HUNTON & WILLIAMS LLP

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J. KENNERLY DAVIS, JR.

DIRECT DIAL: 804 • 788 • 8559
EMAIL: kdavis@hunton.com

September 23, 2011

Re: Filing of an Executed Large Generator Interconnection Agreement Among the
New York Independent System Operator, Inc., Niagara Mohawk Power
Corporation d/b/a National Grid, New York State Electric & Gas Corporation,
and Nine Mile Point Nuclear Station, LLC, and Request for Waiver of 60-Day
Notice Period; Docket No. ER11-___-000

Dear Ms. Bose:

Pursuant to Section 205 of the Federal Power Act,1 Section 35.12 of the Commission’s
regulations,2 and Section 30.11.3 of the New York Independent System Operator, Inc.’s
(“NYISO’s”) Standard Large Facility Interconnection Procedures,3 the NYISO, Niagara
Mohawk Power Corporation d/b/a National Grid (“National Grid”), and New York State Electric
& Gas Corporation (“NYSEG”) (together, the “Joint Filing Parties”) hereby tender for filing an
executed Large Generator Interconnection Agreement (the “Nine Mile Agreement”).4 The Nine
Mile Agreement has been entered into by and among the NYISO, National Grid and NYSEG as
the Connecting Transmission Owners, and Nine Mile Point Nuclear Station, LLC (“Nine Mile”),
as the Developer, to interconnect the uprated, existing Nine Mile Point Unit 2 nuclear generating
facility to the New York State Transmission System. The Nine Mile Agreement is labeled as
Service Agreement No. 1757 under the NYISO Open Access Transmission Tariff (“OATT”).
As described below, the Nine Mile Agreement supersedes an existing interconnection agreement
entered into by and among National Grid, NYSEG, and Nine Mile in 2001.

1 16 U.S.C. § 824d (2008).

2 18 C.F.R. § 35.12 (2009).

3 NYISO OATT Attachment X § 30.11.3.

4 Capitalized terms not otherwise defined have the meaning ascribed to them in the NYISO OATT and Attachments S and X to the NYISO OATT.

Honorable Kimberly D. Bose September 23, 2011

Page 2 of 11

The Joint Filing Parties respectfully request that the Commission accept the Nine Mile Agreement for filing. With the exceptions described in Part I.B of this letter, the Nine Mile Agreement conforms to the NYISO’s pro forma Standard Large Generator Interconnection
Agreement that is contained in Attachment X of the NYISO OATT (“Pro Forma LGIA”).
Further, as described in Part II of this letter, the Joint Filing Parties respectfully request a waiver of the Commission’s prior notice requirements to make the Nine Mile Agreement effective as of September 8, 2011, which is the date of its execution.

I.Discussion

A.Background

Nine Mile operates the existing Nine Mile Point Unit 2 nuclear generating facility located in Oswego, New York (“Existing Nine Mile Facility”), which Nine Mile co-owns with the Long Island Lighting Company d/b/a LIPA. The Existing Nine Mile Facility currently has a capacity
of 1212 MW. The Existing Nine Mile Facility interconnects with the New York State
Transmission System in the Scriba Substation, which is jointly owned by National Grid and
NYSEG. Additional details regarding the Existing Nine Mile Facility can be found in Appendix C of the Nine Mile Agreement.

The rights and obligations associated with interconnecting the Existing Nine Mile

Facility to the New York State Transmission System are currently set forth in a three-party

interconnection agreement that was entered into by and among National Grid, NYSEG, and Nine
Mile (“Existing Interconnection Agreement”). The Existing Interconnection Agreement is
designated as Service Agreement No. 309 under the NYISO OATT. An unexecuted version of
the Existing Interconnection Agreement was first accepted by the Commission in Docket No.
ER01-1986-000 on July 6, 2001.5 An updated and signed version of the Existing
Interconnection Agreement was accepted by the Commission by a letter order issued in Docket
No. ER02-1067 on April 23, 2002. An amendment to the Existing Interconnection Agreement
was accepted by the Commission by a letter order issued in Docket No. ER02-2494 on October
4, 2002.

