Re: Filing of an Executed Amended and Restated Large Generator Interconnection
Agreement Among the New York Independent System Operator, Inc.,
Consolidated Edison Company of New York, Inc., and Bayonne Energy Center,
LLC and Request for Critical Energy Infrastructure Information Designation,
Docket No. ER14-___-000

Dear Ms. Bose:

Pursuant to Section 205 of the Federal Power Act,1 Section 35.12 of the Commission’s
Regulations,2 and Section 11.3 of its Large Facility Interconnection Procedures (“LFIP”), the
New York Independent System Operator, Inc. (“NYISO”) and Consolidated Edison Company of
New York, Inc. (“Con Edison”) (“Joint Filing Parties”) hereby tender for filing an executed
Amended and Restated Large Generator Interconnection Agreement (“Amended Agreement”) as
Service Agreement No. 1668 among the NYISO, Con Edison as the Connecting Transmission
Owner, and Bayonne Energy Center, LLC (“BEC”) as the Developer.3 The Joint Filing Parties
respectfully request waiver of the Commission’s 60-day notice period to make this Agreement
effective as of October 16, 2013, the execution date of the Amended Agreement.

I.Documents Submitted

The NYISO submits the following documents:

• this filing letter;

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

1 16 U.S.C. § 824d (2006).

2 18 C.F.R. § 35.12 (2008).

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 30, 2013

Page 2

• a blacklined Public version showing the Amended Agreement’s changes from the
Original Agreement (Attachment II);

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

• a graphic of the signature pages for the Amended Agreement (Attachment IV).

II.Discussion of Changes

The Amended Agreement supersedes a Large Generator Interconnection Agreement

among the parties that was filed in Docket No. ER11-2199-000 as Service Agreement No. 1668
(“Original Agreement”). The Original Agreement was accepted by the Commission on
December 28, 2010.4 The Original Agreement stated that BEC’s Large Generating Facility
(“BEC Facility”) would be a nominal 512 MW multi-unit, simple-cycle natural gas-fired facility
with a net summer capability of 500 MW at 95º F, and a net winter capability of 500 MW at
10º F.

The BEC Facility’s capability, as reflected in the Original Agreement, was based on data
provided to the NYISO and Con Edison by BEC in the final NYISO interconnection study - the
Class Year 2009 Interconnection Facilities Study (“Class Year 2009 Study”). Notably, in an
earlier study, the System Reliability Impact Study for the BEC Facility, it was studied with a
winter capability of 512 MW - its full nameplate value. In the data collection portion of the
Class Year 2009 Study, however, BEC represented that it anticipated 12 MW in auxiliary load
year-round, resulting in a net capability of 500 MW in both summer and winter. BEC also
represented that its gross capability was a flat 512 MW in both summer and winter - i.e., that the
unit is not temperature sensitive. As a result, the Original Agreement provided that the BEC
Facility has a net summer capability of 500 MW at 95º F, a net winter capability of 500 MW at
10º F, and that the BEC Facility would not deliver in excess of 500 MW to the Point of
Interconnection at any time.

Since the filing of the Original Agreement, the BEC Facility has become fully

operational and it has become apparent to the parties that its net winter capability exceeds the

500 MW by up to 12 MWs. This is due, in part, to a mis-estimation by BEC of its auxiliary load,
which is often less than 12 MW, and is also due to the BEC Facility, as built, being temperature
sensitive.

The Joint Filing Parties therefore submit this Amended Agreement to update the

description of the BEC Facility that was provided in Appendix C of the Original Agreement and
to clearly specify, through technical description and the insertion of a performance curve, the
BEC Facility’s as-built capability. In addition, the Joint Filing Parties submit additional
revisions that were agreed to by the Parties as part of the Amended Agreement to reflect updated

4 New York Independent System Operator, Inc. and Consolidated Edison Company of New York, Inc., Order, Docket No. ER08-618-000 (issued April 29, 2008).

