UNITED STATES OF AMERICA
BEFORE THE

FEDERAL ENERGY REGULATORY COMMISSION

Increased Market and Planning Efficiency

Through Improved SoftwareDocket No. AD10-12-000

COMMENTS OF THE NEW YORK INDEPENDENT SYSTEM OPERATOR, INC.

The New York Independent System Operator, Inc. (“NYISO”) submits these

comments in response to the Commission’s July 27, 2010 Notice Establishing Date for Comments in the above-captioned docket.

The NYISO is the independent body responsible for the reliable operation of the
New York Transmission System1 and for system planning.  The NYISO participated in
the technical conferences convened by the Commission in June of this year.  Those
conferences presented an excellent mix of academic theory, algorithm development,
model efficiency developments, and large user perspectives.  The NYISO commends the
Commission’s efforts to bring these different viewpoints together, as these types of
collaborations offer great potential benefits to the industry and ratepayers.
The NYISO believes that the conference discussions underscore the necessity for a pragmatic approach to modeling.  The Commission should encourage the industry to focus on development of a common database and database management to assist the modeler in developing databases that can be readily documented and produce repeatable results.

1 Capitalized terms used in these comments, unless otherwise defined, have the meanings ascribed to them in the NYISO’s Open Access Transmission Tariff.

As the Commission is well aware, the power system is becoming more and more
complex, and this increasing complexity presents system planners with increasing
uncertainties.  The development of new control technologies, smart grid implementation,
regulatory and policy directives/goals, market rule changes, uncertainty in resources and
their locations, trends toward broader regional markets and interregional planning,
demands from regulators and market participants for more accuracy, and compliance and
auditing requirements all lead to planning becoming more data-intensive and to a
heightened need to quickly validate data, view it, and understand it.
In particular, the success of the Department of Energy’s initiatives in
interconnection-wide planning and the Commission’s efforts to promote interregional
planning, as proposed in the recent Notice of Proposed Rulemaking in Docket No.
RM10-23-000, will depend greatly on the development of credible common databases.
Adoption of robust common databases will also support the integration of new
technologies and renewable supply sources into the bulk power system.  Optimizing
application execution time will provide the modeler with the ability to perform more
scenario analysis to deal with these evolving and ever increasing uncertainties.  Software
tools must also provide the user the capability to process and understand voluminous
input and output data quickly, in order to provide clear and concise reports to the many
stakeholders involved in the planning process.

Multi-disciplinary conferences such as those the Commission sponsored in June
are critical to developing practical tools for planners as they undertake more complex
tasks.  Outside of the technical presentations, these events provide important forums for

discussion and interaction.  The NYISO suggests that the Commission set aside more time for such informal interactions at future conferences on this topic.

Respectfully submitted,

/s/Elaine D. Robinson

Elaine D. Robinson

Director of Regulatory Affairs

New York Independent System Operator, Inc.

10 Krey Blvd.

Rensselaer, NY  12144
Tel: 518-356-6178
erobinson@nyiso.com

September 10, 2010

CC:     Eric.Krall@ferc.gov

Thomas.Dautel@ferc.gov