From time to time there have been discussions in the TIE list criticizing
Con Edison for its involvement in out-of-merit actions, implying that it is
inappropriate for Con Edison control room operators to make such requests.
In its recent order on the Revised Local Mitigation Measures, FERC, in
response to allegations made by Orion, ordered the NYISO to take
responsibility for out-of-merit.

The Con Edison system has the world's most concentrated use of energy for
residential and commercial purposes. It is also a highly
transmission-constrained area where transfer limitations under normal and
second contingency conditions require certain minimum generation levels
within specific load pockets to assure reliability under existing
reliability rules. One of the main functions of the Con Edison control
center is to be vigilant of system conditions at all times and prevent the
system from reaching an unreliable operating state. When such conditions are
imminent, the Con Edison operator so advises the NYISO. Some parties have
said that Con Edison operators should never make out-of-merit requests. Con
Edison operators would be acting irresponsibly if they were to detect an
imminent unreliable operating condition and just sit back and not inform the
NYISO of the potential danger. Con Edison operators have been trained to
focus on operating the New York City system. The NYISO operators have a much
wider state-wide focus. It is entirely appropriate for both a transmission
owner (TO) and NYISO operators to work cooperatively in maintaining
reliability with the clear understanding that under the FERC-approved
tariff, it is the NYISO that has sole responsibility for reliability. I
would like to clarify that all involvement by Con Edison operators in
out-of-merit actions are based on the following  FERC-approved process in
which the NYISO, and not the TO operator, has sole responsibility for these
actions.

	The NYISO FERC Electric Tariff, Section 5.4,  Operations Under
Adverse Conditions states in essence that:
		*	The NYISO shall operate the system in accordance
with Reliability Rules, including local rules
		*	The NYISO will do this, among other measures, by
adjusting generator output levels
		*	The NYISO has sole responsibility for declaring that
Adverse Conditions are imminent
		*	Activation of these actions shall involve a two-step
process
			1.	The TO involved will advise the NYISO that
an Adverse Condition is imminent and recommend action
			2.	The NYISO activates the appropriate
procedures
		*	Records of the activation of such procedures shall
be maintained by both the TO and the NYISO

Having stated the above, let me also say that Con Edison has been working
with NYISO operations to minimize the occurrences of conditions that require
Con Edison operators to request actions that result in OOM operations. Con
Edison supports current efforts by the NYISO to manage load pocket
reliability events in a way that SCD can be used to maintain reliability
with in-merit generation.

In effect, the FERC recent order does not require any change from present
practice which is, and has always been, in compliance with Section 5.4 of
the NYISO FERC Electric Tariff, and in compliance with FERC's recent order:
the NYISO is solely responsible for out-of-merit actions.

Mayer Sasson
Principal Advisor, Electric Markets Policy Group
Con Edison, 4 Irving Place, 1138
New York, NY  10028
212-460-6253
212-673-0649 (F)
sassonm@coned.com









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