December 11, 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., Proposed Tariff Revisions Regarding
Public Policy Transmission Planning Process; Docket No. ER19-____-000

Dear Ms. Bose:

Pursuant to Section 205 of the Federal Power Act,1 the New York Independent System
Operator, Inc. (“NYISO”) hereby submits proposed revisions to the Public Policy Transmission
Planning Process (“Public Policy Process”) portion of its Comprehensive System Planning
Process (“CSPP”),2 as well as to its pro forma non-incumbent transmission owner operating
agreement (“Operating Agreement”).3 The NYISO’s proposed revisions to these tariff
provisions located in Attachment Y of the NYISO Open Access Transmission Tariff (“OATT”)
will clarify and enhance the Public Policy Process and Operating Agreement.4

I.List of Documents Submitted

The NYISO submits the following documents with this filing letter:

1.A clean version of the proposed revisions to the OATT (Attachment I); and

2.A blacklined version of the proposed revisions to the OATT (Attachment II).

1 16 U.S.C. § 824d (2012).

2 As described below, the NYISO also makes certain conforming revisions to the reliability planning process portion of its CSPP.

3 Capitalized terms that are not otherwise defined in this filing letter shall have the meaning specified in Section 31.1.1 of Attachment Y to the NYISO OATT, and if not defined therein, in the NYISO OATT and NYISO Market Administration and Control Area Services Tariff.

4 Unless otherwise indicated, the tariff references in this filing letter are to Attachment Y of the NYISO

OATT.

10 Krey Boulevard, Rensselaer, New York 12144 | www.nyiso.com

Karen G. Gach, Acting General Counsel
Raymond Stalter, Director of 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 kgach@nyiso.com

rstalter@nyiso.com
cpatka@nyiso.com
bhodgdon@nyiso.com

* Persons designated for service.

III.Background

* Ted J. Murphy

Hunton Andrews Kurth LLP 2200 Pennsylvania Avenue, NW Washington, DC 20037

Tel: (202) 955-1500
Fax: (202) 778-2201

tmurphy@huntonak.com

* Michael J. Messonnier, Jr.5 Sevren R. Gourley

Hunton Andrews Kurth LLP 951 East Byrd Street

Richmond, VA 23219
Tel: (804) 788-8200
Fax: (804) 344-7999

mmessonnier@huntonak.com sgourley@huntonak.com

The CSPP is comprised of the NYISO’s local, reliability, economic, and public policy
transmission planning processes. Since implementing the Public Policy Process in 2014, the
NYISO has administered the process to solicit, evaluate, and select a transmission solution to
address a Western New York Public Policy Transmission Need (“Western New York Need”) and
is currently evaluating solutions to AC Transmission Public Policy Transmission Needs. In light
of the experience gained from implementing and administering the Public Policy Process thus
far, the NYISO, in conjunction with stakeholders and Developers, has reviewed the tariff
requirements for its Public Policy Process and has identified revisions to clarify, streamline, and
enhance the process. These proposed revisions apply equally to both incumbent and non-
incumbent Developers. They serve as immediate process improvements that once accepted by
the Federal Energy Regulatory Commission (“Commission”), the NYISO will implement in time
for a solicitation of projects to meet identified needs, if any, for the 2018-2019 cycle of the
Public Policy Process.

The NYISO reviewed the proposed tariff revisions described below with its stakeholders,
which approved the tariff amendments at NYISO governance committee meetings. The NYISO
Board of Directors approved the changes at its November 2018 meeting and directed the changes

5 The NYISO respectfully requests waiver of 18 C.F.R. § 385.203(b)(3) (2014) to permit service on counsel for the NYISO in both Washington, DC and Richmond, VA.

Honorable Kimberly D. Bose December 11, 2018

Page 3

to be filed with the Commission under Section 205 of the Federal Power Act. The NYISO
requests that the Commission accept the proposed tariff revisions with an effective date of
February 10, 2019, which is the day following the end of the statutory 60-day notice period.

