133 FERC ¶ 61,276
UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION
Before Commissioners: Jon Wellinghoff, Chairman;
Marc Spitzer, Philip D. Moeller,
John R. Norris, and Cheryl A. LaFleur.
New York Independent System Operator, Inc.Docket Nos. ER08-1281-005
ER08-1281-006
ORDER ON REHEARING AND COMPLIANCE
(Issued December 30, 2010)
1.Public Service Electric and Gas Company and its affiliates1 (PSEG) seek
rehearing of a Commission order issued in this proceeding on July 15, 2010.2 For the
reasons discussed below, we deny rehearing.
2. We also address the parties’ data responses submitted in response to the July 15,
2010 Order, i.e., the submissions made by International Transmission Company, d/b/a
ITC Transmission (ITC), PJM Interconnection, L.L.C. (PJM), the Independent Electricity
System Operator (IESO), New York Independent System Operator, Inc. (NYISO), and
the Midwest Independent Transmission System Operator, Inc. (Midwest ISO). These
data responses address the parties’ progress, to date, in developing long-term,
comprehensive solutions to the occurrence of Lake Erie loop flow.3 For the reasons
discussed below, we impose additional compliance obligations establishing a
re-prioritized implementation schedule that includes firm deadlines applicable to the
resolution of these issues.4
1 PSEG Power LLC and PSEG Energy Resources & Trade LLC.
2 New York Independent System Operator, Inc., 132 FERC ¶ 61,031 (2010) (July 15, 2010 Order).
3 As discussed more fully below, these loop flows were first addressed by the Commission in an order issued August 21, 2008. See New York Independent System Operator, Inc., 124 FERC ¶ 61,174 (2008) (August 21, 2008 Order).
4 In a companion order, we address cost allocation issues associated with ITC’s
(continued…)
Docket Nos. ER08-1281-005 and ER08-1281-006-2-
I.Background
3.This proceeding was instituted by the NYISO to address the market distortions and
increased congestion attributable to certain transactions that began to be submitted to the
NYISO in January 2008. The NYISO stated that these transactions, submitted for the
purpose of exporting power to PJM, were being scheduled by a small number of market
participants as circuitous flows around Lake Erie, utilizing a scheduled path that exited
the NYISO and then crossed through both the IESO and the Midwest ISO, before
ultimately sinking in PJM. The NYISO noted that, in fact, approximately eighty percent
of this scheduled power actually flowed directly across the NYISO/PJM border. The
NYISO added that, by utilizing the scheduled path at issue, these transactions benefited
from the relatively lower market prices at the NYISO’s western border, i.e., the
NYISO/IESO border, and thus avoided the relatively higher market price at the more
congested NYISO/PJM border.
4. To address these market distortions, the NYISO sought authorization to mandate a more direct routing option, i.e., it proposed to prohibit the scheduling of external
transactions over eight specified circuitous paths, until such time as adequate operational controls are implemented, including new PARs.
5. In the August 21, 2008 Order, the Commission accepted the NYISO’s proposed
temporary solutions.5 The Commission encouraged the parties to consider all appropriate
long-term solutions, including market reforms and the installation of PARs on the
Ontario-Michigan interconnection. In a related order issued July 16, 2009, the
Commission required the NYISO to submit a report addressing its proposed solutions.6
6. On January 12, 2010, the NYISO filed its report (NYISO Report). With respect to the Ontario-Michigan PARs, the report noted that ITC will not execute the operating
new phase angle regulators (PARs). See Midwest Transmission System Operator, Inc.,
133 FERC ¶ 61,275 (2010) (PARs Cost Allocation Order). PARs are electrical devices
that help control power flows through a particular component of the transmission
network.
5 August 21, 2008 Order, 124 FERC ¶ 61,174 at P 20. The NYISO’s initial filing was made pursuant to the “exigent circumstances” provisions of its tariff, subject to an automatic sunset date. In a later order, the Commission conditionally accepted the
NYISO’s proposal to make permanent the routing restriction. See New York Independent System Operator, Inc., 125 FERC ¶ 61,184, at P 20 (2008).
