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Minutes of the Annual Meeting of the Power - New York Power ...

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B. Issue: Increased “Cost-Based” Credit for Ancillary Services Production<br />

Public Comments:<br />

NYAPP asserts that it should receive a larger cost-based credit for <strong>the</strong> production<br />

<strong>of</strong> ancillary services than is included in <strong>the</strong> CoS. NYAPP reaches this conclusion<br />

through its review <strong>of</strong> NYPA data showing <strong>the</strong> gross volume <strong>of</strong> sales <strong>of</strong> two<br />

ancillary services from <strong>the</strong> Niagara Project to <strong>the</strong> NYISO (<strong>the</strong>re are none from <strong>the</strong><br />

St. Lawrence Project): regulation service and operating reserves. NYAPP<br />

proposes that <strong>the</strong> base hydro rates should be lowered to reflect <strong>the</strong> costs <strong>of</strong><br />

producing <strong>the</strong>se additional sales <strong>of</strong> ancillary services, and not simply <strong>the</strong> costs<br />

associated with <strong>the</strong> production <strong>of</strong> ancillary services for <strong>the</strong> needs <strong>of</strong> <strong>the</strong><br />

Authority’s contract customers. (NYAPP Statement at 4-5; Russell at 29-34).<br />

NYAPP proposes two possible CoS adjustments, based on ei<strong>the</strong>r summer peak<br />

period sales or <strong>the</strong> “peak month” sales which NYAPP says occurred in October<br />

2005. The requested adjustments are ei<strong>the</strong>r $10.5 million or $17.5 million in<br />

Rate Year 2007, and ei<strong>the</strong>r $11.2 million or $18.6 million in Rate Year 2008.<br />

(NYAPP Statement at 4-5; Russell at 31-32). The Neighboring States appear to<br />

make a similar claim when <strong>the</strong>y state that <strong>the</strong> CoS should recognize an additional<br />

“cost-based credit” in excess <strong>of</strong> $6 million for each Rate Year. (NS Comments §<br />

2). 11<br />

11<br />

It is not entirely clear whe<strong>the</strong>r <strong>the</strong> Neighboring States are requesting, similar to NYAPP, a<br />

larger cost-based credit for producing ancillary services at <strong>the</strong> Hydro Projects, or a direct share <strong>of</strong><br />

<strong>the</strong> Hydro Project revenues derived from ancillary services sales. To <strong>the</strong> extent <strong>the</strong> NS<br />

Customers are requesting such inflated credit, <strong>the</strong>ir claim is disposed with in <strong>the</strong> same manner as<br />

NYAPP’s in <strong>the</strong> discussion accompanying this footnote. To <strong>the</strong> extent <strong>the</strong>y are claiming a direct<br />

share <strong>of</strong> NYPA’s ancillary services sales revenue, that is a violation <strong>of</strong> <strong>the</strong> Auer Settlement<br />

principles to which <strong>the</strong>y have agreed, and <strong>the</strong> response to such arguments is subsumed within<br />

Issue E, “Request for CoS Credit for Hydroelectric Energy Sales into NYISO Markets.”<br />

15

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