EL26-69-000 · 2026-08-03 · New York Independent System Operator, Inc.

NYISO requests more time to answer the June 18 show cause order

UNITED STATES OF AMERICA 
BEFORE THE 
FEDERAL ENERGY REGULATORY COMMISSION 
 
 
 
                   ) 
 
 
New York Independent System Operator, Inc. 
       )        
Docket No. EL26-69-000 
 
 
                   ) 
 
 
 
MOTION FOR ABEYANCE OF THE NEW YORK INDEPENDENT SYSTEM 
OPERATOR, INC., REQUEST FOR SHORTENED COMMENT PERIOD  
AND REQUEST FOR EXPEDITED ACTION  
 
 
In accordance with Rule 212 of the Rules of Practice and Procedure of the Federal 
Energy Regulatory Commission (“Commission”), the New York Independent System Operator, 
Inc. (“NYISO”) submits this motion in response to the Commission’s June 18, 2026 order, in the 
above-captioned docket.1  That order directed the NYISO to show cause by August 17, 2026, 
why the existing NYISO Tariffs2 remain just and reasonable and not unduly discriminatory 
without modifications related to transmission and interconnection services for large loads 
(“Show Cause Order” or “Order”).  The NYISO respectfully requests that the Commission hold 
this proceeding in abeyance for the maximum period permitted by the Show Cause Order, i.e., 
for 90 days, until November 16, 2026.  Granting abeyance would enable the NYISO to pursue a 
Federal Power Act (“FPA”) section 2053 filing through the NYISO’s governance process to 
address the issues raised in the Order.4  The requested abeyance will also allow the NYISO to 
coordinate with the transmission owning Commission-jurisdictional utilities in New York State 
(the “New York TOs”) regarding any issues that may be subject to their reserved section 205 
 
1 N.Y. Indep. Sys. Operator, Inc., 195 FERC ¶ 61,216 (2026). 
2 The Show Cause Order used the term “NYISO Tariff” to refer to the NYISO’s Open Access Transmission 
Tariff. (“OATT”).  However, the issues raised by the Show Cause Order, and the reforms that the NYISO intends to 
propose in response to it, also implicate the NYISO’s Market Administration and Control Area Services Tariff. In 
this motion, the NYISO uses the term “NYISO Tariffs” to refer to both documents.  
3 16 U.S.C. § 824d. 
4 See Show Cause Order, 195 FERC ¶ 61,216 at P 42 (discussing requests for abeyance).

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filing rights.5  As the Order states, the NYISO and/or the New York TOs “may elect to address 
some or all of the issues discussed in this order by proposing revisions to the Tariff pursuant to 
their applicable FPA section 205 filing rights.  We strongly encourage this.”6 
The NYISO respectfully requests that the Commission act on this motion by August 13, 
2026, to provide the NYISO with regulatory certainty.  Without an abeyance, the NYISO’s 
response to the Show Cause Order would be due on August 17, 2026.  Consistent with the 
Commission’s procedural rules and the need for expedited action, the NYISO respectfully 
requests that the Commission limit the answer period to five calendar days.7 
I. 
Background 
The Commission has determined that there are “a host of urgent challenges associated 
with providing the transmission service needed to serve the ongoing influx of large loads while 
 
