VIA ELECTRONIC TARIFF FILING

May 4, 2015

Ms. Kimberly D. Bose, Secretary

Federal Energy Regulatory Commission 888 First Street, NE

Washington, D.C. 20426

Re: New York Independent System Operator, Inc. et al., Compliance Filing
Docket No. ER15-572-000

Dear Ms. Bose:

In compliance with the Order on Transmission Formula Rate, Return on Equity, Cost
Allocation, and Transmission Incentives issued by the Federal Energy Regulatory Commission
(“Commission”) in the above-captioned proceeding on April 2, 2015,1 New York Transco, LLC
(“NY Transco”), Consolidated Edison Company of New York, Inc. (“Con Edison”), Orange &
Rockland Utilities, Inc. (“O&R”), Niagara Mohawk Power Corporation d/b/a National Grid
(“National Grid”), New York State Electric & Gas Corp. (“NYSEG”), Rochester Gas and
Electric Corp. (“RG&E”), and Central Hudson Gas & Electric Corp. (“Central Hudson”)2
respectfully submit this compliance filing. NY Transco and the NYTOs are referred to in this
filing as the “Filing Parties.”

I.COMMUNICATIONS

Communications and correspondence regarding this filing should be sent to the following

individuals:

Robert Caso

VP Budget, Finance, and Accounting, NY Transco

284 South Avenue

Poughkeepsie, NY 12601 Tel: (845) 486-5824

E-mail: rcaso@cenhud.com

Neil H. Butterklee

Assistant General Counsel

Consolidated Edison Company of New
York, Inc.

4 Irving Place, Room 1875-s New York, NY 10003

Tel: (212) 460-1089

Email: butterkleen@coned.com

David C. Lodemore

Niagara Mohawk Power Corporation
d/b/a/ National Grid

40 Sylvan Road

Waltham, MA 02451-1120 Tel: (781) 907-3704

E-mail:

david.lodemore@nationalgrid.com

Ray Kinney

Director - Transmission, Energy Services Electric Transmission Services

New York State Electric & Gas Corp. Rochester Gas and Electric Corp.

18 Link Drive - P.O. Box 5224 Binghamton, NY 13902-5224 Tel: (607) 762-4321

E-mail: RPKinney@nyseg.com

David Kimiecik

Vice President - Energy Services New York State Electric & Gas Corp. Rochester Gas and Electric Corp.

18 Link Drive

Binghamton, NY 13902-5224 Tel: (607) 762-8701

E-mail: DJKimiecik@nyseg.com

Richard W. Allen

VP Capital Investment, NY Transco Albany, NY 12204

Tel: (518) 433-5021

E-mail: Richard.Allen@nationalgrid.com

Marie Berninger
Project Manager

Consolidated Edison Company of New
York, Inc.

4 Irving Place - Room 2315-S New York, NY 10003

Tel: (212) 460-3194

E-mail: berningerm@coned.com

Bart Franey

Director, Regulations and Pricing
Niagara Mohawk Power Corporation

d/b/a National Grid 300 Erie Boulevard West Syracuse, NY 13202 Tel: (315) 428-5136

E-mail: bart.franey@nationalgrid.com

Paul A. Dumais

Director of Regulatory Iberdrola USA

89 East Avenue

Rochester, NY 14609 Tel: 585-794-9510

E-mail: Paul.dumais@iberdrolausa.com

Noelle Kinsch

Deputy General Counsel
Iberdrola USA Mgmt. Corp.

99 Washington Ave., Suite 2018 Albany, NY 12210

Tel: (518) 434-4977

E-mail: Noelle.Kinsch@Iberdrolausa.com

Paul E. Haering

Vice President of Engineering and
Operations Services

Central Hudson Gas & Electric Corporation

Elias G. Farrah

Raymond B. Wuslich Kimberly Ognisty Victoria L. Hsia

Winston & Strawn LLP 1700 K Street, NW

Washington, DC 20006-3817 Tel: (202) 282-5000

E-mail: efarrah@winston.com
rwuslich@winston.com

kognisty@winston.com vhsia@winston.com

284 South Avenue

Poughkeepsie, NY 12601 Tel: (845) 486-5351

E-mail: phaering@cenhud.com

Paul A. Colbert

Associate General Counsel - Regulatory
Affairs

Central Hudson Gas & Electric
Corporation

284 South Avenue

Poughkeepsie, NY 12601 Tel: (845) 486-5831

E-mail: pcolbert@cenhud.com

II.LIST OF DOCUMENTS SUBMITTED

The Filing Parties respectfully submit the following documents for filing:

