September 18, 2019
By Electronic Delivery
Honorable Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE
Washington, D.C. 20426
Re: Response to Deficiency Letter in Docket No. ER19-2276-000
Dear Ms. Bose:
The New York Independent System Operator, Inc. (“NYISO”) submits this response to the Federal Energy Regulatory Commission’s (“Commission”) deficiency letter issued in this proceeding on August 23, 2019 (“Deficiency Letter”). The Deficiency Letter directs the NYISO to respond to six enumerated questions regarding the NYISO’s June 27, 2019 filing in this
proceeding (the “June 27 Filing”).1 Responses to each of the Commission’s questions are
provided in Attachment I to this letter.
In addition to the attached responses to the Commission’s questions, the NYISO
resubmits certain proposed Tariff revisions (identified as Attachments III and IV in the June 27
Filing). For purposes of this filing, Attachment II contains the redline tariff sections, and
Attachment III contains the clean versions. NYISO proposes to change the requested effective
date for these tariff revisions from November 1, 2019, to May 1, 2020 for the reasons explained
in the NYISO’s September 4, 2019 submittal in this proceeding.2 The NYISO hereby requests
that the remainder of the tariff revisions proposed in its June 27 Filing be permitted to become
effective as proposed in that filing. The NYISO further requests that the Commission issue an
order accepting all of the tariff revisions proposed in the June 27 Filing within 60 days of the
date of this response.
The NYISO will send an electronic link to this filing to the official representative of each
party to this proceeding, to the official representative of each of its customers, to each participant
on its stakeholder committees, to the New York State Public Service Commission, and to the
1 New York Indep. Sys. Operator, Inc., Proposed Tariff Revisions Regarding Establishment of Participation Model for Aggregations of Resources, Including Distributed Energy Resources, and Proposed Effective Dates,
Docket No. ER19-2276 (June 27, 2019) (“June 27 Filing”).
2 New York Indep. Sys. Operator, Inc. September 4, 2019 Filing, Docket No. ER19-2276-000.