On January 23, 2023, NEPGA filed Comments in support of RENEW Northeast’s complaint alleging that ISO-NE’s Tariff is unjust, unreasonable and unduly discriminatory in imposing on generators, for the duration of 20 to 40-year interconnection agreements, the operating and maintenance (O&M) costs of certain transmission infrastructure put in service to enable a new generator to interconnect to the grid (Docket No. EL23-16). RENEW asserts that ISO-NE’s assignment of these O&M costs to generators violates FERC’s cost causation/beneficiary pays policies, among other arguments. RENEW asks FERC to direct ISO-NE to amend the Tariff to remove its assignment of these costs to generators or, in the alternative, direct changes to provide greater transparency in the calculation of O&M costs and to provide estimates of those costs earlier in the interconnection process. In its Comments, NEPGA adds that the current assignment of these costs to generators interferes with competitive market outcomes which in turn creates resource and energy adequacy risks. Other parties filing in support of the complaint included CPV Towantic and CPV Renewable Power, the Northeast Clean Energy Council and Advanced Energy United (jointly), and Glenvale LLC (a renewable generation developer). ISO-NE earlier filed a motion to dismiss it as a party to the proceeding (on the basis that the Participating Transmission Owners hold the FPA Section 205 rights on the material parts of the filing) – alternatively ISO-NE takes no position on the complaint. Several parties filed in opposition to the complaint, including the New England Transmission Owners, New England Consumer-Owned Systems, the Massachusetts Attorney General, and the New England States Committee on Electricity.  RENEW asks for a Commission order on its complaint by April 14.