10 Krey Boulevard Rensselaer, NY 12144
October 7, 2014
The Honorable Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE
Washington, D.C. 20245
Re: Resubmission of Unexecuted Minimum Oil Burn Agreement Docket No. ER14-
1822-000 and Request that the Commission Hold in Abeyance Proceeding in
Docket No. ER14-1822-000
On June 24, 2014 and again on August 20, 2014, the New York Independent System
Operator, Inc. (“NYISO”) and TC Ravenswood, LLC filed requests simultaneously to hold the
proceedings in Docket No. ER14-1711 and ER14-1822 in abeyance (the “Joint Request”). The
Joint Request explained that delaying action in both dockets would allow the NYISO, TC
Ravenswood, and other interested parties more time to engage in settlement discussions.
Since that time, TC Ravenswood, the NYISO, the New York State Public Service
Commission (“NYSPSC”), Consolidated Edison Company of New York, Inc. (“Con Edison”)
and other parties to the proceedings have continued their discussions with the goal of settling
both dockets. The parties continue to work towards the goal of achieving a settlement that will
be supported, or not opposed, by all parties to the two proceedings. The NYISO and TC
Ravenswood believe we are very close to finalizing an agreement. However, the parties need
additional time to resolve the language to be included in the settlement documents, obtain
internal authority to finalize them, seek support from other parties, and make the appropriate
filings with the Commission. The NYISO and TC Ravenswood have mutually agreed that each
will seek to have the Commission hold their respective proceedings in abeyance for another 60
days, until December 5, 2014. While the NYISO believes the issues will settle and a filing will
be made well before this date, requesting the full 60 day extension appears prudent.
Accordingly, the NYISO respectfully submits the pending tariff record from its April 30,
2014 filing in Docket No. ER14-1822-000 with the same text and proposed effective date as in
the original filing.1 The NYISO understands that filing a pending tariff record will be treated by
the Commission as an amendment, defer Commission action for 60 more days, or until
December 5, 2014, and preserve the May 1, 2014 effective date originally requested by the
NYISO. The NYISO also understands that TC Ravenswood intends to make a similar filing in
Docket No. ER14-1711-000.
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.
Kimberly D. Bose, Secretary October 7, 2014
Page 2
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.
This filing will be posted on the NYISO’s website at www.nyiso.com. In addition, the
NYISO will e-mail an electronic link to this filing to the official representative of each party to
this proceeding, to each of its customers, to each participant on its stakeholder committees, to the
New York Public Service Commission, and to the New Jersey Board of Public Utilities.
Please feel free to contact me if your office has any additional questions.
Respectfully submitted,
/s/ Mollie Lampi
Mollie Lampi
Assistant General Counsel
New York Independent System Operator, Inc. (518) 356 7530
Cc: Michael Bardee
Gregory Berson
Anna Cochrane
Jignasa Gadani
Morris Margolis
Michael McLaughlin
David Morenoff
Daniel Nowak