FERC Filings

COMPLAINT CONCERNING ALLOCATION OF SYSTEM UPGRADE FACILITY COSTS

ADDITIONAL REQUIREMENTS OF RULE 206

In addition to the foregoing and in accordance with Rule 206, Complainants state that no purpose would be served by pursuing alternate dispute resolution (“ADR”) procedures in this case. Complainants have attempted to resolve these issues both formally and informally as part of the NYISO stakeholders’ process for over six months. The NYISO, however, rejected making the necessary revisions to the Cost Allocation Report. As such, expedited Commission action is necessary to address this matter because the NYISO is continuing the cost allocation process following the initial decision period.

As noted above, on July 16, 2002, the NYISO Board rejected Ravenswood’s appeal. Complainants bring this Complaint to the Commission only after Ravenswood has fully exhausted its remedies at the NYISO. A prompt resolution of the issues raised in this Complaint will benefit the NYISO and all members of the Class of 2002, as well as market participants in future years.

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