UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
)
New York Independent System Operator, Inc.)Docket No. ER15-1061-000
)
MOTION FOR EXTENSION OF COMPLIANCE FILING DEADLINE,
SHORTENED RESPONSE PERIOD AND EXPEDITED ACTION OF
THE NEW YORK INDEPENDENT SYSTEM OPERATOR, INC.
Pursuant to Rules 212 and 2008 of the Rules of Practice and Procedure
promulgated by the Federal Energy Regulatory Commission (“Commission”), 18 C.F.R.
§§ 385.212 and 385.2008, the New York Independent System Operator, Inc. (“NYISO”)
respectfully requests that the Commission grant an extension of the compliance filing
deadline established by the Commission’s April 20, 2015 Order in this proceeding (“April
20 Order”) as it relates to a very limited aspect of the Comprehensive Shortage Pricing project.1
The April 20 Order required the NYISO to establish an effective date in November
2015 for the tariff revisions related to the Comprehensive Shortage Pricing project.2 As
further described herein, the NYISO currently remains on schedule to comply with the
Commission’s directive for nearly all aspects of the Comprehensive Shortage Pricing
project. The NYISO, however, seeks an extension to implement the proposed revisions to
Section 2.20 of its Market Administration and Control Area Services Tariff (“Services
Tariff”) and Section 1.20 of its Open Access Transmission Tariff (“OATT”). These tariff
revisions are contingent on the implementation of the Transmission Shortage Cost
modifications previously approved by the Commission to establish a graduated
1 New York Independent System Operator, Inc., 151 FERC ¶ 61,057 (2015).
2 Id. at P 20.
transmission demand curve.3 Despite the NYISO’s diligence, certain anomalies were
identified within the software coding for the graduated transmission demand curve. The
process involved to recode the software to correct the identified anomalies and then retest
the revised software have resulted in making it impracticable for the NYISO to implement
the graduated transmission demand curve on or before November 30, 2015.4
Consequently, the NYISO is unable to implement the revisions to Section 2.20 of the
Services Tariff and Section 1.20 of the OATT in November 2015. The NYISO currently
plans to: (i) proceed with implementing all other aspects of the Comprehensive Shortage
Pricing project on or before November 30, 2015; and (ii) submit the required advance
notice thereof to establish a precise effective date in the near future.
The NYISO also requests that the Commission waive the normal period for
responding to motions or, alternatively, shorten such period to no more than five days in
order to facilitate expedited action with respect to this request by no later than October 30,
2015. Expedited action by the Commission will provide greater certainty to the NYISO
and its Market Participants regarding the implementation of the Comprehensive Shortage
Pricing project in light of the delayed implementation of the graduated transmission
demand curve and its impacts on a very limited aspect of the project.
3 Docket No. ER15-485-000, New York Independent System Operator, Inc., Letter Order
(January 15, 2015) (“GTDC Order”). Capitalized terms not otherwise defined herein shall have the meaning specified in Section 2 of the Services Tariff and Section 1 of the OATT.
4 Before concluding that delaying implementation of the graduated transmission demand curve was its best available option, the NYISO considered all near-term project and software
implementation commitments, including implementation of Coordinated Transaction Scheduling with ISO New England, Inc., as well as the potential benefits for winter operations that could be garnered from proceeding with implementation of the remaining components of the
Comprehensive Shortage Pricing project.
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I.REQUEST FOR EXTENSION OF COMPLIANCE FILING DEADLINE
Pursuant to Rule 2008 of the Commission’s Rules of Practice and Procedure, 18
C.F.R. § 385.2008, the Commission may extend a compliance filing deadline it has
imposed “for good cause, upon a motion made before the expiration of the period
prescribed or previously extended.” The NYISO submits that there is good cause to grant its extension request.
