10 Krey Boulevard Rensselaer, NY 12144
April 13, 2011
ELECTRONICALLY SUBMITTED
Kimberly D. Bose
Secretary
Federal Energy Regulatory Commission 888 First Street, N.E.
Washington, D.C. 20426
Re: New York Independent System Operator, Inc.’s Supplement to First
Informational Report on Efforts to Develop Rules Addressing Compensation to Generators that Are Determined to be Needed for Reliability;
Docket No. ER10-2220-000
Dear Secretary Bose:
In accordance with paragraph 54 and ordering paragraph “(C)” of the Federal Energy Regulatory Commission’s (“Commission’s”) October 12, 2010 Order On Proposed Mitigation Measures in Docket No. ER10-2220-000 (“Order”),1 the New York Independent System
Operator, Inc. (“NYISO”), hereby submits this Supplement to First Informational Report on Efforts to Develop Rules Addressing Compensation to Generators that Are Determined to be Needed for Reliability (“Supplement”). In footnote 44 of its Order the Commission stated that it does not intend to issue public notices, accept comments, or issue orders on the informational reports that the NYISO submits in this Docket.
The NYISO’s description of the “Documents Submitted” with its First Informational
Report stated that Attachment B thereto would include “an alternative proposal submitted by the
Independent Power Producers of New York (“IPPNY”).” In compliance with the cited sections
of the Order, and consistent with the description of the documents that the NYISO stated would
be included in Attachment B to its First Informational Report, the NYISO submits herewith the
page of draft talking points that IPPNY shared with the NYISO staff, and that the NYISO staff
described on slide 8 of the March 31, 2011 Market Issues Working Group (“MIWG”)
presentation that was included as Attachment C to the NYISO’s First Informational Report.
IPPNY has indicated that it plans to present a more complete proposal that will take into
consideration the discussions that occurred at the March 31, 2011 MIWG meeting at an
upcoming joint meeting of the NYISO’s MIWG and its Electric System Planning Working
Group.
1 New York Independent System Operator, Inc., 133 FERC ¶ 61,030.
Federal Energy Regulatory Commission Hon. Kimberly D. Bose
April 13, 2011
Page 2
This Supplement will be posted on the NYISO’s website at www.nyiso.com. In addition,
the NYISO will e-mail an electronic link to this Supplement 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/ Alex M. Schnell
Rana Mukerji, Senior Vice President of Market Structures Robert E. Fernandez, General Counsel
Shaun Johnson, Manager of Energy Market Products Alex M. Schnell
New York Independent System Operator, Inc.
April 13, 2011
CERTIFICATE OF SERVICE
I hereby certify that I have this day served the foregoing document upon each person
designated on the official service lists 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, New York this 13th day of April, 2011.
/s/ Alex M. Schnell
Alex M. Schnell
New York Independent System Operator, Inc.
10 Krey Boulevard
Rensselaer, New York 12144 518-356-8707
INDEPENDENT POWER PRODUCERS OF NEW YORK, INC
Independent Power Producers of New York, Inc.
19 Dove Street, Suite 302, Albany, NY 12210
P: 518-436-3749 F:518-436-0369
www.ippny.org
Christopher@ippny.org
To:NYISO Staff
From: Chris LaRoe
Date:March 14, 2011
Re:Reliability Resource Compensation
The following is the framework for an IPPNY proposal that could serve as an alternative
to the NYISO proposal that was presented at the February 10, 2011 MIWG.
IPPNY Proposal
-A resource can request a confidential reliability study from the NYISO (and TO
as necessary).
-NYISO should conduct the study in 30 or 60 days
-Regardless of study findings a resource may stay in the market if it so chooses.
-If the generator decides to retire:
-If it’s needed for reliability, the resource may seek a RMR type contract from
FERC as soon as the resource submits its retirement notice to the PSC. This
needs to be explicitly stated in the tariff to avoid procedural arguments.
-Att. Y would proceed as currently defined. The FERC contract would be in
place until the Gap solution or Reliability Backstop solution is put in place.
-If the resource is not needed for reliability (as determined above), it should be
allowed to retire immediately.
-The unit should be removed from the Capacity market as soon as it files to retire
-The unit must bid in economically into the Energy markets
-End-
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