March 29, 2018
By Electronic Delivery
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission 888 First St., N.E.
Washington, D.C. 20426
Re: New York Independent System Operator, Inc., Proposed Tariff Revisions
Addressing Provision of Synchronized Reserves by Inverter-Based Energy Storage Resources; Docket No. ER18-___-000
Dear Ms. Bose:
Pursuant to Section 205 of the Federal Power Act,1 the New York Independent System
Operator, Inc. (“NYISO”) hereby submits proposed revisions to its Open Access Transmission
Tariff (“OATT”) and its Market Administration and Control Area Services Tariff (“Services
Tariff”) that address supplier eligibility to provide synchronized Operating Reserves.2 The
revisions proposed in this filing will, if accepted, permit resources using inverter-based
technology (i.e., batteries) to supply Spinning (10-Minute Synchronized) and 30-Minute
synchronized Reserves. These tariff enhancements were developed in response to the Northeast
Power Coordinating Council’s (“NPCC”) clarification that inverter-based energy storage
resources are eligible to provide Synchronized Reserves, and will permit two classes of inverter-
based resources to provide Synchronized Reserves: (i) Generators,3 and (ii) Demand Side
Resources.4
The NYISO requests that the Federal Energy Regulatory Commission (“FERC” or
“Commission”) accept these tariff amendments and permit the proposed revisions to become
1 16 U.S.C. § 824d.
2 Capitalized terms that are not defined in this filing letter have the meaning ascribed to them in Section 1 of the OATT and Section 2 of the Services Tariff.
3 The term Generator is defined in OATT Section 1.7 and Services Tariff Section 2.7. Generators include Energy Limited Resources (“ELRs”) and Limited Energy Storage Resources (“LESRs”).
4 The term Demand Side Resource is defined in OATT Section 1.4 and Services Tariff Section 2.4. Demand Side
Resources include resources participating in the NYISO’s Emergency Demand Response Program, Day-Ahead
Demand Response Program, Demand-Side Ancillary Services Program and/or Special Case Resource (“SCR”)
program.
Honorable Kimberly D. Bose March 29, 2018
Page 2
effective on Wednesday, May 30, 2018, which is the first business day following the last day of the sixty-day time period.5
I.List of Documents Submitted
The NYISO respectfully submits the following documents with this filing letter:
1.A clean version of the proposed revisions to the NYISO’s OATT (“Attachment I”);
2.A clean version of the proposed revisions to the NYISO’s Services Tariff
(“Attachment II”);
3.A blacklined version of the proposed revisions to the NYISO’s OATT (“Attachment
III”); and
4.A blacklined version of the proposed revisions to the NYISO’s Services Tariff
(“Attachment IV”).
II.Overview
In order to ensure adequate reserve capability to resolve a Balancing Contingency Event,6 the NPCC requires the NYISO (as the Balancing Authority for the New York Control Area) to
maintain Operating Reserves at least sufficient to recover within ten minutes from its first
contingency loss.7 Of the required 10-Minute Reserve capability, at least twenty-five percent
(and up to one hundred percent) must be provided by synchronized resources.8 Traditionally,
this Synchronized Reserve service has been provided by Generators9 that are online and
committed at least to the unit’s minimum generation level. NPCC defines Synchronized Reserve as “[t]he unused portion of generating capacity which is synchronized to the system and ready to pick up load to claimed capacity….”10
5 Due to the Memorial Day holiday, Tuesday, May 29 is the last day of the sixty-day time period. See 18 C.F.R. § 385.2007, 5 U.S.C § 6103.
6 N. Am. Elec. Reliability Corp. Reliability Standard BAL-002-2(i) (Disturbance Control Standard - Contingency Reserve for recovery from a Balancing Contingency Event). BAL-002-2(i) ensures that “the Balancing Authority … balances resources and demand and returns the Balancing Authority’s … Area Control Error to defined values (subject to applicable limits) following a Reportable Balancing Contingency Event.”
7 Ne. Power Coordinating Council Regional Reliability Reference Directory No. 5 - Reserve, § 5.1 (Dec. 2, 2010).
8 Id. at § 5.5. The requirement for 10-Minute Synchronized Reserve is based on the Balancing Authority’s
demonstrated performance in returning its Area Control Error to pre-contingency values (or zero) within fifteen minutes following the loss of a resource.
9 While the vast majority of Synchronized Reserve procured by the NYISO is provided by generation assets,
Demand Side Resources in the NYISO’s Demand-Side Ancillary Services Program may also provide such service.
10 Ne. Power Coordinating Council Glossary of Terms, at 20.
Honorable Kimberly D. Bose March 29, 2018
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The reliability rule does not address whether emerging inverter-based energy storage technologies - which have different operational characteristics than traditional thermal
generation - are eligible to provide Synchronized Reserve. The NYISO, therefore, sought clarification from NPCC as to whether inverter-based energy storage technology is eligible to provide Synchronized Reserve.
