10 Krey Boulevard     Rensselaer, NY  12144

October 12, 2012

By Electronic Filing

Honorable Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE

Washington, DC 20426

Re:    New York Independent System Operator, Inc., Docket No. ER11-2547-001,
15-Minute Variable Scheduling at the PJM Interconnection, LLC Interface
Neptune Proxy Generator Bus Compliance Filing

Dear Secretary Bose:

On December 28, 2010, the New York Independent System Operator, Inc. (“NYISO”)
filed proposed tariff revisions to allow the NYISO to implement more frequent transaction
scheduling at the borders of the New York Control Area (“NYCA”), enabling system
operators to utilize transmission between New York and its neighbors more efficiently
(“December 28, 2010 Filing”).  In accordance with the Commission’s March 14, 2011, Order
Conditionally Accepting Proposed Tariff Revisions and Granting Waiver1 the NYISO
submitted a compliance filing on April 13, 2011 (“April 13, 2011 Filing”), which was
accepted by the Commission in a letter order dated July 21, 2011 (“July 21, 2011 Order”).

The April 13, 2011 Filing included proposed Tariff2 changes specifying each NYCA
Proxy Generator Bus3 and identifying the scheduling frequencies available for Transactions at
each of the Proxy Generator Buses.  The April 13, 2011 Filing included an advisory timetable
for the phased implementation of variable scheduling at those Proxy Generator Buses.  In its

1 New York Independent System Operator, Inc., 134 FERC ¶ 61,186 (2011).

2 Capitalized terms not specifically defined herein have the meaning set forth in the NYISO’s Market Administration and Control Area Services Tariff (“Services Tariff”) or in its Open Access Transmission Tariff (“OATT”).

3 Each “Proxy Generator Bus,” as that term is defined in the NYISO’s Tariffs, is reflected in the NYISO’s software, and in the compliance revisions submitted herewith, as a twinned pair of an import (gen) and export (load) bus.

Kimberly D. Bose, Secretary October 12, 2012

Page 2

April 13, 2011 Filing the NYISO committed to submit a compliance filing prior to

implementation of variable scheduling at a Proxy Generator Bus and to notify Market

Participants of the availability of this feature as the implementation plan progressed.  As

anticipated in the April 13, 2011 Filing, PJM Interconnection, LLC (“PJM”) has confirmed that it is prepared to proceed with 15-minute variable scheduling at the Neptune Proxy
Generator Bus.

Consistent with the NYISO’s April 13, 2011 Filing and the Commission’s

July 21, 2011 Order, the NYISO is hereby notifying the Commission and Market Participants
that the NYISO and PJM intend to implement 15-minute variable scheduling at the Neptune
Proxy Generator Bus on October 30, 2012.  The Tariff changes submitted with this
compliance filing, to become effective with the October 30, 2012 implementation, update the
table in Market Services Tariff Section 4.4.4 accepted by the Commission’s July 21, 2011
Order.  This updated table specifically provides that ‘variably scheduled’ will be an available
scheduling frequency in addition to ‘hourly scheduled’ for the Neptune Proxy Generator Bus.

Also, in accordance with the commitments made in the April 13, 2011 Filing, the

NYISO hereby provides two weeks notice of its proposal to “go live” with 15-minute variable scheduling on October 30, 2012 at the Neptune Proxy Generator Bus.

The timing of the NYISO’s implementation of 15-minute variable scheduling could be impacted by system conditions.  If the NYISO determines operating conditions are not
favorable for implementation of 15-minute variable scheduling at the Neptune Proxy
Generator Bus, it will notify the Commission and Market Participants as soon as practicable. The NYISO will include a revised “go live” date with any such notification.

I.DOCUMENTS SUBMITTED

1.This filing letter;

2.A clean version of the proposed revisions to the NYISO’s Services Tariff

(“Attachment I”); and

3.A black lined version of the proposed revisions to the NYISO’s Services Tariff

(“Attachment II”).

II.SERVICE LIST

The NYISO will send an electronic copy of this filing to the official representative of
each party to this proceeding, the New York Public Service Commission, and the New Jersey
Board of Public Utilities.  The NYISO will send an electronic link to this filing to the official
representative of each of its customers and to each participant on its stakeholder committees.
In addition, the complete public version of this filing will be posted on the NYISO’s website
at www.nyiso.com.

III.CONCLUSION

Kimberly D. Bose, Secretary October 12, 2012

Page 3

The NYISO respectfully submits this compliance filing, consistent with the

April 13, 2011 Filing and July 21, 2011 Order, to notify the Commission that the NYISO

intends to implement 15-minute variable scheduling at the PJM Neptune Proxy Generator Bus on October 30, 2012, as reflected in Market Services Tariff Section 4.4.4.

Respectfully submitted,

/s/  James H. Sweeney

James H. Sweeney

New York Independent System Operator, Inc.

cc:Travis Allen

Michael Bardee

Gregory Berson

Anna Cochrane

Jignasa Gadani

Morris Margolis

Michael McLaughlin
Joseph McClelland
Daniel Nowak

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 12th day of October, 2012

/s/ Mohsana Akter

Mohsana Akter

Regulatory Affairs

New York Independent System Operator, Inc.

10 Krey Blvd.

Rensselaer, NY 12144 (518) 356-7560