UNITED STATES OF AMERICA
BEFORE THE
FEDERAL ENERGY REGULATORY COMMISSION
New York Independent System Operator, Inc.)Docket No. RM08-5-000
MOTION FOR EXTENSION OF FILING DEADLINE OF THE
NEW YORK INDEPENDENT SYSTEM OPERATOR, INC.
In accordance with Rules 212 and 2008 of the Commission’s Rules of Practice and
Procedure,1 the New York Independent System Operator, Inc. (“NYISO”) respectfully requests
that the Commission grant a 15 day extension of the filing deadline for Federal Energy
Regulatory Commission (“FERC”) Form No. 3-Q, Quarterly Financial Report of Electric
Utilities, Licensees, and Natural Gas Companies. The filing for the Third Quarter of 2018 is due
on November 29, 2018.2 The NYISO requests a 15 day extension to submit its Form No. 3-Q
for the Third Quarter of 2018 not later than December 14, 2018, for the reasons set forth below.
There is good cause for granting the requested extension. As discussed in greater detail below, although the NYISO has compiled the necessary information and is prepared to submit its Form No. 3-Q, it has encountered unexpected technical difficulties with electronically submitting its Form No. 3-Q to the Commission. The NYISO has informed FERC staff of this matter is continuing to work with FERC staff to resolve the issue. Granting the requested extension will provide the NYISO the time it requires to continue work with FERC staff on these technical
difficulties and allow it to make its electronic submission of Form No. 3-Q.
1 18 C.F.R. §§ 385.212 and 2008 (2018).
2 18 C.F.R. §141.400 (b)(2)(vii)(2018).
1
The NYISO respectfully requests that the standard five day period for answering motions for extension of time established under Rule 213(d)(1)(i) apply to this filing.3
I.Communications
Communications and correspondence regarding this filing should be directed to:
Karen G. Gach, Acting General Counsel
Raymond Stalter, Director, Regulatory Affairs
*Christopher R. Sharp, Senior Compliance Attorney New York Independent System Operator, Inc.
10 Krey Boulevard
Rensselaer, NY 12144
Tel: (518) 356-6000
Fax: (518) 356-4702
kgach@nyiso.com
rstalter@nyiso.com
csharp@nyiso.com
* Person designated for service.
II. Request for Extension of Filing Deadline
Rule 2008 authorizes the Commission to extend any deadline, including one imposed by a Commission compliance directive, before it expires if a requesting party demonstrates that there is “good cause” to do so. For the reasons set forth below, the NYISO respectfully submits that there is good cause to grant its requested 15 day extension of time.
The NYISO has on multiple occasions timely submitted FERC Form Nos. 1 and 3-Q
electronically using the FERC submission software. However, despite extended communication
with and assistance from FERC technical support, the submission software is at this time not
permitting the NYISO to make its electronic submission for FERC Form No. 3-Q for the Third
Quarter of 2018. It appears that this issue will not be resolved prior to the November 29, 2018
3 18 C.F.R. § 385.213(d)(1)(i) (2018).
2
filing deadline for the Third Quarter of 2018. Although NYISO has requested a 15 day
extension, it is fully prepared to submit Form 3-Q as soon as the technical issue is resolved.
Finally, the NYISO requests that the Commission apply the standard five day answer period for motions for extensions of time and act expeditiously to grant the requested extension as soon as possible thereafter.
III.Conclusion
WHEREFORE, for the foregoing reasons, the NYISO respectfully requests that the
Commission grant a 15 day extension to the Form 3-Q filing deadline for the Third Quarter of 2018 so that the NYISO may submit its filing no later than December 14, 2018.
Respectfully submitted,
/s/ Christopher R. Sharp
Christopher R. Sharp
Senior Compliance Attorney
New York Independent System Operator, Inc.
10 Krey Blvd.
Rensselaer, New York 12144 csharp@nyiso.com
Date: November 29, 2018
cc:Nicole Buell
Anna Cochrane
James Danly
Jignasa Gadani
Jette Gebhart
Kurt Longo
David Morenoff
Daniel Nowak
Larry Parkinson
Douglas Roe
Kathleen Schnorf Gary Will
3
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 29th day of November 2018.
/s/ Joy A. Zimberlin
Joy A. Zimberlin
New York Independent System Operator, Inc.
10 Krey Blvd.
Rensselaer, NY 12144 (518) 356-6207