IV. Description of Proposed Tariff Revisions

A.Technical Conference with Developers

In the NYISO’s “lessons learned” process following the Public Policy Process to address the Western New York Need, both incumbent and non-incumbent Developers commented that they would like more technical information on identified Public Policy Transmission Needs before the NYISO solicits solutions. Specifically, Developers expressed the need for a greater understanding of how the NYISO proposes to apply the selection metrics for a specific Public Policy Transmission Need. Accordingly, the NYISO proposes to insert a new process step in Section 31.4.4.3.1 to hold a technical conference with Developers and interested parties prior to issuing a solicitation for solutions to a Public Policy Transmission Need.

The technical conference would obtain input and answer questions on the NYISO’s

application for the particular Public Policy Transmission Need of the selection metrics that are
contained in the tariff, any metrics identified by the New York Public Service Commission
(“NYPSC”) in its order identifying the need, and any additional metrics that the NYISO may
apply to the need. This step will provide additional clarity at the start of the process concerning
the scope of the metrics that the NYISO will use in evaluating proposed solutions and enhance
the openness and transparency of the Public Policy Process for all Developers and interested
parties.

B.Elimination of the Pause Point for New York Public Service Commission to

Confirm the Need

The NYISO is currently required to pause the Public Policy Process following its

completion of the Viability and Sufficiency Assessment of proposed solutions to afford the

NYPSC an opportunity to review all of the viable and sufficient solutions and confirm whether
the NYISO should proceed to evaluate proposals and select a transmission solution to the Public
Policy Transmission Need.6 This built-in “pause point” can result in months of inactivity in the
process without the NYISO being able to move forward to the evaluation of competing
proposals.

The NYISO proposes to eliminate this pause in its process. Specifically, the NYISO
proposes to revise Sections 31.4.6.6 and 31.4.6.7 to remove the requirement that the NYPSC
must issue an order confirming the Public Policy Transmission Need before the NYISO can
move forward with its evaluation and selection process. These revisions will remove a
procedural step that has the potential to result in extended periods of inactivity in the process by
allowing the NYISO to begin evaluating projects for selection following completion of the

6 OATT, Att. Y, Section 31.4.6.

Honorable Kimberly D. Bose December 11, 2018

Page 4

Viability and Sufficiency Assessment. While the NYISO continues to make progress on

evaluating competing projects, the NYPSC can consider whether to issue an order eliminating or modifying the Public Policy Transmission Need. This change will not diminish the authority of the NYPSC, as the transmission siting entity for the State of New York,7 since the NYPSC still has the authority to cancel or modify the Public Policy Transmission Need at any time prior to the NYISO’s selection of the more efficient or cost-effective transmission solution.

In eliminating the pause point, the NYISO proposes to shift the deadline in Section

31.4.6.6 by which a Developer must provide notice that it intends for its project to continue to be
evaluated and to demonstrate that it has an executed System Impact Study Agreement or System
Reliability Impact Study Agreement, as applicable. Under the proposed revisions, the 15-day
period would commence following the NYISO’s filing of the final Viability and Sufficiency
Assessment with the NYPSC rather than the date of the NYPSC’s order confirming the Public
Policy Transmission Need. The NYISO will thereafter begin evaluating proposals for selection
as the more efficient or cost effective solution(s) and continue until selection or the NYPSC
issues an order cancelling or modifying the Public Policy Transmission Need. Under the revised
Section 31.4.6.7, if the NYPSC were to take such action, the NYISO would halt the current
process. Furthermore, if the NYPSC were to modify the need, the NYISO would proceed with
an out-of-cycle process to address the modification, including issuing a new solicitation for
proposed solutions to the need.

The linking of the deadline for Developers to satisfy the requirements under Section

31.4.6.6 following the filing of the Viability and Sufficiency Assessment still affords more than
adequate time for both incumbent and non-incumbent Developers to complete the necessary
steps.8 First, the NYISO is retaining the requirement for it to present the Viability and
Sufficiency Assessment to stakeholders, interested parties and New York State Department of
Public Service prior to finalizing the assessment.9 This step will allow Developers to review the
initial draft and begin considering whether they wish to continue in the process in advance of the
15-day period under Section 31.4.6.7. Second, the execution of a System Impact Study
Agreement or System Reliability Impact Study Agreement is almost entirely within the control
of the Developers,10 as they can proceed directly to the System Impact Study or System
Reliability Impact Study under the NYISO’s Transmission Interconnection Procedures and Large
Facility Interconnection Procedures, respectively.11 The practical effect is that Developers have

7 See New York Pub. Serv. L. Article VII.

8 The NYISO did not receive any opposition from Developers for this change during the stakeholder

process.

