UNITED STATES OF AMERICA
BEFORE THE

FEDERAL ENERGY REGULATORY COMMISSION

Enhancement of Electricity Market

Surveillance and Analysis Through OngoingDocket No. RM11-17-001

Electronic Delivery of Data From Regional

Transmission Organizations and Independent System Operators

MOTION FOR EXTENSION OF TIME TO COMPLY AND

REQUEST FOR EXPEDITED COMMISSION ACTION OF THE
NEW YORK INDEPENDENT SYSTEM OPERATOR, INC.

Pursuant to Rules 212 and 2008 of the Commission’s Rules of Practice and Procedure,1 the New York Independent System Operator, Inc. (the “NYISO”) respectfully submits this
Motion for Extension of Time to Comply (“Motion”) with the Federal Energy Regulatory
Commission’s (“FERC” or “Commission”) Order No. 760.2 The NYISO requests an extension to commence ongoing electronic delivery of each of the four datasets described in the Order and proposes a schedule for compliance below.

Because the compliance filing is due on August 20, 2012, and the corresponding compliance obligations also begin on that date, the NYISO respectfully requests that the Commission act expeditiously on this Motion.

18 C.F.R. §§ 385.212 and 385.2008 (2011).

Enhancement of Electricity Market Surveillance and Analysis Through Ongoing Electronic Delivery of Data From Regional Transmission Organizations and Independent System Operators, Order No. 760, 139 FERC ¶ 61,053 (2012) (“Order No. 760” or “the Order”).

I.INTRODUCTION AND SUMMARY

Order No. 760 imposes new requirements on each regional transmission organization (“RTO”) and independent system operator (“ISO”, collectively “RTOs/ISOs”) to electronically deliver, on an ongoing basis, data related to the markets each RTO/ISO administers to the
Commission. The amended regulations require ongoing, electronic delivery of data relating to physical and virtual offers and bids, market awards, resource outputs, marginal cost estimates, shift factors, financial transmission rights, internal bilateral contracts, uplift, and interchange pricing. According to the Commission:

“[s]uch data will facilitate the Commission’s development and

evaluation of its policies and regulations and will enhance

Commission efforts to detect anti-competitive or manipulative

behavior, or ineffective market rules, thereby helping to ensure just and reasonable rates.”3

Order No. 760 specifies the implementation timeline for commencing ongoing electronic
delivery to the Commission. The RTOs/ISOs are directed to implement the ongoing delivery of
four datasets no later than August 20, October 4, December 3, 2012 and February 1, 2013,
respectively.

For the reasons set forth below, the NYISO requests an extension of time to comply with each of these four deadlines as follows:

Task

Compliance Filing

Commence Ongoing Delivery of First Dataset

Commence Ongoing Delivery of Second Dataset

Implementation Deadline in
Order No. 760

August 20, 2012
August 20, 2012
October 4, 2012

NYISO’s Requested
Implementation Deadline

August 20, 2012
March 4, 2013
April 4, 2013

Commence Ongoing DeliveryDecember 3, 2012June 4, 2013

of Third Dataset

Commence Ongoing DeliveryFebruary 1, 2013September 4, 2013

of Fourth and Final Dataset

II.BACKGROUND

On October 20, 2011, the Commission issued a notice of proposed rulemaking to revise
its regulations to require each RTO/ISO to electronically deliver to the Commission, on an
ongoing basis, data related to the markets that it administers (“NOPR”). Approximately one
month later, the Commission sent a data request to each RTO/ISO seeking 26 months of
historical data for the same market data that was contemplated in the NOPR (“26-Month Data
Request”). In multiple discussions with FERC Staff and members of the RTOs/ISOs, the 26-
Month Data Request was described as a method for FERC Staff to collect and begin to
understand the data elements and format that the RTOs/ISOs would utilize in their efforts to
comply with the NOPR when it became a final rule. FERC Staff issued a second, less extensive,
data request mirroring the data elements discussed in the NOPR due to the length of time that the
RTOs/ISOs required to produce the significant quantity of data requested in the 26-Month Data
Request. The second request was for one day of market data (“1-Day Data Request”).
The NYISO responded fully to the 1-Day Data Request with five separate submissions on January 13, 2012, January 20, 2012, January 27, 2012, February 3, 2012, and March 2, 2012. The NYISO then responded fully to the 26-Month Data Request with four separate submissions on April 6, 2012, April 13, 2012, April 27, 2012, and May 31, 2012.4

