UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION
New York Independent System Operator, Inc. } Docket No. ER22-772-000
COMMENTS OF THE ELECTRIC POWER SUPPLY ASSOCIATION
On March 23, 2022, Independent Power Producers of New York, Inc. (“IPPNY”) and the Electric Power Supply Association (“EPSA”) filed an answer to the comments submitted by Clean Energy Advocates on January 26, 2022 on the New York Independent System Operator, Inc.’s (“NYISO”) proposed revisions to its Market Administration and Control Area Services Tariff (“Services Tariff”) filed on January 5, 2022 in Docket No. ER22-772-000 comprehensively reforming its capacity market structure. Pursuant to the Combined Notice of Filings issued on March 14, 2022, IPPNY and EPSA also hereby comment in support of the NYISO’s March 11, 2022 responses to the Commission Staff’s February 9, 2022 letter requesting additional information concerning the NYISO Comprehensive Capacity Market Filing.
The IPPNY and EPSA Answer demonstrates, as further supported by the supplemental affidavit of Mr. Younger and the NYISO Response, that the Commission should reject the relief sought in the CEA Comments opposing the Marginal Capacity Accreditation Revisions. The NYISO demonstrated in its Comprehensive Capacity Market Filing that its Proposal was just and reasonable. The NYISO’s Response further built on the record and the substantial evidence provided in this proceeding. All State entities, including those charged with administering the State’s public policy initiatives, support the NYISO Proposal. As established by the NYISO in its CMR Filing and in the NYISO Response and as further supported in the IPPNY Comments, this submission and the answers of the NYISO, New York Transmission Owners (“TOs”) and the NYISO Market Monitoring Unit (“MMU”) to CEA’s Comments, the NYISO Proposal is just and reasonable and the Commission should accept it, without modification, effective one day after the expiration of the standard sixty-day statutory notice period, i.e., on May 11, 2022.
