10 Krey Boulevard  Rensselaer, NY 12144

October 27, 2015

By Electronic Delivery

Kimberly D. Bose, Secretary

Federal Energy Regulatory Commission 888 First Street N.E.

Washington, D.C. 20426

Re: Response to Deficiency Letter; Request for a Revised Effective Date; and
Resubmission of Proposed Tariff Revisions; Docket No. ER15-2059-000

Dear Ms. Bose:

The New York Independent System Operator, Inc. (“NYISO”) submits this response to
the deficiency letter issued by the Federal Energy Regulatory Commission (“Commission”) in
this proceeding on August 28, 2015 (“Deficiency Letter”). The Deficiency Letter directed the
NYISO to provide additional information regarding the proposed revisions in its June 29, 2015,
filing1 (“June 2015 Filing”) to its Open Access Transmission Tariff (“OATT”) to clarify and
enhance the Public Policy Transmission Planning Process (“Public Policy Process”) portion of its
Comprehensive System Planning Process.2 The NYISO submits the requested information in
Attachment I to this filing letter.

The NYISO understands that this response to the Deficiency Letter constitutes an

amendment to its June 2015 Filing and a new filing date will be established pursuant to Duke

Power Co., 57 FERC ¶ 61,215 (1991). The NYISO requests that the tariff amendments proposed in the June 2015 Filing become effective in accordance with the regular, statutory sixty-day
notice period, which effective date will be December 26, 2015.

Timely approval of the proposed revisions in the June 2015 Filing is important to the

NYISO’s ability to carry out its Public Policy Process. On November 1, 2015, the NYISO will
solicit solutions to a Public Policy Transmission Need based on a Public Policy Requirement
issued by the New York State Public Service Commission (“NYPSC”) in July calling for
transmission upgrades in Western New York.3 In addition, in September, the New York

1 New York Independent System Operator, Inc., Proposed Tariff Revisions Regarding Public Policy Transmission Planning Process, Docket No. ER15-2059-000 (June 29, 2015).

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 See Order for Addressing Public Policy Requirements for Transmission Planning Purposes, In the Matter of New York Independent System Operator, Inc.’s Proposed Public Policy Transmission Needs for Consideration, NYPSC Case 14-E-0454 (July 20, 2015).

Honorable Kimberly D. Bose October 27, 2015

Page 2

Department of Public Service (“NYDPS”) Staff issued a motion calling on the NYPSC to issue a determination finding that there is Public Policy Transmission Need to upgrade the transmission system through existing Mohawk and Hudson Valley transmission corridors that connect upstate and downstate New York.4 The NYPSC is expected to rule on this second transmission need by the end of this year. Should the NYPSC issue a need determination, the NYISO will commence a second Public Policy Process to address that need in early 2016.

To successfully implement its Public Policy Process to meet both of New York’s

transmission needs as intended by Order Nos. 890 and 1000, the NYISO requires the tariff

revisions proposed in the June 2015 Filing to clarify certain elements of its process. These

revisions were developed with, and approved without objection by, the NYISO’s stakeholders.
Accordingly, the NYISO respectfully requests that FERC Staff recommend and the Commission accept the June 2015 Filing by December 26, 2015 in accordance with the regular, statutory sixty day notice period, such that the NYISO can implement its Public Policy Process to address New York’s transmission needs.

The NYISO respectfully submits a clean version of the pending tariff amendments from its June 2015 Filing in Docket No. ER15-2059-000, with an amended effective date of December 26, 2015, in Attachment II to this filing letter.5

This filing will be posted on the NYISO’s website at www.nyiso.com. In addition, the
NYISO will e-mail an electronic link to this filing to the official representative of each party to
this proceeding, to 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.

Please feel free to contact me if your office has any additional questions.

Respectfully submitted,

/s/ Carl F. Patka

Carl F. Patka

Assistant General Counsel

New York Independent System Operator, Inc. (518) 356 6220

4 See Motion of DPS Trial Staff for Commission to Declare a Public Policy Need & Take Further
Action Regarding Alternating Current Transmission Proposals, Proceeding on Motion of the
Commission to Examine Alternating Current Transmission Upgrades, NYPSC Case 12-T-0502, et al.
(Sept. 22, 2015).

5 Subsequent revisions have been filed on OATT Sections 31.1 and 31.5 in Docket No. ER16-

120-000 and Section 31.4 in ER13-1942-001. However, none of the pending revisions impact the instant
filing.

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 27th day of October, 2015.

By:/s/ John C. Cutting

John C. Cutting

New York Independent System Operator, Inc.

10 Krey Blvd.

Rensselaer, NY 12144 (518) 356-7521