July 10, 2017
By Electronic Delivery
Honorable Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE
Washington, DC 20426
Re: Response to Deficiency Letter; Resubmission of Proposed Tariff Revisions with
a Revised Effective Date; Docket No. ER17-1310-___
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 May 24, 2017 (“Deficiency Letter”). The Deficiency Letter directed the NYISO to
provide additional information required for the Commission to address the NYISO’s March 27, 2017,
filing (“March 2017 Filing”)1 of a regional cost allocation methodology pursuant to Section
31.5.5.4.1 of its Open Access Transmission Tariff (“OATT”). The methodology was prescribed by
the Public Policy Requirement that resulted in the identification by the New York Public Service
Commission of the AC Transmission Public Policy Transmission Needs, for which the NYISO must
solicit and evaluate solutions. The NYISO submits the requested information in Attachment I to this
letter.
The NYISO understands that this response to the Deficiency Letter constitutes an amendment
to its March 2017 Filing and that a new filing date will be established pursuant to Duke Power Co.,
57 FERC ¶ 61,215 (1991). The NYISO respectfully re-files clean and marked versions of the
pending tariff amendments submitted with its March 2017 Filing as Attachments II and III to this
letter, respectively, and proposes to change the effective date from May 26, 2017, to an unspecified effective date. The NYISO hereby requests that the tariff revisions proposed in the March 2017
Filing be permitted to become effective on the date of the Commission’s issuance of an order ruling on the proposed revisions.2
The 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.
1 New York Independent System Operator, Inc., Docket No. ER17-1310-000 (March 27, 2017).
2 See New York Independent Operator, Inc., 154 FERC ¶ 61,111 (2016) at PP 14, 39 (accepting effective date as date of Commission’s order, as requested in NYISO response to deficiency letter).
