August 21, 2019

By Electronic Delivery

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

Washington, DC 20426

Re: Joint 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 Ball Hill Wind Energy, LLC; Request for
Waiver of the 60-Day Notice Period; Docket No. ER19-____-000

Dear Ms. Bose:

Pursuant to Section 205 of the Federal Power Act1 and Section 35.13 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 Ball Hill Wind Energy, LLC (“Ball Hill”), as the Developer (the “Interconnection Agreement”).3 The
Interconnection Agreement is labeled as Service Agreement No. 2473 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 the limited exception described 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 July 31, 2019, which is the date of its full execution.

1 16 U.S.C. § 824d (2012).

2 18 C.F.R. § 35.13 (2017).

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).

10 Krey Boulevard, Rensselaer, New York 12144 | www.nyiso.com

Honorable Kimberly D. Bose August 21, 2019

Page 2

I.Discussion

A.Background

Ball Hill is constructing a wind farm located in the town of Hamlet in Chautauqua

County, New York (the “Facility”). The Facility will consist of twenty-nine Vestas V136 3.45 MW wind turbines, with a total output of 100 MW. Additional details regarding the Facility can be found in Appendix C of the Interconnection Agreement.

The Facility will interconnect to certain facilities of National Grid that are part of the

New York State Transmission System. The Point of Interconnection will be located on National
Grid’s Dunkirk-New Gardenville Line 73, between structures 281 and 282. Appendix A of the
Interconnection Agreement includes a one-line diagram showing the Point of Interconnection.

B.The Agreement Closely Conforms to the Pro Forma LGIA Contained in

Attachment X of the NYISO OATT

The Interconnection Agreement was fully executed on July 31, 2019, by the NYISO,

National Grid, and Ball Hill. The Interconnection Agreement largely conforms to the language in the Pro Forma LGIA contained in Attachment X of the NYISO OATT with the limited
exceptions described below in this Part I.B. The Joint Filing Parties submit that the changes specified below satisfy the Commission’s standard for variations from the Pro Forma LGIA, because unique circumstances exist that require a non-conforming agreement.5 Therefore, the Joint Filing Parties respectfully request that the Commission accept the Interconnection
Agreement with the limited non-conforming changes.

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

Ball Hill elected to seek both Energy Resource Interconnection Service (“ERIS”) and

Capacity Resource Interconnection Service (“CRIS”) from the NYISO. Ball Hill participated in the Class Year Interconnection Facilities Study (“Class Year Study”) for Class Year 2017. The Class Year Study identified certain system upgrades required in New York to mitigate transfer degradation between the NYISO and PJM Interconnection, LLC (“PJM”) caused by certain projects participating in the Class Year Study, including the Facility. The Class Year Study also identified related other upgrade facilities that are required in PJM.

These upgrades may not be completed prior to Ball Hill’s completion of the Facility.

Accordingly, the parties detailed in Section 3 of Appendix C of the Interconnection Agreement
the process by which the NYISO and National Grid may perform certain analysis consistent with
the limited operations requirements in Section 5.9 of the Pro Forma LGIA and Section 30.12.3 of
Attachment X of the NYISO OATT to determine the extent to which the Facility can operate at
its maximum generating capability prior to completion of the upgrades. The parties also

5 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 August 21, 2019

Page 3

modified Article 4.1.1 of the Interconnection Agreement to provide that the NYISO’s provision
of ERIS and CRIS are subject to the limited operations requirements in Article 3 of Appendix C.
The Commission has previously accepted this change to the Pro Forma LGIA in similar
circumstances.6

2.Modification to Recent NYISO Interconnection Queue Reform

Revisions

On October 16, 2017, the NYISO submitted in Docket No. ER18-80-000 modifications to its interconnection procedures and agreements, including the Pro Forma LGIA, which
revisions the Commission accepted on December 7, 2017.7 The parties have agreed to make the following modifications in the Interconnection Agreement to correct certain modifications to the Pro Forma LGIA in the recent filing:

• Correction of the cross-reference in Article 2.1 from Article 3.1, which no longer exists,
to Article 3;

• Correction to the first reference to “Indemnified Party” in Article 18.1.2 of the Pro Forma
LGIA, which was inadvertently changed to “Indemnifying Party;”

• Correction of two cross-references in Section 18.3.12; and

• Correction of a cross-reference in Article 22.4.

The Commission has previously accepted these changes 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 July 31, 2019 for the Interconnection Agreement, which is the date of its full 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

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

7 See New York Independent System Operator, Inc., Letter Order, Docket No. ER18-80-000 (December 7,

2017).

8 See, e.g., New York Independent System Operator, Inc. and Consolidated Edison Co. of New York, Inc., Letter Order, Docket No. ER18-1161-000 (May 17, 2018).

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 F. 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 Andrews Kurth LLP 2200 Pennsylvania Avenue, NW Washington, D.C. 20037
Tel: (202) 955-1500

Fax: (202) 778-2201

tmurphy@hunton.com

*Michael J. Messonnier Jr. Sevren R. Gourley

Hunton Andrews Kurth LLP 951 East Byrd Street

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

mmessonnier@hunton.com

For National Grid

Christopher J. Novak Senior Counsel

National Grid

40 Sylvan Road

Waltham, MA 02451
Tel: 781-907-2112
Fax: 781-296-8091

Chris.Novak@nationalgrid.com

*Designated to receive service.
IV. Documents Submitted

The Joint Filing Parties submit the following documents with this filing letter:

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

10 The NYISO respectfully requests waiver of 18 C.F.R. § 385.203(b)(3) (2014) to permit service on counsel in both Washington, D.C. and Richmond, VA.

Honorable Kimberly D. Bose August 21, 2019

Page 5

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

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

V.Service

On behalf of the Joint Filing Parties, 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 July 31, 2019.

Respectfully submitted,

Sara B. Keegan

Counsel for the

New York Independent System Operator, Inc.

Christopher J. Novak

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

cc:Anna Cochrane

James Danly
Jignasa Gadani
Jette Gebhart
Kurt Longo
John C. Miller
David Morenoff
Daniel Nowak
Larry Parkinson
Douglas Roe
Frank Swigonski
Gary Will