10 Krey Boulevard     Rensselaer, NY  12144

May 9, 2011

By Electronic Delivery

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

Washington, DC 20426

Re:    Compliance Filing of the New York Independent System Operator, Inc. in
Docket No. ER11-2842-000

Dear Secretary Bose:

Pursuant to the Federal Energy Regulatory Commission’s (“Commission”) April 8, 2011 Order On Tariff Revisions (“April 8 Order”)1 in this proceeding, the New York Independent System Operator, Inc. (“NYISO”) respectfully submits this compliance filing.

I.Documents Submitted

1.This filing letter;

2.A clean version of the proposed compliance revisions to the NYISO’s Open

Access Transmission Tariff (“OATT”) (“Attachment I”); and

3.A blacklined version of the proposed revisions to the NYISO’s OATT

(“Attachment II”).

II.Background

On February 7, 2011, the NYISO submitted in this proceeding proposed revisions to its
Standard Large Facility Interconnection Procedures2 contained in Attachment X to the NYISO
OATT (“Attachment X”) and also proposed revisions to the Small Generator Interconnection
Procedures contained in Attachment Z to the NYISO OATT (“Attachment Z”) (“February 7
Filing”).  The Commission accepted the proposed revisions to Attachments X and Z with an
effective date of March 1, 2011, subject to a compliance filing, as discussed below.

1 New York Independent System Operator, Inc., 135 FERC ¶51,014 (2011).

2 Capitalized terms not otherwise defined in this letter have the meaning set forth in Attachments S, X and Z of the NYISO’s Open Access Transmission Tariff (“OATT”).

Honorable Kimberly D. Bose, Secretary May 9, 2011

Page 2

The modifications accepted in the Commission in its April 8, 2011 Order revise

Attachment X to more equitably allocate the study costs from the Class Year Interconnection
Facilities Study (“Class Year Study”) among the projects comprising a Class Year group of
projects electing to be evaluated for Energy Resource Interconnection Service (“ERIS”).3  The
modifications also revise Attachment Z as to limit the circumstances under which a Small
Generating Facility is required to enter a Class Year Study and thereby incur additional Class
Year Study costs.

The Commission accepted the proposed modifications and proposed effective date,

noting, however, that “NYISO’s intent that they apply to Class Years beginning with Class Year
2011 is only expressly reflected in Tariff language in section 30.13.3.1.”  The Commission
therefore ordered the NYISO to submit a compliance filing with revised Tariff records for each
of the other proposed revisions to reflect that the proposed revisions apply to Class Year 2011
and later.

III. Description of the Proposed Revisions

As the Commission noted in its April 8 Order, the NYISO intends for these proposed

tariff revisions to be effective starting with Class Year 2011, but only one of the  tariff sections, as revised, states this expressly - Attachment X, Section 30.13.3.1.  Pursuant to the
Commission’s April 8 Order, the NYISO hereby submits revised tariff language to reflect that the proposed revisions to Attachment Z apply to Class Year 2011 and later.

Specifically, the NYISO proposes to revise Section 32.3.5.3.2 of Attachment Z by adding the following language:  “The standard described above in this Section regarding when a Small Generating Facility must enter a Class Year will apply to Small Generating Facilities being
considered for entry into Class Year 2011 and beyond.”

Additional modifications included in the NYISO’s February 7 Filing were merely crossreferences to the above-mentioned Sections and, in both Attachment X and Attachment Z, the addition of a definition for the term, “Local System Upgrade Facilities.”  The NYISO proposes not to duplicate the Class Year 2011 reference in each of those provisions.

3 The NYISO offers two levels of interconnection service under its OATT:  Energy Resource Interconnection

Service (“ERIS”) and Capacity Resource Interconnection Service (“CRIS”).  ERIS is the service provided by

NYISO to interconnect the Generating Facility or Merchant Transmission Facility to the New York State

Transmission System in accordance with the NYISO Minimum Interconnection Standard, to enable the New York State Transmission System to receive Energy and Ancillary Services from the Generating Facility or Merchant Transmission Facility, pursuant to the terms of the NYISO OATT.

Honorable Kimberly D. Bose, Secretary May 9, 2011

Page 3

V.Requested Effective Date

Pursuant to the Commission’s April 8, 2011 Order, the NYISO requests an effective date of March 1, 2011.

VI.Service

Copies of this filing are being served on all parties designated on the official service list
maintained by the Secretary of the Commission in this proceeding.  The NYISO will also send
an electronic link to this filing to the official representative of 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.  In addition, the complete filing will be posted on the
NYISO’s website at www.nyiso.com.

Respectfully submitted,

/s/ Sara B. Keegan

Sara Branch Keegan
Senior Attorney

New York Independent System Operator, Inc.

10 Krey Blvd.

Rensselaer, New York 12144 (518) 356-8554

skeegan@nyiso.com