10 Krey Boulevard Rensselaer, NY 12144
September 22, 2011
Ms. Kimberly D. Bose Secretary
Federal Energy Regulatory Commission 888 First St, NE
Washington, DC 20426
Re: New York Independent System Operator, Inc., Compliance Filing
Docket No. ER11-2224-010
Dear Ms. Bose:
Pursuant to the Commission’s September 15, 2011 Order on Compliance Filing
(“September Order”)1 regarding the NYISO’s proposed updated Installed Capacity (“ICAP”)
Demand Curves,2 the New York Independent System Operator Inc. (“NYISO”) respectfully
submits this compliance filing. This filing provides compliance tariff revisions to Section
5.14.1.2 of the NYISO’s Services Tariff which modify the ICAP Demand Curve points to reflect
the revised values for the winter to summer ratios (“WSR”), as directed by the September
Order.3 Additionally, pursuant to paragraph 86 of the September Order, the NYISO notifies the
Commission that it will implement these revised ICAP Demand Curves for the period beginning
October 1, 2011, covering activities associated with the October ICAP Spot Market Auction.
I.LIST OF DOCUMENTS SUBMITTED
The NYISO respectfully submits the following documents:
1. This filing letter;
2. A blacklined version of the modifications to Section 5.14 of the Services Tariff
(“Attachment I”); and
3. A clean version of the modifications to Section 5.14 of the Services Tariff (“Attachment
II”).
II.BACKGROUND
The NYISO filed proposed ICAP Demand Curves for Capability Years 2011/2012,
1 New York Independent System Operator, Inc., 136 FERC ¶ 61,192 (2011) (“September Order”).
2 Terms with initial capitalization that are not otherwise defined herein shall have the meaning set forth in the NYISO’s Market Administration and Control Area Services Tariff (“Services Tariff”).
3 September Order at PP 81, 86.
Ms. Kimberly D. Bose, Secretary
Page 2
2012/2013, and 2013/2014 on November 30, 2010 (“November Filing”).4 The Commission
issued an order on the filing on January 28, 2011 (“January Order”),5 accepting, suspending and
ordering a compliance filing. On May 20, 2011 the Commission issued an order on rehearing of
the January Order directing a further compliance filing (“May Order”), to, among other things,
revise the values for the winter to summer ratios (“WSR”) “consistent with the assumed average
levels of excess capacity used to calculate the other components of net CONE, or to explain why
the values of WSR calculated based on recent actual data reasonably approximate the ratio of
winter-to-summer DMNCs that would arise under the assumed average level of excess capacity.”6
On June 20, 2011 the NYISO filed its compliance filing addressing, among other things,
the May Order’s directive by justifying its use of WSR values calculated based on recent actual
data. On September 15 the Commission issued an order on the NYISO’s compliance filing,
accepting subject to condition the proposed ICAP Demand Curves and directing this further
compliance filing.
III. DESCRIPTION OF PROPOSED COMPLIANCE TARIFF REVISIONS
The September Order rejected the NYISO’s explanation of the WSR values calculated
based on recent actual data and directed the NYISO to include WSR values in the ICAP Demand
Curves that “so that the same levels of excess capacity, and the underlying mix of resources, are
used to calculate deliverability costs and the winter/summer adjustment.”7 Accordingly, the
NYISO is making compliance modifications to the ICAP Demand Curve points in the table in
Section 5.14.1.2 of the Services Tariff to reflect adjustments in the WSR values consistent with
the assumed levels of excess capacity, in compliance with the Commission’s directive.
The NYISO is also revising the table in Section 5.14.1.2 to delete the phrase “Date
Determined by Commission Order” in the third column of the table and insert a September 30, 2011 end date for the rates currently in effect. The NYISO is also deleting the phrase “Date Determined by Commission Order” in the fourth column of the table and inserting October 1, 2011 as the date for the rates to begin to apply for the revised ICAP Demand Curves effective until April 30, 2012.8 These proposed ending and starting dates will be effectuated in the
NYISO’s systems so that the revised rates are known prior to and are applied to activities
associated with the October ICAP Spot Market Auction.
4 Tariff Revisions to Implement ICAP Demand Curves for Capability Years 2011/2012, 2012/2013, and 2013/2014, Docket No. ER11-2224-000 (filed November 30, 2010).
5 New York Independent System Operator, Inc., 134 FERC ¶ 61,058 (2011) (“January Order”).
6 New York Independent System Operator, Inc., 135 FERC ¶ 61,170 at P 100 (2011) (“May
Order”).
7 September Order at P 81.
8 September Order at P 86.
Ms. Kimberly D. Bose, Secretary
Page 3
IV. EFFECTIVE DATE AND NOTICE OF IMPLEMENTATION
In accordance with the September Order, these proposed modifications would be effective as of September 15, 2011.
The Commission also directed the NYISO to provide notice “as to the ICAP spot market auction in which the new demand curve rate will be in effect.”9 The NYISO hereby notifies the Commission that it will implement the revised ICAP Demand Curves on this date, September 22, 2011, which is in time for the October ICAP Spot Market Auction.
V.SERVICE
This filing will be posted on the NYISO’s website at www.nyiso.com. In addition, the
NYISO will e-mail an electronic link to this filing to the official representative of each party to
this proceeding, to 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.
Respectfully submitted,
/s/ Gloria Kavanah
Gloria Kavanah
Senior Attorney
New York Independent System Operator, Inc.
10 Krey Boulevard
Rensselaer, NY 12144 518.356.6103
gkavanah@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
9 Id.
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 22nd day of September, 2011.
/s/ Joy Zimberlin
Joy Zimberlin
New York Independent System Operator, Inc
10 Krey Blvd.
Rensselaer, NY 12114 (518) 356-6207