9 OATT, Att. Y, Section 31.4.6.5.

10 See generally, New York Indep. Sys. Operator, Inc., Request for Leave to Answer and Answer, Docket
No. ER13-102-009, at pp 9-10 (Apr. 27, 2016) (explaining that the requirement to execute a System Impact Study
Agreement or System Reliability Impact Study Agreement is “almost entirely within a Developer’s control”).

11 The Transmission Interconnection Procedures under Attachment P permit a Transmission Developer to
proceed directly to a System Impact Study at its election, skipping the feasibility study. See OATT, Att. P, Section

22. Additionally, in 2017, the NYISO proposed and the Commission accepted revisions to the Large Facility

Honorable Kimberly D. Bose December 11, 2018

Page 5

nearly the entire duration of the NYISO’s viability and sufficiency analyses to execute a study agreement.

C. Consistency of Project Information in the Interconnection Process

In order to propose a solution to a Public Policy Transmission Need, a Developer is

required to, within the 60-day solicitation window, simultaneously submit a proposed project in
the Public Policy Process and demonstrate that it has submitted a Transmission Interconnection
Application or Interconnection Request, as applicable.12 To ensure that the project information
matches in both submissions, the NYISO proposes to clarify this requirement by adding an
explicit requirement in a new Section 31.4.4.3.4 that the project description of a Transmission
Interconnection Application or Interconnection Request, as applicable, must be the same as the
project information submitted in the Public Policy Process. Specifically, the project description
in the interconnection process must contain “the same electrical characteristics, related modeling
information, and contingency information to perform all analyses, including thermal, voltage,
stability, short circuit, and transfer limit analysis” as the project proposed in the Public Policy
Process.13

Pursuant to Section 31.4.4.3, a Developer will be afforded an opportunity to take
remedial steps to satisfy this matching information requirement if the NYISO identifies a
difference between the original submissions in the Public Policy Process and the applicable
interconnection process.14 If the NYISO notifies a Developer that the project information (i.e.,
the same electrical characteristics, related modeling information, and contingency information)
does not match, the Developer has an opportunity to align the project information within 15
days.15 Importantly, a Developer will not be permitted to make modifications to the proposed
project in the Public Policy Process, which means the Developer can only make changes to the
Transmission Interconnection or Interconnection Request. If a Transmission Interconnection
Application or Interconnection Request requires revisions, the Developer must take the necessary
steps in accordance with the applicable interconnection process and inform the NYISO staff
administering the Public Policy Process. In the event that a Developer fails to satisfy this

Interconnection Procedures similarly making the feasibility study at the Developer’s option. See New York Indep.
Sys. Operator, Inc., Letter Order, Docket No. ER18-80-000 (Dec. 7, 2017); New York Indep. Sys. Operator, Inc.,
Proposed Tariff Revisions Regarding Interconnection Process Improvements, Docket No. ER18-80-000, at pp 26-30
(Oct. 16, 2017).

12 OATT, Att. Y, Section 31.4.4.3.1.

13 To ensure transparency to all Developers, the proposed language specifies the data that a Developer must
ensure is the same in both processes. See proposed OATT, Att. Y, Section 31.4.4.3.4. Given that the
interconnection process and Public Policy Process are distinct and have different aims, the Transmission
Interconnection Application does not need all of the information required to be submitted for a proposal in the
Public Policy Process. Therefore, the requirement targets only the information needed for the NYISO to evaluate
the proposed interconnection. See New York Indep. Sys. Operator, Inc., 162 FERC ¶ 61,107 at PP 32, 35-36 (2018).

