{"document":{"slug":"motion-el26-69-nyiso-abeyance","title":"NYISO requests more time to answer the June 18 show cause order","issued":"2026-08-03","accession":"20260803-5229","docket":"EL26-69-000","group":"NYISO filings","filer":"New York Independent System Operator, Inc.","kind":"motion for abeyance","file":"sources/originals/20260803-5229_01.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260803-5229","sha256":"3ebb72a07927d5be18b28e74a2549e7e26a74f6a055e18943d0f9945940dd72f","pages":13,"tokens":4187,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":324,"text":"UNITED STATES OF AMERICA \nBEFORE THE \nFEDERAL ENERGY REGULATORY COMMISSION \n \n \n \n                   ) \n \n \nNew York Independent System Operator, Inc. \n       )        \nDocket No. EL26-69-000 \n \n \n                   ) \n \n \n \nMOTION FOR ABEYANCE OF THE NEW YORK INDEPENDENT SYSTEM \nOPERATOR, INC., REQUEST FOR SHORTENED COMMENT PERIOD  \nAND REQUEST FOR EXPEDITED ACTION  \n \n \nIn accordance with Rule 212 of the Rules of Practice and Procedure of the Federal \nEnergy Regulatory Commission (“Commission”), the New York Independent System Operator, \nInc. (“NYISO”) submits this motion in response to the Commission’s June 18, 2026 order, in the \nabove-captioned docket.1  That order directed the NYISO to show cause by August 17, 2026, \nwhy the existing NYISO Tariffs2 remain just and reasonable and not unduly discriminatory \nwithout modifications related to transmission and interconnection services for large loads \n(“Show Cause Order” or “Order”).  The NYISO respectfully requests that the Commission hold \nthis proceeding in abeyance for the maximum period permitted by the Show Cause Order, i.e., \nfor 90 days, until November 16, 2026.  Granting abeyance would enable the NYISO to pursue a \nFederal Power Act (“FPA”) section 2053 filing through the NYISO’s governance process to \naddress the issues raised in the Order.4  The requested abeyance will also allow the NYISO to \ncoordinate with the transmission owning Commission-jurisdictional utilities in New York State \n(the “New York TOs”) regarding any issues that may be subject to their reserved section 205 \n \n1 N.Y. Indep. Sys. Operator, Inc., 195 FERC ¶ 61,216 (2026). \n2 The Show Cause Order used the term “NYISO Tariff” to refer to the NYISO’s Open Access Transmission \nTariff. (“OATT”).  However, the issues raised by the Show Cause Order, and the reforms that the NYISO intends to \npropose in response to it, also implicate the NYISO’s Market Administration and Control Area Services Tariff. In \nthis motion, the NYISO uses the term “NYISO Tariffs” to refer to both documents.  \n3 16 U.S.C. § 824d. \n4 See Show Cause Order, 195 FERC ¶ 61,216 at P 42 (discussing requests for abeyance)."},{"page":2,"startToken":324,"endToken":876,"text":"2 \n \nfiling rights.5  As the Order states, the NYISO and/or the New York TOs “may elect to address \nsome or all of the issues discussed in this order by proposing revisions to the Tariff pursuant to \ntheir applicable FPA section 205 filing rights.  We strongly encourage this.”6 \nThe NYISO respectfully requests that the Commission act on this motion by August 13, \n2026, to provide the NYISO with regulatory certainty.  Without an abeyance, the NYISO’s \nresponse to the Show Cause Order would be due on August 17, 2026.  Consistent with the \nCommission’s procedural rules and the need for expedited action, the NYISO respectfully \nrequests that the Commission limit the answer period to five calendar days.7 \nI. \nBackground \nThe Commission has determined that there are “a host of urgent challenges associated \nwith providing the transmission service needed to serve the ongoing influx of large loads while \n \n5 The Show Cause Order states that it will “consider [abeyance] requests from NYISO and/or the \nTransmission Owners.” Id.  The NYISO believes that if the Commission grants the NYISO’s request for a 90-day \nabeyance of all of the Show Cause Order’s requirements then such an abeyance could also encompass any issues for \nwhich the New York TOs may have a filing obligation.  The NYISO understands that the New York TOs are \nconcurrently filing their own request for abeyance.  The NYISO welcomes and shares the New York TOs’ \ncommitment to coordinate with the NYISO in an expedited effort to address the Show Cause Order’s directives.  \nHowever, the NYISO is not yet prepared to take a position on any of the specific assertions in the New York TOs’ \nabeyance request. \n6 Show Cause Order, 195 FERC ¶ 61,216 at P 41; see also id. at P 8 (Swett, Chairman, concurring) (“To be \nclear, we very much encourage 205 submissions encapsulating the principles we articulate in the 206s, and with all \ndue deliberate haste.”); id. at P 16 (Rosner, Comm’r, concurring) (“As a potential next step, today’s orders invite \nRTO/ISOs to respond by submitting proposals under FPA section 205. I cannot encourage this enough.”); id. at P 4 \n(See, Comm’r, concurring) (“Recognizing the value in region-specific approaches, we are directing individual action \nin each of the RTO/ISO regions and encouraging—strongly—proposals under section 205 of the Federal Power Act \nfrom transmission providers or other entities that are molded to their unique system needs.”); id. at P 3 (Chang, \nComm’r, concurring) (“The Commission also invites each region to submit FPA section 205 filings that can address \neach issue identified in the orders, thereby resolving the Commission’s concerns.”); id. at P 5 (LaCerte, Comm’r, \nconcurring) (“By inviting you to proceed under FPA section 205, we are giving you significant perks: the benefits of \nfirst wielder of the pen and the relatively capacious standard under FPA section 205 that allows us to accept a \npotentially broad range of proposals provided they are shown to be just and reasonable and not unduly \ndiscriminatory or preferential.”). \n7 See 18 C.F.R. § 385.213(d)(1)(i) (“If a motion requests an extension of time or a shortened time period for \naction, then answers to the motion to extend or shorten the time period shall be made within 5 days after the motion \nis filed, unless otherwise ordered.”)."},{"page":3,"startToken":876,"endToken":1182,"text":"3 \n \nmaintaining reliability and affordability.”8  It therefore issued show cause orders to each of the \nsix jurisdictional Independent System Operators and Regional Transmission Organizations \n(“ISOs/RTOs”) and the jurisdictional transmission owners in their regions.  As it did for each \nISO/RTO, the Commission instituted this proceeding pursuant to section 206 of the FPA.  It has \ndirected the NYISO9 and, to the extent applicable, the New York TOs, within 60 days, to either \n(1) show cause as to why the NYISO Tariffs remain just and reasonable and not unduly \ndiscriminatory or preferential without various changes pertaining to large loads and co-located \narrangements or (2) explain what changes to the NYISO Tariffs would remedy the identified \nconcerns if the Commission were to determine that the NYISO Tariffs have become unjust and \nunreasonable and to establish a replacement rate.10   \nThe Commission expressed concerns that large loads are not efficiently integrated onto \nthe transmission system; present a number of unique operational and reliability challenges; and \ncreate questions as to how to ensure that the rates, terms, and conditions of transmission service \nremain just and reasonable.11  The Commission called for reforms to expedite large load \ninterconnection, establish efficient transmission service application and study processes, prevent \ncost-shifting and increase transparency, accommodate co-location agreements and behind-the-\nmeter generation, potentially create new transmission services for flexible large loads, and \ninstitute a process for studying generating facilities that serve electrically proximate and co-\n \n8 Show Cause Order, 195 FERC ¶ 61,216 at P 1. \n9 The Show Cause Order also directed the NYISO to submit, within 30 days an informational report \ndescribing how the NYISO intends to ensure that adequate generation will be available to serve existing and new large \nloads. Id. at P 39.  The NYISO submitted its informational report on July 20, 2026.  \n10 Id. at P 3.  \n11 Id."