10 Krey Boulevard, Rensselaer, NY 12144
Ph: 518.356.6000 | Fax: 518.356.8899

June 9, 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 Amended and Restated 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.
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 Amended and Restated 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
“Amended Agreement”).3 The Amended 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 Amended
Agreement for filing. The Amended Agreement conforms to the NYISO’s pro forma Large
Generator Interconnection Agreement (“Pro Forma LGIA”) that is contained in Attachment X to
the OATT with limited non-conforming exceptions previously accepted by the Commission for
the prior version of this agreement. 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
Amended Agreement effective as of May 27, 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 June 9, 2021

Page 2

I.Discussion

The Amended Agreement supersedes the Large Generator Interconnection Agreement
among the NYISO, National Grid, and Ball Hill that was filed in the Commission’s Docket No.
ER19-2665-000 on August 21, 2019,5 and was accepted by the Commission on October 16, 2019
(the “Original Agreement”).6 The Original Agreement was based on and is consistent with the
Pro Forma LGIA, but included certain non-conforming modifications, which were accepted by
the Commission.

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

County, New York (the “Facility”). The Facility will have a maximum injection at the Point of Interconnection of 100 MW. Additional details regarding the Facility can be found in Appendix C of the Amended Agreement.

Subsequent to the effective date of the Original Agreement, Ball Hill proposed changes to
the project’s Commercial Operation Date and the turbines for the Facility. The NYISO
determined that the changes were non-material, and Ball Hill elected to move forward with the
changes.

Accordingly, the NYISO, National Grid, and Ball Hill have revised the description of the
Facility in Appendices A and C to reflect the turbine changes and related equipment changes and
to update the one-line diagram, along with modifications to the project milestones in Appendix

B. In addition, the NYISO, National Grid, and Ball Hill have made the following additional modifications to the Original Agreement:

• Revisions to reflect that this is the “Amended and Restated” Agreement;

• Revisions to incorporate modifications to the Pro Forma LGIA that occurred
following the effective date of the Original Agreement;

• Updates to cost estimates in Appendix A concerning related upgrades for Ball Hill’s
project; and

• Updates to contact information in Appendices E and F.

The Amended Agreement does not include variations from the Pro Forma LGIA other than those already accepted by the Commission for the Original Agreement.

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

The Joint Filing Parties request an effective date of May 27, 2021, for the Amended

Agreement, which is the date of its full execution. The Joint Filing Parties respectfully request

5 New York Independent System Operator and Niagara Mohawk Power Corporation d/b/a National Grid, Docket No. ER19-2665-000 (August 21, 2019).

6 New York Independent System Operator and Niagara Mohawk Power Corporation d/b/a National Grid, Letter Order, Docket No. ER19-2665-000 (October 16, 2019).

Honorable Kimberly D. Bose June 9, 2021

Page 3

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@hunton.com

*Michael J. Messonnier Jr. 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

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) (2014) to permit service on counsel in both Washington, D.C. and Richmond, VA.

Honorable Kimberly D. Bose June 9, 2021

Page 4

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 Amended Agreement (Attachment I);

• A blacklined version of the Amended Agreement showing the changes from the
Original Agreement (Attachment II); and

• The signature pages for the Amended 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.

VII. Conclusion

Wherefore, the Joint Filing Parties respectfully request that the Commission accept the Amended Agreement for filing with an effective date of May 27, 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