14 Proposed OATT, Att. Y, Section 31.4.4.3.5.

15 OATT, Att. Y, Sections 31.4.4.3.5, 31.4.4.3.8.

Honorable Kimberly D. Bose December 11, 2018

Page 6

matching information requirement after an opportunity to correct it, the NYISO will reject the
proposed project in the Public Policy Process, disqualifying it from further consideration.16

The NYISO also proposes to clarify that a Developer may submit, at the same time as its
project information in the Public Policy Process, a revised version of a Transmission
Interconnection Application or Interconnection Request that was submitted prior to a solicitation
in the Public Policy Process. This clarification will maintain flexibility for Developers electing
to proceed with the initial interconnection evaluations of a potential project in advance of the
competitive planning process. In addition, any revisions to the Transmission Interconnection
Application or Interconnection Request must be made in accordance with the applicable
interconnection process.17

D.Refund of Interest on Study Deposits

Under the CSPP, a Developer submitting a project in either the reliability planning

process or Public Policy Process must provide a study deposit in the amount of $100,000. The

NYISO will bill the Developer on a monthly basis for the costs of the completed study work, and will use the study deposit to satisfy unpaid monthly or final invoices. Sections 31.2.6.2 and

31.4.4.4 require the NYISO to pay interest on any amount of the study deposit that is refunded to
the Developer following settlement of the final invoice at an interest rate consistent with Section

35.19a of the Commission’s Regulations (hereinafter “FERC interest rate”).

The NYISO proposes to revise Sections 31.2.6.2 and 31.4.4.4 to change the interest rate
owed on amounts refunded to a Developer from the FERC interest rate to “interest actually
earned on such deposits.” The revised language would also require the NYISO to hold the study
deposit in an interest-bearing account with the deposited amount being associated with the
Developer. The NYISO proposes these revisions because it is unable to earn interest at the
FERC interest rate. As a not-for-profit organization that derives its operating revenues from its
Market Participants, the NYISO lacks the resources to cover the difference between the FERC
interest rate and the rate that is actually earned on the deposits. The Commission has approved a
similar interest rate for refunded security deposits in the competitive transmission planning
processes of other ISOs/RTOs.18

16 Proposed OATT, Att. Y, Section 31.4.4.3.5.

17 Consistent with the Commission’s directive in the NYISO’s Order No. 1000 compliance docket, the

NYISO will not forward a new or revised Transmission Interconnection Application or Interconnection Request to a Connecting Transmission Owner, which is submitted during a solicitation window, until after the close of the 60-day period. See New York Indep. Sys. Operator, Inc., 162 FERC ¶ 61,107 at P 40; see also New York Indep. Sys.
Operator, Inc., Compliance Filing, Docket Nos. ER13-102-008, et al., at pp 4-5 (Mar. 19, 2018).

18 See, e.g., Southwest Power Pool, Inc., 149 FERC ¶ 61,048, at PP 203, 205 (2014); California Indep. Sys. Operator, 149 FERC ¶ 61,178 at P 11 (2014); Midcontinent Indep. Sys. Operator, Inc., 153 FERC ¶ 61,168, at P 83 (2015) (accepting the revision to the interest rate to be the “interest actually earned on such deposits” as proposed in MISO’s September 16, 2015 filing in Docket No. ER15-2657-000).

Honorable Kimberly D. Bose December 11, 2018

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The NYISO also proposes to change the interest rate for disputed study costs owed by a
Developer to be the interest actually earned. Currently, a Developer is required to place the
disputed amount into an escrow account until the matter is resolved.19 For any amounts that are
required to be paid after resolution of the dispute, the Developer is required to pay such amount
with interest calculated at the FERC interest rate. Changing the interest rate to the interest
actually earned on any amount found due to the NYISO will ensure consistent treatment for both
the NYISO and Developers.

