10 Krey Boulevard Rensselaer, NY 12144
August 16, 2010
ELECTRONICALLY SUBMITTED
Kimberly D. Bose
Secretary
Federal Energy Regulatory Commission 888 First Street, N.E.
Washington, D.C. 20426
Re: New York Independent System Operator, Inc.’s Response to Questions and Supplemental
Report on Broader Regional Markets; Long-Term Solutions to Lake Erie Loop Flow;
Docket No. ER08-1281-___.
Dear Secretary Bose:
In accordance with ordering paragraph “B” of the Federal Energy Regulatory Commission’s
(“Commission’s”) July 15, 2010 Order on Compliance Filing in Docket No. ER08-1281-004 (“July
Order”),1 the New York Independent System Operator, Inc. (“NYISO”), hereby submits this Response to Questions and Supplemental Report on Broader Regional Markets; Long-Term Solutions to Lake Erie Loop Flow (“Response”). Ordering paragraph “B” of the July Order instructs the NYISO to respond to a series of seventeen questions posed by the Commission.
The text answers to the Commission’s specific questions are set forth in Section III of this
Response. The NYISO submits as electronic “attachments” to this filing letter the documents it is
producing in response to the Commission’s questions. In addition to responding to the Commission’s questions, in Section II of this Response the NYISO provides a brief overview of the progress that has been made in developing the Broader Regional Market solutions since it filed its last formal report with the Commission on July 12, 2010.
The NYISO would like to take this opportunity to thank the participating ISOs and RTOs, their
Boards of Directors2 and their stakeholders for complying with both the letter and spirit of the
Commission’s encouragement that “all interested parties … pursue a constructive, workable consensus
addressing these matters as expeditiously as possible.”3 The progress that has been achieved in the
ongoing effort to develop a comprehensive set of market solutions would not be possible if entities like
PJM Interconnection (“PJM”), the Midwest Independent Transmission System Operator, Inc. (“Midwest
ISO”) and Ontario Independent Electricity System Operator (“IESO”) did not continue to shoulder a
1 New York Independent System Operator, Inc., 132 FERC ¶ 61,031.
2 The Boards of Directors of the various ISOs and RTOs have taken an active interest in ensuring the timely development of effective solutions to Lake Erie loop flow.
3 July Order at P. 6.
Federal Energy Regulatory Commission Hon. Kimberly D. Bose
August 16, 2010
Page 2
significant share of the burden. The NYISO hopes and expects that the cooperative effort that has
permitted the ISOs and RTOs to expeditiously develop the Broader Regional Market solutions that are
described in this Report and detailed in the white papers that are attached hereto, will continue until all of the solutions described in this report have been fully implemented.
I.Documents Submitted
1.This Response;
2.Preliminary Results of Analysis of the Broader Regional Markets Initiatives, prepared by
Dr. David Patton of Potomac Economics and dated April 21, 2010, a component of the NYISO’s response to Question No. 2 (“Attachment A”);
3. Analysis of the Broader Regional Market Initiatives, prepared by Dr. David Patton of
Potomac Economics and dated June 2010, a component of the NYISO’s response to Question No. 2 (“Attachment B”);
4. Long Term Solutions to Loop-Flow Concerns—Issue Background, prepared by Robert Pike
(NYISO) and dated December 16, 2008, a component of the NYISO’s response to Question No. 10 (“Attachment C”);
5. Long Term Solutions to Loop-Flow Concerns—Contract Sink Pricing, prepared by Robert
Pike (NYISO) and dated February 6, 2009, a component of the NYISO’s response to Question No. 10 (“Attachment D”);
6. Buy-Through of Congestion, prepared by Robert Pike (NYISO) and dated July 8, 2009, a
component of the NYISO’s response to Question No. 10 (“Attachment E”);
7.Broader Regional Market—Interface Pricing Revisions, prepared by Robert Pike (NYISO)
and dated January 5, 2010, a component of the NYISO’s response to Question No. 11
(“Attachment F”);
8.Broader Regional Market—Interface Pricing Revisions, prepared by Robert Pike (NYISO)
and dated April 12, 2010, a component of the NYISO’s response to Question No. 11
(“Attachment G”);
9.Broader Regional Market—Interface Pricing Revisions, prepared by Robert Pike (NYISO)
and dated May 24, 2010, a component of the NYISO’s response to Question No. 11
(“Attachment H”); and
10.Broader Regional Market—Interface Pricing Revisions, prepared by Robert Pike (NYISO)
and dated June 2, 2010, a component of the NYISO’s response to Question No. 11
(“Attachment I”).
Federal Energy Regulatory Commission Hon. Kimberly D. Bose
August 16, 2010
Page 3
II.Summary of Proposed Broader Regional Market Solutions
A.Introduction
The NYISO, IESO, PJM and Midwest ISO have continued to work collaboratively to jointly
develop the concepts proposed in the NYISO’s January 12, 2010 report, including (i) Buy-Through
Congestion, (ii) Market-to-Market Coordination, (iii) Interface Pricing Revisions, and (iv) Enhanced
Interregional Transaction Coordination. The members of the inter-ISO/RTO design groups have
expanded to capture the necessary expertise to address the complexity of the initiatives and produce the necessary additional design details. The groups have hosted weekly conference calls and two multi-day site visits dedicated to further refining the initiatives and addressing the complexities of their
implementations. Each organization continues to provide regular status updates to their respective
stakeholders on the progress being made.4
In addition, the NYISO engaged its Market Monitoring Unit, Potomac Economics, to prepare an
analysis of the potential benefits to the collective markets that may be achieved through the
implementation of these initiatives. Preliminary estimates were presented to the NYISO’s Management
Committee on April 21, 2010. The preliminary estimate is submitted as Attachment A to this Response.
Potomac Economics subsequently completed its final estimate, which is submitted as Attachment B to
this Response. The final analysis indicates a total potential regional annual benefit of over $362 million
in fuel-adjusted production cost savings. Dr. Patton of Potomac Economics will present the findings at
the upcoming Broader Regional Markets technical conference that PJM is hosting on September 27, 2010
in Philadelphia, Pennsylvania.
B.Interface Pricing Revisions
The NYISO has worked with its Market Participants to develop and receive approval for revisions
to the LBMP calculation method. The new method will recognize the physical distribution of flow
around Lake Erie (including parallel flows) when determining the impact that all resources, including
internal generation and external interchange, have on transmission constraints. As explained in greater
detail in response to the Commission’s questions, the NYISO and its stakeholders propose to maintain the
existing Commission approved path validation process preventing circuitous path scheduling until such
time as the effectiveness of the physical and market solutions to loop flow have been demonstrated. The
revised LBMP calculation method is designed to apply to the existing network configuration—without the
availability of PARs to match actual power flows to schedules at the Ontario - Michigan border. The
design was approved, in concept, by the NYISO Business Issues Committee on June 6, 20105 and is being
4 PJM provides updates to its Markets and Reliability Committee, Midwest ISO provides updates to its Market Subcommittee, IESO provides updates to its Stakeholder Advisory Subcommittee, and the NYISO provides updates to its Business Issues Committee and/or to its Market Issues Working Group.
