Aaron Breidenbaugh <aaron@global2000.net> writes to the NYISO_TECH_EXCHANGE 
Discussion List:

Greetings,

I was surprised today to learn that MSWG is recommending a delay in the
implementation of zonal price capped load bidding until the fall, when
it can be implemented simultaneously with virtual bidding.

The priority assigned to zonal PCLB is a settled issue and one that is
not properly before the MSWG or BIC at this time. The NYISO Management
and Board have already determined that implementation of zonal PCLB by
May is one of the ISO's highest priorities. Implementation of zonal PCLB
by this summer is even part of the NYISO Business Plan, Goal and
Objectives, and Incentive Compensation plan. In addition, the project
prioritization process adopted by the Management Committee has ratified
the priority assigned to this critical effort.

Apart from sporadic concerns raised by a few generators, there has never
been any indication that zonal PCLB should be delayed until virtual
bidding can be implemented. Indeed, it appears that the decision by the
MSWG to advance this proposal was decided upon at the last meeting of
the Virtual Bidding Task Force which does not even have official
standing as a NYISO subcommittee. That meeting's material did not in any
way indicate that such a major change was being contemplated, let alone
that it would be a recommendation to the BIC less than a week later.

The Price Responsive Load Coalition strongly supports the ISO's previous
decisions to implement zonal PCLB by this summer and views it as a
critical component of the state's efforts to engage loads' participation
in the market in a meaningful way. We will oppose any efforts to delay
implementation simply because some generators raise speculative fears of
"manipulation" of the markets by loads.

While there may well be merit to implementing zonal PCLB and virtual
bidding simultaneously, the proposal now before us threatens to throw
the baby out with the bathwater, depriving customers of one of their
only means of ameliorating the effects of markets that may not be
workably competitive.

From both a procedural and substantive perspective, the proposal
presented to the BIC is fundamentally defective and must be rejected.

Sincerely,
Aaron Breidenbaugh
Executive Director
Price Responsive Load Coalition
--

Aaron Breidenbaugh
Senior Manager &
Editor, ISO Navigator: New York Edition (tm)
http://www.iso-navigator.com


Navigant Consulting, Inc.
20 Madison Avenue Extension
Albany, NY  12203-5326

(518) 456-1082 phone
(518) 456-6008 fax
(518) 369-7987 cell

aaron_breidenbaugh@rmiinc.com


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