10 Krey Boulevard Rensselaer, NY 12144
June 25, 2012
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 Large Generator Interconnection
Agreement Among the New York Independent System Operator, Inc., the New
York Power Authority and Marble River, LLC and Request for Waiver of the 60-
Day Notice Period, Docket No. ER12-___-000
Dear Ms. Bose:
Pursuant to Section 205 of the Federal Power Act,1 Section 35.12 of the Commission’s
Regulations, 2 and Section 11.3 of its Large Facility Interconnection Procedures (“LFIP”), the
New York Independent System Operator, Inc. (“NYISO”) and the New York Power Authority
(“NYPA”) (collectively, “Joint Filing Parties”) hereby tender for filing an executed Amended
and Restated Large Generator Interconnection Agreement (“Amended Agreement”) as Service
Agreement No. 1774 among the NYISO, NYPA as the Transmission Owner, and Marble River,
LLC (“Marble River”) as the Developer (collectively, “Parties”).3 The Joint Filing Parties
respectfully request waiver of the Commission’s 60-day notice requirement, to make the Amended Agreement effective as of June 13, 2012
The Amended Agreement supersedes a Large Generator Interconnection Agreement
(“LGIA”) among the Parties that was filed in Docket No. ER11-4056-000, as Service Agreement No. 1774 (“Original Agreement”). The Original Agreement was accepted by the Commission on September 2, 2011, effective June 29, 2011.
The Original Agreement accepted by the Commission provided for the interconnection of
Marble River’s 216.3 MW wind generating facility (“the Facility”) to the New York State
Transmission System for Energy Resource Interconnection Service (“ERIS”).4 The Original
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 and X of the NYISO’s Open Access Transmission Tariff (“OATT”).
4 The Developer elected only ERIS and not Capacity Resource Interconnection Service (“CRIS”).
Honorable Kimberly D. Bose June 25, 2012
Page 2
Agreement provided that the Facility would consist of 103 Suzlon S-88 singly-fed induction
generators (“turbines”), each 2.1 MW; one 230kV, 2000A three-phase switch; eight 34.5kV,
1200A, 40kA interrupting vacuum circuit breakers; one 4000A main breaker; and two blocks of
34.5kV 20 MVAR shunt capacitor banks. The Original Agreement also contained non-
conforming provisions to reflect circumstances specific to the project, namely: (1) NYPA’s
unique legal status as a power authority governed under New York’s Power Authority Act; 5
(B) the unique existence of “common” System Upgrade Facilities shared by Marble River and certain other Class Year 2006 Developers; and (C) necessary ministerial revisions.
I.Discussion of Changes
Since the filing of the Original Agreement, Marble River proposed to change the
turbines from Suzlon S88 2.1 MW turbines to Vestas V112 3.075 MW turbines, and to reduce
the number of turbines from 103 to 70, resulting in a nominal reduction in the Facility’s
generating capacity. The NYISO evaluated the proposed changes and determined that they are
not Material Modifications. The changes do, however, require modification to certain equipment
descriptions and Milestones specified in the Original Agreement. The Joint Filing Parties
therefore submit this Amended Agreement to reflect the modifications to the Original
Agreement.
Specifically, the Amended Agreement modifies the LGIA as follows:
• The body of the Amended Agreement reflects the following modifications to the body of
the Original Agreement: (1) a new effective date - the date of execution of the Amended Agreement; and (2) changes to reflect that this is the “Amended and Restated” version of the Interconnection Agreement;
• Appendix A reflects the following modifications: (1) equipment changes and equipment
specifications for Developer’s Attachment Facilities resulting from the turbine changes
(e.g., deletion of references to capacitor banks and related equipment that are not needed
with the Vestas turbines); (2) additional technical specifications for existing equipment
(e.g., the nominal breaker ratings for the disconnect switches and specific 34.5 kV feeder
breaker information); (3) deletion of inapplicable diagram references in Section III(B);
and (4) updated one-line diagram at Figure 1 consistent with the turbine changes and
related change in equipment generating capacity;
• Appendix B reflects updated dates and ministerial revisions in the Milestone table;
• Appendix C reflects modifications replacing the description and technical specifications
of the Suzlon turbines and related equipment with details and technical specifications of the Vestas turbines, and providing additional detail related to the generator step up
transformer; and
5 N.Y. Public Authorities Law §§ 1000-1017.
Honorable Kimberly D. Bose June 25, 2012
Page 3
• Appendices E and F reflect updated contact information for NYPA.
The blacklined version attached to this filing shows all of these changes that were made to the currently effective interconnection agreement. The Parties respectfully request that the Commission accept this Amended Agreement.
III. Proposed Effective Date and Request for Waiver of the 60-Day Notice Period
The parties request an effective date of June 13, 2012 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 pre-dates 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
For New York Power Authority
Judith C. McCarthy, Executive Vice President & General Counsel *Andrew F. Neuman, Special Counsel
New York Power Authority
123 Main Street
White Plains, New York 10601
Tel: (914) 390-8028
Fax: (914) 390-8038
andrew.neuman@nypa.gov
*Designated to receive service.
Honorable Kimberly D. Bose June 25, 2012
Page 4
V.Documents Submitted
The NYISO submits the following documents:
1.this filing letter;
2.a clean version of the Amended Agreement (Attachment I); and
3.a blackline showing the changes between the Original Agreement and the Amended
Agreement (Attachment II).
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 New Jersey Board of Public Utilities. 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 attached Agreement effective as of June 13, 2012.
Respectfully submitted,
/s/ Sara B. Keegan
Sara B. Keegan
Counsel for the
New York Independent System Operator, Inc.
/s/Andrew F. Neuman
Andrew F. Neuman
Special Counsel for the New York Power Authority