5 See http://www.nyiso.com/public/webdocs/committees/bic/meeting_materials/2010-06-
02/Agenda_09_BIC_Interface_Price_Revisions.pdf
Federal Energy Regulatory Commission Hon. Kimberly D. Bose
August 16, 2010
Page 4
incorporated into the NYISO’s project implementation schedule. The NYISO currently estimates a Q3 2011 implementation timeframe.
The broader inter-ISO/RTO design group has discussed several possible methods of adjusting LBMP calculation methods if the PAR controls on the Ontario - Michigan border are implemented and determined to be effective at conforming actual power flows to schedules.
C.Regional PAR Coordination
As the NYISO explained in the January 12, 2010 Report, coordinated operation of the PARs in the
four markets around Lake Erie can enhance the degree to which circulation flows are managed and avert
instances where regional PARs could work at cross-purposes. To this end, a regional study was recently
initiated to identify PARs and other controllable devices that are capable of influencing Lake Erie loop
flows and to study the potential reliability and market impacts of better coordinated operation. This study
will also identify significant regional paths or flowgates impacted by Lake Erie loop flows.
The four markets have agreed that the Midwest ISO will lead this regional effort. Each market has a representative participating in the study. A kick off meeting was held in August, 2010. A draft scoping document, to be refined by the regional team, includes the following steps:
• Identify the set of PARs, variable frequency transformers, series capacitors and other such
devices that have the ability to alter flows around Lake Erie and should be included in the
coordination process
• Identify the operating characteristics of each of device
• Identify how operations of the devices impact Lake Erie loop flow including:
o the flowgates around Lake Erie that are impacted by each device
o the appropriate method(s) of incorporating the operation of controllable devices into
the Interchange Distribution Calculator
o the appropriate method(s) of representing the operation of controllable devices in the
markets around Lake Erie
• Develop a comprehensive operating guide among the four parties that coordinates the
operation of the power control devices around Lake Erie.
Federal Energy Regulatory Commission Hon. Kimberly D. Bose
August 16, 2010
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D.Parallel Flow Visualization Tool
The Parallel Flow Visualization Tool is intended to provide improved visibility to the origins of transmission system power flows. The North American Electric Reliability Company (“NERC”)
Interchange Distribution Calculator Working Group (“IDCWG”) has led the efforts to develop an
improved Parallel Flow Visualization Tool to enhance the existing Interchange Distribution Calculator and has been coordinating with the industry and Open Access Technologies, Inc. (“OATi”) to produce the necessary system requirement documentation and desired functionality.
All of the ISOs and RTOs are engaged in internal development efforts to meet the enhanced data
reporting requirements needed to provide the Parallel Flow Visualization Tool with the necessary input
data. The NYISO continues to support a schedule that will allow the Parallel Flow Visualization Tool to
achieve its milestone and enter a parallel operations mode by the fourth Quarter of 2010. In addition to
satisfying multiple NERC expectations, the results of the effort will be the fundamental determinant in the
establishment of a broader Market-to-Market coordination effort among the ISOs and RTOs. The
importance of the Parallel Flow Visualization Tool to the Broader Regional Market effort is addressed in the NYISO’s responses to the Commissions questions.
To support the Parallel Flow Visualization Tool development effort, the ISOs and RTOs continue
to work with the North American Electric Standards Board’s (“NAESB”) Business Practices
Subcommittee to develop a standard for the reporting of the transmission service priorities for the
elements of system flows. These priorities will be used in the NERC TLR process to determine
curtailment priority. The Business Practices Subcommittee is currently working on an interim solution to
facilitate a November 1, 2010 deadline for placing the Parallel Flow Visualization Tool into a parallel
operations mode.
E.Buy-Through of Congestion
Buy-Through of Congestion recognizes the financial impacts created by parallel flows. The joint ISO/RTO design team has continued to work through the details of implementing the provisions of a BuyThrough of Congestion protocol and the impacts the protocol will have on NERC standards and Market Participant scheduling and settlement interactions. The ISOs and RTOs have scheduled a technical
conference for September 27, 2010 in Philadelphia, Pennsylvania to review the proposal, as it currently stands, with stakeholders. The ISOs and RTOs anticipate that each ISO and RTO will then discuss the Buy-Through of Congestion proposal within their individual stakeholder processes.
Consistent with comments received from stakeholders, the ISOs and RTOs have determined that
the Buy-Through of Congestion solution must be coordinated with the NERC Transmission Loading
Relief (“TLR”) protocol in order to be able to fully implement the needed rules and achieve desired
efficiencies. In order to coordinate Buy-Through of Congestion with TLR, some changes to the existing
TLR protocol may be necessary, including the ability to purchase an improved quality of transmission
service—Buy-Through of Congestion service—for the parallel flow impact. The ISOs and RTOs
reviewed the Buy-Through of Congestion concepts with the NERC Operating Reliability Subcommittee
Federal Energy Regulatory Commission Hon. Kimberly D. Bose
August 16, 2010
Page 6
(“ORS”) at their May 5-6, 2010 meeting6 and were instructed by the group to work with the NERC
IDCWG to “review the BTC concepts and estimate the IDC enhancements needed.” The ISOs and RTOs
anticipate engaging the IDCWG in these discussions after Market Participants have had an opportunity to
review and weigh-in on the proposed design. Implementation of Buy-Through of Congestion will require
tariff changes within each ISO or RTO, and potentially new joint operating agreements between the ISOs
and RTOs.
F.Market-to-Market Coordination
Market-to-Market Coordination is intended to more cost effectively utilize the region’s collective
assets to address constraints across multiple systems, resulting in lower congestion costs to consumers,
and provide a more consistent pricing profile across markets. The scope of this effort is to extend the
benefits achieved through the existing PJM-Midwest ISO agreement to additional borders. This effort is
dependent on the implementation of NERC’s Parallel Flow Visualization Tool. Once the Parallel Flow
Visualization Tool begins generating meaningful data it will become possible to perform an informed
review of the relative impacts of parallel flows on neighboring ISO and RTOs systems. At that time, the
ISOs and RTOs will resume discussions on the implementation and establishment of flowgate
entitlements. Market-to-Market Coordination is discussed in greater detail in the NYISO’s responses to the Commission’s questions.
