UNITED STATES OF AMERICA
BEFORE THE

FEDERAL ENERGY REGULATORY COMMISSION

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New York Independent System Operator, Inc.)Docket Nos. ER08-1281-010

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REQUEST FOR EXTENSION OF TIME TO SUBMIT COMPLIANCE FILING,

SHORTENED NOTICE AND COMMENT PERIOD AND EXPEDITED COMMISSION
ACTION OF THE NEW YORK INDEPENDENT SYSTEM OPERATOR, INC.

Pursuant to Rule 212 of the Federal Energy Regulatory Commission’s (“Commission’s”) Rules of Practice and Procedure,1 the New York Independent System Operator, Inc. (“NYISO”) submits this Request for Extension of Time to Submit Compliance Filing, Shortened Notice and Comment Period and Expedited Commission Action (“Request”).

On March 30, 2012, the NYISO submitted a request that the Commission schedule an onthe-record technical conference in the above-captioned Docket to permit the NYISO to obtain Commission Staff guidance on its proposed method of achieving compliance with the
Commission’s March 15, 2012 Order on Compliance Filing (“March 15 Order”).  The NYISO’s March 30 pleading included a request for extension of time to permit the NYISO to submit its compliance filing 30 days after the requested technical conference is held.  The purpose of the requested extension of time is to permit the NYISO an opportunity to incorporate the guidance it receives at the technical conference into the Tariff revisions it submits.

On April 10, 2012, the Commission issued a Notice of Extension granting the NYISO an
extension of time, until May 10, 2012, to submit its compliance filing.  The Notice of Extension

1 18 C.F.R. § 385.212 (2012).

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did not rule on the NYISO’s request for a technical conference and the Commission has not yet ruled on the NYISO’s request.

The NYISO now requests that the Commission grant the NYISO an additional extension of time to permit the NYISO to submit its compliance filing either 30 days after the date of the
requested technical conference or 30 days after the Commission issues an order denying the
NYISO’s request for a technical conference.  Because the NYISO’s compliance filing is
currently due on May 10, 2012, the NYISO requests that the Commission abbreviate the
notice period for submitting comments on this Request and that the Commission rule on
this Request by May 7, 2012.

I. Request for Extension of Time to Submit Compliance Filing

The NYISO is required to submit its compliance filing in the above Docket by Thursday,
May 10, 2012.2  The NYISO requests that the Commission grant an additional extension to
permit the NYISO to submit its compliance filing 30 days after the date of the technical
conference or 30 days after the Commission issues an order denying the NYISO’s request for
technical conference.  Granting the NYISO 30 days after the technical conference, if the
Commission is willing to schedule such a technical conference, will enable the NYISO to
incorporate the guidance received from Commission Staff3 into the compliance filing it submits.
On March 30, 2012, the NYISO requested an opportunity to present to Commission Staff how it proposes to comply with the March 15 Order, and to seek further guidance from
Commission Staff regarding the NYISO’s proposal.  The NYISO committed to provide technical
conference materials to the Commission and other interested parties prior to the technical

2 May 10, 2012 is 30 days after the date of the April 10, 2012, Notice of Extension.

3 The NYISO recognizes that Commission Staff is not the Commission, and that the Commission’s authority to

consider and rule on the NYISO’s compliance filing will not be bound by guidance that the NYISO receives from Commission Staff.

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conference.  Consistent with its commitment, on April 10, 2012, the NYISO submitted all of its
proposed technical conference materials to the Commission.  The materials submitted to the
Commission include: (1) the NYISO’s technical conference presentation; (2) the NYISO’s
external Market Monitoring Unit’s (“NYISO MMU’s”) technical conference talking points; and

(3) PJM Interconnection, LLC’s (“PJM’s”) technical conference talking points.

If the Commission is prepared to schedule such a technical conference and to permit

Commission Staff to provide guidance, the NYISO would prefer to move forward with its

compliance filing after it receives Commission Staff guidance at the technical conference.

Obtaining input from Commission Staff regarding the NYISO’s proposal will enable the NYISO
to better understand the scope and nature of the compliance obligations imposed by the March 15
Order, and should reduce the administrative burden on both the NYISO and the Commission.
Providing the NYISO sufficient time to incorporate Commission Staff’s guidance into its filing
should, in turn, reduce the likelihood that the Commission will be required to issue additional
orders requiring modifications to the NYISO’s compliance filing, should the Commission find
such actions necessary.

II.Request for Shortened Notice and Comment Period and Expedited Commission

Action on this Request

Unless the Commission grants the NYISO’s requested extension of time to submit its
compliance filing, the NYISO is required to submit its compliance filing on May 10, 2012.  In
order to provide the NYISO with sufficient time to prepare and submit a compliance filing if the
Commission decides to reject this Request, the NYISO requests that the Commission employ a
shortened notice and comment period, and issue a ruling on this request by close-of-business on
May 7, 2012.

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III.Conclusion

WHEREFORE, the New York Independent System Operator, Inc. respectfully requests
that the Commission act on an expedited basis and issue a ruling by May 7, 2012 on the
NYISO’s request for an extension of time to submit a compliance filing in response to the March

15 Order until 30 days after either (a) the date of the requested technical conference, or (b) the date the Commission rejects the NYISO’s request for a technical conference.

Respectfully submitted,

/s/  Alex M. Schnell

Robert E. Fernandez, General Counsel Alex M. Schnell

James H. Sweeney

New York Independent System Operator, Inc.

Dated:  May 2, 2012

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CERTIFICATE OF SERVICE

I hereby certify that I have this day served the foregoing document upon each person

designated on the official service list compiled by the Secretary in this proceeding in accordance with the requirements of Rule 2010 of the Rules of Practice and Procedure, 18 C.F.R. §385.2010.
Dated at Rensselaer, NY this 2nd day of May, 2012.

/s/ Joy A. Zimberlin

Joy A. Zimberlin

New York Independent System Operator, Inc

10 Krey Blvd.

Rensselaer, NY 12144 (518) 356-6207