New York Independent System Operator (NYISO) has warned the Federal Energy Regulatory Commission that applying the PJM Interconnection LLC grid operation model to the entire Northeast could cause problems and risks to consumers.
The NYISO filed comments last week about the perceived consequences of using PJM as a straight model for the Northeastern RTO. NYISO argued that the three ISOs must have equal representation on the board of a new RTO.
“Giving PJM absolute control would be unlawful, deprive the board of legitimacy, and provoke protracted judicial challenges,” NYISO said.
The commission has ordered PJM, New England ISO, and the New York ISO to form a super RTO. Since little progress was made in negotiations among the ISOs, the commission appointed a mediator who issued a report last month. Comments were due last week.
New York even questioned the efficacy of forming such a large control system, given the Sept. 11 terrorist attacks on the World Trade Center and the Pentagon.
“The Northeast’s economic, political, and symbolic importance make it an inviting target for terrorism,” NYISO said. “It would not be responsible to combine essential market and reliability functions in a single RTO without carefully considering the security implications.”
NYISO pointed out that the Northeast RTO would serve 110,000 Mw of load, operate 37,000 miles of transmission, and serve about 54 million people. But the interconnections between the three ISO’s are limited to only 4,000 Mw. The system faces severe congestion making parts of the new RTO subject to market power abuse. There will probably be problems with the hardware and software to operate such an enormous system too, New York said.
The filing also noted that the implementation of the RTO would take much more time than presumed. It will take at least 2 years to adopt the PJM platform to New England and even more time to expand it to the entire Northeast, NYISO claimed.
The ISO pointed out that New York and New England are dominated by merchant suppliers with different incentives and different bidding strategies. Most of the generation in PJM is still controlled by vertically-integrated utilities.
New York faces congestion, market power, reserve issues, and other operational challenges not necessarily experienced in PJM, the filing said.