Elias G. Farrah

Partner

(202) 282-5503

efarrah@winston.com

April 12, 2016

VIA ELECTRONIC TARIFF

The Honorable Kimberly D. Bose Secretary

Federal Energy Regulatory Commission 888 First Street, N.E.

Washington, D.C. 20426

Re: New York Independent System Operator, Inc., et al.

Compliance Filing and Request for Expedited Action Docket Nos. ER15-572-001 and ER15-572-004

Dear Secretary Bose:

New York Transco, LLC, Central Hudson Gas and Electric Corp., Consolidated Edison
Company of New York, Inc., Niagara Mohawk Power Corporation, New York State Electric and
Gas Corporation (“NYSEG”), Orange and Rockland Utilities, and Rochester Gas and Electric
Corporation (collectively referred to herein as “NY Transco”) hereby file revisions to the New
York Independent System Operator, Inc.’s (“NYISO”) Open Access Transmission Tariff

(“OATT”)1 in compliance with the Settlement Agreement in Docket No. ER15-572-000 and the
Commission’s order issued March 17, 2016, approving the Settlement Agreement.2 Consistent
with the March 17 Order, NY Transco requests that the tariff revisions be made effective April 3,
2015. In addition, NY Transco requests that the Commission expeditiously review this
compliance filing and issue an order accepting the compliance filing by May 31, 2016.

I.BACKGROUND

On December 4, 2014, NY Transco submitted a rate filing pursuant to section 205 of the
Federal Power Act (“FPA”) requesting that the Commission: (1) approve certain incentive rate
treatments pursuant to section 219 of the FPA and Order No. 679 for its investment in five-
interrelated high-voltage transmission projects in New York; (2) accept NY Transco’s

transmission formula rate, which includes a formula rate template and protocols; (3) approve NY
Transco’s requested return on equity; (4) accept NY Transco’s cost allocation method to recover
its revenue requirement; and (5) accept NY Transco’s proposed revisions to the NYISO OATT
to include recovery of the proposed Transco Facilities Charge under Schedule 13 (Section 6.13)
and the proposed cost allocation and formula rate template and implementation protocols as

1 Pursuant to Order No. 714, this filing is submitted by the NYISO on behalf of NY Transco as part of an electronic filing package that conforms to the Commission’s regulations.

2 New York Indep. Sys. Operator, Inc., 154 FERC ¶ 61,196 (2016) (“March 17 Order”).

April 12, 2016
Page 2

Attachment DD(Section36).Numerous parties, including the Settling Parties,3 filed

interventions, protests, comments, and answers in response to NY Transco’s December 4 filing.

On April 2, 2015, the Commission issued an order, inter alia, accepting NY Transco’s
proposed formula rate for filing, suspending the formula rate for a nominal period of one day,
and setting the formula rate for hearing, subject to refund.4 Several parties filed requests for
rehearing of the April 2 Order, including NY Transco, NYPSC, and NYPA. The April 2 Order
also required NY Transco to submit a compliance filing to revise the formula rate protocols as
directed in the April 2 Order and to remove the cost allocation tables included in Attachment DD
(Section 36) of the OATT.5 On May 4, 2015, NY Transco submitted a compliance filing
consistent with the Commission’s direction in the April 2 Order (“May 4 Compliance Filing”).

On November 5, 2015, NY Transco filed an Offer of Partial Settlement with the
Commission that would resolve all of the issues set for hearing or pending in requests for
rehearing of the April 2 Order with respect to NY Transco’s three proposed Transmission Owner
Transmission Solutions (“TOTS”) Projects (the “Settlement Agreement”), including, as relevant
to this compliance filing, a cost allocation methodology for the TOTS Projects.6 Subsequent to
the filing of the Settlement Agreement, comments were filed with the Commission identifying
certain mutually agreed upon corrections to the formula rate template and to Schedule 13
(Section 6.13) of the OATT with respect to the calculation of the NYPA component of the
Transco Facilities Charge for customers in a region designated by the NYISO as “NYPA
North.”7

