February 24, 2012

VIA ELECTRONIC FILING

Ms. Kimberly D. Bose

Secretary

Federal Energy Regulatory Commission 888 First Street, NE

Washington, DC 20426

RE: Niagara Mohawk Power Corporation
Docket No. ER12-_____

Interconnection Agreement between Niagara Mohawk Power
Corporation and the Griffiss Utility Services Corporation

Request for Waiver of 60-day Prior Notice Period

Dear Secretary Bose:

Pursuant to Section 205 of the Federal Power Act (“FPA”),1 Part 35 of the

Commission’s regulations,2 and Order No. 714,3 Niagara Mohawk Power Corporation
d/b/a National Grid (“Niagara Mohawk”) submits for Commission acceptance an
Interconnection Agreement (“IA” or “Agreement”) between Niagara Mohawk and
Griffiss Utility Services Corporation (“GUSC”) (collectively, the “Parties”). GUSC is a
transmission customer that provides service to end-use customers located at the Griffiss
Business and Technology Park in Rome, New York (the “Park”). The Agreement is
designated under the New York Independent System Operator, Inc. (“NYISO”) open
access transmission tariff (“OATT”), FERC Electric Tariff, Original Volume No. 1 as
Service Agreement No. 1852.

For the reasons discussed below, Niagara Mohawk, with the support of GUSC,
requests a waiver of the 60-day prior notice period to permit the Agreement to become
effective on January 1, 2012. A January 1, 2012, effective date will allow the Agreement
to become effective on the day after the expiration of Service Agreement No. 920, a prior
agreement between Niagara Mohawk and GUSC that was accepted by the Commission.

16 U.S.C. § 824d.

18 C.F.R. Part 35.
Electronic Tariff Filings, FERC Stats. & Regs. ¶ 31,276 (2008).

The Honorable Kimberley D. Bose February 24, 2012

Page 2

I.Background

Niagara Mohawk is a public utility that owns transmission and distribution

facilities in New York. Niagara Mohawk provides retail electric service in the City of

Rome, New York, and the Town of Floyd, New York, where the Griffiss Air Force Base (“the Base”) was formerly located. Prior to January 1, 2002, Niagara Mohawk provided electric service at retail to the United States Air Force at the Base.

Griffiss Local Development Corporation (“GLDC”) is a not-for-profit corporation
created to revitalize the economy of Rome, New York, by transforming the Base from a
military installation into the Park, which is akin to an industrial park. By order dated
December 1, 1999, the New York State Public Service Commission (“New York PSC”)
granted GLDC interim authority to provide electric service at retail in the Park.4 On
January 1, 2002, GLDC began receiving transmission and sales service from Niagara
Mohawk and providing electricity service to retail customers in the Park. Terms of
Niagara Mohawk’s service to GLDC were set forth in Niagara Mohawk Rate Schedule
No. 315, accepted by the Commission in a letter order issued in Docket No. ER02-2288
on October 22, 2002. Rate Schedule No. 315 provided for GLDC to pay certain charges
incorporated by reference from Niagara Mohawk’s retail tariff as a settlement of Niagara
Mohawk’s claims that GLDC should pay an exit fee under the retail tariff.

GUSC subsequently took over responsibility for operating and maintaining the
electric distribution system in the Park pursuant to certain agreements with GLDC. By
order dated July 20, 2006, the New York PSC approved the transfer of GLDC’s
certificate of public convenience and necessity to own, operate, and maintain the electric
facilities in the Park to GUSC.5 GUSC is a not-for-profit corporation providing electric
service to businesses and other residents in the Park. To document GUSC’s role, as well
as a number of related terms and conditions related to certain low cost power deliveries
allocated to GLDC under New York State programs, Niagara Mohawk, GLDC, and
GUSC entered into an amended settlement agreement. This amended settlement
agreement was designated as Service Agreement No. 920 under the NYISO OATT.
Service Agreement No. 920 was accepted by the Commission in a letter order issued in
Docket No. ER06-1451 on October 2, 2006.

