Subject: RE: 150 mW DEC Cap for "Emergency Exempt" for EDRP
From: [email-masked]
To: [email-masked], [email-masked], [email-masked]
Cc: [email-masked]
Date: Fri, 11 May 2001 09:19:00 -0700 (PDT)

"Mark Younger" <[email-masked]> writes to the NYISO_TECH_EXCHANGE 
Discussion List:

If only 150 MW can be called on when the NYISO needs them then no more than
150 MW should be allowed to qualify as ICAP providers.  The purpose of ICAP
is to assure that the NYISO has capacity when it needs it.  "Having" the
capacity and then not being allowed to use it makes the capacity worthless.
Resources that cannot be called upon are do not add to system security.

-----Original Message-----
From: [email-masked]
[mailto:[email-masked]] On Behalf Of jdprunkl
Sent: Friday, May 11, 2001 3:55 PM
To: 'Larry DeWitt: PACE'; PRLWG
Subject: RE: 150 mW DEC Cap for "Emergency Exempt" for EDRP

Larry:

A couple of comments:

1. I recommend that the 150 MW limit be managed by NYISO Operations.  They
are going to understand the problems in real time and should have complete
authority of which generators get run based on the situation. Trying to
fairly rotate which units get called at this late date, given the hours of
operation are completely unknown would be a waste of time, in my opinion.

2. We all should be very grateful that the DEC has taken the action they
have on expanding the exempt generator definition.  If people are not happy
with the 150MW cap then they should get a registration or state facility
permit and notify the ISO that the their site is not to be counted in the
150 MW cap calculation.

3. Not paying full ICAP for these resources would be a disaster.  If we want
to kill the emergency program, this is the best way to do it.  Again,
calling of generators should be based on the NYISO Operations assessment of
the emergency situation.  A special case resource generator standing ready
to serve, even if DEC has placed some limits on the number of MW running at
one time, should not be penalized by this cap.  We may find situations where
some of the SCR "exempt" generators called can not start or limit their
generation hours for some reason.  In this case we need as many SCR
resources ready to fill the void as possible. Limit payments really hurts
the credibility and effectiveness of the programs we have all worked so hard
to develop.

4. I do not think the EDRP manuals need to say anything on this subject.
This should strictly be an internal NYISO operation matter on which
generators get called in each zone.  If the Operations manual needs to be
updated to reflect the 150 MW exempt generator class of EDRP generators lets
do it here not in the EDRP manual.

Looking forward to Monday's discussion. Have a great weekend.

Best Regards,
John D. Prunkl
MetroGen LLC
205-343-1977 w
217-454-0295 cell
509-356-9367 fax
[email-masked]
www.metrogen.com

-----Original Message-----
From: Larry DeWitt: PACE [SMTP:[email-masked]]
Sent: Friday, May 11, 2001 1:43 PM
To: PRLWG
Subject: 150 mW DEC Cap for "Emergency Exempt" for EDRP

Colleagues,
This is a "heads up" that there are several issues we will need to look at
on Monday with respect to the new NYS DEC expanded definition of "emergency
exempt" when participating in the EDRP.  The problems needing solving that I
am aware of so far concern the 150 mW cap that DEC placed on the ISO's call
for emergency customer generation.  Our understanding is that more than that
amount can be signed up for the program--but only 150 mWs can be called at
any one time.

Some have suggested that the DEC does not have the right or power to
regulate the NYISO.  I don't know.  But I do know that DEC would revoke this
in heart-beat if they thought we were going to ignore it--especially after
all these different parties, including the ISO and the self-generation
developers, bargained with NYS DEC to do what they have done.  Also, the
individual participating customers would be more than some upset if they
found out that DEC was revoking their emergency exempt status because they
were deemed to have been the ones who were over the 150 mW limit in an
emergency call.

There are two problems that I have seen, both related to enrolling more than
150 mWs of emergency exempt EDRP participants.  First, if there is more than
150 mWs in the region being called, we need to determine a method for who
gets called--it could rotate in an equitable fashion.  But our manual should
probably speak to this.

The other problem is that we probably shouldn't be paying full ICAP to 300
mWs of emergency exempt EDRP participants if we know that no more than half
of them can respond to any ICAP call.  We might derate them in percentage to
the subscription over the 150 mWs.  Or some other system.

My purpose here is to alert you to the issue and suggest that we want to
come up with a solution on Monday.  I spoke with Mollie Lampi about it and
hope the ISO has a chance to work on it today.  We want all EDRP and DADRP
manual matters to go before the BIC on May 24th.

Have a great weekend and thanks for all of the creative thinking and
constructive participation on getting these programs as right as we can as
quickly as we can!

Larry
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