10 Krey Boulevard Rensselaer, NY 12144
December 5, 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. ER11-3881-_____
Dear Ms. Bose:
The New York Independent System Operator, Inc. (“NYISO”), submits this compliance
filing pursuant to the Commission’s October 20, 2011 Order Conditionally Accepting Tariff
Fling in Part, Denying Tariff Filing in Part, and Requiring Compliance Filing (“October
Order”).1 The October Order accepted and denied in part the NYISO’s filing proposing to
revise its definition of Available Transfer Capability (“ATC”) and update its tariff provisions
regarding its compliance with North American Energy Standards Board (“NAESB”) Wholesale
Electric Quadrant (“WEQ”) Business Practice standards (“NAESB WEQ standards”).
This compliance filing proposes tariff revisions to the NYISO’s Open Access
Transmission Tariff (“OATT”) to revise the definition of ATC as directed by P 17 of the October Order. Additionally, as directed by P 20 of the October Order, this filing provides a renewed
justification of various existing waivers of the NAESB WEQ standards that continue to be
warranted notwithstanding the change to the NYISO’s definition of ATC. This filing also
identifies those waivers that are no longer necessary in light of that change. The NYISO is
proposing to reflect these adjustments in the lists of applicable and inapplicable NAESB WEQ standards set forth in OATT Section 2.17 and in Section 5.1.2.6 of its Market Administration and Control Area Services Tariff (“Services Tariff”).
The NYISO requests an effective date of December 5, 2011 for the compliance modifications to update the definition of ATC and for those related to the NAESB WEQ standards adopted in Order No. 676-E.2
1New York Independent System Operator, Inc., 137 FERC ¶ 61,069 (2011) (“October Order”).
2 Standards for Business Practices and Communication Protocols for Public Utilities, Order No. 676-E, Final Rule, 74 Fed. Reg. 63288 (Dec. 3, 2009), FERC Stats. & Regs. ¶ 31,299, 129 FERC
¶ 61,162 (2009).
Kimberly D. Bose, Secretary December 5, 2011
Page 2
I.LIST OF DOCUMENTS SUBMITTED
The NYISO respectfully submits the following documents:
1. This filing letter;
2. A blacklined version of the proposed compliance modifications to Sections 1.1 and
2.17 of the OATT (“Attachment I”);
3. A clean version of the proposed compliance modifications to Sections 1.1 and 2.17 of
the OATT (“Attachment II”);
4. A blacklined version of the proposed compliance modifications to Section 5.1.2.6 of
the Services Tariff (“Attachment III”); and
5. A clean version of the proposed compliance modifications to Section 5.1.2.6 of the
Services Tariff (“Attachment IV”).
II.BACKGROUND
On June 24, 2011, as amended on August 17, 2011, the NYISO filed proposed tariff
modifications under section 205 of the Federal Power Act to revise the definition of ATC in its OATT (“June Filing”). The NYISO had made that filing in response to the Commission’s
September 16, 2010 order (“September Order”) that approved an interpretation by NERC of certain reliability standards.3 The September Order indicated the NYISO should make revisions to its tariff to “harmonize” its tariff language and operations.4
The June Filing also proposed compliance modifications to update the OATT and
Services Tariff to incorporate by reference the Version 002.1 NAESB WEQ standards which had been accepted in Order No. 676-E.5 In compliance with Order No. 676-E, the NYISO proposed modifications to incorporate by reference the NAESB WEQ standards that it was subject to and to list those NAESB WEQ standards for which it had been granted waivers.6
In the October Order, the Commission directed that the NYISO modify the proposed
definition of ATC by December 5, 2011. Additionally, the October Order found that because
3 North American Electric Reliability Corp., 132 FERC ¶ 61,239 at P 20 (2010) (“September
Order”).
4 Id.
5 Standards for Business Practices and Communication Protocols for Public Utilities, Order No.
676-E, Final Rule, 74 FR 63288 (Dec. 3, 2009), FERC Stats. & Regs. ¶ 31,299, 129 FERC ¶ 61,162
(2009).
6 New York Independent System Operator, Inc., 133 FERC ¶ 61,246 (2010) (“2011 Waiver
Order”).
Kimberly D. Bose, Secretary December 5, 2011
Page 3
the NYISO is now required to “calculate and post ATC on its external paths . . .”7 it should
reconsider previously granted waivers that were granted, in part, because at the time that waiver
was granted, the “NYISO was not required to calculate ATC on any of its facilities... ”8 Thus,
the October Order did not accept the NYISO’s proposed modifications to the list of applicable
and inapplicable NAESB WEQ standards in its tariffs. Instead, the Commission directed the
NYISO to include in its compliance filing “the justification for any waivers it believes continue
to be appropriate; and to identify any waivers that can no longer be justified and should be
revoked … .”9 The Commission also required the NYISO to submit tariff modifications
reflecting the results of its re-evaluation, along with the revised ATC definition.