4 The fourth and final submission was delivered to FERC Staff on May 31, 2012 and included the

NYISO’s capacity market data. The timeline for this submission was agreed to with FERC Staff and was later than the other submissions due to the timing of the NYISO’s capacity market auctions.

On April 19, 2012, the Commission issued Order No. 760 based on the NOPR from October 2011.5 NYISO immediately began work to comply with the Order based on its
responses to the 1-Day Data Request and 26-Month Data Request consistent with FERC Staff discussions. The NYISO’s expectation was to deliver data pursuant to the Order in a format consistent with the data request responses. FERC Staff indicated to the NYISO, for the first time, on June 1, 2012, that the format the NYISO used for its data request responses was not the desired format for ongoing Order No. 760 compliance.

On June 12, 2012, FERC Staff issued File Submission Guidelines for FERC Order 760
(“Submission Guidelines”) providing detailed instructions to the RTOs/ISOs regarding how to
format and submit the ongoing electronic data deliveries to the Commission. After issuing the
Submission Guidelines, FERC Staff emphasized that the NYISO should not take any further
steps to provide data in response to the Order in the format that was utilized to prepare NYISO’s
responses to the 1-Day and 26-Month Data Requests. Accordingly, since June 12, 2012, the
NYISO has been diligently developing a project plan to comply with Order No. 760 and the
modified expectations announced by FERC Staff. The NYISO supports the approach outlined in
FERC Staff’s Submission Guidelines and agrees that this approach is more technically sound
given the NYISO’s understanding of the Commission’s long term objectives.

III.DOCUMENTS SUBMITTED

1.This Motion; and

2.The Affidavit of Mr. Richard Dewey, the NYISO’s Senior Vice President

and Chief Information Officer (Attachment A).

5 Order No. 760 was published in the Federal Register on May 7, 2012. This date defines the timelines specified in Order No. 760 discussed throughout this pleading.

IV.COPIES OF CORRESPONDENCE

Correspondence concerning this filing should be served on: Robert E. Fernandez, General Counsel

Raymond A. Stalter, Director of Regulatory Affairs *James H. Sweeney, Attorney

New York Independent System Operator, Inc.

10 Krey Boulevard

Rensselaer, NY 12144
Tel: (518) 356-7659
Fax: (518) 356-7678
jsweeney@nyiso.com

* Person designated for receipt of service

V. MOTION FOR EXTENSION OF TIME TO COMPLY WITH ORDER NO. 760

AND THE CORRESPONDING SUBMISSION GUIDELINES

The Commission published Order No. 760 in the Federal Register on May 7, 2012

triggering RTO/ISO compliance obligations on August 20, October 4, December 3, 2012 and

February 1, 2013.6 The NYISO respectfully requests an extension of time to comply with these
four deadlines in order to develop and test the software necessary to facilitate the sustainable
ongoing electronic delivery of market data to the Commission in accordance with Order No. 760
and the Submission Guidelines. The NYISO believes that the software development and testing
schedule proposed in this Motion is critical to ensure the successful implementation of ongoing
electronic delivery of market data in a method that is beneficial to the Commission and satisfies
Order No. 760 and all the requirements detailed in the subsequently issued Submission

6 77 Fed. Reg. 26,674 (May 7, 2012).

Guidelines. The NYISO requires an extension of time to comply for the reasons discussed
below.

