10 Krey Boulevard Rensselaer, NY 12144
April 20, 2011
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. ER11-3236
Errata to the Filing to Revise the Calculation of Bid Production Cost
Guarantees and Request for Shortened Comment Period
Dear Ms. Bose:
The New York Independent System Operator, Inc. (“NYISO”) is filing these errata to
complete and correct its proposed revisions to the NYISO’s Market Administration and Control
Area Services Tariff (“Services Tariff”) in the above-captioned proceeding. As is set forth
below, these errata corrections are necessary to fully implement the NYISO’s proposed changes
and to avoid unintended inconsistencies in the Services Tariff. Because its proposed errata are
entirely consistent with, and address the same substantive issue as, the revisions included in the
NYISO’s March 30, 2011 filing in the above-captioned proceeding, the NYISO respectfully
requests the Commission not establish any additional notice and comment period for its errata.
Should the Commission notice this filing for comment, however, the NYISO requests that the
Commission waive the standard sixty day notice period and, to the extent necessary, establish a
shortened comment period to preserve the effective date of June 1, 2011 requested in the March
30, 2011 filing. To the extent necessary, the NYISO also requests waiver of any answer period
that might otherwise apply to this request.
I.Documents Submitted
1.This filing letter;
2.A clean version of the proposed revisions to the NYISO’s Services Tariff
(“Attachment I”); and
3.A blacklined version of the proposed revisions to the NYISO’s Services Tariff
(“Attachment II”).
Honorable Kimberly D. Bose April 20, 2011
Page 2
II.Errata
It has come to the NYISO’s attention that the Services Tariff amendments proposed in its March 30, 2011 filing were incomplete in describing the expansion of Bid-Production Cost
Guarantee (“BPCG”) eligibility for Import Transactions that the NYISO was seeking. As the NYISO explained in its March 30 filing in this docket:
The NYISO is proposing a set of BPCG-related amendments to align the
treatment Generators and importers with Bilateral Transactions receive from both
the scheduling and the BPCG eligibility and calculation software. That is, the
NYISO proposes to hold the BPCG calculation indifferent to whether the
schedule of the Generator or importer supports Bilateral Transactions. This
revised BPCG calculation will eliminate the risk that NYISO-provided schedules
for Generators and importers will produce insufficient revenues to support
recovery of their bid-in production costs. To the extent this assumed risk is
incorporated in their Bids, these amendments should also reduce bid-in costs and
benefit the Loads (and thus consumers). Generators and importers will be assured
that all their bid-in costs not otherwise recovered through daily revenue will be
covered through a BPCG payment for the day.1 Transmission Customers with
Import schedules will be assured that their BPCG eligibility and calculation
methodologies are consistent with those provided to internal Generators.
The NYISO properly proposed amendments to Services Tariff Sections 4.6.6.2 and
Section 4.6.6.5 to indicate that Suppliers scheduling Imports were eligible for a BPCG whether they were making sales to the LBMP Market or scheduling an Import Bilateral Transaction. The NYISO overlooked the need to make similar amendments to Sections 18.3.1 and 18.6.1.1 in
Attachment C of the Services Tariff. The NYISO is proposing to correct that oversight in these errata by proposing amendments to Sections 18.3.1 and 18.6.1.1 that conform to the amendments to Sections 4.6.6.2 and 4.6.6.5 that it sought in its March 30, 2011 filing.
The properly proposed amendment to Section 4.6.6.5, which describes BPCG eligibility
for Imports scheduled in the Real-Time Market, and the parallel amendment to Section 4.6.6.2,
which describes BPCG eligibility for Imports scheduled in the Day-Ahead Market, eliminate the
limitation on BPCG eligibility for Importers by proposing to drop the words “sale to the LBMP
Market” as shown:
4.6.6.5 The ISO shall determine if a Supplier supplying an Import sale to the
LBMP Market and eligible under Section 18.6.1 of Attachment C of this ISO Services
Tariff for a real-time Bid Production Cost guarantee payment will not recover its real-
1 As is described in greater detail in the next Section, because Bilateral Transaction revenue is not revealed to the NYISO, the BPCG tariff amendments and software will assume that Bilateral Transaction revenue is equal to LBMP revenues otherwise available for the same interval and megawatt hours.
Honorable Kimberly D. Bose April 20, 2011
Page 3
time Decremental Bid through realtime LBMP revenues and real-time Imputed LBMP Revenue….