Honorable Kimberly D. Bose October 30, 2013

Page 3

milestones, updated contact information, revisions that have been approved to the pro forma Large Generator Interconnection Agreement since the Original Agreement was executed, and revisions to reflect that this is an “Amended and Restated” agreement. Specifically, the
Amended Agreement reflects the following modifications:

(1) modifications to the technical description of the BEC Facility in Appendix C to
reflect the as-built gross and net capability with more specificity;

(2) insertion of a performance curve as “Figure C-1” and re-naming as “Figure C-2” the
diagram that was previously designated as “Figure C-1”;

(3) updates to the milestones in Appendix B;

(4) updates to the contact information in Appendix F;

(5) modifications to reflect revisions to the pro forma Large Generator Interconnection
Agreement that have been approved by the Commission since the execution of the
Original Agreement; and

(6) modifications to reflect that this is an “Amended and Restated” agreement, including
language added to Section 2.1 to indicate that “[u]pon its effectiveness, this
Agreement will supersede and replace the November 10, 2010 Large Generator
Interconnection Agreement among the Developer, NYISO and Connecting
Transmission Owner, without prejudice to any rights, claims, or obligation under the
November 2010 LGIA that have accrued as of the date of effectiveness of this
Agreement.”

The blacklined Amended Agreement attached to this filing shows all of these changes that were made to the currently effective Original Agreement. The Joint Filing Parties
respectfully request that the Commission accept this Amended Agreement.

III. Request for CEII Treatment

Pursuant to the Commission’s regulations at 18 C.F.R. §388.112 and 18 C.F.R.

§ 388.113, Con Edison requests that the one-line diagram included as part of Appendix A to the
Amended Agreement (Figure A-1) be protected from disclosure as Critical Energy Infrastructure
Information (“CEII”). This one-line diagram is unchanged from Figure A-1 in the Original
Agreement for which Con Edison requested, and the Commission granted, CEII treatment.

This diagram contains detailed, one-line schematics of transmission lines, the Gowanus
substation and generation facilities that, if disclosed, could pose a threat to the security and the
reliability of the New York State bulk power system. This diagram provides more than simply
the general location of critical infrastructure. Unlike publicly available maps of power
transmission lines and generation and substation facilities, this schematic shows the exact nature
and specific location of facilities and transmission lines used to maintain the reliability of the

Honorable Kimberly D. Bose October 30, 2013

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New York State bulk power system. This diagram, in Con Edison’s assessment, reveals such
critical information related to the facilities and transmission depicted therein that, if disclosed,
could be useful to a person seeking to disable the power grid. Therefore, the disclosure of this
CEII diagram would pose a threat to the reliability of the New York State bulk power system and to the health and safety of New York residents. Moreover, the information revealed in this
schematic reveals CEII which FERC has determined to be exempt from mandatory disclosure
under 5 U.S.C. § 552(b)(7)(F). The diagram has been omitted from the Public version of the
Amended Agreement included in this filing. The diagram is included only in the CEII version of the Amended Agreement in the filing.

All communications relating to this request for CEII treatment should be addressed to the following:

John BeckPaul Savage

Section ManagerAssociate Counsel

Consolidated Edison Company of New York,Consolidated Edison Company of New York,

Inc.Inc.

4 Irving Place, Room 1450-S4 Irving Place, Room 1815-S

New York, NY 10003New York, NY 10003

Phone: (212) 460-4244Phone: (212) 460-2764

Fax: (212) 529-1130Fax: (212) 529-9265

BeckJ@coned.comSavageP@coned.com

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

The parties request an effective date of October 16, 2013 for the Amended Agreement,
which is the date of execution. The Commission has allowed interconnection agreements to
become effective on the date of execution, even when that date precedes the date that an
interconnection agreement is filed. Accordingly, the parties request that the Commission grant a
waiver of its prior notice requirements to the extent necessary to accommodate this requested
effective date.

V.Communications and Correspondence

Communications regarding this filing should be directed to:

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

Honorable Kimberly D. Bose October 30, 2013

Page 5

Rensselaer, NY 12144
Tel: (518) 356-6000
Fax: (518) 356-4702
skeegan@nyiso.com

For Consolidated Edison Company of New York, Inc.

*Paul Savage, Associate Counsel

Consolidated Edison Company of New York, Inc.

4 Irving Place, Room 1815-S

New York, NY 10003
Phone: (212) 460-2764
Fax: (212) 529-9265

SavageP@coned.com

*Designated to receive service. 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 this filing will be posted on the NYISO’s website at www.nyiso.com.

VII. Conclusion

Wherefore, the NYISO respectfully requests that the Commission accept the Amended Agreement effective as of October 16, 2013.

Respectfully submitted,

/s/ Sara B. Keegan

Sara B. Keegan
Counsel for the

New York Independent System Operator, Inc.

/s/ Paul Savage

Paul Savage

Counsel for Consolidated Edison Company of New York, Inc.