},{"page":4,"startToken":1182,"endToken":1491,"text":"4 \n \nlocated large loads.12  In particular, the Commission: (i) recognized that the NYISO has an \nexisting load interconnection process but expressed concern that its procedures are only partially \nset forth in the NYISO Tariffs;13 (ii) preliminarily found that the NYISO Tariffs lack sufficiently \nclear and consistent provisions establishing the application process and study procedures that \nwill be used for large loads while indicating that the “NYISO may [] elect to propose Tariff \nrevisions establishing such an application process, fee, and requirements[,];”14 and (iii) directed \nthe NYISO to explain whether the NYISO Tariffs remain just and reasonable even though they \nallow “netting of behind the meter generation from gross load for purposes of determining \nTransmission Service Charges for Host Loads configured in a Behind-the-Meter Net Generation \n(“BTM:NG”) Resource arrangement or propose Tariff revisions.”15 \nThe Show Cause Order, and each of the Commissioners, strongly endorsed the \nsubmission of section 205 filings as a more effective means of addressing the issues raised in the \nShow Cause Order,16 and recognized that additional time may be needed to do so.17  The \nCommission accordingly stated that it would consider a request from the NYISO to hold, for up \nto 90 days, all or certain aspects of this proceeding in abeyance, while the NYISO works through \nthe stakeholder processes to develop a section 205 filing.18   The Show Cause Order emphasized \nthat a successful abeyance request should “include both (1) a robust description of the content of \n \n12 See News Release, FERC, FERC Launches Aggressive Targeted Action to Speed Large Load Integration \n(Jun. 18, 2026), https://www.ferc.gov/news-events/news/ferc-launches-aggressive-targeted-action-speed-large-load-\nintegration. \n13 Show Cause Order, 195 FERC ¶ 61,216 at P 64. \n14 Id. at P 65. \n15 Id. at P 110. \n16 See supra at n. 6.  \n17 See Show Cause Order at P 42. \n18 Id."},{"page":5,"startToken":1491,"endToken":1811,"text":"5 \n \na potential future filing under FPA section 205 and (2) a reasoned and specific explanation of \nwhen such a filing is expected to be made.”19  The following sections address these directives. \nII. \nThe NYISO Should Be Granted a 90-Day Abeyance to Pursue a Section 205 Filing \nThrough Its Shared Governance Process to Address the Show Cause Order in a \nManner Tailored to the NYISO Region \nThe NYISO recognizes that the concerns raised in the Show Cause Order are critically \nimportant and must be of the utmost priority.  The NYISO has determined that a number of its \nexisting Tariff provisions and related rules should be expanded or clarified to address the Show \nCause Order’s preliminary findings.  However, the NYISO believes that the best approach is to \nengage the NYISO’s stakeholder process and pursue a FPA section 205 filing to address these \nissues, rather than through making narrative responses to section 206 compliance directives.  An \nabeyance is justified in the NYISO’s case for the reasons described below. \nFirst, this proceeding involves numerous, complex, and consequential issues.  The \nNYISO is working diligently to formulate a comprehensive section 205 proposal to address them \nin a manner that recognizes New York’s regional differences.  This includes developing a load \nintegration process that builds on the existing division of responsibilities between the NYISO \nand the New York TOs.20  Granting the requested abeyance will give the NYISO time to more \nfully respond to the Show Cause Order’s many directives with the benefit of stakeholders’ \nperspectives and expertise.  Incorporating that input will minimize disagreements and narrow the \nscope of any future litigation.  Thus, instead of delaying the introduction of enhancements, an \nabeyance would likely lead to them being adopted and implemented more expeditiously.      \n \n19 Id. \n20 See Show Cause Order at P 58 (confirming that the Commission does not seek to alter the allocation of \nrights and responsibilities between the NYISO and the New York TOs)."},{"page":6,"startToken":1811,"endToken":2168,"text":"6 \n \nThe NYISO has already made progress towards developing rules and procedures that \nadvance and better effect the integration of large loads.  An abeyance would afford the NYISO a \nreasonable opportunity to finish its work.  The NYISO’s efforts began before the issuance of the \nShow Cause Order.  