A.The NYISO Must Largely Start from Scratch to Satisfy the Requirements of

FERC’s Submission Guidelines

Order No. 760 states that the Commission “will allow data to be electronically delivered to the Commission in a format consistent with how the data is collected in each RTO and ISO system.”7 Further, the Commission “will direct that such data be delivered in one of two file types; namely, Comma Separated Value (i.e., CSV) or Tab Delimited. … they are commonly used file types and provide sufficient flexibility to allow for divergent formatting schemes
among the RTOs and ISOs.”8 Based on this language the NYISO began developing a system to commence ongoing electronic data delivery to the Commission in the same flat CSV format that was utilized in its responses to the 1-Day and 26-Month Data Requests.

The File Submission Guidelines for FERC Order 760 were then issued by FERC Staff on
June 12, 2012 providing significantly more detail on how the Commission expects the data
provided by the RTOs/ISOs to be formatted and delivered on an ongoing basis. The Submission
Guidelines require the RTO/ISO data be formatted into Fact and Dimension tables for
submission to FERC.9 This formatting obligation drastically reduces the flexibility of formatting
schemes contemplated by the Order. The Commission’s Order specifies that RTO/ISO data be
delivered in CSV file types intended to “provide sufficient flexibility to allow for divergent

7 Order No. 760, P. 40.

8 Order No. 760, P. 42.

9 Submission Guidelines, P11-12. The Fact Tables must contain the actual data facts and the Dimension Tables, companion tables to the Fact Tables, must contain the descriptive attributes necessary for query constraining/filtering and query result set labeling.

formatting schemes consistent with how the data is collected in each RTO/ISO.”10 The Order
considers “format to include the structure of the data (i.e., the data tables, columns, rows, and
fields), as well as details relating to the data specifications for each field (i.e., string, numeric,
etc.).”11

The data formatting and delivery requirements in the Submission Guidelines differ

significantly from the approach the NYISO was developing to comply with Order No. 760. The
NYISO’s responses to the 1-Day and 26-Month Data Requests were not formatted as Fact and
Dimension tables; the NYISO’s data was formatted into a group of flattened CSV files pursuant
to its understanding of the NOPR. The use of Fact and Dimension tables requires the NYISO to
design software that will pull its market data and separate the data into Fact or Dimension tables
and to design an entity relationship model (a.k.a. “Entity Relationship Diagram” or “ERD”) that
will link the Fact tables to, any number of, applicable Dimension tables. The new software will
require two stages of design. The first stage will identify the location of the market data

elements in the NYISO’s source files and extract the necessary market data from its source files. The second stage of the design will separate the market data into Fact and Dimension tables. Both stages are necessary to generate the data tables required in Order No. 760 in the format requested by FERC Staff in the Submission Guidelines. The Fact and Dimension tables must be specifically designed in a manner that allows the FERC to comprehend and query the data. The Submission Guidelines’ requirements introduce substantial new and additional work that the NYISO must undertake to comply with the Order.

10 Order No. 760, P. 42; See also, Order No. 760, P. 40.

11 Order No. 760, FN 72.

The Commission’s expectations regarding the data dictionary and data format required to comply with the Order only became clear to the NYISO after the Submission Guidelines were received on June 12, 2012. As a result of these additional requirements, the NYISO cannot use the data dictionary, ERD or data format that the NYISO created in order to respond to the 1-Day and 26-Month Data Requests. The NYISO now must develop new data collection and
formatting software, a new data dictionary and new ERDs, resulting in a significant new
software development effort that was not anticipated.

B.The Critical NYISO Resources are Fully Committed to Other Regulatory

Compliance Projects

The NYISO employs a limited number of software developers with the knowledge of the
internal market data and the technical skills required to develop the software necessary for
ongoing collection and delivery of the data requested in Order No. 760. These scarce resources
are currently fully committed to other regulatory compliance projects requiring the same
extensive understanding of the software and hardware used to run the NYISO’s markets and
retain the market data.12 For example, experienced NYISO software developers, whose
participation in the Order No. 760 project is absolutely necessary, must continue their full-time
work on the current Commission-mandated projects to comply with FERC Order No. 75513 and
to timely complete and implement the Market-to-Market Coordination project (“M2M
Coordination Project”) with PJM Interconnection, LLC (“PJM”).14 If the NYISO’s experienced
software developers are pulled from those other Commission-mandated projects in order to

12 These necessary resources were available to assist with the 1-Day and 26-Month Data Requests.

13 Frequency Regulation Compensation in the Organized Wholesale Power Markets, Order No. 755, 137 FERC ¶ 61,054 (2011) (“Order No. 755”).

