10 Krey Boulevard  Rensselaer, NY  12144

March 18, 2016

By Electronic Delivery

Honorable Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE

Washington, DC 20426

Re:    Filing of an Executed Transmission Facility Interconnection Agreement Among
New York State Electric & Gas Corporation, Trans-Allegheny Interstate Line
Company, and the New York Independent System Operator, Inc.; and Request for
Waiver of the 60-Day Notice Period; Docket No. ER16-___000

Dear Ms. Bose:

Pursuant to Section 205 of the Federal Power Act1 and Section 35.12 of the

Commission’s regulations,2 New York State Electric & Gas Corporation (“NYSEG”), Trans-
Allegheny Interstate Line Company (“TrAILCo”), and the New York Independent System
Operator, Inc. (“NYISO”) hereby tender for filing a transmission facility interconnection
agreement (“Interconnection Agreement”) between and among NYSEG, TrAILCo, and the
NYISO (collectively, the “Parties”) that was executed on March 16, 2016.  The Interconnection Agreement is labeled as Service Agreement No. 2257 under the NYISO’s Open Access
Transmission Tariff (“OATT”).3

As described in Part I below, the Interconnection Agreement concerns the construction
and interconnection of a substation, which will be owned by TrAILCo and under the operational
control of PJM Interconnection, L.L.C. (“PJM”), with a transmission line owned by NYSEG and
under the operational control of the NYISO.  Given that PJM has indicated that the substation is
required to be in-service within a limited time frame to address a reliability need identified by
PJM, the Commission has granted TrAILCo a one-time waiver from the requirement that its

project be evaluated under the NYISO’s Standard Large Facility Interconnection Procedures set
forth in Attachment X (Section 30) of the OATT.4  Instead, the project was evaluated under the

1 16 U.S.C. § 824d (2014).

2 18 C.F.R. § 35.12 (2014).

3 The NYISO files New York Transmission Owners’ wires-to-wires interconnection agreements
with the Commission on behalf of New York Transmission Owners with a NYISO Services Agreement
number.  See, e.g., New York Independent System Operator, Inc., and Consolidated Edison Company of
New York, Inc., Letter Order, Docket No. ER15-1845-000 (July 17, 2015) (accepting Transmission
Owners’ interconnection agreement filed by the NYISO with a NYISO Services Agreement number).

4 See PJM Interconnection, L.L.C and Trans-Allegheny Interstate Line Company, Order Granting
Tariff Waiver Request, 144 FERC ¶ 61,060 (2013) (“TrAILCo Waiver Order”).  The facilities subject to

Honorable Kimberly D. Bose March 18, 2016

Page 2

NYISO’s transmission expansion process contained in Section 3 of the OATT.  As a result of the waiver, TrAILCo’s project was not generally subject to the NYISO’s interconnection process requirements, and TrAILCo and NYSEG are not required to enter into the pro forma Large
Generator Interconnection Agreement (“Pro Forma LGIA”) contained in Attachment X.
However, given these unique circumstances, TrAILCo, NYSEG, and NYISO agreed that it was appropriate for the NYISO to be a party to the Interconnection Agreement.

The Parties respectfully request that the Commission accept the Interconnection

Agreement for filing.5  While the interconnection is not subject to terms of the Pro Forma LGIA, the Interconnection Agreement developed by the Parties is generally consistent with the Pro Forma LGIA as described in Part II below.  The Commission has previously accepted a similar interconnection agreement for a transmission facility filed by Parties under comparable
circumstances.6  Further, as described in Part III of this letter, the Parties respectfully request a waiver of the Commission’s prior notice requirements7 to make the Interconnection Agreement effective as of March 19, 2016, which is the date following the date of filing.

I.BACKGROUND

TrAILCo is constructing a substation in Smethport, Pennsylvania that is required under
PJM’s Regional Transmission Expansion Plan to address a reliability need (“Pierce Brook
Substation”).  Once constructed, the Pierce Brook Substation will be under the operational
control of PJM.  The New York State Transmission System operated by the NYISO expands into
Pennsylvania via a 345 kV transmission line owned by NYSEG that currently runs from the
Homer City Substation in Pennsylvania to the Stolle Road Substation in New York.  Niagara
Mohawk Power Corporation d/b/a National Grid (“National Grid”) has separately constructed a
substation (“Five Mile Road Substation”) that is interconnected with the Homer City to Stolle
Road 345 kV line.  The Pierce Brook Substation will interconnect to the 345 kV line between
Homer City and National Grid’s Five Mile Road Substation (“HC - FMR Line”). 8 The Pierce
Brook Substation will electrically bifurcate the HC-FMR Line into two segments that are both
owned by NYSEG and operated by the NYISO as part of the New York State Transmission

the Interconnection Agreement were previously referred to as the “Farmers Valley” project at the time of
the TrAILCo Waiver Order, as the new facilities were planned to be constructed near the existing Farmers
Valley substation.  The project subsequently moved approximately two miles to a new site called Pierce
Brook.