1. A Transmittal letter;

2. A clean version of the New York Independent System Operator, Inc.
(“NYISO”) Open Access Transmission Tariff (“OATT”), Section 36,
Attachment DD - Rules to Allocate the Cost of NY Transco LLC
Transmission Facilities and Formula Rates, which reflects proposed
revisions in compliance with the April 2015 Order (Attachment A);
and

3. A redline and strikeout version of NYISO OATT, Section 36,

Attachment DD - Rules to Allocate the Cost of NY Transco LLC

Transmission Facilities and Formula Rates , which reflects the proposed
revisions in compliance with the April 2015 Order (Attachment B).

III.BACKGROUND

On December 4, 2014, NY Transco and the NYTOs submitted an application providing a
proposed transmission cost-of-service formula rate template and formula rate implementation
protocols for NY Transco to recover the costs associated with five transmission projects that NY
Transco will develop and own.3 The Filing Parties also requested several transmission rate
incentives.

3 New York Transco, LLC, et al., Application for Acceptance of Transmission Formula Rate and Approval of
Transmission Rate Incentives and Cost Allocation Method, Docket No. ER15-572-000 (filed Dec. 4, 2014).

May 4, 2015
Page 4

The April 2015 Order accepted in part, and rejected in part, the transmission rate

incentives requested by the Filing Parties.4 The April 2015 Order also accepted and suspended,
for a nominal period, the formula rate proposal, subject to refund, and established hearing and
settlement judge procedures for certain formula rate issues.5 The Commission directed the Filing
Parties to make a compliance filing within 30 days of the April 2015 Order: (1) revising the
formula rate protocols (“Protocols”) to add the New York Association of Public Power’s
(“NYAPP”) proposed Section 3(e)(ix) and to revise Section 4(b) regarding interested parties’
rights with respect to requests for information on intercompany allocations and listing project
specific data; and (2) removing from the proposed tariff the cost allocation for all five projects.6

IV. REVISIONS TO FORMULA RATE PROTOCOLS

The Protocols are located in Section 36.3.1.2 of Attachment DD of the NYISO OATT.

The April 2015 Order directed the Filing Parties to revise Section 3(e) of the Protocols to include NYAPP’s proposed language, which identifies the specific amounts included in the Annual
Update related to each transmission incentive project with a derivation value for each project.7 In addition, the Commission directed the Filing Parties to revise Section 4(b) of the Protocols to be consistent with the transparency requirements outlined in Midwest Independent Transmission Sys. Operator, Inc.8 Specifically, the Commission asked the Filing Parties to remove the
limitations on seeking information related to costs or allocations.9

In compliance with the April 2015 Order, the Filing Parties have added the following language proposed by NYAPP as new Section 3(e)(vi) of the Protocols:

Shall identify the specific amounts included in the Annual Update related to each
transmission incentive project, a citation to the proceeding in which FERC
granted the incentive, and provide a derivation of the value for each such project.

The Filing Parties also have revised Section 4(b) of the Protocols to remove the following

text:

Information requests shall not solicit information concerning costs or allocations where the costs or allocation methods have been determined to be appropriate by FERC in the context of prior NY Transco Annual Updates, except that such information requests shall be permitted if they (i) seek to determine if there has been a change in circumstances, (ii) are in connection with corrections pursuant to Section 6, or (iii) relate to costs or allocations that have not previously been challenged and adjudicated by FERC.

