Cricket Valley Energy argues points related to its 1,000-MW project

Cricket Valley Energy Center LLC (CVEC), developer of a gas-fired, 1,000-MW project in New York, on Jan. 29 filed comments with the Federal Energy Regulatory Commission in a case involving the New York ISO.

In a recent answer in this case, the NYISO responded to and generally expressed support for the relief requested in the complaint filed by Consolidated Edison Co. of New York, Orange and Rockland Utilities, New York State Electric and Gas, Rochester Gas and Electric and Central Hudson Gas and Electric. Those companies have argued that there should be a competitive entry exemption to the buyer-side mitigation (BSM) measures currently applicable to the NYISO’s market for installed capacity (ICAP).

“The NYISO Answer, while supportive of the need for a competitive entry exemption (‘CEE’) from BSM, did not support several aspects of the Complainants’ proposed CEE design,” Cricket Valley noted. “Specifically, the NYISO did not support Complainants’ Proposal with respect to the de minimis exception for non-qualifying contractual relationships, the self-certification requirement (‘Certification’), and the penalties for violation of the Certification requirement. CVEC offers this brief response to the issues raised in the NYISO Answer in order to provide the perspective of a developer that will be seeking a CEE, if available under the NYISO tariff. In short, CVEC generally supports the NYISO’s CEE Proposal, but does not support the proposals made by certain intervenors to add requirements to the Certification that will make it more burdensome for competitive developers. In general, CVEC also supports the Complainants’ efforts to streamline the Certification process to the extent that such changes would not substantially weaken the NYISO’s ability to ensure that only competitive projects take advantage of the CEE.”

CVEC plans to construct an approximately 1,000-MW combined cycle project on a site located in Dover, Dutchess County, New York. After initially entering the NYISO interconnection queue in 2008, the CVEC facility is now in an advanced stage of preconstruction development.

“If a competitive entry exemption from BSM is not soon implemented, CVEC will most likely be required to bid into the ICAP market subject to an offer floor, because it will be located within the new Lower Hudson Valley mitigated capacity zone in New York State,” CVEC wrote. “CVEC is therefore in a position to provide unique and relevant insight concerning the developer Certification requirement and other aspects of the CEE at issue in the Complaint and NYISO Answer, among other pleadings in this docket. Accordingly, good cause exists to accept and consider this answer as part of the record in this proceeding.”

About Barry Cassell 20414 Articles
Barry Cassell is Chief Analyst for GenerationHub covering coal and emission controls issues, projects and policy. He has covered the coal and power generation industry for more than 24 years, beginning in November 2011 at GenerationHub and prior to that as editor of SNL Energy’s Coal Report. He was formerly with Coal Outlook for 15 years as the publication’s editor and contributing writer, and prior to that he was editor of Coal & Synfuels Technology and associate editor of The Energy Report. He has a bachelor’s degree from Central Michigan University.