5 TrAILCo and PJM will be separately filing the Interconnection Agreement with PJM Service Agreement No. 4368.

6 See New York Independent System Operator, Inc., Letter Order, Docket No. ER15-2398-000 (September 18, 2015) (“Mainesburg Order”).

7 See Prior Notice and Filing Requirements Under Part II of the Federal Power Act, 64 FERC ¶ 61,139, clarified, 65 FERC ¶ 61,081 (1993).

8 The Parties will coordinate with National Grid and PJM to develop mutually agreeable

operating protocols that will address, among other things, routine switching and relay settings for the operation of the Pierce Brook Substation.

Honorable Kimberly D. Bose March 18, 2016

Page 3

System: (i) the Five Mile Road Substation to Pierce Brook Substation segment, and (ii) the Pierce Brook Substation to Homer City Substation segment.

The NYISO’s OATT contains both a transmission expansion process in Section 3 of the
OATT and an interconnection process in Attachment X of the OATT.  When the Pierce Brook
Substation project was introduced (then known as the Farmers Valley project), the NYISO
determined that it did not fit within the definition of projects eligible to be evaluated under the
transmission expansion process.  For this reason, the NYISO determined that the project had to
be evaluated pursuant to its interconnection process in Attachment X.  PJM and TrAILCo raised
concerns regarding the timing to complete the interconnection process given the short time frame
for resolving the reliability need identified by PJM.  They requested that the Commission grant a
one-time, limited waiver of the NYISO tariff requirements to permit the substation to be
evaluated under the transmission expansion process.9  Due to the impending reliability need, the
Commission granted the requested limited, one-time waiver,10 and the NYISO performed a
System Impact Study for the project under the transmission expansion process requirements set
forth in Section 3 of the OATT.

As a result of the granted waiver, the TrAILCo project was not required to proceed

through the NYISO’s Standard Large Facility Interconnection Procedures set forth in

Attachment X. However, TrAILCo, NYSEG, and NYISO agreed that it was appropriate for the NYISO to be a party to the Interconnection Agreement because, were it not for the limited, onetime interconnection process waiver granted here, the NYISO would be required by its OATT to be a party to the Interconnection Agreement, which governs the rates, terms, and conditions
regarding the interconnection of the Pierce Brook Substation to the New York State
Transmission System.11  While the Parties were not required to enter into the Pro Forma LGIA, the Interconnection Agreement developed by the Parties is generally consistent with the Pro
Forma LGIA as described in Part II below.12

II. DESCRIPTION OF INTERCONNECTION AGREEMENT

The rates, terms, and conditions of the Interconnection Agreement were agreed to by the
Parties and are generally consistent with the Pro Forma LGIA.  The primary differences between
the Interconnection Agreement and the Pro Forma LGIA reflect: (i) the unique circumstances of
the agreement, which addresses the interconnection of transmission facilities operated by PJM

9 TrAILCo Waiver Order at PP 2-6.

10 TrAILCo Waiver Order at PP 12-17.

11 The Parties took the same approach in developing a three-party interconnection agreement for the Mainesburg Substation, which was also a TrAILCo owned and PJM operated substation that
interconnected to a transmission line owned by NYSEG and operated by the NYISO.  The Commission accepted this approach.  See Mainesburg Order.

12 As the Parties are not subject to the terms of the Pro Forma LGIA, the Interconnection

Agreement is not subject to the Commission’s high standard for accepting variations from the Pro Forma
LGIA.

Honorable Kimberly D. Bose March 18, 2016

Page 4

with those operated by the NYISO: and (ii) the application of the agreement to transmission facilities, rather than generation facilities.  Key differences include:

 The Interconnection Agreement specifies TrAILCo’s and NYSEG’s responsibilities for

the design, construction, ownership, operation and maintenance of the System Upgrade
Facilities that interconnect the Pierce Brook Substation to the HC-FMR Line that is part
of the New York State Transmission System.  For this reason, the Interconnection
Agreement does not include developer’s options for performing such work.  In addition,
as the facilities to be constructed under the Interconnection Agreement are defined as
System Upgrade Facilities, references to Attachment Facilities have been removed.