The Commission approved the Settlement Agreement on March 17, 2016, and rejected
NY Transco’s May 4 Compliance Filing as moot because the Settlement Agreement includes the
allocation of costs for the TOTS Projects.8 The Commission directed Applicants to file within

3 The Settling Parties are NY Transco, New York Power Authority (“NYPA”), Power Supply Long Island, New York Public Service Commission (“NYPSC”), New York State Department of State Utility Intervention Unit, City of New York, New York Association of Public Power, Municipal Electric Utilities Association of New York, and Multiple Intervenors (an unincorporated association of approximately 60 industrial, commercial, and institutional energy consumers with manufacturing and other facilities located throughout New York State).

4 New York Indep. Sys. Operator, Inc., 151 FERC ¶ 61,004 (2015) (“April 2 Order”).

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

6 The TOTS Projects are the Ramapo to Rock Tavern Project, the Staten Island Unbottling Project, and NYSEG’s
portion of the Marcy South Series Compensation Fraser to Coopers Corner Reconductoring Project. The two
projects proposed to be developed by NY Transco in the NYPSC’s Alternating Current Transmission Proceeding -
the Edic to Pleasant Valley Project and the Oakdale to Fraser Project (together, the “AC Projects”) - are not subject
to the terms of the Settlement Agreement. On January 27, 2016, the Chief Administrative Law Judge held the
proceeding in Docket No. ER15-572-000 in abeyance with respect to outstanding issues associated with the AC
Projects until the NYISO issues a Viability and Sufficiency Assessment, consistent with the NYISO OATT, with
respect to the AC Projects.

7 See Comments of Applicants filed November 25, 2015; Comments of FERC Trial Staff filed November 25, 2015; Reply Comments of Applicants filed December 14, 2015; Reply Comments of FERC Trial Staff filed December 14, 2015; Supplemental Comments of FERC Trial Staff filed December 22, 2015; and Comments of NYPA filed on December 28, 2015.

8 March 17 Order, at P 6.

April 12, 2016
Page 3

30 days of the March 17 Order revised tariff sheets implementing the Settlement Agreement, including the minor agreed upon changes to the formula rate template as well as the changes to the protocols for the formula rate pursuant to the April 2 Order.9

II.DESCRIPTION OF FILING

In compliance with the Commission’s April 2 Order and March 17 Order, NY Transco hereby submits the following revisions to the NYISO OATT, all of which are identified in blackline in this filing.

First, Attachment DD (Section 36) of the OATT is revised to reflect revision to the formula rate protocols, as directed by the Commission in the April 2 Order. These revisions are located in Sections 3(e)(xi) and 4(b) of the formula rate protocols (Section 36.3.1.2).

Second, Attachment 1 to Attachment DD (Section 36.2) is revised to reflect the cost allocation for the TOTS Projects set forth in the Settlement Agreement.

Third, Attachment DD (Section 36.1.1) is revised to accurately reflect the projects to which Attachment DD applies. In addition, revisions have been made throughout the formula rate template (Section 36.3.1.1) and implementation protocols (Section 36.3.1.2) to reflect the agreement of the Settling Parties as set forth in the Settlement Agreement and the comments submitted in response to the Settlement Agreement.

Fourth, Schedule 13 (Section 6.13) is revised throughout to reflect necessary revisions to the calculation of the NYPA component of the Transco Facilities Charge to account for NYPA North customers. These revisions were filed as comments on the Settlement Agreement by NY Transco at the request of the NYISO to ensure that the OATT provisions to be implemented accurately reflect the Settlement Agreement.