On February 18, 2015, the NYISO filed proposed revisions to its Operating
Reserve Demand Curves, Regulation Service Demand Curve and Transmission Shortage
Cost related to its Comprehensive Shortage Pricing project.5 The project proposes to: (i)
implement an additional reserve region encompassing southeastern New York;6 (ii) revise the currently effective shortage pricing levels to better reflect resource costs and ensure
continued comparability with shortage pricing in neighboring regions;7 and (iii) place
limitations on the contribution of reserves held on Long Island to the rest of New York in light of certain transmission constraints that limit the flow of energy off Long Island.8 The NYISO requested that the Commission approve a flexible effective date that would be no earlier than November 1, 2015. The NYISO proposed that the specific effective date
would be established by a subsequent compliance filing submitted at least two weeks prior to the date on which the revisions will take effect.9
5 Docket No. ER15-1061-000, New York Independent System Operator, Inc., Proposed Tariff Revisions to Ancillary Service Demand Curves and the Transmission Shortage Cost (February 18, 2015) (“Comprehensive Shortage Pricing Filing”).
6 Id. at 4-5.
7 Id. at 5-12
8 Id. at 4-5.
9 Id. at 17-18.
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The April 20 Order approved the Comprehensive Shortage Pricing project,
including the NYISO’s request for a flexible effective date. The Commission directed the NYISO to establish an effective date for the tariff revisions related to the project “in
November 2015, subject to the condition that NYISO provide the Commission with no less than two weeks’ notice of the actual effective date.”10
The NYISO currently remains on schedule to comply with the April 20 Order and
implement the Comprehensive Shortage Pricing project on or before November 30, 2015,
except for a very limited aspect of the project which is contingent on the implementation of
a separate project - the graduated transmission demand curve.11 Specifically, the NYISO
will be unable to implement the revisions to Section 2.20 of the Services Tariff and Section
1.20 of the OATT on or before November 30, 2015.
The graduated transmission demand curve will replace the NYISO’s current, single
price Transmission Shortage Cost with a series of pricing points that reflect an escalating
cost associated with increasing levels of shortage in securing the transmission system.12
Implementation of the revised Operating Reserve Demand Curve values associated with
the Comprehensive Shortage Pricing project required a review of the pricing levels of the
graduated transmission demand curve to ensure that the market software would maintain
appropriate economic tradeoffs between the scheduling of reserves and securing
10 April 20 Order at P 20.
11 See Docket No. ER15-485-000, New York Independent System Operator, Inc., Proposed Tariff Amendments to Revise Transmission Shortage Costs (November 25, 2014) (“GTDC Filing); and GTDC Order.
12 GTDC Filing at 3-5. Implementation of a graduated transmission demand curve will
replace the current, single value Transmission Shortage Cost, which prices all shortages at $4,000
per MWh, with the following series of escalating pricing points: (a) $350 per MWh for shortages
greater than zero and less than or equal to 5 MW; (b) $1,175 per MWh for shortages greater than 5
MW and less than or equal to 20 MW; and (c) $4,000 per MWh for shortages greater than 20 MW.
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transmission constraints. This review indicated a need to revise the value of the middle
pricing point of the graduated transmission demand curve (i.e., the value associated with
shortages of greater than 5 MW and less than or equal to 20 MW).13 The proposed
revisions to Section 2.20 of the Services Tariff and Section 1.20 of the OATT are intended
to ensure that appropriate economic priority is maintained between the scheduling of 10-
minute total reserves in the East of Central-East region and securing the Central-East
interface.14
For quality assurance and to avoid the potential for inappropriate market outcomes, the NYISO conducts extensive testing prior to the implementation of software changes. The testing of the initial software coding for the graduated transmission demand curve
revealed the presence of certain anomalies. Identification of the anomalies has required recoding of the software and additional testing of the revised software. Despite the
NYISO’s diligence, the process involved, and time required, to recode the software to
correct the previously-identified anomalies and then retest the revised software have
resulted in making it impracticable for the NYISO to implement the graduated
transmission demand curve on or before November 30, 2015.
In the absence of the graduated transmission demand curve, the current, single price
Transmission Shortage Cost is sufficiently high to maintain the appropriate economic
scheduling priority between the scheduling of 10-minute total reserves in the East of
Central-East region and securing the Central-East interface due to the valuing of all
13 Specifically, as part of the Comprehensive Shortage Pricing project, the NYISO
proposed to increase the value of the middle pricing point of the graduated transmission demand
curve from $1,175 per MWh to $2,350 per MWh. See Comprehensive Shortage Pricing Filing at
11-13.