5 The Show Cause Order states that it will “consider [abeyance] requests from NYISO and/or the 
Transmission Owners.” Id.  The NYISO believes that if the Commission grants the NYISO’s request for a 90-day 
abeyance of all of the Show Cause Order’s requirements then such an abeyance could also encompass any issues for 
which the New York TOs may have a filing obligation.  The NYISO understands that the New York TOs are 
concurrently filing their own request for abeyance.  The NYISO welcomes and shares the New York TOs’ 
commitment to coordinate with the NYISO in an expedited effort to address the Show Cause Order’s directives.  
However, the NYISO is not yet prepared to take a position on any of the specific assertions in the New York TOs’ 
abeyance request. 
6 Show Cause Order, 195 FERC ¶ 61,216 at P 41; see also id. at P 8 (Swett, Chairman, concurring) (“To be 
clear, we very much encourage 205 submissions encapsulating the principles we articulate in the 206s, and with all 
due deliberate haste.”); id. at P 16 (Rosner, Comm’r, concurring) (“As a potential next step, today’s orders invite 
RTO/ISOs to respond by submitting proposals under FPA section 205. I cannot encourage this enough.”); id. at P 4 
(See, Comm’r, concurring) (“Recognizing the value in region-specific approaches, we are directing individual action 
in each of the RTO/ISO regions and encouraging—strongly—proposals under section 205 of the Federal Power Act 
from transmission providers or other entities that are molded to their unique system needs.”); id. at P 3 (Chang, 
Comm’r, concurring) (“The Commission also invites each region to submit FPA section 205 filings that can address 
each issue identified in the orders, thereby resolving the Commission’s concerns.”); id. at P 5 (LaCerte, Comm’r, 
concurring) (“By inviting you to proceed under FPA section 205, we are giving you significant perks: the benefits of 
first wielder of the pen and the relatively capacious standard under FPA section 205 that allows us to accept a 
potentially broad range of proposals provided they are shown to be just and reasonable and not unduly 
discriminatory or preferential.”). 
7 See 18 C.F.R. § 385.213(d)(1)(i) (“If a motion requests an extension of time or a shortened time period for 
action, then answers to the motion to extend or shorten the time period shall be made within 5 days after the motion 
is filed, unless otherwise ordered.”).

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maintaining reliability and affordability.”8  It therefore issued show cause orders to each of the 
six jurisdictional Independent System Operators and Regional Transmission Organizations 
(“ISOs/RTOs”) and the jurisdictional transmission owners in their regions.  As it did for each 
ISO/RTO, the Commission instituted this proceeding pursuant to section 206 of the FPA.  It has 
directed the NYISO9 and, to the extent applicable, the New York TOs, within 60 days, to either 
(1) show cause as to why the NYISO Tariffs remain just and reasonable and not unduly 
discriminatory or preferential without various changes pertaining to large loads and co-located 
arrangements or (2) explain what changes to the NYISO Tariffs would remedy the identified 
concerns if the Commission were to determine that the NYISO Tariffs have become unjust and 
unreasonable and to establish a replacement rate.10   
The Commission expressed concerns that large loads are not efficiently integrated onto 
the transmission system; present a number of unique operational and reliability challenges; and 
create questions as to how to ensure that the rates, terms, and conditions of transmission service 
remain just and reasonable.11  The Commission called for reforms to expedite large load 
interconnection, establish efficient transmission service application and study processes, prevent 
cost-shifting and increase transparency, accommodate co-location agreements and behind-the-
meter generation, potentially create new transmission services for flexible large loads, and 
institute a process for studying generating facilities that serve electrically proximate and co-
 
8 Show Cause Order, 195 FERC ¶ 61,216 at P 1. 
9 The Show Cause Order also directed the NYISO to submit, within 30 days an informational report 
describing how the NYISO intends to ensure that adequate generation will be available to serve existing and new large 
loads. Id. at P 39.  The NYISO submitted its informational report on July 20, 2026.  
10 Id. at P 3.  
11 Id.

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located large loads.12  In particular, the Commission: (i) recognized that the NYISO has an 
existing load interconnection process but expressed concern that its procedures are only partially 
set forth in the NYISO Tariffs;13 (ii) preliminarily found that the NYISO Tariffs lack sufficiently 
clear and consistent provisions establishing the application process and study procedures that 
will be used for large loads while indicating that the “NYISO may [] elect to propose Tariff 
revisions establishing such an application process, fee, and requirements[,];”14 and (iii) directed 
the NYISO to explain whether the NYISO Tariffs remain just and reasonable even though they 
allow “netting of behind the meter generation from gross load for purposes of determining 
Transmission Service Charges for Host Loads configured in a Behind-the-Meter Net Generation 
(“BTM:NG”) Resource arrangement or propose Tariff revisions.”15 
The Show Cause Order, and each of the Commissioners, strongly endorsed the 
submission of section 205 filings as a more effective means of addressing the issues raised in the 
Show Cause Order,16 and recognized that additional time may be needed to do so.17  The 
Commission accordingly stated that it would consider a request from the NYISO to hold, for up 
to 90 days, all or certain aspects of this proceeding in abeyance, while the NYISO works through 
the stakeholder processes to develop a section 205 filing.18   The Show Cause Order emphasized 
that a successful abeyance request should “include both (1) a robust description of the content of 
 
12 See News Release, FERC, FERC Launches Aggressive Targeted Action to Speed Large Load Integration 
(Jun. 18, 2026), https://www.ferc.gov/news-events/news/ferc-launches-aggressive-targeted-action-speed-large-load-
integration. 
13 Show Cause Order, 195 FERC ¶ 61,216 at P 64. 
14 Id. at P 65. 
15 Id. at P 110. 
16 See supra at n. 6.  
17 See Show Cause Order at P 42. 
18 Id.

