10 Krey Boulevard Rensselaer, NY 12144
June 24, 2014
The Honorable Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE
Washington, D.C. 20245
Re: Submission of Amendment in Docket No. ER14-1822-000 to Address eTariff
Requirements in Connection with Joint Request that the Commission Hold
Proceedings in Abeyance, Submitted in Docket Nos. ER14-1711-001 and ER14-
1822-000 (Not Consolidated)
On June 20, 2014, the New York Independent System Operator, Inc. (“NYISO”) and TC
Ravenswood, LLC (“TCR”) filed a joint request to hold the proceedings in Docket No. ER14-
1711 and ER14-1822 in abeyance (the “Joint Request”). TCR had submitted a tariff filing that
initiated Docket No. ER14-1711 on April 11 and made an amended filing in that proceeding on
May 19. The NYISO initiated Docket No. ER14-1822 by filing an unexecuted service
agreement on April 30, 2014. The Joint Request explained that delaying action in both dockets
would allow the NYISO, TCR, and other interested parties more time to engage in settlement
discussions.
It has been brought to the NYISO’s attention that your office has determined that the
Joint Request is subject to the eTariff filing requirements that are described at
http://www.ferc.gov/docs-filing/etariff/comm-order/extend-date.pdf (“eTariff Requirements”).
Under the eTariff Requirements “filings to extend the date by which the Commission must act
are required to be made under the eTariff filing procedures for amendment filings in section
35.17(b) of the Commission’s regulations.”
Accordingly, the NYISO respectfully submits the pending tariff record from its April 30,
2014 filing in Docket No. ER14-1822 with the same text and proposed effective date as in the
original filing.1 The NYISO’s understanding is that the filing of a pending tariff record will be
treated by the Commission as an amendment and, by complying with the eTariff requirements,
will defer Commission action 60 days or, in this case, until August 25, 2014. This filing will
also preserve the May 1, 2014 effective date originally requested by the NYISO. The NYISO
also understands that TCR intends to make a similar filing in Docket No. ER14-1711.
Because this filing is designed to simply obtain an extension of the statutory date for the
Commission to act on the NYISO’s proposed Unexecuted Minimum Oil Burn Agreement, the
NYISO requests that the Commission provide a shortened comment period. The NYISO also
1 As Attachment I to this filing letter, the NYISO is submitting a clean version of the proposed Unexecuted Minimum Oil Burn Agreement that it first submitted on April 30, 2014.
