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. 2217, 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 interconnection of the Con Edison owned

transmission line to certain flex links connectors within the Sugarloaf Substation that is
owned by O&R. 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 flex links. Con

Edison will also be responsible for the cost of the interconnection facilities, including the future operating and maintenance costs of the flex links. 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.

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 reconnection by Con Edison of a transmission line that is owned by
O&R. Specifically, that 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. The 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

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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, O&R 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 a
transmission line and the Sugarloaf flex links 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 a transmission
line used to maintain the reliability of the New York State bulk power system. They
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 this schematic contains 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: (845) 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

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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,

Vice President

Consolidated Edison Company of New York, Inc.