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a potential future filing under FPA section 205 and (2) a reasoned and specific explanation of 
when such a filing is expected to be made.”19  The following sections address these directives. 
II. 
The NYISO Should Be Granted a 90-Day Abeyance to Pursue a Section 205 Filing 
Through Its Shared Governance Process to Address the Show Cause Order in a 
Manner Tailored to the NYISO Region 
The NYISO recognizes that the concerns raised in the Show Cause Order are critically 
important and must be of the utmost priority.  The NYISO has determined that a number of its 
existing Tariff provisions and related rules should be expanded or clarified to address the Show 
Cause Order’s preliminary findings.  However, the NYISO believes that the best approach is to 
engage the NYISO’s stakeholder process and pursue a FPA section 205 filing to address these 
issues, rather than through making narrative responses to section 206 compliance directives.  An 
abeyance is justified in the NYISO’s case for the reasons described below. 
First, this proceeding involves numerous, complex, and consequential issues.  The 
NYISO is working diligently to formulate a comprehensive section 205 proposal to address them 
in a manner that recognizes New York’s regional differences.  This includes developing a load 
integration process that builds on the existing division of responsibilities between the NYISO 
and the New York TOs.20  Granting the requested abeyance will give the NYISO time to more 
fully respond to the Show Cause Order’s many directives with the benefit of stakeholders’ 
perspectives and expertise.  Incorporating that input will minimize disagreements and narrow the 
scope of any future litigation.  Thus, instead of delaying the introduction of enhancements, an 
abeyance would likely lead to them being adopted and implemented more expeditiously.      
 
19 Id. 
20 See Show Cause Order at P 58 (confirming that the Commission does not seek to alter the allocation of 
rights and responsibilities between the NYISO and the New York TOs).

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The NYISO has already made progress towards developing rules and procedures that 
advance and better effect the integration of large loads.  An abeyance would afford the NYISO a 
reasonable opportunity to finish its work.  The NYISO’s efforts began before the issuance of the 
Show Cause Order.  In February 2026, the NYISO shared information regarding its “Reliability 
Planning & Large Load Integration” project to “improve the current load interconnection process 
to further address bulk system reliability concerns and speed up the overall load interconnection 
process to provide solutions for the unique issues presented by these types of large load projects 
and accelerated timelines for project development and in-service dates.”21  Furthermore, 
beginning in February 2026, the NYISO made stakeholder presentations regarding its “Flexible 
Load Models – Large Loads” and “DER Market Enhancements” projects which sought to 
“incentivize large loads to participate in NYISO’s markets as flexible Resources”22 and to 
improve market access to “animate load in the NYISO markets,”23 respectively.  At that time, the 
NYISO planned to make a section 205 filing by the end of 2026.   
The NYISO has already built on its earlier work to develop an extensive proposal to 
address the expanded set of issues raised by the Show Cause Order.  The NYISO presented an 
overview of its evolving post-Show Cause Order proposals at the July 23, 2026 meeting of its 
Electric System Planning Working Group (“ESPWG”), Transmission Planning Advisory 
 
21 See NYISO, TPAS/ESPWG, Load Interconnection Process: Challenges and Considerations Slide 3 
(Feb. 3, 2026), https://www.nyiso.com/documents/20142/56802634/04_Load_interconnection_reform_2-3-
26_TPAS_final.pdf/063ff31f-a5ad-0494-707d-3275f007d23a. 
22 See, e.g., NYISO, ICAPWG/MIWG, Flexible Load Models – Large Loads Slide 6 (Feb. 24, 2026), 
https://www.nyiso.com/documents/20142/57218179/flexible%20large%20loads%20022426%20icap.pdf/8ec9d774-
a5ce-eae2-93e2-ddc298f07781 (highlighting the importance of three inter-related large load project efforts – 
Reliability Planning and Large Load Integration, Flexible Load Models – Large Loads, and DER Market 
Enhancements projects). 
23 See, e.g., NYISO, ICAPWG/MIWG, DER Market Enhancements Slide 4 (Feb. 24, 2026), 
https://www.nyiso.com/documents/20142/57218179/DER%20Market%20Enhancements%20kick%20off_021726%
20ICAPWG_MIWG_final.pdf/c3c77fa7-f00a-7b5f-fe1d-598d2b466071.