III. PROPOSED COMPLIANCE REVISION TO THE DEFINITION OF “ATC”
The October Order rejected the NYISO’s proposed revised definition of ATC and
directed a further modification to make it “consistent with the definition used by NERC and … also enable NYISO to continue to use its financial model for its internal interfaces.”10 In
accordance with P 17 of the October Order, the NYISO revises the definition of Available
Transfer Capability, as directed by the Commission, to state that ATC is: “A measure of the
Transfer Capability remaining in the physical transmission network for further commercial
activity, over and above already committed uses, calculated using the methodology described in Attachment C in the OATT.”
IV. PROPOSED COMPLIANCE REVISIONS BASED ON THE NYISO’S RE-
EVALUATION OF NAESB WEQ STANDARD WAIVERS
A. THE NYISO’S COMMISSION-APPROVED TRANSMISSION MODEL
CONTINUES TO DIFFER SUBSTANTIALLY FROM THE PRO FORMA OATT TRANSMISSION MODEL THAT MOST NAESB WEQ
STANDARDS ARE BASED ON
In its prior waiver requests the NYISO has explained that its Commission-approved
transmission model differs substantially from the model contemplated by the Order No. 890 pro
forma OATT in many significant respects. The Commission has on multiple occasions
recognized these distinctions, granted the NYISO waivers from NAESB WEQ standards that are
intended and structured to apply the pro forma OATT transmission model,11 and confirmed that
7 October Order at P 16.
8 Id. at P 20
9 Id.
10 Id. at P 17.
11 See New York Independent System Operator, Inc., 133 FERC ¶ 61,246 at P 25 (2010); New
York Independent System Operator, Inc., 127 FERC ¶ 61,005 at P 7 (2009); New York Independent
System Operator, Inc., 125 FERC ¶ 61,275 at P 15 (2008); New York Independent System Operator, Inc.,
Kimberly D. Bose, Secretary December 5, 2011
Page 4
the NYISO may continue to use its model.12 The Commission has also approved numerous
waivers of NAESB WEQ standards for other Independent System Operators and Regional
Transmission Organizations (“ISOs/RTOs”) that administer markets similar to the NYISO’s and that employ transmission models substantially different from those contemplated by the pro
forma OATT.13
As stated in the NYISO’s prior waiver requests, the fundamental difference between the
NYISO and the pro forma transmission models is that the NYISO’s system does not provide for
separate “express” or “explicit” reservations of transmission capacity. Instead, transmission
service is scheduled in tandem with the scheduling of energy transactions as part of the NYISO’s
centralized, bid-based, economic dispatch algorithms. This is true for both the NYISO’s internal
and external interfaces. Thus, for example, the NYISO transmission model does not provide for
pre-selection of time periods or contract paths for any form of transmission service.
Additionally, the pro forma OATT Point-to-Point and Network Integration Transmission
Services provisions have been revised substantially to reflect the location based marginal pricing
(“LBMP”) context of those offerings. Thus, the NYISO’s tariffs do not include many rules and
concepts that the NAESB WEQ standards are designed to implement, including, for example,
roll-overs of transmission reservations, resales or reassignments of transmission reservations,
redirects, conditional firm service, or conditional curtailment options. Additionally, the
Commission has found that many of the OASIS posting regulations are “incompatible with the
transmission services” that the NYISO provides pursuant to its tariffs and has granted waivers.14
121 FERC ¶ 61,036 at P 9 (2007); New York Independent System Operator, Inc., 117 FERC ¶ 61,197 at PP 15-17 (2006).
12 See, e.g., New York Independent System Operator, Inc., 123 FERC ¶ 61,134 at P 13 (2008)
(conditionally approving NYISO’s Order No. 890 compliance filing and acknowledging the substantial
differences between the NYISO’s tariffs and the pro forma OATT related to the NYISO’s transmission
model). The Commission also recognized that many ISOs and RTOs use financial reservation models
instead of the pro forma OATT transmission model and noted that the Commission did not intend to
“upset” those market designs. See Preventing Undue Discrimination and Preference in Transmission
Service, Order No. 890, FERC Stats. & Regs., Regulations Preambles ¶ 31,241 at PP 158, 603 (2007)
(Order No. 890); order on reh’g, Order No. 890-A, FERC Stats. & Regs., Regulations Preambles ¶
31,261 (2007) (Order No. 890-A); order on reh’g and clarification, Order No. 890-B, 123 FERC ¶
61,299 (2008), order on reh’g, Order No. 890-C, 126 FERC ¶ 61,228 (2009) (“Order No. 890”).
