10 Krey Boulevard  Rensselaer, NY 12144

November 15, 2016

By Electronic Delivery

Honorable Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE

Washington, DC 20426

Re: Filing of an Executed Large Generator Interconnection Agreement Among the
New York Independent System Operator, Inc., New York State Electric & Gas
Corporation, and Greenidge Generation LLC; Request for Waiver of the 60-Day
Notice Period; Docket No. ER17-____-000

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
New York State Electric & Gas Corporation (“NYSEG”) (together, the “Joint Filing Parties”)
hereby tender for filing an executed Large Generator Interconnection Agreement entered into by the NYISO, NYSEG, as the Connecting Transmission Owner, and Greenidge Generation LLC
(“Greenidge”), as the Developer (the “Interconnection Agreement”).3 The Interconnection
Agreement is labeled as Service Agreement No. 2305 under the NYISO’s Open Access
Transmission Tariff (“OATT”).

The Joint Filing Parties respectfully request that the Commission accept the

Interconnection Agreement for filing. With limited non-conforming exceptions, the justification
for which are described in Part I of this letter, the Interconnection Agreement conforms to the
NYISO’s pro forma Large Generator Interconnection Agreement (“Pro Forma LGIA”) that is
contained in Attachment X to the OATT. Further, as described in Part II of this letter, the Joint
Filing Parties respectfully request a waiver of the Commission’s prior notice requirements4 to
make the Interconnection Agreement effective as of October 31, 2016, which is the date of its
execution.

1 16 U.S.C. § 824d (2016).

2 18 C.F.R. § 35.12 (2016).

3 Capitalized terms that are not otherwise defined in this filing letter shall have the meaning

specified in Attachments S or X of the NYISO OATT, and if not defined therein, in the NYISO OATT and NYISO Market Administration and Control Area Services Tariff.

4 See Prior Notice and Filing Requirements Under Part II of the Federal Power Act, 64 FERC ¶ 61,139, clarified, 65 FERC ¶ 61,081 (1993).

Honorable Kimberly D. Bose November 15, 2016

Page 2

I.Discussion

A.Background

Greenidge is restarting Unit #4 of the Greenidge plant in Dresden, New York

(“Facility”). The Facility will be powered by natural gas and biomass. The Facility will have a net output of 106.3 MW. Additional details regarding the Facility can be found in Appendix C of the Interconnection Agreement.

The Facility will interconnect to certain transmission facilities of NYSEG that are part of
the New York State Transmission System. The Point of Interconnection is the point where
NYSEG’s 115 kV cable circuit from its Isolating Switch B4-76 connects to the existing NYSEG
115 kV Greenidge Substation between Switch B4-74 and B4-78. Figure A-1 of Appendix A of
the Interconnection Agreement provides a one-line diagram showing the Point of
Interconnection.

B. The Interconnection Agreement Closely Conforms to the Pro Forma LGIA

Contained in Attachment X of the NYISO OATT

The Interconnection Agreement was executed on October 31, 2016, by the NYISO,
NYSEG, and Greenidge. The Interconnection Agreement closely follows the language in the
Pro Forma LGIA contained in Attachment X of the NYISO OATT. However, the
Interconnection Agreement does contain limited variations from the Pro Forma LGIA that are
described in this Part I.B. These variations are necessary because of the unique circumstances of
Greenidge’s project. The Joint Filing Parties submit that these changes specified below satisfy
the Commission’s standard for variations from the Pro Forma LGIA, because unique
circumstances exist that require a non-conforming agreement.5 Therefore, the Joint Filing
Parties respectfully request that the Commission accept the Interconnection Agreement with
these limited non-conforming changes.

