Amanda C. Downey

Counsel

February 4, 2015

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. ER15-___-000

Interconnection Agreement with Village of Boonville

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 for
Commission acceptance an Interconnection Agreement (“IA”) between National Grid
and the Village of Boonville (“Boonville”). The attached IA (the “Boonville IA”) is
designated as Service Agreement No. 2204 under the New York Independent System
Operator Corporation’s (“NYISO”) Open Access Transmission Tariff (“OATT”).

National Grid requests that the Commission grant waiver of its notice requirement
and accept the Boonville IA effective as of the date it was executed, January 15, 2015.

I.Background

Niagara Mohawk Power Corporation d/b/a National Grid is a public utility

subsidiary of National Grid USA serving retail electric customers in New York. National
Grid is an owner of transmission facilities subject to the operational control of the
NYISO.

Boonville is a municipal corporation located in New York that owns and operates a load-serving municipal electric system interconnected to the transmission system of National Grid. Boonville takes transmission service under the NYISO OATT. National Grid and Boonville are not parties to any prior interconnection agreement.

The Honorable Kimberly Bose February 4, 2015

Page 2

Niagara Mohawk Power Corporation d/b/a National Grid is interconnected to 29
municipal electric systems in the State of New York. The majority of these municipal
interconnections are not governed by any existing interconnection agreement. National
Grid has, however, entered into and received Commission acceptance of certain
interconnection agreements with a small number of New York municipal electric systems
in the past, in particular the Interconnection Agreement between National Grid and the
Village of Solvay, New York (“Solvay IA”) accepted by the Commission in Docket No.
ER03-1304-000.

In recent years, National Grid determined that it would be beneficial to develop a standard municipal interconnection agreement that will document terms and conditions related to the interconnection of the National Grid system and a number of municipal electric systems in New York. Among other things, such a standard municipal
interconnection agreement will allow the parties to document certain terms and
conditions related to the interconnection of their respective systems and the manner by which National Grid and the interconnected municipal will coordinate to ensure the
ongoing reliability of the New York State Transmission System.

National Grid developed a draft of such a standard New York municipal

interconnection agreement incorporating elements of both the Solvay IA and the pro

forma Large Generator Interconnection Agreement set forth in Appendix 6 of Attachment X to the NYISO OATT. National Grid then engaged in negotiations over a number of
years with the Municipal Electric Utilities Association of New York State (“MEUA”) to further refine the standard municipal interconnection agreement to address the particular needs of New York municipal electric systems.3 In late 2014, National Grid provided a final draft of the standard municipal interconnection agreement to the NYISO.4 The
NYISO requested a number of minor modifications to the agreement, which were agreed to by both National Grid and the MEUA.

The Village of Boonville is a member of the MEUA. The Boonville IA is the first
agreement filed with the Commission based on the final negotiated standard municipal
interconnection agreement. The negotiation of the Boonville IA was triggered by recent
work to study improvements to the interconnection of the Boonville municipal electric
system to the transmission system of National Grid. National Grid intends to use the
Boonville IA as the template for all future interconnection agreements with New York
municipal electric systems, recognizing that minor modifications from this template may
be appropriate in some circumstances to reflect the needs of individual municipal electric
systems.

The Honorable Kimberly Bose February 4, 2015

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II.The Boonville IA

The Boonville IA documents terms and conditions related to the interconnection of the National Grid and Boonville systems and the manner in which National Grid and Boonville will coordinate to ensure the ongoing reliability of the New York State
Transmission System.5 The following discussion addresses some of the more significant elements of the IA. The Boonville IA is to become effective as of the date of execution (i.e., January 15, 2015) and remain in effect for twenty years.6

Article II of the Boonville IA sets forth general terms and conditions under which the Boonville system is interconnected to and operates in parallel with the National Grid transmission system. This Article, along with Exhibit A, defines the respective
Interconnection Facilities of the Parties. Section 2.5 provides that Boonville and National Grid shall each be responsible for protection of their respective facilities consistent with Good Utility Practice and Applicable Reliability Standards. National Grid expects that
individual protection arrangements may be advisable for other interconnected municipal electric systems in certain circumstances.

