10 Krey Boulevard Rensselaer, NY 12144
December 16, 2013
By Electronic Delivery
Honorable Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE
Washington, DC 20426
Re: New York Independent System Operator, Inc., Proposed Tariff Revisions
Regarding Interconnection Process Improvements, Docket No. ER14-____
Dear Secretary Bose:
In accordance with Section 205 of the Federal Power Act1 and Part 35 of the Federal
Energy Regulatory Commission’s (“Commission”) regulations,2 the New York Independent
System Operator, Inc. (“NYISO”) respectfully submits proposed revisions to the interconnection procedures set forth in Attachment X to the NYISO Open Access Transmission Tariff (“OATT”) (Standard Large Facility Interconnection Procedures), and Attachment Z to the NYISO OATT (Small Generator Interconnection Procedures).3
The NYISO is proposing changes to Attachments X and Z as part of an ongoing effort to
improve upon its interconnection study process. These proposed changes to NYISO’s
interconnection procedures relate to the evaluation of increases in the energy capability of
existing facilities. Currently such increases trigger the requirement that a developer submit a
new Interconnection Request, regardless of how minimal the increase might be. By revising the
tariff to permit limited increases in energy capability of existing facilities without requiring a
new Interconnection Request, this proposal eliminates unnecessary interconnection studies. It
thereby adds efficiencies to the NYISO’s interconnection process and provides added flexibility
to existing facilities interconnected to the New York State Transmission System. The NYISO’s
proposed revisions to Attachments X and Z also include a number of ministerial revisions. All
of the proposed revisions are further described below in Section IV of this letter.
1 See 16 U.S.C. § 824d (2000).
2 18 C.F.R § 35 et seq. (2009).
3 Capitalized terms not otherwise defined in this letter have the meaning set forth in Attachments X and Z of the NYISO’s Open Access Transmission Tariff (“OATT”), as amended by the enclosed proposed revisions to
Attachments X and Z of the OATT.
Honorable Kimberly D. Bose, Secretary December 16, 2013
Page 2
I.Documents Submitted
1.This filing letter;
2.A clean version of the proposed revisions the NYISO’s OATT (“Attachment I”);
and
3.A blacklined version of the proposed revisions to the NYISO’s OATT
(“Attachment II”).
II.Background
The rights and obligations of all Large Facility project Developers and Small Generating
Facility Interconnection Customers (collectively, “Developers”),4 Transmission Owners, and the
NYISO with respect to interconnecting new generation and merchant transmission projects are
set forth in Attachments S, X, and Z to the NYISO’s OATT. Attachment X to the OATT
contains the procedures for processing FERC-jurisdictional interconnections of Large Generating
Facilities and Merchant Transmission Facilities. Attachment Z to the OATT contains the
procedures for processing FERC-jurisdictional interconnections of Small Generating Facilities.
Attachments X and Z set forth the detailed procedures for the identification and cost
allocation of System Upgrade Facilities required for a project to reliably interconnect to the
system and thereby provide Energy Resource Interconnection Service (“ERIS”). ERIS is basic
interconnection service that allows a Developer to interconnect its facility to the New York State
Transmission System or Distribution System in accordance with the NYISO Minimum
Interconnection Standard to enable the New York State Transmission System or Distribution
System to receive electric energy from the facility. In addition to ERIS, Developers may also
elect Capacity Resource Interconnection Service (“CRIS”). Unlike ERIS, CRIS is the
interconnection service that allows a Developer to interconnect its facility to the New York State
Transmission System or Distribution System in accordance with the NYISO Deliverability
Interconnection Standard, which allows participation in the NYISO’s Installed Capacity market
to the extent of the facility’s deliverable capacity. The NYISO’s proposed tariff revisions that
are the subject of this filing relate only to ERIS, not CRIS.5 Specifically, the tariff revisions -
explained in detail in Section IV, below - relate to an existing facility’s ability to increase its
existing ERIS.
Attachments X and Z of the OATT currently require a Developer to submit an
Interconnection Request not only to interconnect new Large Facilities and Small Generating
4 While “Developer” is a tariff-defined term referring to a project developer for a Large Facility (versus a Small
Generating Facility), for ease of reference, this filing letter uses the term “Developers” to refer to both Large Facility project developers and Small Generating Facility project developers.