E. Stakeholder Review of Transmission Project Information

Stakeholders and Developers have requested that Developers’ non-confidential project
information be made available earlier in the Public Policy Process for their review and to better
understand the NYISO staff’s calculations and analyses. The NYISO proposes to insert a new
Section 31.4.4.3.10 to provide that the NYISO will post on its website a brief description of
project proposals within five business days after the close of the solicitation window. In
addition, the NYISO proposes to insert a new Section 31.4.4.3.11 to provide that at least thirty
calendar days prior to the Viability and Sufficiency Assessment undertaken by the NYISO
pursuant to Section 31.4.6.5, the NYISO will make available, upon request, Developers’ project
proposals redacted of Confidential Information as defined in revised Section 31.4.15. The
NYISO will also make available to requestors any additional, non-confidential project
information submitted by Developers within thirty calendar days of the NYISO’s receipt of such
information. These requirements will enhance the Public Policy Process by improving its
openness and transparency while protecting project information that is defined as Confidential
Information.20

To assist with the NYISO’s efficient administration of the proposed redaction and

disclosure process, the revisions also require Developers to submit both a redacted version of their project information that does not contain Confidential Information and an un-redacted version of their project information.21 The NYISO will review the Developers’ redactions for compliance with the limited definition of Confidential Information and may make additional redactions or disclosures.22 If requested by other Developers or interested parties, the NYISO will provide the redacted version. All requestors must comply with the NYISO’s requirements for the disclosure of Critical Energy Infrastructure Information.23

19 OATT, Att. Y, Section 31.4.4.4.

20 The NYISO also proposes to modify the definition of Confidential Information in the Public Policy Process. See Part F, infra.

21 This requirement is similar to PJM’s requirement that Developers submit both redacted and unredacted versions of competitive planning process proposals. PJM INTERCONNECTION, PJM MANUAL 14F: COMPETITIVE PLANNING PROCESS (rev.02, 2018), at 27-28.

22 OATT, Att. Y, Section 31.4.15.4.

23 OATT, Att. Y, Section 31.4.15.1.

Honorable Kimberly D. Bose December 11, 2018

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F.Confidentiality

The NYISO proposes to clarify in Section 31.4.15 the definition and treatment of

Confidential Information in the Public Policy Process. As revised, Section 31.4.15.2 identifies as Confidential Information: (i) all project cost information; (ii) all details of the Developer’s
financing arrangements; (iii) any non-public financial qualification information; and (iv) any
contracts provided as part of the project information requirements. These limited categories are
consistent with the current definition of Confidential Information for proposed projects in
Section 31.4.15.2, which are preliminary cost estimates, non-public financial qualification
information, and contracts. The Commission has accepted definitions from other ISOs/RTOs
that encompass all project cost information and financing arrangements.24 Except for the above enumerated categories, all other project information may be disclosed in the stakeholder process as required by Section 31.4 of Attachment Y.

G. Clarification of Project Information Requirements

The NYISO proposes to revise Section 31.4.5.1 to clarify certain project information

requirements. Specifically, the NYISO proposes to revise certain project information categories
for Public Policy Transmission Projects in Section 31.4.5.1.1 to: (i) require a detailed major
milestone schedule and an expected In-Service Date; (ii) clarify that Developers must provide a
transmission and substation routing study or studies and a demonstration that they have or will
have the property rights necessary to implement the project; (iii) require that Developers provide
a copy of a Transmission Interconnection Application or Interconnection Request, as applicable;
(iv) request further details with respect to permitting and other project risks, including any
proposed mitigation to such risks; and (v) clarify that Developers must provide information
required by the NYISO’s procedures. These clarifications arise from discussions with
stakeholders and the NYISO’s experience in gathering and analyzing project data.

The NYISO also proposes to clarify that the only alternative that a Developer may offer to project characteristics within a single project proposal is alternative routing. Based on the NYISO’s handling of proposals for past Public Policy Transmission Needs, and stakeholder and Developer feedback, this clarification will avoid potential confusion for Developers by clearly identifying what types of alternatives are permissible within the same proposal. In doing so, the proposed revision explicitly states that alternatives other than routing require a separate project submission, application fee and study deposit.25

Further, several project information requirements are currently spread across different sections of Section 31.4. The NYISO proposes to consolidate the project information

24 See, e.g., MISO OATT, Att. FF, Section VIII.D.9 (prohibiting transmission providers from unilaterally disclosing detailed costs breakdowns and financing arrangements); PJM INTERCONNECTION, PJM MANUAL 14F: COMPETITIVE PLANNING PROCESS (rev.02, 2018), at 29-30 (permitting the redaction of proprietary information, such as detailed cost estimates and commercially sensitive practices).

