10 Krey Boulevard Rensselaer, NY 12144
June 13, 2011
By Electronic Delivery
Honorable Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE
Washington, DC 20426
Re: Filing of an Executed Amended and Restated Small Generator Interconnection
Agreement Among the New York Independent System Operator, Inc., Niagara
Mohawk Power Corporation d/b/a National Grid, and Chautauqua County and
Request for Waiver of the 60-Day Notice Period, Docket No. ER1___-___-___
Dear Ms. Bose:
Pursuant to Section 205 of the Federal Power Act1 and Section 35.12 of the
Commission’s Regulations,2 the New York Independent System Operator, Inc. (“NYISO”) and
Niagara Mohawk Power Corporation d/b/a National Grid (“National Grid”) (collectively, the
“Joint Filing Parties”) hereby tender for filing an Amended and Restated Executed Small
Generator Interconnection Agreement (“Amended Agreement”) as Service Agreement No. 1530
among the NYISO, National Grid as the Transmission Owner, and Chautauqua County (“the
County”) as the Interconnection Customer.3 The Joint Filing Parties respectfully request waiver
of the Commission’s 60-day notice period to make this Agreement effective as of June 1, 2011.
I.Background
The Amended Agreement supersedes a Small Generator Interconnection Agreement
(“SGIA”) among the parties that was filed in Docket No. ER10-555-000, as Service
Agreement No. 1530 (“Original Agreement”). The Original Agreement was accepted by the
Commission on March 1, 2010.4 The Original Agreement stated that the County’s landfill gas-
to-energy generation facility (“Facility”) would consist of consist of four 1.6 MW generators,
1 16 U.S.C. § 824d (2006).
2 18 C.F.R. § 35.12 (2008).
3 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”).
4 New York Independent System Operator, Inc. and Niagara Mohawk Power Corporation d/b/a National Grid, Order, Docket No. ER10-555-000 (issued March 1, 2010).
Honorable Kimberly D. Bose June 13, 2011
Page 2
associated breakers, and appurtenant equipment with a total generating capacity of 6.4 MW.5 The Original Agreement also specified that the Point of Interconnection would be the tap point on the Connecting Transmission Owner’s 34.5 kV Hartfield-South Dow Line #859.
II.Discussion of Changes
Since the filing of the Original Agreement, the County proposed to expand the Facility
from 6.4 MW to 9.6 MW. The proposed expansion was evaluated through the NYISO
interconnection process. As a result of the County’s proposed expansion, the equipment and
Milestones specified in the Original Agreement require modification. The Joint Filing Parties
therefore submit this Amended Agreement to reflect the modifications to the Original
Agreement.
Specifically, the Amended Agreement modifies the SGIA as follows:
• Section 1.3.1 of the body of the Amended Agreement has been modified to
incorporate a reference to Attachment 6, Section G which provides that the
additional 3.2 MW are only eligible for Energy Resource Interconnection Service and not Capacity Resource Interconnection Service;
• The body of the Amended Agreement reflects the following modifications to the
body of the Original Agreement: (1) a new effective date; (2) changes to reflect
that this is the “Amended and Restated” version of the Interconnection
Agreement;
• The body of the Amended Agreement reflects modifications to the Original
Agreement necessary in order to make the Amended Agreement conform to the pro forma SGIA;
• The body of the Amended Agreement reflects ministerial corrections to correct
tariff section numbers referenced in the pro forma SGIA;
• Attachment 2 has been modified to reflect: (1) two additional 1.6 MW generators
and two additional generator circuit breakers; (2) additional technical detail for
the existing generators and appurtenant equipment (e.g., reactive power capability
and winding configurations); (3) design and construction requirements for the
New Generating Facilities; (4) a cost estimate for the portion of the New
Generating Facilities related to the expansion that includes National Grid’s
engineering and field review and compliance verification of modifications to the
Interconnection Facilities; and (5) an affirmative selection of the Option 2 O&M
Expense payment option.
5 Additional details regarding the interconnection are found in Attachment 2 of the Amended Agreement.
Honorable Kimberly D. Bose June 13, 2011
Page 3
• Attachment 3 has been modified to reflect an updated one-line diagram at 3-2 of
the Amended Agreement;
• Attachment 4 has been modified to reflect that Milestones associated with the
Existing Facility have been completed and to add Milestones associated with the New Facility; and
• Attachment 6 has been modified to reflect (1) revisions to conform to the current
pro forma SGIA; (2) that there are no Connecting Transmission Owner
Distribution Upgrades or Connecting Transmission Owner System Upgrade
Facilities for the New Facility; (3) revisions required for consistency; and (4) that
the additional 3.2 MWs are only eligible for Energy Resource Interconnection
Service and the Facility’s Capacity Resource Interconnection Service will
continue to be limited to 6.4 MW.
The Joint Filing Parties, therefore, respectfully request that the Commission accept this Amended Agreement.
III. Effective Date and Request for Wavier of the 60-Day Notice Period
The parties request an effective date of June 1, 2011 for the Amended Agreement, which
is the date of execution. The Commission has allowed interconnection agreements to become
effective on the date of execution, even when that date preceeds the date that an interconnection
agreement is filed. Accordingly, the parties request that the Commission grant a waiver of its
prior notice requirements to the extent necessary to accommodate this requested effective date.
IV. Communications and Correspondence
Communications regarding this filing should be directed to:
For the NYISO
Robert E. Fernandez, General Counsel
Karen Georgenson Gach, Deputy General Counsel *Sara B. Keegan, Senior Attorney
New York Independent System Operator, Inc.
10 Krey Boulevard
Rensselaer, NY 12144
Tel: (518) 356-6000
Fax: (518) 356-4702
rfernandez@nyiso.com
kgach@nyiso.com
skeegan@nyiso.com
Honorable Kimberly D. Bose June 13, 2011
Page 4
For Niagara Mohawk d/b/a National Grid
* Daniel Galaburda
Senior Counsel
Niagara Mohawk d/b/a National Grid
40 Sylvan Road
Waltham, MA 02451-1120
Phone: (781) 907-1847
Email: Daniel.galaburda@us.ngrid.com
*Designated to receive service.
V.Documents Submitted
The NYISO submits the following documents:
• this filing letter;
• a clean version of the Amended Agreement; and
• a blacklined version showing the changes between the Original Agreement and the
Amended Agreement.
VI. Service
The NYISO will 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 electric utility regulatory agency of New Jersey. In addition, a
complete copy of the Public documents included with this filing will be posted on the NYISO’s
website at www.nyiso.com.
VII. Conclusion
Wherefore, the NYISO respectfully requests that the Commission accept the Amended Agreement effective as of June 1, 2011.
Honorable Kimberly D. Bose June 13, 2011
Page 5
Respectfully submitted,
/s/ Sara B. Keegan
Sara B. Keegan
Counsel for the
New York Independent System Operator, Inc.
/s/Daniel Galaburda
Daniel Galaburda
Counsel for Niagara Mohawk d/b/a National Grid
