Amanda Downey
Counsel

August 20, 2012

The Honorable Kimberly D. Bose Secretary

Federal Energy Regulatory Commission 888 First Street, NE

Washington, DC 20426

Re: Niagara Mohawk Power Corporation

Filing of Interconnection Agreement with the Village of Solvay and Request for Waiver of Commission Notice Requirement
Docket No. ER12-___-000

Dear Secretary Bose:

Pursuant to Section 205 of the Federal Power Act, 16 U.S.C. § 824d, and Part 35
of the Federal Energy Regulatory Commission’s (“Commission”) regulations, 18 C.F.R.
Part 35, Niagara Mohawk Power Corporation d/b/a National Grid (“Niagara Mohawk”)
submits for filing and Commission acceptance an executed Interconnection Agreement
between Niagara Mohawk and the Village of Solvay (“Solvay”) (“Interconnection
Agreement”), designated as Service Agreement No. 1913 under the New York
Independent System Operator, Inc.’s (“NYISO”) Open Access Transmission Tariff
(“OATT”), FERC Electric Tariff, Original Volume No. 1. Niagara Mohawk respectfully
requests that the Commission grant waiver to permit the Interconnection Agreement to go
into effect as of June 18, 2012, as specified in the Interconnection Agreement.

I.Background

Niagara Mohawk is a transmission-owning public utility that has transferred

operational control of its transmission facilities to the NYISO. Solvay is a municipal

electrical utility located in the state of New York. The New York Power Authority

(“NYPA”) provides power and energy that are delivered to Solvay in accordance with the NYISO OATT utilizing facilities owned by National Grid.

National Grid and Solvay are parties to two existing interconnection agreements
that facilitate the deliveries of power and energy to Solvay, one filed with and accepted
by the Commission in Docket No. ER99-3170-000, and the other filed with and accepted
by the Commission in Docket No. ER03-1304-000. National Grid is currently
interconnected to Solvay at Solvay's Mathews Avenue substation, Industrial substation,
and Lakeland substation. Solvay is making modifications to its existing Industrial and
Mathews substations that will require modifications to National Grid’s facilities. In
connection with these modifications, National Grid and Solvay have entered into the

40 Sylvan Road, Waltham, MA 02451

 T: 781-907-2136  F: 781-907-5701  amanda.downey@nationalgrid.com  www.nationalgrid.com

The Honorable Kimberly D. Bose August 20, 2012

Page 2

Interconnection Agreement included in this filing to set forth their respective rights and obligations as to their current and modified interconnection arrangements, which are intended to supersede and replace the interconnection arrangements described in the interconnection agreements accepted in Docket Nos. ER99-3170-000 and ER03-1304-
000. Accordingly, on the same date as the instant filing, Niagara Mohawk is also filing with the Commission to cancel those two interconnection agreements.

II. Overview of the Interconnection Agreement

The Interconnection Agreement generally covers interconnection service provided
by Niagara Mohawk for specified interconnection facilities at Solvay’s Mathews Avenue
substation, Industrial substation, and Lakeland substation. The Interconnection
Agreement includes provisions covering an interconnection study and the operation and
maintenance of the interconnection facilities. Under the Interconnection Agreement,
interconnection service is provided on a contract basis, subject to all applicable
regulatory requirements. The Interconnection Agreement also contains standard contract
provisions such as provisions regarding insurance, payment of costs, and dispute
resolution.

Solvay agrees to reimburse Niagara Mohawk for specified costs incurred with
respect to the interconnection facilities. The Interconnection Agreement also sets forth
procedures to be used if the interconnection facilities must be retired or modified, for
termination, amendment, or modification of the Interconnection Agreement, and for
notices between Niagara Mohawk and Solvay. Other provisions govern metering and
losses, force majeure, liabilities and indemnification, choice of law, and other matters.
The Interconnection Agreement is to continue in effect for twenty (20) years.

III. Request for Waiver of Commission Notice Requirements

Pursuant to Section 35.11 of the Commission’s regulations (18 C.F.R. § 35.11), Niagara Mohawk respectfully requests waiver of Section 35.3 of the Commission’s
regulations (18 C.F.R. § 35.3) in order to permit the Interconnection Agreement to go
into effect as of June 18, 2012. Under Section 35.3(a)(2), service agreements are to be filed with the Commission not more than 30 days after service has commenced or such other date as may be permitted by the Commission. Granting the requested waiver is
appropriate because the June 18 effective date is consistent with the agreement of the
customer, as specified in the Interconnection Agreement, and no party will be harmed by granting that effective date. For these reasons, the Commission should grant Niagara
Mohawk’s request for waiver of the notice requirements.

Amanda C. Downey

Counsel for National Grid USA
Service Company, Inc.

40 Sylvan Road

Waltham, MA 02451 781-907-2136

amanda.downey@nationalgrid.com

William L. Malee

Director, Transmission Commercial New England Power Company,

A National Grid Company

40 Sylvan Road

Waltham, MA 02451 781-907-2422

bill.malee@us.ngrid.com

Sean Atkins

Bradley R. Miliauskas Alston & Bird LLP The Atlantic Building 950 F Street, NW

Washington, DC 20004 202-239-3300

sean.atkins@alston.com
bradley.miliauskas@alston.com

Copies of this filing have been served on Solvay, the NYISO, and the New York State Public Service Commission.

Please contact the undersigned with any questions. Thank you for this assistance in this matter.

Respectfully submitted,

/s/ Sean Atkins

Amanda C. DowneySean Atkins

CounselBradley R. Miliauskas

National Grid USAAlston & Bird LLP

Service Company, Inc.950 F Street, NW

40 Sylvan RoadWashington, DC 20004

Waltham, MA 02451

Counsel for Niagara Mohawk Power
Corporation d/b/a National Grid