10 Krey Boulevard Rensselaer, NY 12144

June 14, 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 Amended and Restated Small Generator Interconnection
Agreement Among the New York Independent System Operator, Inc., Niagara
Mohawk Power Corporation d/b/a National Grid, and Albany Energy LLC and
Request for Waiver of the 60-Day Notice Period, Docket No. ER12-___-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 Amended and Restated Small
Generator Interconnection Agreement (“Amended Agreement”) as Service Agreement No. 1168 among the NYISO, National Grid as the Transmission Owner, and Albany Energy LLC
(“Albany Energy”) as the Interconnection Customer.3

The Joint Filing Parties respectfully request that the Commission accept the Amended 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
Amended Agreement effective as of May 2, 2012.

I.Background

The Amended Agreement supersedes a Small Generator Interconnection Agreement
(“SGIA”) among the parties that was filed in Docket No. ER08-427-000, as Service
Agreement No. 1168 (“Original Agreement”). The Original Agreement was accepted by the
Commission on February 28, 2008.4 The Original Agreement stated that Albany Energy’s
landfill recovery generation facility (“Facility”) would consist of two generating units with a

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, X and Z of the NYISO’s Open Access Transmission Tariff (“OATT”).

4 New York Independent System Operator, Inc. and Niagara Mohawk Power Corporation d/b/a National Grid, Order, Docket No. ER08-427-000 (issued February 28, 2008).

Honorable Kimberly D. Bose June 14, 2012

Page 2

combined capacity of 1.9 MW, associated breakers, and appurtenant equipment and a third

generating unit with capacity of 950 kW, with a total generating capacity of 2.85 MW.5 The

Original Agreement also specified that the Point of Interconnection would be the tap point on the Connecting Transmission Owner’s 34.5 kV Karner-Patroon Line #5.

II.Discussion of Changes

Since the filing of the Original Agreement, Albany Energy proposed to expand the

Facility from 2.85 MW to 9.2 MW (“New Facility”). The proposed expansion was evaluated
through the NYISO interconnection process. As a result of the proposed expansion, the
equipment and Milestones specified in the Original Agreement require modification. The Joint
Filing Parties therefore submit this Amended Agreement to reflect the modifications to the
Original Agreement.

Specifically, the Amended Agreement modifies the SGIA as follows:

• The body and attachments to the Amended Agreement reflect modifications to the

Original Agreement required by the current pro forma SGIA, certain provisions of
which were not in existence at the time the Original Agreement was executed;

• The body of the Amended Agreement reflects the following modifications to the

body of the Original Agreement: (1) change in the Developer’s name from MM

Albany Energy LLC to Albany Energy LLC; (2) a new effective date - the date of execution of the Amended Agreement; (3) changes to reflect that this is the
“Amended and Restated” version of the Interconnection Agreement; and (4)
ministerial corrections to correct outdated contact information for individuals
referenced in the Notice provisions and incorrect tariff section numbers
referenced in the pro forma SGIA;

• Section 1.3.1 of the body of the Amended Agreement has been modified to

incorporate a reference to Attachment 5 in order to clarify that with respect to
Capacity Resource Interconnection Service (“CRIS”), the Interconnection
Customer elected not to have the additional capacity created by the uprate
evaluated for deliverability in the Class Year Facilities Study process and,
therefore, the New Facility’s CRIS will remain 2.5 MW unless and/or until the
CRIS value is modified pursuant to applicable provisions of the NYISO’s OATT;

• Attachment 2 has been modified to reflect the expansion of the Facility, from 2.85

MW to 9.2 MW including: (1) additional technical detail for the existing

generators and appurtenant equipment (e.g., reactive power capability and

winding configurations); (2) a clear demarcation of existing versus new facilities
and equipment; (3) design and construction requirements for the expansion of the
existing facility (i.e., the New Facility); (4) a description of the phases of the
interconnection of the New Facility; (5) details regarding the generator lead

5 Additional details regarding the interconnection are found in Attachment 2 of the Amended Agreement.

Honorable Kimberly D. Bose June 14, 2012

Page 3

relocation modifications; and (6) a cost estimate for work related to the

Connecting Transmission Owner’s Interconnection Facilities and modifications thereto required by the expansion;

• Attachment 3 has been modified to reflect an updated one-line diagrams;

• Attachment 4 has been modified to reflect updated Milestones associated with the
Existing Facility and to add Milestones associated with the New Facility;

• Attachment 5 has been modified primarily to reflect (1) changes and updates to

the Connecting Transmission Owner’s Electric System Bulletins referenced in the
Original Agreement; and (2) that the New Facility’s Capacity Resource
Interconnection Service will continue to be 2.5 MW unless and/or until the CRIS
value is modified pursuant to applicable provisions of the NYISO’s OATT;6 and

• Attachment 6 has been modified to reflect that there are no Distribution Upgrades
for the New Facility; and to provide a description of and cost estimate for System
Upgrade Facilities required for the New Facility.

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

The Joint Filing Parties request an effective date of May 2, 2012 for the Amended

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.7

6 Attachment 5 has also been modified to provide that (1) the Interconnection Customer will comply with requirements set forth in the Amended Agreement; (2) the Interconnection Customer will be responsible for
correcting certain system performance issues that may arise in day-to-day operations of the New Facility; and (3) that the Amended Agreement does not guarantee delivery of New Facility’s full capability to the transmission system. The Parties are working to further revise the Amended Agreement to revise or delete these provisions, which include an inapplicable reference to an Interim Constrained Operation Period. Toward that end, the Parties anticipate executing and filing a second amendment to reflect such changes in the future.

7 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 June 14, 2012

Page 4

IV. 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

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@us.ngrid.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

Honorable Kimberly D. Bose June 14, 2012

Page 5

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.

VII. Conclusion

Wherefore, the NYISO respectfully requests that the Commission accept the Amended Agreement effective as of May 2, 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.