2012_08_20_NYISO_Dcmnt_Lss_Mtn_Intrvn_EL12_89_000[1].txt

Submission Description: (doc-less) Motion to Intervene of New York Independent System Operator, Inc. under EL12-89-000.

Submission Date:8/20/2012 11:04:56 AM

Filed Date:8/20/2012 11:04:56 AM

Dockets

-------

EL12-89-000Formal Complaint

Filing Party/Contacts:

Filing PartySigner (Representative)

Other Contact (Principal)

-----------------------------------

-------------------------

New York Independent System Operator, Inc. mlampi@nyiso.com rstalter@nyiso.com

New York Independent System Operator, Inc. jzimberlin@nyiso.com

New York Independent System Operator, Inc. jcutting@nyiso.com

New York Independent System Operator, Inc. makter@nyiso.com

Basis for Intervening:

The New York Independent System Operator, Inc. ("NYISO" or "ISO") is a

not-for-profit corporation responsible for providing open-access transmission

service and administering open and competitive wholesale markets.  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.  As
part of its operations, the NYISO maintains the OATT and Market Administration and
Control Area Services Tariff for the New York Control Area and manages the Market
Mitigation and Analysis Department which, among other duties, administers market
mitigation measures in accordance with the ISO's Tariffs, monitors daily the ISO's
markets to identify potential violations of the Market Mitigation Measures, works
collaboratively with other ISO departments to analyze market outcomes, and brings to
the Market Monitoring Unit's attention market-related concerns (including, but not
limited, to possible Market Violations) that it identified while carrying out its
responsibilities.

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.

Page 1