Nine Mile is expanding the capacity of the Existing Nine Mile Facility by 168 MW

through an uprate project (“Expansion Project”). The combined capacity of the Existing Nine
Mile Facility and the Expansion Project (together, the “Large Generating Facility”) will total
1380 MW. The Large Generating Facility is expected to operate at 1327 MW beginning in June
2012. After the loading of additional nuclear fuel during a scheduled maintenance outage in
2014, the Large Generating Facility is expected to operate at its total capacity of 1380 MW
beginning in June 2014. The Large Generating Facility will continue to interconnect with the
New York State Transmission System in the Scriba Substation. Figure A-1 in Appendix A of the
Nine Mile Agreement provides a one-line diagram that illustrates the interconnection in the

5 Niagara Mohawk Power Corp., et al., 96 FERC ¶ 61,027 (July 6, 2001).

Honorable Kimberly D. Bose September 23, 2011

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Scriba Substation. Additional details regarding the Large Generating Facility can be found in Appendix C of the Nine Mile Agreement.

The four-party Nine Mile Agreement submitted here for the Large Generating Facility will supersede the Existing Interconnection Agreement. Concurrent with this filing, National Grid is submitting a filing with the Commission requesting that the Commission cancel the Existing Interconnection Agreement, with such cancellation to be effective on the Commissionaccepted effective date of the new four-party Nine Mile Agreement.

B. The Nine Mile Agreement Generally Conforms to the Pro Forma LGIA

Contained in Attachment X of the NYISO OATT

The Nine Mile Agreement was executed on September 8, 2011, by the NYISO, National
Grid, NYSEG, and Nine Mile (collectively, the “Parties”). The Nine Mile Agreement generally
follows the Pro Forma LGIA. However, the Nine Mile Agreement does contain variations from
the Pro Forma LGIA as described in Sections I.B.1 through I.B.9 below. These variations are
necessary due to the unique circumstances associated with the Nine Mile Agreement, including
the conversion of the three-party Pro Forma LGIA into a four-party agreement to accommodate
two Connecting Transmission Owners, and the incorporation from the Existing Interconnection
Agreement of several provisions specific to this nuclear generating facility. The Joint Filing

Parties submit that the changes specified below satisfy the Commission’s standard for variations from the Pro Forma LGIA, because unique circumstances exist that require a non-conforming agreement.6 Therefore, the Joint Filing Parties respectfully request that the Commission accept the Nine Mile Agreement with these non-conforming changes.

1. Modifications to Reflect Four-Party Agreement

The Pro Forma LGIA is structured as a three-party agreement among the NYISO, the
Developer, and the applicable Connecting Transmission Owner. As described above, National
Grid and NYSEG jointly own the Scriba Substation and certain additional facilities associated
with the Existing Nine Mile Facility. Accordingly, the Parties have agreed to modify the Pro
Forma LGIA to make the Nine Mile Agreement a four-party agreement, with both National Grid
and NYSEG included as Connecting Transmission Owners. This approach is consistent with the
Existing Interconnection Agreement, accepted by the Commission, to which both National Grid
and NYSEG are parties.

To create the four-party Nine Mile Agreement, the Parties have agreed to modify the Pro
Forma LGIA by allocating between the two Connecting Transmission Owners the rights and
obligations normally assigned to one Connecting Transmission Owner. National Grid and
NYSEG have previously designated between themselves certain rights and obligations associated
with operating and maintaining the Scriba Substation and related facilities by means of a

6 See, e.g., PJM Interconnection, LLC, 111 FERC ¶ 61,163 at PP 10-11, reh’g denied, 112 FERC ¶ 61,282

(2005).

Honorable Kimberly D. Bose September 23, 2011

Page 4 of 11

Transmission Owners Agreement entered into by and between National Grid and NYSEG, dated February 21, 2001, and accepted by the Commission as Niagara Mohawk Power Corporation
FERC Electric Rate Schedule No. 300 in Docket No. ER01-1986-000. As National Grid is the
party actually performing the operation and maintenance requirements under the Transmission
Owners Agreement, the Nine Mile Agreement has, for the avoidance of confusion, been
modified to replace the term “Connecting Transmission Owner” in many locations with the term “National Grid,” which has been defined to mean “National Grid acting on behalf of both
National Grid and NYSEG (collectively) pursuant to the Transmission Owners Agreement,”
except as expressly indicated otherwise in the Nine Mile Agreement. In the remaining locations in the Nine Mile Agreement, the term “Connecting Transmission Owner” is used to signify
either National Grid or NYSEG, and the term “Connecting Transmission Owners” in the plural is used to signify collectively both National Grid and NYSEG.

