TCS Project Companies Answer ISO-NE’s Emergency Motion by requesting a 10-day comment period for its waiver request and a 20-day answer period for the Complaint

ISO-NE opposes TCS Project Companies request for a shortened comment period; requests full 30-day comment period to respond to Complaint

TCS Project Companies* request file (i) a Complaint alleging ISO-NE’s assignment of upgrade costs to interconnection customers in the first Transitional Clusty Study violates the FERC’s cost
causation principles and the Tariff and (ii) a request for limited waiver of identified Schedule 22 provisions so as to preserve TCS Project Companies’ interconnection queue position while the Complaint is addressed by the FERC

*TCS Project Companies are: Moraga Storage, LLC and River Mill Storage, LLC (the “Segue Companies”); Hecate Energy Medway Energy Center LLC; and Brough Storage, LLC and Partridge Storage, LLC (the “CleanCapital Companies”).