G.Ontario-Michigan PAR Instillation
A forty six day transmission line outage to allow for the installation of a communication link to support relaying and communication requirements associated with the PARs was recently completed. Installation of this communication link will support subsequent relay and operational testing required prior to energizing the PARs.
In addition to the testing tasks, the Midwest ISO is coordinating regulatory, modeling, pricing, and software tasks with ITC, IESO, NYISO and PJM. Completion of these tasks include gaining an
understanding of how the PARs will be operated under several expected operational scenarios, and is
required prior to placing the PARs in service.
It is anticipated that completion of the tasks necessary to permit ITC’s PARs to enter service will occur during the fourth quarter of 2010.
6 See http://www.nerc.com/docs/oc/ors/ORS_Agenda_5-6May-10.pdf
Federal Energy Regulatory Commission Hon. Kimberly D. Bose
August 16, 2010
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H. Enhanced Interregional Transaction Coordination
The NYISO continues to work with its Market Participants to complete the Enhanced
Interregional Transaction Coordination design details. Numerous discussions have occurred within the NYISO Stakeholder process to review the necessary market rule changes. Additionally, the NYISO has begun its process of preparing proposed updates to its Tariffs to accommodate the changes that will be necessary to implement Enhanced Interregional Transaction Coordination. The NYISO anticipates filing the proposed Tariff revisions in the fourth quarter of 2010.
The NYISO is working with both Hydro Quebec TransEnergie and PJM to develop appropriate
operating procedures and address any reliability concerns. The NYISO and ISO-NE have also initiated
discussions, with the objective of improving the efficiency of transaction scheduling at their shared
border.
III.NYISO’s Responses to the Commission’s Broader Regional Market Questions
A.Buy-Through of Congestion
1.The NYISO Report provides a chart, at Attachment C, p. 52, showing how the different
RTOs and ISOs will manage congestion cost exposure in the day-ahead market. Please
provide a comparison of the NYISO’s transaction modeling methodologies for intra-
NYISO transactions and for transactions between the NYISO and its neighboring RTOs
and ISOs.
Internal Bilateral Transactions: Transactions that source and sink in the New York Control Area
(“NYCA”) are called internal Bilateral Transactions. They are financial transactions that assign financial responsibility for the cost of congestion and losses between two locations to a particular Market
Participant. These transactions do not create/modify any scheduling decisions or affect any modeled scheduled or actual power flows within the NYISO’s Day Ahead or Real-Time Markets. Internal
Bilateral Transactions are not considered in the economic scheduling evaluation, and are implemented without consideration of the cost of congestion and losses between the end-points.
External Transactions: External Transactions requested by Market Participants seek to flow power
between the NYISO and one of its neighboring Control Areas. External transactions requests are used by the Day Ahead and Hour-Ahead Market tools to determine the scheduled flow between the NYISO and its neighbors based upon the economic bid or offer associated with the request and the prevailing system
prices. Like Internal Bilateral Transactions, the cost of congestion and losses components of an Import
Bilateral Transactions are financially binding, regardless of the economic scheduling outcome of the
associated Energy transaction.
The only Real-Time scheduling decisions made regarding Transactions applies to non-firm transmission
service, which indicates that the Market Party is not willing to pay congestion within the NYISO market
Federal Energy Regulatory Commission Hon. Kimberly D. Bose
August 16, 2010
Page 8
design. If congestion is encountered along the path of a non-firm transaction, real-time actions will be taken to remove (curtail) the transaction schedule.
One of the proposed Broader Regional Market enhancements that the NYISO and its neighboring Control
Areas are working on is the evaluation and scheduling of interchange transactions as frequently as every
five or fifteen minutes, instead of only once an hour. This enhancement will give Market Participants the
ability to more effectively manage risk through the ability to self-curtail transactions on a more frequent
basis, thereby reducing exposure to parallel path congestion charges. In addition, Market Participants will
have the ability to schedule counter-flow on a more frequent basis in order to reap the financial benefits of
relieving congestion.
Products are available within the NYISO marketplace to hedge potential congestion cost exposures
associated with NYISO secured facilities. Transmission Congestion Contracts (“TCCs”),7 provides the
right to collect, or the obligation to pay, Congestion Rents in the Day-Ahead Market for Energy
associated with transmission between a specified Point of Injection (“POI”) and Point of Withdrawal
(“POW”). TCCs are financial instruments that enable Energy buyers and sellers to hedge fluctuations in
the price of transmission congestion. Virtual Transactions (Virtual Load and Virtual Supply) allow users
to purchase Day-Ahead congestion hedges against real-time cost exposures at pre-defined NYISO LBMP
locations. The NYISO intends to expand the locations and granularity at which Virtual Transactions will
be offered in the future.
In addition to the currently available products to manage congestion cost exposure, the NYISO is
evaluating the potential to offer a real-time congestion hedging product. This product is under
consideration within the NYISO stakeholder budget development process to consider the desirability and
feasibility of offering this new capability. A real-time congestion hedge would allow Market Participants
to submit virtual Bids into the Day-Ahead Market based on the difference in congestion costs between
any two points that are eligible for virtual trading. The difference in congestion costs between the two
points would be purchased (or sold) in the Day-Ahead Market and then sold (or purchased) in the real-
time market. This would improve the hedging options available to Market Participants once Buy-
Through of Congestion has been implemented.
2. Please provide copies of all studies performed by, or for, the NYISO regarding the
impact of the buy-through of congestion proposal within the NYISO and in its neighboring RTOs and ISOs.
Submitted with the NYISO’s filing as Attachments A and B are a pair of analyses summarizing the
potential market efficiency benefits to be achieved through the implementation of the Broader Regional
Market initiatives, prepared by David Patton, Ph. D., of Potomac Economics. The first analysis dated
7 Capitalized terms that are not defined in these responses have the meaning ascribed to them in the NYISO’s Market Administration and Control Area Services Tariff.
Federal Energy Regulatory Commission Hon. Kimberly D. Bose
August 16, 2010
Page 9
April 21, 2010 contains the preliminary results determined by Dr. Patton. It was presented to the
NYISO’s Management Committee. The second analysis, dated June 2010, incorporates Dr. Patton’s final updated results. It will be presented at the joint stakeholder technical conference that PJM
Interconnection (“PJM”) is hosting at the Loews Hotel in Philadelphia on September 27, 2010.