5 Requests to increase CRIS are already explicitly addressed in Attachments S, X and Z of the NYISO’s OATT.
Honorable Kimberly D. Bose, Secretary December 16, 2013
Page 3
Facilities (collectively “facilities”), but also “to increase the capacity of, or make a material
modification to the operating characteristics of, an existing [facility] that is interconnected with
the New York State Transmission System or with the Distribution System.”6 The current tariff
language does not provide for any flexibility with respect to the requirement that a Developer
submit a new Interconnection Request for an increase in the capability to an existing facility.
For example, a facility that is evaluated in the NYISO interconnection process as a 100 megawatt
(“MW”) project, and subsequently executes an Interconnection Agreement for such facility, but
that as-built, is capable of 101 MW, triggers the requirement that it submit a new Interconnection
Request and be studied under Attachment X for the additional 1 MW that it is capable of
generating. This requires three consecutive interconnection studies under Attachment X for the
incremental 1 MW, only one of which - the Interconnection Feasibility Study - may be waived
upon consent of the parties.7
Experience has revealed that it is not uncommon for facilities’ as-built capability to
exceed the estimated capability of yet-to-be-constructed facilities. As a result, as-built capability
can slightly exceed the MW level that was evaluated in the NYISO’s interconnection study
process. This is particularly true for facilities that propose to incorporate new technologies.
Experience also has shown that existing generators, even long existing generators, on occasion
are able (in periodic required field tests) to demonstrate a level of capability that is slightly
higher than previously demonstrated in recent history without having made any material
modifications to equipment. Although infrequent, such increases in capability may occur for
various reasons such as after completion of a maintenance cycle, or the replacement of like-in-
kind equipment. Upon notification that a facility seeks to increase its existing ERIS capability,
the NYISO requires the Developer to submit a new Interconnection Request for the incremental
output, even when the increase in existing ERIS has negligible or no impact on system reliability
under the Minimum Interconnection Standard.
This is only a requirement for existing facilities and, consistent with Commission
guidance, is not applied to facilities in the interconnection queue that have not yet crossed the
“existing facility” threshold. 8 Facilities that have not reached that “existing facility” stage may
request an increase in ERIS capability and, if determined non-material under Section 30.4.4.3 of
Attachment X, such increase is permitted.9 The difference in treatment for the two types of
6 See Attachment X, Sections 30.1 and 30.14; see also, Attachment Z, Section 32.5.
7 See Attachment X, Section 30.6.
8 Based on Commission guidance, the NYISO has deemed a facility an “existing facility” if it either (1) has
completed all required NYISO interconnection studies and has an effective Interconnection Agreement; or (2) is
fully constructed, synchronized to the grid; and has an executed Interconnection Agreement. See, e.g., 330 Fund I, L.P. v. New York Independent System Operator, Inc., 121 F.E.R.C. P61,001, Order Denying Complaint at P 32 (2007) ; Midwest Independent Transmission System Operator, Inc., 125 F.E.R.C. P61,210, Order Granting
Rehearing, In Part at P 15 (2008).
9 See Attachment X, Section 30.4.4.3.
Honorable Kimberly D. Bose, Secretary December 16, 2013
Page 4
facilities stems from the language in the pro forma definition of Interconnection Request, which only speaks to increases in the capacity of existing Facilities.
The existing requirement that any increase in an existing facility’s ERIS capability
triggers the requirement that the facility submit a new Interconnection Request has proven to be
difficult to manage in the NYISO interconnection process and has added procedural
requirements to existing facilities, with associated added cost and burden, that both the NYISO
and its stakeholders seek to lessen. The NYISO is cognizant of the urging of former
Commissioner Kelly, in her concurring opinion in an order accepting an Interconnection
Agreement, encouraging an examination of the need for a de minimis exception related to
increases in generation capacity.10 The NYISO and its stakeholders have conducted a thorough
evaluation of this need and, while desiring to retain the ability to evaluate the materiality of
changes in existing facilities, have worked collaboratively to develop such an exception, subject
to certain very specific, well-delineated limitations, described in detail in Section IV, below.11
III. The Independent Entity Variation Standard
The NYISO’s proposed revisions to Attachments X and Z would modify tariff language
that the Commission adopted in Order Nos. 2003 and 2006, or their successors as part of the pro
forma interconnection procedures.12 The Commission has accepted other modifications and
improvements to the NYISO interconnection procedures,13 recognizing that where changes to
pro forma interconnection procedures “are clarifying and/or ministerial in nature and/or NYISO
has supplied sufficient justification,” such modifications are acceptable under the “independent
entity variation” standard.14 The Commission has explained that under this standard, “the
Commission will review the proposed variations to ensure they do not provide an unwarranted
10 See Midwest Indep. Transmission Sys. Operator, Inc., 124 FERC P61,277 at P62, Order Accepting Agreements
(2008).
