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New Hampshire Department of Energy (DOE) opened this proceeding in response to HB690 of 2025, which required it to investigate withdrawing from ISO New England (ISO-NE), “as well as other strategies to assure that New Hampshire ratepayers do not pay for public policy initiatives of other New England states, including environmental policies, in a manner that is unjust and unreasonable.” In addition to questions regarding the necessary steps to withdrawing and the costs, benefits, and effects of doing so, issues DOE will consider :

• how a regional wholesale market could balance differing state policy goals;
• alternative regulatory structures New Hampshire should consider; and
• whether the governance of ISO-NE is sufficiently accountable to the public and is adequate to assure it is operated in the public interest.

DOE retained London Economics International (LEI) to conduct analyses required to respond to questions posed by HB690. DOE was required to submit a report responding to those questions by 7/15/26.

On July 15, 2026 the results from London Economics International (LEI)  final report was delivered to the legislature.

LEI’s report, among other things:

(1) found that “New Hampshire could theoretically withdraw from ISO-NE, but there is significant practical uncertainty,” as: (i) the state “is not officially a part of ISO-NE”; and (ii) “ISO-NE’s governing documents do not lay out a guide to such a withdrawal”;

(2) “identified that a pragmatic and administratively coherent withdrawal structure would involve implementation of stand-alone functions within New Hampshire but also continue with trading with ISO-NE”;

(3) found that withdrawal would require that: (i) ISO-NE’s “three core services – regional grid planning, market administration, and grid operations” be “assigned to other (willing) parties”; and (ii) New Hampshire laws, as well as various agreements and business practices, would need to be modified to achieve compliance with Federal and regional planning mandates, as well as transmission system operating and reliability requirements”;

(4) found that “consumer costs would likely rise on a net basis because of the loss of efficiency,” and “ratepayers would also face transition costs and costs of the new administrative responsibilities,” estimating an increase of $147.53 million, or 13.6%, through 2030, but noting that this estimate does not include: (i) “any FERC-mandated exit fees; (ii) “legal expenses with implementing a withdrawal”; and (iii) “consideration of the ongoing operating budgets for the new roles and responsibilities that New Hampshire entities would need to take on from ISO-NE”;

(5) said that “Remaining in ISO-NE would preserve the benefits that New Hampshire already enjoys from accessing a competitive existing wholesale market, tight coordination on regional transmission planning, allocation of regional transmission revenue requirements (through RNS rates) across all loads in the six states, and centralized grid operations (taking on responsibility for all required FERC and NERC compliance),” but noted that continuation does not require inaction; and

(6) recommended that the state: (i) “develop a holistic supply and transmission strategy and to identify New Hampshire-specific priorities that can guide state engagement at ISO-NE, NEPOOL, and through NESCOE and FERC processes”; (ii) “consider developing a risk analysis tool that evaluates supply mix, transmission, distribution, retail services, and market participation on an integrated basis” to assist it “in identifying which concerns can be addressed through state authority, which require ISO-NE or FERC action, and which would require broader regional coordination.”