The NYISO is also working with Potomac Economics to assess the impact to the economic viability and risk exposure of historic IESO-MISO-PJM transactions with the application of a NYISO Buy-Through of Congestion charge. The proposed charge will provide a greater level of security for External Transactions that have parallel flow impacts than is currently afforded External Transactions under the existing
Transmission Loading Relief methodology.8 The NYISO intends to have the analysis complete and
available for discussion at the joint stakeholder technical conference on September 27, 2010, and will provide a copy of that analysis to the Commission at that time.
3. The NYISO Report states, at Attachment A, p. 18, that “[a]ctual experience has not
shown the need for an up-to congestion product to be necessary if there is adequate
real-time price transparency around price differences.” With respect to this statement, please explain: (i) the experience the NYISO has had, to date, with buy-through of congestion; (ii) why an “up-to” component is undesirable; and (iii) whether the NYISO would support the adoption of an “up to” approach for the buy through of congestion (and if not, why not), assuming the majority of stakeholders in the NYISO’s
neighboring RTOs and ISOs favor such an approach.
(i) NYISO’s experience with buy-through of congestion to-date;
For Import, Export and Wheel-Through transactions, NYISO Market Participants may chose to request Firm Transmission Service or Non-Firm Transmission Service from or to the NYCA border(s). The
designation of “Firm” indicates that the Market Participant is willing to pay for some quantity of
congestion within the NYCA, while a “Non-Firm” designation indicates that a Market Participant is not willing to pay any congestion-related costs in order to get its External Transaction scheduled. If
scheduled, a Non-Firm transaction will be curtailed in-hour should (any) congestion occur. A Non-Firm transaction is the only type of transaction that the NYISO curtails in-hour based on economics. Market Participants rarely submit Non-Firm transaction bids and offers because congestion is common on the NYISO system, so Non-Firm transactions are rarely scheduled.
In the Day-Ahead and Real-Time Markets, Market Participants can specify maximum and minimum source and sink prices in their External Transaction bids and offers. In the Day-Ahead Market,
transactions are selected and settled based on these bids and offers. In the Real-Time Market, bids and offers are selected based on the hour-ahead evaluation, but are settled at real-time prices that may differ from the results of the evaluation that scheduled an External Transaction.
8 See North American Energy Standards Board (“NAESB”) WEQ-008-2.3.
Federal Energy Regulatory Commission Hon. Kimberly D. Bose
August 16, 2010
Page 10
The only form of “up-to” bidding available in the NYISO is for Wheels-Through transactions, which may specify in their bid the level of congestion charges they are willing to be exposed to. An evaluation of Wheel-Through bids based on expected system conditions occurs in the NYISO’s Day-Ahead and hourahead markets. Wheels-Through are scheduled based on these evaluations. Once a Wheel-Through has been scheduled, the scheduling party is financially responsible for any change in real-time system
conditions that affect the congestion costs assessed to the Wheel-Through transaction.
(ii) why an “up-to” component is undesirable;
The NYISO agrees with the comments that Potomac Economics submitted on February 2, 2010.
Forecasting congestion for a subsequent hour is subject to considerable uncertainty. Such forecasts are
likely not sufficiently accurate to support “up-to” bidding at this time because the ISOs and RTOs will not
be able to instantaneously remove these transactions when an up-to congestion bid is exceeded in a
parallel path control area. If the ISOs and RTOs hold some scheduling Market Participants harmless to
their up-to bids, then unexpected events that create market volatility could lead to substantial uplift costs
when actual congestion costs exceeded the “up-to” bids of transactions, since it is not possible to
immediately evaluate and remove the uneconomic transactions.9 Effectively, using an “up-to” component
would move the risk from the entity that scheduled an External Transaction to the entities that are
responsible for covering uplift in each market (which are primarily load serving entities in New York).
Entities that did not participate in the decision to schedule an External Transaction would be made
financially responsible for insulating the scheduling Market Participant from the market risk associated
with its External Transaction. The NYISO believes that the better choice is to place the risk on the entity
that is scheduling an external transaction that has potential parallel path impacts.
Currently, none of the ISOs or RTOs around Lake Erie offer an “up to” product for real-time interchange transactions. A Market participant may make a real-time decision as to its willingness to pay, or not to pay, for congestion within a market area for a transaction in the NYISO and PJM markets. In the NYISO, transactions that are not willing to pay real-time congestion must be designated as Non-Firm. It is not possible to specify an “up to” bid outside the transaction scheduling horizon.
The NYISO is developing the ability to schedule External Transactions on a more frequent basis than the
current hourly schedules. This will give Market Participants the ability to more effectively manage risk
through the ability to self-curtail transactions on a more frequent basis, thereby reducing exposure to
parallel path congestion charges. In addition, Market Participants will have the ability to schedule
counter-flow on a more frequent basis in order to reap the financial benefits of relieving congestion.
9 Under ideal circumstances, it can take from 15 to 30 minutes to remove a transaction using current NERC TLR procedures. Substantial congestion and resulting uplift can occur during this period of time.
Federal Energy Regulatory Commission Hon. Kimberly D. Bose
August 16, 2010
Page 11
(iii) whether the NYISO would support the adoption of an “up to” approach for the
buy through of congestion (and if not, why not), assuming the majority of
stakeholders in the NYISO’s neighboring RTOs and ISOs favor such an approach.
The NYISO does not support the adoption of an “up to” approach for Buy-Through of Congestion because, as explained above, adopting “up to” will transfer market risk from the entities scheduling External Transactions to the entities in the markets around Lake Erie that are responsible for covering uplift, including load serving entities in New York State.
B.Congestion Management/Market-to-Market Coordination
4.The NYISO Report states, at Attachment A, pp. 34-45, that firm flow entitlements will
be based on expected usage and the location of flowgate capacity. With respect to this
statement, please describe: (i) how the initial flow entitlements will be determined; (ii)
whether the initial determination will be used in the settlement process; and (iii) what, if
any, alternative methods the NYISO has considered for establishing the initial flow
entitlements.
The initial focus of the Market-to-Market Coordination expansion was to develop a protocol between the
NYISO and PJM, based upon the existing PJM and Midwest Independent Transmission System Operator,
Inc. (“Midwest ISO”) joint operating agreement. As such, the previous conversations on this topic have
been between NYISO and PJM, and focused on a new two party arrangement. More recently, discussions
regarding the potential to expand the protocol to include Midwest ISO have occurred; including whether
to develop a pair of bilateral agreements, or to draft a three-party arrangement. For purposes of
responding to this question from the Commission, the NYISO recaps the discussions that have previously occurred with PJM.