Service Agreement No. 920 expired consistent with its own terms on December
31, 2011.6 The Parties have agreed to enter into the Agreement for the purpose of
documenting certain terms and conditions governing the relationship between National

The Honorable Kimberley D. Bose February 24, 2012

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Grid and GUSC after the expiration of Service Agreement No. 920. The attached

Agreement addresses the terms and conditions of the interconnection between the GUSC electric system and the Niagara Mohawk transmission system. GUSC has also entered into a standard service agreement under the NYISO OATT for transmission service to GUSC commencing January 1, 2012.

II.Interconnection Agreement

Niagara Mohawk has entered into comparable interconnection agreements with
New York municipal electric systems in recent years. The attached Agreement is
modeled, in large part, on an interconnection agreement between Niagara Mohawk and
the Village of Solvay, New York, which was accepted by Commission letter order on
October 22, 2003 in Docket No. ER03-1304-000. Consistent with the Solvay agreement
and Commission precedent, the Agreement provides for the direct assignment of certain
costs and charges for interconnection facilities that are solely for the use of GUSC.

As documented in Article IV of the Agreement, all interconnection facilities and upgrades necessary to effect the transfer of electricity from Niagara Mohawk’s
transmission system to GUSC have already been constructed. As of the effective date, no interconnection study contemplates any further changes to these interconnection facilities and upgrades. Certain provisions of Article IV of the Agreement shall apply only if
modifications are made to the interconnection facilities or the transmission system after the effective date of the Agreement.

The Agreement is for a term of twenty years. The Agreement also includes terms
and conditions that are standard for comparable interconnection agreements, including
provisions addressing the coordinated operation and maintenance of the Niagara Mohawk
transmission system and the GUSC electric system, metering provisions, provisions
addressing emergency operations, insurance and liability provisions, and miscellaneous
provisions.

III.Effective Date

Niagara Mohawk requests waiver of the Commission’s 60-day notice requirement
to permit the Agreement to become effective on January 1, 2012. Good cause exists for
such a waiver. As detailed above, the attached Agreement documents certain terms and
conditions to facilitate continuation of service to GUSC after the termination of Service
Agreement No. 920 on December 31, 2011. Niagara Mohawk and GUSC worked in
good faith to finalize the Agreement as soon as possible. Although the Parties had
reached agreement in principle by the end of 2011, the need to finalize the language of
certain provisions, including Article IV, resulted in the execution of the Agreement in
February. Granting the requested waiver will allow Niagara Mohawk to accommodate

The Honorable Kimberley D. Bose February 24, 2012

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GUSC and is in the public interest and consistent with the standard set forth by the Commission in Central Hudson.7

Niagara Mohawk requests a waiver of any Commission requirements not specifically addressed herein necessary to allow the included agreement to become effective as of January 1, 2012.

IV.Communications and Service

Communications and correspondence with respect to this matter should be

addressed to the following individuals, and the following should be included on the

official service list for this proceeding:8

William Malee

Director, Transmission Commercial Services
Niagara Mohawk Power Corporation,

A National Grid Company

40 Sylvan Road

Waltham, MA 02451 (781) 907-2422

bill.malee@us.ngrid.com

Amanda Downey

Counsel for National Grid

40 Sylvan Road

Waltham, MA 02451-1120 781-907-2136

amanda.downey@nationalgrid.com

Sean A. Atkins

Walton Harris Walker III Alston & Bird, LLP

The Atlantic Building 950 F Street, NW

Washington, DC 20004 (202) 239-3300

(202) 239-3333 facsimile
sean.atkins@alston.com
walton.walker@alston.com

7See Central Hudson Gas & Electric Corp., 60 FERC ¶ 61,106 at 61,338, reh’g denied, 61 FERC ¶

The Honorable Kimberley D. Bose February 24, 2012

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V.Conclusion

For the reasons stated herein, Niagara Mohawk respectfully requests that the Commission accept the Agreement, effective January 1, 2012.

Copies of this filing have been served on Griffiss, the New York State Public Service Commission, and the NYISO.

Respectfully submitted,

/s/ Amanda Downey

Amanda Downey

National Grid USA Service Company, Inc.

40 Sylvan Road

Waltham, MA 02451

Attorney for Niagara Mohawk Power
Corporation, d/b/a National Grid