In addition to the changes to the term Connecting Transmission Owner as used in the Pro Forma LGIA, the Parties have agreed to amend certain provisions in the Pro Forma LGIA that do not function properly as part of a four-party agreement:

• Sections 17.1.1 and 17.1.2 of the Pro Forma LGIA establish that upon a breach of the

agreement, the non-breaching parties shall take action to provide written notice of the breach, and shall act together to declare a default and terminate the agreement. The Parties have agreed that in the event of a breach by one of the Connecting Transmission Owners, only the NYISO and Developer are required to act together to take the actions assigned to the non-breaching parties.

• Sections 27.2 and 27.4 of the Pro Forma LGIA establish the method for selecting and

paying arbitrators to resolve disputes. Pursuant to Section 27.2, each Party is responsible
for selecting an arbitrator for a three-member panel if the Parties cannot agree on a single
arbitrator. Pursuant to Section 27.4, each Party is responsible for either one-third of the
costs of a single arbitrator, or the full costs of an arbitrator selected for a three-member
panel. The Parties have agreed to modify these provisions to provide in the Nine Mile
Agreement that the Connecting Transmission Owners (i) will mutually select an

arbitrator, and (ii) will both be responsible for the one-third share of the cost of that arbitrator. This cost will be allocated between the Connecting Transmission Owners based on each Connecting Transmission Owner’s percentage ownership of the Scriba Substation and related facilities.

• The Parties have agreed in the Nine Mile Agreement to revise all of those provisions in

the Pro Forma LGIA that refer to the number of parties, so that these provisions function within a four-party agreement. For example, Section 29.11 has been modified to require that the four, rather than three, Parties to the agreement must execute a written instrument to amend the agreement.

• The Parties have agreed to make additional conforming changes throughout the Nine

Mile Agreement to ensure that it functions as a four-party agreement, including: (i)

changing certain terms from singular to plural (e.g., “its” to “theirs”) and related

grammatical changes, (ii) including terms such as “each,” “either,” “respective,”

“affected,” or similar when the term Connecting Transmission Owner or Party could refer

Honorable Kimberly D. Bose September 23, 2011

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to either one of or both National Grid or NYSEG, and (iii) other related conforming changes to specify the appropriate Parties.

2. Modifications to Address Requirements for Nuclear Facility

The Large Generating Facility is a nuclear generating facility that is subject to certain
nuclear-specific requirements that are not addressed in the Pro Forma LGIA. The Parties have
agreed to several modifications to the Pro Forma LGIA to insert provisions that are specific to
and necessary for the Large Generating Facility’s operation as a nuclear generating facility in
accordance with applicable regulatory requirements. These insertions are consistent with the
nuclear-specific provisions included in the Existing Interconnection Agreement previously

accepted by the Commission.

The Nine Mile Agreement includes the following additional provisions and revisions to address the requirements for a nuclear facility:

• Section 9.10 (“NRC Requirements and Commitments for Voltage Limits”) establishes

notification requirements concerning the required voltage limits for the off-site power supply for the Large Generating Facility.

• Section 9.11 (“Energy Management System Voltage Monitoring”) sets forth rights and

obligations related to an energy management system contingency alarm, including related
requirements regarding the cost and maintenance of the energy management system.
• Section 9.12 (“Operating Committee”) sets forth the requirements for the establishment
of an Operating Committee, the appointment of representatives to the Operating
Committee from Nine Mile, National Grid, and NYSEG, and the duties of the
representatives. In addition, Section 5.19.1 has been revised to require that Connecting
Transmission Owners and the Developer shall mutually agree through the Operating
Committee on scheduling any modification to their respective facilities covered by the
Nine Mile Agreement.

• Section 10.6 (“NRC Maintenance Rule”) sets forth Developer’s and Connecting

Transmission Owners’ responsibilities for complying with the Nuclear Regulatory Commission (“NRC”) Maintenance Rule.

• Section 10.5 (“Operating and Maintenance Expenses”) has been revised to provide that

the Developer will also be responsible for incremental costs incurred by the Connecting
Transmission Owners to assure compliance with the NRC Maintenance Rule.
• Section 18.3 (“Insurance and Indemnification for Nuclear Generating Unit”) sets forth
insurance and indemnification requirements specific to Developer’s nuclear facility. The
existing insurance requirements in Section 18.3 have been relabeled “General Insurance”
and are now located in Section 18.4.

