FERC Finds Current NYISO Metering Requirements For CSPs Unreasonable, Sets Hearing
FERC issued an order finding that the current NYSIO tariff, that provides that Curtailment Service Providers (CSPs) and Responsible Interface Parties (RIPs) that participate in NYISO’s installed capacity (ICAP) markets must use New York State Department of Public Service (NY DPS)-certified Meter Service Providers (MSPs) or Meter Data Service Providers (MDSPs) to install and read non-revenue grade interval meters, is unjust and unreasonable, and unduly discriminatory
FERC's order came in ruling on a complaint from an NRG Energy curtailment response company
"[W]e find that NYISO’s existing Services Tariff is unjust and unreasonable, unduly discriminatory or preferential to the extent it requires CSPs and RIPs that are not transmission owners, but that wish to provide metering services in the wholesale electric markets that NYISO administers, to be certified as MSPs or MDSPs by the NY DPS. Through its MSP and MDSP certification programs, NY DPS certifies only entities that also provide metering services for the state’s retail electric market. The result, even if not so intended, is that retail market participation is a prerequisite for demand response resource participation in NYISO’s wholesale market. Indeed, in this proceeding, the New York Commission disavows the role ascribed to it through NYISO’s requirements and explicitly states that its certification program was designed to facilitate retail billing service, not for participation in wholesale markets or for measuring load reductions. In fact, the New York Commission has issued a notice proposing to eliminate the state MSP and MDSP programs and the certifications related to these programs," FERC said
"Therefore, we find that NYISO’s requirement to use either a transmission owner or an existing NY DPS-certified MSP or MDSP is unduly discriminatory to customers in service territories where transmission owners do not perform metering services,"
FERC, however, denied NRG's request for a waiver of the tariff provision, finding that such action would essentially create a new self-certification process without attendant metering standards, detailed documentation requirements, and oversight
FERC instead set the matter for paper hearing to address, among other things:
1. What metering requirements could be implemented in NYISO, would not be unduly discriminatory and yet would effectively evaluate, measure, and verify customer meter data? Please describe the advantages and disadvantages of various approaches, and identify any factors that the Commission should consider in this paper hearing.
2. How would such metering requirements address the verification of meter data and auditing of metering service providers?
3. How would such metering service eligibility criteria ensure that metering services are available to customers in all geographic areas of NYISO?
4. Would such metering requirements allow self-certification for demand response providers in NYISO? If not, please explain why.