The NYISO and PJM are in the process of determining how the initial flow entitlements for the reciprocal
coordinated flowgates will be established. In order to evaluate the appropriateness of the methods that are
under consideration, a representative sample of historical flow impacts must be assembled to test each
method and consider the impacts of choosing a particular method. The NYISO and PJM have spent
considerable time discussing and understanding the method that is employed to perform the flow impact
calculations utilized in the PJM and Midwest ISO market-to-market coordination protocol. Because
similar tools to perform the necessary calculations did not exist within the NYISO infrastructure, both
PJM and the NYISO agreed to leverage the North American Electric Reliability Company (“NERC”)
Parallel Flow Visualization initiative, rather than incur the cost of developing new, potentially redundant,
NYISO or PJM-specific applications. The Parallel Flow Visualization Tool, which is being developed
under NERC’s oversight, is expected to provide not only the necessary flow impact data, but also to offer
a single, common, transparent, auditable and archived method of supporting the implementation of
Market-to-Market Coordination. Past experience has demonstrated the complexities associated with the
Federal Energy Regulatory Commission Hon. Kimberly D. Bose
August 16, 2010
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market-to-market solution implementation, and both parties agreed this open architecture solution provided a beneficial outcome.
At this time, the NYISO anticipates that the settlement protocol employed within the PJM/Midwest ISO
market-to-market coordination protocol would be largely maintained. Under this protocol, an ISO or
RTO’s actual real-time flow impacts on a neighboring system, relative to that ISO or RTO’s entitlement
to that system, will prescribe the amount and direction of the financial settlement between the parties.
The NYISO prefers the determinants of the settlements to be driven by the Parallel Flow Visualization
calculation for the reasons noted above (reciprocal, transparent, auditable, etc.). Validation and
verification of the applicability of the Parallel Flow Visualization Tool calculations and processes to the purpose that NYISO and PJM propose are necessary prerequisites to implementing Market-to-Market
Coordination.
In addition to historical flow driven entitlements, the NYISO and PJM have also discussed (i) day-ahead schedule defined flow impacts, (ii) real-time actual flow defined flow impacts, and (iii) pre-defined
bandwidths of allowable flow impacts. It is the NYISO's and PJM's intention to evaluate the potential
methods using a representative data sample, and to move forward with the joint agreement including
defining flow entitlements.
5. The NYISO Report states, at p. 10 and Attachment A, p. 28, that the proposed
congestion management/market-to-market coordination solution is similar to the
initiative developed by PJM and the Midwest ISO. With respect to this statement,
please explain the differences between the NYISO’s proposal and the market-to-market coordination program used by PJM and Midwest ISO. Include a discussion of how each program does (or will) affect the need, frequency and/or magnitude of
transmission loading relief (TLR) events.
The NYISO has identified three areas in which a NYISO/PJM implementation may deviate from the
existing solution between PJM and the Midwest ISO. These include: (i) establishment of firm flow
entitlements, (ii) source data for settlement determinants, and (iii) congestion cost price intervals. The
efforts to develop entitlements and selection of a data source for settlements are described more fully in
our response to question 4 above. With respect to congestion cost pricing intervals, all congestion cost
settlements within the NYISO marketplace are performed on an interval level basis (nominally five-
minutes), based upon the MWh and LBMP for the interval; whereas, within PJM and MISO the
settlements are performed on an hourly basis based upon the total MWh and the average LBMP for the
hour.
The NYISO has not completed internal software requirement and design documentation to achieve
implementation of a market-to-market coordination solution. As the NYISO does so in the course of
implementing the anticipated operating protocol, additional areas of difference may be identified and may need to be addressed.
Federal Energy Regulatory Commission Hon. Kimberly D. Bose
August 16, 2010
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The proposed congestion management/Market-to-Market Coordination programs may reduce the need,
frequency and/or magnitude of transmission loading relief (“TLR”) events to the extent that the reliability concerns are exacerbated by parallel flows from generation-to-load dispatches, and additional resources are available in the neighboring control area that can be utilized to effectively mitigate the reliability
concern. Market-to-Market Coordination provides access to a larger pool of resources to effectuate redispatch to respond to reliability concerns. To the extent re-dispatch alleviates the need to request a TLR event to address the identified reliability concern, an economic solution to the reliability concern will
replace a less efficient administrative solution.
6. Please explain to what extent the market-to-market coordination program used by PJM
and the Midwest ISO is enhanced by: (i) the buy through of congestion programs
(indicating whether these programs allow “up-to” bidding); and (ii) PARs coordination.
The market-to-market coordination program utilized by PJM and Midwest ISO is designed to address
parallel flow impacts associated with internal generation dispatch necessary to meet a Control Area’s own
load. It explicitly excludes parallel flow impacts caused by External Transactions from the associated
settlement rules. Buy-Through of Congestion compliments Market-to-Market Coordination by focusing
on the parallel flow impacts associated directly with External Transactions. The net effect of the two
solutions is to address multiple sources of parallel flow impacts by either providing the necessary cost
recovery associated with supporting the parallel flows, or the ability to adjust the sources of such flows to
reduce their impacts.
Under the current PJM and Midwest ISO scheduling protocols, the effect of market-to-market
coordination on PJM and Midwest ISO proxy bus prices must be included in the forecast of expected
price outcomes performed as part of a trader’s decision to request an External Transaction schedule. If
the pricing outcomes observed in real-time differ from the expected prices in a detrimental way, the
traders must manually remove the transaction request pursuant to the ISO or RTO’s scheduling protocols. The Buy-Through of Congestion service without an “up-to” bidding option will, similarly, require traders to forecast parallel path cost exposure as part of a traders decision to request a schedule and, similarly, can be manually removed pursuant to the same ISO or RTO scheduling practices if the observed real-time
conditions differ from forecast conditions.
Traders that do not elect to purchase service that covers their parallel flow impacts can continue to operate as they do today. These traders will remain subject to same TLR obligations they are subject to today.
Neither PJM nor Midwest ISO currently support any “up-to” congestion scheduling services for their realtime contract path transaction scheduling decisions. Economic viability of transaction schedules and/or congestion cost hedging opportunities must be considered by traders when entering into a transmission service arrangement. This scheduling practice appropriately places the risk of economic viability on the trader that schedules an External Transaction, rather than transferring the exposure to parties that had no involvement in the decision to schedule the transaction.
Federal Energy Regulatory Commission Hon. Kimberly D. Bose
August 16, 2010
Page 14
The ability of phase angle regulators to reduce and, in some hours, eliminate parallel flows will reduce the need for the activation of the Market-to-Market Coordination program. To the extent that PAR
coordination enhances the ability to control parallel flows, it will further alleviate the need for protocols to address the impacts from those parallel flows. Alternatively, to the extent that phase angle regulators
cannot be adjusted to align actual flow conditions with schedule criteria, regardless of the cause of the limitation, Market-to-Market Coordination and Buy-Through of Congestion can be effectively utilized to manage the resulting parallel flows and to permit appropriate cost recovery.
