UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION
New York Independent System Operator, Inc. } Docket No.: ER22-772-000
COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION
The Electric Power Supply Association (“EPSA”) submits these comments on the New York Independent System Operator, Inc.’s (“NYISO”) filing submitted to the Federal Energy Regulatory Commission on January 5, 2022, pursuant to Section 205 of the Federal Power Act (“FPA”) with its proposed Comprehensive Mitigation Review reforms. Specifically, the NYISO proposes to enhance the currently effective buyer-side capacity market power mitigation measures (“BSM Rules”), improve the NYISO’s valuation of resources’ capacity contributions through adoption of a Marginal Capacity Accreditation market design, and enhance the procedures for defining Installed Capacity (“ICAP”) Demand Curves to better reflect a rapidly changing resource mix.
EPSA supports the NYISO Filing as a just and reasonable and balanced set of revisions that ensure competitive suppliers are neither under nor over-compensated to preserve the long-term reliability of the system. This is consistent with the requirements of Section 205 of the FPA and Commission precedent addressing the NYISO’s capacity markets in orders spanning more than a decade. To maintain the
balance achieved, EPSA urges the Commission to approve the filing as a package without modification, to be effective on March 6, 2022. Additionally, the Comments state that EPSA has reviewed the detailed supporting comments and accompanying expert affidavit filed concurrently by IPPNY in response to the NYISO Filing, and EPSA supports and incorporates by reference the IPPNY Supporting Comments filed in this proceeding.
The EPSA Comments highlight three key points in support of the NYISO Filing and to underscore the rationale for expeditious FERC approval without modifications: (1) The NYISO Filing is the result of an extensive stakeholder process and the proposal received overwhelming stakeholder support across stakeholder sectors; (2) The NYISO Filing reflects a balanced approach in developing the set of proposed capacity market reforms resulting in a just and reasonable proposal; and, (3) Commission precedent allows for regional differences in ISO/RTO capacity market design proposals.