2024 FERC and NYISO Filings

ACE NY actively participates in committee and working groups at the NYISO that pertain to clean energy issues. Currently, the topics in which ACE NY is active are: the interconnection queue process, carbon pricing, capacity market issue, and transmission planning. ACE NY submits formal and informal written comments to the NYISO and makes filings to the Federal Energy Regulatory Commission in support of clean energy issues.


  • Transmission Needs

    Comments on the Need for Public Policy Transmission Need Declarations. Submitted to the NYISO by ACE NY, Nov. 4, 2024.

  • Interconnection Improvements

    Comments to FERC on the NYISO’s Order No. 2023 Compliance Filing regarding the need for an efficient and timely interconnection process. Submitted by ACE NY, June 12, 2024.

  • Interconnection Queue Reform

    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.

  • Interconnection Queue Reform

    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.

  • Interconnection Queue Reform

    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.

  • Interconnection Queue Reform

    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.

  • Interconnection Queue Reform

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

2023 FERC and NYISO Filings


  • Interconnection Queue Reform

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

  • Interconnection Queue Reform

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

  • Interconnection Queue Reform

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

  • Interconnection Queue Reform

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

  • Interconnection Queue Reform

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

  • Transmission

    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.

  • AOC Transmission Upgrades

    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.

  • Interconnection Costs

    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.

  • Interconnection Queue Reform

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

  • Interconnection Delays

    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.

  • Interconnection Queue Reform

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

  • Interconnection Queue Reform

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

  • Interconnection Queue Reform

    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.

  • Interconnection Queue Reform

    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.

  • Interconnection Delays

    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.

2022 FERC and NYISO Filings


  • Interconnection Improvements

    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.

  • Transmission Planning

    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.

  • Transmission Needs

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

  • Interconnection Improvements

    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.

  • Interconnection Delays

    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.

  • Transmission Planning

    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.

  • Capacity Market Rules

    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.

2021 FERC and NYISO Filings


  • September 7, 2021

    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.

  • August 23, 2021

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

  • July 28, 2021

    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.

  • June 30, 2021

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

  • March 19, 2021

    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.

  • February 19, 2021

    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.

2020 FERC and NYISO Filings


  • November 18, 2020

    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.

  • November 15, 2020

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

  • August 28, 2020

    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.

  • June 30, 2020

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

  • March 17, 2020

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

2019 FERC and NYISO Filings


  • August 26, 2019

    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.

  • August 19, 2019

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

  • August 18, 2019

    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.

  • July 1, 2019

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

  • June 26, 2019

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

  • April 30, 2019

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