7. The NYISO Report projects, at p. 19, that the implementation of a market-to-market
coordination program by the NYISO, PJM, and the Midwest ISO will take place by the third quarter of 2011 and will be implemented in additional regions by 2012. With respect to this projection, please identify and discuss any potential impediments faced by the NYISO in meeting these projected target dates.
The largest impediment the NYISO faces in meeting the third quarter 2011 date for implementation of
Market-to-Market Coordination with PJM is the finalization and acceptance of the Parallel Flow
Visualization Tool. The adaptation of this tool is needed for two key aspects of Market-to-Market
Coordination. First, real-time conditions that drive the results of this tool will be utilized in assessing
PJM and the NYISO’s relative impacts on each other’s systems. This information is necessary to
establish appropriate firm flow entitlements. The NYISO has no convenient ability to analyze historic or
current system usage from which to derive an appropriate level of entitlements. The NYISO supports the
development of a common, standardized Parallel Flow Visualization Tool over the alternative of
developing and implementing a NYISO-specific stand alone tool to assess potential levels of firm flow
entitlements. Perhaps more important, the Parallel Flow Visualization Tool will become the common,
“single-source” application used by PJM and NYISO to monitor market flow impacts and relief for the
Market-to-Market Coordination program. The NYISO sees significant value in having all participating
Control Areas use the same tool to measure parallel path flow impacts. Using a single, common tool
should avoid the potential for participating Control Areas to calculate different results.
The current schedule for the Parallel Flow Visualization Tool indicates that it may not complete the testing phase by Q3 2011. The establishment of entitlements, and the NYISO’s and PJM's ability to implement Market-to-Market Coordination, is firmly tied to the successful development of the Parallel Flow Visualization Tool.
8. Please provide copies of all studies performed by, or for, the NYISO regarding the
impact of the congestion management/market-to-market coordination proposal within the NYISO and in its neighboring RTOs and ISOs.
Please see the analyses prepared by Dr. David Patton of Potomac Economics that are included with the NYISO’s submission, and that are described in the NYISO’s response to Question 2.
Federal Energy Regulatory Commission Hon. Kimberly D. Bose
August 16, 2010
Page 15
C.Interface Pricing Revisions
9.Please describe whether and how the interface pricing revisions will address the
economic incentives that lead to the scheduling of the now prohibited Paths 1 and 5, or any other paths that might result in increased loop flow.
Interface pricing revisions are being pursued to provide regional consistency in the recognition of power flows around Lake Erie based upon the network characteristics. The proposed interface pricing revisions may reduce, but will not eliminate the economic incentives that lead to the scheduling of transactions over the now prohibited Paths 1 and 5 (or any other circuitous scheduling path). When power flows and
schedules are not aligned, the interface pricing methods employed by the ISOs and RTOs around Lake Erie can provide inappropriate incentives to schedule circuitous transactions.
It is not appropriate to permit the scheduling of External Transactions via circuitous paths unless and until it is possible to conform schedules to actual power flows. Absent the expectation that actual power flows will be reasonably closely aligned with schedules, the scheduling of External Transactions via circuitous scheduling paths will result in significant levels of Lake Erie loop flow, regardless of the interface pricing scheme that is employed.
Path prohibitions provide a more rigorous limitation on inappropriate scheduling action than economic incentives. The NYISO evaluated alternative settlement methods10 and concluded that maintaining the existing path validations is the more robust solution.
Significant unscheduled Lake Erie loop power flows are undesirable to all of the Control Areas that
surround Lake Erie because unscheduled Lake Erie power flows can aggravate transmission constraints, result in inappropriate costs to consumers, or raise reliability concerns in any/all of the Control Areas that surround Lake Erie.
10. Please provide copies of all studies performed by, or for, the NYISO regarding the
impact of the interface pricing revisions proposed by the NYISO and in its neighboring RTOs and ISOs.
In addition to the analyses provided by Dr. David Patton of Potomac Economics, which are described in the NYISO’s response to Question 2, above, the following three presentations, are included with the NYISO’s submission:
10 See February 6, 2009 presentation titled “Long Term Solutions to Loop Flow Concerns—Contract Sink Pricing” and
December 16, 2008 presentation titled “Long Term Solutions to Loop Flow Concerns—Issue Background.” Both studies are provided in response to Question 10.
Federal Energy Regulatory Commission Hon. Kimberly D. Bose
August 16, 2010
Page 16
a. December 16, 2008 presentation by Robert Pike to the Market Issues Working Group titled Long
Term Solutions to Loop-Flow Concerns—Issue Background. Submitted as Attachment C to this
Response;
b. February 6, 2009 presentation by Robert Pike to the Market Issues Working Group titled Long
Term Solutions to Loop-Flow Concerns—Contract Sink Pricing. Submitted as Attachment D to
this Response; and
c. July 8, 2009 presentation by Robert Pike to the Market Issues Working Group titled Buy-Through
of Congestion. Submitted as Attachment E to this Response.
In addition, please see the documents provided in the NYISO’s response to Question 11.
11. Please provide copies of all studies performed by, or for, the NYISO that: (i) describe
the current interface proxy price determination methodology and any adjustments;
(ii) explain how the interface proxy price methodology will reflect the state of control of
PARs (including how PAR controllability affects proxy price assumptions for day-
ahead and hour-ahead markets); (iii) list the additional locations evaluated and selected
for proxy price determination; and (iv) explain why the NYISO’s proposed interface
proxy price determination methodology changes based on scheduled and unscheduled
flows.
In addition to the documents provided in support of the NYISO’s responses to Questions 2 and 10, the following four presentations are provided in response to this request.
a. January 5, 2010 presentation by Robert Pike to the Business Issues Committee titled Broader
Regional Market—Interface Pricing Revisions. Submitted as Attachment F to this Response;
b. April 12, 2010 presentation by Robert Pike to the Market Issues Working Group titled Broader
Regional Market—Interface Pricing Revisions. Submitted as Attachment G to this Response;
c. May 24, 2010 presentation by Robert Pike to the Market Issues Working Group titled Broader
Regional Market—Interface Pricing Revisions. Submitted as Attachment H to this Response; and
d. June 2, 2010 presentation by Robert Pike to the Business Issues Committee titled Broader
Regional Market—Interface Pricing Revisions. Submitted as Attachment I to this Response.
Federal Energy Regulatory Commission Hon. Kimberly D. Bose
August 16, 2010
Page 17
D.Implementation and Operation of PARs
12. Please provide all studies performed by, or for, the NYISO which show how the
operation of the Michigan-Ontario PARs: (i) will affect scheduling on transmission
systems of the NYISO and its neighboring RTOs and ISOs; (ii) impact settlements
administered by the NYISO; and (iii) will financially impact NYISO members.