In response to the NYISO’s request, NPCC stated that “energy-producing technologies which do not depend on the start of a steam, gas or hydraulic driven turbine,” and instead
“connects to the power system through an electrical inverter,” do not experience “the failure
modes that impact the ability of turbine-driven resources.”11 And, though not specifically
addressed in the reliability rule, such resources “compl[y] with the original intent of the
synchronized reserve requirement and therefore shall qualify toward a [Balancing Authority’s] complement of synchronized reserve.”12 NPCC’s clarification will help guide the NYISO as it develops its energy storage resource participation model to comply with Order No. 841,13 and allow inverter-based energy storage resources currently participating in the NYISO’s markets to provide a service they are technically capable of providing.
III. Description of Proposed Tariff Revisions
Effectuating the proposed change to permit inverter-based energy storage resources to provide synchronized Operating Reserves requires minor modifications to the definition of “Operating Reserves” in the OATT and Services Tariff, and to the supplier eligibility criteria found in Services Tariff Section 15.4 (Rate Schedule 4). The NYISO also proposes two
ministerial changes that are not related to the substantive revisions proposed in this filing to OATT Section 1.12, and Services Tariff Section 2.19.
The NYISO proposes to amend parts (1) and (3) of the definition of “Operating
Reserves” in OATT Section 1.15 and in Services Tariff Section 2.1514 to permit Generators and Demand Side Resources using inverter-based energy storage technology to provide
Synchronized Reserves. The proposed changes to the OATT are set forth below.
11 Ne. Power Coordinating Council Task Force on Coordination of Operation, Response to NYISO Inquiry (2016).
12 Id. NPCC clarified, however, that inverter-based resources must meet the sustainability requirements requiring at least one hour of capability from the time of activation.
13 Electric Storage Participation in Markets Operated by Regional Transmission Organizations and Independent System Operators, Order No. 841, 162 FERC ¶ 61,127 (Feb. 15, 2018); Errata Notice (Feb. 28, 2018).
14 The definition of Operating Reserves in OATT Section 1.15 contains two minor differences from the Operating Reserves definition in Services Tariff Section 2.15. Existing language in OATT Section 1.15 contains a
typographical error in which the definition of Operating Reserves referred to “Rate Schedule 4 of this ISO Services Tariff,” (emphasis added). The NYISO proposes to correct OATT Section 1.15 to state “Rate Schedule 4 of the ISO Services Tariff” (emphasis added) in this filing. Similarly, the proposed revisions in OATT Section 1.15 state “that otherwise meet the eligibility criteria set forth in the ISO Services Tariff,” (emphasis added) whereas the revisions in Services Tariff Section 2.15 state “this ISO Services Tariff” (emphasis added).
Honorable Kimberly D. Bose March 29, 2018
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Operating Reserves:
(1) Spinning Reserve: Operating Reserves provided by Generators and Demand
Side Resources that meet the eligibility criteria set forth in Rate Schedule 4
of this the ISO Services Tariff, that are already synchronized to the NYS
Power System, and can respond within ten (10) minutes. Generators utilizing
inverter-based energy storage technology and that otherwise meet the
eligibility criteria set forth in the ISO Services Tariff may provide Spinning
Reserves. Spinning Reserves may not be provided by a Demand Side
Resources that are facilitates demand reduction using a Local Generators,
unless that Local Generator utilizes inverter-based energy storage
technology, or by Behind-the-Meter Net Generation Resources that are
comprised of more than one generating unit that are dispatched as a single
aggregate unit.
(3) 30-Minute Reserve: Synchronized Operating Reserves provided by
Generators, except Behind-the-Meter Net Generation Resources that are
comprised of more than one generating unit and dispatched as a single
aggregate unit, and Demand Side Resources that are do not facilitate demand
reduction using Local Generators, or that facilitate demand reduction using a
Local Generator utilizing inverter-based energy storage technology; or non-
synchronized Operating Reserves provided by Generators, Behind-the-Meter
Net Generation Resources that are comprised of more than one generating
unit and dispatched as a single aggregate unit, or Demand Side Resources
that meet the eligibility criteria set forth in Rate Schedule 4 of this ISO
Services Tariff and that can respond to instructions to change their output
level within thirty (30) minutes, including starting and synchronizing to the
NYS Power System.
The NYISO further proposes to revise Services Tariff Sections 15.4.1.2.1 and 15.4.1.2.3, which address Supplier eligibility criteria to provide Spinning and 30-Minute Reserve,
respectively, as follows:
Section 15.4.1.2.1: Suppliers that are ISO Committed Flexible or Self-
Committed Flexible, are operating within the dispatchable portion of their
operating range, are capable of responding to ISO instructions to change their
output level within ten minutes, and that meet the criteria set forth in the ISO
Procedures shall be eligible to supply Spinning Reserve (except for Demand
Side Resources that are Local Generators not utilizing inverter-based energy
storage technology and Behind-the-Meter Net Generation Resources that are
comprised of more than one generating unit and dispatched as a single
aggregate unit). Suppliers utilizing inverter-based energy storage
technology, and that meet the criteria set forth in the ISO Procedures, shall be eligible to supply Spinning Reserve.
