. These were in response to the NYISO’s request for feedback from stakeholders. Submitted by ACE NY, February 27, 2024.

Comments to NYISO’s Interconnection Issues Task Force (IITF) regarding the termination of ongoing Small and Large Generation studies. These are part of our continuing interconnection reform efforts. Submitted by ACE NY, February 26, 2024.

Comments to NYISO’s Interconnection Issues Task Force (IITF) and the ongoing interconnection reform efforts. Submitted by ACE NY, January 31, 2024.

Comments to NYISO’s Interconnection Issues Task Force (IITF) and the 2023 interconnection reform efforts. Submitted by ACE NY, December 21, 2023.

Comments to NYISO’s Interconnection Issues Task Force (IITF) and the 2023 interconnection reform efforts. Submitted by ACE NY, November 29, 2023.

Comments to NYISO’s Interconnection Issues Task Force (IITF) and the 2023 interconnection reform efforts. Submitted by ACE NY, October 13, 2023.

Comments to NYISO as part of the 2023 Interconnection Reform Project. Submitted by ACE NY, July 21, 2023.

Comments to NYISO as part of the 2023 Interconnection Reform Project. Submitted by ACE NY, June 20, 2023.

Comments of NYOWA on NYISO staff evaluation report of projects submitted by developers in response to Long Island Public Policy Transmission Need. Submitted by ACE NY and NYOWA to NYISO Business Investments Committee, May 22, 2023.

Letter requesting clarification on how the Areas of Concern Transmission Projects will be treated during the NYISO Class Year 2023 (CY23) Studies for the purpose of cost allocation and security deposits for renewable generation developers. Submitted by ACE NY, May 3, 2023.

Comments in regard to an Unexecuted Engineering, Procurement, and Construction Agreement filed by the NYISO, et al. for the Ticonderoga Solar Project. Submitted to FERC in Docket No. ER23-1573-000 by ACE NY, April 26, 2023.

Comments to the NYISO regarding the queue window approach as part of the Interconnection Queue Reform Project. Submitted by ACE NY, April 24, 2023.

Comments supporting Homer Solar Energy Center, LLC’s request for tariff waiver and expedited action relevant to the NYISO’s interconnection process. Submitted to FERC in Docket No. ER23-1575-000 by ACE NY, April 21, 2023.

Comments to NYISO regarding the queue window approach as part of the 2023 Interconnection Reform Project. Submitted by ACE NY, April 10, 2023.

Comments to the NYISO as part of the 2023 Interconnection Reform Project. Submitted by ACE NY, March 10, 2023.

Proposal to the NYISO to study the mutually exclusive alternatives of a single large SRIS study cluster approach versus the use of SRIS mini clusters. Submitted by ACE NY, February 6, 2023.

Comments to NYISO regarding the Interconnection Queue Reform Project. Requesting consideration of potential proposals from several NY developers and ACE NY Members. Submitted by ACE NY, February 6, 2023.

Comments supporting a waiver request of a New York developer to waive the need to complete an SRIS study prior to entering the 2023 NYISO Class Year Study.

NB: ACE NY filed 17 of these in January. This is one example of the 17 comments filed.

Reply Comments on Notice of Proposed Rulemaking Regarding Improvements to Generator Interconnection Procedures and Improvements. Submitted to FERC in Docket No. RM22-14-000 by ACE NY, December 14, 2022.

Comments supporting CPNY’s request for a waiver for certain requirements in NYISO Open Access Transmission Tariff, facilitating the Clean Path Project becoming part of the NYISO 2023 Class Year. Submitted to FERC in Docket No. ER23-253-000 by ACE NY and NRDC, November 18, 2022.

Comments on the Need for Public Policy Transmission Need Declarations. Submitted to the NYISO by ACE NY, October 31, 2022.

Comments on Notice of Proposed Rulemaking Regarding Improvements to Generator Interconnection Procedures and Agreements. Submitted to FERC in Docket No. RM22-14-000 by ACE NY, October 13, 2022.

Letter recommending changes to the NYISO interconnection process that do not require a tariff change. Submitted to the NYISO by ACE NY, August 23, 2022.

Comments on the Notice of Proposed Rulemaking titled Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection. Submitted to FERC in Docket No. RM21-17-000 by ACP, ACE NY, NYOWA, MAREC, and Clean Grid Alliance, August 17, 2022.

Comments of Clean Energy Advocates on a NYISO Filing Regarding Buyer’s Side Mitigation Reform and Capacity Accreditation. Submitted to FERC in Docket No. ER22-772-000 by Earthjustice, NY-BEST, NRDC, ACP, AEE, Sustainable FERC, ACE NY, and seven other parties, January 26, 2022.

Support Letter on NRDC Protest of NYISO Order 2222 Filing on Efficiency in The Capacity Market, submitted by ACE NY to FERC Docket No Er21-2460-000.

Preliminary Comments on NYISO Capacity Accreditation, submitted to the NYISO by ACE NY.

Comments on NY Transmission Owner’s Response to FERC Deficiency Letter, submitted by ACE NY, ACP, NY-BEST, ESA, and IPPNY to FERC Docket No El21-66-000.

Comments to NYISO Regarding BSM Consideration Questions, submitted by ACE NY, NRDC, and EJ to NYISO.

Answer to the NYISO Response About Excessive Administrative Fees for Co-Located Storage Resources, submitted by ACE NY, ACP, NY-BEST and ESA to FERC Docket No. ER21-1001-000.

Protest About Excessive Administration Fees for Co-Located Storage Resources, submitted by ACE NY, ESA, and American Clean Power Association to FERC Docket No. ER21-1001-000.

Protest of Cricket Valley Energy Center LLC & Empire Generating Company, LLC V. NYISO, submitted by Sustainable FERC Project, NRDC, Sierra Club, AWEA, ACE NY, and AEE to FERC Docket No. EL21-7-000.

Comments on Proposed Policy Statement on Carbon Pricing, submitted by AWEA and ACE NY to FERC Docket No.AD20-14-000.

Comments on NYISO’s BSM Proposal, submitted by AWEA, ACE NY, NRDC, Sustainable FERC Project, and Solar Council to FERC Docket No. ER16-1404-002.

Interconnection: ACE NY Proposes New Regulatory Milestone for NYISO Interconnection Process, submitted by ACE NY to the NYISO.

Comments on NYISO’s Proposal for Renewable Exemptions Cap for Buyer Side Mitigation, submitted comments by ACE NY to the NYISO.

Diverse Transmission Stakeholders File Joint Reply Comments with FERC on Modernizing and Expanding the Electricity Grid, submitted joint reply comments of ACE NY and 17 other organizations to FERC Docket No. PL19-3-000.

Comments Regarding NYISO Proposals for Redesign of the Class Year Study Process, submitted by ACE NY to the NYISO.

Comments in Support of Complaint Field by PSC and NYSERDA Against NYISO regarding Energy Storage, submitted by AEE, AEMA, ACE NY, CPA, NRDA, NY-BEST, and Clean Energy Parties to FERC Docket No. EL19-86-000.

Comments on NYISO’s Grid in Transition Draft Whitepaper, submitted by NRDC, Sustainable FERC, AEA, ACE NY, and AWEA to the NYISO.

Filing on Order 845, submitted by AWEA, ACE NY, and Solar Council to FERC Docket No. ER19-1949.

Comments on NYISO’s Grid in Transition Whitepaper Outline , submitted by NRDC, ACE NY, AWEA, AEA, and NY-BEST to the NYISO.