The NYISO has not performed studies on the actual operation of the Michigan-Ontario PARs. However, the NYISO expects that the Michigan-Ontario PARs would be operated in order to conform the actual
IESO-MISO interchange with the scheduled IESO-MISO interchange. If the Michigan-Ontario PARs are not operated to conform actual flows to scheduled flows, the NYISO will continue to be subject to
unscheduled flow impacts and would expect minimal, if any, changes to the scheduling or settlement of
the NY transmission system. NYISO would expect to continue to rely on the TLR protocol to address the unscheduled flow impacts on the NYISO transmission system if no other cost recovery mechanisms are
available, such as Buy-Through of Congestion. In the absence of these alternatives, New York load
serving entities would be primarily responsible for the costs associated with managing the unscheduled
power flows on the New York transmission system.
If the Michigan-Ontario PARs are operated to conform actual flows to scheduled flows at the Ontario-
Michigan border, the NYISO expects that Generation-to-Load and Interchange impacts from its western
neighbors on the New York transmission system would be greatly diminished, thereby leaving more of
the New York transmission system available for scheduling by the NYISO. If more of the New York
transmission system is available for scheduling on a real-time basis, it is expected that real-time re-
dispatch costs would be reduced. The other Control Areas around Lake Erie would be expected to benefit
in a similar manner.
13. Please specify the PAR settings for all existing PARs that can affect circuitous flows
around Lake Erie (e.g., Ramapo) for both before and after the Michigan-Ontario PARs are placed into service. Provide all studies which examine the effects of the existing and proposed PARs on circuitous flows around Lake Erie.
Only six of the twenty-six AC interconnection facilities between the PJM and NYISO are controlled by
phase angle regulators (“PARs”). Five of the six PAR controlled interconnections are used to effectuate
the Operating Protocol for the Implementation of Commission Order No. 476. This Operating Protocol,
set forth in Attachment M-1 of the NYISO Market Services tariff, establishes procedures for the planning,
operation, control, and scheduling of energy by the NYISO, PJM, Consolidated Edison Company of New
York (“ConEd”) and Public Service Electric and Gas Company (“PSE&G”) pursuant to contracts dated
May 22, 1975 (as amended May 9, 1978) and May 8, 1978 between ConEd and PSE&G.
The sixth and remaining PAR controlled interconnection is the Branchburg-Ramapo facility. This facility
is primarily used to facilitate the delivery of energy over the AC interconnections between PJM and the
Federal Energy Regulatory Commission Hon. Kimberly D. Bose
August 16, 2010
Page 18
NYISO as determined by the level of economic interchange schedules of Market Participant External Transactions.
The settings for the six AC interconnection facilities between the PJM and NYISO that are controlled by PARs are not dependent on whether the Michigan-Ontario PARs are placed into service.
The NYISO is not aware of any studies that demonstrate that the settings of the PJM-NYISO PARs are a source of loop flows around Lake Erie. A Regional PAR Coordination Study is underway to investigate the impacts of all inter-regional PAR operations, including the PJM-NYISO PAR controlled
interconnections. This study was described on page 14 of the January 12, 2010 Report on Broader
Regional Markets; Long-Term Solutions to Lake Erie Loop Flow.
E.Scheduling Issues
14. The Commission’s August 21, 2008 and November 17, 2008 Orders accepted tariff
sheets which preclude the scheduling of flows over eight transmission paths. Please
explain whether the adoption of the initiatives present in the NYISO Report negates the need for the restriction on scheduling over those eight transmission paths.
The NYISO does not believe it is appropriate to permit the scheduling of External Transactions via
circuitous paths unless and until it is possible to conform schedules to actual power flows. Absent the
expectation that actual power flows will be reasonably closely aligned with schedules, the scheduling of
External Transactions via circuitous scheduling paths is not appropriate under any pricing regime. The
best and most obvious opportunity to implement operational controls to better align actual power flows
with contract path energy transaction scheduling is the commissioning and operation of the Ontario-
Michigan PARs to align power flows with interchange schedules between Michigan and Ontario. This
opportunity is clearly identified in the NERC 2007 Long Term Reliability Assessment and in the PJM and
MISO Investigation of Loop Flows Across Combined Midwest ISO and PJM Footprints.11
15. Explain how the combined proposals identified in your filing contribute to the
management of unscheduled flows in the NYISO and neighboring RTOs and ISOs.
A long-term solutions to unscheduled flow can best be achieved by the collective implementation of all of the proposed initiatives. Individually, each initiative only addresses a component of the unscheduled loop flow problem, and provides only a subset of the available benefits in terms of improved market efficiency. Implemented as a group, the proposed solutions are expected to produce far greater benefits by providing economic alternatives to address regional impacts resulting from unscheduled flows.
11 See page 27 of the NYISO’s July 21, 2008 Exigent Circumstances Filing Requesting Authority to Amend its Tariffs to Preclude the Scheduling of Certain External Transactions.
Federal Energy Regulatory Commission Hon. Kimberly D. Bose
August 16, 2010
Page 19
Buy-Through of Congestion addresses the scheduling of external transactions, but does not address the
impact that scheduling a particular mix of generation to serve Balancing Authority load may have on a
neighboring market. Market-to-Market Coordination addresses the impact from unscheduled flows
caused by neighboring areas generation dispatch. Enhanced Interregional Transaction Coordination
allows for more frequent region-to-region interchange adjustments which will improve the efficacy and
responsiveness of the markets to react to changes in system conditions of the effects of either the Buy-
Through of Congestion charges or the Market-to-Market Coordination price impacts. Together, the
package of proposed solutions offer economic alternatives that will permit the ISOs and RTOs around
Lake Erie to identify and utilize the lowest overall cost solution to resolve system constraints. The
combined capabilities of the proposed solutions compliment each other and offer the potential to reduce
uplift costs associated with real-time event management and congestion management, to improve the
capability to incorporate intermittent resources, and to lower total system operating costs.
To illustrate the benefits of the collective Broader Regional Market solutions to loop flow, please consider the following hypothetical example:
A New York flowgate is congested, with 300MW of unscheduled loop flow contributing to the congestion on the flowgate. 150MW of the unscheduled loop flow can be attributed to
interchange scheduling between IESO and the Midwest ISO (IESO-MISO interchange impacts). The remaining 150MW of unscheduled flow can be attributed to the central dispatch of PJM generators (PJM generation-to-load impacts).