11 In developing these tariff revisions, the NYISO and its stakeholders also viewed this as an opportunity to propose
certain limited ministerial revisions - primarily formatting - to language in Attachments X and Z. All of the
proposed revisions were approved by the NYISO’s stakeholders, without opposition, and are described in Section
IV, below.
12 Standardization o/Generator Interconnection Agreements and Procedures, Order No. 2003, FERC Stats. & Regs.
31,146 (2003), order on re’g, Order No. 2003-A, FERC Stats. & Regs. 31,160 (2004), order on reh’g, Order No.
2003-B, FERC Stats.& Regs. 31,171 (2004), order on reh’g, Order No. 2003-C, FERC Stats. & Regs. 131,190
(2005), affirmed sub nom. Nat’I Ass’n of Regulatory Util. Com’rs v. FERC, 475 F.3d 1277 (D.C. Cir. 2007);
Standardization of Small Generator Interconnection Agreements and Procedures, Order No. 2006, 70 Fed. Reg.
34190 (June 13, 2005), 111 FERC ¶ 161,220 (2005), order on reh'g, Order No. 2006-A, 113 FERC ¶ 61,195, 70
Fed. Reg. 71760 (Nov. 30, 2005).
13 See, e.g., New York Independent System Operator, Inc., 135 FERC ¶ 51,014 (2011); New York Independent System Operator, Inc., 124 FERC ¶ 61,238 (2008).
14 New York Independent System Operator, Inc., 124 FERC ¶ 61,238 at PP 17-18.
Honorable Kimberly D. Bose, Secretary December 16, 2013
Page 5
opportunity for undue discrimination or produce an interconnection process that is unjust and unreasonable.”15
The revisions to Attachment X and Z that are proposed herein are fully justified under the
Commission’s “independent entity variation” standard because they have been approved by the
NYISO's stakeholders after an extensive and open process, have been endorsed by the NYISO’s
independent Board of Directors, and, as discussed herein, revise tariff provisions that have
proven unnecessarily prescriptive. Meetings held over the course of four (4) months resulted in a
consensus among stakeholders on the amendments proposed in this filing. These tariff revisions
are intended to improve upon the NYISO’s current interconnection process. The NYISO and its
stakeholders believe that the proposed tariff modifications can provide considerable
improvement to the existing process by eliminating studies that are not needed. The NYISO
therefore respectfully request that the Commission approve these tariff revisions under the
“independent entity variation” standard.
IV.Description of the Proposed Tariff Modifications
A.Overview
As described in more detail in the following sections, NYISO is proposing tariff changes
to implement de minimus criteria for determining when increases in the capability of existing
generating facilities are required to undergo the NYISO interconnection study procedures.
The NYISO respectfully submits that the Commission’s rationale supporting the current
pro forma requirement - the requirement that any increase in existing capability triggers a new
Interconnection Request - does not apply in the NYISO’s interconnection process due to unique
regional variations in the NYISO’s markets. In its post-Order 2003 and post-Order 2006
decisions reinforcing the requirement that any increase whatsoever in a unit’s capability requires
a new Interconnection Request, the Commission has emphasized two factors. First, the
Commission has opined that “[i]nsisting that parties file new pro forma LGIAs when electing to
increase generation capacity, as already required, provides consistency and eliminates
confusion.”16 Second, the Commission has emphasized its concern that “an increase in the
amount of power the Generating Facility will produce should be treated as significant because it
is an important change in one of the most fundamental characteristics of a Generating Facility.”17
With respect to the first concern regarding the need to provide consistency and eliminate
confusion, the NYISO’s proposed tariff revisions were designed to address these very concerns.
By revising its interconnection procedures to allow for a de minimis increase to be permitted in
15 See Id. at P18.
16 See Id. at P11.
17 Midwest Independent Transmission System Operator, Inc., 125 F.E.R.C. P61,210, Order Granting Rehearing, In Part at P16 (2008).
