10 Krey Boulevard Rensselaer, NY 12144
December 18, 2015
By Electronic Delivery
Honorable Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE
Washington, DC 20426
Re: Docket No. ER16-81-000, Huntley Power LLC
Dear Secretary Bose:
On October 14, 2015, Huntley Power LLC (“Huntley”) filed an unexecuted cost-of-
service agreement, designated as Huntley’s FERC Electric Rate Schedule No. 1 (“Rate
Schedule”). On December 7, 2015, Huntley filed an Amended Application to revise the Rate Schedule that it filed on October 14, 2015. Huntley’s Amended Application incorporated the result of its discussions with the New York Independent System Operator, Inc. (“NYISO”) into the proposed Rate Schedule. Although the NYISO and Huntley were not able to reach
agreement on all issues related to the non-rate terms and conditions of service, the NYISO
appreciates Huntley’s efforts to develop an amended Rate Schedule.
While the NYISO was working with Huntley to revise the non-rate terms and conditions of the Rate Schedule, the NYISO was also working with National Grid, to determine if a local Reliability Need might require the NYISO to enter into the Rate Schedule with Huntley for a period of months. The NYISO has determined that the retirement of Huntley Units 67 and 68 on March 1, 2016 (along with the Mothball Outage of all remaining Dunkirk Units) is not expected to result in any national, regional, state or local reliability criteria violations, and that both
Huntley Generators can be Retired on March 1, 2016.
The NYISO’s made its determination based on the NYISO’s proposed rules addressing RMRs that are pending Commission review in Docket No. ER16-120-000. Under its proposed rules, the NYISO would only enter into an RMR Agreement to address an identified “Reliability Need.” A Reliability Need is defined as “[a] condition identified by the ISO as a violation or potential violation of one or more Reliability Criteria and, for purposes of administering the Gap Solution process in Section 31.2.11, applicable local criteria.”1
1 See NYISO’s Proposed OATT Section 31.1.1. “Reliability Criteria” are the electric power
system planning and operating policies, standards, criteria, guidelines, procedures, and rules promulgated by the North American Electric Reliability Corporation, Northeast Power Coordinating Council and the New York State Reliability Council.
