Daniel Galaburda

Assistant General Counsel

June 24, 2011

VIA ELECTRONIC FILING

Ms. Kimberley D. Bose Secretary

Federal Energy Regulatory Commission 888 First Street, NE

Washington, DC 20426

RE: Niagara Mohawk Power Corporation
Docket No. ER11-_____

Interconnection Agreement between Niagara Mohawk Power Corporation and the Village of Ilion, New York

Request for Expedited Commission Action,

Shortened Comment Period, and Waiver of 60-day Prior Notice
Period

Dear Secretary Bose:

Pursuant to Section 205 of the Federal Power Act (“FPA”),1 Part 35 of the

Commission’s regulations,2 and Order No. 714,3 Niagara Mohawk Power Corporation (“Niagara Mohawk”), d/b/a National Grid submits for Commission acceptance an
Interconnection Agreement (“IA” or “Agreement”) between Niagara Mohawk and the Village of Ilion, New York (“Ilion”)(collectively, the “Parties”). The Agreement is
designated under the New York Independent System Operator, Inc. (“NYISO”) open
access transmission tariff (“OATT”), FERC Electric Tariff, Original Volume No. 1 as Service Agreement No. 1755.

For the reasons discussed below, Niagara Mohawk, with the support of Ilion,
requests a shortened comment period of seven days on this filing and waiver of the 60-
day prior notice period to permit this agreement to become effective on July 1, 2011. A July 1, 2011, effective date is critical to Ilion’s plans to maintain jobs in upstate New
York through arrangements with the Remington Arms Company factory (“Remington Factory”) located in the Village of Ilion. Although Niagara Mohawk is not requesting a Commission order on the filing by any specific date, Niagara Mohawk does request an expedited Commission order on this filing.

The Honorable Kimberley D. Bose June 24, 2011

Page 2

I.Background

The Village of Ilion owns and operates a load serving municipal electric system which is currently interconnected to the transmission system of Niagara Mohawk through a single delivery point. The Agreement details terms and conditions related to the
ongoing interconnection of the Niagara Mohawk and Ilion systems and the manner by which National Grid and Ilion will coordinate to ensure the ongoing reliability of the
New York State Transmission System.

The Remington Factory is located in a dual franchise area and is currently a retail
customer of Niagara Mohawk. The Remington Factory has notified Niagara Mohawk
that it would like to exit the Niagara Mohawk retail franchise under Rule 52 in Niagara
Mohawk’s retail tariff, PSC 220, and become a retail costumer of the Village. The
Agreement in combination with the Village’s purchase of assets from Remington Factory
provides for the current retail delivery point to be converted to a wholesale delivery point
between the Niagara Mohawk and Ilion systems.4 This change will enable the Village,
rather than Niagara Mohawk, to offer service to the Remington Factory. This
arrangement was developed by the Village with the support of Niagara Mohawk to
address the interests of the Remington Factory and allow the Remington Factory access
to inexpensive hydro power under a New York State program administered by the New
York Power Authority. This arrangement will allow the Remington Factory to maintain
its presence in the Village and thereby retain much-needed jobs in upstate New York.

II.Interconnection Agreement

Niagara Mohawk has entered into comparable interconnection agreements with
other New York municipal electric systems in recent years. The attached Agreement is
modeled in large part on an interconnection agreement between Niagara Mohawk and the
Village of Solvay, New York, which was accepted by Commission letter order on
October 22, 2003 in Docket No. ER03-1304-000. Consistent with the Solvay agreement
and Commission precedent, the Agreement provides for the direct assignment of certain
costs and charges for interconnection facilities that are solely for the use of Ilion.5

Niagara Mohawk is currently in the process of developing a standard municipal
interconnection agreement that can document the terms and conditions of interconnection
between Niagara Mohawk and a number of municipal electric systems in New York.
Niagara Mohawk is engaged in negotiations with the Municipal Electric Utilities
Association of New York (“MEUA”) to develop this standard municipal interconnection
agreement. Niagara Mohawk expects to submit the standard municipal interconnection
agreement for Commission approval once the negotiations with MEUA are completed.

The Honorable Kimberley D. Bose June 24, 2011

Page 3

Given the need for the Village of Ilion to have an interconnection agreement in
effect by July 1, 2011, that documents the needed arrangements to accommodate the
Remington Factory, the Parties have agreed to contractual provisions that will allow the
attached Agreement to become effective by the start of July but also allow Ilion to benefit
from future input from MEUA and others related to the appropriate terms and conditions
of the standard municipal interconnection agreement under development. Specifically,
Section 30.6 of the Agreement requires Niagara Mohawk to offer to Ilion revisions to the
Agreement based upon the final standard municipal interconnection agreement negotiated
between Niagara Mohawk and the MEUA and accepted by the Commission

III.Effective Date and Request for Shortened Comment Period and Expedited

Action

Niagara Mohawk requests waiver of the Commission’s 60-day notice requirement to permit the Agreement to become effective on July 1, 2011. Niagara Mohawk also requests a shortened comment period of seven days on the filing to facilitate an expedited Commission order on the Agreement.

Good cause exists for such a waiver. As detailed above, Niagara Mohawk is

responding to Ilion’s immediate need to reach suitable arrangements with the Remington
Factory in order to allow the factory to continue its presence in upstate New York. The
Remington Factory provides jobs that are important to the economy of the Village of
Ilion. Granting the requested waiver will allow Niagara Mohawk to accommodate Ilion
and is in the public interest and consistent with the standard set forth by the Commission
in Central Hudson.6

Niagara Mohawk requests a waiver of any Commission requirements not

specifically addressed herein necessary to allow the included agreements to become effective as of July 1, 2011.

See Central Hudson Gas & Electric Corp., 60 FERC ¶ 61,106 at 61,338, reh’g denied, 61 FERC ¶

The Honorable Kimberley D. Bose June 24, 2011

Page 4

IV.Communications and Service

Communications and correspondence with respect to this matter should be

addressed to the following individuals, and the following should be included on the

official service list for this proceeding:7

Daniel Galaburda

Assistant General Counsel

National Grid USA Service Company, Inc.

40 Sylvan Road

Waltham, MA 02451
Tel: (781) 907-1847

daniel.galaburda@us.ngrid.com

V.Conclusion

Sean Atkins

Stacey Tyrewala
Alston & Bird LLP

The Atlantic Building 950 F Street, NW

Washington, DC 20004 Tel: 202-239-3300

Fax: 202-239-3333

Sean.Atkins@alston.com
Stacey.Tyrewala@alston.com

For the reasons stated herein, Niagara Mohawk respectfully requests that the Commission accept the Agreement, effective July 1, 2011.

Copies of this filing have been served on Ilion, New York state regulators, and the
NYISO.

Respectfully submitted,

/s/ Daniel Galaburda

Daniel Galaburda

Assistant General Counsel

National Grid USA Service Company, Inc.

40 Sylvan Road

Waltham, MA 02451

Attorney for Niagara Mohawk Power
Corporation, d/b/a National Grid