13 The Commission has granted waivers from many NAESB WEQ standards to both CAISO and
ISO-NE because of the differences between their market designs and transmission models and the
structures contemplated by the pro forma OATT. See, e.g., ISO New England, Inc., 133 FERC ¶ 61,215
(2010) (granting waiver from several inapplicable WEQ-001 and WEQ-008 standards); California
Independent System Operator, Corp., 125 FERC ¶ 61,380 at P 7 (2008) (granting the CAISO waivers of
WEQ-001, WEQ-002, WEQ-003, WEQ-008 and WEQ-013) (“CAISO NAESB Waiver Order”).
14 See New York Independent System Operator, Inc., 133 FERC ¶ 61,208 (2010) (“December
2010 OASIS Waiver Order”). The NYISO has also been granted waivers from 18 C.F.R. §: 37.2(b);
37.6(a)(1) (to the extent it requires NYISO to post information relating to transmission services as
contemplated in the pro forma OATT), 37.1(a)(4), 37.1(a)(5) (to the extent it requires posting of
Kimberly D. Bose, Secretary December 5, 2011
Page 5
The Commission has found that the NYISO’s services are consistent with or superior to
the pro forma OATT requirements15 and has authorized the NYISO to provide them in lieu of
the pro forma OATT’s model.16 The fact that the Commission has held that the NYISO must
calculate “ATC” for its external interfaces does not change the fact that the NYISO continues to
use a Commission-approved economic transmission model for providing transmission service for
both internal and external transactions. Consequently, because the NYISO continues to use its
alternative transmission model the continuation of most of its established waivers from the
NAESB WEQ standards is warranted. Requiring the NYISO to comply with NAESB WEQ
standards based on the pro forma OATT transmission model would impose requirements that are
not necessary to arrange for transmission service in the NYISO’s markets, and would impose a
needless financial burden on the NYISO’s customers while providing them with no benefits.
B.REJUSTIFICATION OF WAIVER FROM INAPPLICABLE NAESB WEQ
STANDARDS
In December 2010, the Commission granted the NYISO’s request for waiver of the
following version 002.1 NAESB WEQ standards adopted in 676-E, principally because of the NYISO’s use of a market system and transmission model that differs from that contemplated under Order No. 890.17
• WEQ-001, Version 002.1, Standards 001-2 through 001-012, et seq., 001-
13.1.3(b), 001-13.1.3(c), 001-14, et seq., through 001-22, et seq., and Appendices 001-A, 001-B, and 001-D;
information related to historical transmission service requests); 37.6(b)(2)(iii); 37.6(c)(1), 37.6(c)(2) (to
the extent it requires posting information related to transmission services as contemplated in the pro
forma OATT), 37.6(c)(3)-(5); 37.6(d)(1)-(5); 37.6(e)(1)-(3); 37.6(f); 37.6(g)(1)-(4); 37.6(i)(1)-(4);
37.6(j)(1)-(2); and 38.2(1)-(3), (11). See New York Independent System Operator, Inc., 130 FERC ¶
61,104 (2010) (“February 2010 OASIS Waiver Order”); New York Independent System Operator, Inc., 94 FERC ¶ 61,215 (2001) (“2001 OASIS Waiver Order”); Central Hudson Gas & Electric Corp., 88 FERC ¶ 61,253 (1999) (“1999 OASIS Waiver Order”). The Commission has also largely granted a request for
waivers of certain ancillary OASIS regulations, including waivers of specific sections of the Standards
and Communications Protocols Documents and the Uniform Business Practices Standards. See 2001
OASIS Waiver Order at 61,794. Most recently, the Commission granted the NYISO’s request for
waivers from 18 C.F.R. § 37.6(b)(1), 37.6(b)(2)(i-iii) and 37.6(b)(3)(i-iii), with respect to its internal
Interfaces which the Commission has found are not ATC Paths. See New York Independent System
Operator, Inc., 133 FERC ¶ 61,208 (2010).
15 See, e.g., New York Independent System Operator, Inc., 123 FERC ¶ 61,134 at P 13 (2008)
(finding “that NYISO’s proposed deviations from the pro forma OATT… [are] consistent with or superior to the pro forma OATT….”), New York Independent System Operator, Inc., 125 FERC ¶ 61, 274 at P 13
(2008) (same).
16 See supra n. 12.
17 2011 Waiver Order at P 25.
Kimberly D. Bose, Secretary December 5, 2011
Page 6
• WEQ-002, Version 002.1;
• WEQ-003, Version 002.1;
• WEQ-004, Version 002.1, Standards 004-3, 004-3.1, 004-8.2, 004-11.1(a), 004-
18, et seq., and Appendices 004-A, and 004-C, to the extent they govern express
transmission reservations; and
• WEQ-013, Version 002.1.