Honorable Kimberly D. Bose, Secretary December 16, 2013
Page 6
certain limited circumstances, and apprising stakeholders of such tariff revisions, the NYISO
does not anticipate creating any confusion; to the contrary, the NYISO believes this will
eliminate confusion and improve consistency. Currently, increases are permitted prior to the
facility being deemed an “existing facility.” Yet once the facility becomes an “existing facility,” an increase in unit output is not permitted. A facility must submit an Interconnection Request for any increase. This “zero tolerance” is inconsistent with the tolerance for increases that are
requested prior to a facility crossing the “existing facility” threshold.
With respect to the second concern, the Commission has noted that, “[a]n increase in
generating capacity is generally a significant change (material modification) to an
interconnection request that requires new studies and a new interconnection request.”18 The
Commission has further expressed its concern that, “[h]ow much power a Generating Facility
will produce is critical to the very nature of the Generating Facility, and it is reasonable to treat a
change to that characteristic as a new Interconnection Request.”19 Balancing the Commission’s
concern regarding the critical nature of an increase in output is the fact that NYISO’s proposal
only allows limited increases within a specified de minimis threshold, thereby addressing any
reliability concerns. Moreover, due to unique variations in the NYISO, increases in capability do
not pose the reliability risk that they might in other regions. This is true for two reasons: (1) the
NYISO does not have a firm reservation system for access to the New York State Transmission
System; and (2) in operating its Energy markets, NYISO commits and dispatches generation in a
manner that maintains reliability, including reducing a unit’s output level, or even de-committing
the unit if necessary to maintain the reliability of the transmission system (i.e., if the dispatch of
an existing facility at a MW level higher than its existing level would create reliability issues, the
NYISO’s scheduling and dispatch software would not dispatch the unit at increased output.)20
The standard for evaluating a unit electing ERIS under the NYISO’s interconnection
process is the Minimum Interconnection Standard, which does not analyze whether the facility will have deliverability across the New York State Transmission System (commonly referred to as “energy deliverability issues”) or whether/how it will be dispatched. Those are all issues that will be solved through the NYISO’s commitment and dispatch software. Rather, the Minimum Interconnection Standard, defined below, focuses on the reliability of the physical
interconnection of the facility to the transmission system.
Minimum Interconnection Standard shall mean the reliability
standard that must be met by any Large Generating Facility, or a
18 See Midwest Independent Transmission System Operator, Inc., 122 FERC P61,019, Order Accepting Revised Interconnection Agreement at P16 (2008).
19 See Midwest Independent Transmission System Operator, Inc., 125 F.E.R.C. P61,210 at P16.
20 The NYISO’s Security Constrained Unit Commitment (“SCUC”) is the process through which the NYISO
prepares a generation schedule for the following day through the operation of a computer algorithm that minimizes
the total bid production cost of energy while observing various operational parameters. Among such operational
parameters are local and bulk system reliability. The NYISO uses a similar process for the Real-Time Market.
Honorable Kimberly D. Bose, Secretary December 16, 2013
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Merchant Transmission Facility, proposing to connect to the New
York State Transmission System or to the Distribution System.
The Standard is designed to ensure reliable access by the proposed
project to the New York State Transmission System or to the
Distribution System, as applicable. The Standard does not impose
any deliverability test or deliverability requirement on the
proposed interconnection.21
Because of the narrow scope of the Minimum Interconnection Standard, together with the fact that the NYISO’s commitment and dispatch software dispatches generation in a manner that maintains reliability, the Commission’s concerns regarding the potential impact of unevaluated increases in generator output are not as applicable in the NYISO as they might be in other
regions. For the above reasons, the proposed modifications to the pro forma described in
Sections IV.B. and IV.C., below are justified in the NYISO’s OATT.
B.Revisions to the Definition of Interconnection Request
The NYISO’s proposal to address this issue begins with the definition of Interconnection
Request. The proposed tariff revisions add the qualifying term, “materially” in the definition of
Interconnection Request. With this change, the only increases in capacity that would trigger a
new Interconnection Request would be those that “materially increase the capacity of …an
existing [facility].” (emphasis added). This revision is reflected in Sections 30.1, 30.14, and
32.5 - all of the sections of the NYISO OATT in which the definition of Interconnection Request
appears.
C.Clear Delineation of Permissible Increases and Associated
Modifications to Establish Existing ERIS Levels
The above-described revision to the pro forma definition of Interconnection Request
would permit increases in output without triggering a new Interconnection Request as long as
such increases are not “material.” To clarify what is meant by a “material increase” that would
trigger a new Interconnection Request, the NYISO proposes revisions to Sections 30.3 and 32.1.
