May 2, 2018
By Electronic Delivery
Honorable Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE
Washington, DC 20426
Re: New York Independent System Operator, Inc., Refiling of Tariff Section to
Correct Ministerial Error; Docket No. ER13-102-___
Dear Secretary Bose:
On March 19, 2018, the New York Independent System Operator, Inc. (“NYISO”) filed
with the Federal Energy Regulatory Commission (“Commission”) in the above-referenced
docket, revisions to Section 31.11 of the NYISO’s Open Access Transmission Tariff (“OATT”)
to fulfill the directives of the Commission in its February 15, 2018, Order Conditionally
Accepting Tariff Revisions and Requiring Further Compliance (“March 2018 Filing”).1 That
filing is pending before the Commission. In that filing, the NYISO filed its revisions to Section
31.11 of the OATT on an incorrect base document, from which proposed language previously filed in another proceeding was inadvertently omitted.
I.Description of Filing
The NYISO has identified a ministerial error in its March 2018 Filing, where the NYISO
used an incorrect base document to create the clean and blacklined versions of the proposed
revisions to Section 31.11 of the OATT (i.e., the pro forma Operating Agreement) with an
effective date of April 1, 2016. The submitted base document did not include revised language
that the NYISO filed on September 19, 2016 (“September 2016 Filing”) to comply with an order
issued by the Commission on April 21, 2016,2 and consequently the proposed revisions in the
March 2018 Filing did not address the added language from the September 2016 Filing.
1 New York Independent System Operator, Inc., Compliance Filing, Docket No. ER13-102-012 (March 19, 2018) (“March 2018 Filing”).
2 New York Independent System Operator, Inc., Order on Compliance and Rehearing, 155 FERC ¶ 61,076 (2016) (“April 2016 Order”). See generally, New York Independent System Operator, Inc., Notice of Extension of Time, Docket Nos. ER16-120-000, EL15-37-001 (May 21, 2016).
10 Krey Boulevard, Rensselaer, New York 12144 | www.nyiso.com
Honorable Kimberly D. Bose May 2, 2018
Page 2
In its September 2016 Filing, the NYISO proposed to add the phrase “or Attachment FF”
to a reference to the requirements of Attachment Y in connection with recovery of costs in
Article 3.08 of Section 31.11 of the OATT. To conform Article 3.08 of the Operating
Agreement with Article 3.10 of the ISO/TO Agreement as directed by the Commission, the
NYISO proposed in the March 2018 Filing to revise the language related to recovery of costs,
which included removing the reference to Attachment Y and should have included removing the
reference to Attachment FF. Consistent with the revisions in its March 2018 Filing, the attached
corrected base document reflects the revision to remove the phrase “or Attachment FF” as shown
in Attachment II to this filing letter.3
II.Effective Date
The NYISO respectfully requests that the Commission accept the tariff revisions
resubmitted in this errata filing with an effective date of April 1, 2016, which is consistent with the effective date requested in the March 2018 Filing.
III.Documents Submitted
The NYISO respectfully submits the following documents with this filing letter:
1. A clean version of the corrected Section 31.11 of the OATT (“Attachment I”); and
2. A blacklined version of the corrected Section 31.11 of the OATT (“Attachment II”).
IV.Communications
Communications and correspondence regarding this filing should be directed to:
Robert E. Fernandez, General Counsel
Raymond Stalter, Director, Regulatory Affairs *Carl F. Patka, Assistant General Counsel *Brian R. Hodgdon, Attorney
New York Independent System Operator, Inc.
10 Krey Boulevard
Rensselaer, NY 12144
Tel: (518) 356-6000
Fax: (518) 356-4702
3 In the September 2016 Filing, the NYISO inadvertently left out of the submitted base document a
correction to the revisions to Section 31.11 of the OATT that the NYISO proposed in its March 22, 2016 compliance
filing in Docket No. ER13-102. See New York Independent System Operator, Inc., Errata Correcting Compliance
Filing, Docket Nos. ER13-102-009, -010, at p 2 (May 24, 2016) (correcting and refiling Article 3.03c of the pro
forma Operating Agreement to remove an inadvertent duplication of the language in Article 3.03b). Given that the
language currently at issue has the same effective date of April 1, 2016 and was not revised in the September 2016
Filing, the discrepancy has no practical effect and is noted in this filing to correct and complete the record.
Honorable Kimberly D. Bose May 2, 2018
Page 3
rfernandez@nyiso.com
rstalter@nyiso.com
cpatka@nyiso.com
bhodgdon@nyiso.com
* Persons designated to receive service
V.Service
The NYISO will send an electronic link to this filing to the official representative of each
party to this proceeding, to the official representative of 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. In addition, the complete filing will be posted on the NYISO’s
website at www.nyiso.com.
VI.Conclusion
The NYISO respectfully requests that the Commission accept this correction to Section
31.11 of the NYISO’s OATT with an effective date of April 1, 2016.
Respectfully submitted,
/s/ Brian R. Hodgdon
Brian R. Hodgdon, Attorney
New York Independent System Operator, Inc. Tel: (518) 356-6054
Email: bhodgdon@nyiso.com
cc:Anna Cochrane
James Danly
Jette Gebhart
Kurt Longo
David Morenoff
Daniel Nowak
Larry Parkinson
J. Arnold Quinn
Douglas Roe
Kathleen Schnorf Gary Will