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Subcommittee (“TPAS”), and Installed Capacity Working Group (“ICAPWG”) (“July 23 
Stakeholder Presentation”).  A link to the July 23 Stakeholder Presentation is provided for 
informational purposes.24  The proposals described therein are preliminary and will continue to 
develop.  Nevertheless, the July 23 Stakeholder Presentation demonstrates the substantial 
progress that has been made to date.   
As the presentation describes, the NYISO plans to create a new large load study process 
that would replace and improve upon its existing load interconnection rules.  The NYISO and 
New York TOs would collaborate to complete large load integration studies within expedited 
time periods.  The NYISO would make firm and non-firm variants of its existing financial 
reservation transmission service available to transmission customers serving large loads subject 
to certain necessary transmission security and resource adequacy requirements.  This approach 
would, for example, make large loads eligible to take non-firm withdrawal service to the extent 
their ability to be flexible mitigates their impact on the system.   
The NYISO also presented a framework for and will develop detailed NYISO Tariff 
provisions governing or addressing co-located load arrangements, the treatment of proximate 
generators, operating requirements, the Commission’s cost-shifting and transparency concerns, 
and a host of other related market design matters.  For example, for co-located load 
arrangements, the NYISO intends to propose sunsetting its BTM:NG program and replacing it 
with a new co-located resource participation model that treats load and generation as separate 
 
24 A link to the July 23 ESPWG /TPAS presentation, updated on July 29 to include minor corrections, is 
posted at: 
https://www.nyiso.com/documents/20142/58620525/04_FERC%20Large%20Load%20Show%20Cause%20Order%
20-%20ESPWG.pdf/3b66b965-05ad-51e6-a4c5-c9846eeada4c.

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and distinct market entities.25  And the NYISO will adopt transition rules to avoid disrupting 
existing commercial arrangements.    
Second, the abeyance will allow the NYISO to structure and refine its proposals in a 
manner that preserves the long-standing independent entity variations that have benefited the 
NYISO region.  Granting an abeyance will facilitate leveraging the NYISO’s “financial” 
reservation transmission service model to maximize the benefits to flexible large loads and other 
customers.  For example, the NYISO’s firm reservation transmission service enables 
transmission customers to benefit from the use of the system in the same manner as pro forma 
Network Integration Transmission Service without the restrictions associated with traditional 
Network Load or Network Resource designations.26  In addition, the NYISO does not require, or 
accept, physical transmission reservations for internal transactions.  The Commission has 
frequently recognized that the NYISO’s use of this model, along with other regional differences, 
are just and reasonable under the “consistent with or superior to” and “independent entity 
variation” standards.27  The NYISO strongly believes that its financial reservation model 
 
