On May 24, 2001 the Business Issues Committee will consider proposed Stage
2 modifications to the NYISO Market Administration and Control Area
Services Tariff, including changes to reflect a conversion from ICAP to
UCAP, and from a six-month to a one-month Obligation Procurement Period.
The Department of Public Service offers the attached comments on the
proposal and on the need for a "hard look" at ICAP rules, in general.



Steven F. Keller
Office of Electricity and the Environment
New York State Department of Public Service
Phone (518) 486-2430
Fax      (518) 473-2420
 - NYSDPS Position on ICAP Issues.doc