In compliance with the October Order, the NYISO has re-evaluated all of these waivers and determined that most of them continue to be warranted, because as explained above, the
NYISO has concluded that they are not applicable to its transmission model and market system. Although the NYISO calculates and posts ATC for certain external transactions, those
transactions are scheduled and settled utilizing the NYISO’s Commission-approved transmission model. Thus, as explained in Section IV.C below, waiver of the following NAESB WEQ
standards continues to be justified:
• WEQ-001, Version 002.1, Standards 001-2 through 001-012, et seq., 001-
13.1.3(b), 001-13.1.3(c), 001-14.2, et seq., 001-15.2.1, et seq., 001-17.5 through 001-22, et seq., and Appendices 001-A, 001-B, and 001-D;
• WEQ-002, Version 002.1;
• WEQ-003, Version 002.1;
• WEQ-004, Version 002.1, Standards 004-3, 004-3.1, 004-8.2, 004-11.1(a), 004-
18, et seq., and Appendices 004-A, and 004-C, to the extent they govern express
transmission reservations; and
• WEQ-013, Version 002.1.
The NYISO’s re-evaluation has determined that waiver is no longer necessary for the following NAESB WEQ Standards, as further explained in Section IV.D below.
• WEQ-001, Version 002.1, Standards 001-14.1, et seq., 001-15.1, et seq., 001-
16.1, 001-17.1 through 001-17.4, et seq.
In compliance with P 20 of the October Order, the NYISO is submitting modified
versions of OATT Section 2.17 and Services Tariff Section 5.1.2.6, which are consistent with its re-justified waiver of inapplicable NAESB WEQ standards.
Kimberly D. Bose, Secretary December 5, 2011
Page 7
C.EVALUATION OF INDIVIDUAL NAESB WEQ STANDARDS
1.WEQ-001
The NYISO currently has waiver of many WEQ-001 standards that impose obligations to
perform certain actions relevant only to the pro forma OATT model. The NYISO is currently
exempt from the obligations to: (1) allow entities to register on the OASIS site; (2) have
processes regarding interactions for negotiating transmission service; (3) have OASIS Data
Templates that allow the coupling of ancillary service arrangements with the purchase of
transmission service; (4) have certain path naming conventions defined in the Standards and
Communications Protocol Data Dictionary; (5) have requirements for dealing with multiple
identical transmission service requests, redirects, resales, and transfers. Continued waiver is
justified because these standards were designed for and are applicable to the pro forma OATT
transmission model, but are not relevant to the NYISO’s model. Additionally, the vast majority
of these standards do not impose obligations related to the posting of ATC, and thus the rationale
for the NYISO’s waivers from them are not impacted by the Commission’s determination that
the NYISO must calculate ATC for its external interfaces. As further explained below, most of
the NAESB WEQ-001 standards do not relate to ATC postings. Only WEQ-001-13 through
WEQ-001-19 have any connection to ATC, and for a number of those standards there continues
to be ample justification for continuing the NYISO’s existing waivers.
• WEQ-001-2, et seq. (Attribute Values Defining the Period of Service) - The NYISO does
not accept express transmission reservations as contemplated in the pro forma OATT, so this
standard requiring the use of terminology relevant only to express transmission reservation
service should not apply to it.
• WEQ-001-3, et seq. (OASIS Registration Procedures) - The NYISO does not accept
express transmission reservations as contemplated in the pro forma OATT or schedule
transactions along contract paths. Because this standard imposes requirements relevant only to the posting of contract path data associated with express transmission reservations, a
waiver continues to be appropriate.
• WEQ-001-4, et seq. (On-Line Negotiation and Confirmation Process) - The NYISO does
not utilize the kinds of negotiation or confirmation procedures used in the pro forma OATT
model, so this standard concerning the negotiation process for express transmission
reservations is inapplicable.
• WEQ-001-5, et seq. (Procurement of Ancillary Services) - This standard is inapplicable
because it governs the posting of ancillary services information as relevant to express
transmission reservations. The NYISO procures ancillary services through its centralized,
co-optimized, bid-based economic dispatch and does not utilize express transmission
reservations. Thus, this standard continues to be inapplicable.
Kimberly D. Bose, Secretary December 5, 2011
Page 8
• WEQ-001-6, et seq. (Pathnaming Standards) - This standard governs path-naming
standards and is inapplicable to the NYISO because it does not accept express transmission reservation requests, or grant transmission service, tied to particular paths.
• WEQ-001-7, et seq. (Next Hour Market Service) - This standard is inapplicable because it
concerns “Next Hour Market Service” a service that transmission providers are not required to offer under the pro forma OATT and that is not provided for in the NYISO OATT or offered under the NYISO’s transmission model.
