10 Krey Boulevard  Rensselaer, NY 12144

March 6, 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 Amended and Restated Small Generator Interconnection
Agreement Between the New York Independent System Operator, Inc. and
Rochester Gas and Electric Corporation, and Request for Waiver of the 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
Rochester Gas and Electric Corporation (“RG&E”) (collectively, the “Joint Filing Parties”)
hereby tender for filing an executed Amended and Restated Small Generator Interconnection
Agreement (“Amended Agreement”) as Service Agreement No. 1829 between the NYISO and
RG&E.3 The Joint Filing Parties respectfully request that the Commission accept the Amended
Agreement for filing. Further, as described in Part III of this letter, the Joint Filing Parties
respectfully request a waiver of the Commission’s 60-day notice requirement to make the
Amended Agreement effective as of February 19, 2015, the date the Amended Agreement was
executed.

I.Background

The Amended Agreement supersedes a Small Generator Interconnection Agreement
(“SGIA”) between the NYISO and RG&E that was filed in Docket No. ER12-1086-000 on
February 14, 2012, as Service Agreement No. 1829 (“Original Agreement”).4 The Original
Agreement was accepted by the Commission on March 22, 2012.5 While it substantially

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 New York Independent System Operator, Inc. and Rochester Gas and Electric Corporation, Filing of
Executed Small Generator Interconnection Agreement between the New York Independent System Operator, Inc.
and the Rochester Gas and Electric Corporation, Docket No. ER12-1086-000 (February 14, 2012) (“February 2012
Filing”).

5 New York Independent System Operator, Inc. and Rochester Gas and Electric Corporation, Letter Order, Docket No. ER12-1086-000 (March 22, 2012).

Honorable Kimberly D. Bose March 6, 2015

Page 2

conformed to the NYISO’s pro forma SGIA, the Original Agreement contained modifications

that converted the pro forma three-party agreement into a two-party agreement because RG&E is the owner and operator of the Small Generating Facility. For this reason, RG&E undertook
under the Original Agreement the responsibilities assigned to both the Connecting Transmission Owner and the Interconnection Customer under the pro forma SGIA.

As reflected in the Original Agreement, the Small Generating Facility, known as Brown’s Race, consists of a hydropower plant located at the base of the High Falls on the Genesee River in Rochester, New York (“Facility”). The Facility has been operated by RG&E since at least 1960 at a capacity of 6.5 MW. 6 The NYISO and RG&E filed the Original Agreement in
connection with modifications to the Facility that increased its capacity to 8.5 MW.7 The
Original Agreement specified that the Point of Interconnection would be located at the 11.5 kV bus tap at breaker 65202 of the RG&E Station 6 Substation.

Subsequent to the execution of the Original Agreement, RG&E proposed a two-phase set
of additional modifications to the Facility: (i) to relocate the Point of Interconnection for the
Facility, and (ii) to expand the Facility from 8.5 MW to 14.8 MW (“New Facility”). The
proposed modifications have been evaluated through the NYISO’s interconnection process.

II.Discussion of Changes

The Joint Filing Parties submit this Amended Agreement to reflect these modifications to the Facility. In addition, the Joint Filing Parties submit additional revisions that were agreed to by the Parties as part of the Amended Agreement. Specifically, the Amended Agreement reflects the following modifications:

• revisions to Attachments 2 and 6 to reflect the modifications to the Facility - specifically,
the relocation of the Point of Interconnection and the expansion of the Facility from 8.5
MW to 14.8 MW;

• updates to the one-line diagram in Attachment 3 to reflect the above-referenced
modifications to the Facility;

• updates to the milestones in Attachment 4;

• updates to RG&E’s technical requirements described in Attachment 5;

• revisions to Attachment 7 to clarify that the insurance requirements in that provision
apply to RG&E;

• modifications to reflect revisions to the NYISO’s pro forma SGIA that have been
approved by the Commission since the execution of the Original Agreement;

• updates to the NYISO’s contact information on page 1 and in Section 13.1; and

6 Additional details regarding the interconnection are found in Attachment 2 of the Amended Agreement.

7 As noted in the February 2012 Filing, there was no pre-existing interconnection agreement between the NYISO and RG&E prior to the Original Agreement because the plant was already in operation at the time the NYISO was formed. February 2012 Filing at p 1.

Honorable Kimberly D. Bose March 6, 2015

Page 3

• modifications to reflect that this is an “Amended and Restated” agreement.

The blacklined Amended Agreement attached to this filing shows all of these changes to the currently effective Original Agreement. The Joint Filing Parties respectfully request that the Commission accept this Amended Agreement.

III. Proposed Effective Date and Request for Wavier of the 60-Day Notice Period

The Joint Filing Parties request an effective date of February 19, 2015, for the Amended
Agreement, which is the date of 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.8

IV. Communications and Correspondence

Communications regarding this filing should be directed to:
For the NYISO9

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
skeegan@nyiso.com

*Ted J. Murphy

Hunton & Williams LLP
2200 Pennsylvania Avenue, NW Washington, D.C. 20037
Tel: (202) 955-1500

Fax: (202) 778-2201
tmurphy@hunton.com

*Michael J. Messonnier Jr. Hunton & Williams LLP 951 East Byrd Street

Richmond, VA 23219
Tel: (804) 788-8200
Fax: (804) 344-7999

mmessonnier@hunton.com

8 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).

9 The NYISO respectfully requests waiver of 18 C.F.R. § 385.203(b)(3) to permit service on counsel in both Washington, D.C. and Richmond, VA.

Honorable Kimberly D. Bose March 6, 2015

Page 4

For RG&E:

*Jeffrey A. Rosenbloom

Director, NY Legal Services and Assistant Secretary New York State Electric & Gas Corporation
Rochester Gas and Electric Corporation

89 East Avenue

Rochester, NY 14649
Tel: (585) 724-8132
Fax: (585) 724-8668

Jeffrey_rosenbloom@rge.com

*Designated to receive service.

V.Documents Submitted

The NYISO submits the following documents:

• this filing letter;

• a clean version of the Amended Agreement (Attachment I);

• a blacklined version showing the Amended Agreement’s changes from the Original
Agreement (Attachment II); and

• the signature pages for the Amended 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 Public 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 Amended Agreement effective as of February 19, 2015.

Honorable Kimberly D. Bose March 6, 2015

Page 5

Respectfully submitted,

/s/ Sara B. Keegan

Sara B. Keegan
Counsel for the

New York Independent System Operator, Inc.

/s/ Jeffrey A. Rosenbloom

Jeffrey A. Rosenbloom

Counsel for Rochester Gas and Electric Corporation