UNITED STATES OF AMERICA
BEFORE THE

FEDERAL ENERGY REGULATORY COMMISSION

New York Independent System Operator, Inc. )Docket Nos. ER08-1281-005

ER08-1281-006

MOTION FOR MODIFICATION TO REPORTING OBLIGATION OF THE
NEW YORK INDEPENDENT SYSTEM OPERATOR, INC.

Pursuant to Rules 212 of the Commission’s Rules of Practice and Procedure,1 the New
York Independent System Operator, Inc. (the “NYISO”) respectfully submits this Motion for
Modification to Reporting Obligation (“Motion”) with the Federal Energy Regulatory
Commission’s (“FERC” or “Commission”).  This Motion requests that the current semiannual
informational filing obligation in this Docket be modified to an annual informational filing
obligation.

On December 30, 2010, the Commission issued an Order on Rehearing and Compliance in Docket No. ER08-1281 (“December 2010 Order”)2 requiring the NYISO to submit
semiannual informational reports, in collaboration with its neighboring ISOs and RTOs, NERC and other market participants, commencing one year after the implementation of interface
pricing reform and congestion management/market-to-market coordination.
The December 2010 Order required:

“[O]ne year after the implementation of interface pricing reform
and congestion management/market-to-market coordination, and

1 18 C.F.R. § 385.212 (2013).

2 New York Independent System Operator, Inc., 133 FERC ¶ 61,276 PP 33 and ordering paragraph “D” (2010).

every six months thereafter until the market initiatives are fully
implemented, we require the NYISO, in collaboration with its
neighboring RTO/ISOs, NERC and other market participants, to
submit a report, as an information filing, addressing: (i) the effects
of the reforms on reducing congestion that results from loop flows
and the costs associated with mitigating congestion; (ii) the effects
of the implementation of the enhanced interregional transaction
coordination initiative; and (iii) recommendations and analyses as
to whether the buy-through congestion proposal is required, and if
so, when it should be implemented.”3

The NYISO submitted the first Broader Regional Markets Informational Report in this Docket
on March 19, 2014 (“March Report”).  The March Report was jointly developed with PJM
Interconnection, L.L.C. (“PJM”), the Midcontinent Independent System Operator, Inc.
(“MISO”), and the Ontario Independent Electricity System Operator (“IESO”), (collectively, the
“ISOs and RTOs”).

The NYISO, with the support of the ISOs and RTOs, respectfully requests that the

Commission amend the informational filing obligation to require annual reports to the

Commission.  Postponing the next informational filing until March 20, 2015 will provide

necessary time for the ISOs and RTOs to develop a more substantive update for the Commission than the ISOs and RTOs will be able to provide in September 2014.  Several initiatives described in the March Report (PJM/NYISO Coordinated Transaction Scheduling, for example) will
require the majority of 2014 to complete.  Therefore, the status will not change significantly
from the March Report to a September 2014 reporting date.  Also, gaining additional operating experience with the features that entered service in 2012-2013, and the features being
implemented in 2014, will allow the ISOs and RTOs to better understand their impact before
providing another update to the Commission.

3 New York Independent System Operator, Inc., 133 FERC ¶ 61,276 at P 33 (2010) (original footnotes omitted).

2

The NYISO will send an electronic link to this filing to the official representative of each
party to this proceeding, 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.

The NYISO respectfully requests that the Commission change the semiannual reporting requirement imposed in the December 2010 Order to an annual reporting requirement.
Respectfully submitted,

/s/ James H. Sweeney

James H. Sweeney, Attorney

New York Independent System Operator, Inc.

10 Krey Boulevard

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

jsweeney@nyiso.com

Dated:     April 25, 2014

cc:Michael Bardee

Gregory Berson

Anna Cochrane

Jignasa Gadani

Morris Margolis

Michael McLaughlin
David Morenoff
Daniel Nowak

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 25th day of April, 2014.

By:/s/ John C. Cutting

John C. Cutting

New York Independent System Operator, Inc.

10 Krey Blvd.

Rensselaer, NY 12144 (518) 356-7521