The Services Tariff, Attachment C provisions Section 18.3.1 and 18.6.1.1 also describe the circumstances under which a Supplier bidding an Import Transaction is eligible for a Bid Production Cost Guarantee payment in the Day-Ahead Market and Real-Time Market
respectively. The oversight in failing to amend Sections 18.3.1 and 18.6.1.1 can be rectified by eliminating the phrases, as shown:
18.3.1 Eligibility to Receive a Day-Ahead BPCG for Imports
A Supplier that bids an Import sale to the LBMP Market that is committed by the ISO in the Day-Ahead Market shall be eligible to receive a Day-Ahead Bid Production Cost guarantee payment….
18.6.1.1 Eligibility.
A Supplier that bids an Import to sell Energy to the LBMP Market that is committed by the ISO in the Real-Time Market shall be eligible to receive a real-time Bid Production Cost guarantee payment for all intervals….
The Tariff sheets attached to this filing in Attachments I and II propose the amendments striking the phrases shown above.
The NYISO is also proposing one additional ministerial correction to the amendment
proposed in the March 30, 2011 filing to Section 4.6.6.2 of the Services Tariff. The amendment proposed in the March 30, 2011 filing proposed to strike only the words “to the LBMP Market” as shown below.
4.6.6.2 Day-Ahead BPCG for Imports
The ISO shall determine if a Supplier supplying an Import Sale to the LBMP Market and
eligible under Section 18.3.1 of Attachment C of this ISO Services Tariff for a Day-
Ahead Bid Production Cost guarantee payment will not recover its Day-Ahead
Decremental Bid through Day-Ahead LBMP revenues and Day-Ahead Imputed LBMP
Revenue….
This amendment should also have proposed to strike the word “Sale” in the phrase “Sale to the LBMP Market.” The correction that the NYISO is proposing in this erratum is to strike the word “sale” from this section as shown below:
4.6.6.2 Day-Ahead BPCG for Imports
The ISO shall determine if a Supplier supplying an Import Sale and
eligible under Section 18.3.1 of Attachment C of this ISO Services Tariff for a Day-
Ahead Bid Production Cost guarantee payment will not recover its Day-Ahead
Decremental Bid through Day-Ahead LBMP revenues and Day-Ahead Imputed LBMP
Revenue….
Honorable Kimberly D. Bose April 20, 2011
Page 4
III.Effective Date
The NYISO respectfully requests that the Commission accept the tariff modifications
included with this filing with the same June 1, 2011 effective date as requested in Section V. of
the March 30, 2011 filing in this docket. The NYISO is preparing the software that will
implement this expansion of BPCG payments for Suppliers bidding Importer Transactions for a
June 1, 2011 implementation. As these changes will improve the efficiency of the market and
potentially act to reduce the bids submitted for Import Bilateral Transactions, reducing customer
costs, the NYISO would like to implement these changes s soon as possible. Moreover, granting
a June 1 effective date would not harm any potentially interested party because the corrections
included in this filing address the same substantive issue as the ones included in the March 30,
2011 filing which has already had a full notice and comment period. There is, therefore, good
cause for the Commission to waive the standard sixty day notice period. Similarly, there is good
cause to shorten the comment period to the extent necessary to allow the Commission to issue an
order accepting the March 30, 2011 filing effective June 1, 2011.
VI. Communications and Correspondence
All communications and service in this proceeding should be directed to:
Robert E. Fernandez, General Counsel
*Mollie Lampi, Assistant General Counsel
Ray Stalter, Director Regulatory Affairs
New York Independent System Operator, Inc.
10 Krey Boulevard
Rensselaer, NY 12144
Tel: (518) 356-8875
Fax: (518) 356-7678
rfernandez@nyiso.com
rstalter@nyiso.com
mlampi@nyiso.com
• Designated to receive 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 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.
Honorable Kimberly D. Bose April 20, 2011
Page 5
VIII. Conclusion
Wherefore, for the foregoing reasons, the New York Independent System Operator, Inc. respectfully requests that the Commission accept these errata to its March 30, 2011 filing to be effective June 1, 2011.
Respectfully submitted,
/s/ Mollie Lampi
Mollie Lampi
Assistant General Counsel
New York Independent System Operator, Inc.
10 Krey Blvd.
Rensselaer, New York 12144 (518) 356 7530
mlampi@nyiso.com
cc:Michael A. Bardee
Gregory Berson
Connie Caldwell
Anna Cochrane
Jignasa Gadani
Lance Hinrichs
Jeffrey Honeycutt
Michael Mc Laughlin
Kathleen E. Nieman
Daniel Nowak
Rachel Spiker
CERTIFICATE OF SERVICE
I hereby certify that I have this day served the foregoing document upon each person
designated on the official service list 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, NY this 20th day of April, 2011.
/s/ Joy Zimberlin
Joy Zimberlin
New York Independent System Operator, Inc
10 Krey Blvd
Rensselaer, NY 12114 (518) 356-6207
