10 Krey Boulevard Rensselaer, NY 12144
July 27, 2015
By Electronic Delivery
Honorable Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE
Washington, DC 20426
Re: Filing of an Executed Small Generator Interconnection Agreement Among the
New York Independent System Operator, Inc., Niagara Mohawk Power
Corporation d/b/a National Grid, and Monroe County, New York; and Request for Waiver of 60-Day Notice Period; Docket No. ER15-___-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 Niagara Mohawk Power Corporation d/b/a National Grid (“National Grid”) (collectively, the
“Joint Filing Parties”) hereby tender for filing an executed Small Generator Interconnection
Agreement (“Interconnection Agreement”) as Service Agreement No. 2219 among the NYISO, National Grid as the Connecting Transmission Owner, and Monroe County, New York (“Monroe County”) as the Interconnection Customer.3
The Joint Filing Parties respectfully request that the Commission accept the
Interconnection Agreement for filing. With the limited exception described in Part II of this
letter, the Interconnection Agreement conforms to the NYISO’s pro forma Small Generator
Interconnection Agreement (“Pro Forma SGIA”) that is contained in Attachment Z to the
NYISO’s Open Access Transmission Tariff (“OATT”). Further, as described in Part III 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 July 13, 2015, which is the
date of its execution.
1 16 U.S.C. § 824d (2014).
2 18 C.F.R. § 35.12 (2014).
3 Capitalized terms not otherwise defined in this letter have the meaning set forth in Attachments S, X and Z of the NYISO’s Open Access Transmission Tariff (“OATT”).
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 July 27, 2015
Page 2
I.Background
The Interconnection Agreement governs the interconnection of Monroe County’s landfill gas-to-energy generation facility (“Facility”) located in Riga, New York. Monroe County
currently operates the Facility at a capacity of 6.4 MW under an agreement with National Grid
that pre-dates the NYISO’s interconnection procedures. The existing 6.4 MW Facility consists
of eight Caterpillar 800 kW 3516 generators. Monroe County is expanding the Facility to 9.6
MW by installing two Caterpillar 1600 kW 3520 generators in a separate structure. The Point of Interconnection for the Facility is the point at which it interconnects to National Grid’s
Caledonia-Churchville 34.5 kV Line #201 at Pole 610, approximately 8.42 miles from Caledonia Substation and 0.65 miles from Churchville Substation, as depicted on the one-line diagram in
Attachment 3 of the Interconnection Agreement.
II. Variations From the NYISO’s Pro Forma SGIA
The Interconnection Agreement conforms with the Pro Forma SGIA with one minor
modification agreed to by the Parties that is necessary to reflect the unique circumstances
concerning the Capacity Resource Interconnection Service (“CRIS”) rights for the expanded
Facility. The existing Facility has a CRIS value of 6.4 MW. Monroe County did not elect for
the NYISO to evaluate under its Class Year Facilities Study process the additional capacity
created by the Facility’s expansion to 9.6 MW. For this reason, the Facility’s CRIS value will be
limited to 6.4 MW, unless and until the CRIS value is modified under the applicable provision of
the NYISO’s OATT. The Parties modified Section 1.3.1 and Appendix C of the Interconnection
Agreement to reflect that the CRIS value for the expanded Facility remains at 6.4 MW.
The Commission has accepted variations from a pro forma interconnection agreement
where operational concerns or other factors necessitate the changes, including reliability
concerns, novel legal issues, or other unique circumstances.5 The Joint Filing Parties submit that
the modification to the Interconnection Agreement satisfies the Commission’s standard for
variations from the Pro Forma SGIA, because unique circumstances exist that require the
modified language. In fact, this particular non-conforming modification to the Pro Forma SGIA
is substantially similar or identical to modifications previously accepted by the Commission.6
As with prior Commission-approved Small Generator Interconnection Agreements containing
this non-conforming provision, Monroe County’s election to have the Facility’s uprate studied
only for Energy Resource Interconnection Service and not for deliverability in the NYISO
interconnection process is a specific circumstance that requires modification of the Pro Forma
SGIA. Therefore, the Joint Filing Parties respectfully request that the Commission accept the
Interconnection Agreement with this limited non-conforming change.
5 See Order No. 2006 at P 562; see also Midwest Independent Transmission System Operator, Inc., 111 FERC ¶ 61,421 at P 11 (2005) (citing Order No. 2003 at PP 913-15); PJM Interconnection, LLC, 111 FERC ¶ 61,163 at PP 10-11, reh’g denied, 112 FERC ¶ 61,282 (2005).
6 See e.g., New York Independent System Operator, Inc. and New York State Electric & Gas, Letter Order, Docket No. ER12-2410-000 (October 1, 2012); New York Independent System Operator, Inc. and National Grid, Letter Order, Docket No. ER12=2045-000 (August 8, 2012).
Honorable Kimberly D. Bose July 27, 2015
Page 3
III. Proposed Effective Date and Request for Waiver of the 60-Day Notice Period
The Joint Filing Parties request an effective date of July 13, 2015 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.7
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 Niagara Mohawk d/b/a National Grid
*William L. Malee*Amanda C. Downey
Director, Transmission CommercialCounsel for National Grid USA
National GridService Company, Inc.
40 Sylvan Road40 Sylvan Road
Waltham, MA 02451Waltham, MA 02451
Tel: 781-907-2422Tel: 781-907-2136
7 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).
Honorable Kimberly D. Bose July 27, 2015
Page 4
Fax: 781-907-5707Fax: 781-907-5701
Bill.Malee@nationalgrid.comAmanda.Downey@nationalgrid.com
*Designated to receive service.
V.Documents Submitted
The NYISO submits the following documents along with the filing letter:
• a clean version of the Interconnection Agreement (“Attachment I”);
• a blacklined version showing the changes between the Pro Forma SGIA and the
Interconnection Agreement (“Attachment II”); and
• the signature pages for the Interconnection Agreement (“Attachment III”).
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 documents included with this filing will be posted on the NYISO’s website at
www.nyiso.com.
VII. Conclusion
Wherefore, the Joint Filing Parties respectfully request that the Commission accept the Interconnection Agreement effective as of July 13, 2015.
Respectfully submitted,
/s/ Sara B. Keegan
Sara B. Keegan
Counsel for the
New York Independent System Operator, Inc.
/s/Amanda C. Downey
Amanda C. Downey
Counsel for Niagara Mohawk Power Corporation d/b/a National Grid
