NYISO Draft ICAP Demand Curve Recommendations for Capability Years 2017/ /2021. Randy Wyatt New York Independent System Operator

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NYISO Draft ICAP Demand Curve Recommendations for Capability Years 2017/2018-2020/2021 Randy Wyatt New York Independent System Operator ICAPWG August 19, 2016 Rensselaer, NY 2000-2016 New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY

Topics NYISO Preliminary Recommendations Overview Ongoing NYISO Evaluations Remaining ICAP Demand Curve Reset (DCR) Schedule 2000-2016 New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 2

NYISO Draft Recommendations At this time, NYISO concurs with the recommendations of Analysis Group and Lummus Consultants International (Consultants) in all but the following instance: NYISO recommends the use of a gas only peaking plant configuration with selective catalytic reduction (SCR) emissions control technology for Load Zones C and F As noted later in the presentation, the NYISO is continuing to assess certain other aspects of the Consultants recommendations Fixed property tax rate of 0.75% for Load Zones C, F, G and K Level of excess adjustment factor (LOE-AF) values determined based on the 2016 CARIS Phase 2 database 2000-2016 New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 3

NYISO Evaluation of Dual Fuel Requirement Consultants Recommendation Market Participant Comments NYISO Assessment 2000-2016 New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 4

Consultants Recommendation Consultants recommend dual fuel capability for the peaking plant technology in all locations Dual fuel capability serves as a hedge against the expected increase in New York state s reliance on natural gas in the coming years Dual fuel expands siting flexibility Provides opportunity for increased revenue earnings compared to a gas-only unit during periods when oil is more economic than natural gas for electricity production or when natural gas supply is unavailable On balance, a developer would more likely than not decide to include dual fuel capability 2000-2016 New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 5

Stakeholder Feedback Supply-side interests generally supported the Consultants recommendation of dual fuel capability and SCR technology for the peaking plants across all locations Load-side interests contend that the recommendation for dual fuel in Load Zones C, F, and G is not justified Uneconomic Not mandated by LDC tariffs Not required to qualify as an Installed Capacity Supplier 2000-2016 New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 6

NYISO Assessment Concur with Consultants recommendation for including dual fuel for the peaking plants located in NYC and LI Consistent with prior DCRs, it is a requirement for interconnection in these locations Concur with Consultants recommendation for inclusion of dual fuel capability in the G-J Locality Consistent with 2013 DCR Dual fuel capability is required to allow the peaking plants to interconnect to the LDC systems in this region. Absence of dual fuel capability would unduly limit siting flexibility in the region and potentially increase cost Dual fuel capability serves as a hedge against the expected increase in New York state s reliance on natural gas in the coming years Given current conditions in the gas market and general availability of gas supply upstate, NYISO believes that gas-only peaking plant remains reasonable for Load Zones C and F at this time. Incremental revenues received by a dual fuel plant, as determined by the net EAS revenues model for the 2017/2018 Capability Year calculations, do not offset the additional capital costs of dual fuel capability over the historic period analyzed, Greater availability of sites in these locations 2000-2016 New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 7

Ongoing NYISO Evaluations Property Tax Rate Outside NYC Level of Excess-Adjustment Factors (LOE-AFs) Evaluation Process (same as described previously for dual fuel assessment): Consultants Recommendation Market Participant Comments NYISO Assessment 2000-2016 New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 8

NYISO Evaluation of Property Taxes Consultants Recommendation Market Participant Comments NYISO Assessment (Ongoing) 2000-2016 New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 9

Consultants Recommendation Consultants recommend an effective property tax rate of 0.75% outside of NYC Consultants recommendation based on a review of PILOT agreement data available through the New York State Comptroller s Office Focused on natural gas plants (11), vintage: 1989-2009, with Fiscal Year 2014 effective tax rates that range from 0.2% to 2.01 % Median value of 0.83% Weighted average by PILOT payment of 0.80% 2000-2016 New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 10

Stakeholder Feedback NYTOs recommend that the property tax rate outside NYC be reduced to 0.5% in order to be consistent with the 20 year amortization period Analysis of full PILOT schedules for 3 units Athens, Empire and Bethlehem Consistent with the recommended 20-year amortization period, only the property tax rates for the first 20 years of each plant s life was considered Average tax rate for the 3 units analyzed, based on a 20 year amortization period, was 0.5% Supply-side interests raised concerns regarding whether past PILOT agreement data is representative of future potential PILOT agreements given the current regulatory environment and public policies 2000-2016 New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 11

NYISO Evaluation of LOE-AFs Consultants Recommendation Market Participant Comments NYISO Assessment (Ongoing) 2000-2016 New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 12

Consultants Recommendation LOE-AF values used in the Consultants Final Report are based on the 2016 CARIS Phase 2 database 2016 CARIS Phase 2 database reflects current changes to system conditions and updated parameters, as presented at the July 13, 2016 BIC meeting LOE-AF values established using the 2016 CARIS Phase 2 database is consistent with stakeholder discussions LOE-AF values were determined using the same methodology as the LOE-AF values presented in the Consultants Draft Report using the 2015 CARIS Phase 1 database Referred to as Method 1 in the August 10, 2016 presentation by Analysis Group to the ICAPWG 2000-2016 New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 13

Stakeholder Concerns and Feedback General concern about the impact of the Clean Energy Standard recently approved by the NYPSC on the retirement assumptions in ongoing planning studies such as CARIS Supply-side interests Suggested the methodology of scaling load instead of generation to get to the tariff specified level of excess potentially overstates LOE-AF values Expressed concern that some of the LOE-AF values may be too high 2000-2016 New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 14

Impact of NYISO Recommended Changes on 2017/2018 ICAP Demand Curve Reference Point Prices for Simple Cycle F Class Frame with SCR Capacity Region Consultants Recommended Fuel Requirement Consultants Recommended Reference Point Price NYISO Recommended Fuel Requirement NYISO Recommended Reference Point Price $/kw-mo. $/kw-mo. % Change NYC Dual 18.81 Dual 18.81 0.00% Long Island Dual 13.75 Dual 13.75 0.00% G-J Locality Dual 14.96 Dual 14.96 0.00% NYCA Dual 11.34 Gas Only 10.84-4.4% Note: % change calculated relative to Consultants preliminary reference point prices, as set forth in the Consultants Final Report. The values represent data for the period from August 2013 through July 2016. The values will be updated in September 2016 to reflect final data for the period from September 2013 through August 2016 2000-2016 New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 15

DCR Schedule September 1, 2016: Stakeholder Comments Due on NYISO Staff s Draft Recommendations September 8, 2016 Placeholder for potential, additional ICAPWG meeting to discuss NYISO responses to stakeholder feedback (if requested by stakeholders) Targeted date for completion of NYISO s ongoing assessments on property taxes outside of NYC, and LOE-AF values using the 2016 CARIS Phase 2 database September 15, 2016: NYISO Staff Final Recommendations Posted October 3, 2016: Stakeholder Written Comments Due to NYISO Board of Directors (Board) October 17, 2016: Stakeholder Oral Presentations to Board On or before November 30, 2016: NYISO submits DCR Filing to FERC 2000-2016 New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 16

The mission of the New York Independent System Operator, in collaboration with its stakeholders, is to serve the public interest and provide benefit to consumers by: Maintaining and enhancing regional reliability Operating open, fair and competitive wholesale electricity markets Planning the power system for the future Providing factual information to policy makers, stakeholders and investors in the power system www.nyiso.com 2000-2016 New York Independent System Operator, Inc. All Rights Reserved. DRAFT FOR DISCUSSION PURPOSES ONLY 17