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

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(NS Comments, § 2), but it does nothing to help <strong>the</strong>ir argument. Under <strong>the</strong>ir<br />

Niagara contracts, <strong>the</strong> Neighboring States agreed to allow <strong>the</strong> Authority to<br />

continue its existing practice <strong>of</strong> making credits to <strong>the</strong> RSR for such sales.<br />

2. Contrary to NYAPP’s Assertions, <strong>the</strong> Authority’s Sales <strong>of</strong><br />

Ancillary Services into <strong>the</strong> NYISO Do Not Represent Additional<br />

Firm Capacity.<br />

NYAPP is mistaken when it asserts that <strong>the</strong>re is additional firm capacity available<br />

to be sold to preference customers. While much <strong>of</strong> Mr. Russell’s testimony is a<br />

critique <strong>of</strong> <strong>the</strong> Niagara Study, which is not subject to review in this proceeding, it<br />

is important to rebut some <strong>of</strong> NYAPP’s notions concerning <strong>the</strong> operations <strong>of</strong> <strong>the</strong><br />

Niagara Project.<br />

When <strong>the</strong> Authority bids and <strong>the</strong>n sells ancillary services in quantities that<br />

exceed those associated with needs <strong>of</strong> contract customers, this does not reflect<br />

an increase in <strong>the</strong> firm capacity <strong>of</strong> <strong>the</strong> plant. Ra<strong>the</strong>r, this may result in less<br />

energy available to sell to contract load which NYPA makes up, as Mr. Russell<br />

frequently observes, by purchasing energy from <strong>the</strong>rmal sources to meet <strong>the</strong><br />

Authority’s contractual commitments to customers. The Authority is at risk for<br />

gaining or losing net revenues in this market, but is providing a benefit to <strong>the</strong><br />

NYISO for <strong>the</strong>se ancillary services for which it is well-suited. Likewise, a decision<br />

not to sell ancillary services into <strong>the</strong> NYISO would not result in an increase <strong>the</strong><br />

firm capacity <strong>of</strong> <strong>the</strong> Project. Mr. Russell again appears to believe that <strong>the</strong><br />

nameplate capacity increase stemming from <strong>the</strong> Niagara Project Upgrade led to<br />

a corresponding increase in firm capacity which serves as <strong>the</strong> basis for<br />

“substantial sales into NYISO ancillary services markets.” (Russell at 28). This<br />

Staff Analysis has already explained that such nameplate capacity increases did<br />

not lead to a firm capacity increase <strong>of</strong> <strong>the</strong> Project. For <strong>the</strong> same reasons, Mr.<br />

Russell’s reliance (at 33) on <strong>the</strong> installed capacity rating <strong>of</strong> <strong>the</strong> Niagara Project is<br />

similarly misplaced.<br />

18

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