14 See, New York Independent System Operator, Inc., 133 FERC ¶ 61,276 (2010) and New York Independent System Operator, Inc., 136 FERC ¶ 61,011 (2011).

comply with Order No. 760, the NYISO will not be able to meet the deadlines associated with those compliance projects.

The FERC Order No. 755 compliance project and the M2M Coordination Project have
been combined into a single software development effort due to the timing, complexity and
substantial overlap of software systems. The software associated with this massive combined
project is slated for deployment in October 2012. It will be the largest single deployment by the NYISO since the NYISO’s Standardized Market Design II software was deployed in February of 2005. The NYISO believes it is critical to complete these ongoing projects prior to beginning
the Order No. 760 compliance project. The NYISO IT team has been fully engaged in the M2M Coordination Project since February 2012 and the Order No. 755 compliance project since April 2012. A continued tight focus on these combined projects is necessary to achieve the October
2012 deployment and overall compliance timelines.15

C. The NYISO’s Internal Market Data and Data Retention would be subject to

Substantial Risk by Starting the Order No. 760 Compliance Project Now

The NYISO must develop new software to implement the data collection and delivery
requirements of Order No. 760. The new software is expected to follow industry standard data
extraction processes. Therefore, the data extraction process will rely on the NYISO’s internal
market data retention structure which is in flux as part of the October deployment for the M2M
Coordination Project and Order No. 755 compliance project. The projects for the October 2012

15 The software necessary to complete the NYISO’s Order No. 755 compliance project and M2M

Coordination Project will be deployed in October 2012, however, the projects will not be fully

implemented until later in October 2012 and January 15, 2013, respectively. The NYISO needs until early January 2013 to appropriately train its system operators on the new tools that will be installed for Market-to-Market with PJM. The system operator training sessions will begin around the time of the software deployment and continue through early January 2013, approximately 12 weeks.

deployment impact over 80% of the IT systems employed by the NYISO, which is a much wider
impact than the NYISO typically undertakes in a single deployment. If the additional software
code necessary for Order No. 760 is started in parallel with these projects, there would be
significant added risk to the extraction code which could result in failed data collection or
inaccurate data submission to the Commission. Furthermore, the NYISO cannot undertake the
additional software code necessary for Order No. 760 in parallel with current projects due to the
significant risk that such development could interfere with existing software.
The limitations imposed by the market data knowledge and software development skill required to develop software to comply with Order No. 760 and the risk that additional software development would introduce to all NYISO projects make it impractical to utilize additional software developers to speed the delivery of an Order No. 760 compliance project.
VI. PROPOSED PLAN AND SCHEDULE FOR IMPLEMENTING ORDER NO. 760
The NYISO has developed an aggressive proposed Order No. 760 implementation
schedule. The implementation schedule relies on NYISO staff resources currently committed to
the other regulatory compliance projects discussed above.

A.NYISO Resources

The NYISO must utilize internal software developers with extensive knowledge of the
NYISO’s market systems and market data to develop the software necessary to comply with
Order No. 760 and the requirements of the Submission Guidelines. The NYISO’s primary
software developers needed for Order No. 760 are currently fully committed to the NYISO’s
M2M Coordination and Order No. 755 compliance projects and are not available to begin work

on Order No. 760 compliance until mid-August 2012.16 Software developers will begin working
fulltime on the Order No. 760 compliance project in August 2012 and will continue, almost
fulltime, through June 2013. Additional software developers will be added to this compliance
project in September 2012 and January 2013, and be engaged, almost fulltime, through June
2013. The software developers will work in parallel to achieve the most aggressive schedule
possible; however, not all of the work necessary to complete this compliance project can be
accomplished simultaneously. The software necessary to deliver the first and second datasets
will be developed almost in parallel. Software development will be followed by quality
assurance testing for each dataset in-series, i.e., the quality assurance testing cannot be
completed simultaneously for multiple datasets. The NYISO must perform quality assurance
testing individually for each dataset in order to isolate and identify any issues with the software;
otherwise it would be very difficult to determine which dataset each software issue related to or
if each issue impacted more than one dataset.

