10 Krey Boulevard Rensselaer, NY 12144
October 25, 2012
By Electronic Delivery
Honorable Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE
Washington, DC 20426
Re: New York Independent System Operator, Inc., Docket Nos. ER12-1653-000,
RM11-7-000, AD10-11-000, Notice of Potential Change in Effective Date
Dear Ms. Bose:
The New York Independent System Operator, Inc. (“NYISO”) respectfully reports that in
order to implement the Commission’s Order No. 755 directives with respect to compensation for
providers of Regulation Service this year it would need an approval order by October 31, 2012.
Because it is the practice of the NYISO to avoid implementing changes to software that
implicate bid-to-bill processes after mid-November, the lack of a Commission determination by
October 31, 2012 will require the NYISO to request a delay in the effective date until after the
first of the year.
In its compliance filings in this docket,1 the NYISO proposed an effective date between
October 10, 2012 and November 14, 2012, to be established on two weeks’ written notice to the
Commission and the market.2 A window rather than a firm effective date was necessary to
accommodate the underlying software revision installation schedule which can change
depending on system conditions, the NYISO’s testing protocols and other influences.3
Although the Commission has not yet acted on the NYISO’s filings in this docket, the NYISO installed the software necessary for its Order No. 755 obligations on October 24, 2012. These Order 755 software revisions were installed in the “off” position. Given the need to issue a two-week notice establishing the effective date, the NYISO would need a Commission
determination on or before October 31 to issue a market notice by November 1, 2012 and turn the software “on” effective as of November 14, 2012.
1 See: New York Independent System Operator, Inc., Docket No. ER12-1653-000, Letters to Kimberly D. Bose, April 30, 2012 and August 17, 2012 .
2 The Commission has accepted an effective date established on a two-week notice in other NYISO
dockets. See: New York Independent System Operator, Inc. ER12-1868-000 & ER07-521-011, August 1, 2012 Office of Energy Market Regulation, Acceptance for Filing.
3 Among others, changes to the Regulation Service Market required installation of code revisions to the scheduling, dispatch, pricing and settlement software.