4 April 2015 Order at PP 75-100.

5 Id. at PP 140-148.

6 Id. at Ordering Paragraphs (E) and (F).

7 Id. at P 144.

8 Midwest Indep. Transmission Sys. Operator, Inc., 143 FERC ¶ 61,149 (2013), reh’g denied, 146 FERC ¶ 61,209
(2014).

9 April 2015 Order at P 146.

May 4, 2015
Page 5

V.COST ALLOCATION

The cost allocation tables for each project are located in Section 36.2 of Attachment DD of the NYISO OATT.10 In the April 2015 Order, the Commission noted that Power Supply Long Island and New York Power Authority have not agreed to pay the percentage of costs allocated to their transmission districts under the Filing Parties’ proposed cost allocation method for the TOTS and AC Projects.11 Thus, the Commission rejected the Filing Parties’ proposed cost
allocation and directed the Filing Parties to make a compliance filing removing the cost
allocation for all five projects from the proposed tariff.12

In compliance with the April 2015 Order, the Filing Parties have removed the percentage of costs attributable to each transmission district from the cost allocation tables in Section 36.2 of Attachment DD of the NYISO OATT.

The Filing Parties are submitting simultaneously herewith a request for rehearing of the April 2015 Order challenging, inter alia, the Commission’s rejection of their proposed cost
allocation. The ultimate resolution of the cost allocation issue by the Commission on rehearing, by a court on appeal, or otherwise may cause a later retroactive adjustment to the cost allocation submitted by the Filing Parties.13

VI.SERVICE

The Filing Parties will serve each person designated on the official service list compiled by the Secretary in this proceeding.

VII. TARIFF EFFECTIVE DATE

The Filing Parties request an effective date for the revised tariff section of April 3, 2015.

10 Section 36.2 of Attachment DD only includes tables allocating the costs of the three TOTS Projects. There are no cost allocation tables to remove with respect to the AC Projects.

11 Id. at P 185.

12 Id. at P 188, Ordering Paragraph (F).

13 See, e.g., Canadian Ass’n of Petroleum Producers v. FERC, 254 F.3d 289, 300 (D.C. Cir. 2001) (“The filed rate
doctrine simply does not extend to cases in which buyers are on adequate notice that resolution of some specific
issue may cause a later adjustment to the rate being collected at the time of service.”) (internal quotations omitted).

/s/ Neil H. Butterklee

Neil H. Butterklee

Assistant General Counsel

Consolidated Edison Company of New
York, Inc.

Orange and Rockland Utilities, Inc.

4 Irving Place, Room 1875-s New York, NY 10003

Tel: (212) 460-1089

Email: butterkleen@coned.com

Counsel for Consolidated Edison Company
of New York, Inc., Orange and Rockland

Utilities, Inc.

/s/ R. Scott Mahoney by EES

R. Scott Mahoney, Esq.
New York State Electric & Gas
Corp. Rochester Gas and Electric Corp. Iberdrola USA

18 Link Drive
P.O. Box 5224

Binghamton, NY 13902-5224

Email: scott.mahoney@iberdrolausa.com

Counsel for New York State Electric & Gas
Corp. and Rochester Gas and Electric
Corp.

/s/ Elias G. Farrah Elias G. Farrah

Raymond B. Wuslich Kimberly Ognisty Victoria L. Hsia

Winston & Strawn LLP 1700 K Street, N.W.

Washington, DC 20006-3817 (202) 282-5000

Email: efarrah@winston.com
rwuslich@winston.com

kognisty@winston.com vhsia@winston.com

Counsel for New York Transco, LLC

/s/ David C. Lodemore by EES

David C. Lodemore Senior Counsel

Niagara Mohawk Power Corporation d/b/a/ National Grid

40 Sylvan Road

Waltham, MA 02451-1120 (781) 907-3704

Email: david.lodemore@nationalgrid.com

Counsel for National Grid

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 Rule 2010 of the Commission’s Rules of Practice and Procedure, 18 C.F.R. § 385.2010.

Dated at Washington, D.C., this 4th day of May, 2015.

/s/ Carlos L. Sisco

Carlos L. Sisco

Winston & Strawn LLP
1700 K Street N.W.
Washington, D.C. 20006
(202) 282-5907