Acadia Center Comments in Response to NWA NOI
The comments made the following recommendations:
- The statutory definition of NWAs should be amended to make explicitly clear that any rightsizing of a wired solution that meets the system need, including alternate routing, deferring the upgrade, and any combination thereof with a GET or other alternate infrastructure, technology or application, is included. This amendment would forestall argumentation over the exact slate of technical solutions over which the NWA coordinator has purview.
- The exclusion for review of small Asset Condition Projects should be removed.
- The utility’s Integrated Grid Plan should specifically coordinate with and incorporate as possible planned NWA reviews.
- The Commission should continue to advocate, per statute, for least-cost solutions to bulk power system needs, and for nontransmission alternatives to be considered comparably to transmission.
- The Commission should lay out in an Order the appropriate flow of information from the utility to the NWA coordinator, rather than relying on a MOU negotiated by the OPA and CMP.
- Pool transmission facilities projects identified by ISO-NE should be exempted from the NWA coordinator process.