UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
)
New York Power Authority)Docket No. ER12-2317-000
)
MOTION TO INTERVENE AND COMMENTS OF
THE NEW YORK INDEPENDENT SYSTEM OPERATOR, INC.
In accordance with Rules 212, and 214 of the Commission’s Rules of Practice and
Procedure,1 the New York Independent System Operator, Inc. (“NYISO”) respectfully moves to intervene and comment in the above-captioned proceeding.2
I.BACKGROUND
On July 27, 2012, the New York Power Authority (“NYPA”) filed an Application, under
Section 205 of the Federal Power Act, to increase its annual revenue requirement used to develop
the charges for transmission services provided by NYPA under the NYISO’s Open Access
Transmission Tariff (“OATT”). Because the filing included revisions to the NYISO OATT, the
NYISO executed the filing of NYPA’s Application, under its FERC-assigned eTariff Company
ID, in accordance with the requirements of FERC’s eTariff guidelines. As NYPA and the
NYISO coordinated preparation of the filing, the NYISO advised NYPA to make several
ministerial subsection renumbering changes. These changes were not substantive but will
resolve potential confusion that could have been caused by leaving the subsection numbering
uncorrected.
1 18 C.F.R. §§ 385.212, and 385.214.
2 New York Power Authority, Docket No. ER12-2317-000 (July 27, 2012) (“NYPA Application”).
1
II.COMMUNICATIONS
Copies of correspondence concerning this filing should be served on:
Robert E. Fernandez, General Counsel
Raymond Stalter, Director of Regulatory Affairs
*Mollie Lampi, Assistant General Counsel
New York Independent System Operator, Inc.
10 Krey Boulevard
Rensselaer, NY 12144
Tel: (518) 356-7530
Fax: (518) 356-4702
rfernandez@nyiso.com
rstalter@nyiso.com
mlampi@nyiso.com
* Persons designated for service.
III.MOTION TO INTERVENE
The NYISO is a not-for-profit corporation responsible for providing open-access
transmission service, administering open and competitive wholesale markets, and bringing
together buyers and sellers of electricity, capacity, and ancillary services, in New York State. The NYISO is also responsible for the reliable operation of the bulk electricity grid, and both short-term and long-term planning for the bulk power system in New York State. The NYISO manages the flow of power over nearly 11,000 circuit-miles of transmission lines and centrally dispatches over 300 generating units.
As part of its operations, the NYISO maintains the OATT and Market Administration and Control Area Services Tariff for the New York Control Area. Accordingly, the NYISO has an interest in this proceeding. This interest cannot be adequately represented by any other party. The NYISO, therefore, should be permitted to intervene in this proceeding.
IV.COMMENTS
The NYISO takes no position on the merits of NYPA’s revenue requirement filing.
2
However, the NYISO appreciates NYPA’s inclusion in its filing of several ministerial
renumbering revisions to Attachment H, Section 14.2.2 of the NYISO OATT, which it made at
the NYISO’s request. These ministerial section numbering revisions correct inadvertent errors
introduced when the NYISO transitioned to the eTariff system. Revising these section numbers
does not change the substance of Section 14.2.2 but it eliminates confusion which could be
caused by erroneous numbering and aids in the understanding of the Section 14.2.2 provisions.
V.CONCLUSION
WHEREFORE, for the foregoing reasons, the NYISO respectfully requests that the Commission grant this Motion to Intervene and accept these Comments.
Respectfully submitted,
/s/ Mollie Lampi
Assistant General Counsel
New York Independent System Operator, Inc.
10 Krey Blvd.
Rensselaer, New York 12144 (518) 356 7530
mlampi@nyiso.com
August 17, 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
Rachel Spiker
3
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 17th day of August, 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
