Subject: Out-of-Merit


From time to time there have been discussions in the TIE list criticizing Con Edison for its involvement in out-of-merit actions, implying that it is inappropriate for Con Edison control room operators to make such requests.
In its recent order on the Revised Local Mitigation Measures, FERC, in response to allegations made by Orion, ordered the NYISO to take responsibility for out-of-merit.
The Con Edison system has the world's most concentrated use of energy for residential and commercial purposes.
It is also a highly transmission-constrained area where transfer limitations under normal and second contingency conditions require certain minimum generation levels within specific load pockets to assure reliability under existing reliability rules.
One of the main functions of the Con Edison control center is to be vigilant of system conditions at all times and prevent the system from reaching an unreliable operating state.
When such conditions are imminent, the Con Edison operator so advises the NYISO.
Some parties have said that Con Edison operators should never make out-of-merit requests.
Con Edison operators would be acting irresponsibly if they were to detect an imminent unreliable operating condition and just sit back and not inform the NYISO of the potential danger.
Con Edison operators have been trained to focus on operating the New York City system.
The NYISO operators have a much wider state-wide focus.
It is entirely appropriate for both a transmission owner (TO) and NYISO operators to work cooperatively in maintaining reliability with the clear understanding that under the FERC-approved tariff, it is the NYISO that has sole responsibility for reliability.
I would like to clarify that all involvement by Con Edison operators in out-of-merit actions are based on the following  FERC-approved process in which the NYISO, and not the TO operator, has sole responsibility for these actions.
The NYISO FERC Electric Tariff, Section 5.4,  Operations Under Adverse Conditions states in essence that: 		*	The NYISO shall operate the system in accordance with Reliability Rules, including local rules 		*	The NYISO will do this, among other measures, by adjusting generator output levels 		*	The NYISO has sole responsibility for declaring that Adverse Conditions are imminent 		*	Activation of these actions shall involve a two-step process 			1.
The TO involved will advise the NYISO that an Adverse Condition is imminent and recommend action 			2.
The NYISO activates the appropriate procedures 		*	Records of the activation of such procedures shall be maintained by both the TO and the NYISO  Having stated the above, let me also say that Con Edison has been working with NYISO operations to minimize the occurrences of conditions that require Con Edison operators to request actions that result in OOM operations.
Con Edison supports current efforts by the NYISO to manage load pocket reliability events in a way that SCD can be used to maintain reliability with in-merit generation.
In effect, the FERC recent order does not require any change from present practice which is, and has always been, in compliance with Section 5.4 of the NYISO FERC Electric Tariff, and in compliance with FERC's recent order: the NYISO is solely responsible for out-of-merit actions.