May 18, 2017
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.’s Proposed Tariff
Amendments to Coordination Agreement Between ISO New England Inc.
and the New York Independent System Operator; Docket No. ER17-___-000
Dear Secretary Bose:
The New York Independent System Operator, Inc. (“NYISO”) submits this filing
pursuant to Section 205 of the Federal Power Act1 to propose amendments to the Coordination
Agreement between ISO New England Inc. (“ISO-NE”) and NYISO (“Coordination
Agreement”) which is Section 37 of the NYISO’s Open Access Transmission Tariff (“OATT”).
The NYISO and ISO-NE worked together to develop the revisions proposed herein and gained
approval of the revisions from their respective stakeholders. ISO-NE will separately file the
revised Coordination Agreement that resides in its tariffs with the Federal Energy Regulatory
Commission (“Commission”). The NYISO and ISO-NE are collectively referred to herein as the
“ISOs.”
The ISOs propose two sets of Coordination Agreement revisions in this filing. The
revisions to Articles 1 and 6 of the Coordination Agreement propose minor corrections to
improve the accuracy of the Agreement. The proposed revisions to Schedule C to the
Coordination Agreement are improvements to the rules for pricing Emergency Energy. Both sets
of revisions were approved by the NYISO Management Committee and are described further
below.
I.Documents Submitted
1.This filing letter;
1 16 U.S.C. §824d.
Honorable Kimberly D. Bose May 18, 2017
Page 2
2.A clean version of the proposed revisions to the NYISO’s OATT (“Attachment I”);
and
3.A blacklined version of the proposed revisions to the NYISO’s OATT
(“Attachment II”).
II.Description and Justification of Proposed Revisions to the Coordination Agreement
A. Coordination Agreement Articles 1 and 6
On September 10, 2015, the ISOs each submitted a Federal Power Act Section 205 filing to the Commission, setting forth rules necessary to enable them to implement Coordinated
Transaction Scheduling (“CTS”)2 (the “2015 Filings”) at their primary A/C interface.3 The
Commission accepted the 2015 Filings and Coordinated Transaction Scheduling between
NYISO and ISO-NE was implemented on December 15, 2015.4 The ISOs identified minor
additional revisions that are necessary to improve consistency within the rest of the Coordination Agreement and to eliminate unintended redundancy. The proposed revisions to Articles 1 and 6 of their Coordination Agreement are described below.
Coordination Agreement Article 1
In the 2015 Filings, the ISOs added a definition of “Transfer Limit” to their Coordination Agreement. Transfer Limit was defined as the maximum net interchange that can be scheduled at a CTS Enabled Interface. However, the ISOs later identified an inconsistency between that
definition and Section 5.0 of Schedule D to the Coordination Agreement. Section 5.0 describes how Transfer Limits are established and states that a Transfer Limit sets the minimum or
maximum net interchange that can be scheduled on a CTS Enabled Interface between NYISO
and ISO-NE. Since the Transfer Limit can be a minimum or a maximum, the ISOs propose to
revise the definition of “Transfer Limit” in Article 1.0 of the Coordination Agreement to be the minimum or maximum net interchange that can be scheduled at a CTS Enabled Interface. The proposed revision directly parallels the description of how a Transfer Limit is established in
Section 5.0 of Schedule D to the Coordination Agreement.
2 Capitalized terms not otherwise defined herein shall have the meaning specified in Article 1 of the Coordination Agreement.
3 New York Independent System Operator, Inc.’s Proposed Tariff Amendments to Implement External Coordinated Transaction Scheduling with ISO New England Inc., Docket No. ER15-2640-000 (September 10, 2015); ISO New England Inc. and New England Power Pool, Coordination Agreement, Market Rule 1, OATT Conforming Revisions Relating to Coordinated Transaction Scheduling, Docket No. ER15-2641-000 (September 10, 2015).
4 New York Independent System Operator, Inc., 153 FERC ¶ 61,158 (2015); New York Independent System
Operator, Inc., Docket No. ER15-2640-001 (unpublished letter order issued February 5, 2016); ISO New England Inc., 153 FERC ¶ 61,159 (2015); ISO New England Inc., Docket No. ER15-2641-001 (unpublished letter order issued February 5, 2016).
Honorable Kimberly D. Bose May 18, 2017
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Coordination Agreement Article 6
In the 2015 Filings, the ISOs proposed and the Commission accepted revisions to Article
6.0 of the Coordination Agreement related to the exchange of information between NYISO and
ISO-NE and the treatment of Confidential Information or Critical Energy Infrastructure
Information that the ISOs exchange. In preparing the materials for their respective filings with
the Commission in September 2015,5 the ISOs discovered two provisions in Section 6.5 of the
Coordination Agreement that they had intended to strike - specifically, Sections 6.5 (d) and (h) -
were inadvertently removed from the draft Coordination Agreement before the proposed changes
were presented to stakeholders for their consideration. Because stakeholders did not have the
opportunity to review these proposed deletions, the ISOs agreed not to remove the two
provisions from Section 6.5 in the 2015 Filings. The ISOs have now presented the removal of
these two provisions to their respective stakeholders and obtained the needed approvals. The
ISOs now propose to remove Sections 6.5(d) and 6.5(h) from the Coordination Agreement.