In February 2026, the NYISO shared information regarding its “Reliability \nPlanning & Large Load Integration” project to “improve the current load interconnection process \nto further address bulk system reliability concerns and speed up the overall load interconnection \nprocess to provide solutions for the unique issues presented by these types of large load projects \nand accelerated timelines for project development and in-service dates.”21  Furthermore, \nbeginning in February 2026, the NYISO made stakeholder presentations regarding its “Flexible \nLoad Models – Large Loads” and “DER Market Enhancements” projects which sought to \n“incentivize large loads to participate in NYISO’s markets as flexible Resources”22 and to \nimprove market access to “animate load in the NYISO markets,”23 respectively.  At that time, the \nNYISO planned to make a section 205 filing by the end of 2026.   \nThe NYISO has already built on its earlier work to develop an extensive proposal to \naddress the expanded set of issues raised by the Show Cause Order.  The NYISO presented an \noverview of its evolving post-Show Cause Order proposals at the July 23, 2026 meeting of its \nElectric System Planning Working Group (“ESPWG”), Transmission Planning Advisory \n \n21 See NYISO, TPAS/ESPWG, Load Interconnection Process: Challenges and Considerations Slide 3 \n(Feb. 3, 2026), https://www.nyiso.com/documents/20142/56802634/04_Load_interconnection_reform_2-3-\n26_TPAS_final.pdf/063ff31f-a5ad-0494-707d-3275f007d23a. \n22 See, e.g., NYISO, ICAPWG/MIWG, Flexible Load Models – Large Loads Slide 6 (Feb. 24, 2026), \nhttps://www.nyiso.com/documents/20142/57218179/flexible%20large%20loads%20022426%20icap.pdf/8ec9d774-\na5ce-eae2-93e2-ddc298f07781 (highlighting the importance of three inter-related large load project efforts – \nReliability Planning and Large Load Integration, Flexible Load Models – Large Loads, and DER Market \nEnhancements projects). \n23 See, e.g., NYISO, ICAPWG/MIWG, DER Market Enhancements Slide 4 (Feb. 24, 2026), \nhttps://www.nyiso.com/documents/20142/57218179/DER%20Market%20Enhancements%20kick%20off_021726%\n20ICAPWG_MIWG_final.pdf/c3c77fa7-f00a-7b5f-fe1d-598d2b466071."},{"page":7,"startToken":2168,"endToken":2440,"text":"7 \n \nSubcommittee (“TPAS”), and Installed Capacity Working Group (“ICAPWG”) (“July 23 \nStakeholder Presentation”).  A link to the July 23 Stakeholder Presentation is provided for \ninformational purposes.24  The proposals described therein are preliminary and will continue to \ndevelop.  Nevertheless, the July 23 Stakeholder Presentation demonstrates the substantial \nprogress that has been made to date.   \nAs the presentation describes, the NYISO plans to create a new large load study process \nthat would replace and improve upon its existing load interconnection rules.  The NYISO and \nNew York TOs would collaborate to complete large load integration studies within expedited \ntime periods.  The NYISO would make firm and non-firm variants of its existing financial \nreservation transmission service available to transmission customers serving large loads subject \nto certain necessary transmission security and resource adequacy requirements.  This approach \nwould, for example, make large loads eligible to take non-firm withdrawal service to the extent \ntheir ability to be flexible mitigates their impact on the system.   \nThe NYISO also presented a framework for and will develop detailed NYISO Tariff \nprovisions governing or addressing co-located load arrangements, the treatment of proximate \ngenerators, operating requirements, the Commission’s cost-shifting and transparency concerns, \nand a host of other related market design matters.  For example, for co-located load \narrangements, the NYISO intends to propose sunsetting its BTM:NG program and replacing it \nwith a new co-located resource participation model that treats load and generation as separate \n \n24 A link to the July 23 ESPWG /TPAS presentation, updated on July 29 to include minor corrections, is \nposted at: \nhttps://www.nyiso.com/documents/20142/58620525/04_FERC%20Large%20Load%20Show%20Cause%20Order%\n20-%20ESPWG.pdf/3b66b965-05ad-51e6-a4c5-c9846eeada4c."},{"page":8,"startToken":2440,"endToken":2968,"text":"8 \n \nand distinct market entities.25  And the NYISO will adopt transition rules to avoid disrupting \nexisting commercial arrangements.    \nSecond, the abeyance will allow the NYISO to structure and refine its proposals in a \nmanner that preserves the long-standing independent entity variations that have benefited the \nNYISO region.  Granting an abeyance will facilitate leveraging the NYISO’s “financial” \nreservation transmission service model to maximize the benefits to flexible large loads and other \ncustomers.  For example, the NYISO’s firm reservation transmission service enables \ntransmission customers to benefit from the use of the system in the same manner as pro forma \nNetwork Integration Transmission Service without the restrictions associated with traditional \nNetwork Load or Network Resource designations.26  In addition, the NYISO does not require, or \naccept, physical transmission reservations for internal transactions.  The Commission has \nfrequently recognized that the NYISO’s use of this model, along with other regional differences, \nare just and reasonable under the “consistent with or superior to” and “independent entity \nvariation” standards.27  The NYISO strongly believes that its financial reservation model \n \n25 See July 23 Presentation at Slide 77. \n26 See, e.g., Cent. Hudson Gas & Elec. Corp. et al. Compliance Filing vol. 1, Docket No. ER97-1523-000, \nat 27-28 (filed Apr. 30, 1999).  The transmission service offered by the NYISO is fundamentally similar to that \nprovided by the California Independent System Operator Corporation (“CAISO”).  The Commission’s Show Cause \nOrder for the CAISO acknowledged that it “does not offer traditional Order No. 888 network and point-to-point \ntransmission services, offers no firm, long-term transmission reservations of capacity, and does not provide a formal \napplication process for transmission service.” Cal. Indep. Sys. Operator Corp., 195 FERC ¶ 61,214 at P 19 (2026).   \n27 See, e.g., N.Y. Indep. Sys. Operator, Inc., 195 FERC ¶ 61,028, at P 29 (2026) (finding “that NYISO’s \nproposed revisions are consistent with or superior to the pro forma OATT” in connection with new market rules for \noperations, scheduling, and management of transmission service for the Champlain Hudson Power Express Merchant \nTransmission Facility); N.Y. Indep. Sys. Operator, Inc., 183 FERC ¶ 61,036, at P 12 (2023) (“[W]e find that NYISO’s \nproposed definition is consistent with or superior to the pro forma OATT Attachment M Transmission Line Rating \ndefinition.”); N.Y. Indep. Sys. Operator, Inc., 148 FERC ¶ 61,181, at P 9 (2014) (accepting NYISO’s proposal as \n“consistent with or superior to the language specified in Order No. 784); N.Y. Indep. Sys. Operator, Inc., 146 FERC ¶ \n61,208, at PP 19, 31 (2014) (finding NYISO’s proposed tariff revisions as meeting both the “consistent with or superior \nto” and “independent entity variation” standards for tariff revisions to comply with the requirements of Order No. \n764); N.Y. Indep. Sys. Operator, Inc., 125 FERC ¶ 61,274, at P 13 (2008) (recognizing “that NYISO’s proposed \ndeviations from the pro forma OATT reflect the actual market design used by NYISO, and find the deviations to be \nconsistent with or superior to the pro forma OATT” in connection with NYISO’s Order No. 890-A compliance filing); \nN.Y. Indep. Sys. Operator, Inc., 123 FERC ¶ 61,134, at P 37 (2008) (same with respect to NYISO’s Order No. 890"},{"page":9,"startToken":2968,"endToken":3350,"text":"9 \n \ncontinues to be the best approach for New York and intends that the reforms advanced in this \nproceeding will work within that framework.     \nSimilarly, the NYISO has long had distinct interconnection procedures that were \ndesigned to address NYISO-specific circumstances.  These procedures were recently revised in \ncompliance with Order No. 2023 but continue to reflect important regional variations.28  The \nNYISO OATT has also included separate load interconnection procedures since 1999 that are \ncoordinated with state-jurisdictional processes.  The NYISO intends to propose numerous \nenhancements to both sets of procedures that will respond to the Show Cause Order while still \naccounting for reliability, operational and policy factors that are unique to New York.  \nThird, a 90-day abeyance is reasonable in the NYISO’s case because it will facilitate the \nNYISO’s ability to obtain approval from its stakeholder Management Committee before making \na section 205 filing.29  Given the NYISO’s shared governance structure, it would be appropriate \nto grant a 90-day abeyance to help the NYISO build consensus support for a section 205 filing.  \nEven if stakeholders do not ultimately approve a proposal that fully addresses every aspect of the \nShow Cause Order, taking additional time to incorporate their input is all but certain to improve \nthe quality of the NYISO’s response, to reduce the number of disputed issues, and to increase the \nlikelihood of legally durable solutions.   \n \ncompliance filing); N.Y. Indep. Sys. Operator, Inc., 114 FERC ¶ 61,271 (2006) (“We will accept the proposed changes \nbecause, as applied to New York, they are both “consistent with or superior to” the terms in the pro forma LGIP and \nLGIA and they reflect regional needs.”); N.Y. Indep. Sys. Operator, Inc., 97 FERC ¶ 61,118, 61,574 (2001) (finding, \nin connection with Attachment S to the OATT, “that the proposed cost allocation rules, as modified, are reasonable \nand are consistent with or superior to the pro forma tariff”); Cent. Hudson Gas & Elec. Corp., 88 FERC ¶ 61,138, \n61,382 (1999) (concluding that “the Member Systems have complied with the requirement to provide long-term \nservice” and finding “that the service offered by the ISO is consistent with or superior to that offered under the pro \nforma tariff”). \n28 See N.Y. Indep. Sys. Operator, Inc., 196 FERC ¶ 61,073 (2026). \n29 See ISO Agreement, art. 19."},{"page":10,"startToken":3350,"endToken":3655,"text":"10 \n \nFinally, the NYISO is a single-state entity whose operational boundaries coincide with \nthe area subject to the retail rate and resource adequacy jurisdiction of the New York State Public \nService Commission (“NYPSC”).  The NYPSC has previously indicated that it intends to play a \nsubstantial role in addressing large load interconnection issues that fall within its purview.30  \nAmong other things, the NYPSC has an ongoing proceeding to “review interconnection \nprocesses, cost-allocation mechanisms and tariff structures relating to the integration of large \nloads with the State's transmission and distribution systems.”31  The NYISO will need to \nconsider the implications of the regulatory structures that the NYPSC is developing as the \nNYISO devises its section 205 proposal.  Granting the requested abeyance will facilitate these \nefforts and would be consistent with the Commission’s clearly stated respect for cooperative \nfederalism.32     \nIII. \nThe NYISO’s Plans for Developing and Submitting its Section 205 Proposal \n \nThe NYISO asked stakeholders for written feedback on the July 23 Stakeholder \nPresentation by July 27, 2026, and reviewed their submissions.  It is apparent that stakeholders \nendorse an abeyance and are prepared to work collaboratively and quickly to help refine the \nNYISO’s proposal.  The NYISO is already adopting changes to the July 23 version of its \nproposal based on stakeholder recommendations and expects its plans to improve through \nmultiple iterations as it incorporates stakeholder feedback and makes further additions of its own.   \n \n30 See Notice of Intervention and Preliminary Comments of the NYPSC, Docket No. EL26-29-000 (Jul. 9, \n2026); Comments of the NYPSC, Docket No. RM26-4-000 (Nov. 21, 2025). \n31  See Proceeding on Motion of the Commission to Address Interconnection Reforms for Large Loads, \nCase No. 26-E-0045. \n32 See, e.g., Show Cause Order at P 76 (“[T]he Commission’s objective in this proceeding is to respect the \ncooperative federalism approach established under the FPA.”)"},{"page":11,"startToken":3655,"endToken":3908,"text":"11 \n \nIf the Commission grants the requested abeyance, the NYISO will move forward with an \nintensive stakeholder process “with all due deliberate haste.”33  The NYISO anticipates holding \nregular stakeholder meetings, as frequently as weekly, to develop a comprehensive filing, \nincluding drafting and reviewing revisions to the NYISO Tariffs.  The next meeting to discuss \nthese proposals is scheduled for August 13, 2026.  \nThe NYISO will work towards approval by the stakeholder Business Issues Committee \nand Operating Committee in October, currently scheduled for October 14 and 15, 2026, \nrespectively.  