HUNTON & WILLIAMS LLP
1900 K STREET, N.W.
WASHINGTON, D.C. 20006-1109
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VANESSA A. COLÓN
DIRECT DIAL: 202 • 955 • 1631
EMAIL: vcolon@hunton.com
July 30, 2010FILE NO: 55430.000072
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission 888 First Street, NE
Washington, DC 20426
Re: New York Independent System Operator, Inc., Errata to July 26, 2010 Filing in
Docket No. ER10-1977-000
Dear Ms. Bose:
On July 26, 2010, the New York Independent System Operator, Inc. (“NYISO”)
submitted proposed revisions to its Market Administration and Control Area Services Tariff (“Services Tariff”) and its Open Access Transmission Tariff (“OATT”) to revise rules related to Real-Time Energy offers. Specifically, the July 26, 2010 filing proposed tariff changes to allow Generators to increase their real-time offers for Day-Ahead Market committed
incremental Energy. It has since come to the NYISO’s attention that several inadvertent
errors were made in the proposed tariff sheets and the NYISO is submitting this filing to
correct those errors. The changes proposed herein do not alter the substance of the NYISO’s filing, but will correct errors, eliminate ambiguities and ensure that the submitted tariff
language accurately reflects the NYISO’s proposal. Therefore, the NYISO submits that this errata should be accepted by the Commission.
I.Communications and Correspondence
All communications and correspondence in this proceeding should be directed to:
Robert E. Fernandez, General Counsel*Ted J. Murphy
Elaine D. Robinson, Director of Regulatory AffairsVanessa A. Colón
*Mollie Lampi, Assistant General CounselHunton & Williams LLP
10 Krey Boulevard1900 K Street, NW
Rensselaer, NY 12144Suite 1200
Tel: (518) 356-7530Washington, D.C., 20006
Fax: (518) 356-7678Tel: (202) 955-1500
rfernandez@nyiso.comFax: (202) 778-2201
erobinson@nyiso.comtmurphy@hunton.com
mlampi@nyiso.comvcolon@hunton.com
* Persons designated for receipt of service.
II.Documents Submitted
1. This filing letter;
2. Clean Services Tariff Sheets reflecting the proposed changes; and
3. Redline Services Tariff Sheets reflecting the proposed changes.
III.Proposed Modifications
A.Clarifying Changes
Section 15.4.1.3 of the Services Tariff provides requirements for payment of
Operating Reserves to Suppliers of Operating Reserves located within the NYCA and subject
to the NYISO’s Operational Control. Section 15.4.1.3 addresses a Generator’s ability to
increase Incremental Energy Bids that have been scheduled in the Day-Ahead Market. The
July 26, 2010 filing should have proposed a modification to this section to allow entities to
increase their real-time bids, so long as they are not otherwise prohibited from doing so by
other tariff provisions. While the NYISO submitted conforming revisions to Section 4.4.2.2.1
of the Services Tariff, due to an administrative oversight it did not submit the necessary
revisions to Section 15.4.1.3. The NYISO proposes to modify section 15.4.1.3, as follows:
Generators or Demand Side Resources that are selected to provide Operating
Reserve in the Day-Ahead Market or any supplemental commitment may not
increase their Incremental Energy Bids or Demand Reduction Bids for portions
of their Resources that have been Scheduled through those processes,;
provided however, that they are not otherwise prohibited from doing so
pursuant to other provisions of the ISO’s Tariffs. They may not, however,or
reduce their Day-Ahead Market or supplemental commitments in real-time
except to the extent that they are directed to do so by the ISO.
The July 26, 2010 filing also omitted changes to two inputs to the formula for
determining Real-Time BPCG for Generators in RTD intervals other than supplemental event intervals. Section 18.4.2 of the Services Tariff should have been modified to reflect that such inputs may include costs authorized for recovery under Section 4.1.8 of the Services Tariff. The NYISO, therefore, proposes the following modifications:
MGCgiRT=Minimum Generation Bid by Generator g, or when applicable the
mitigated Minimum Generation Bid for Generator g, in the Real-Time
Market for the hour that includes RTD interval i, expressed in terms of $/MWh, which Bid or mitigated Bid may include costs pursuant to
Section 4.1.8
SUCgjRT=Start-Up Bid by Generator g, or when applicable the mitigated Start-Up
Bid for Generator g, for hour j into RTD expressed in terms of $/start,
which Bid or mitigated Bid may include costs pursuant to Section 4.1.8
B.Corrections to Typographical Errors
Additionally, the NYISO proposes to correct the following typographical errors:
•In the first paragraph of section 4.4.2.2.1 of the Services Tariff, replace the word “or”
with “and”;
•In section 23.4.3.2 of Attachment H of the Services Tariff, correct the spelling of the
word “made”;
•In section 23.4.3.3.4 of Attachment H of the Services Tariff, correct the spelling of the
words “Market” and “pursuant”;
•In section 23.4.7.1 of Attachment H of the Services Tariff, replace the word “of” with
“for”;
•In Section 18.1(iii) of Attachment C of the Services Tariff, insert a space between the
words “a” and “real-time”; and
•In Section 18.1(viii) of Attachment C of the Services Tariff, replace the word “Care”
with “Case”.
IV.Effective Date
The NYISO respectfully requests that the Commission accept these modifications with a September 30, 2010 effective date, the same effective date requested for the modifications proposed in the July 26, 2010 filing.
V.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 electric utility regulatory agency of New Jersey. In
addition, the complete filing will be posted on the NYISO’s website at www.nyiso.com. This
is in accordance with 18 C.F.R. § 35.2(e).
VI.Conclusion
The NYISO respectfully requests that the Commission accept this errata for the reasons specified herein.
Respectfully submitted,
/s/Vanessa A. Colón____________________
Vanessa A. Colón
Counsel to
the New York Independent System Operator, Inc.
