Amanda C. Downey

Counsel

May 9, 2013

The Honorable Kimberly D. Bose Secretary

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

Washington, DC 20426

Re:Niagara Mohawk Power Corporation, d/b/a National Grid

Docket No. ER13-1077-001

Amendment to Large Generator Interconnection Agreement with Indeck-Yerkes Limited Partnership and

Request for Waiver of Commission Notice Requirement

Dear Secretary Bose:

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

Federal Energy Regulatory Commission’s (“Commission”) regulations,2 Niagara Mohawk Power Corporation d/b/a/ National Grid (“National Grid”) submits an amended Large
Generator Interconnection Agreement (“LGIA”) between National Grid and Indeck-Yerkes Limited Partnership (“Indeck-Yerkes”). The attached LGIA (the “Amended Indeck-Yerkes LGIA”) is designated as First Revised Service Agreement No. 1970 under the New York Independent System Operator, Inc.’s (“NYISO”) Open Access Transmission Tariff
(“OATT”). National Grid requests that the Commission accept the Amended Indeck-Yerkes LGIA effective as of the date it was executed, December 26, 2012.

I.Background

National Grid filed the original version of the Indeck-Yerkes LGIA in this

proceeding on March 13, 2013, with a requested effective date of December 26, 2012.

Subsequently, Commission Staff informed National Grid that the Indeck-Yerkes LGIA

needed to be amended to replace the term Network Access Interconnection Service, which is
no longer used in the NYISO OATT, with the terms Capacity Resource Interconnection
Service (“CRIS”) and Energy Resource Interconnection Service (“ERIS”), as defined in the
NYISO OATT.

II.The Amended Indeck-Yerkes LGIA

National Grid proposes to replace the term Network Access Interconnection Service

with the terms CRIS and ERIS in Articles 1, 4.1.1, 13.4.2, and 29.8 of the Indeck-Yerkes

The Honorable Kimberly Bose May 9, 2013

Page 2

LGIA. The Amended Indeck-Yerkes LGIA defines CRIS and ERIS using the same definitions of those terms set forth in Article 1 of Appendix 6 to Appendix X (Large Generator Interconnection Procedures) to the NYISO OATT.

III. Effective Date and Request for Waiver

Pursuant to Section 35.11 of the Commission’s regulations,3 National Grid

respectfully requests waiver of the requirement contained in Section 35.3 of the

Commission’s regulations to file service agreements not more than 30 days after service

under the agreements has commenced,4 in order to allow the Amended Indeck-Yerkes LGIA to become effective as of December 26, 2012.

The Parties have agreed that the Indeck-Yerkes LGIA “shall become effective upon
execution by the Parties, subject to acceptance by FERC.”5 The Parties executed the
Indeck-Yerkes LGIA on December 26, 2012. Granting the requested waiver will permit the
Amended Indeck-Yerkes LGIA to become effective as of the date agreed upon by the
Parties and will not result in prejudice to any party. For these reasons, the Commission
should find that good cause exists to grant an effective date of December 26, 2012.

18 C.F.R. § 35.11.

18 C.F.R. § 35.3.
Indeck-Yerkes LGIA, Article 2.1.

The Honorable Kimberly Bose May 9, 2013

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IV.Documents Enclosed

In addition to this filing letter, attached are the following documents:

i. The Amended Indeck-Yerkes LGIA (First Revised Service Agreement No.

1970 under the NYISO OATT), provided in clean format (Attachment A)

ii. Black-lined revisions showing the differences between the Amended Indeck-

Yerkes LGIA and the Indeck-Yerkes LGIA as originally filed in this proceeding on March 13, 2013 (Attachment B)

V.Communications and Service

Communications regarding this filing should be addressed to the following

individuals, whose names should be entered on the official service list maintained by the

Secretary for this proceeding:6

Amanda C. Downey
Counsel for National Grid

Service Company, Inc.

40 Sylvan Road

Waltham, MA 02451 (781) 907-2136

amanda.downey@nationalgrid.com

William L. Malee

Director, Transmission Commercial National Grid USA

40 Sylvan Road

Waltham, MA 02451 (781) 907-2422

bill.malee@nationalgrid.com

Sean A. 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

National Grid requests waiver of 18 C.F.R. § 385.203(b) to allow four persons to be added to the

The Honorable Kimberly Bose May 9, 2013

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VI.Conclusion

For the reasons stated herein, National Grid respectfully requests that the

Commission accept the Amended Indeck-Yerkes LGIA effective as of December 26, 2012.

Respectfully submitted,

/s/ Amanda C. Downey

Amanda Downey
Counsel

National Grid USA

Service Company, Inc.

40 Sylvan Road

Waltham, MA 02451

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