10 Krey Boulevard  Rensselaer, NY 12144

July 13, 2015

By Electronic Delivery

Ms. Kimberly D. Bose Secretary

Federal Energy Regulatory Commission 888 First St, NE

Washington, DC 20426

Re: New York Independent System Operator, Inc. and New York Transmission Owners,
Interregional Compliance Filing, Docket Nos. ER13-1942-___, ER13-1946-___,
ER13-1957-___

Dear Ms. Bose:

The New York Independent System Operator, Inc. (“NYISO”) and the New York

Transmission Owners (“NYTOs”)1 hereby jointly submit this compliance filing to fulfill the

directives of the Commission2 in its May 14, 2015, Order on Compliance Filings in the abovecaptioned proceedings3 concerning their compliance with the Order No. 1000 interregional transmission coordination and cost allocation requirements (“May 2015 Order”).4 The NYISO and NYTOs are referred to jointly in this filing as the “Filing Parties.”

1 The NYTOs are: Central Hudson Gas & Electric Corporation, Consolidated Edison Company of
New York, Inc., Long Island Lighting Company d/b/a LIPA, New York Power Authority, New York
State Electric & Gas Corp., Niagara Mohawk Power Corp. d/b/a National Grid, Rochester Gas & Electric
Corp., and Orange & Rockland Utilities, Inc. LIPA and NYPA as transmission owners not subject to the
FERC’s rate jurisdiction under Section 205 of the Federal Power Act have voluntarily participated in the
development of this comprehensive filing and thereby join the other NYTOs in this pleading.

2 Capitalized terms that are not otherwise defined in this filing letter shall have the meaning

specified in Attachment Y of the NYISO OATT, and if not defined therein, in the NYISO OATT and the NYISO Market Administration and Control Area Services Tariff.

3 ISO New England Inc., et al., Order on Compliance Filings, 151 FERC ¶ 61,133 (2015) (“May 2015 Order”).

4 Transmission Planning and Cost Allocation by Transmission Owning and Operating Public Utilities, Order No. 1000, 136 FERC ¶ 61,051 (2011) (“Order No. 1000), order on reh’g and
clarification, Order No. 1000-A, 139 FERC ¶ 61,132 (2012) (“Order No. 1000-A), order on reh’g and clarification, 141 FERC ¶ 61,044 (2012) (“Order No. 1000-B”). For convenience, unless otherwise
specified, references in this filing to “Order No. 1000” should be understood to encompass Order Nos. 1000, 1000-A, and 1000-B.

Kimberly D. Bose, Secretary July 13, 2015

Page 2

The NYISO developed this compliance filing in close collaboration with the NYTOs and
with its two Commission-jurisdictional neighboring transmission system operators, i.e., the PJM
Interconnection, L.L.C. (“PJM”) and ISO New England, Inc. (“ISO-NE”).5 Separately, ISO-NE
is submitting on behalf of itself, NYISO and PJM a further amended version (“Amended
Protocol”) of the Amended and Restated Northeastern ISO/RTO Planning Coordination Protocol
(“Protocol”).6 The revisions address the May 2015 Order’s directives regarding the Protocol
between and among the NYISO, PJM, and ISO-NE, with voluntary participation of their
neighboring Canadian system operators. The NYISO fully supports the Amended Protocol and
is submitting, through ISO-NE’s filing, a Certificate of Concurrence regarding the Amended
Protocol pursuant to Section 35.1(a) of the Commission’s regulations.7 For the Commission’s
convenience, the NYISO is also including a copy of the Amended Protocol as an exhibit to this
filing letter.

The Filing Parties are also submitting revisions to Attachment Y of the NYISO Open
Access Transmission Tariff (“OATT”) to address the May 2015 Order’s directives. The
proposed tariff revisions are described in Part V of this filing letter. The Filing Parties request
that the proposed tariff revisions be made effective January 1, 2014, which is the effective date
for which the Commission has accepted the Filing Parties’ prior Order No. 1000 interregional
related revisions to the OATT. Contemporaneous with this filing, PJM and ISO-NE are making
individual filings to comply with the requirements of the May 2015 Order that are applicable to
their respective regions.

The Filing Parties respectfully submit that - with the proposed revisions to the Amended Protocol and the NYISO OATT described in this compliance filing - they fully comply with the interregional requirements set forth in Order No. 1000 and the May 2015 Order.

I.COMMUNICATIONS

Communications and correspondence regarding this filing should be directed to:

Robert E. Fernandez, General Counsel*Ted J. Murphy

Raymond Stalter, Director of Regulatory AffairsHunton & Williams LLP

*Carl F. Patka, Assistant General Counsel2200 Pennsylvania Ave, NW

New York Independent System Operator, Inc.Washington, DC 20037

5 The Filing Parties, ISO-NE, and PJM are filing individually, as directed by the Commission, to demonstrate their own compliance with the directives of the May 2015 Order and the Order No. 1000 interregional requirements.