The NYISO proposes the following project schedule to develop and deliver a product that
will satisfy the requirements of Order No. 760 and the Submission Guidelines. The proposed
Order No. 760 compliance project implementation schedule is aggressive, but feasible, and the
NYISO respectfully requests that the Commission adopt the implementation schedule proposed
below. The proposed schedule takes into account the efforts that will be necessary to enhance the

16 Between the ISO/RTO Council’s (“IRC”) submission of comments in response to the NOPR and the
issuance of the final order, the NYISO’s 2012 project obligations increased substantially with the
issuance of FERC Order 755. During the time the NYISO was working with the IRC to draft comments
on the NOPR, the NYISO was not aware of the extent of the staff commitments that would be required
for the Order No. 755 compliance project. In April 2012, NYISO IT, including the software developer
who worked on the 1-Day and 26-Month Data Requests and is imperative to the Order No. 760
compliance project, began working fulltime to develop the Order No. 755 software slated for the October
2012 deployment.

NYISO’s software capabilities and operating procedures to successfully administer the ongoing electronic delivery of market data necessary to properly comply with Order No. 760 and the Submission Guidelines.

B.NYISO’s Requested Implementation Schedule

1.Commencement of the Ongoing Delivery of the First Dataset as

Described in Order No. 760

The NYISO is in the process of identifying the project requirements for the first dataset
and should have a complete set of requirements developed by the end of July. Once the project
requirements are clearly defined qualified software developers will begin software development
in August 2012. Software development for the first dataset is expected to be complete in
December 2012. Quality assurance testing will begin immediately after completion of the
software and is expected to be complete by early March 2013. The NYISO proposes to
commence ongoing electronic delivery of the first dataset to the FERC on March 4, 2013.

2.Commencement of the Ongoing Delivery of the Second Dataset as

Described in Order No. 760

The NYISO will identify the project requirements for the second dataset during the

month of August 2012. However, qualified software developers will not be available to program
the software until part way through October 2012 when the NYISO is able to redirect staff from
the ongoing, combined M2M Coordination and Order No. 755 compliance projects to the Order
No. 760 compliance project. Software development for the second dataset is expected to be
complete in January 2013. Quality assurance testing will begin immediately after completion of
the software and is expected to be complete by early April 2013. The NYISO proposes to
commence ongoing electronic delivery of the second dataset to the FERC on April 4, 2013.

3.Commencement of the Ongoing Delivery of the Third Dataset as

Described in Order No. 760

The NYISO will identify the project requirements for the third dataset during the month
of January 2013. However, the qualified software developers will not be available to program
this software until part way through February 2013 when the second dataset software testing is at
least partially complete. Software development for the third dataset is expected to be complete
in April 2013. Quality assurance testing will begin shortly after completion of the software,
there may be a slight delay while testing is completed on the second dataset. Quality assurance
testing is expected to be complete by early June 2013. The NYISO proposes to commence
ongoing electronic delivery of the third dataset to the FERC on June 4, 2013.

