Request for Abeyance of the New York Transmission Owners and Request for Expedited Commission Action and Shortened Comment Period
Topics in the text: Filing procedure · Cost allocation · Reliability and curtailment
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Opening text
opening text · Topic match: Filing procedure
In this case, the Commission did not name NYPA and LIPA as parties in the Show Cause Order and therefore they are not filing parties to this abeyance request.Read this passage
I. BACKGROUND
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I.Read this passage
BACKGROUND
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BACKGROUNDRead this passage
A. The Show Cause Order
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Specifically, the Show Cause Order states that: The Commission will consider requests for abeyance of up to 90 days; The abeyance period will begin as of the deadline to respond to the Show Cause Order (August 17, 2026); Abeyance requests must be submitted within 45 days of the issuance of…Read this passage
B. The NYTOs’ Independent Filing Rights Under the NYISO-TO Agreement
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The NYTOs’ Independent Filing Rights Under the NYISO-TO Agreement The NYTOs file this request independently from the NYISO, in accordance with the rights explicitly reserved in section 3.10(a) of the NYISO-TO Agreement.19 Section 3.10(a) provides, in relevant part, that: Each Transmission Owner…Read this passage
II. REQUEST FOR ABEYANCE
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REQUEST FOR ABEYANCE The NYTOs respectfully submit this request for a full 90-day abeyance of the above- captioned show cause proceeding.Read this passage
III. DESCRIPTION OF ANTICIPATED FPA SECTION 205 FILING
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DESCRIPTION OF ANTICIPATED FPA SECTION 205 FILING Consistent with the Show Cause Order’s requirement that a successful abeyance request include a robust description of the content of any anticipated FPA section 205 filing, the NYTOs provide the following description of the Tariff revisions they…Read this passage
A. Cost Recovery and Transmission Service Charges
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Network Upgrade Cost Recovery The Commission preliminarily found in the Show Cause Order that the NYISO Tariff appears unjust and unreasonable because it lacks adequate mechanisms to mitigate the risk of cost shifting among transmission customers.Read this passage
B. Large Load Interconnection Procedures and Agreements
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Large Load Interconnection Procedures and Agreements The Commission preliminarily found in the Show Cause Order that the NYISO and/or NYTOs should modify the NYISO OATT and/or agreements to address: the scope and timing of interconnection studies, including the Facilities Studies; 46 the evaluation…Read this passage
C. Operating Terms Applicable to Non-Firm Transmission Withdrawal Service
printed heading · Topic match: Connecting load and generation
With potentially large increases in the amount of new large loads on the system, and new non-firm or contract demand services, new operating requirements will be needed, as the Commission recognizes.58 The NYTOs will coordinate with the NYISO to develop operating requirements for loads that have…Read this passage
IV. REQUEST FOR EXPEDITED COMMISSION ACTION AND SHORTENED
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REQUEST FOR EXPEDITED COMMISSION ACTION AND SHORTENED COMMENT PERIOD The NYTOs respectfully request that the Commission act on this request on or before August 13, 2026, to provide the NYTOs with certainty regarding the need to file a response to the Show Cause Order and to allow the NYTOs to focus…Read this passage
V. COMMUNICATIONS
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COMMUNICATIONS All communications and correspondence regarding this filing should be forwarded to the following individuals, whose names should be placed on the Commission’s service list:61 60 18 C.F.R. § 385.213(d)(1)(i) (“If a motion requests an extension of time or a shortened time period for…Read this passage
C. Dixon Wallace III
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Douglas TROUTMAN PEPPER LOCKE LLP 401 9th Street NW, Suite 1000 Washington, DC 20004 (202) 274-2886 william.derasmo@troutman.com dixon.wallace@troutman.com antonia.douglas@troutman.com Marina Chu Regulatory Attorney – Regulatory Affairs Central Hudson Gas & Electric Corporation 284 South Avenue…Read this passage
VI. CONCLUSION
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VI.Read this passage
CONCLUSION
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Derasmo William R.Read this passage
C. Dixon Wallace III
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Douglas TROUTMAN PEPPER LOCKE LLP Counsel to the New York Transmission Owners /s/ Marina Chu Marina Chu Central Hudson Gas & Electric Corporation /s/ Phillip D.Read this passage
CERTIFICATE OF SERVICE
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Bascus FERC Energy Specialist TROUTMAN PEPPER LOCKE LLP 401 9th Street NW, Suite 1000 Washington, DC 20004 (202) 274-1949 daryl.bascus@troutman.comRead this passage