The final section 205 proposal would then be brought before the Management \nCommittee currently scheduled for October 28, 2026, and finally to the independent Board of \nDirectors.  Provided that Management Committee and Board approvals are secured, the NYISO \nwill submit a section 205 proposal on November 16, 2026, along with a Show Cause Order \nresponse to the extent necessary.     \nIV. \nRequest for Expedited Action by August 13 and for Shortened Comment Period  \nThe NYISO respectfully requests that the Commission act on this motion by August 13, \n2026.  Without an abeyance, the NYISO’s response to the Show Cause Order would be due on \nAugust 17, 2026.  Action by or before August 13, 2026 would provide NYISO with regulatory \ncertainty regarding the timing of its response to the Show Cause Order and allow the NYISO to \nfocus its time and resources on completing an expedited effort to prepare a comprehensive \nsection 205 filing.   \n \n33 Show Cause Order, 195 FERC ¶ 61,216 at P 16 (Swett, Chairman, concurring)."},{"page":12,"startToken":3908,"endToken":4105,"text":"12 \n \nConsistent with the Commission’s rules governing responses to procedural motions and \nwith the need for expedited action, the NYISO respectfully requests that the Commission limit \nthe time for answers to five calendar days.34 \nV. \nConclusion \nFor the foregoing reasons, the NYISO respectfully requests that the Commission issue an \norder by August 13, 2026, holding this proceeding in abeyance for 90 days until November 16, \n2026. \nRespectfully submitted, \n \n \n/s/  Ted J. Murphy \n \nKim Loan Osborne \nSenior Attorney I  \nNew York Independent System  \nOperator, Inc.  \n10 Krey Boulevard  \nRensselaer, NY 12144  \nkosborne@nyiso.com \n \n \n \nTed J. Murphy \nNathan R. Menard \nHunton Andrews Kurth LLP \n2200 Pennsylvania Avenue, NW \nWashington, DC 20037 \n(202) 955-1588 \n(202) 419-2071 \ntmurphy@hunton.com \nnmenard@hunton.com \n \nMackinlee Rogers35  \nHunton Andrews Kurth LLP  \n1445 Ross Avenue  \nDallas, TX 75202  \nTel: (214) 979-3000  \nrogersm@hunton.com \n \n \nCounsel to the New York Independent System \nOperator, Inc. \n \n \n \n \n34 See 18 C.F.R. § 385.213(d)(1)(i). \n35 To the extent necessary, the NYISO respectfully requests waiver of 18 C.F.R. § 385.203(b)(3) to allow \nmore than two individuals to be designated for service on the official service list in this proceeding."},{"page":13,"startToken":4105,"endToken":4187,"text":"13 \n \nCERTIFICATE OF SERVICE \n \nI hereby certify that I have this day served the foregoing document upon each person \ndesignated on the official service list compiled by the Secretary in this proceeding in accordance \nwith the requirements of Rule 2010 of the Rules of Practice and Procedure, 18 C.F.R. §385.2010. \nDated at Rensselaer, NY this 3rd day of August 2026. \n /s/ Alexander Morse \n  \n \nAlexander Morse \nNew York Independent System Operator, Inc. \n10 Krey Blvd. \nRensselaer, NY 12144 \n(518) 285-7826"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":2,"endAt":710,"startToken":0,"endToken":442},{"p":2,"at":710,"title":"I. Background","method":"printed heading","endPage":2,"endAt":714,"startToken":442,"endToken":443},{"p":2,"at":714,"title":"Background","method":"printed heading","endPage":5,"endAt":198,"startToken":443,"endToken":1524},{"p":5,"at":198,"title":"II. The NYISO Should Be Granted a 90-Day Abeyance to Pursue a Section 205 Filing","method":"printed heading","endPage":10,"endAt":960,"startToken":1524,"endToken":3488},{"p":10,"at":960,"title":"III. The NYISO’s Plans for Developing and Submitting its Section 205 Proposal","method":"printed heading","endPage":11,"endAt":998,"startToken":3488,"endToken":3802},{"p":11,"at":998,"title":"IV. Request for Expedited Action by August 13 and for Shortened Comment Period","method":"printed heading","endPage":12,"endAt":234,"startToken":3802,"endToken":3943},{"p":12,"at":234,"title":"V. Conclusion","method":"printed heading","endPage":12,"endAt":238,"startToken":3943,"endToken":3944},{"p":12,"at":238,"title":"Conclusion","method":"printed heading","endPage":13,"endAt":6,"startToken":3944,"endToken":4106},{"p":13,"at":6,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":13,"endAt":508,"startToken":4106,"endToken":4187}]}