25 OATT, Att. Y, Section 31.4.4.3.2.

Honorable Kimberly D. Bose December 11, 2018

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requirements applicable to Developers by relocating, without change, the capital cost estimate

requirements formerly located in Section 31.4.8.1.1 to new Section 31.4.5.1.2, and relocating the transmission and substation route planning and study requirements from Section 31.4.8.1.6 to new Section 31.4.5.1.3.

The NYISO proposes to revise Section 31.4.5.2.1 to similarly clarify the informational
requirements applicable to Other Public Policy Projects.26 Specifically, the NYISO proposes to
require certain forms of information only where such information is available for the proposed
project type and to clarify that Developers must provide information required by the NYISO’s
procedures.

H.Description of Information and Sources

In response to stakeholder and Developer requests for additional clarity concerning the basis of the NYISO’s conclusions in its planning reports, the NYISO proposes to clarify in Sections 31.4.6.5 and 31.4.11 that the Viability and Sufficiency Assessment and the Public Policy Transmission Planning Report will identify the information and sources relied upon by the NYISO in its analyses, determinations, and recommendations.

I.Revisions to Pro Forma Operating Agreement

As part of its Order No. 1000 compliance filings, the NYISO submitted a pro forma

Operating Agreement for non-incumbent transmission owners, which is located in Appendix H
(Section 31.11) of Attachment Y to the OATT. Before the Commission accepted the pro forma
Operating Agreement, the NYISO and the New York Transco, LLC (“Transco”) were required
to enter into the Operating Agreement for certain Transco facilities that were entering into
service. In the course of developing the Transco Operating Agreement, the NYISO and Transco
identified certain clarifications to the pro forma Operating Agreement. The NYISO filed and the
Commission accepted the Transco Operating Agreement with those clarifications.27
Subsequently, the NYISO and Transco submitted an amended Operating Agreement, whereby
the NYISO and Transco identified additional clarifications and clean-ups to the pro forma
Operating Agreement.28 The NYISO filed and the Commission accepted the additional
revisions.29 In both filings, the NYISO informed the Commission that it would, in a subsequent
Section 205 filing, incorporate into the pro forma Operating Agreement the clarifications and

26 As defined in Section 31.1.1 of Attachment Y to the OATT, “Other Public Policy Project” means “[a] non-transmission project or portfolio of transmission and non-transmission projects proposed by a Developer to satisfy an identified Public Policy Transmission Need.”

27 New York Indep. Sys. Operator, Inc., Letter Order, Docket No. ER16-1785-001 (Jul. 19, 2016); New York Indep. Sys. Operator, Inc., Filing of Executed Operating Agreement, Docket No. ER16-1785-000 (May 25, 2016) (“First Transco Filing”).

28 New York Indep. Sys. Operator, Inc., Filing of Executed and Amended and Restated Operating Agreement, Docket No. ER18-2015-000 (Jul. 13, 2018) (“Second Transco Filing”).

29 New York Indep. Sys. Operator, Inc., Letter Order, Docket No. ER18-2015-000 (Sep. 6, 2018).

Honorable Kimberly D. Bose December 11, 2018

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clean-ups identified in developing the Transco Operating Agreement at its next opportunity.30 Accordingly, the NYISO proposes the following revisions to Section 31.11:

• Correction of a typographical error in the Table of Contents by removing an

erroneous “s” from “Performance of Obligation by Third Parties;”

• Revision of Articles 2.09 and 3.07 of the Operating Agreement to clarify that the

parties will negotiate in good faith concerning the compliance obligations for applicable NERC functions;

• Revision of Article 2.12 of the Operating Agreement to clarify the transmission

owner’s right to assign consistent with Article 4.0;

•Clarification of language by adding the word “be” after “not” and before

“limited” in Article 2.13.c.1;

•Correction of the description of applicable agreements in Article 3.05;

•Revision of Article 3.07 to add Transmission Planner to the functions designated

by NERC; and

•Correction of a typographical error by adding “re” to the word “covered” in

Article 3.08.f.