14 Id. at 11, fn. 37.
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transmission shortages at $4,000 per MWh regardless of the magnitude of such shortages. Accordingly, the revisions to Section 2.20 of the Services Tariff and Section 1.20 of the OATT are not needed at this time to facilitate appropriate market outcomes. The NYISO is capable of proceeding with the implementation of all other aspects of the
Comprehensive Shortage Pricing project.
The NYISO respectfully requests an extension of the implementation deadline
imposed by the April 20 Order only as it relates to the very limited aspect of the
Comprehensive Shortage Pricing project that is contingent on the implementation of the
graduated transmission demand curve. Specifically, the NYISO requests an extension to
delay the effective date of the proposed revisions to Section 2.20 of the Services Tariff and
Section 1.20 of the OATT beyond November 2015. Consistent with the mechanics of the
flexible effective date approved by the Commission, the NYISO proposes to submit a
compliance filing at least two weeks prior to the proposed effective date for Section 2.20 of
the Services Tariff and Section 1.20 of the OATT which will specify the date on which
these revisions will take effect. The NYISO is unable to establish a specific effective date
until after the revised software has been tested and deemed ready for implementation.
The NYISO currently remains on schedule to implement all other aspects of the Comprehensive Shortage Pricing project on or before November 30, 2015. The NYISO currently plans to: (i) proceed with implementing the Comprehensive Shortage Pricing project on or before November 30, 2015, except for the very limited aspect of the project related to the graduated transmission demand curve; and (ii) submit the required advance notice to establish a precise effective date in the near future for the tariff revisions related
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to the project, except for the proposed revisions to Section 2.20 of the Services Tariff and Section 1.20 of the OATT.
II.REQUEST FOR SHORTENED RESPONSE PERIOD AND EXPEDITED
ACTION
The NYISO respectfully requests that the Commission waive the normal period for
answering motions or, alternatively, shorten such period to no more than five days in order
to facilitate action by the Commission on this request as expeditiously as possible, but no
later than October 30, 2015. The NYISO informed Market Participants of its intent to seek
this request at a Business Issues Committee meeting held on October 14, 2015. Expedited
action by the Commission will provide certainty regarding the NYISO’s ability to proceed
with implementing all aspects of the Comprehensive Shortage Pricing project, except for
the revisions to Section 2.20 of the Services Tariff and Section 1.20 of the OATT, on or
before November 30, 2015. This will also provide certainty to the marketplace regarding
the ability to proceed with implementation of these important market design changes prior
to the upcoming winter period. The Comprehensive Shortage Pricing project, among other
benefits, is intended to significantly improve performance of supply resources during
critical operating periods. By providing schedules and appropriate price signals to supply
resources, this project seeks to ensure that resources are properly incented to be available
to meet their schedules and procure the necessary fuel supplies to achieve such availability.
III.CONCLUSION
For the foregoing reasons, the NYISO respectfully requests that the Commission:
(i) grant an extension of time to implement the proposed revisions to Section 2.20 of the
Services Tariff and Section 1.20 of the OATT until the NYISO implements the graduated
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transmission demand curve; and (ii) waive the normal period for responding to this request
or, alternatively, shorten such response period to no more than five days, to facilitate
expeditious action by the Commission with respect to this request by no later than October
30, 2015.
Dated: October 16, 2015
Respectfully submitted,
/s/ Garrett E. Bissell
Garrett E. Bissell
Senior Attorney
New York Independent System Operator, Inc.
10 Krey Blvd.
Rensselaer, New York 12144 (518) 356-6107
gbissell@nyiso.com
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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 16th day of October 2015.
/s/ Joy A. Zimberlin
Joy A. Zimberlin
New York Independent System Operator, Inc.
10 Krey Blvd.
Rensselaer, NY 12144 (518) 356-6207
