ISO-NE’s Order 2023 Compliance Decision is In – Here’s What Renewable Developers Need to Know 

FERC’s decision on ISO New England’s (ISO-NE) Order 2023 compliance filing is official! With an effective date of August 12, 2024, the interconnection landscape in the region is shifting and developers need to be paying attention. A few highlights that might be important for your projects: 

Confirmed or approved: 

• Transition Cluster Study approved: FERC approved Transitional Capacity Network Resource (CNR) Group Study and completing late-stage System Impact Studies (SIS) 
• ISO-NE plans to set a late-stage SIS completion deadline of April 4, 2025. Queue projects that have completed SIS as of April 4, 2025, will be able to participate in the CNR Group Study and Transitional Serial Interconnection Facility Study.  
• Timelines: 270-day base timeline, 90-day restudy period, and streamlined window notice provisions.  
• Financial commitments clarified: $500k readiness deposits required, $250k flat study deposit required. Readiness deposit requirements for the transitional cluster were also approved.  
• CNRIS milestones changed: will shift from FCM process to the interconnection process. 
• Flexibility added: projects can now downgrade from CNRIS to NRIS automatically to manage upgrade risks. Additionally, MW reduction will be allowed during restudy (if no shared upgrades involved). 
• Battery projects approval: FERC approved ISO-NE’s battery charging study assumptions. It will be important for developers to become familiar with the “shoulder load scenario.” 

Rejected: 

• No automatic withdrawal without a cure period for deficiencies. This includes entry requirements for the transitional cluster. 
• No POI changes during the cluster process. 
• ISO-NE must improve clarity on site control regulatory limitations and proportional cost allocation of substation upgrades. 

Important Next Steps 

• ISO- NE plans to file the compliance to this decision in two steps. The first step will be focused on limited changes required to move transitional study activities by one year. The second step will involve addressing the remaining compliance issues raised by FERC in its decision. 
• ISO- NE plans to tender transitional study agreements on August 11, 2025, and start the transitional studies 60 days later on October 10, 2025. 
• Projects eligible for the transitional cluster study will need to satisfy entry requirements by October 10 –, this includes models and PSCAD benchmarking to the latest testing protocols in PP5-6.  

For renewable developers, these updates offer more structure, more cost certainty, but also more accountability. 

Contact us below if you're navigating ISO-NE interconnection or preparing for the upcoming transitional cluster. Our team is actively supporting clients through the changes.