The proposed language added to these sections details the limited circumstances under which an
increase in energy output would be permitted, and thereby ensures that material modifications to
existing facilities are still subject to thorough evaluation in the interconnection study process.
The proposed language in Sections 30.3 and 32.1 would provide that an increase in an
existing facility’s capability is not a “material increase” as long as it is associated with non-
material equipment changes (or no equipment change) and the increase is within the following
thresholds:
21 See Attachment X, Sections 30.1 and 30.14; see also, Attachment Z, Section 32.5.
Honorable Kimberly D. Bose, Secretary December 16, 2013
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• for Large Facilities, no more than 10 MW or 5% of the existing ERIS level, whichever is
greater; or
• for Small Generating Facilities, no more than 2 MW of the existing ERIS level up to a
new total at or below 20 MW.
The proposed language added to these sections then proceeds to explain what it meant by
term “existing ERIS,” which is the baseline from which any increase, now or in the future is
measured.22 The proposed language provides that an existing facility’s existing ERIS level is
the greater of:
(i) the existing Large Facility’s CRIS level determined as a facility pre-dating Class
Year 2007 pursuant to Section 25.9.3.1 of Attachment S of the OATT, if applicable (“grandfathered CRIS”); or
(ii) the final maximum summer megawatt electrical output studied for ERIS in the
NYISO’s interconnection process for the existing Large Facility;
If neither of the above is applicable, the NYISO proposes that the existing ERIS be the value
reflected in the facility’s interconnection agreement or other applicable documentation governing the facility’s interconnection.
The justification for the above criteria is as follows:
For existing facilities that had received grandfathered CRIS pursuant to Section 25.9.3.1
- by far the overwhelming majority of the New York fleet of generators - their CRIS level was
set, pursuant to Section 25.9.3.1 of Attachment S, at the highest Dependable Maximum Net
Capability (“DMNC”)23 achieved by the facility during a five year period. The NYISO
concluded that the highest DMNC achieved by this universe of existing facilities made the most
sense to rely on as the “high water mark” for the facilities’ maximum energy output, and
therefore the baseline that is referred to in this proposal as “existing ERIS.” For the subset of
existing facilities with grandfathered CRIS that were going through the NYISO’s interconnection
process at the time the “grandfathering” provisions in Section 25.9.3.1 went into effect, the
NYISO proposes that their existing ERIS be the higher of their grandfathered CRIS or the final
maximum summer MW level at which they were evaluated in the NYISO’s interconnection
studies.
22 For example, an existing facility’s that has an “existing ERIS” of 100 MW, but as-built, is capable of 110 MWs, could request an increase in 10 MW over its existing ERIS. If, two year later, that facility does routine maintenance, and, as a result, is capable of 112 MW, the NYISO would evaluate the additional 2 MW as part of a twelve MW increase above the existing ERIS of 100 MW.
23 DMNC is defined as “The sustained maximum net output of a Generator, as demonstrated by the performance of a test or through actual operation, averaged over a continuous time period as defined in the ISO Procedures.” See Section 1 of the NYISO OATT.
Honorable Kimberly D. Bose, Secretary December 16, 2013
Page 9
For newer facilities that were not eligible for grandfathered CRIS under Section 25.9.3.1,
the most appropriate measure of existing ERIS is the final maximum summer MW level at which
they were evaluated in the NYISO’s interconnection studies. If the existing facility is a
temperature sensitive unit, the maximum capacity of which varies based on ambient temperature,
the NYISO’s proposal provides that the increase in existing capacity will be measured based on
the largest increase from the existing capacity to the proposed capacity at the same temperature,
i.e., at the same temperature along the maximum megawatt electrical output versus temperature
curves.
For facilities that do not have a grandfathered CRIS level but that were not subject to the NYISO’s interconnection study requirements,24 the NYISO proposes a third criteria: that the existing ERIS be the value reflected in the facility’s interconnection agreement or other
applicable documentation governing the facility’s interconnection.
Below is a detailed description of the specific tariff amendments necessary to implement this proposal.