• WEQ-001-8, et seq. (Requirements for Dealing with Multiple, Identical Transmission
Service Requests) and WEQ-001-A (Appendix A - Standard Examples) - These
standards govern the treatment of multiple identical transmission service requests. They are inapplicable to the NYISO’s system because it does not require customers to submit express requests for transmission service and thus does not require procedures for handling multiple identical requests.
• WEQ-001-9, et seq. (Requirements for Dealing with Redirects on a Firm Basis), WEQ-
001-10, et seq. (Requirements for Dealing with Redirects on a Non-Firm Basis) and
WEQ-001-B (Appendix B - Redirect Standards Examples) - These standards relate to
“redirects” on a Firm and Non-Firm basis. The NYISO’s transmission model does not
provide for “redirects” because they have to do with modifications to express transmission
reservations.18 Indeed, the NYISO OATT does not include the tariff provisions that these
standards are intended to implement.19 Therefore, these NAESB WEQ standards should not
apply to the NYISO.
• WEQ-001-011, et seq. (Resales) and WEQ-001-012 et seq., (Transfers) - These standards
govern resales and transfers of point-to-point transmission reservations. The NYISO’s
system does not support such requests and thus does not support resales or transfers of them. Indeed, the NYISO OATT does not include the tariff provisions that these standards are intended to implement.20
• WEQ-001-13.1.2 (Standards of Conduct Link) - This standard mandates the posting of
information required to be provided pursuant to the Standards of Conduct for Transmission
18 See Available Transfer Capability Implementation Document at 4, available at <
http://www.nyiso.com/public/webdocs/market_data/power_grid_info/CurrentAvailableTransferCapability
ImplementationDocumentATCID.pdf.> (“ATCID”).
19 See New York Independent System Operator, Inc., Docket No. ER11-2459-000, Letter Order
(issued February 2, 2011) (accepting the NYISO’s proposal to eliminate the pro forma redirect provisions from its OATT).
20 See New York Independent System Operator, Inc., Docket No. ER09-984-000, Letter Order (issued June 5, 2009) (accepting the NYISO’s proposal to eliminate vestigial pro forma re-assignment provisions from its OATT).
Kimberly D. Bose, Secretary December 5, 2011
Page 9
Providers. The NYISO, as an ISO, is exempt from 18 C.F.R. Part 358 and there is thus no reason for it to post Standards of Conduct related information.
• WEQ-001-13.1.3(b) and (c) (Performance Metrics Link) - These standards require the
NYISO to provide links to transmission service request metrics information as required by the OASIS regulations.21 The NYISO has waivers of the underlying OASIS regulations and that these standards relate to because: (1) it does not have an express transmission service request process and therefore does not have any grants or denials of service to report; and (2) it continuously redispatches the transmission system to meet load and support requests for firm transmission service using its bid-based, security-constrained economic
dispatch/redispatch process and does not offer the more limited redispatch services found in the pro forma OATT.
• WEQ-001-14.2.1 through 14.2.3.2, WEQ-001-15.2.1 through 15.2.3.5, and WEQ-001-
17.5.1 through 17.6.6 - These ATC related standards require the NYISO to post, using the
OASIS Data templates defined in WEQ-002: (1) “zero ATC narratives”; (2) “ATC change
narratives”; and (3) actual daily peak load and final forecasted system-wide load. While the
NYISO is not requesting continued waiver of the obligations to post this information, as
explained in Section IV.D below, it is requesting continuation of the waiver of the
requirement that such information be posted using the OASIS Data Templates. As explained
in Section IV.C.2 below, those templates were designed for express transmission reservation
systems and include features, and impose requirements that are mostly irrelevant to the
NYISO’s model. The Commission recognized that the differences in the NYISO’s model
justified excusing it from using the OASIS Data Templates designed for the pro forma
OATT system. Requiring the NYISO to adopt the standard OASIS Data Templates solely
for the limited purposes of these NAESB WEQ standards would serve no purpose, and
therefore would impose needless efforts and costs.
• WEQ-001-18 (Postback Requirements) and WEQ-001-D (Postback Conditions for Use
in Calculation of ATC or AFC, as Appropriate) - These standards continue to be
inapplicable to the NYISO because it requires the incorporation of “Postbacks” of redirected
services in its ATC postings. Because the NYISO does not use express transmission
reservations, it does not release unscheduled service, provide for annual transmission
reservations, or redirect transmission service. Accordingly, the NYISO does not have
Postbacks to incorporate in its ATC postings, as further explained in the NYISO’s Available
Transfer Capability Implementation Document (“ATCID”).22 Therefore, the fact that the
NYISO calculates and posts ATC for external interfaces does not affect the justification for
waiver from this standard.
