UNITED STATES OF AMERICA
BEFORE THE

FEDERAL ENERGY REGULATORY COMMISSION

Regional Reliability Standard)

PRC-006-NPCC-1 Automatic)Docket No. RM12-12-000

Underfrequency Load Shedding)

COMMENTS OF THE

NEW YORK INDEPENDENT SYSTEM OPERATOR, INC.

I.INTRODUCTION

The New York Independent System Operator (“NYISO”) respectfully submits these

comments in support of the Federal Energy Regulatory Commission’s (“Commission” or

“FERC”) Notice of Proposed Rulemaking (“NOPR”), dated September 20, 2012.1  In its NOPR, the Commission proposes to approve regional Reliability Standard PRC-006-NPCC-1
(Automatic Underfrequency Load Shedding) developed by the Northeast Power Coordinating Council (“NPCC”) and approved by the North American Electric Reliability Corporation
(“NERC”).  The Commission also proposes to approve the associated violation risk factors
(“VRFs”) and violation severity levels (“VSLs”), implementation plan, and effective dates
proposed by NERC.  The NYISO supports the Commission’s efforts on this matter and also
appreciates this opportunity to offer comments.

II. COMMUNICATIONS AND CORRESPONDENCE

All communications and services in this proceeding should be directed to:

Robert E. Fernandez, General Counsel

Raymond Stalter, Director of Regulatory Affairs

1 Regional Reliability Standard PRC-006-NPCC-1 Automatic Underfrequency Load Shedding, 140 FERC ¶ 61,203 (September 20, 2012) (“NOPR”)

1

*Carl F. Patka, Assistant General Counsel *Nathan D. Markey, Attorney

New York Independent System Operator, Inc.

10 Krey Boulevard

Rensselaer, NY 12144
Tel:  (518) 356-8875
Fax: (518) 356-7678
rfernandez@nyiso.com
rstalter@nyiso.com
cpatka@nyiso.com
nmarkey@nyiso.com

* Persons designated for receipt of service

III.COMMENTS

The NYISO supports the Commission’s proposed approval of regional Reliability Standard PRC-006-NPCC-1 and the associated VFRs and VSLs, effective dates and implementation plan

NERC regional Reliability Standard PRC-006-NPCC-1 is designed to ensure the

development of an effective automatic underfrequency load shedding (“UFLS”) program to

preserve the security and integrity of the Bulk-Power System during declining frequency events.
The regional reliability standard is designed to work in coordination with and augment NERC’s
continent-wide UFLS Reliability Standard PRC-006-1.  The NYISO supports this standard as
NYISO staff was involved in the drafting of the regional standard and the NYISO voted to
support the standard at NPCC as it is effectively designed to mitigate the consequences of an
underfrequency event.  The proposed standard satisfies the factors set forth in Order No. 672 for
the criteria required for approval of a regional Reliability Standard because it adds specificity not
contained in the NERC continent wide UFLS Reliability Standard PRC-006-1.
Accordingly, the NYISO requests that FERC approve the proposed Regional Reliability Standard PRC-006-NPCC-1 (Automatic Underfrequency Load Shedding) without modification.

2

IV.CONCLUSION

WHEREFORE, for the reasons stated above, the NYISO requests that the Commission
consider these comments and approve the regional Reliability Standard, as discussed above.

Respectfully submitted,

/s/ Nathan D. Markey

Nathan D. Markey Attorney

New York Independent System Operator, Inc.

10 Krey Blvd.

Rensselaer, New York 12144 (518) 356 7372

nmarkey@nyiso.com

November 26, 2012

3

CERTIFICATE OF SERVICE

I hereby certify that I have this day served the foregoing document upon each person

designated on the official service list compiled by the Secretary in this proceeding in accordance with the requirements of Rule 2010 of the Rules of Practice and Procedure, 18 C.F.R. §385.2010.
Dated at Rensselaer, NY this 26th day of November, 2012.

/s/ Joy A. Zimberlin

Joy A. Zimberlin

New York Independent System Operator, Inc.

10 Krey Blvd.

Rensselaer, NY 12144 (518) 356-6207