1. Language the NYISO Proposes to Add to Section 30.3
The NYISO proposes to add the following language to Section 30.3 to clarify how the proposal would apply to Large Facilities:
An increase in the capacity of an existing Large Facility is a material increase for
purposes of this Section 30.3.1 unless the increase (a) is not associated with any
equipment changes or is associated with equipment changes determined by the
NYISO to be non-material; and (b) is an increase in the Large Facility’s existing
ERIS level that is equal to or less than ten (10) megawatts or five (5) percent,
whichever is greater. For purposes of this Section 30.3.1, the existing ERIS level
of an existing Large Facility is (a) the greater of (i) the existing Large Facility’s
CRIS level determined as a facility pre-dating Class Year 2007 pursuant to
Section 25.9.3.1 of Attachment S of the OATT, if applicable; or (ii) the final
maximum summer megawatt electrical output studied for ERIS in the NYISO’s
interconnection process for the existing Large Facility; or (b) if neither (a)(i) nor
(a)(ii) are applicable, the existing ERIS level is the value reflected in the Large
Facility’s interconnection agreement or other applicable documentation governing
the Large Facility’s interconnection. If the existing Large Facility is a
temperature sensitive unit, the maximum capacity of which varies based on
24 An example of this very limited universe of facilities might be a load modifier that did not participate in the
capacity market until recently. Such units may not have had DMNC tests during the five-year DMNC window
under Section 25.9.3.1 and therefore have zero CRIS. If they were pre-existing at the time the pro forma
interconnection procedures went into effect and were not subject to the NYISO’s interconnection study requirements under the applicable transition mechanisms, they also would not have a summer MW level at which they were
studied in the NYISO interconnection process.
Honorable Kimberly D. Bose, Secretary December 16, 2013
Page 10
ambient temperature, the increase in existing capacity will be measured based on the largest increase from the existing capacity to the proposed capacity at the same temperature, i.e., at the same temperature along the maximum megawatt electrical output versus temperature curves.
2. Language the NYISO Proposes to Add to Section 32.1
The NYISO proposes to add the following language to Section 32.1 to clarify how the proposal would apply to Small Generating Facilities:
An increase in the capacity of an existing Small Generating Facility is a material
increase for purposes of this Section 32.1.3 unless the increase (a) is not
associated with any equipment changes or is associated with equipment changes
determined by the NYISO to be non-material; and (b) is an increase in the Small
Generating Facility’s existing ERIS level that is equal to or less than two (2)
megawatts and which provides for a total output of the Small Generating Facility
of no more than twenty (20) megawatts. For purposes of this Section 32.1.3, the
existing ERIS level of an existing Small Generating Facility is (a) the greater of
(i) the existing Small Generating Facility’s CRIS level determined as a facility
pre-dating Class Year 2007 pursuant to Section 25.9.3.1 of Attachment S of the
OATT, if applicable; or (ii) the final maximum summer megawatt electrical
output studied for ERIS in the NYISO’s interconnection process for the existing
Small Generating Facility; or (b) if neither (a)(i) nor (a)(ii) are applicable, the
existing ERIS level is the value reflected in the Small Generating Facility’s
interconnection agreement or other applicable documentation governing the Small
Generating Facility’s interconnection. If the existing Small Generating Facility is
a temperature sensitive unit, the maximum capacity of which varies based on
ambient temperature, the increase in existing capacity will be measured based on
the largest increase from the existing capacity to the proposed capacity at the
same temperature, i.e., at the same temperature along the maximum megawatt
electrical output versus temperature curves.
D. Additional Ministerial Revisions and Tariff Clean Up
The NYISO’s proposed revisions to Attachments X and Z involve modifications to
several sections of the NYISO tariff, including the lengthy appendices included in Attachments
X and Z of the OATT. In order to ensure consistency throughout these sections of the OATT,
and to streamline formatting of pro forma agreements contained in the appendices to Attachment
X and Z - Sections 30.14 and 32.5 - a number of minor and ministerial changes are required.
Also, upon review of these sections of the OATT, a few typographical errors and other minor
error were discovered that require modification for accuracy and internal consistency. These
minor, clarifying, and ministerial corrections - specified in the chart below - are necessary to
clarify, and ensure the internal consistency and accuracy of the proposed tariff modifications.