21 See February 2010 OASIS Waiver Order at P 18.
22 See ATCID at 4 (stating that “the ISO’s financial reservation based transmission system does not provide for ‘redirects’ … therefore [it] does not support ‘postbacks’ of such ‘redirects’).
Kimberly D. Bose, Secretary December 5, 2011
Page 10
• WEQ-001-19 (Grandfathered Agreements) - This standard addresses the treatment of
grandfathered agreements that are included in the Existing Transmission Commitments
(“ETC”) component of ATC calculations. The NYISO does not make express transmission
reservations in connection with grandfathered transmission arrangements. As indicated in
the NYISO’s ATCID, the NYISO assigns zero values for the variables associated with
grandfathered agreements in its ETC.23 Therefore, the fact that the NYISO calculates and
posts ATC for its external interfaces does not affect the justification for waiver from this
standard.
• WEQ-001-20 (Rollover Rights) - This standard requires the posting of information relevant
to rollover rights upon approving a Long-Term Firm Point-to-Point request with rollover
rights. The NYISO OATT has never included provisions supporting such roll-overs because
it does not provide express transmission reservations. Accordingly, the NYISO does not
have information to post pursuant to this standard and its existing waiver should be
continued.24
• WEQ-001-21 (Granting and Managing a CCO Reservation) - This standard requires the
posting of information regarding granting and managing “Conditional Curtailment Options.” The NYISO OATT does not include conditional firm service provisions. Accordingly,
Conditional Curtailment Options are not relevant under the NYISO OATT and waiver
continues to be justified.25 Additionally, waiver is supported by the language of Appendix 001-C to WEQ-001, which provides that Conditional Firm Service-related requirements do not apply to ISOs/RTOs that administer real-time energy markets.
• WEQ-001-22 (Information to Audit Usage of CBM) - This standard requires the posting of
all scheduled uses of Capacity Benefit Margin (“CBM”) and curtailments of these schedules.
As recognized in Attachment C of the NYISO OATT, the NYISO does not set-aside
transmission capacity as CBM, so CBM is not relevant within the NYISO’s market design.26
23 See id. at 5 (explaining that “the ISO assigns zero values to the GFf or GFnf terms in the firm and non-firm ATC calculations”).
24 See id. at 5 (noting that “the ISO’s Commission-approved …[OATT] does not include a
rollover rights provisions. Accordingly the ISO does not track RORf”). See also New York Independent
System Operator, Inc., 123 FERC ¶ 61,134 at PP 12-13 (2008) (Accepting the NYISO’s Order No. 890
compliance filing which explained that the pro forma OATT roll-over provision was never included in the
NYISO OATT).
25 The Commission found that it was unnecessary for ISOs/RTOs administrating real-time energy markets to adopt these provisions. See Order No. 890 at P 158; see also New York Independent System Operator, Inc., 123 FERC ¶ 61,134 at P 13 (2008) (same); New York Independent System Operator, Inc., 125 FERC ¶ 61,274 at P 11 (2008) (same).
26 Section 9.7 of Attachment C to the NYISO’s OATT provides that the NYISO “shall not set
aside transmission capacity as CBM”; see also Capacity Benefit Margin Implementation Document at 1, available at <
http://www.nyiso.com/public/webdocs/market_data/power_grid_info/CurrentCBMImplementationDocu
Kimberly D. Bose, Secretary December 5, 2011
Page 11
Therefore, the fact that the NYISO calculates and posts ATC for its external interfaces does not affect the justification for waiver from this standard.
2.WEQ-002
The Commission should continue the NYISO’s waiver of WEQ-002 (OASIS Standards
and Communication Protocols (S&CP)) for the same reasons it has granted waiver in the past.
The NYISO’s OASIS, known as the Market Information System, provides its customers with
market, transmission, and operational information through automated processes which post the
data in CSV, HTML and PDF formats. The data is updated automatically and made available to
all customers at the same time. The NYISO’s OASIS provides customers all information
necessary to participate in the NYISO’s markets. The NYISO’s OASIS does not use the OASIS
Data Templates and the NYISO has received waiver of the requirements to utilize such
templates, because they are designed for the pro forma OATT transmission model. As the
Commission has found:
[t]he NY ISO OASIS differs extensively from the standard OASIS design. First,
the New York model does not require transmission service reservations. Instead
of using OASIS … templates for making transmission reservations, the NY ISO
has adopted a series of templates that support: Energy Supplier Bidding; Load
Serving Entity load forecast and load bid functions; and Transmission Service
request for bilateral transaction scheduling. Second, the NY ISO OASIS contains
functions to enable transmission customers to submit schedules to the NY ISO
identifying transactions and purchases of energy and ancillary services in the
LBMP markets, and state whether they agree to pay congestion rents to acquire
firm service.27
WEQ-002 provides the processes, including templates, through which entities comply
with the obligations for providing and obtaining express transmission reservations, as set forth in
WEQ-001. Specifically, this standard establishes requirements on network architecture,
information access, interface, and performance requirements that were designed for express
transmission reservation systems and are thus inapplicable to the NYISO. As explained in prior
waiver requests, the content in the NYISO site differs from the Commission’s templates in that it
is designed to support the NYISO’s market design and transmission model.28 Further, the
NYISO has received waivers of the relevant OASIS regulations dealing with the reservation
process. Therefore the NYISO submits that continued waiver of this requirement is justified.
