Daniel Galaburda
Assistant General Counsel
December 17, 2010
The Honorable Kimberly D. Bose Secretary
Federal Energy Regulatory Commission 888 First Street, NE, Room lA
Washington, D.C. 20426
RE: Interconnection Agreement Between Niagara Mohawk Power Corp. and
WPS Syracuse Generation, LLC
Docket No. ER11-_______
Dear Secretary Bose:
Pursuant to Section 205 of the Federal Power Act, 16 U.S.C. § 824d, and Part
35.12 of the Federal Energy Regulatory Commission’s (“Commission”) regulations, 18
C.F.R. Part 35.12 (2010), Niagara Mohawk Power Corporation, d/b/a National Grid
(“Niagara Mohawk”), submits for filing a Second Revised Service Agreement No. 316
(“Second Revised Service Agreement”) between Niagara Mohawk and WPS Syracuse
Generation, LLC (“WPS Syracuse” or “Producer”) under the New York Independent
System Operator, LLC’s (“NYISO”) open access transmission tariff, FERC Electric Tariff,
Original Volume No. 1. Under the Second Revised Service Agreement, Niagara Mohawk
will continue to provide interconnection service to WPS Syracuse for WPS Syracuse’s
approximately 108 MW generating facility located in the Town of Geddes, New York.
I.Information Submitted with Filing
Niagara Mohawk filed the original interconnection agreement on March 7, 2002 in
Docket No. ER02-1314-000 (“Original Agreement”). It was accepted pursuant to a
Commission letter order on May 3, 2002 in Docket No. ER02-1314-000. On August
13, 2002, Niagara Mohawk filed a First Revised Service Agreement (“First Revised
Agreement”) and this agreement was accepted by Commission letter order on October 4,
2002 in Docket No. ER02-2462-000. The First Revised Agreement set the term to
expire in June 2008. Niagara Mohawk and WPS Syracuse desire that the
interconnection relationship continue for an additional ten years. Due to the expiration
of the First Revised Agreement and in an effort to ensure the justness and
reasonableness of the Second Revised Service Agreement, Producer and Niagara Mohawk
mutually agree to use as the form of the Second Revised Service Agreement the pro forma
Large Generator Interconnection Agreement in Attachment X of the NYISO OATT.
The Second Revised Service Agreement restates, supersedes and replaces the First Revised Agreement in its entirety. Under the Second Revised Service Agreement, Niagara Mohawk will charge Producer for its actual costs of operating and maintaining the interconnection facility.
40 Sylvan Road, Waltham, MA 02451
T: 781-907-1847F: 781-907-5701 daniel.galaburda@us.ngrid.com www.nationalgrid.com
Pursuant to the Commission’s order in New England Power Company, 109
FERC ¶ 61, 364 (2004) (“NEP”), the Commission's standard interconnection rules
promulgated in Order No. 2003, and the procedures and agreements related thereto,
including the NYISO Large Facility Interconnection Procedures, do not apply in this
case. In NEP, the Commission held that, where there are no proposed increases in capacity
or material modifications of the characteristics of an existing generating facility, Order
No. 2003 did not apply to generator interconnection agreements because they were not
“new interconnection requests.” Id. at P 13; see also Jersey Central Power & Light
Company, 110 FERC ¶ 61,273 at P 11 (2005)(“because the revision to the existing
interconnection agreement does not ‘increase the capacity of a generating unit in the PJM
Region,’ PJM’s interconnection procedures in its OATT...do not apply”). The WPS
Syracuse generating facility is an existing facility, and there are no proposed increases in
capacity or material modifications to the characteristics of the facility. Thus, as the
Commission held in NEP, the Commission should also find here that the Commission’s
standard interconnection rules promulgated in Order No. 2003, and the procedures and
agreements related thereto, including the NYISO Large Facility Interconnection
Procedures, do not apply in this case.
II.Communications and Service
Communications regarding this filing should be addressed to the following individuals, whose names should be entered on the official service list maintained by the Secretary for the docket established with respect to this filing:
Daniel Galaburda
Assistant General Counsel and Director, Federal Regulatory National Grid USA Service Company, Inc.
40 Sylvan Road
Waltham, MA 02451 Phone: (781) 907-1847 Fax: (781) 907-5701
Email: daniel.galaburda@us.ngrid.com
Mary Ellen Paravalos
Vice President of Transmission Regulation & Commercial Services Niagara Mohawk Power Corporation,
d/b/a National Grid 40 Sylvan Road Waltham, MA 02451
Phone: (781) 907-5706
Email: Mary.ellen.paravalos@us.ngrid.com
William Malee
Director of Transmission Commercial Services
Niagara Mohawk Power Corporation, d/b/a National Grid
40 Sylvan Road
Waltham, MA 02451
Phone: (781) 907-2422
Email: bill.malee@us.ngrid.com
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A copy of this filing has been served on WPS Syracuse, the New York Independent System Operator and the New York State Department of Public Service.
III. Proposed Effective Date
In accordance with section 35.3 of the Commission's Regulations, Niagara Mohawk respectfully requests that the Commission accept this Second Revised Service Agreement for filing, effective as of February 15, 2011.
IV. Order No. 614 Designations
Pursuant to the Commission's orders in Designation of Electric Rate Schedule Sheets, Order No. 614, 90 FERC ¶ 61,352 (2000) and Southwest Power Pool, Inc., 92 FERC ¶ 61,109 (2000), Niagara Mohawk is required to designate the Revised Service Agreement as a service agreement under the NYISO OATT. As a result, Niagara Mohawk has designated the Service Agreement as:
New York Independent System Operator, Inc. Open Access Transmission Tariff
Second Revised Service Agreement No. 316 Issued by: Mary Ellen Paravalos
Vice President of Transmission Regulation & Commercial
Services National Grid USA for Niagara Mohawk Power
Corporation
Issued on: December 17, 2010
Effective: February 15, 2011
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V.Documents Enclosed
Enclosed please find:
i.This filing letter;
ii.A Second Revised Service Agreement No. 316
Copies of this filing have been served on WPS Syracuse, the NYISO and New York Public Service Commission.
Respectfully submitted,
/s/ Daniel Galaburda
Daniel Galaburda
Assistant General Counsel, Federal Regulatory
National Grid USA Service Company, Inc.
40 Sylvan Road
Waltham, MA 02451
Attorney for
Niagara Mohawk Power Corporation, d/b/a National Grid
Enclosures
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