1. Modifications to Address Execution of Greenidge Interconnection
Agreement Prior to Completion of Class Year Study

Greenidge has elected to seek both Energy Resource Interconnection Service (“ERIS”)
and Capacity Resource Interconnection Service (“CRIS”). Greenidge is participating in the
current Class Year Interconnection Facilities Study (“Class Year Study”), which is still
underway. The Class Year Study identifies required System Upgrade Facilities for the reliable
interconnection of all of the facilities in the Class Year and determines whether any System
Deliverability Upgrades are required for the Facility to be fully deliverable at its requested level
of CRIS.

5 See, e.g., PJM Interconnection, LLC, 111 FERC ¶ 61,163 at PP 10-11, reh’g denied, 112 FERC ¶ 61,282 (2005).

Honorable Kimberly D. Bose November 15, 2016

Page 3

Since the Class Year Study was not completed at the time the parties executed the

Greenidge Interconnection Agreement, the parties modified Section 4.1.1 of the Interconnection
Agreement to provide that the NYISO’s provision of ERIS and CRIS are subject to the
requirements in Section 7 of Appendix A of the Interconnection Agreement. Section 7 of
Appendix A provides that if the Connecting Transmission Owner’s Attachment Facilities,
System Upgrade Facilities, and System Deliverability Upgrades identified in the Class Year
Study differ in any material way from the facilities described in the Interconnection Agreement,
the parties will amend the Interconnection Agreement to incorporate the results of the Class Year
Study. Section 7 of Appendix A further provides that Greenidge will be responsible for
providing NYSEG with any difference between the Security it provided NYSEG
contemporaneously with the execution of the Interconnection Agreement for its estimated share
of the required System Upgrade Facilities for Class Year 2015 and the final share determined in
the Class Year Study.6 Finally, Section 7 of Appendix A provides that Greenidge may not
supply Unforced Capacity to the New York Control Area from the Facility until it has complied
with the deliverability requirements set forth in Attachment S of the OATT, including acceptance
of any cost allocation for System Deliverability Upgrades and the posting of associated security
or payments. The Commission has previously accepted these types of changes to the Pro Forma
LGIA where, as here, the Developer was participating in a pending Class Year Study at the time
the Interconnection Agreement was executed.7

2. Modifications to Address Limited Operation of the Facility Prior to
Completion of Certain Upgrade Facilities

The parties have determined that certain Connecting Transmission Owner’s Attachment
Facilities, System Upgrade Facilities, and other required upgrade facilities will not be completed
prior to the Commercial Operation Date of the Facility. Consistent with Section 5.9 of the Pro
Forma LGIA, the parties will perform certain operating studies and will permit Greenidge to
operate the Facility in accordance with the requirements of these studies. The description of the
studies and the work required to provide for limited operation are described in Section 3 of
Appendix C of the Interconnection Agreement. Accordingly, the parties have modified Section

4.1.1 of the Interconnection Agreement to provide that the NYISO’s provision of ERIS and CRIS are subject to the limited operations requirements in Section 3 of Appendix C.

3. Non-Inclusion of Pending Compliance Revisions to Pro Forma LGIA

With the agreement of all parties, the NYISO circulated the final version of the

Interconnection Agreement on October 10, 2016 for the parties’ execution. Prior to all parties’

6 If the final Security amount determined in the Class Year Study is less than the Security provided by the Greenidge, NYSEG will return the excess Security amount to Greenidge.

7 See, e.g., New York Independent System Operator, Inc., Letter Order, Docket No. ER11-2199-
000 (December 28, 2010) (accepting revisions to CRIS requirements in Pro Forma LGIA to reflect the timing of the execution of the interconnection agreement).

Honorable Kimberly D. Bose November 15, 2016

Page 4

execution of the Interconnection Agreement, the NYISO filed revisions to the Pro Forma LGIA8
to comply with the Commission’s Order No. 827.9 Order No. 827 directed revisions to the Pro
Forma LGIA to require reactive power capability from non-synchronous generators. In response
to Order No. 827, the NYISO proposed conforming revisions to the power factor requirements in
Section 9.5.1 and Appendix G of the Pro Forma LGIA and requested that the revisions become
effective on October 13, 2016. The proposed tariff revisions are currently pending at the

Commission.