Specifically, the NYISO seeks continued waiver of the WEQ-002 standards as follows:
mentCBMID.pdf> (stating that “the ISO shall not set aside transmission capacity as CBM when calculating ATC or otherwise in developing SCUC and RTS market schedules”).
27 1999 OASIS Waiver Order at 5-6, see also 2001 OASIS Waiver Order at 3-5 (accepting a renewed request for waiver).
28 1999 OASIS Waiver Request at 4-10, and Affidavit of Dean J. Chapman P.E. at 9-11.
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• WEQ-002-2, et seq. (Network Architecture Requirements) - This standard requires
compliance with certain Internet connectivity requirements and support for specific Internet tools, both for use over the Internet and private connections between users and OASIS
Nodes. Waiver of this requirement is justified because, as the Commission has recognized, the NYISO does not use the OASIS Data Templates due to the differences between the pro forma OATT model and the NYISO’s model.
• WEQ-002-3, et seq. (Information Access Requirements) - This standard concerns the
procedures for providing access to information through the use of the OASIS Node. The
standard contains provisions on how users may access information on OASIS, registration
and login requirements, and user interaction procedures. For example, WEQ-002-3.4(i)
requires all posting and updating of transmission service information, as well as all user
logins, disconnects, download requests, service requests and all other transactions to be time
stamped and stored in an OASIS audit log. WEQ-002-3.6(b) and (c) require customers to
submit a request to purchase or resell service through the OASIS Node. Waiver of these
requirements is justified because, as the Commission has recognized, the NYISO does not
use the OASIS Data Templates due to the differences between the pro forma OATT model
and the NYISO’s model.
• WEQ-002-4, et seq. (Interface Requirements) - This standard: (1) establishes procedures
for providing information to users through the OASIS Data Templates, as described in the
WEQ-002-4.3, et seq., and the Data Element Dictionary in WEQ-003; (2) includes
requirements on the use of certain OASIS Node naming conventions, certain script names in
the OASIS Data Templates, the Data Element Dictionary and processes for the construction
of OASIS Data Templates; and (3) concerns the procedures for general postings on OASIS
for information that does not require the use of a standard template. Waiver of these
requirements is justified because, as the Commission has recognized, the NYISO does not
use the OASIS Data Templates due to the differences between the pro forma OATT model
and the NYISO’s model. Waiver of these standards is also appropriate because the NYISO is
exempt from 18 C.F.R. Part 358, Standards of Conduct for Transmission Providers.
• WEQ-002-5, et seq. (Performance Requirements) - This standard establishes performance
requirements for the OASIS Nodes. The standards set forth certain specifications to be met
for security, sizing, response to user queries, availability, backup and other performance
requirement parameters for the OASIS Nodes. Because these parameters are applicable to
the OASIS Node and OASIS Data Templates, waivers of these requirements are justified
because, as the Commission has recognized, the NYISO does not use the OASIS Data
Templates due to the differences between the pro forma OATT model and the NYISO’s
model.
3.WEQ-003
The Commission should continue the NYISO’s waiver of WEQ-003 (OASIS S&CP Data
Dictionary) for the same reasons it has granted waiver in the past. WEQ-003 includes a list of
Kimberly D. Bose, Secretary December 5, 2011
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technical data element definitions, “element names,” and file formats to be used in relation to the OASIS Data Templates. These were designed with the pro forma OATT system in mind that, as explained above, is not relevant under the NYISO’s model. The 2008, 2009 and 2010 Waiver Orders granted the NYISO’s request for a waiver of WEQ-003 to the extent that it applied to express transmission reservations. The NYISO submits that continued waiver is justified on the same grounds, and to the same extent, as past waivers.
4.WEQ-004
The NYISO has previously been granted, and seeks continued waiver, of several WEQ-
004 standards that are inapplicable to its market design and transmission model. Specifically,
waiver of WEQ-004-3, et seq., WEQ-004-8.2, WEQ-004-11.1(a), WEQ-004-18 and WEQ-004
Appendix A and Appendix C continues to be justified. These WEQ-004 standards are
unaffected by the revised definition of ATC as they establish requirements related to the use of
express transmission reservations in the interchange process that are not relevant to the NYISO,
because it does not receive or support such reservation requests. Further WEQ-004-018, requires
the setting aside of capacity for CBM to support energy imports but the NYISO does not set-
aside transmission capacity as CBM. Consequently, waiver of these requirements continues to
be appropriate.
