UNITED STATES OF AMERICA
BEFORE THE

FEDERAL ENERGY REGULATORY COMMISSION

PJM Interconnection, L.L.C.)Docket No. ER12-718-002

PJM INTERCONNECTION, L.L.C. AND

NEW YORK INDEPENDENT SYSTEM OPERATOR, INC. PETITION
FOR EXTENSION OF LIMITED TARIFF WAIVER,

SHORTENED COMMENT PERIOD,

AND EXPEDITED COMMISSION ACTION

Pursuant to Rule 207(a)(5) of the Federal Energy Regulatory Commission

(“Commission” or “FERC”) Rules of Practice and Procedure, 18 C.F.R. § 385.207(a)(5),
PJM Interconnection, L.L.C. (“PJM”) and New York Independent System Operator, Inc.
(“NYISO”) (collectively, the “RTOs”) respectfully request an extension until August 15,
2013 of the temporary, limited waiver of sections 7 and 10 of Schedule D (Market-to-
Market Coordination Process) to the Joint Operating Agreement Among and Between
NYISO and PJM (“JOA”) (and any other relevant provisions of the JOA) that was
granted in a Letter Order issued on January 14, 2013 in the above Docket.1 The
previously approved limited Tariff waiver permits the RTOs to temporarily suspend
market-to-market coordination and settlement under the following two scenarios: (1) the
data link between the RTOs fails precluding the exchange of data necessary to implement
the market-to-market coordination process; or (2) either RTO’s energy management

1 PJM Interconnection, L.L.C. and New York Independent System Operator, Inc., 142 FERC ¶ 61,026
(2013).

system (“EMS”)2 or real-time security constrained economic dispatch (“RTD”), fails
rendering impossible the creation of data necessary for market-to-market coordination.

I. REQUEST FOR EXTENSION OF WAIVER PERIOD

The RTOs December 24, 2012 joint filing explained why it is appropriate to
temporarily suspend market-to-market coordination and settlement when: (1) the data
link between the RTOs fails precluding the exchange of data necessary to implement the
market-to-market coordination process; or (2) either RTO’s EMS or RTD, fails rendering
impossible the creation of data necessary for market-to-market coordination. Acting
pursuant to delegated authority, the Secretary’s office accepted the RTOs explanation of
the need for a limited Tariff waiver and granted the requested limited tariff waiver on
January 14, 2013.3

The RTOs respectfully request that the end date of the limited waiver period be
extended from June 30, 2013 to August 15, 2013. The RTOs have been working
diligently to develop and file with the Commission the JOA clarifications necessary to
temporarily suspend market-to-market coordination and settlement in the two scenarios
that the RTOs explained in their December 24, 2012 joint filing. In addition, the RTOs
have been working to develop and review with stakeholders other mutually agreed upon
clarifications of the market-to-market coordination rules. The NYISO will not be able to
complete its Tariff review process in time to obtain a required Board of Directors
(“Board”) approval until the NYISO Board’s June meeting. The requested extension of
the waiver to August 15, 2013 will permit the RTOs to submit their proposed Tariff

2 The EMS includes real-time telemetry, contingency and state estimator functions.

3 See n. 1, supra.

revisions before June 15, 2013, so that the Commission will have a full 60 days to review the proposed Tariff revisions before it acts on the RTOs’ proposal.

II. REQUEST FOR SHORTENED NOTICE PERIOD AND FOR

COMMISSION ACTION BY JANUARY 14, 2013

The RTOs respectfully request that the Commission grant this temporary waiver
request by no later than May 31, 2013. To meet this expedited schedule, the RTOs
respectfully request that the Commission immediately issue notice of their waiver request
and provide, in accordance with its Rule 210(b),4 for a shortened comment period of
seven days. Expedited action is necessary because effective July 1, 2013, in the absence
of the requested waiver, the RTOs will be required under the JOA to conduct market-to-
market coordination during emergency data system outages where such outages preclude
the creation and exchange of data necessary to implement market-to-market coordination.

III.CONCLUSION

For the reasons stated above, PJM and NYISO request that the Commission grant
an expedited extension of the temporary waiver that was granted by Letter Order on
January 14, 2013 in the above Docket. The RTOs request that the waiver period be
extended to August 15, 2013. The RTOs propose to submit their clarifying Tariff
revisions before June 15, 2013, with a requested effective date of August 16, 2013 (the

4 18 C.F.R. § 385.210(b).

day after the conclusion of the requested waiver period). The RTOs further request that the Commission provide for a shortened comment period and rule on this request on or before May 31, 2013.

Respectfully submitted,

/s/ James M. Burlew

James M. Burlew
Steven R. Pincus

Attorneys for PJM Interconnection, L.L.C. 955 Jefferson Avenue

Norristown, PA 19403
(610) 666-4370 (phone)
(610) 666-8211 (fax)

/s/ Alex M. Schnell

Alex M. Schnell

James Sweeney, Attorney

10 Krey Boulevard

Rensselaer, NY 12144
(518) 356-8707 (phone)
(518) 356-7678 (fax)

New York Independent System Operator, Inc.

Dated: April 23, 2013

CERTIFICATE OF SERVICE

I hereby certify that I this day served the foregoing document upon each person designated on the official service list compiled by the Secretary in this proceeding.
Dated at Rensselaer, New York this 23rd day of April 2013.

/s/ Alex M. Schnell

Alex M. Schnell

New York Independent System Operator, Inc.

10 Krey Boulevard

Rensselaer, NY 12144 518-356-6000