6 New York Independent System Operator, Inc., 128 FERC ¶ 61,049, at P 6 (2009) (July 16, 2009 Order).
Docket Nos. ER08-1281-005 and ER08-1281-006-3-
agreements required to make the PARs operational until such time as an agreement is in
place addressing the equitable allocation of all costs attributable to the PARs.7 With
respect to market initiatives, the NYISO Report recommended a series of four initiatives
to be developed and implemented by the NYISO and its neighboring regional
transmission organizations (RTO) and independent system operators (ISO). The NYISO
Report asserted that these four initiatives, taken as a whole, would help reduce uplift
costs associated with real-time event management and congestion management and
thereby lower total system operating costs. The timeline included in the NYISO Report
had implementation dates ranging from the spring of 2010 through the end of 2012.8 The
Commission addressed the NYISO Report in the July 15, 2010 Order.
7. In that order, the Commission found that intervenors had raised issues and
concerns related to the proposed initiatives which had not been fully addressed by the
NYISO Report. Accordingly, the Commission directed the NYISO and additional parties to answer a series of data requests. The Commission also noted that progress on the
proposals set forth in the NYISO Report should proceed expeditiously.
8. On December 28, 2010 in Docket No. ER11-2547-000, the NYISO filed tariff
sheets to revise its Market Administration and Control Area Services Tariff and its Open
Access Transmission Tariff. The proposed revisions address the enhanced interregional
transaction coordination initiative, one of the four initiatives described by the NYISO in
the NYISO Report. The NYISO states that the proposed revisions: (i) will allow for
more frequent transaction scheduling at the borders of the New York Control Area, and
(ii) will modify pricing rules for intra-hour scheduling. This filing is pending before the
Commission.
II.Request for Rehearing
9.PSEG seeks rehearing of the July 15, 2010 Order. PSEG takes issue with the
Commission’s interim finding that the planned initiatives outlined in the NYISO Report,
subject to the submission of additional information, “appear to represent a constructive,
workable framework for minimizing the occurrence of Lake Erie region loop flow.”9
7 Such a proposal was jointly made by the Midwest ISO and ITC on October 20,
2010 in Docket No. ER11-1844-000. See PARs Cost Allocation Order, 133 FERC
¶ 61,275.
8 NYISO Report at 19.
9 PSEG Request for Rehearing at 7 (citing July 15, 2010 Order, 132 FERC ¶ 61,031 at P 40).
Docket Nos. ER08-1281-005 and ER08-1281-006-4-
10. PSEG argues that this finding is in error because the July 15, 2010 Order failed to adequately address what PSEG asserts are three fundamental elements necessary to
manage the NYISO/PJM interface. Specifically, PSEG submits that the July 15, 2010
Order erred in: (i) failing to require NYISO and PJM to develop a robust and transparent regional planning process that includes cost allocation principles applicable to
transmission projects that provide regional benefits; (ii) failing to require that all
controllable lines that cross the NYISO/PJM seam have separate proxy bus calculations; and (iii) failing to require modifications to the PJM tariff to allow transmission lines
constructed by PJM transmission owners providing services under cost of service tariffs to be awarded capacity injection and withdrawal rights.
11.On September 3, 2010, an answer to PSEG’s request for rehearing was filed by the
NYISO transmission owners (NYTOs).10
A.Procedural Matters
12.Rule 713(d) of the Commission’s Rules of Practice and Procedure, 18 C.F.R.
§ 385.713(d) (2010), prohibits answers to requests for rehearing. Accordingly, NYTOs’
September 3, 1010 Answer is hereby rejected.
B.Commission Determination
13.PSEG asserts, as error, the July 15, 2010 Order’s failure to address certain
Lake Erie loop flow issues on the merits, including seams issues as between the NYISO
and PJM and that the Commission should direct the NYISO and PJM to adopt proposals
PSEG submitted in comments it filed in response to the NYISO’s compliance filing. We
deny rehearing. The July 15, 2010 Order addressed the NYISO’s compliance filing,
submitted by the NYISO in response to the July 16, 2009 Order and determined that
certain issues and concerns remained unaddressed.11 Therefore, the Commission set
forth a procedural path requiring the parties to supplement the record.12 Specifically, the
Commission identified unanswered questions based on the record as it then existed and
directed that these matters be addressed by the parties (by the NYISO, its neighboring
RTOs/ISOs, and ITC) within 30 days of the date of the Commission’s order. No
10 Central Hudson Gas & Electric Corporation, Consolidated Edison Company of New York, Inc., Long Island Power Authority, New York Power Authority, New York State Electric & Gas Corporation, Niagara Mohawk Power Corporation, Orange and Rockland Utilities, Inc., and Rochester Gas and Electric Corporation.
