June 20, 2017

By Electronic Delivery

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

Washington, DC 20426

Re: Filing of an Executed Large Generator Interconnection Agreement Among the
New York Independent System Operator, Inc., Niagara Mohawk Power
Corporation d/b/a National Grid, and PSEG Power New York, LLC; Request for
Waiver of the 60-Day Notice Period; Docket No. ER17-____-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 Niagara Mohawk Power Corporation d/b/a National Grid (“National Grid”) (together, the “Joint Filing Parties”) hereby tender for filing an executed Large Generator Interconnection Agreement entered into by the NYISO, National Grid, as the Connecting Transmission Owner, and PSEG Power New York, LLC (“PSEG”), as the Developer (the “Interconnection Agreement”).3 The Interconnection Agreement is labeled as Service Agreement No. 2341 under the NYISO’s Open Access Transmission Tariff (“OATT”).

The Joint Filing Parties respectfully request that the Commission accept the

Interconnection Agreement for filing. With limited non-conforming exceptions that are

described and justified in Part I of this letter, the Interconnection Agreement conforms to the
NYISO’s pro forma Large Generator Interconnection Agreement (“Pro Forma LGIA”) that is
contained in Attachment X to the OATT. Further, as described in Part II of this letter, the Joint
Filing Parties respectfully request a waiver of the Commission’s prior notice requirements4 to
make the Interconnection Agreement effective as of June 7, 2017, which is the date of its
execution.

1 16 U.S.C. § 824d (2016).

2 18 C.F.R. § 35.12 (2016).

3 Capitalized terms that are not otherwise defined in this filing letter shall have the meaning

specified in Attachments S or X of the NYISO OATT, and if not defined therein, in the NYISO OATT and NYISO Market Administration and Control Area Services Tariff.

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

Honorable Kimberly D. Bose June 20, 2017

Page 2

I.Discussion

A.Background

PSEG currently operates a combined-cycle facility located in Bethlehem, New York

(“Facility”) under an interconnection agreement with National Grid that pre-dates the NYISO’s
interconnection procedures.5 The Facility is comprised of three GE 7FA gas combustion
turbines and one steam turbine and currently has net maximum generating capabilities of 763
MW (summer) and 853.8 MW (winter). PSEG is increasing the summer and winter capabilities
of the Facility by installing advanced gas path equipment on the three gas combustion turbines.
As a result of this upgrade to the Facility, the parties have entered into this Interconnection
Agreement for the Facility in place of the previous two-party agreement. After the upgrade, the
maximum generating capabilities of the Facility will be 835 MW (summer) and 905 MW
(winter). Additional details regarding the Facility can be found in Appendix C of the
Interconnection Agreement.

The Facility is currently interconnected to certain transmission facilities of National Grid. The Facility’s Points of Interconnection are at the connections to the 115 kV switchyard bus in the Albany Steam Station. Figure A-1 of Appendix A of the Interconnection Agreement
provides a one-line diagram showing the Point of Interconnection.

B. The Interconnection Agreement Closely Conforms to the Pro Forma LGIA

Contained in Attachment X of the NYISO OATT

The Interconnection Agreement was executed on June 7, 2017 by the NYISO, National
Grid, and PSEG. The Interconnection Agreement follows the language in the Pro Forma LGIA
contained in Attachment X of the NYISO OATT with limited exceptions. The Interconnection
Agreement contains two limited variations from the Pro Forma LGIA that are described in this
Part I.B. These variations are necessary to address the unique circumstances of this
interconnection and to accurately describe the operational control of the attachment facilities and
upgrades associated with the Facility. The Joint Filing Parties submit that the change specified
below satisfies the Commission’s standard for variations from the Pro Forma LGIA, because
unique circumstances exist that require a non-conforming agreement.6 Therefore, the Joint
Filing Parties respectfully request that the Commission accept the Interconnection Agreement
with the limited non-conforming changes.

5 See Niagara Mohawk Power Corporation, Letter Order, Docket No. ER03-1258-000 (October
22, 2003); Niagara Mohawk Power Corporation, Letter Order, Docket No. ER00-1191-000 (March 17,
2000).

6 See, e.g., PJM Interconnection, LLC, 111 FERC ¶ 61,163 at PP 10-11, reh’g denied, 112 FERC ¶ 61,282 (2005).

Honorable Kimberly D. Bose June 20, 2017

Page 3

1. Modifications to Address Limited Operation of the Facility Prior to Completion of Certain Upgrade Facilities

The parties have determined that certain System Upgrade Facilities will not be completed
prior to PSEG’s completion of some or all of the upgrades to its gas combustion turbines.
Consistent with Section 5.9 of the Pro Forma LGIA, the parties performed certain analysis and
determined the extent to which the Facility can operate at its maximum generating capability, as
modified by the completion of each turbine upgrade, prior to the completion of the System
Upgrade Facilities. The description of the limited operation of the Facility is described in
Section 3 of Appendix C of the Interconnection Agreement. Accordingly, the parties have
modified Section 4.1.1 of the Interconnection Agreement to provide that the NYISO’s provision
of Energy Resource Interconnection Service and Capacity Resource Interconnection Service are
subject to the limited operations requirements in Section 3 of Appendix C. The Commission has
previously accepted this change to the Pro Forma LGIA in similar circumstances.7

2. Modifications to Address Operational Control of Attachment Facilities
and Upgrades

The parties have agreed to modify Article 5.11 (“Connecting Transmission Owner’s
Attachment Facilities Construction”) to provide that National Grid shall “not” transfer to the
NYISO operational control of the Connecting Transmission Owner’s Attachment Facilities
(“CTOAFs”) and Stand-Alone System Upgrade Facilities (“SASUFs”) associated with the
Facility. This change is necessary because National Grid will retain operational control over
these 115 kV facilities. The Commission has previously accepted this change to the Pro Forma LGIA in similar circumstances.8

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

The Joint Filing Parties request an effective date of June 7, 2017, which is the date of its
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.9

7 See New York Independent System Operator, Inc., Letter Order, Docket No. ER17-352-000 (January 5, 2017) (accepting modifications to Section 4.1.1 of the filed interconnection agreement to address limited operations).

8 See, e.g., New York Independent System Operator, Inc. and Niagara Mohawk Power Corp.,

Letter Order, Docket No. ER10-1507-000 (August 17, 2010); New York Independent System Operator, Inc., Letter Order, Docket No. ER09-905-000 (May 15, 2009).

9 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).

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

Honorable Kimberly D. Bose June 20, 2017

Page 5

IV. Documents Submitted

The NYISO submits the following documents with this filing letter:

• A clean version of the Interconnection Agreement (Attachment I);

• A blacklined version of the Interconnection Agreement showing the changes from the
body of the Pro Forma LGIA (Attachment II); and

• The signature pages for the Interconnection Agreement (Attachment III).

V.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 documents included with this filing will be posted on the NYISO’s website at
www.nyiso.com.

VI. Conclusion

Wherefore, the Joint Filing Parties respectfully request that the Commission accept the Interconnection Agreement for filing with an effective date of June 7, 2017.

Respectfully submitted,

/s/ Sara B. Keegan

Sara B. Keegan

Counsel for the

New York Independent System Operator, Inc.

/s/ David C. Lodemore

David C. Lodemore

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

cc:Michael BardeeLarry Parkinson

Nicole BuellJ. Arnold Quinn

Anna CochraneDouglas Roe

Kurt LongoKathleen Schnorf

David MorenoffJamie Simler

Daniel NowakGary Will