Using Market-to-Market Coordination, the NYISO could request that PJM re-dispatch to eliminate the 150MW of PJM generation-to-load impacts on the New York flowgate. However, this would only address half of the identified loop flow related congestion. Market to Market Coordination does not affect interchange scheduling between ISO/RTOs, so the 150MW of IESO-MISO
interchange impacts would not be addressed by PJM’s redispatch.
With Buy-Through of Congestion, IESO-MISO interchange transactions would have the ability to
elect to buy-through New York congestion. If the transactions elected to buy-through the NYISO
would recover the redispatch costs it incurred to support the IESO-MISO interchange transactions.
The NYISO would use the NERC TLR protocol to remove any IESO-MISO interchange
transactions that had the requisite impact, but did not opt to buy-through the New York
congestion.
Finally, Enhanced Interregional Transaction Coordination offers the ability for transactions to be
economically scheduled more frequently than once per hour. With Enhanced Interregional
Transaction Coordination, the NYISO would be able to rely on a broader resource base to manage
the constrained New York flowgate congestion. It might prove more economically efficient to
modify External Transaction schedules intra-hour than to re-dispatch New York generation to
solve the constraint.
Federal Energy Regulatory Commission Hon. Kimberly D. Bose
August 16, 2010
Page 20
As can be seen in the example above, the collective market solutions offer significant additional flexibility for dealing with loop flow impacts on a congested flowgate. The proposed Broader Regional Market
solutions also provide the proper economic incentives for market participants to make informed trade
decisions and may reduce the overall system production cost by increasing the set of resources available for managing flowgate congestion.
F.Loop Flows Created Outside the NYISO
16. Describe the tariff mechanisms or other procedures that address loop flows caused by
transactions between entities located outside of the NYISO.
The NYISO currently employs the NERC TLR procedure to mitigate the reliability impact of loop flows caused by External Transactions that are scheduled using non-firm transmission service. The parallel path flow impacts of these transactions can cause additional congestion costs in the NYISO’s Day-Ahead and Real-Time Markets.
In addition, NYISO procedures require that estimates of Lake Erie loop flow be included in its Day-
Ahead and Real-Time markets to account for expected levels of unscheduled flow impacts on New York State transmission constraints. This is appropriate both from a reliability perspective, and to ensure that the NYISO’s economic dispatch accounts for a known system impact.
17. In a report issued by PJM and made available on its website (at www.pjm.com/
~/media/committees-groups/committees/mic/20090910/20090910-item-07-m2m-
calculation-error.ashx), PJM states that it implemented corrections for daily production calculations in its congestion management models on June 18, 2009. PJM states that it did so because several generation units were not updated through time in the model. Please describe how this updated model has affected loop flows in the NYISO.
The NYISO has not observed any change to loop flows through New York based on PJM’s updating of its congestion management models on June 18, 2009.
Federal Energy Regulatory Commission Hon. Kimberly D. Bose
August 16, 2010
Page 21
IV.Communications
Communications and correspondence regarding this Report should be directed to:
Rana Mukerji, Senior Vice President of Market Structures
Robert E. Fernandez, General Counsel
*Robert Pike, Director of Market Design
Elaine D. Robinson, Director of Regulatory Affairs *Alex M. Schnell
New York Independent System Operator, Inc.
10 Krey Boulevard
Rensselaer, N.Y. 12144
Tel: (518) 356-8707
Fax: (518) 356-7678
rpike@nyiso.com
aschnell@nyiso.com
*Persons designated for receipt of service.
V.Service
The NYISO will send an electronic link to this Response to every party included on the
Secretary’s official service list in Docket Nos. ER08-1281, 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 electric utility regulatory agency of New Jersey. In addition, the complete filing
will be posted on the NYISO’s website at www.nyiso.com.
VI.Conclusion
The NYISO respectfully requests that the Commission accept this Response as satisfying the requirements of the Commission’s July Order.
Respectfully submitted,
/s/ Alex M. Schnell
Rana Mukerji, Senior Vice President of Market Structures Robert E. Fernandez, General Counsel
Robert Pike, Director of Market Design Alex M. Schnell
New York Independent System Operator, Inc.
10 Krey Boulevard
Rensselaer, NY 12144
August 16, 2010
CERTIFICATE OF SERVICE
I hereby certify that I have this day served the foregoing document upon each person designated on the official service lists 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, New York this 16th day of August, 2010.
/s/ Alex M. Schnell
Alex M. Schnell
New York Independent System Operator, Inc.
10 Krey Boulevard
Rensselaer, New York 12144 518-356-8707
Attachment A
Preliminary Results of Analysis of the Broader Regional
Markets Initiatives
Prepared by: Dr. David Patton, Potomac Economics
Dated: April 21, 2010
[Due to the size of the files associated with some of the
Attachments, each Attachment is being individually submitted to the Commission.]
Attachment B
Analysis of the Broader Regional Market Initiatives
Prepared by: Dr. David Patton, Potomac Economics
Dated: June, 2010
[Due to the size of the files associated with some of the
Attachments, each Attachment is being individually submitted to the Commission.]
Attachment C
Long Term Solutions to Loop-Flow Concerns—Issue
Background
Prepared by: Robert Pike, NYISO
Dated: December 16, 2008
[Due to the size of the files associated with some of the
Attachments, each Attachment is being individually submitted to the Commission.]
Attachment D
Long Term Solutions to Loop Flow Concerns—Contract Sink
Pricing
Prepared by: Robert Pike, NYISO
Dated: February 6, 2009
[Due to the size of the files associated with some of the
Attachments, each Attachment is being individually submitted to the Commission.]
Attachment E
Buy-Through of Congestion
Prepared by: Robert Pike, NYISO
Dated: July 8, 2009
[Due to the size of the files associated with some of the
Attachments, each Attachment is being individually submitted to the Commission.]
Attachment F
Broader Regional Market—Interface Pricing Revisions
Prepared by: Robert Pike, NYISO
Dated: January 5, 2010
[Due to the size of the files associated with some of the
Attachments, each Attachment is being individually submitted to the Commission.]
Attachment G
Broader Regional Market—Interface Pricing Revisions
Prepared by: Robert Pike, NYISO
Dated: April 12, 2010
[Due to the size of the files associated with some of the
Attachments, each Attachment is being individually submitted to the Commission.]
Attachment H
Broader Regional Market—Interface Pricing Revisions
Prepared by: Robert Pike, NYISO
Dated: May 24, 2010
[Due to the size of the files associated with some of the
Attachments, each Attachment is being individually submitted to the Commission.]
Attachment I
Broader Regional Market—Interface Pricing Revisions
Prepared by: Robert Pike, NYISO
Dated: June 2, 2010
[Due to the size of the files associated with some of the
Attachments, each Attachment is being individually submitted to the Commission.]