6 In accordance with the Commission’s electronic tariff filing requirements, only one entity, in
this case ISO-NE, is filing the Amended Protocol. ISO-NE, PJM, and NYISO propose an effective date
of July 13, 2015, for the Amended Protocol, which is its date of execution by the CEOs of ISO-NE, PJM,
and NYISO.

7 Contemporaneous with this filing, the NYISO will submit a Designation of Filing Party

pursuant to Section 35.1 of the Commission’s regulations designating ISO-NE as the filing party for the Amended Protocol.

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

rfernandez@nyiso.com rstalter@nyiso.com

cpatka@nyiso.com

Company representatives listed in Attachment I9

*Persons designated to receive service

II.LIST OF DOCUMENTS SUBMITTED

Tel: (202) 955-1500
Fax: (202) 778-2201
tmurphy@hunton.com

*Michael Messonnier8
Hunton & Williams LLP

Riverfront Plaza, East Tower 951 East Byrd Street

Richmond, VA 23219
Tel: (804) 788-8712
Fax: (804) 343-4646

mmessonnier@hunton.com

*Elias G. Farrah

Winston & Strawn, LLP 1700 K Street, NW

Washington, DC 2006-3817 Tel: (202) 282-5503

efarrah@winston.com

*Paul L. Gioia

Whiteman Osterman & Hanna LLP 111 Washington Avenue

Suite 401

Albany, NY 12210
Tel: (518) 449-3337
pgioia@woh.com

(“Attachment I”);

2. A blacklined version of the NYISO OATT Sections 31.2. 31.3. and 31.4 containing

the proposed compliance modifications (“Attachment II”);

8 Waiver of the Commission’s regulations (18 C.F.R. § 385.203(b)(3) (2014)) is requested to the
extent necessary to permit service on counsel for the NYISO in both Richmond, VA and Washington,
DC.

9 Waiver of the Commission’s regulations (18 C.F.R. § 385.203(b)(3) (2014)) is also requested to the extent necessary to permit service on counsel for the NYTOs in both Albany, NY and Washington, DC, as well as the inclusion on the service list of all of the parties listed in Attachment I.

Kimberly D. Bose, Secretary July 13, 2015

Page 4

3. A clean version of the NYISO OATT Sections 31.2, 31.3, and 31.4 containing the

proposed compliance modifications (“Attachment III”);10

4. A clean version of the NYISO OATT Section 31.2 incorporating the revisions to

Section 31.2 that became effective May 1, 2015 (“Attachment IV”);11

5. A clean version of the NYISO OATT Section 31.4 incorporating the revisions to

Section 31.2 that were filed on June 29, 2015, in Docket No. ER15-2059-000 with a requested effective date of August 28, 2015 (“Attachment V”); and12

6. A copy of the Amended Protocol being filed with the Commission by ISO-NE on

behalf of ISO-NE, PJM, and the NYISO (“Attachment VI”).

III.BACKGROUND

In response to the Order No. 1000 interregional transmission planning and cost allocation
directives, the Filing Parties submitted compliance filings on July 10, 2013, in concert with
filings by PJM and ISO-NE, to revise: (i) the Northeastern ISO/RTO Planning Coordination
Protocol, (ii) the Joint Operating Agreement Among and Between New York Independent System
Operator, Inc. and PJM Interconnection, L.L.C. located in Attachment C of the NYISO OATT,
and (iii) the requirements for the NYISO’s Comprehensive System Planning Process in
Attachment Y of the NYISO OATT.13 The May 2015 Order largely accepted the Filing Parties’

10 Sections 31.2 and 31.4 of the NYISO OATT included in Attachments II and III reflect

language that is currently pending at the Commission with a requested effective date of January 1, 2014 in Docket No. ER13-102-007 as part of the Filing Parties’ proposed tariff revisions in the Order No. 1000 regional proceeding. New York Independent System Operator, Inc. and New York Transmission Owners, Compliance Filing, Docket No. ER13-102-007 (May 18, 2015).

11 Section 31.2 of the NYISO OATT included in Attachments II and III does not reflect language
that is presently effective as accepted in New York Independent Operator, Inc., Order Conditionally
Accepting In Part and Rejecting In Part Proposed Tariff Changes and Directing Compliance Filing, 151
FERC ¶ 61,075 (2015) (accepting revisions to Section 31.2.10 of the NYISO OATT, effective May 1,
2015). The revisions to Section 31.2.10 effective May 1, 2015, have been omitted from Section 31.2 in
Attachments II and III solely for purposes of the eTariff filing because the Filing Parties have requested
that the tariff language proposed in this filing have an earlier effective date, i.e., January 1, 2014, as
described in Part VI below.

