10 Krey Boulevard, Rensselaer, NY 12144
Ph: 518.356.6000 | Fax: 518.356.8899
May 28, 2021
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 Small Generator Interconnection Agreement Among
the New York Independent System Operator, Inc., Niagara Mohawk Power
Corporation d/b/a National Grid, and Rock District Solar, LLC; Request for
Waiver of the 60-Day Notice Period; Docket No. ER21-____-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 Small Generator Interconnection Agreement entered into by the NYISO, National Grid, as the Connecting Transmission Owner, and Rock District Solar, LLC (“Rock District”), as the Interconnection Customer (the “Interconnection Agreement”).3 The Interconnection Agreement is labeled as Service Agreement No. 2662, 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 one limited exception described in Part I of this
letter, the Interconnection Agreement conforms to the NYISO’s pro forma Small Generator
Interconnection Agreement (“Pro Forma SGIA”) that is contained in Attachment Z 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 May 18, 2021, which is the date of its full execution.
1 16 U.S.C. § 824d.
2 18 C.F.R. § 35.13 (2019).
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).
Website: www.nyiso.com | LinkedIn: NYISO | Twitter: @NewYorkISO
Honorable Kimberly D. Bose May 28, 2021
Page 2
I.Discussion
A.Background
Rock District is constructing a 20 MW solar generation facility to be located in
Cobleskill, New York (the “Facility”). Additional details regarding the Facility can be found in Attachment 2 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 is National Grid’s existing 69kV Marshville-Cobleskill Line 16/17 that is comprised of the Marshville-Sharon Line 16 and the Sharon-Cobleskill Line 17. Attachment 3 of the Interconnection Agreement includes a oneline diagram showing the Point of Interconnection.
B. The Interconnection Agreement Closely Conforms to the Pro Forma SGIA
Contained in Attachment Z of the NYISO OATT
The Interconnection Agreement was fully executed on May 18, 2021 by the NYISO, National Grid, and Rock District. The Interconnection Agreement largely conforms to the
language in the Pro Forma SGIA contained in Attachment Z of the NYISO OATT with the
exceptions described below in this Part I.B. The Joint Filing Parties submit that the change specified below satisfies the Commission’s standard for variations from the Pro Forma SGIA, 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 non-conforming change.
1. Rock District’s Construction of Portions of the Connecting
Transmission Owner’s Interconnection Facilities
Section 1.5.3 of the Pro Forma SGIA provides that the Connecting Transmission Owner
shall construct, operate, and maintain its Interconnection Facilities and Upgrades covered by the
agreement. National Grid and Rock District have agreed that Rock District will be responsible
for constructing certain Connecting Transmission Owner’s Interconnection Facilities associated with the Facility. Accordingly, the parties agreed to modify Section 1.5.3 of the Interconnection Agreement to clarify that the Interconnection Customer, Rock District, can construct the
Connecting Transmission Owner’s Interconnection Facilities with the agreement of the parties. The Commission has previously accepted this change to the Pro Forma SGIA.6
5 See, e.g., PJM Interconnection, LLC, 111 FERC ¶ 61,163 at PP 10-11, reh’g denied, 112 FERC ¶ 61,282
(2005).
6 See New York Independent System Operator, Inc. and New York State Electric & Gas Corporation¸ Letter
Order, Docket No. ER20-1603-000 (June 18, 2020) (accepting interconnecting agreement modified to permit the
Interconnection Customer to agree to construct Connecting Transmission Owner’s Interconnection Facilities); New
Honorable Kimberly D. Bose May 28, 2021
Page 3
II. Proposed Effective Date and Request for Waiver of the 60-Day Notice Period
The Joint Filing Parties request an effective date of May 18, 2021 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.7
III.Communications and Correspondence
All communications and service in this proceeding should be directed to:
For the NYISO8
Robert E. Fernandez, Executive Vice President & 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
*Andrea D. Gardner
Hunton Andrews Kurth LLP 951 East Byrd Street
Richmond, VA 23219
Tel: (804) 788-8200
Fax: (804) 344-7999
agardner@huntonak.com
York Independent System Operator, Inc. and New York State Electric & Gas Corporation¸ Letter Order, Docket No. ER20-1602-000 (June 18, 2020) (same).
7 See, e.g., New York Independent System Operator, Inc. and New York State Electric & Gas Corporation,
Letter Order, 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).
8 The NYISO respectfully requests waiver of 18 C.F.R. § 385.203(b)(3) (2019) to permit service on counsel in both Washington, D.C. and Richmond, VA.
Honorable Kimberly D. Bose May 28, 2021
Page 4
For Niagara Mohawk Power Corporation d/b/a 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);
A blacklined version of the Interconnection Agreement showing the changes from the
Pro Forma SGIA (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.
Honorable Kimberly D. Bose May 28, 2021
Page 5
VI. Conclusion
Wherefore, the Joint Filing Parties respectfully request that the Commission accept the Interconnection Agreement for filing with an effective date of May 18, 2021.
Respectfully submitted,
/s/ Sara B. Keegan
Sara B. Keegan
Counsel for the
New York Independent System Operator, Inc.
/s/ Christopher J. Novak
Christopher J. Novak
Counsel for
Niagara Mohawk Power Corporation d/b/a National Grid
cc:Janel Burdick
Matthew Christiansen Jignasa Gadani
Jette Gebhart
Leanne Khammal Kurt Longo
John C. Miller
David Morenoff
Douglas Roe
Frank Swigonski
Eric Vandenberg
Gary Will