Honorable Kimberly D. Bose March 29, 2018
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Section 15.4.1.2.3: Generators, except Behind-the-Meter Net Generation
Resources that are comprised of more than one generating unit and
dispatched as a single aggregate unit, that are ISO-Committed Flexible or
Self-Committed Flexible and operating within the dispatchable portion of
their operating range and Demand Side Resources that do not facilitate
demand reduction using, that are not Local Generators, or that facilitate
demand reduction using a Local Generator utilizing inverter-based energy
storage technology, that are capable of reducing their Energy usage within
thirty (30) minutes shall be eligible to supply synchronized 30-Minute
Reserves. Suppliers utilizing inverter-based energy storage technology, and
that meet the criteria set forth in the ISO Procedures, shall be eligible to
supply synchronized 30-Minute Reserves. (i) Off-line Generators that are
capable of starting, synchronizing, and increasing their output level within
thirty (30) minutes, (ii) Behind-the-Meter Net Generation Resources that are
comprised of more than one generating unit and dispatched as a single
aggregate unit that are capable of increasing their output level within thirty
(30) minutes, and (iii) Demand Side Resources that are capable of reducing
their Energy usage within thirty (30) minutes, that meet the criteria set forth
in the ISO Procedures shall be eligible to supply non-synchronized 30-Minute
Reserves.
These proposed revisions, if accepted, will benefit both bulk power system reliability and the wholesale markets administered by the NYISO. These revisions represent an incremental
step forward in the NYISO’s pursuit of full integration for energy storage resources, and will
provide system operators another tool to effectively manage New York’s bulk power system
during a Balancing Contingency Event. The revisions will also provide an additional market
participation opportunity for inverter-based energy storage resources seeking to obtain value for the services they can technically provide.
In addition to the proposed tariff enhancements for inverter-based energy storage
resources, the NYISO proposes to make two ministerial changes to OATT Section 1.12 and to Services Tariff Section 2.19. The revision to OATT Section 1.12 adds a new defined term— Local Generator—that references the definition found in Services Tariff Section 2.12. The
NYISO proposes to add this definition to the OATT because that term is used occasionally in the OATT, but is not defined therein. Adding the defined term will clarify that the term Local
Generator has the same meaning in the OATT and in the Services Tariff.
The NYISO also proposes to remove certain outdated language from the definition of SCR in Services Tariff Section 2.19:
Special Case Resource (“SCR”): Demand Side Resources whose Load is
capable of being interrupted upon demand at the direction of the ISO, and/or
Demand Side Resources that have a Local Generator, which is not visible to
Honorable Kimberly D. Bose March 29, 2018
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the ISO’s Market Information System and is rated 100 kW or higher, that can
be operated to reduce Load from the NYS Transmission System or the
distribution system at the direction of the ISO. Special Case Resources are
subject to special rules, set forth in Section 5.12.11.1 of this ISO Services Tariff
and related ISO Procedures, in order to facilitate their participation in the
Installed Capacity market as Installed Capacity Suppliers. SCRs that do not
use Local Generators may be offered as synchronous Operating Reserves and
Regulation Service and Energy in the Day-Ahead Market. SCRs, using Local
Generators rated 100 kW or higher, that are not visible to the ISO’s Market
Information System may also be offered as non-synchronized Operating
Reserves.
The NYISO proposes to remove the stricken language to avoid confusion related to the services SCRs provide. A SCR is a particular type of Demand Side Resource that supplies
Installed Capacity. Demand Side Resources may also supply Ancillary Services by participating in the NYISO’s Demand Side Ancillary Services Program (“DSASP”). While a single Demand Side Resource may simultaneously be a SCR and a DSASP resource, not all SCRs are DSASP resources. The NYISO proposes to remove the final two sentences of the SCR definition to
avoid confusion as to the services SCRs provide.
IV.Proposed Effective Date
The NYISO respectfully requests that the Commission accept the proposed tariff
revisions for filing with an effective date of May 30, 2018, the day following the close of the sixty-day period.
V.Requisite Stakeholder Approval
The proposed amendments were approved by the NYISO Management Committee on October 25, 2017 by a show of hands with no votes in opposition. The NYISO’s Board of Directors approved the proposed revisions on February 13, 2018.
Honorable Kimberly D. Bose March 29, 2018
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VI.Communications and Correspondence
All communications and service in this proceeding should be directed to:
Robert E. Fernandez, General Counsel
Raymond Stalter, Director, Regulatory Affairs *Gregory J. Campbell, Attorney
10 Krey Boulevard
Rensselaer, NY 12144
Tel:(518) 356-8540
Fax:(518) 356-7678
gcampbell@nyiso.com
*Person designated for receipt of service.
VII.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.
VIII. Conclusion
For the foregoing reasons, the NYISO respectfully requests that the Commission accept for filing the proposed revisions to the Services Tariff and the OATT that are attached, with the changes becoming effective on the date specified in part IV of this filing letter.
Respectfully submitted,
/s/ Gregory J. Campbell
Gregory J. Campbell Attorney
New York Independent System Operator, Inc.
cc:Anna CochraneLarry Parkinson
Jette GebhartJ. Arnold Quinn
Kurt LongoDouglas Roe
David MorenoffKathleen Schnorf
Daniel NowakGary Will