12 Section 31.4 of the NYISO OATT included in Attachments II and III does not reflect language
currently pending at the Commission in Docket No. ER15-2059-000 with a proposed effective date of
August 28, 2015. New York Independent System Operator, Inc., Proposed Tariff Revisions Regarding
Public Policy Transmission Planning Process, Docket No. ER15-2059-000 (June 29, 2015) (proposing
revisions to Section 31.4 of the NYISO OATT). The revisions to Section 31.4 of the NYISO OATT that,
if accepted by the Commission will become effective August 28, 2015, have been omitted from Section

31.4 in Attachments II and III solely for purposes of the eTariff filing because the Filing Parties have requested that the tariff language proposed in this filing have an earlier effective date, i.e., January 1, 2014, as described in Part VI below.

13 New York Independent System Operator, Inc. and New York Transmission Owners,

Interregional Compliance Filing, Docket Nos. ER13-1942-000, ER13-1946-000 (July 10, 2013).

Kimberly D. Bose, Secretary July 13, 2015

Page 5

compliance with the Order No. 1000 interregional requirements. The May 2015 Order directed the Filing Parties, along with PJM and ISO-NE, to submit a further compliance filing to make a small number of revisions to the Protocol and to the tariffs and/or agreements in each of the
neighboring regions. The NYISO discussed the amendment to the Protocol and the incremental tariff changes submitted in this compliance filing with stakeholders and all interested parties at joint meetings of the Electric System Planning Working Group and the Interregional Planning Task Force held on May 21 and June 25, 2015.

In response to the directives of the May 2015 Order, the Filing Parties propose the revised Amended Protocol submitted by ISO-NE and the revisions to Attachment Y of the NYISO OATT as described in Parts IV and V of this filing letter.

IV. REVISED AMENDED PROTOCOL

In response to the directives of the May 2015 Order, the NYISO, PJM, and ISO-NE are proposing minor revisions to the Protocol. As described above, ISO-NE, as the designated filing party, is submitting the Amended Protocol on behalf of the three parties. A detailed description of the parties’ proposed revisions to the Protocol is set forth in ISO-NE’s compliance filing in Docket No. ER13-1957 that is being filed contemporaneously with this filing.

V. REVISIONS TO ATTACHMENT Y OF THE NYISO OATT

The May 2015 Order found that “it was unclear where and when, in NYISO’s regional
transmission planning process, stakeholders can propose interregional transmission facilities,”
and directed the NYISO to revise its OATT to “explain how a stakeholder may propose an
interregional transmission facility for joint evaluation.”14 The Filing Parties propose to revise the
requirements for the NYISO’s reliability, economic, and public policy planning processes to
clarify how stakeholders can propose an Interregional Transmission Project for: (i) evaluation in
the NYISO’s regional reliability, economic, or public policy planning processes, as applicable, in
accordance with the requirements set forth in Attachment Y of the OATT, and (ii) joint
evaluation by the NYISO and the relevant neighboring transmission planning region(s) under the
Amended Protocol. Specifically, the Filing Parties propose to revise the project proposal
requirements in Sections 31.2.4.2 (reliability), 31.3.2.4 (economic), and 31.4.3 (public policy) to
state when an interested party can submit an Interregional Transmission Project in each planning
process and to provide that the project will be evaluated both in the regional planning process
under the relevant provisions in Attachment Y and jointly evaluated in the interregional planning
process under the Amended Protocol. The NYISO and the applicable neighboring transmission
planning region(s) will jointly evaluate a proposed Interregional Transmission Project under the
Amended Protocol prior to the NYISO’s selection of the more efficient or cost-effective
transmission solution to an identified need in its applicable regional process.15

14 May 2015 Order at P 72.

15 See, e.g., OATT, Att. Y, Section 31.2.7 (indicating that the NYISO will include the

interregional analysis performed under the Amended Protocol in its draft Comprehensive Reliability Plan
report prepared for stakeholder review and Board approval); Section 31.4.11 (as renumbered in June 29,
2015 filing)(indicating that the NYISO will include the interregional analysis performed under the

Kimberly D. Bose, Secretary July 13, 2015

Page 6

VI.EFFECTIVE DATE

The Commission has previously accepted a January 1, 2014, effective date for the Filing
Parties’ Order No. 1000 interregional transmission planning related revisions to the NYISO
OATT.16 The Filing Parties respectfully request that the compliance tariff modifications
proposed herein similarly become effective January 1, 2014. The NYISO understands that PJM
and ISO-NE are proposing the same effective date for their Order No. 1000 interregional
compliance revisions.

