October 18, 2018
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., Docket No. ER19-____-000;
Proposed Revisions to the Requirements for Reporting Historic Congestion
Data
Dear Secretary Bose:
In accordance with Section 205 of the Federal Power Act1 and Part 35 of the regulations of the Federal Energy Regulatory Commission (“Commission”), the New York Independent
System Operator, Inc. (“NYISO”) submits proposed revisions to Appendix A of Attachment Y to its Open Access Transmission Tariff (“OATT”) that modify the requirements for reporting
historic congestion data.2
The NYISO Management Committee approved the proposed revisions, without
opposition, on July 25, 2018. The NYISO respectfully requests that the proposed revisions
become effective on December 18, 2018 (i.e., the day following the end of the statutory 60-day notice period).
I.Documents Submitted
The NYISO respectfully submits the following documents with this filing letter:
1.A clean version of the proposed revisions to the OATT (“Attachment I”); and
2.A blacklined version of the proposed revisions to the OATT (“Attachment II”).
II.Background
In connection with its Comprehensive System Planning Process, Appendix A of
Attachment Y to the OATT requires the NYISO to report certain information regarding historic
1 16 U.S.C. § 824d.
2 Capitalized terms not otherwise defined herein shall have the meaning specified in the OATT.
Honorable Kimberly D. Bose October 18, 2018
Page 2
congestion in the New York Control Area (“NYCA”).3 This reporting requirement predates the NYISO’s economic planning process implemented in response to Order No. 890.4
While certain information required to be reported derives from actual Day-Ahead Market outcomes, the current requirements also obligate the NYISO to develop and report information related to a hypothetical system condition that is completely devoid of transmission constraints (often referred to as a “copper sheet”). The NYISO proposes to modify the current reporting
requirements to: (1) retain and enhance the reporting of information from actual Day-Ahead
Market outcomes; and (2) eliminate the production and reporting of information based on a
hypothetical unconstrained system.
III.Description of the Proposed Tariff Revisions
Reporting of historic congestion data provides meaningful information to the marketplace
regarding actual system conditions, including patterns and trends of persistently constrained
locations. However, the extremely low likelihood of achieving a completely unconstrained
system in New York calls into question the value to the marketplace of reporting information
related to such a hypothetical system condition. Further, data related to a hypothetical
unconstrained system does not provide information that would meaningfully inform the
evaluation of any transmission project proposal submitted as part of the NYISO’s economic
planning process.
Production of data and information related to a hypothetical unconstrained transmission system requires a commitment of significant time and resources by the NYISO. The current tool utilized to produce this data is a user-developed application built in 2005. This tool is not
automated, thereby requiring a significant level of manual user actions to produce the required data and information, including data collection, data compilation, and data entry. The tool is also not supported or otherwise maintained as part of the NYISO’s overall corporate information
technology infrastructure. As a result, the NYISO’s continued ability to accurately, reliably, and timely produce such hypothetical system data and information requires the development of a
fully supported and maintained automated software solution.
In light of the relatively limited value provided to the marketplace by the currently
required data and information related to a hypothetical unconstrained system, instead of
undertaking the development of an automated software solution, the NYISO proposes to modify
the current historic congestion reporting requirements to focus solely on providing data and
3 See, e.g., Docket No. ER04-1144-000, New York Independent System Operator, Inc., Filing of Comprehensive Reliability Planning Process and Related Agreement (August 20, 2004); and New York Independent System Operator, Inc., 109 FERC ¶ 61,372 (2004).
4 See, e.g., Docket No. OA08-52-000, New York Independent System Operator, Inc., Order No. 890 Transmission Planning Compliance Filing (December 7, 2007); New York Independent System Operator, Inc., 125 FERC ¶ 61,068 (2008); New York Independent System Operator, Inc., 129 FERC ¶ 61,044 (2009); New York Independent System Operator, Inc., 132 FERC 61,028 (2010); and New York Independent System Operator, Inc., 132 FERC ¶ 61,188 (2010).
Honorable Kimberly D. Bose October 18, 2018
Page 3
information resulting from actual market conditions. This would allow the NYISO to prudently avoid the unnecessary costs and resource commitments that would otherwise be incurred to
continue producing data related to a hypothetical unconstrained system. In doing so, the NYISO also proposes to enhance the historic congestion information provided to the market by
expanding the congestion metrics reported. The expanded reporting will provide additional
information regarding the congestion cost to consumers of the actual binding transmission
constraints that arise in the Day-Ahead Market.
Enhanced reporting of actual historic congestion data in combination with the forward-
looking projections of system congestion produced as part of the NYISO’s economic planning
process should yield a meaningful and informative dataset that provides greater value to the
market. This information should continue to help market participants identify trends and patterns of system congestion. This dataset should also continue to assist project developers in evaluating potential system upgrades that could address such congestion and identifying the appropriate
locations where such upgrades may provide the greatest benefit in reducing congestion costs
and/or improving system operability.
The NYISO proposes to revise Sections 2.0 and 5.0 of Appendix A of Attachment Y to the OATT to more clearly identify the data and information related to actual Day-Ahead Market congestion that will be reported on a going forward basis. The information to be provided
includes: (1) Locational Based Marginal Price (“LBMP”) costs to Load by Load Zone,
disaggregated into the three components of LBMPs (i.e., the marginal energy component,
Congestion Component, and Marginal Losses Component); (2) LBMP payments to suppliers by Load Zone, disaggregated into the three components of LBMPs; (3) total congestion cost of each binding transmission constraint; and (4) the congestion costs to Load for each binding
transmission constraint. The proposed revisions also eliminate the requirement to develop data and information related to a hypothetical unconstrained system.
The NYISO proposes to begin utilizing the revised reporting requirements for 2018 data. The historic congestion data and information for 2018 will be developed and posted to the
NYISO’s website in early 2019.
IV.Effective Date
The NYISO respectfully requests that the proposed tariff revisions become effective on December 18, 2018 (i.e., the day following the end of statutory 60-day notice period).
V.Requisite Stakeholder Approval
The proposed tariff amendments were approved, without opposition, by the NYISO Management Committee on July 25, 2018. The NYISO’s Board of Directors approved the proposed revisions on October 16, 2018.
Honorable Kimberly D. Bose October 18, 2018
Page 4
VI.Communications and Correspondence
Please direct all communications and service in this proceeding to:
Karen Georgenson Gach, Acting General Counsel Raymond Stalter, Director, Regulatory Affairs *Garrett E. Bissell, Senior Attorney
10 Krey Boulevard
Rensselaer, New York 12144
Telephone: 518-356-6107
Email: gbissell@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, each participant on its stakeholder committees, the New York State Public
Service Commission, and the New Jersey Board of Public Utilities. The NYISO will also post
the complete filing on its website at www.nyiso.com.
VIII.Conclusion
The NYISO respectfully requests that the Commission accept the proposed revisions to the OATT attached hereto with an effective date of December 18, 2018.
Respectfully submitted,
/s/ Garrett E. Bissell
Garrett E. Bissell
Senior Attorney
New York Independent System Operator, Inc.
cc:Nicole Buell
Anna Cochrane
James Danly
Jignasa Gadani
Jette Gebhart
Kurt Longo
David Morenoff
Daniel Nowak
Larry Parkinson
Douglas Roe
Kathleen Schnorf Gary Will