The Joint Filing Parties respectfully request that the Commission accept the

Interconnection Agreement without these pending revisions to the Pro Forma LGIA that were
filed by the NYISO after the parties began execution of the Interconnection Agreement. The
absence of these provisions will not impact the design of the Facility, which is a synchronous
generator.

II. Proposed Effective Date and Request for Wavier of the 60-Day Notice Period

The Joint Filing Parties request an effective date of October 31, 2016, for the

Interconnection Agreement, which is the date of its execution. The Joint Filing Parties

respectfully request that the Commission waive its prior notice requirement to permit the

requested effective date. The Commission has previously permitted interconnection agreements to become effective upon the date of execution.10

III.Communications and Correspondence

Communications regarding this filing should be directed to:

For the NYISO11

Robert E. Fernandez, General Counsel*Ted J. Murphy

Karen Georgenson Gach, Deputy GeneralHunton & Williams LLP

Counsel2200 Pennsylvania Avenue, NW

8 See New York Independent System Operator, Inc., Compliance Filing, Docket No. ER17-61-000 (October 12, 2016).

9 Reactive Power Requirements for Non-Synchronous Generation, Order No. 827, 81 Fed. Reg. 40,793 (June 23, 2016), 155 FERC ¶ 61,277 (2016).

10 See, e.g., New York Independent System Operator, Inc. and New York State Electric & Gas

Corporation, Docket No. ER11-2953-000 (April 7, 2011) (accepting interconnection agreement effective as of date of execution); see also New York Independent System Operator, Inc. and Niagara Mohawk Power Corp., Letter Order, Docket No. ER08-985-000 (June 26, 2008) (same); New York Independent System Operator, Inc. and New York Power Authority, Letter Order, Docket No. ER08-861-000 (May 27, 2008) (same); New York Independent System Operator, Inc. and New York Power Authority, Letter
Order, Docket No. ER08-699-000 (May 16, 2008) (same).

11 The NYISO respectfully requests waiver of 18 C.F.R. § 385.203(b)(3) (2014) to permit service on counsel in both Washington, D.C. and Richmond, VA.

*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
skeegan@nyiso.com

Washington, D.C. 20037 Tel: (202) 955-1500

Fax: (202) 778-2201
tmurphy@hunton.com

*Michael J. Messonnier Jr. Hunton & Williams LLP 951 East Byrd Street

Richmond, VA 23219
Tel: (804) 788-8200
Fax: (804) 344-7999

mmessonnier@hunton.com

For NYSEG:

*Jeffrey A. Rosenbloom

Director, NY Legal Services

New York State Electric & Gas Corporation
c/o Rochester Gas and Electric Corporation

89 East Avenue,

Rochester, NY 14649
Tel (585) 724-8132
Fax: (585) 724-8668

Jeffrey.Rosenbloom@Avangrid.com

*Designated to receive service.
IV. Documents Submitted

The NYISO submits the following documents with this filing letter:

• a clean version of the Interconnection Agreement (Attachment I);

• a blacklined version of the Interconnection Agreement showing the changes from the
body of the Pro Forma LGIA (Attachment II); and

• the signature pages for the Interconnection Agreement (Attachment III).

V.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 New Jersey Board of Public Utilities. In addition, a complete
copy of the documents included with this filing will be posted on the NYISO’s website at
www.nyiso.com.

Honorable Kimberly D. Bose November 15, 2016

Page 6

VI. Conclusion

Wherefore, the Joint Filing Parties respectfully request that the Commission accept the Interconnection Agreement for filing with an effective date of October 31, 2016.

Respectfully submitted,

/s/ Sara B. Keegan

Sara B. Keegan
Counsel for the

New York Independent System Operator, Inc.

/s/ Jeffrey A. Rosenbloom

Jeffrey A. Rosenbloom Counsel for

New York State Electric & Gas Corporation