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LEGAL BEAT OFFSHORE WIND point in between, is an at least hourly calculation involving ue? ed natural gas gasi? cation facility, and the region’s two a control-to-control room check. The 1,200 MW value does remaining nuclear plants, Seabrook in New Hampshire and not appear in the 1991 agreement, but is observed by the three Millstone in Connecticut, can all operate above 1,200 MW grid operators as the lower limit under which system operators and up to their limits as long as system generation dispatch will redispatch generation to maintain. The 1991 agreement and resulting power ? ows on the New York and PJM systems was ? led with the Federal Energy Regulatory Commission allow. The 2016 planning process limit only applies prospec- (FERC) in Docket No. ER07-231-000 on an “informational” tively to new resources – HVDC lines interconnecting off- basis in November of 2006 because it did not contain “rates, shore wind included. terms, or conditions” under the Federal Power Act (FPA). As more focus was placed on the 1,200 MW limit by policy

FERC rejected that informational characterization in its Janu- makers and developers, in March of 2023, ISO-NE sent a letter ary 12, 2007 order, and accepted the ? ling under Section 205 to the Joint ISO/RTO Planning Committee requesting a coor- of the FPA. The 1991 agreement can be found on the FERC dinated study among ISO-NE, NYISO, and PJM to determine website using the citation 111 FERC ¶ 61,017. if the 1,200 MW limit could be raised. ISO-NE described the

In practical terms, this means that, since 1991 until the pres- 1,200 MW design limit as a means to address the issue as ent day, resources like the Phase II HVDC line from Canada one of “daily unpredictability” regarding the size of the single to the United States that can operate at up to 2,000 MW, contingency limit under the 1991 agreement. In its letter, ISO- the Boston-based Mystic Generating Station units 8 and 9, NE notes the size of larger resources could be “constrained which collectively are a 1,600 MW single source loss due to by an otherwise optimal interconnection design,” and asks the a common natural gas fuel source issue from an adjacent liq- Joint ISO/RTO Planning Committee to assess the source limit

The introduction of the 1991 Procedure to Protect for the Loss of Phase II Imports 18 November/December 2023

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