FERC Filings
MOTION FOR LEAVE TO INTERVENE AND PROTEST Re: NYISO
- I. THE NYISO HAS NOT DEMONSTRATED THAT “EXIGENT CIRCUMSTANCES” EXIST AND HAS NOT COLLECTED AMPLE INPUT FROM NEW YORK STAKEHOLDERS
- THE NYISO’S PENALTY PROVISION PROGRAM WILL UNDERMINE THE DEVELOPMENT OF COMPETITIVE MARKETS, INCREASE UNCERTAINTY AND DRIVE SUPPLY OUT OF NEW YORK.
- II. THE NYISO HAS FAILED TO DEMONSTRATE THE NEED FOR ITS PENALTY PROVISIONS
- CONCLUSION