The continuing promises to reduce OOM requests by the NYISO would seem to be
nothing more than empty verbage. I am referring to the continued multitude
of OOM dispatches that are requested every day by either ConEd and the
NYISO.

Any request for generation OOM is bypassing the SCD dispatch algorithm. The
requests are so frequent that it makes one wonder if SCD is capable of
dispatching the system at all. Generation is consistently requested OOM into
any pickup hour whether in the morning or the evening, this can mean one of
two things either SCD is significantly flawed and cannot handle any system
condition in which the system is marginally stressed or that operator
intervention into the dispatch process is for price control and not for
system security.

The nebulous and overused rationale of "requested OOM for ISO or local
security" lacks detail and any rationale. An OOM request is a special
exception to the dispatch algorithm as afforded in the tariff to allow
resolution of a system condition that SCD cannot resolve. Since these
requests are requested so frequently you have to assume that SCD is
inherently flawed.

Yes the 138 KV modeling may go in service in the near future but will it
really reduce the OOM calls. ConEd has a carte blanche to load generation
whatever and whenever they want, even when it is not in their transmission
district (Roseton OOM dispatch). There is no justification required and
clearly it is in their economic interest to request generation OOM. Controls
and the capability to audit these requests are required to mitigate the load
server with 40% of the New York State load to cease and desist bypassing the
SCD dispatch algorithm.

The consistent use of the NYPA GTs, the Gilboa generators, etc. are a
consistent abuse of a loophole in the tariff that allow interference into
the system dispatch unchecked and without any published rationale. I would
only assume that if a generator abused the dispatch to the same extent they
would have been thrown in mitigation jail a long time ago.


Joe

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