11 128 FERC ¶ 61,049 at P 6.
12 July 15, 2010 Order, 132 FERC ¶ 61,031 at P 41.
Docket Nos. ER08-1281-005 and ER08-1281-006-5-
substantive rulings were made and the NYISO’s ongoing compliance obligations were
made subject to its further compliance submissions, as addressed in this order, below. As
such, the July 15, 2010 Order did not err in failing to address any issues on the merits or
take any of the specific actions proposed by PSEG at that time. Rather, as clarified by
the July 15, 2010 Order,13 the parties have already been directed to address “all”
solutions to the loop flow problem. Therefore, PSEG’s proposals should be among those
considered by the NYISO and the other parties in their on-going discussions.
III.Data Responses
14.Data responses addressing the issues raised by the Commission in the July 15,
2010 Order were submitted by ITC on August 5, 2010, PJM on August 6, 2010, IESO on August 13, 2010, and the NYISO and Midwest ISO on August 16, 2010. In addition, the NYISO filed a supplemental data response on October 14, 2010.
15. In its August 13, 2010 data response, the NYISO notes that the regional RTOs and
ISOs have continued to work collaboratively to develop the initiatives proposed in the
NYISO Report, including: (i) buy-through congestion; (ii) market-to-market
coordination; (iii) interface pricing revisions; and (iv) enhanced interregional transaction
coordination. The NYISO adds that the members of the inter-ISO/RTO design groups
have expanded to capture the necessary expertise to address the complexity of the
initiatives and produce the necessary additional design details. The NYISO states that
these working groups have hosted weekly conference calls and two multi-day site visits
dedicated to further refining the initiatives and addressing the complexities of their
implementations.
16. In its October 14, 2010 supplemental data response, the NYISO states that it has
engaged Potomac Economics, its independent market monitor (NYISO IMM), to prepare
an analysis of the potential benefits to the collective markets that may be achieved
through the implementation of these initiatives. The NYISO IMM’s analysis included,
among other things, an economic analysis of the effects of interface optimization,
coordinated congestion management and buy-through-of congestion on Lake Erie loop
flow. The NYISO IMM identified, as the largest source of benefits, the efficiency
savings achievable by improved utilization of the inter-RTO/ISO interfaces, in particular,
improved real-time coordination of the net scheduled interchange.14 The NYISO IMM
described the coordination of the net scheduled interchange as using bids and offers in
each market to establish the optimal net scheduled interchange in the same way that
RTOs/ISOs establish optimal power flows across each transmission interface inside these
13 Id. P 6.
14 NYISO Supplemental Data Response at 10.
Docket Nos. ER08-1281-005 and ER08-1281-006-6-
markets.15 The NYISO IMM recommended that interface optimization be given the
highest priority. The NYISO IMM estimated a total potential regional annual benefit of over $362 million in fuel-adjusted production cost savings.16
17. In the July 15, 2010 Order, the Commission required the Midwest ISO, PJM,
IESO, and the NYISO to identify and describe any tariff mechanisms currently in place,
and/or any other procedures, that address loop flows caused by transactions between
entities located outside of their respective markets. The Midwest ISO and PJM, in
response, explain that congestion management/market-to-market coordination is used as
an exception to the use of transmission load relief (TLR) procedures to manage loop
flows caused by external transactions. The Midwest ISO adds that, because entities other
than the Midwest ISO, PJM, and the Southwest Power Pool (SPP) do not report their
market flows to the North American Electric Reliability Corporation (NERC), relying on
a TLR measure will not always result in the proper curtailment of transactions internal to
the balancing authority. IESO and PJM further add that they participate in the Lake Erie
Emergency Redispatch agreement to facilitate emergency redispatch among balancing
authorities surrounding Lake Erie to avoid the shedding of firm customer load.
18.ITC, in its response, provides additional details addressing the operation of the
Ontario-Michigan PARs, the cost of the PARs, and their anticipated completion. ITC
explains that the PARs will be operated in accordance with a Presidential Permit and
various operating agreements.
A.Notice of Filings and Responsive Pleadings
19.Notices of the parties’ data responses were published in the Federal Register, 75
Fed. Reg. 49,921 and 52,527 (2010), with comments and interventions due on or before September 15, 2010. Comments were submitted by the NYTOs, ITC, and Monitoring Analytics, LLC, PJM’s independent market monitor (PJM IMM).