Honorable Kimberly D. Bose, Secretary December 16, 2013
Page 11
Tariff SectionModification
ATTACHMENT X
Attachment XReplaced “Large Generating Facility or Merchant Transmission Facility” with
§ 30.3“Large Facility,” which is a defined term in Section 30.1 defined as, “either a
Large Generating Facility or a Merchant Transmission Facility.”25
Attachment XCorrected section references in articles 7.4 and 7.5 of the pro forma
§ 30.14, Appx. 2,Interconnection Feasibility Study Agreement in Appendix 2, the pro forma
Appx. 3 and Appx. 5Interconnection System Reliability Impact Study Agreement in Appendix 3, and
the pro forma Optional Interconnection Study Agreement in Appendix 5.
Articles 7.4 and 7.5 of these pro forma agreements refer to sections of the study
agreements, not sections of Attachment X; therefore the references should not be
preceded by the number “30” (Attachment X is Section “30” of the NYISO
OATT).
Attachment XAdded additional spaces for text on the data form to be provided with the pro
§ 30.14, Appx. 4forma Interconnection Facilities Study Agreement
Attachment XCorrected a grammatical error by adding the word “in” to the definition of
§ 30.14, Appx. 6Byway in the Standard Large Generator Interconnection Agreement in Appendix
6
ATTACHMENT Z
Attachment ZChanged the brackets that appear in the definitions of “Class Year” and “Class
§ 32.5Year Project” to parentheticals
Appx. 1
Attachment ZRemoved unnecessary brackets from language in the “whereas” clauses in the
§ 32.5pro forma Feasibility Study Agreement in Appendix 6, the pro forma System
Appx. 6, Appx. 7 andImpact Study Agreement in Appendix 7, and the pro forma Facilities Study
Appx. 8Agreement in Appendix 8
Removed a stray bracket from Article 6.0 of the pro forma Facilities Study Agreement in Appendix 8
Added additional spaces for text on the data form to be provided with the pro forma Facilities Study Agreement in Appendix 8
25 See Attachment X, Section 30.1.
Honorable Kimberly D. Bose, Secretary December 16, 2013
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Tariff SectionModification
ATTACHMENT Z (continued)
Attachment ZDeleted the entry for a subheading in the table of contents for the Standard Small
§ 32.5Generator Interconnection Agreement in Appx. 9
Appx. 9
Replaced a semicolon with a colon in Article 1.6
Corrected the section reference in Article 1.9
Capitalized “operator” in the defined term “Affected System Operator” used in Article 5.3
Corrected the parenthetical numbers used to distinguish three clauses in Article
6.2
GLOBAL
GlobalVarious spacing and formatting edits (e.g., making indents in pro forma
agreements consistent; removing stray bold and underline formatting; deleting extra spaces and extra lines between text)
Replaced “NYISO” with “New York Independent System Operator, Inc.” in the signature blocks in the pro forma agreements
V.Requested Effective Date
The NYISO requests that the Tariff revisions proposed herein become effective on February 14, 2014, which is sixty days from the date of this filing.
VI.Requisite Stakeholder Approval
The tariff revisions proposed in this filing were the product of discussions with
stakeholders in the NYISO’s Transmission Planning Advisory Subcommittee beginning in July,
2013. These proposed changes to the OATT were approved unanimously by the Operating
Committee on October 17, 2013 and by the Management Committee (with one abstention) on
October 30, 2013. The NYISO Board of Directors also approved the filing of these proposed.
Honorable Kimberly D. Bose, Secretary December 16, 2013
Page 13
VII. Communications and Correspondence
All communications and services in this proceeding should be directed to:
Robert E. Fernandez, General Counsel
Raymond Stalter, Director of Regulatory Affairs
Karen Georgenson Gach, Deputy General Counsel
*Sara Branch Keegan, Senior Attorney
New York Independent System Operator, Inc.
10 Krey Boulevard
Rensselaer, NY 12144
Tel: (518) 356-8554
Fax: (518) 356-7678
skeegan@nyiso.com
* Persons designated for receipt of service.
VIII. Service
The NYISO will send an electronic link to this filing to the official representative of each
of its customers, to each participant on its stakeholder committees, to the New York Public
Service Commission, and to the New Jersey Board of Public Utilities. In addition, the complete
filing will be posted on the NYISO’s website at www.nyiso.com.
Respectfully submitted,
/s/ Sara B. Keegan
Sara Branch Keegan
Counsel for the
New York Independent System Operator, Inc.
cc:Michael A. Bardee
Gregory Berson
Anna Cochrane
Jignasa Gadani
Morris Margolis
Michael McLaughlin
David Morenoff
Daniel Nowak