B. Emergency Energy Transactions Schedule
The ISOs propose revisions to the Emergency Energy settlement provisions specified in
Schedule C to the Coordination Agreement. The proposed revisions provide a specific formula
to price Emergency Energy based on which ISO is the delivering party. Two formulas allow the
ISOs to align Emergency Energy settlement intervals and prices with their respective real-time
energy market settlement intervals and prices. In addition, the ISOs propose to prevent negative
prices from being used to settle Emergency Energy transactions. A negative real-time Locational
Based Marginal Price (“LBMP”), or Locational Marginal Price (“LMP”), will be set to $0.00 for
purposes of an Emergency Energy transaction because the delivering ISO should not be required
to pay the receiving ISO for the Emergency Energy that the delivering ISO provides when an
Emergency Energy transaction occurs during an interval with negative prices.
For ISO-NE as the Delivering Party
When ISO-NE is the delivering party the proposed settlement formula aligns the
Emergency Energy settlement intervals with the five-minute settlement intervals in ISO-NE’s
Real-Time Energy Market and for Real-Time reserves.6 The settlement interval associated with
ISO-NE delivering Emergency Energy to New York should be consistent with the five-minute
settlement interval used in the ISO-NE Real-Time Energy Market and apply the same five-
minute prices to the Emergency Energy and the energy market. Therefore, the proposed
Coordination Agreement revisions specify that when ISO-NE is the delivering Party, the
5 New York Independent System Operator, Inc.’s Proposed Tariff Amendments to Implement External Coordinated Transaction Scheduling with ISO New England Inc., Docket No. ER15-2640-000 (September 10, 2015); ISO New England Inc. and New England Power Pool, Coordination Agreement, Market Rule 1, OATT Conforming Revisions Relating to Coordinated Transaction Scheduling, Docket No. ER15-2641-000 (September 10, 2015).
6 Letter Order issued in Docket No. ER16-1838-000 (July 26, 2016) (effective March 1, 2017, ISO-NE replaced its
hourly settlement interval in its Real-Time Energy Market and for Real-Time reserves with a five-minute settlement
interval.).
Honorable Kimberly D. Bose May 18, 2017
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Emergency Energy charge for an hour equals the sum of the energy charges (LMP * MWh) for each five minute settlement interval in the hour multiplied by 110%.7
For NYISO as the Delivering Party
The ISOs propose similar, clarifying revisions to the settlement formula used when NYISO is the delivering Party. The proposed clarifications state that the Emergency Energy charge for an hour equals the sum of the energy charges (LBMP * MWh) for each real-time interval in that hour when NYISO is the delivering Party multiplied by 110%.
III.Effective Date
The NYISO respectfully requests that the Commission issue an order accepting the
proposed tariff revisions by July 17, 2017 (i.e., sixty days from the date of this filing) with an effective date of August 1, 2017.
IV.Stakeholder Approval
The proposed amendments to Coordination Agreement Articles 1 and 6 were approved without dissent by the NYISO Management Committee on March 30, 2016. The NYISO Board of Directors approved the filing of these proposed revisions on April 18, 2016.
The proposed revisions to Schedule C to the Coordination Agreement were approved
unanimously by the NYISO Management Committee on March 29, 2017. The NYISO Board of Directors approved these proposed revisions on April 11, 2017.
V.Communications and Correspondence
All communications and service in this proceeding should be directed to:
Robert E. Fernandez, General Counsel
Raymond Stalter, Director, Regulatory Affairs *James H. Sweeney, Senior Attorney
10 Krey Boulevard
Rensselaer, NY 12144
Tel: (518) 356-6000
Fax: (518) 356-7678
rfernandez@nyiso.com
rstalter@nyiso.com
jsweeney@nyiso.com
*Person designated for receipt of service.
7 The 110% factor is not being proposed in this filing. The current formula multiplies the hourly energy settlement by 110% for Emergency Energy transactions.
Honorable Kimberly D. Bose May 18, 2017
Page 5
VI.Service
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 State 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.
VII. Conclusion
The New York Independent System Operator, Inc. respectfully requests that the
Commission accept for filing the proposed tariff revisions that are attached hereto with an effective date of August 1, 2017.
Respectfully submitted,
/s/ James H. Sweeney
James H. Sweeney, Senior Attorney
New York Independent System Operator, Inc.
cc:Michael Bardee
Nicole Buell
Anna Cochrane
Kurt Longo
David Morenoff
Daniel Nowak
Larry Parkinson
J. Arnold Quinn
Douglas Roe
Kathleen Schnorf
Jamie Simler
Gary Will