20. The NYTOs urge the Commission to require ITC to supplement its responses on a monthly basis regarding the status of the PARs. In particular, the NYTOs argue that ITC should be required to address when it expects to receive its Presidential Permit, what
operating agreements need to be executed, and when ITC expects to be in a position to
place the PARs into service, and whether ITC will place the PARs into service as soon as those events take place irrespective of any funding by parties other than ITC, either
within or outside the Midwest ISO.
15 Id. at 19.
16 Id. at 12.
Docket Nos. ER08-1281-005 and ER08-1281-006-7-
21. The NYTOs also urge the Commission to require ITC to provide additional
information regarding the PARs’ costs and the delays encountered in the physical
completion of the PARs, and the NYTOs request that additional information be provided explaining why these delays have occurred and when ITC expects these issues to be
resolved such that the PARs may be place into service.
22. ITC notes that the Commission’s data requests, in the July 15, 2010 Order,
required the NYISO to submit copies of all studies it has done regarding loop flow issues
and the various possible solutions to loop flow. ITC argues, however, that the NYISO, in
response, appears to have provided only copies of presentations reporting on the results
of certain studies, rather than copies of the actual studies themselves. ITC requests the
Commission require the NYISO to submit copies of the actual studies. In addition, ITC
asserts that the NYISO, in its initial filing in this proceeding, referenced several studies
regarding loop flow and the costs caused by loop flow, as previously prepared by the
NYISO IMM. ITC requests that these studies also be provided. Finally, ITC states that it and the Midwest ISO intend to submit a rate filing, addressing a regional sharing of the costs of the PARs.17
23. The PJM IMM states that, while it is optimistic that the implementation of the
RTO/ISO recommendations will address most loop flow issues over the long term, the
NYISO has failed to explain why interface pricing reform and congestion
management/market-to-market coordination cannot be implemented more expeditiously.
The PJM IMM argues that interface pricing reform will remove the incentives for
scheduling circuitous transactions and that congestion management/market-to-market
coordination will allow the ISOs and RTOs to curtail transactions in an efficient manner,
in accordance with existing transmission rights. The PJM IMM adds that the NYISO has
failed to explain why the buy-through of congestion proposal is a necessary part of the
proposed solutions. The PJM IMM also explains that the buy-through of congestion
proposal may have a significant and inappropriate impact on the relative value of firm
and non-firm transmission service. The PJM IMM further notes that, under certain
circumstances, firm service could be curtailed prior to non-firm service, which would be
inconsistent with PJM’s tariff.18
24. The PJM IMM also claims that the NYISO has failed to adequately explain why
the parallel flow visualization tool is necessary for the implementation of the market-to-
17 On October 20, 2010 in Docket No. ER11-1844-000, the Midwest ISO and ITC submitted tariff sheets to allocate costs associated with the PARs among the
Midwest ISO, PJM and the NYISO. That filing is being addressed in a separate order.
See supra note 4.
18 See PJM Open Access Transmission Tariff at Section 13.6.
Docket Nos. ER08-1281-005 and ER08-1281-006-8-
market coordination proposal.19 The PJM IMM states that the data for establishing firm flow entitlements already exists, and that the necessary entitlements can be established without the parallel flow visualization tool. Finally, the PJM IMM urges that the NYISO be directed to develop firm flow entitlements using existing data rather than waiting until the parallel flow visualization tool is completed.
B.Commission Determination
25.For the reasons discussed below, we establish additional compliance obligations
and reporting requirements for the purpose of assuring that the Lake Erie loop flow
concerns giving rise to this proceeding are resolved expeditiously and without any further
undue delay. First, we agree with ITC that the NYISO has failed to identify and produce
the loop flow-related studies it was directed to produce by the July 15, 2010 Order.20
Accordingly, we require the NYISO to submit this information in a compliance filing to
be made within 30 days of the date of this order. In the alternative, the NYISO may post
these studies on its website and reference the relevant postings in its compliance filing.
