TexasBlake R. Urban

New YorkAttorney

Washington, DC

Connecticut+1.202.828.5868 Office

Seattle+1.800.404.3970 Fax

Dubai

Londonblake.urban@bracewelllaw.com

Bracewell LLP

2001 M Street NW
Suite 900

Washington, DC
20036-3310

November 2, 2016

Kimberly D. Bose Secretary

Federal Energy Regulatory Commission 888 First Street, N.E.

Washington, DC 20426

Re: New York State Electric & Gas Corporation
Docket No. ER17-__-000

Filing of Executed Cost Reimbursement Agreement

Dear Secretary Bose:

Pursuant to Section 205 of the Federal Power Act1 and Part 35 of the regulations of the Federal Energy Regulatory Commission (“Commission”),2 New York State Electric & Gas Corporation (“NYSEG”) hereby submits for filing a Cost Reimbursement Agreement
(“Reimbursement Agreement”) by and between NYSEG and Niagara Mohawk Power
Corporation (“National Grid”). The Reimbursement Agreement is designated as Service
Agreement No. 2319 under the New York Independent System Operator, Inc.’s (“NYISO”) Open Access Transmission Tariff (“OATT”).

For the reasons set forth below, NYSEG respectfully requests that the Commission accept the Reimbursement Agreement for filing effective October 7, 2016.

I.COMMUNICATIONS

All communications and service related to this filing should be directed to:

Blake R. UrbanJeffrey A. Rosenbloom

Bracewell LLPDirector - New York Legal Services

2001 M Street NW, Suite 900New York State Electric & Gas Corporation

Washington, DC 2003689 East Avenue

202-828-5868Rochester, NY 14649

blake.urban@bracewelllaw.com585-724-8132

jeffrey.rosenbloom@avangrid.com

116 U.S.C. § 824d (2012).

218 C.F.R. Pt. 35 (2016).

Ms. Kimberly D. Bose
November 2, 2016
Page 2

II.BACKGROUND

NYSEG and National Grid are both public utilities subject to the Commission’s jurisdiction that own transmission facilities under the operational control of the NYISO.

National Grid is rebuilding its 115 kV substation located in West Seneca, New York. In
connection with this work, National Grid has requested that NYSEG relocate its 34.5 kV
Transmission Line #513 that currently traverses the proposed construction area for National Grid’s
rebuilt substation, and perform certain conceptual engineering and environmental site assessment.
NYSEG agreed to perform the work requested by National Grid subject to reimbursement by
National Grid of NYSEG’s costs and expenses incurred in connection with the work, as discussed
further below.3

On October 7, 2016, NYSEG and National Grid executed the Reimbursement Agreement. NYSEG projects that the work to be performed under the Reimbursement Agreement will be completed by December 31, 2016.4

III. DESCRIPTION OF THE REIMBURSEMENT AGREEMENT

Pursuant to the Reimbursement Agreement, National Grid agreed to pay for or reimburse NYSEG for (i) 100 percent of the costs and expenses incurred by NYSEG in connection with the relocation of NYSEG’s transmission line; and (ii) 50 percent of the actual costs and expenses incurred by NYSEG to accomplish all remaining work contemplated in Exhibit A of the Reimbursement Agreement. Exhibit A of the Reimbursement Agreement details the work to be performed under the agreement by NYSEG.5 The Reimbursement Agreement sets forth the terms and conditions of this work and certain related commitments by National Grid. The Reimbursement Agreement includes provisions addressing the performance and schedule of the work, liability and indemnification, insurance, regulatory and governmental approvals, and various standard provisions for utility cost reimbursement agreements.

NYSEG is performing these services at actual costs (defined as “Company Reimbursable
Costs”) as set forth in Article 1.0 of the Reimbursement Agreement. As set forth in Article 6.1
of the Reimbursement Agreement, NYSEG estimates the Company Reimbursable Costs,
exclusive of any applicable taxes, to be $615,000. The Commission should find the price of the
services to be performed pursuant to the Reimbursement Agreement to be just and reasonable
because NYSEG will perform these services at actual cost (i.e., its out-of-pocket expenses), and
does not include any return on investment, carrying charge, or any other amount to be collected
for profit.

Reimbursement Agreement, Recitals, Article 3.0 and Exhibit A. Id., Exhibit B.

Id., Exhibit A.

Ms. Kimberly D. Bose
November 2, 2016
Page 3

IV. REQUESTED EFFECTIVE DATE AND WAIVER

In accordance with the date of execution of the Reimbursement Agreement, NYSEG respectfully requests that the Commission accept the Reimbursement Agreement with an effective date of October 7, 2016.

Pursuant to Section 35.3(a)(2) of the Commission’s regulations,6 the Commission

requires that service agreements be filed not more than 30 days after service commences.7

Because service commenced under the Reimbursement Agreement (i.e., the date of execution on October 7, 2016) less than 30 days from the date of this filing, the requested effective date is consistent with the Commission’s regulations.

To the extent necessary, NYSEG requests a waiver of any Commission regulation or requirement not otherwise satisfied by this filing in order to permit acceptance of the
Reimbursement Agreement, effective as requested.

V. SERVICE

A copy of this fling will be served on National Grid and the NYISO.

VI. CONTENTS OF FILING

In accordance with the Commission’s eTariff regulations and other filing requirements,8 this filing consists of:

 This transmittal letter; and

 A copy of the executed Reimbursement Agreement in PDF.

VII. CONCLUSION

For the foregoing reasons, NYSEG respectfully requests that the Commission accept the Reimbursement Agreement with an effective date of October 7, 2016.

Respectfully submitted,

/s/ Blake R. Urban

Catherine P. McCarthy Blake R. Urban

Counsel to New York State Electric & Gas Corporation