10 Krey Boulevard Rensselaer, NY 12144
April 30, 2015
Submitted Electronically
Kimberly D. Bose
Secretary
Federal Energy Regulatory Commission 888 First Street N.E.
Washington, D.C. 20426
Re: Response to Deficiency Letter in Docket No. ER15-1042 Dear Ms. Bose:
The New York Independent System Operator, Inc. (“NYISO”) submits this response to the Federal Energy Regulatory Commission’s (the “Commission’s”) deficiency letter issued in this proceeding on April 10, 2015 (“Deficiency Letter”). The Deficiency Letter directs the NYISO to provide:
1) An explanation of the methodology, calculation and underlying assumptions used
to determine the proposed $2,592 per MVAR VSS compensation rate.
2) Supporting documentation demonstrating that the proposed amendments maintain
the approximate total dollar value of the current VSS program in the near term.
The proposed amendments to Rate Schedule 2 of the Market Administration and
Control Area Services Tariff would compensate Voltage Support Service (“VSS”)1 Suppliers
$2,592 per MVAr based on their demonstrated lagging and leading voltage support
capability.2 As Mr. Garrison explains in his affidavit,3 the NYISO arrived at the
$2,592/MVAr rate by dividing the total VSS program compensation paid to qualified VSS
Suppliers in 2012 by the total lagging and leading reactive power capability of all qualified
VSS Suppliers in 2012. The approach utilized by Mr. Garrison to develop the proposed VSS
compensation rate was specifically designed to maintain the approximate total dollar value of
the VSS program in the near term. The attached affidavit provides complete responses to the
Commission’s requests.
As required by the Deficiency Letter at fn 2, the NYISO respectfully submits an
unmarked version of tariff amendments filed in its February 13, 2015 Voltage Support
1 Capitalized terms that are not otherwise defined herein shall have the meaning specified in the Market Administration and Control Area Services Tariff.
2 MVAr is the unit of measure for Reactive Power capability.
3 Attachment I to this filing letter.
Kimberly D. Bose, Secretary April 30, 2015
Page 2
Service Filing in Docket No. ER15-1042-000.4 The NYISO requests that the tariff revisions proposed in its February 13, 2015 filing be permitted to become effective on January 1, 2016. The NYISO also respectfully requests that the Commission issue an order in this docket
within 60 days of the date that this response is submitted.
The NYISO renews its request for a waiver of Commission regulations to allow the
NYISO to make the filing more than 120 days prior to the date on which the proposed
revisions are to become operational.5 No Market Participant will be prejudiced by NYISO’s
request because the proposed implementation timetable was developed in consultation with
Market Participants. Market Participants have known, for some time, that the NYISO will be
prepared to implement the revised compensation structure for the entire 2016 calendar year.
The NYISO seeks acceptance of these tariff revisions now to give VSS Suppliers time to test
and prepare for the revised compensation structure in 2016.6 Since VSS compensation is an
annual payment, the NYISO also seeks to have one compensation structure in place for each
complete calendar year. Therefore, the NYSIO intends for the existing VSS compensation
structure to continue through the end of 2015.
The NYISO will send an electronic link to this filing to the official representative of
each of its customers, to each participant on its stakeholder committees, to the New York
Public Service Commission, and to the New Jersey Board of Public Utilities. In addition, the
complete filing will be posted on the NYISO’s website at www.nyiso.com.
Respectfully submitted,
/s/ James H. Sweeney
James H. Sweeney, Attorney
New York Independent System Operator, Inc.
cc:Michael Bardee
Gregory Berson
Anna Cochrane
Michael Lee
Morris Margolis
David Morenoff
Daniel Nowak
Kathleen Schnorf
Jamie Simler
Kevin Siqveland
4 Attachment II to this filing letter.
5 See 18 CFR §35.3(a)(1).
6 Lagging reactive power capability must be tested or demonstrated between May 1 and October 31 of the year prior to the compensation year. Leading reactive power capability must be tested or demonstrated between January 1 and October 31 of the year prior to the compensation year.
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 30th day of April, 2015.
/s/ Joy A. Zimberlin
Joy A. Zimberlin
New York Independent System Operator, Inc.
10 Krey Blvd.
Rensselaer, NY 12144 (518) 356-6207
