10 Krey Boulevard Rensselaer, NY 12144
October 1, 2010
By Electronic Filing
Hon. Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission 888 First Street, NE
Washington, DC 20426
Re: Application of TC Ravenswood, LLC to Implement a Minimum Oil Burn Service
Cost of Service Recovery Rate Schedule, Docket No. ER10-1359-000;
TC Ravenswood, LLC v. New York Independent System Operator, Inc., Docket
No. EL10-70-000
Dear Secretary Bose:
By Motion filed August 16, 2010, the New York Independent System Operator, Inc.
(“NYISO”) requested that the Commission hold the above captioned proceedings in abeyance
and suspend the filing deadlines for sixty days.1 The NYISO explained that a period within
which all matters in these dockets were held in abeyance would allow the parties to continue
settlement negotiations without the pressure of also litigating the same issues before the
Commission.
On August 18, 2010, TC Ravenswood filed in support of the NYISO’s August 16, 2010
Motion including the NYISO’s request to suspend filing deadlines.2 By letter dated August 30,
2010, TC Ravenswood reported to the Commission that negotiations were on-going and renewed
its request that the Commission continue to defer issuing substantive orders in both dockets.
By letter dated September 28, 2010, TC Ravenswood now reports that the parties to these negotiations remain far apart. Therefore, TC Ravenswood has requested that the Commission act within 30 days on its pending application in Docket No. ER10-1359-000 and act
expeditiously with respect to its complaint in Docket No. EL10-70-000.
1 See: Motion to Hold Proceedings in Abeyance, Request to Suspend Filing Deadlines, and Request for Expedited
Procedure, filed August 16, 2010. The NYISO Motion followed the July 21, 2010 letter request by TC
Ravenswood to defer action in the two dockets; See: Letter from Kenneth Wiseman to Secretary Bose, dated July
21, 2010 in these dockets. The NYISO is unaware of any action by the Commission in response to these pleadings.
2 See: TC Ravenswood LLC’s Response to the New York Independent System Operator, Inc.’s Motion to Hold
Proceedings in Abeyance, Request to Suspend Filing Deadlines and Request for Expedited Procedures, filed August 18, 2010 in this docket.
The Honorable Kimberly Bose October 1, 2010
Page 2
The NYISO agrees that there appears, at the moment, to be no reason to continue to hold these proceedings in abeyance and the NYISO agrees with the TC Ravenswood request that the Commission restart the proceedings in these two dockets.
The NYISO further requests that the Commission allow a fifteen-day period in Docket
No. EL10-70-000, starting Monday, October 4, 2010, for parties to respond to the TC
Ravenswood Answer filed August 2, 2010, the day before the first settlement conference was
convened at NYISO headquarters, and twelve days after TC Ravenswood’s July 21, 2010 request
to suspend Commission action in this docket. In its August 2, 2010 Answer, TC Ravenswood
requested that the Commission strike the affidavit the NYISO had submitted in its answer to the
TC Ravenswood May 27, 2010 Protest against the NYISO. The fifteen-day period will allow the
NYISO an adequate opportunity to address TC Ravenswood’s request to strike this affidavit.
Respectfully submitted,
_/s/Mollie Lampi _______________ Mollie Lampi
Assistant General Counsel
New York Independent System Operator, Inc.
10 Krey Blvd.
Rensselaer, New York 12144 (518) 356 8540
mlampi@nyiso.com
cc:Michael A. Bardee
Gregory Berson
Connie Caldwell
Anna Cochrane
Jignasa Gadani
Lance Hinrichs
Jeffrey Honeycutt
Michael Mc Laughlin
Kathleen E. Nieman
Daniel Nowak
Rachel Spiker