25 See July 23 Presentation at Slide 77. 
26 See, e.g., Cent. Hudson Gas & Elec. Corp. et al. Compliance Filing vol. 1, Docket No. ER97-1523-000, 
at 27-28 (filed Apr. 30, 1999).  The transmission service offered by the NYISO is fundamentally similar to that 
provided by the California Independent System Operator Corporation (“CAISO”).  The Commission’s Show Cause 
Order for the CAISO acknowledged that it “does not offer traditional Order No. 888 network and point-to-point 
transmission services, offers no firm, long-term transmission reservations of capacity, and does not provide a formal 
application process for transmission service.” Cal. Indep. Sys. Operator Corp., 195 FERC ¶ 61,214 at P 19 (2026).   
27 See, e.g., N.Y. Indep. Sys. Operator, Inc., 195 FERC ¶ 61,028, at P 29 (2026) (finding “that NYISO’s 
proposed revisions are consistent with or superior to the pro forma OATT” in connection with new market rules for 
operations, scheduling, and management of transmission service for the Champlain Hudson Power Express Merchant 
Transmission Facility); N.Y. Indep. Sys. Operator, Inc., 183 FERC ¶ 61,036, at P 12 (2023) (“[W]e find that NYISO’s 
proposed definition is consistent with or superior to the pro forma OATT Attachment M Transmission Line Rating 
definition.”); N.Y. Indep. Sys. Operator, Inc., 148 FERC ¶ 61,181, at P 9 (2014) (accepting NYISO’s proposal as 
“consistent with or superior to the language specified in Order No. 784); N.Y. Indep. Sys. Operator, Inc., 146 FERC ¶ 
61,208, at PP 19, 31 (2014) (finding NYISO’s proposed tariff revisions as meeting both the “consistent with or superior 
to” and “independent entity variation” standards for tariff revisions to comply with the requirements of Order No. 
764); N.Y. Indep. Sys. Operator, Inc., 125 FERC ¶ 61,274, at P 13 (2008) (recognizing “that NYISO’s proposed 
deviations from the pro forma OATT reflect the actual market design used by NYISO, and find the deviations to be 
consistent with or superior to the pro forma OATT” in connection with NYISO’s Order No. 890-A compliance filing); 
N.Y. Indep. Sys. Operator, Inc., 123 FERC ¶ 61,134, at P 37 (2008) (same with respect to NYISO’s Order No. 890

9 
 
continues to be the best approach for New York and intends that the reforms advanced in this 
proceeding will work within that framework.     
Similarly, the NYISO has long had distinct interconnection procedures that were 
designed to address NYISO-specific circumstances.  These procedures were recently revised in 
compliance with Order No. 2023 but continue to reflect important regional variations.28  The 
NYISO OATT has also included separate load interconnection procedures since 1999 that are 
coordinated with state-jurisdictional processes.  The NYISO intends to propose numerous 
enhancements to both sets of procedures that will respond to the Show Cause Order while still 
accounting for reliability, operational and policy factors that are unique to New York.  
Third, a 90-day abeyance is reasonable in the NYISO’s case because it will facilitate the 
NYISO’s ability to obtain approval from its stakeholder Management Committee before making 
a section 205 filing.29  Given the NYISO’s shared governance structure, it would be appropriate 
to grant a 90-day abeyance to help the NYISO build consensus support for a section 205 filing.  
Even if stakeholders do not ultimately approve a proposal that fully addresses every aspect of the 
Show Cause Order, taking additional time to incorporate their input is all but certain to improve 
the quality of the NYISO’s response, to reduce the number of disputed issues, and to increase the 
likelihood of legally durable solutions.   
 
compliance filing); N.Y. Indep. Sys. Operator, Inc., 114 FERC ¶ 61,271 (2006) (“We will accept the proposed changes 
because, as applied to New York, they are both “consistent with or superior to” the terms in the pro forma LGIP and 
LGIA and they reflect regional needs.”); N.Y. Indep. Sys. Operator, Inc., 97 FERC ¶ 61,118, 61,574 (2001) (finding, 
in connection with Attachment S to the OATT, “that the proposed cost allocation rules, as modified, are reasonable 
and are consistent with or superior to the pro forma tariff”); Cent. Hudson Gas & Elec. Corp., 88 FERC ¶ 61,138, 
61,382 (1999) (concluding that “the Member Systems have complied with the requirement to provide long-term 
service” and finding “that the service offered by the ISO is consistent with or superior to that offered under the pro 
forma tariff”). 
28 See N.Y. Indep. Sys. Operator, Inc., 196 FERC ¶ 61,073 (2026). 
29 See ISO Agreement, art. 19.

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Finally, the NYISO is a single-state entity whose operational boundaries coincide with 
the area subject to the retail rate and resource adequacy jurisdiction of the New York State Public 
Service Commission (“NYPSC”).  The NYPSC has previously indicated that it intends to play a 
substantial role in addressing large load interconnection issues that fall within its purview.30  
Among other things, the NYPSC has an ongoing proceeding to “review interconnection 
processes, cost-allocation mechanisms and tariff structures relating to the integration of large 
loads with the State's transmission and distribution systems.”31  The NYISO will need to 
consider the implications of the regulatory structures that the NYPSC is developing as the 
NYISO devises its section 205 proposal.  Granting the requested abeyance will facilitate these 
efforts and would be consistent with the Commission’s clearly stated respect for cooperative 
federalism.32     
III. 
The NYISO’s Plans for Developing and Submitting its Section 205 Proposal 
 
The NYISO asked stakeholders for written feedback on the July 23 Stakeholder 
Presentation by July 27, 2026, and reviewed their submissions.  It is apparent that stakeholders 
endorse an abeyance and are prepared to work collaboratively and quickly to help refine the 
NYISO’s proposal.  The NYISO is already adopting changes to the July 23 version of its 
proposal based on stakeholder recommendations and expects its plans to improve through 
multiple iterations as it incorporates stakeholder feedback and makes further additions of its own.   
 
