By Michael Kuser
NYISO on Tuesday asked FERC to deny Entergy’s request that the commission clarify the deadline for the ISO to complete a final market power review for the deactivation of the Indian Point nuclear plant (ER16-120, EL15-37).
At issue is the commission’s acceptance in November of NYISO’s revisions to its reliability-must-run program, adding a 365-day notice period for a generator to notify the ISO that it plans to retire. (See FERC Approves NYISO Reliability-Must-Run Plan.)
In a Dec. 18 filing with FERC, Entergy noted that NYISO failed to include a 120-day market power review deadline that was in an earlier filing. The company contended that without a clear deadline for review, its 2,311-MW Indian Point plant lacked certainty about authorization to exit the market. (See Entergy Asks FERC to Clarify Indian Point Retirement Process.) The company is seeking a March 13 deadline for NYISO to complete a market power study for the closure. Units 2 and 3 at the plant are slated to close in 2020 and 2021, respectively.
In its Jan. 2 response, NYISO said that requiring it “to complete physical withholding analyses years in advance of generator deactivation would clearly be unreasonable and unjustified on equitable or policy grounds.” The ISO argued that market conditions could change “dramatically” over a two- or three-year period, “as could a generator owner’s business plans as well as the plans of other generators.”
NYISO also contended that its previous references to completing market power studies within 120 days only applied to generating units closing within one year of providing notice.
“This focus on generators deactivating in 365 days, and the NYISO’s rationale for proposing this time frame as the minimum notice period, is made abundantly clear in all of the NYISO’s stakeholder presentations and all of its filings in this proceeding,” the ISO said.
The Independent Power Producers of New York also on Tuesday filed in support of Entergy’s request for clarification. IPPNY argued that without a clear deadline for the final market power assessment, “a generator owner will have difficulty planning when its generator will be able to deactivate. … NYISO’s completion of the final market power assessment may effectively operate as a bar on a generator’s deactivation, which is entirely contrary to [FERC’s] goal that generator owners know with certainty when they can deactivate their resources.”
An ISO report in December found that new gas-fired and dual-fuel generation coming online in the next few years, led by the 1,020-MW Cricket Valley plant in Zone G, will be enough to maintain reliability after Indian Point shuts down completely. (See New Builds to Cover Indian Point Closure, NYISO Finds.)