Paul A. Colbert
Associate General Counsel Regulatory Affairs
December 17, 2018
Kimberly D. Bose, Secretary
Federal Energy Regulatory
Commission 888 First Street, NE Washington, DC 20426
Re:Dockets ER18-1598-000 and EL18-77-000, Show Cause Order
Dear Secretary Bose,
In response to the Show Cause Order issued by the Federal Energy Regulatory
Commission (“Commission”) in Docket EL18-77-000 on March 15, 2018, Central
Hudson Gas & Electric Corporation (“Central Hudson”) on May 14, 2018, filed with the
Commission an amended transmission revenue requirement with an effective date of
July 1, 2018 that reflects adjustment for the Tax Cut and Jobs Act of 2017. On
November 15, 2018 Commission Staff (“Staff”) issued a deficiency letter and asked
Central Hudson to provide additional information. On behalf of Central Hudson, the
New York Independent System Operator, Inc. (“NYISO”) has submitted this letter and
amendment in response to the deficiency letter, agreeing with Staff’s proposals.1 The
revised amendments submitted with this filing represent Central Hudson’s agreement
with, and adoption of, Commission Staff’s calculated revenue requirement adjustment
and suggested effective date.2
The following attachments are included with this filing:
Attachment 1: A clean version of Section 14.1 of the NYISO OATT reflecting the tariff revisions proposed herein;
1 The NYISO is submitting this filing in the Commission’s e-Tariff system on Central Hudson’s behalf solely in its role as Tariff Administrator. The burden of demonstrating that the proposed tariff amendments are just and reasonable rests on Central Hudson, the sponsoring party. The NYISO takes no position on any substantive aspect of this filing at this time.
2 In the November 15, 2018 deficiency letter, Commission Staff estimated a revenue requirement
reduction of $1,049,067 and suggested that a proposed effective date of March 21, 2018 for the
adjustment may be more appropriate. The tariff revisions submitted herewith propose revisions to Table
1 in Section 14.1.4 of the NYISO Open Access Transmission Tariff (“OATT”) to reflect a reduction to
Central Hudson’s stated annual revenue requirement in an amount equal to the value calculated by the Commission Staff. Consistent with Commission Staff’s position, Central Hudson also proposes a March 21, 2018 effective date for the proposed tariff revisions.