5.WEQ-013
Continued waiver of WEQ-013 (Business Practices for OASIS Implementation Guide) is justified on the same basis and for the same reasons waiver has been granted in the past. The
October Order’s modifications to the definition of ATC in the NYISO OATT does not affect the NYISO’s waiver of this standard which establishes an OASIS Implementation Guide. The
OASIS Implementation Guide outlines the basic OASIS transaction processes and provides
additional requirements and guidance for processing specific types of business transactions in the implementation of OASIS, pursuant to WEQ-001, WEQ-002 and WEQ-003. This standard is inapplicable to the NYISO because it provides the processes for transmission service requests, secondary market requests, renewals of expiring transmission contracts, redirects, and resales, which are all processes that do not exist under the NYISO’s system.
D.NAESB WEQ STANDARDS FOR WHICH WAIVERS ARE NO LONGER
NECESSARY
The NYISO’s re-evaluation of its existing waivers of NAESB WEQ standards identified some standards for which waiver is no longer necessary. Specifically, the NYISO has identified the following as standards for which waiver is no longer appropriate:
• WEQ-001-14.1 through WEQ-001-14.2 (Zero ATC Narrative) - This standard requires
the posting of narratives associated with yearly or monthly ATC values when such posted
firm or non-firm ATC remains unchanged at a value of zero for six months or longer;
Kimberly D. Bose, Secretary December 5, 2011
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• WEQ-001-15.1 through 001-15.2 (ATC Change Narrative) - This standard requires the
posting of a narrative explanation of a change in monthly or yearly ATC values on
constrained Post Paths where such change is the result of a 10 percent or greater change in
the related posted Total Transfer Capability;
• WEQ-001-16, et seq. (ATC or AFC Methodology Questions) - This standard requires the
posting of responses to questions regarding ATC, including estimates of response time;
• WEQ-001-17.1 through WEQ-001-17.4.3 (Actual and Forecasted Load) - This standard
requires the posting of actual daily peak load and final forecasted system-wide load.
As the October Order found, for transactions on the NYISO’s external interfaces, the
NYISO is required to calculate and post ATC. Therefore, the NYISO does not seek continued
waiver of these standards. However, the NYISO does seek to continue its waiver of the
requirements in these standards that obligate the posting of such information using OASIS Data
Templates, as further explained in Section IV.C.1 above.29 The NYISO has already been,
posting the information required by WEQ-001-14, WEQ-001-15, WEQ-001-16 and WEQ-001-
17 and will continue to do in the future.
V. EFFECTIVE DATES AND REQUEST FOR WAIVER
The NYISO requests that the proposed compliance modifications be made effective as of the date of this compliance filing, i.e., December 5, 2011.
To the extent necessary, the NYISO requests waiver of the Order No. 676-E requirement
to make the compliance tariff modifications to comply with the Version 002.1 NAESB WEQ
standards for which it no longer requires waiver effective as of April 1, 2011. Even though the
NYISO believes it has satisfied the requirements of those standards for past periods, a waiver of
the April 1, 2011 date is warranted. Waiver is justified because the NYISO had received waiver
from several standards with which the NYISO has determined are no longer necessary. The
October Order did not indicate that the NYISO would be retroactively subject to any NAESB WEQ standards to the extent that it determined that waivers were no longer necessary.
Establishing a prospective effective date for the elimination of previously granted waivers would also avoid unnecessary complexities in the administration of compliance tracking for the period between April 1, 2011 and the date of this filing. Therefore, the NYISO requests an effective date of December 5, 2011 for it proposed compliance tariff revisions.
VI.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
29 Specifically, the NYISO requires continued waiver of WEQ-001-14.2.1 through 14.2.3.2, WEQ-001-15.2.1 through 15.2.3.5, and WEQ-001-17.5.1 through 17.6.6.
Kimberly D. Bose, Secretary December 5, 2011
Page 15
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.
VII. CONCLUSION
WHEREFORE, the New York Independent System Operator, Inc. respectfully requests
that the Commission accept this compliance filing, accept for filing the proposed compliance
tariff amendments and grant its request for continued waivers, effective as of December 5, 2011.
Respectfully submitted,
Ted J. Murphy_______________________ Counsel for the
New York Independent System Operator, Inc.
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 5th day of December, 2011.
/s/ Joy A. Zimberlin
Joy A. Zimberlin
New York Independent System Operator, Inc
10 Krey Blvd.
Rensselaer, NY 12114 (518) 356-6207
