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New England's Asset Condition Reviewer: What the $25 Million Threshold Will and Will Not Catch

On 16 October 2026 the Federal Energy Regulatory Commission accepted tariff and Transmission Operating Agreement revisions that make ISO New England the region's Asset Condition Reviewer (197 FERC ¶ 61,042, Docket Nos. ER26-3533-000 and ER26-3534-000). The role starts on 1 January 2027. ISO-NE has already acted as an interim reviewer on some projects this year.

Asset condition projects are the part of transmission spending that replaces or rebuilds ageing, deteriorating or obsolete equipment. In New England they are planned by the participating transmission owners and, until now, have had less independent scrutiny than reliability or public-policy projects. The new function gives ISO-NE a formal role in looking at the need for them, the alternatives considered and the cost-effectiveness of the chosen solution.

The filing had unanimous support at NEPOOL, from the six states, the transmission owners and consumer advocates. FERC accepted it without modification. Commissioners Rosner and Chang wrote concurrences urging other regions to adopt something similar.

The money involved

The scale is the reason for the change. According to an ISO-NE presentation in June, transmission owners expect to add about $5 billion of asset condition projects by 2034, including about $1.3 billion in 2027.

By our arithmetic, that means the first year of the reviewer's formal operation carries 26% of the eight-year total (1.3 ÷ 5.0). If the remaining $3.7 billion were spread evenly over 2028–2034, it would average about $0.53 billion a year, well under half of 2027's level. Either the profile front-loads spending into the year review begins, or later years will be filled in as owners add projects to the list. ISO-NE updates its Asset Condition List three times a year, so the next updates will show which.

Method: the $5 billion and $1.3 billion figures are from ISO-NE's June 2026 presentation as reported by Utility Dive. We divided the residual evenly across seven years for comparison only; actual spending is lumpy.

What gets reviewed

Not every project is covered. The order sets out the thresholds:

  • Individual projects where the owner forecasts Pool Transmission Facilities costs of at least $25 million on a single line or at a single station or substation, over five years or less.
  • Programmes (groups of similar projects addressing a common condition) forecast at $100 million or more.
  • Smaller programmes that meet all three of these tests: they touch 15% or more of the owner's PTF lines or substations, include more than $5 million of work on any single line or station, and cost at least $25 million over five years or less.

Projects below those levels are outside the reviewer's scope. The $25 million single-facility trigger is high relative to many substation refurbishments, and a series of $20 million projects at different stations would not trip it unless they were grouped into a programme. The programme definition is meant to prevent that kind of splitting, since it covers projects of a "similar type, class, vintage, design, manufacturer, or failure mode." How strictly ISO-NE applies that language will decide how much of the $5 billion is actually reviewed.

For a sense of scale: the roughly $360 million Eversource project in New Hampshire that consumer advocates challenged at FERC in May is 14 times the single-project threshold. The $82.4 million project near Boston that Eversource paused last month, after an ISO-NE consultant found it had not shown near-term need, is about 3.3 times the threshold. Both would be in scope. Plenty of smaller work would not.

What the reviewer cannot do

The order is explicit about limits that the states and owners agreed to:

  1. The role is advisory. ISO-NE will not decide whether a project proceeds.
  2. ISO-NE will not be a petitioning party in any local, state or federal siting or regulatory proceeding on an asset condition project.
  3. ISO-NE will not make a legal finding or issue an opinion on whether a project's costs are prudent.
  4. The transmission owners indemnify ISO-NE for liability arising from the role, except for gross negligence or wilful misconduct.

So the reviewer produces information, published through the Planning Advisory Committee. Whether that information changes outcomes depends on state regulators and on FERC rate proceedings, where prudence is actually decided. The order also leaves existing processes in place, including significant adverse impact reviews and the cost allocation reviews that decide whether costs are "localised" to one state's customers rather than paid regionally.

The access provision may matter more than the advisory label. The revised TOA gives ISO-NE equipment-level information from the owners, including asset strategy guides, inventories, inspections and risk assessments. Until now, much of the evidence for need has sat inside the utilities.

The disagreement the order does not settle

Eversource's response to the consultant's finding on the Boston project frames the core dispute. It argued that requiring evidence of physical deterioration or impending failure for equipment that cannot be effectively inspected sets a threshold a utility cannot meet "without experiencing the very failure the replacement program is intended to prevent." It said it was troubled by an apparent position that projects should proceed only on "specific, concrete evidence" of deterioration.

That is a real issue for assets such as underground pipe-type cables, where condition is hard to observe. The order defines the reviewer's objective as ensuring the owner "has sufficiently demonstrated the technical need," and does not set an evidentiary standard. The Planning Advisory Committee reviews in 2027 will establish one in practice.

New Hampshire's consumer advocate, Donald Kreis, told Utility Dive he was "cautiously optimistic" and noted that Eversource withdrew one of the two projects ISO-NE reviewed on an interim basis.

Other regions

PJM calls the equivalent spending "supplemental" or local projects. Ohio's consumer advocate told FERC in August that Ohio utilities had planned more than $4.3 billion of local transmission since it filed its complaint, with inadequate oversight. Commissioner Chang's concurrence asked ISO-NE and other regions to consider extending expert review beyond asset condition projects to other types of local transmission. The complaint was still pending when the advocate wrote in August.

ISO-NE is setting up a new group in its System Planning Department for the work and will report to its board's System Planning and Reliability Committee. The first annual report on asset condition matters is the document to watch.

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