4.Commencement of the Ongoing Delivery of the Fourth Dataset as

Described in Order No. 760

The NYISO will identify the project requirements for the fourth dataset during the month
of January 2013. However, the qualified software developers will not be available to program
this software until part way through February 2013 when the first dataset software testing is at
least partially complete and the NYISO is able to redirect additional staff from the ongoing,
combined M2M Coordination and Order No. 755 compliance projects to the Order No. 760
compliance project. Software development for the fourth dataset is expected to be complete in
June 2013. The software development for this phase of the Order No. 760 compliance project is
projected to take longer than the other phases because the data is not currently retained in a
centralized database. The NYISO must develop a software system to collect and store the data in
one central NYISO database before the data can be formatted and delivered to the FERC in
accordance with the Submission Guidelines. Quality assurance testing will begin shortly after
completion of the software, there may be a slight delay while testing is completed on the third
dataset. Quality assurance testing is expected to be complete by early September 2013. The

NYISO proposes to commence ongoing electronic delivery of the fourth dataset to the FERC on September 4, 2013.

C.Schedule for Delivery of Data Dictionary, Entity Relationship Model and File

Transfer Record Layout

The Order requires submission of the following documentation prior to commencing
ongoing data delivery: (i) a data dictionary; (ii) an entity relationship model; and (iii) a file
transfer record layout.17 This documentation will provide details about the market data such as
meaning, relationships to other data, origin, usage, and format, as well as details defining the
method for identifying new record submissions and record corrections (i.e., an addition to,
change in, or deletion of previously delivered data).18 FERC Staff has requested that the NYISO
consider providing the data dictionary, ERDs, and file transfer layout documentation more than

30 days prior to the first day of the ongoing delivery of each dataset.19 In order to comply with
the data dictionary requirements specified in the Order and the additional requirements contained
in the Submission Guidelines, the NYISO must re-evaluate all its data source file identification
and design new data collection and formatting software for each dataset prior to generating the
documentation required by the Commission prior to each phase of delivery. The NYISO must
complete the majority of its data collection and logical data formatting process to understand the
number and content of each Fact and Dimension table before it can accurately produce the

documentation FERC Staff is requesting. Therefore, although aggressive, it is feasible for the
NYISO to provide the data dictionary, ERDs and file transfer layout documentation 90 days

17 Order No. 760, P. 43 and FN 75.

18 Id.

19 As a result of the NYISO’s request for extension, FERC Staff requested that NYISO provide its data dictionary, entity relationship model, and file transfer record layout documentation more than 30 days prior to the first day of ongoing delivery, as required by paragraph 43 of the Order.

prior to the first day of the ongoing delivery of each dataset. Minor additional changes may be required up to 30 days prior to the first day of delivery to accommodate issues that are identified during the NYISO’s internal quality assurance and system testing. The NYISO cannot commit to a longer advance period, i.e., 120+ days, due to the amount of design work necessary on the software system that will collect and deliver the market data prior to compiling the data
dictionary, ERDs and file transfer layout documentation. Providing this documentation 90 days prior to commencement of ongoing data delivery will provide FERC Staff substantially more
time to utilize these documents than the 30 days that are required by the Order.20
VII. REQUEST FOR EXPEDITED ACTION

Finally, the NYISO requests expedited action on this Motion by August 6, 2012. The
compliance filing and ongoing data delivery obligations are due in less than one month, and the NYISO requests a determination at the earliest possible date so that it may have sufficient time to develop alternative plans should the Commission reject the NYISO’s Motion.
VIII. CONCLUSION

The NYISO respectfully requests, for the reasons set forth herein, that the Commission grant this Motion for Extension of Time to Comply on an expedited basis and accept the schedule for implementing Order No. 760 proposed in this Motion.

20 Order No. 760, P. 43.

Respectfully submitted,

NEW YORK INDEPENDENT SYSTEM OPERATOR, INC.

/s/ James H. Sweeney

Robert E. Fernandez, General Counsel James H. Sweeney, Attorney

New York Independent System Operator, Inc.

10 Krey Boulevard

Rensselaer, NY 12144
Tel: (518) 356-6000
Fax: (518) 356-4702

rfernandez@nyiso.com
jsweeney@nyiso.com

Dated: July 20, 2012

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 20th day of July, 2012.

By:/s/ John C. Cutting

John C. Cutting

Senior Regulatory Affairs Specialist

New York Independent System Operator, Inc.

10 Krey Blvd.

Rensselaer, NY 12144 (518) 356-7521