VII. SERVICE

The NYISO will send an electronic copy of this filing to the official representative of
each party to these proceedings, to the official representative of each of its customers, to each
participant on its stakeholder committees, to the New York Public Service Commission and the
New Jersey Board of Public Utilities. In addition, the complete public version of this filing will
be posted on the NYISO’s website at www.nyiso.com.

VIII. CONCLUSION

WHEREFORE, the New York Independent System Operator, Inc. and the New York

Transmission Owners respectfully request that the Commission: (i) accept this compliance filing without requiring any modifications, (ii) make the proposed tariff revisions effective on January 1, 2014, and (iii) determine that with this filing and the Amended Protocol, the Filing Parties have fully complied with the interregional planning requirements of Order No. 1000.

Respectfully submitted,

NEW YORK INDEPENDENT SYSTEM OPERATOR, INC.

By: /s/ Carl F. Patka

Robert E. Fernandez, General Counsel
Ray Stalter, Director of Regulatory Affairs
Carl F. Patka, Assistant General Counsel
New York Independent System Operator, Inc.

10 Krey Boulevard

Rensselaer, NY 12144

Email: rfernandez@nyiso.com Email: rstalter@nyiso.com

Email: cpatka@nyiso.com

NEW YORK TRANSMISSION OWNERS

By: /s/ Elias G. Farrah

Elias G. Farrah

Winston & Strawn LLP 1700 K Street, NW

Washington, DC 20006-3817
Email: efarrah@winston.com

*Paul L. Gioia

Whiteman Osterman & Hanna LLP One Commerce Plaza

Albany, NY 12260

Kimberly D. Bose, Secretary July 13, 2015

Page 7

Email: pgioia@woh.com

/s/ John Borchert/s/ Richard B. Miller

John BorchertConsolidated Edison Company of New York, Inc.

Senior Director of Energy Policy andOrange and Rockland Utilities, Inc.

Transmission DevelopmentRichard B. Miller

Central Hudson Gas & Electric CorporationDirector of Energy Markets Policy Group

284 South AvenueConsolidated Edison Co.

Poughkeepsie, NY 12601of New York, Inc.

Email: jborchert@cenhud.com4 Irving Place

Room 2315-s

New York, NY 10003

Email: millerrich@coned.com

/s/Kristina Nifora

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

Kristina Nifora, Esq.

Associate Counsel

Consolidated Edison Co. of New York, Inc.

4 Irving Place

Room 1850-s

New York, NY 10003

Email: niforak@coned.com

/s/ Jon R. Mostel/s/ Andrew Neuman

Jon R. MostelAndrew Neuman, Esq.

General CounselNew York Power Authority

Long Island Lighting Company123 Main Street

333 Earle Ovington BoulevardWhite Plains, NY 10601-3170

Suite 403Email: andrew.neuman@nypa.gov

Uniondale, NY 11553

Email: jmostel@lipower.org/s/ Andrew Antinori

Andrew Antinori

/s/ David ClarkeDirector Market Issues

David ClarkeNew York Power Authority

Director of Power Markets Policy123 Main Street

Long Island Power AuthorityWhite Plains, NY 10601-3170

99 Washington AvenueEmail: andrew.antinori@nypa.gov

10th Floor

Albany, NY 12210-2822

Email: dclarke@lipower.org

/s/ Joseph B. Nelson

Joseph B. Nelson

Kimberly D. Bose, Secretary July 13, 2015

Page 8

Van Ness Feldman, LLP

1050 Thomas Jefferson Street, NW Washington, DC 20007

Email: jbn@vnf.com

/s/ R. Scott Mahoney/s/ David Lodemore

R. Scott Mahoney, Esq.David Lodemore

New York State Electric & Gas CorporationSenior Counsel

Rochester Gas and Electric CorporationNiagara Mohawk Power Corporation

Iberdrola USAd/b/a National Grid

18 Link Drive40 Sylvan Road

P.O. Box 5224Waltham, MA 02451-1120

Binghamton, NY 13902-5224david.lodemore@nationalgrid.com

Email: scott.mahoney@iberdrolausa.com

/s/ Bart Franey

Bart Franey

Director of Federal Regulation

Niagara Mohawk Power Corporation d/b/a National Grid

300 Erie Boulevard West
Syracuse, NY 13202

bart.franey@nationalgrid.com

cc:Michael Bardee

Gregory Berson
Anna Cochrane
Morris Margolis
David Morenoff
Daniel Nowak
Kathleen Schnorf
Jamie Simler

Kevin Siqveland