Fifth, Schedule 13 (Section 6.13.4.2) includes a minor revision to the cross-reference to
the formula rate template (Attachment 2 of Attachment DD or Section 36.3). In discussions with
the NYISO, it was determined that minor clarifying language was necessary to reflect the fact
that the formula rate template approved by the Commission in the March 17 Order is a form of
the formula rate template that will be used to calculate the Transco Facilities Charge on an
annual basis. The collections that the NYISO will begin on behalf of NY Transco on June 1,
2016, will be based on the estimated costs calculated in NY Transco’s November 30, 2015
annual projection, which was posted to the NYISO website in accordance with the protocols.

9 Id. at PP 5, 7. The April 2 Order directed NY Transco to revise its protocols to include language proposed by NYAPP as new Section 3(e)(vi) and Section 4(b). As a result of additional changes to the protocols requested by FERC Trial Staff and Settling Parties, the changes to the protocols directed by the April 2 Order are currently located in Section 3(e)(xi) and Section 4(b).

April 12, 2016
Page 4

III.CONTENTS OF FILING

This compliance filing consists of the following documents:

1. This transmittal letter;

2. Attachment A - A clean version of Schedule 13 (Section 6.13) and
Attachment DD (Section 36) of the NYISO OATT; and

3. Attachment B - A redlined version of Schedule 13 (Section 6.13) and
Attachment DD (Section 36) of the NYISO OATT.

IV.COMMUNICATIONS

All communications regarding this filing should be directed to the following

individuals:10

Stuart Nachmias President

New York Transco, LLC

Consolidated Edison Company of New
York, Inc.

4 Irving Place

New York, NY 10003
Tel: (212) 460-2580

E-mail: nachmiass@coned.com

Robert Caso

Vice President of Finance and Accounting

New York Transco, LLC 284 South Avenue

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

E-mail: rcaso@cenhud.com

Elias G. Farrah

Winston & Strawn LLP 1700 K Street NW

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

E-mail: efarrah@winston.com

James A. Lahtinen

Vice President of Regulatory Affairs New York Transco, LLC

Rochester Gas and Electric Corp.

89 East Avenue

Rochester, NY 14649-0001 Tel: (585) 724-8409

E-mail: james_lahtinen@rge.com

Nabil Hitti

Vice President, Capital Investments New York Transco, LLC

National Grid

40 Sylvan Road

Waltham, MA 02451
Tel: (781) 907-2657

E-mail: nabil.hitti@nationalgrid.com

April 12, 2016
Page 5

V.SERVICE

NY Transco will serve each person designated on the official service list compiled by the
Secretary in this proceeding. This filing will be posted on the NYISO website at

www.nyiso.com, and 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 NYPSC, and to the New Jersey Board of Public Utilities.

VI.TARIFF EFFECTIVE DATE

NY Transco requests an effective date for the revised tariff included herein of April 3, 2015, consistent with the March 17 Order.

VII. REQUEST FOR EXPEDITED ACTION

NY Transco anticipates that the TOTS Projects will be placed into service on June 1,
2016. Accordingly, NY Transco respectively requests a shortened comment period of 21 days or
less and expeditious consideration of this compliance filing by the Commission. NY Transco
requests that the Commission issue an order accepting this compliance filing by May 31, 2016.

VIII. CONCLUSION

For the foregoing reasons, NY Transco respectfully requests the Commission to accept
this compliance filing without modification. Please contact the undersigned if you have any
questions.

Respectfully submitted,

/s/ Elias G. Farrah

Elias G. Farrah

Kimberly Ognisty

Winston & Strawn LLP
1700 K Street, N.W.
Washington, DC 20006
efarrah@winston.com
kognisty@winston.com

Counsel to New York Transco, LLC

CERTIFICATE OF SERVICE

I hereby certify that I have this day served the foregoing document upon each person designated on the official service list in this proceeding in accordance with the requirements of Rule 2010 of the Commission’s Rules of Practice and Procedure.

Dated at Washington, D.C. this 12th day of April, 2016.

/s/ Carlos L. Sisco

Carlos L. Sisco
Senior Paralegal

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

Washington, DC 20006-3817
202-282-5000