 The Interconnection Agreement does not include the provisions in the Pro Forma LGIA

that are specific to the interconnection of a generating facility, as the agreement concerns transmission facilities.

 The Interconnection Agreement enables NYSEG to direct TrAILCo, on its own or at the

NYISO’s direction, to perform certain operations at the Pierce Brook Substation in the
event of an Emergency, to ensure that the NYISO and NYSEG have sufficient
operational control over the segment of the HC-FMR Line that is bound by the Pierce
Brook and Homer City substations, which are both under the operational control of PJM.

 The Interconnection Agreement includes metering, communication, operating, system

protection, outage, and emergency state requirements that differ in part from the Pro

Forma LGIA to address the fact that the interconnection connects transmission facilities
under the separate operational control of the NYISO and PJM, which have different
technical requirements that must be satisfied by the appropriate transmission owner.

 Unlike the Pro Forma LGIA, the Interconnection Agreement does not include references

to the NYISO’s interconnection studies in Attachment X of the OATT as the Pierce Brook Substation was not evaluated under that process.

 The Interconnection Agreement includes specific requirements associated with ensuring

that the HC-FMR Line is placed back in-service in the event of issues with the

interconnection of the Pierce Brook Substation or in response to the disconnection of the Pierce Brook Substation.

 PJM was added as a signatory to the Interconnection Agreement consistent with

Commission precedent to ensure that it is kept fully apprised of the matters addressed

herein, so that it may be kept aware of any reliability and planning issues that may arise.13

Additional differences agreed upon by Parties to reflect the unique circumstance of the

interconnection.

13 See American Electric Power Service Corporation, 112 FERC ¶ 61,128 at P 10 (2005).

Honorable Kimberly D. Bose March 18, 2016

Page 5

The Parties respectfully request that the Commission accept the Interconnection Agreement for filing.

III. EFFECTIVE DATE AND REQUEST FOR WAIVER

The Parties request an effective date of March 19, 2016, for the Interconnection

Agreement, which is the day following the date of this filing.  The Parties respectfully request that the Commission waive its prior notice requirement to permit the requested effective date. The Commission has previously granted waivers of its prior notice requirements to permit the requested effective dates for executed interconnection agreements.14

IV.    COMMUNICATIONS AND CORRESPONDENCE

Communications regarding this filing should be directed to:
For the NYISO15

Robert E. Fernandez, General Counsel
Karen Georgenson Gach, Deputy General Counsel

*Christopher R. Sharp, Compliance Attorney
New York Independent System Operator, Inc.

10 Krey Boulevard

Rensselaer, NY 12144
Tel: (518) 356-6000
Fax: (518) 356-4702

csharp@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

14 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).

15 The Parties respectfully request waiver of 18 C.F.R. § 385.203(b)(3) (2014) to permit service on counsel in multiple locations.

Honorable Kimberly D. Bose March 18, 2016

Page 6

For NYSEG:

*Jeffrey A. Rosenbloom

Director, NY Legal Services

New York State Electric & Gas Corporation
c/o Rochester Gas and Electric Corporation

89 East Avenue

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

jeffrey_rosenbloom@rge.com

For TrAILCo:

*P. Nikhil Rao Attorney

FirstEnergy Corp.

76 South Main Street
Akron, Ohio 44308
Tel: (330) 384-2422

pnrao@firstenergycorp.com

Counsel for the Applicants

*Designated to receive service.

V.DOCUMENTS SUBMITTED

Nicholas A. Giannasca *Carlos E. Gutierrez

Davis Wright Tremaine LLP

1251 Avenue of the Americas, 21st Floor New York, NY 10020-1104

Tel: (212) 603-6402

NicholasGiannasca@dwt.com cgutierrez@dwt.com

Counsel for the Applicants

The NYISO submits the following documents:  this filing letter;

 a clean version of the Interconnection Agreement (Attachment I);

 a blacklined version of the Interconnection Agreement showing the differences from
the body of the Pro Forma LGIA (Attachment II); and

 the signature pages for the Interconnection Agreement (Attachment III).

Honorable Kimberly D. Bose March 18, 2016

Page 7

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 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 Parties respectfully request that the Commission accept the
Interconnection Agreement for filing with an effective date of March 19, 2016.

Respectfully submitted,

/s/  Christopher R. Sharp

Christopher R. Sharp Counsel for the

New York Independent System Operator, Inc.

/s/  Jeffrey A. Rosenbloom

Jeffrey A. Rosenbloom Counsel for

New York State Electric & Gas Corporation

/s/  Carlos E. Gutierrez

Carlos E. Gutierrez Counsel for

Trans-Allegheny Interstate Line Company