10 Krey Boulevard Rensselaer, NY 12144

October 19, 2012

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 Allegany Wind, LLC and Request for
Waiver of the 60-Day Notice Period, Docket No. ER13-___-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”) (collectively, the
“Joint Filing Parties”) hereby tender for filing an executed Large Generator Interconnection
Agreement (“Interconnection Agreement”) as Service Agreement No. 1916 among the NYISO,
National Grid as the Transmission Owner, and Allegany Wind, LLC (“Allegany”) as the
Developer.3

With the limited exceptions noted in Section II of this letter, the Interconnection

Agreement conforms to the NYISO’s pro forma Large Generator Interconnection Agreement

(“LGIA”) that is contained in Attachment X of the NYISO’s OATT. The Joint Filing Parties

respectfully request that the Commission accept the Interconnection Agreement for filing.

Further, as described in Part III of this letter, the Joint Filing Parties respectfully request a waiver of the Commission’s prior notice requirements to make the Interconnection Agreement effective as of October 5, 2012.

I.Background

The Interconnection Agreement governs the interconnection of Allegany’s Large

Generating Facility (“Facility”) in the Town of Olean, Cattaragus County, New York. The

Facility is a 72.5 MW wind power facility that employs twenty-nine (29) Nordex N90, 2.5 MW

1 16 U.S.C. § 824d (2011).

2 18 C.F.R. § 35.12 (2011).

3 Capitalized terms not otherwise defined in this letter have the meaning set forth in Attachments S and X of the NYISO’s Open Access Transmission Tariff (“OATT”).

Honorable Kimberly D. Bose October 19, 2012

Page 2

wind turbines. The Facility will interconnect to National Grid’s Homer Hill-Dugan Road #155 115 kV transmission line. The Point of Interconnection is approximately two (2) miles from National Grid’s Homer Hill Substation. The Point of Interconnection is identified in Appendix A of the Interconnection Agreement at Figure 1.

II. Variations From the NYISO’s Pro Forma LGIA

As noted above, the Interconnection Agreement is based on the NYISO’s pro forma LGIA; however, the parties have agreed to make one (1) substantive modification to the pro forma LGIA as well as ministerial formatting modifications.

Specifically, the parties have agreed to modify an outdated reference in Section 9.6.3 of the Interconnection Agreement. The NYISO’s pro forma LGIA references “NPCC criteria A-3.” The applicable NPCC criteria are now found in “NPCC Regional Reliability Reference Directory # 12.” This single modification to the pro forma LGIA is among modifications previously
accepted by the Commission.4

All of the parties to the Interconnection Agreement (“Parties”) agree to this change. The Joint Filing Parties have included a blackline of the Interconnection Agreement against the
NYISO’s pro forma LGIA to highlight this change. The NYISO respectfully requests that the Commission accept this modification.

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

The Joint Filing Parties request an effective date of October 5, 2012 for the

Interconnection Agreement, which is the date of execution. The Joint Filing Parties respectfully request that the Commission waive its prior notice requirement in order to permit the requested effective date. The Commission has previously permitted interconnection agreements to become effective upon the date of execution.5

IV. Communications and Correspondence

Communications regarding this filing should be directed to:

4 See, e.g., New York Independent System Operator, Inc. and Consolidated Edison Company of New York,
Inc., 135 FERC ¶ 61,264 (Jun. 28, 2011); New York Independent System Operator, Inc., Niagara Mohawk Power
Corporation d/b/a National Grid, and New York State Electric & Gas Corporation, Docket No. ER11-4621-000
(Nov. 4, 2011) .

5 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).

Honorable Kimberly D. Bose October 19, 2012

Page 3

For the NYISO

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
rfernandez@nyiso.com
kgach@nyiso.com
skeegan@nyiso.com

For Niagara Mohawk d/b/a National Grid

*William L. Malee

Director, Transmission Commercial National Grid

40 Sylvan Road

Waltham, MA 02451
Tel: 781-907-2422
Fax: 781-907-5707

Bill.Malee@nationalgrid.com
*Designated to receive service.

V.Documents Submitted

The NYISO submits the following documents: • this filing letter;

*Amanda C. Downey

Counsel for National Grid USA
Service Company, Inc.

40 Sylvan Road

Waltham, MA 02451
Tel: 781-907-2136
Fax: 781-907-5701

Amanda.Downey@nationalgrid.com

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

• a blacklined version showing the changes between the pro forma LGIA and the
Interconnection Agreement (Attachment II).

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 October 19, 2012

Page 4

VII. Conclusion

Wherefore, the NYISO respectfully requests that the Commission accept the Interconnection Agreement effective as of October 5, 2012.

Respectfully submitted,

/s/ Sara B. Keegan

Sara B. Keegan
Counsel for the

New York Independent System Operator, Inc.

/s/Amanda C. Downey

Amanda C. Downey

Counsel for National Grid USA Service Company, Inc.