On March 26, 2026, New York Independent System Operator (NYISO) staff presented the results of the agency’s Preliminary Deliverability Study for the 2024 Clustered Generation Interconnection Facilities Study (2024 Cluster Study) to stakeholders at a meeting of the NYISO’s Transmission Planning Advisory Subcommittee (TPAS). The 2024 Cluster Study currently has 92 projects, with Capacity Resource Interconnection Service (CRIS) requests totaling nearly 16 GW. The 2024 Cluster Study found the estimated cost of the transmission upgrades required to make all of this new generation capacity fully deliverable to be approximately $2.26 billion.
The 2024 Cluster Study also found that nearly one-half of these costs ($1.107 billion) were required to meet the deliverability requirements of 36 projects proposed for the Volney East and Total East Interfaces in the NYISO’s Rest of State (ROS) region,1 which covers all of New York except for the lower Hudson Valley, New York City, and Long Island. This level of required upgrades is notable given that transmission constraints in the ROS region have historically been less severe than in more densely populated downstate areas.
As the NYISO staff explained in their presentation, all but approximately $1.2 million of the $1.107 billion in system delivery upgrade costs will be eliminated in the event that the Federal Energy Regulatory Commission (FERC) accepts the proposed changes to the deliverability requirements under the NYISO’s Open Access Transmission Tariff that NYISO staff are currently developing in the stakeholder process. According to the NYISO’s most recent presentation on those tariff changes, the agency anticipates filing these tariff changes in April or May 2026, with a proposed effective date of 61 days following the filing date.
Barclay Damon’s Regulatory Practice Area attorneys will continue to monitor these NYISO proceedings and are available to assist clients that are participating in the stakeholder process.
If you have any questions regarding the content of this alert, please contact George Pond, partner, at gpond@barclaydamon.com; David Solimeno, associate, at dsolimeno@barclaydamon.com; or another member of the firm’s Regulatory Practice Area.
1The 36 projects in the ROS region that NYISO identified as necessitating these upgrades include: C24-032; C24-048; C24-052-001; C24-060; C24-064; C24-066; C24-072; C24-074; C24-079; C24-097; C24-108; C24-129; C24-135; C24-139; C24-175; C24-176; C24-182; C24-189; C24-190; C24-202; C24-207; C24-217; C24-224; C24-233; C24-253; C24-270; C24-300; C24-301; C24-304-004; C24-317; C24-318; C24-321; C24-326; C24-352; and C24-364.