The Independent Power Producers of New York (IPPNY) and NEPGA jointly answered a protest filed by NYISO in response to an ISO-NE proposal to modify the rules governing the Forward Capacity Market. NYISO protests that part of the rule changes that would allow certain generators in the constrained capacity zones in the New York Control Area to participate in second and third Annual Reconfiguration Auctions (and execute Capacity Supply Obligation bilaterals in that time frame). ISO-NE filed its proposal with FERC on August 19, 2016, as part of a larger package of “FCM Enhancements” (No. ER16-2451-000). NEPOOL unanimously supported the FCM Enhancement changes, which are intended to create more liquidity and efficiency in the FCM and in its Reconfiguration Auctions. NYISO asks FERC to delay the effective date of that part of the rule changes for one year, to allow NYISO to modify its tariff to mitigate the potential increase in capacity prices in New York Control Area import-constrained zones due to capacity exporting to ISO-NE. IPPNY and NEPGA ask FERC to reject NYISO’s protest, arguing that a one year delay in the effective date will interfere with open, competitive and efficient markets, and that the delay is unnecessary because NYISO and its stakeholders are well along in the process of developing tariff changes in response to the FCM Enhancements.