Article III sets forth general representations and warranties of the Parties.

Section 4.1.1 makes it clear that the provisions of the Boonville IA (including Article IV) addressing the design, engineering, procurement, and construction of
Interconnection Facilities and Upgrades shall apply to the Interconnection Facilities and the Upgrades associated with any new, modified, or upgraded delivery point. Section 4.4 governs the respective access rights of the Parties.

Section 5.1 governs the operation and maintenance of the Interconnection

Facilities and provides for National Grid and Boonville to confer regularly to coordinate the planning, scheduling and performance of preventive and corrective maintenance on the Interconnection Facilities.

Section 5.4.2.3 of the Boonville IA requires that, if any required National Grid
Interconnection Facility or Transmission System upgrades are the result of a load
interconnection to the Boonville system, Boonville must “reimburse National Grid for all
actual costs and expenses of studying and constructing, operating, and maintaining the
Transmission System upgrades to the extent consistent with FERC policy.” The
Boonville IA also provides that if upgrades to the National Grid transmission system or
National Grid interconnection facility are required as a result of a proposed generator
interconnection or increase in generator capacity to the Boonville system, such upgrades
will be performed by National Grid “at the expense of either [Boonville] to the extent
consistent with FERC policy or the owner of the Generator, consistent with Attachment S
to the NYISO OATT.”7 Accordingly, these cost allocation provisions under the

The Honorable Kimberly Bose February 4, 2015

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Bonneville IA will be applied consistent with Commission policy or Attachment S to the NYISO OATT if upgrades are required due to a proposed interconnection or increase in generator capacity.

Article VI addresses metering issues and the treatment of losses.

Article VII governs emergency operations. Section 7.1 obligates both Parties to
comply with the Emergency State procedures of the NYISO, the Applicable Reliability
Councils, Applicable Laws and Regulations, and any emergency procedures agreed to by
the NYISO Operating Committee. Section 7.2 establishes procedures for each Party to
notify the other in emergency conditions. Although the NYISO is not a party to the
Boonville IA, Section 7.4 makes it clear that both National Grid and the NYISO have the
authority to take certain actions during emergency conditions. Section 7.5, similarly,
establishes the authority of Boonville to take certain actions during emergency
conditions.

Article VIII establishes insurance requirements for both Parties. Article IX

governs compliance with laws, including environmental laws. Article X governs

invoicing and cost payments under the agreement. Section 10.2.2 provides that Boonville shall be responsible for costs incurred by National Grid for the operation, maintenance, and repair of National Grid interconnection facilities. Any charges assessed by National Grid under the Boonville IA will be just and reasonable because they will be based on
National Grid’s actual costs.8

The remaining provisions of the IA are standard provisions for interconnection agreements reflecting terms and conditions for force majeure, notice, indemnification, amendments, and numerous other matters that the Commission has accepted in many comparable agreements.

III.Effective Date

Section 35.3 of the Commission’s regulations allows a utility to file service

agreements not more than 30 days after service under the agreements has commenced.9
The Boonville IA was entered into on January 15, 2015. The Parties have agreed that the
IA “shall become effective as of the date first above written (the ‘EFFECTIVE DATE’),
subject to its approval or acceptance for filing by the FERC (if applicable).”10 Granting
the requested effective date will permit the Boonville IA to become effective as of the

The Honorable Kimberly Bose February 4, 2015

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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 January 15, 2015.

IV.Documents Enclosed

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

i.The Boonville IA (Service Agreement No. 2204 under the NYISO

OATT), provided in clean format (Attachment A)

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. Downey
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 National Grid USA

40 Sylvan Road

Waltham, MA 02451 (781) 907-2422

bill.malee@nationalgrid.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

The Honorable Kimberly Bose February 4, 2015

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VI.Conclusion

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

Commission accept the Boonville IA effective as of January 15, 2015.

Respectfully submitted,

/s/ Amanda C. Downey/s/ Sean Atkins

Amanda DowneySean Atkins

CounselAlston & Bird LLP

National Grid USAThe Atlantic Building

Service Company, Inc.950 F Street, NW

40 Sylvan RoadWashington, DC 20004

Waltham, MA 02451

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