26. In the July 15, 2010 Order, the Commission commended the NYISO and the entities with whom it collaborated for their efforts to develop a constructive, workable framework for minimizing the occurrence of Lake Erie loop flow.21 However, the
Commission found that the proposed initiatives raised issues and concerns that were not fully addressed by the NYISO Report. Therefore, the Commission directed the NYISO and additional parties to answer questions and provide additional evidence regarding comments filed in response to the NYISO Report.22
27. In one set of questions, the Commission asked about the differences in the way the
RTOs/ISOs price transactions at their borders and how revisions to interface pricing
would address the incentives for scheduling circuitous transactions. The NYISO’s
19 The parallel flow visualization tool is being developed by NERC to assemble real-time data to perform generation-to-load calculations, facilitate the calculation of impacts and make available common and consistent information regarding the sources of power flows and their impacts to all regions. The NYISO Report states that the parallel flow visualization tool, which will distinguish the source of flow between each separate region’s impacts associated with generation-to-load dispatch and individual transaction impacts, is a prerequisite to the implementation of the four initiatives.
20 July 15, 2010 Order, 132 FERC ¶ 61,031, Appendix A, Questions 12-13.
21 Id. at 40.
22 Id. at 42.
Docket Nos. ER08-1281-005 and ER08-1281-006-9-
response indicates that there are differences between the interface pricing methods used
in PJM and the NYISO. PJM and Midwest ISO use NERC tag information regarding the
source and sink of a transaction to determine the price the transaction receives or pays.
In contrast, the NYISO and IESO base the price on the path over which the external
transaction is scheduled into their respective control areas. The NYISO acknowledges
that this difference creates incentives for market participants to schedule circuitous
transactions which can exacerbate loop flow. The NYISO’s comments indicate that a
change to their pricing methodology may reduce the incentives for scheduling these
transactions, and has agreed to evaluate what changes are necessary. Further, the analysis
by the NYISO IMM states that changes to market rules regarding the interfaces would
address most of the problems associated with Lake Erie loop flow.23 Similarly, the
PJM IMM states that interface pricing reform could be implemented immediately and at
minimal cost. We concur with the two IMMs and will thus make revisions to interface
pricing a heightened priority, as outlined in our compliance directives below.
28. The Commission asked whether a congestion management/market-to-market
coordination agreement similar to the one between the Midwest ISO and PJM could be
developed. In response, the NYISO stated that it would have such an agreement by the
third quarter of 2011, provided that the parallel flow visualization tool was in place. The
PJM IMM, however, has argued that this tool was not necessary to implement such an
agreement with neighboring RTOs/ISOs.24 We are not persuaded that the parallel flow
visualization tool is necessary in order to implement a congestion management/market-
to-market coordination agreement between NYISO and its neighboring RTOs/ISOs given
that the Midwest ISO and PJM currently use this type of agreement to manage loop flows
between their systems. While the parallel flow visualization tool will provide additional
data for analyzing loop flows, it is merely an update to the Interchange Distribution
Calculator (IDC); it is not a new technology. Indeed, some of the data required to
address these problems can already be obtained from the existing IDC. Nothing in the
record demonstrates that the NYISO cannot take advantage of the existing technology
and data. Therefore, we find that NYISO can implement a congestion
management/market-to-market coordination agreement prior to finalization of the parallel
flow visualization tool.
29. The NYISO argues that the buy-through of congestion proposal recognizes the
financial impacts created by parallel flows.25 The NYISO also states that an up-to
component is not feasible for real-time interchange transactions. However, the
23 NYISO Supplemental Data Response at 10.
24 PJM IMM Comments at 5.
25 NYISO August 16, 2010 Transmittal Letter at 5.
Docket Nos. ER08-1281-005 and ER08-1281-006-10-
PJM IMM raises concerns regarding this proposal stating that: (i) the benefits of buythrough of congestion appear to be overstated, (ii) the product would take a long time to implement,26 and (iii) the NYISO has not adequately explained why buy-through of congestion is a necessary part of a comprehensive solution to Lake Erie Loop Flow
issues.27 We concur with the PJM IMM that the NYISO did not adequately explain why this proposal should be regarded as a top-priority initiative at this time.