J.Miscellaneous Revisions

To accommodate the above revisions, the NYISO has adjusted section numbering and

cross-references in various places throughout Section 31.4. In addition, the NYISO proposes to

make the following clarifications and clean-up revisions:

Tariff Section(s)

Section 31.1.8.7
Section 31.4.4.2

Section 31.4.3.1
Section 31.4.4.3

Section 31.4.4.3.2
Section 31.4.4.3.4

Section 31.4.4.3.5

Section 31.4.4.4

Reason for Modification

Made conforming changes to reflect the revisions to Section 31.4. Added a placeholder for Section 31.4.4.2 to resolve a pre-existing numbering issue.

Removed duplicative description of 60-day period already described in Section 31.4.4.3.2.

Removed “Timing for” in section header to more accurately reflect the revised provisions.

Replaced “proposed” in the past tense with “proposing.”
Removed “in response to a solicitation for a solution to a Public Policy Transmission Need identified after the 2014-2015 planning cycle” to reflect the end of the period for transition to the NYISO’s Order No. 1000 planning processes.

Clarified that project submissions that do not satisfy the revised requirements of Sections 31.4.4.3 or 31.4.4.4 within the timeframes required under Section 31.4.3.8 will be rejected.

Removed duplicative description of 60-day period already described in Section 31.4.4.3.2.

Honorable Kimberly D. Bose December 11, 2018

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Section 31.4.4.4Clarified that the requirement that Developers execute a study

agreement with the NYISO applies to each individual project proposed.

Section 31.4.4.4Clarified that the NYISO can recover its costs for work undertaken

pursuant to Section 31.4.11.

Section 31.4.5.1.1Added preamble language, “In response to the ISO’s solicitation for

solutions pursuant to Section 31.4.4.3.2.”

Section 31.4.5.1.4Clarified applicable confidentiality requirements by adding a cross-

reference to revised Section 31.4.15.

Section 31.4.5.2.1Added preamble language, “In response to the ISO’s solicitation for

solutions pursuant to Section 31.4.4.3.2.”

Section 31.4.5.2.2Clarified applicable confidentiality requirements by adding a cross-

reference to revised Section 31.4.15.

Section 31.4.6.5Clarified that the Viability and Sufficiency Assessment will be

presented to New York Department of Public Service, rather than the
NYPSC, and that the NYISO will file the final report with the NYPSC.

Section 31.4.6.5Clarified the scope of information that must be identified in the

Viability and Sufficiency Assessment.

Section 31.4.6.6Removed language concerning the disclosure of confidential

information that is no longer required due to changes to confidentiality

requirements.

Section 31.4.8.1.6Clarified evaluation metrics to align them with the revised project

information requirements.

Section 31.4.11Removed an extra space before the words “has determined under.”

Section 31.4.13Removed an extra space in the section header before “Public Policy

Transmission Projects.”

Section 31.12Made conforming revisions to the pro forma Study Agreement for

Evaluation of Public Policy Transmission Projects to reflect revisions
to Section 31.4, specifically related to the scope of the NYISO’s
evaluation of a project and the treatment of Confidential Information.

V.Proposed Effective Date

The NYISO respectfully requests that the Commission accept the proposed tariff

revisions for filing with an effective date of February 10, 2019, which is the day following the end of the statutory 60-day notice period.

VI. Requisite Stakeholder Approval

The tariff revisions proposed in this filing were discussed with stakeholders at multiple Electric System Planning Working Group meetings and were approved at the October 10, 2018, Business Issues Committee meeting, the October 11, 2018, Operating Committee meeting, and at the October 31, 2018, Management Committee meeting. On November 13, 2018, the NYISO Board of Directors approved the proposed tariff revisions for filing with the Commission,
pursuant to Section 205 of the Federal Power Act.

Honorable Kimberly D. Bose December 11, 2018

Page 12

VII. Service List

This filing will be posted on the NYISO’s website at www.nyiso.com. In addition, the
NYISO will email an electronic link to this filing 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.

VIII. Conclusion

For the foregoing reasons, the New York Independent System Operator, Inc. respectfully requests that the Commission accept the proposed tariff changes identified in this filing.

Respectfully submitted,

/s/ Carl F. Patka

Carl F. Patka

Counsel for the

New York Independent System Operator, Inc.

December 11, 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