"Kirkpatrick, Joe" <joe.kirkpatrick@nrgenergy.com> writes to the NYISO_TECH_EXCHANGE Discussion List:

In order to have a functioning market model it is imperative to have a
level playing field for all market participants.

Is it a level playing field or even appropriate for any individual
market participant to dispatch generation and transmission facilities
that affect the economics of other market participants? The dispatch of
transmission and generation to resolve congestion must be made with the
overall economics of the entire market in mind. The only entity that has
the information and empowered to make these decisions is the NYISO.

With that in mind why does a particular market participant have control
over major interfaces that interconnect New York and PJM. Specifically
the control points would be the Linden-Goethals phase angle regulator
and the Hudson Farragut phase angle regulators. These PARs are under
ConEd control and are utilized by ConEd to facilitate whatever
requirements they deem required. As this is being written the New York
PJM schedule is 546 MW out to New York with a flow of 762 MW the flow on
these PARs (including Ramapo) is ~1500 MW to New York.

Are the interests of all market participants being considered by a
market participant that has over 40% of the load in New York State, that
has control over a significant amount of generation utilizing OOM
dispatches and by having control over a significant amount of
transmission facilities capable of altering the flow into New York City
and Central x East.

I suspect not.

Case in point..

There is a transmission constraint in an area in New York city. This
constraint can only be monitored by ConEd and therefore is resolved
utilizing an OOM dispatch request. Generation was reduced to resolve the
constraint, there is another generator in the area that can be reduced
to resolve the constraint, but it would appear that this control action
is not utilized . Coincidently the power from this other generator is
under contract to ConEd (take-or-pay). There is also a PAR
(Linden-Goethals) that can be moved to alleviate the constraint, which
unfortunately is not utilized either. Instead generation is reduced that
does result in additional uplift charges that is socialized as a cost to
all loads in New York. Whether the right economic decisions are being
made is an issue but the larger issue is why is a market participant
with a large economic interest making these decisions.

The NYISO was asked why the PAR was not utilized as a control action to
alleviate the constraint, simply put since the PAR is not under their
control they do not consider it as a control action.

Since ConEd does not have the overall market view or the economic
interests of all market participants in mind is it appropriate to allow
them to operate and dispatch a large part of New York State?

When the NYISO is not controlling major inter-area transmission
interfaces but allows that control to be utilized by a market
participant it is a compromise of the entire market. Economics of an
individual market participant are overriding the economics of all other
participants in New York.

This is not a "best practice" that any sane individual would recommend
for any RTO model.


Joe Kirkpatrick