Amanda C. Downey
Counsel
May 19, 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
Filing of Amended Interconnection Agreement with General Mills Operations Inc. 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
Interconnection Agreement (“Interconnection Agreement”) with General Mills
Operations, LLC (“General Mills”).3 The enclosed Interconnection Agreement amends
the original Interconnection Agreement already on file with the Commission to extend its
term, update outdated references, and make minor clarifying changes and corrections.
National Grid requests waiver of the Commission’s prior notice requirement to permit the
amended Interconnection Agreement to go into effect as of April 1, 2015.
I.Background
The Interconnection Agreement sets forth the terms under which National Grid
provides interconnection service to General Mills. The Commission accepted the original
Interconnection Agreement effective as of October 5, 2004.4
1
2
3
16 U.S.C. § 824d.
18 C.F.R. Part 35.
This filing refers to National Grid and General Mills together as the parties to the Interconnection
4
Commission Letter Order, Docket No. ER05-57-000 (Dec. 13, 2004). The original
Interconnection Agreement is designated as Service Agreement No. 337 under the Open Access Transmission Tariff of the New York Independent System Operator, Inc. (“NYISO”).
40 Sylvan Road, Waltham, MA 02451
T: 781-907-2136 F: 781-907-5701 amanda.downey@nationalgrid.com www.nationalgrid.com
The Honorable Kimberly Bose May 19, 2015
Page 2
II. The Amended Interconnection Agreement
The parties have amended the Interconnection Agreement to make it effective
April 1, 2015 and extend its term through September 30, 2017.5 They have also amended the Interconnection Agreement to update outdated references and make minor clarifying changes and corrections.6
III. Effective Date and Request for Waiver
The Recitals to the amended Interconnection Agreement specify an effective date of April 1, 2015.7 Accordingly, National Grid respectfully requests that the amended Interconnection Agreement be permitted to go into effect as of April 1, 2015, and that the Commission grant waiver of the notice provisions in its regulations that require the filing of service agreements no more than 30 days after service has commenced.8
Granting the requested effective date will permit the amended Interconnection
Agreement 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 April 1.
IV.Documents Enclosed
In addition to this filing letter, attached are the following documents:
i.The amended Interconnection Agreement, provided in clean format
(Attachment A); and
ii. Black-lined revisions showing the amendments to the original
Interconnection Agreement (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:
5
Amended Interconnection Agreement, Recitals and Section 11.1. Although section 11.1 of the
original Interconnection Agreement states that it will continue in effect for ten years, the parties have
continued to follow the terms of the original Interconnection Agreement to the present day and have not
6
7
These amendments are shown in the black-lined revisions contained in Attachment B to this filing. See also amended Interconnection Agreement, Section 11.1 (stating that the amended
Interconnection Agreement “shall become effective as of the EFFECTIVE DATE, subject to its approval or acceptance for filing by the FERC”).
8
Specifically, pursuant to of Section 35.11 of the Commission’s regulations (18 C.F.R. § 35.11),
National Grid requests waiver of Section 35.3 of the Commission’s regulations (18 C.F.R. § 35.3).
The Honorable Kimberly Bose May 19, 2015
Page 3
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 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
Copies of this filing have been served on General Mills and the NYISO.
VI.Conclusion
For the reasons stated herein, National Grid respectfully requests that the
Commission accept the amended Interconnection Agreement contained in this filing effective April 1, 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
