April 19, 2011

The Honorable Kimberly D. Bose Secretary

Federal Energy Regulatory Commission 888 First Street, N.E.,

Washington, DC 20426

Re: TC Ravenswood, LLC v. New York Independent System Operator, Inc., Docket
No. EL10-70-000

Dear Secretary Bose:

Pursuant to Rule 602 of the Federal Energy Regulatory Commission’s (“FERC” or the
“Commission”) Rules of Practice and Procedure, 18 C.F.R. § 385.602 (2010), TC Ravenswood,
LLC, Consolidated Edison Company of New York, Inc., Orange and Rockland Utilities, Inc., the
New York Independent System Operator, Inc. (“NYISO”), New York Power Authority,
Consolidated Edison Solutions, Inc., Constellation NewEnergy, Inc. and Constellation Energy
Commodities Group, Inc., Astoria Generating Company, L.P., a US Power Generating
Company, Independent Power Producers of New York, Inc. and the New York State Public
Service Commission (collectively, “Parties”) hereby submit an Offer of Settlement in the above-
captioned proceeding. The Parties are not aware of any opposition to this Offer of Settlement by
interveners or other interested entities. As is noted below, the Parties are also requesting a
shortened comment period and expedited Commission action so that the Offer of Settlement may
become effective on May 1, 2011.

This Offer of Settlement is being submitted by the Parties and resolves all the issues

raised or that could have been raised in Docket No. EL10-70-000 as well as all issues related to
the compensation of TC Ravenswood for complying with the New York State Reliability
Council Rule I-R3 or Minimum Oil Burn Rule (“MOB Rule”) obligations for the period May 1,
2010 through April 30, 2011,1 pursuant to Section 4.1.9 of the NYISO Market Administration
and Control Area Services Tariff (“Services Tariff”). The Offer of Settlement also resolves
related issues for the period May 1, 2011 through April 30, 2014 thereby avoiding future
disputes. The Parties state that this filing contains copies of or references to all documents
relevant to this Offer of Settlement. Enclosed with this letter are: (a) an Explanatory Statement,

(b) the Offer of Settlement, (c) the TC Ravenswood Minimum Oil Burn Agreement, (d) clean
NYISO Services Tariff Amendments, (e) black lined NYISO Services Tariff Amendments, and

(f) a Certificate of Service.

1 Payment, if any, for April 2011 minimum oil burn compliance will be made in accordance with the existing

Section 4.1.9 of the NYISO Services Tariff and existing Westport Fuel Oil Delivery Agreement as described in the Offer of Settlement.

The Parties state that the proposed NYISO Services Tariff Amendments were voted on and approved unanimously, with abstentions, by the NYISO Management Committee on March 30, 2011 and subsequently approved by the NYISO Board of directors on April 19, 2011. As such, the proposed Services Tariff Amendments meet all of the requirements for a filing by the NYISO with the Commission pursuant to section 205 of the Federal Power Act.

A copy of this filing is being served on the Service List in the above-referenced

proceeding. The filing will also be posted on the NYISO’s website at www.nyiso.com and the
NYISO will e-mail an electronic link to this filing to each of its customers and to each
participant on its stakeholder committees. Copies are also being sent to Commission Staff that
participated in the settlement proceeding as well as Administrative Law Judge H. Peter Young.

Pursuant to Rule 602(f)(2), 18 C.F.R. § 385.602(f)(2), the date for filing initial comments on the Offer of Settlement would be May 9, 2011 and the date for filing reply comments would be May 19, 2011. However, the Parties, with the concurrence of the Commission Staff, hereby request a shortened comment period with initial comments due by April 22, 2011, and reply
comments due by April 26, 2011, provided that the Parties request waiver of reply comments if no initial comments are filed opposing or seeking to modify the Settlement. To the extent
necessary, the Parties also request waiver of any answer period that might otherwise apply to
these requests. Copies of this letter and all enclosures are being served on all persons required to be served by Rule 602(d), 18 C.F.R. § 385.602(d).

In addition, the Parties respectfully request an order approving the Offer of Settlement,
TC Ravenswood Minimum Oil Burn Agreement, and NYISO Services Tariff Amendments be
issued with an effective date of May 1, 2011. TC Ravenswood is moving forward with contracts
to be ready to provide uninterrupted and reliable service pursuant to the MOB Rule in
accordance with the Offer of Settlement and TC Ravenswood Minimum Oil Burn Agreement
commencing May 1, 2011. Accordingly, an effective date of May 1, 2011 would align with the
operational and financial commitments TC Ravenswood is making with its vendors to maintain
uninterrupted and reliable service. The NYISO will make a compliance filing in the e-tariff
system of the amendments to Section 4.1.9 of its Services Tariff on the day following the last
date for filing an application for rehearing with the Commission in accordance with Section 6.1
of this Offer of Settlement.

The Parties request that the Commission approve the Offer of Settlement, TC

Ravenswood Minimum Oil Burn Agreement, and NYISO Services Tariff Amendments without
condition or modification, as fair, reasonable and in the public interest and grant other relief that
the Commission determines is necessary to implement the Offer of Settlement, TC Ravenswood
Minimum Oil Burn Agreement, and NYISO Services Tariff Amendments as described in this
filing.