September 9, 2019

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 Transmission Facility

Interconnection Agreement Among the New York Independent System Operator, Inc., the New York State Electric & Gas Corporation, and Trans-Allegheny
Interstate Line Company; and 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 35.12 of the

Commission’s regulations,2 the New York Independent System Operator, Inc. (“NYISO”), the New York State Electric & Gas Corporation (“NYSEG”), and Trans-Allegheny Interstate Line Company (“TrAILCo”) (together, the “Joint Filing Parties”) hereby tender for filing an executed Amended and Restated Transmission Facility Interconnection Agreement (“Amended
Agreement”) between and among NYSEG, TrAILCo, and the NYISO that was fully executed on July 31, 2019.3 The Amended Agreement is labelled as Service Agreement No. 2257 under the NYISO’s Open Access Transmission Tariff (“OATT”).4

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 July 31, 2019, which is the date of its full execution.

1 16 U.S.C. § 824d (2014).

2 18 C.F.R. § 35.12 (2014).

3 PJM was added as a signatory to the Original Agreement and this Amended 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. See American Elec. Power Services Corp., 112 FERC ¶ 61,128 at P 10 (2005).

4 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).

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

Honorable Kimberly D. Bose September 9, 2019

Page 2

I.Background

The Amended Agreement supersedes the Transmission Facility Interconnection

Agreement between the Joint Filing Parties that was filed in Docket No. ER16-1230-000 on March 18, 2016, as Service Agreement No. 2257 (“Original Agreement”). The Original Agreement was accepted by the Commission on May 6, 2016.5

As reflected in the Original Agreement, the transmission facility consists of a substation
owned by TrAILCo near the town of Smethport, Pennsylvania, 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 runs from the Homer City
Substation in Pennsylvania to the Stolle Road Substation in New York, which is intersected by
the Five Mile Road Substation that is owned and operated by Niagara Mohawk Power
Corporation d/b/a National Grid. The Pierce Brook Substation interconnects with, and
electrically bifurcates, the 345 kV transmission line between the Homer City Substation and the
Five Mile Road Substation (“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 System.

Subsequent to the execution of the Original Agreement, TrAILCo installed one 345 kV shunt reactor and related equipment at the Pierce Brook Substation (“New Facilities”). The New Facilities have been installed on the TrAILCo side of the point of interconnection for the Pierce Brook Substation and have commenced operation. The Joint Filing Parties agreed to amend the Original Agreement to reflect the New Facilities.

II.Discussion of Changes

As described in the March 18, 2016 filing, this interconnection was not subject to the
terms of the NYISO’s pro forma Large Generating Facility Interconnection Agreement (“Pro
Forma LGIA”). Notwithstanding this, the Original Agreement is generally consistent with the
NYISO’s Pro Forma LGIA. The differences reflected the unique circumstances of the Original Agreement, which addresses the interconnection of transmission facilities operated by PJM with those operated by the NYISO, and the application of the agreement to a transmission facility,
rather than a generation facility. The Joint Filing Parties submit this Amended Agreement to
make the following minor changes:6

• modifications to reflect that this is the “Amended and Restated” agreement;

• revisions to the preamble language to indicate that the Original Agreement shall be
superseded by the Amended Agreement;

5 New York Independent System Operator, Inc., New York State Electric & Gas Corporation, Trans-
Allegheny Interstate Line Company, and PJM, Letter Order, Docket No. ER16-1230-000 (May 6, 2016).

6 As the Joint Filing Parties are not subject to the terms of the Pro Forma LGIA, the Amended Agreement is not subject to the Commission’s high standard for accepting variations from the Pro Forma LGIA.

Honorable Kimberly D. Bose September 9, 2019

Page 3

• revisions to: (i) section 18.2.3 and the PJM signature block to change the reference to
PJM’s “officer” to PJM’s “representative”; and (ii) the PJM signature block to provide
for the date of acknowledgment;

• updates to the list of Stand Alone System Upgrade Facilities equipment to reflect the
New Facilities;

• updates to the simplified one-line diagram provided in Appendix A to reflect the New
Facilities; and

• updates to party contact information.

The Joint Filing Parties respectfully request that the Commission accept the Amended Agreement for filing.

III. EFFECTIVE DATE AND REQUEST FOR WAIVER

The Joint Filing Parties request an effective date of July 31, 2019, for the Amended

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 granted waivers of its prior notice requirements to permit the requested effective dates for executed interconnection agreements.7

7 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@huntonak.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@huntonak.com

For NYSEG:

* Jeffrey A. Rosenbloom General Counsel

New York State Electric & Gas Corporation

89 East Avenue

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

jeffrey.rosenbloom@avangrid.com

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

*P. Nikhil Rao Attorney

FirstEnergy Service Company

76 South Main Street

Akron, Ohio 44308
Phone: (330) 384-2422
pnrao@firstenergycorp.com

*Designated to receive service.

V.DOCUMENTS SUBMITTED

*Nicholas A. Giannasca
Davis Wright Tremaine LLP

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

Phone: (212) 603-6406

NicholasGiannasca@dwt.com

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

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

• a blacklined version of the Amended Agreement showing the differences 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.

Honorable Kimberly D. Bose September 9, 2019

Page 6

VII. CONCLUSION

Wherefore, the Joint Filing Parties respectfully request that the Commission accept the Amended Agreement for filing with an effective date of July 31, 2019.

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

New York State Electric & Gas Corporation

/s/ Nicholas A. Giannasca

Nicholas A. Giannasca Counsel for

Trans-Allegheny Interstate Line Company

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