30 See Notice of Intervention and Preliminary Comments of the NYPSC, Docket No. EL26-29-000 (Jul. 9, 
2026); Comments of the NYPSC, Docket No. RM26-4-000 (Nov. 21, 2025). 
31  See Proceeding on Motion of the Commission to Address Interconnection Reforms for Large Loads, 
Case No. 26-E-0045. 
32 See, e.g., Show Cause Order at P 76 (“[T]he Commission’s objective in this proceeding is to respect the 
cooperative federalism approach established under the FPA.”)

11 
 
If the Commission grants the requested abeyance, the NYISO will move forward with an 
intensive stakeholder process “with all due deliberate haste.”33  The NYISO anticipates holding 
regular stakeholder meetings, as frequently as weekly, to develop a comprehensive filing, 
including drafting and reviewing revisions to the NYISO Tariffs.  The next meeting to discuss 
these proposals is scheduled for August 13, 2026.  
The NYISO will work towards approval by the stakeholder Business Issues Committee 
and Operating Committee in October, currently scheduled for October 14 and 15, 2026, 
respectively.  The final section 205 proposal would then be brought before the Management 
Committee currently scheduled for October 28, 2026, and finally to the independent Board of 
Directors.  Provided that Management Committee and Board approvals are secured, the NYISO 
will submit a section 205 proposal on November 16, 2026, along with a Show Cause Order 
response to the extent necessary.     
IV. 
Request for Expedited Action by August 13 and for Shortened Comment Period  
The NYISO respectfully requests that the Commission act on this motion by August 13, 
2026.  Without an abeyance, the NYISO’s response to the Show Cause Order would be due on 
August 17, 2026.  Action by or before August 13, 2026 would provide NYISO with regulatory 
certainty regarding the timing of its response to the Show Cause Order and allow the NYISO to 
focus its time and resources on completing an expedited effort to prepare a comprehensive 
section 205 filing.   
 
33 Show Cause Order, 195 FERC ¶ 61,216 at P 16 (Swett, Chairman, concurring).

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Consistent with the Commission’s rules governing responses to procedural motions and 
with the need for expedited action, the NYISO respectfully requests that the Commission limit 
the time for answers to five calendar days.34 
V. 
Conclusion 
For the foregoing reasons, the NYISO respectfully requests that the Commission issue an 
order by August 13, 2026, holding this proceeding in abeyance for 90 days until November 16, 
2026. 
Respectfully submitted, 
 
 
/s/  Ted J. Murphy 
 
Kim Loan Osborne 
Senior Attorney I  
New York Independent System  
Operator, Inc.  
10 Krey Boulevard  
Rensselaer, NY 12144  
kosborne@nyiso.com 
 
 
 
Ted J. Murphy 
Nathan R. Menard 
Hunton Andrews Kurth LLP 
2200 Pennsylvania Avenue, NW 
Washington, DC 20037 
(202) 955-1588 
(202) 419-2071 
tmurphy@hunton.com 
nmenard@hunton.com 
 
Mackinlee Rogers35  
Hunton Andrews Kurth LLP  
1445 Ross Avenue  
Dallas, TX 75202  
Tel: (214) 979-3000  
rogersm@hunton.com 
 
 
Counsel to the New York Independent System 
Operator, Inc. 
 
 
 
 
34 See 18 C.F.R. § 385.213(d)(1)(i). 
35 To the extent necessary, the NYISO respectfully requests waiver of 18 C.F.R. § 385.203(b)(3) to allow 
more than two individuals to be designated for service on the official service list in this proceeding.

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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 3rd day of August 2026. 
 /s/ Alexander Morse 
  
 
Alexander Morse 
New York Independent System Operator, Inc. 
10 Krey Blvd. 
Rensselaer, NY 12144 
(518) 285-7826