30. In conclusion, we agree with commenters that interface pricing reform and
congestion management/market-to-market coordination can address and resolve many of
the price incentives that create loop flow related concerns. In addition, we agree with the
PJM IMM that implementing these two market solutions sooner will be more cost
effective than implementing all four initiatives at a later date. Because the
implementation of the four proposed market initiatives will require a significant amount
of time and resources, and because the four RTO/ISOs have not met the proposed
timelines, as outlined in the NYISO Report, we find that it is appropriate, at this time, to
re-prioritize the implementation schedule and establish revised, firm deadlines.28
31. First, we require that interface pricing revisions be completed concurrently for the Commission-jurisdictional RTO/ISOs by the second quarter of 2011.29 As noted by the PJM IMM, this method has been used by PJM and the Midwest ISO for years and could be implemented by other RTOs/ISOs at minimal cost.30 We note that this required date, now Commission-mandated, still allows an additional year beyond the date for interface pricing revisions (design) included in the NYISO Report, which was originally proposed for the second quarter of 2010.
26 PJM IMM February Comments at 7-8.
27 PJM IMM Comments at 3.
28 Our re-prioritization of the initiatives affects interface pricing revisions and the congestion management/market-to-market coordination initiatives. It does not affect the NYISO’s proposed tariff revisions made in Docket No. ER11-2547-000 on the enhanced interregional transaction coordination initiative.
29 The Commission does not have jurisdiction over IESO. We note, however, that IESO has been an active participant in these proceedings and we appreciate IESO’s
commitment to resolving the loop flow issues addressed in this order. We direct the NYISO, the Midwest ISO and PJM to continue to work with IESO to develop a
comprehensive resolution to the Lake Erie loop flow problem.
30 PJM IMM Comments at 2.
Docket Nos. ER08-1281-005 and ER08-1281-006-11-
32. Second, we require congestion management/market-to-market coordination for the
Commission-jurisdictional RTO/ISOs to be completed concurrently by the second quarter
of 2011.31 We concur with the PJM IMM that its proposal can build on the existing
framework developed and implemented by the Midwest ISO and PJM.32 We further
agree that market-to-market mechanisms have been shown to economically relieve
congestion and align border prices successfully.33 We also note that this date, albeit now
Commission-mandated, likewise allows more time than originally proposed in the
NYISO Report, which called for implementation of this initiative in the third quarter of
2010. We further note that the NYISO originally projected a date of 2012 for additional
regions.
33. Third, one year after the implementation of interface pricing reform and
congestion management/market-to-market coordination, and every six months thereafter
until the market initiatives are fully implemented, we require the NYISO, in collaboration
with its neighboring RTO/ISOs, NERC and other market participants, to submit a report,
as an information filing, addressing: (i) the effects of the reforms on reducing congestion
that results from loop flows and the costs associated with mitigating congestion; (ii) the
effects of the implementation of the enhanced interregional transaction coordination
initiative;34 and (iii) recommendations and analyses as to whether the buy-through
congestion proposal is required, and if so, when it should be implemented.35 The
RTO/ISO parties are hereby reminded that any agreements and/or tariff provisions that
they may be develop to implement the interface pricing reform and congestion
management/market-to-market coordination initiatives must be filed with the
Commission.
34. Finally, we reject the NYTO’s request that we require ITC to provide additional
information regarding the PARs cost issues. Rather, we have established hearing and
31 See supra note 28.
32 Id. at 5-6.
33 Id. at 4.
34 Action on the NYISO’s tariff proposal in Docket No. ER11-2547-000 to implement its enhanced interregional transaction coordination initiative is pending and will be
addressed in that docket.
35 These reports will be for informational purposes only. They will not be noticed and the Commission does not intend to act on them.
Docket Nos. ER08-1281-005 and ER08-1281-006-12-
settlement judge proceedings in Docket No. ER11-1844-000, where these issues can be resolved.36
The Commission orders:
(A) Rehearing of the July 15, 2010 Order is hereby denied, for the reasons discussed in the body of this order.
(B) The NYISO is hereby directed to make a compliance filing within 30 days of this order in which it provides copies of all of the studies it has done regarding loop flow issues and various possible solutions to such issues.
(C) The RTO/ISO parties are hereby reminded that any agreements and/or tariff provisions that they develop to implement the interface pricing reform and congestion management/market-to-market coordination initiatives must be filed with the
Commission, as discussed in the body of the order.
(D) The RTO/ISO parties are hereby directed to submit informational reports, as discussed in the body of this order
By the Commission.
( S E A L )
Nathaniel J. Davis, Sr.,
Deputy Secretary.
36 See PARs Cost Allocation Order, 133 FERC ¶ 61,275.
