UNITED STATES OF AMERICA
BEFORE THE

FEDERAL ENERGY REGULATORY COMMISSION

Hudson Transmission Partners, LLC)

v.)Docket No. EL12-98-000

New York Independent System Operator, Inc.)

MOTION OF THE NEW YORK INDEPENDENT SYSTEM OPERATOR, INC.
FOR EXTENSION OF TIME, FOR SHORTENED RESPONSE PERIOD,

AND FOR EXPEDITED ACTION

Pursuant to Rules 212 and 2008 of the Commission’s Rules of Practice and Procedure,1 the New York Independent System Operator, Inc. (“NYISO”) respectfully requests that the
Commission grant a 15-day extension of time from the date for comments set by the
Commission’s August 3, 2012 Notice of Complaint, i.e., from August 23, 2012, until no later
than September 7, 2012, for the NYISO to Answer, and, as the Commission may deem
appropriate, for the submittal of interventions and other responses to, the August 3, 2012
Complaint of Hudson Transmission Partners, LLC (“Complaint”) in this proceeding.  The
NYISO also requests that the Commission shorten, or waive, the normal period for responding to this Motion to the maximum extent possible, so that the Commission may act expeditiously to issue an order granting the requested extension by August 20, 2012.

The NYISO is authorized to state that the complainant, Hudson Transmission Partners,
LLC (“HTP”) does not oppose granting the requested extension of time for the NYISO to submit
its Answer.

1 18 C.F.R. §§ 385.212 and 2008 (2011).

I.MOTION FOR EXTENSION OF TIME

Under Rule 2008 the Commission may extend the deadline for comments to the

Complaint “for good cause, upon a motion made before the expiration of the period prescribed or
previously extended.”  The NYISO submits that there is good cause to grant its requested
extension.

The Complaint concerns the determination that the NYISO provided to HTP pursuant to
the NYISO’s buyer-side market power mitigation tariff provisions (“BSM Rules”).  That
determination was made and provided to HTP prior to the Commission’s June 22, 2012 order
regarding the NYISO’s administration of the BSM Rules in Docket No. EL11-42-000.2  In
compliance with the June 22 Order, the NYISO will retest HTP and issue its determination.  The
NYISO intends to issue that determination no later than September 7, 2012.3
Granting the NYISO’s requested extension of time will simplify this proceeding by
allowing it to file its Answer promptly after its announcement of the determination pursuant to
the retest.   It would benefit the Commission, HTP, and any parties if the results of the retest
were available when the NYISO’s Answer is filed.  Granting the NYISO’s request for an
extension will not prejudice any party and the NYISO is authorized to state that HTP does not
oppose the request that the NYISO be provided with additional time to submit its Answer.

2 Astoria Generating Company, L.P., et al. v. New York Independent System Operator, Inc., 139 FERC ¶ 61,244 (2012) (“June 22 Order”).

3 Pursuant to the June 22 Order, the NYISO will issue its determination to HTP, and concurrently provide notice to stakeholders of the exempt or non-exempt determination for HTP, and the independent Market Monitoring Unit for the NYISO (“MMU”) will also concurrently publish its report.

2

II.MOTION FOR SHORTENED RESPONSE PERIOD AND FOR EXPEDITED

ACTION

To the extent necessary, the NYISO respectfully requests that the Commission shorten, or eliminate, the normal period for answering motions so that it may issue an order extending the answer deadline as expeditiously as possible (and no later than August 20, 2012).  Expedited action will give the NYISO, and other parties, certainty regarding the comments deadline and enable the NYISO to develop its Answer accordingly.

III.CONCLUSION

For the reasons set forth above, the New York Independent System Operator, Inc.
respectfully requests that the Commission: (i) grant an extension of time until no later than
September 7, 2012 for the NYISO to submit its Answer, and as the Commission may deem
appropriate, for interventions and other responses, to the Complaint; (ii) shorten, or waive, the
normal response period to the maximum extent practicable so that the Commission may
expeditiously issue an order granting the extension no later than August 20, 2012.
Respectfully submitted,

/s/ Vanessa A. Colón___________________

Vanessa A. Colón

Counsel for the

New York Independent System Operator, Inc.

August 15, 2012

cc:Michael A. Bardee

Gregory Berson
Connie Caldwell
Anna Cochrane
Jignasa Gadani
Lance Hinrichs
Jeffrey Honeycutt

Michael Mc Laughlin
Kathleen E. Nieman
Daniel Nowak

Rachael Spiker

3

CERTIFICATE OF SERVICE

I hereby certify that I have this day caused the foregoing document to be served 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 Commission Rules of Practice and Procedure, 18 C.F.R. § 385.2010 (2011).

Dated at Houston, T.X. this 15th day of August, 2012.

/s/  Vanessa A. Colón

Vanessa A. Colón

Hunton & Williams LLP
Bank of America Center
Suite 4200

700 Louisiana Street
Houston, TX 77002
Tel: (713) 229-5700