Marc Richter

Vice President

Regulatory Services

June 3, 2015

CONTAINS CRITICAL ENERGY
INFRASTRUCTURE INFORMATION

By Electronic Delivery

Honorable Kimberly D. Bose Secretary

Federal Energy Regulatory Commission 888 First Street, NE

Washington, DC 20426

Re: Filing of an Executed Interconnection Agreement Between the

Orange and Rockland Utilities, Inc. and Consolidated Edison

Company of New York, Inc., and Request for Critical Energy

Infrastructure Information Designation, Docket No. ER15-___-000

Dear Ms. Bose:

Pursuant to Section 205 of the Federal Power Act1 and Section 35.12 of the
Commission’s Regulations,2 Orange and Rockland Utilities, Inc. (“O&R”) and
Consolidated Edison Company of New York, Inc. (“Con Edison”) hereby tender for
filing an executed Interconnection Agreement (“Agreement”), designated as Service
Agreement No. 2216, between O&R and Con Edison (collectively, the “Parties”).

Con Edison and O&R request a June 4, 2015 effective date for the Agreement and
further request a waiver of the normal 60-day notice period, as discussed fully below.

Because this interconnection is between two transmission owners, it is not subject to the New York Independent System Operator, Inc.’s (“NYISO’s”) interconnection
process. As such, the NYISO is not a party to this Agreement. Two-party

1 16 U.S.C. § 824d (2006).

2 18 C.F.R. § 35.12 (2008).

Honorable Kimberly D. Bose June 3, 2015

Page 2

interconnection agreements are designated as Service Agreements under the NYISO Open Access Transmission Tariff (“OATT”).3

I.BACKGROUND

The Agreement provides for the reconnection by Con Edison of a transmission

line that is owned by O&R. Specifically, this interconnection agreement provides for the relocation of the interconnection point of O&R’s transmission line from the 138kV
Ramapo Substation, owned by O&R, to the 345kv Ramapo Substation, owned by Con Edison. This Agreement is one of three separate interconnection agreements4 necessary for the construction and operation of the second 345 kV Ramapo to Rock Tavern
transmission line, which also will be interconnected to the Rock Tavern substation, which is owned by Central Hudson Gas & Electric Corp. (“Central Hudson”).

The New York State Public Service Commission (“NYPSC”), in its November 4, 2013 order,5 approved the second 345kV transmission line from the Ramapo Substation to Rock Tavern Substation, as one of the transmission projects that should be constructed as part of the NYPSC’s Indian Point Contingency Plan. The transmission line was
initially proposed as one of the alternatives to maintain reliability should the Indian Point Nuclear Generating Facility’s (“Indian Point”) nuclear license not be renewed. In
addition, the NYPSC states in its November 4th order that this project is beneficial to the state regardless of the outcome of the nuclear re-licensing.6

Con Edison will, at its sole expense, design and construct the reconnection of
O&R’s transmission line into the 345kV Ramapo Substation. The reconnection of the
transmission line into the Ramapo Substation will require the construction of System
Upgrade Facilities (“SUFs”) within the Ramapo substation. In addition, the reconnection
of O&R’s transmission line will also require the design and construction of SUFs at the
Sugarloaf Substation that is owned by O&R. Con Edison will also design, procure and
construct these SUFs and be responsible for the cost of the interconnection facilities,
including the future operating and maintenance costs of the SUFs and attachment

3 Consolidated Edison Company of New York, Inc., 119 FERC ¶ 61,206 (2007); Consolidated Edison

Company of New York, Inc., Docket No. ER09-1515-000, Letter Order dated September 3, 2009; Niagara Mohawk Power Corporation, 121 FERC ¶ 61,183 (2007).

4 One agreement covers the interconnection of the Con Edison 345 kV transmission line into the Rock

Tavern Substation that is owned by Central Hudson. That interconnection agreement between Con Edison and Central Hudson has been filed with and accepted by the Commission in Docket Number ER15-1422. The other agreement involves the interconnection of the Con Edison owned segment of the transmission line to flex links within the Sugarloaf Substation owned by O&R. This second interconnection between Con Edison and O&R will be filed with the Commission shortly.

5 Case 12-E-0503, Proceeding on Motion of the Commission to Review Generation Retirement Contingency Plans, Order Accepting Reliability Contingency Plans, Establishing Cost Allocation and Recovery, and Denying Requests for Rehearing (November 4, 2013).

6 Id. at p. 32.

Honorable Kimberly D. Bose June 3, 2015

Page 3

facilities. Once constructed, the new transmission line will become part of New York
State transmission system and will be available for open access transmission service by
the NYISO.

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 Agreement (Figure A-1) be protected from disclosure as Critical Energy
Infrastructure Information (“CEII”). This one-line diagram contains one-line schematics
of transmission lines and the Ramapo Substation which, 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 New York State bulk power
system. The drawings reveal 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 in these schematics contain CEII that 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 Interconnection Agreement
included in this filing. The diagram is included only in the CEII version of the
Interconnection Agreement in the filing.

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

For Con Edison:

John Coffey

Chief Transmission and Substation Engineer Orange & Rockland Utilities, Inc.

Address 390 West Route 59 Dept. SVOC

Spring Valley NY 10977 Phone: (845) 577-3704 Fax: (8450 577-3720

IV.EFFECTIVE DATE

John Carley

Assistant General Counsel Consolidated Edison Company of New York, Inc.

4 Irving Place, Room 1815-S New York, NY 10003

Phone: (212) 460-2097 Fax: (212) 677-5850

Con Edison and O&R request that the Commission permit the Agreement to

become effective as of June 4, 2015. The Commission has waived the 60-day notice

requirement, partially or entirely, with respect to other interconnection agreements where circumstances warrant. A waiver in this case would serve the public interest by
providing certainty with regard to investments and facilities that Con Edison must make to complete this Transmission Project. Accordingly, O&R and Con Edison request that the Commission grant a waiver of its prior notice requirements to the extent necessary to accommodate the requested effective date.

V. COMMUNICATIONS AND CORRESPONDENCE

Communications regarding this filing should be directed to:

For O&R:

John Carley

Assistant General Counsel

Consolidated Edison Company
of New York, Inc.

4 Irving Place, Room 1815-S
New York, NY 10003
Phone: (212) 460-2097
Fax: (212) 677-5850

Honorable Kimberly D. Bose June 3, 2015

Page 5

For Con Edison:

Paul A. 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

VI.DOCUMENTS SUBMITTED

This filing consists of the following documents:

A.this filing letter;

B.a Public version of the Agreement; and

C.a CEII version of the Agreement.

VII. SERVICE

Con Edison will serve this filing electronically on the NYPSC, the NYISO, and

O&R.

VIII. CONCLUSION

Wherefore, Con Edison and O&R respectfully request that the Commission accept the attached Agreement effective as of June 4, 2015.

Respectfully submitted,

By:

Vice President

Consolidated Edison Company of New York, Inc.