Amanda C. Downey

Counsel

July 10, 2015

The Honorable Kimberly D. Bose Secretary

Federal Energy Regulatory Commission 888 First Street, NE

Washington, DC 20426

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

Docket No. ER15-___-000

Filing of Amended Cost Reimbursement Agreement with

Rochester Gas and Electric Corporation 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
Cost Reimbursement Agreement (“Amended Reimbursement Agreement”) between
National Grid and Rochester Gas and Electric Corporation (“RG&E”).3 The Amended
Reimbursement Agreement is designated as National Grid Service Agreement No. 2135
under the New York Independent System Operator, Inc.’s (“NYISO”) Open Access
Transmission Tariff (“OATT”).

The Amended Reimbursement Agreement is an undisputed agreement to facilitate the performance of certain work that RG&E has requested National Grid to perform with respect to specified stations and related portions of transmission lines/circuits and
equipment as described in the Amended Reimbursement Agreement. National Grid
respectfully requests that the Commission grant waiver of its notice requirement to permit the Amended Reimbursement Agreement to go into effect as of May 29, 2015, the
effective date agreed to by the Parties.

16 U.S.C. § 824d.

18 C.F.R. Part 35.
Together, National Grid and RG&E are referred to in the Amended Reimbursement Agreement

The Honorable Kimberly D. Bose July 10, 2015

Page 2

I.Background

National Grid and RG&E are both public utilities subject to the Commission’s jurisdiction that own transmission facilities located in New York and that have placed their facilities under the operational control of the NYISO.

National Grid and RG&E entered into the Original Reimbursement Agreement to
facilitate the work that RG&E had requested National Grid to perform with respect to
National Grid’s Mortimer Station, Station 251, and related portions of transmission
lines/circuits and equipment located inside the property line of the substation in order for
RG&E to build a new substation to supply the University of Rochester. The Commission
accepted the Original Reimbursement Agreement for filing effective March 31, 2014.4

Since the Commission accepted the Original Reimbursement Agreement for

filing, RG&E has requested changes to the existing scope of work under that agreement to include an upgrade of Mortimer Station that will enable the station to handle a 400 megavolt-ampere (MVA) summer normal and 640 MVA long time emergency rating due to RG&E’s re-conductoring of line 901.

II. The Amended Reimbursement Agreement

The Parties have revised the following provisions in the Amended

Reimbursement Agreement to reflect the changes to the existing scope of work:

• Exhibit A and the annexes thereto (setting forth the scope of work);

• Exhibit B (setting forth the proposed milestone schedule);

• Section 6.1 and Exhibit D (setting forth the estimated cost breakdown); and

• Section 7.1 (setting forth provisions regarding RG&E’s payment or
reimbursement of costs to National Grid).

Commission Letter Order, Docket No. ER14-2506-000 (Sept. 3, 2014).

The Honorable Kimberly D. Bose July 10, 2015

Page 3

As is true under the Original Reimbursement Agreement, National Grid is

performing services at actual cost as set forth in Articles 1.0 and 7.0 to the Amended

Reimbursement Agreement. The Commission should find the price of the services to be performed pursuant to the Amended Reimbursement Agreement to be just and reasonable because National Grid will perform these services at actual cost.5

III. Effective Date and Request for Waiver

Pursuant to section 35.11 of the Commission’s regulations,6 National Grid

respectfully requests waiver of the notice requirement contained in section 35.3 of the

Commission’s regulations7 to allow the Amended Reimbursement Agreement to become effective as of May 29, 2015, the effective date agreed to by the Parties.8

Good cause exists for the Commission to grant this waiver. Granting the waiver
will accord with the intent of National Grid and RG&E to make the Amended
Reimbursement Agreement effective as of May 29, 2015. Therefore, no prejudice will
result to any party from granting the waiver. Further, National Grid and RG&E have
agreed to preliminary projected milestones that anticipate completion of the work
pursuant to the Amended Reimbursement Agreement in 2016.9 For these reasons, the
Commission should find that good cause exists to grant an effective date of May 29,
2015.

IV.Attachments

In addition to this transmittal letter, this filing includes the following attachments:

• Clean version of the Amended Reimbursement Agreement (Attachment A);

• A document showing in red-line the differences between the Original

Reimbursement Agreement and the Amended Reimbursement Agreement (Attachment B); and

5Section 7.1 of the Amended Reimbursement Agreement provides that National Grid will invoice

RG&E for an additional prepayment of $500,000 (“Additional Prepayment”) and RG&E will pay the

Additional Prepayment within 30 days of the invoice due date; however, National Grid has not yet invoiced

RG&E for the Additional Prepayment.

18 C.F.R. § 35.11.

18 C.F.R. § 35.3.

See the agreement between the Parties contained in Attachment C to this filing.
Pursuant to the projected milestone schedule listed in Exhibit B to the Amended Reimbursement

The Honorable Kimberly D. Bose July 10, 2015

Page 4

• An agreement between the Parties to revise the Original Reimbursement

Agreement as reflected in the Amended Reimbursement Agreement (Attachment

C).

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:

Amanda C. DowneySean A. Atkins

CounselBradley R. Miliauskas

National Grid USAAlston & Bird LLP

Service Company, Inc.The Atlantic Building

40 Sylvan Road950 F Street, NW

Waltham, MA 02451Washington, DC 20004

(781) 907-2136(202) 239-3300

amanda.downey@nationalgrid.comsean.atkins@alston.com

bradley.miliauskas@alston.com

William L. Malee

Director, Transmission Commercial National Grid USA

40 Sylvan Road

Waltham, MA 02451 (781) 907-2422

bill.malee@nationalgrid.com

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

The Honorable Kimberly D. Bose July 10, 2015

Page 5

VI.Conclusion

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

Commission accept the Amended Reimbursement Agreement effective as of May 29,
2015.

Respectfully submitted,

/s/ Amanda C. Downey

Amanda C. 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