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March 23, 2012FILE NO: 55430.000064
Ms. Kimberly D. Bose Secretary
Federal Energy Regulatory Commission 888 First Street NE
Washington DC 20426
Re: Docket Nos. RM96-1-037 and AD12-12-000 - Comments on Questions Raised by
Commissioner LaFleur
Dear Ms. Kimberly D. Bose:
At the Commission’s February 16, 2012 open meeting, Commissioner LaFleur invited
comments on several questions related to gas-electric coordination. Commissioner LaFleur
posed these questions during the Commission’s discussion of the notice of proposed
rulemaking in Docket No. RM96-1-037 (“NOPR”). Subsequently, Commissioner LaFleur’s
comments were published in an official statement issued in the NOPR docket.1 At the same
time, Commissioner LaFleur referenced the Commission’s notice seeking comments on a
broad range of gas-electric coordination issues in Docket No. AD12-12-000.2 It appears that
Commissioner LaFleur’s questions are also relevant to Docket No. AD12-12-000.
1 Statement of Commissioner Cheryl A. LaFleur on Standards for Business Practices for Interstate Natural Gas Pipelines, Docket No. RM96-1-037 (issued February 16, 2012).
2 Notice Assigning Docket No. and Requesting Comments, Docket No. AD12-12-000 (issued
February 15, 2012). See also Request for Comments of Commissioner Moeller on Coordination
between the Natural Gas and Electricity Markets (dated February 3, 2012), available at
<http://www.ferc.gov/about/com-mem/moeller/moellergaselectricletter.pdf>.
ATLANTA AUSTIN BANGKOK BEIJING BRUSSELS CHARLOTTE DALLAS HOUSTON LONDON LOS ANGELES
McLEAN MIAMI NEW YORK NORFOLK RALEIGH RICHMOND SAN FRANCISCO TOKYO WASHINGTON
www.hunton.com
Ms. Kimberly D. Bose March 23, 2012
Page 2
The ISO/RTO Council (“IRC”)3 is not submitting comments in Docket No. RM96-1-
037 but may submit comments in Docket No. AD12-12-000. The IRC believes that it would
be most appropriate, and efficient, to submit comments in response to Commissioner
LaFleur’s questions in Docket No. AD12-12-000 rather than RM96-1-037. To the extent that
the Commission intended for Commissioner LaFleur’s question to be addressed in the latter
docket, the IRC respectfully requests leave and reserves its rights to address them in Docket
No. AD12-12-000.4
Respectfully Submitted,
/s/ Craig Glazer
Craig Glazer
Vice President - Federal Government Policy
Jennifer Tribulski Senior Counsel
PJM Interconnection, L.L.C.
1200 G Street, N.W. Suite 600 Washington, DC 20005
glazec@pjm.com
/s/ Mollie Lampi
Mollie Lampi
Assistant General Counsel Raymond Stalter
Director, Regulatory Affairs
New York Independent System Operator, Inc.
10 Krey Blvd
Rensselaer, NY 12144 mlampi@nyiso.com
3 The IRC is comprised of the Alberta Electric System Operator (“AESO”), the California
Independent System Operator Corporation (“CAISO”), Electric Reliability Council of Texas
(“ERCOT”), the Independent Electricity System Operator of Ontario, Inc., (“IESO”), ISO New
England, Inc. (“ISONE”), Midwest Independent Transmission System Operator, Inc., (“MISO”), New
Brunswick System Operator (“NBSO”), New York Independent System Operator, Inc. (“NYISO”),
PJM Interconnection, L.L.C. (“PJM”), and Southwest Power Pool, Inc. (“SPP”). The AESO, IESO,
and NBSO are not subject to the Commission’s jurisdiction, and are not joining in these comments.
ERCOT is subject to the Commission’s jurisdiction for reliability matters pursuant to Section 215 of
the Federal Power Act. The IRC’s mission is to work collaboratively to develop effective processes,
tools, and standard methods for improving the competitive electricity markets across North America.
In fulfilling this mission, it is the IRC’s goal to provide a perspective that balances Reliability
Standards with market practices so that each complements the other, thereby resulting in efficient, robust markets that provide competitive and reliable service to customers.
4 Similarly, to the extent that the Commission were to conclude that responses to
Commissioner LaFleur’s questions in Docket No. AD12-12-000 would be untimely the IRC respectfully requests leave to submit them one week out of time.
Ms. Kimberly D. Bose March 23, 2012
Page 3
/s/ Stephen G. Kozey
Stephen G. Kozey
Vice President, General Counsel, and Secretary
Midwest Independent Transmission System Operator, Inc.
P.O. Box 4202
Carmel, IN 46082-4202
skozey@midwestiso.org
/s/ Heather Starnes
Heather Starnes
Manager, Regulatory Policy
Southwest Power Pool
415 North McKinley #140 Plaza West
Little Rock, AR 72205 hstarnes@spp.org
/s/ Matthew T. Morais
Matthew T. Morais
Electric Reliability Council of Texas
7620 Metro Center Dr. Austin, TX 78744
mmorais@ercot.com
/s/ Andrew Ulmer
Nancy Saracino
General Counsel
Andrew Ulmer
Director, Federal Regulatory Affairs
California Independent System Operator Corporation
250 Outcropping Way
Folsom, CA 95630
aulmer@caiso.com
/s/ Raymond W. Hepper
Raymond W. Hepper
Vice President, General Counsel, and Secretary
Theodore J. Paradise
Assistant General Counsel,
Operations and Planning
ISO New England Inc.
One Sullivan Road
Holyoke, MA 01040
rhepper@iso-ne.com