•Section 5 of Appendix C lists those Scriba Substation components subject to the NRC

Maintenance Rule.

• The Parties have clarified throughout the Nine Mile Agreement that actions performed

under the agreement must be performed in accordance with NRC Requirements and Commitments.

Honorable Kimberly D. Bose September 23, 2011

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• The following defined terms were included to address nuclear facility specific issues:
“NRC,” “NRC Maintenance Rule,” “NRC Requirements and Commitments,” “Nuclear
Incident,” “Off-site Power Supply Points,” “Operating Committee,” and “Operating
Committee Member.”

3. Insertion of Description of Joint-Use Facilities

Nine Mile and National Grid jointly operate certain generator and switchyard facilities
that are owned by Nine Mile or National Grid. The Parties have agreed to insert a new Section

9.13 (“Operation of Joint Use Facilities”) and defined term (“Joint Use Facilities”) that state that
Nine Mile and National Grid will jointly operate the Joint Use Facilities in a safe and reliable
manner in accordance with the Nine Mile Agreement, the NYISO’s tariffs and procedures, and
National Grid’s requirements as described in Section 3 of Appendix C of the Nine Mile
Agreement. The Parties have listed the Joint Use Facilities in Section 4 of Appendix C of the
Nine Mile Agreement. This approach is consistent with the Existing Interconnection Agreement,
accepted by the Commission, to which both Nine Mile and National Grid are parties.

4. Modifications to Reflect Nine Mile’s Acquisition of Installed Capacity Deliverability Rights

The NYISO will provide Nine Mile with both Energy Resource Interconnection Service
(“ERIS”) and Capacity Resource Interconnection Service (“CRIS”) as provided for in Section

4.1.1 of the Pro Forma LGIA. As described in Section 4 of Appendix A of the Nine Mile

Agreement, the Existing Nine Mile Facility currently has 1148.3 MW of grandfathered Installed
Capacity deliverability rights. The Expansion Project was included in Class Year 2008 for
purposes of ERIS cost allocation and CRIS cost allocation pursuant to Attachment S of the
NYISO OATT. Nine Mile accepted its cost allocation for ERIS, but declined to accept its cost
allocation for CRIS. However, in accordance with Section 25.9.5 of Attachment S of the NYISO
OATT, Nine Mile has contracted with two existing facilities for them to transfer to Nine Mile an
additional 96.3 MW of Installed Capacity deliverability rights. Accordingly, the Parties have
agreed to modify Section 4.1.1 of the Nine Mile Agreement, which indicates that Nine Mile has
elected for the NYISO to provide it with CRIS, subject to Section 4 of Appendix A of the Nine
Mile Agreement. Section 4 of Appendix A establishes that, pursuant to Section 25.9.5 of
Attachment S of the NYISO OATT, the Large Generating Facility will acquire 96.3 MW of
transferred Installed Capacity deliverability rights from the two existing facilities when the Large
Generating Facility becomes operational at the level necessary to utilize the transferred rights.
At that point, the NYISO will provide the Large Generating Facility with a total of 1244.6 MW
of CRIS.

5. Modifications to Reflect Work by National Grid on Developer’s Attachment Facilities

Nine Mile and National Grid have agreed that National Grid will perform certain work on
the Developer’s Attachment Facilities for the Large Generating Facility as set forth in Sections

Honorable Kimberly D. Bose September 23, 2011

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1(a)(ii) and 1(a)(iii) of Appendix A of the Nine Mile Agreement. The Parties have agreed to

modifications to Sections 5.5 (“Equipment Procurement”), 5.6 (“Construction Commencement”),

5.11 (“Connecting Transmission Owner’s Attachment Facilities Construction”), 11.5 (“Provision
of Security”), and 12.2 (“Final Invoice”) of the Pro Forma LGIA to make clear that National
Grid is responsible for this work on the Developer’s Attachment Facilities and that Nine Mile is
responsible for providing security for and making payments in connection with this work.

6. Modification to Reflect Engineering, Procurement & Construction Services Agreement

National Grid has already begun engineering and procurement work in connection with
the new Attachment Facilities for the Expansion Project by means of an Engineering,
Procurement & Construction Services Agreement (“EPC Agreement”) entered into by and
between National Grid and Nine Mile, dated March 11, 2011, and filed with the Commission as
Service Agreement No. 1711 under the NYISO OATT in Docket No. ER11-3058-000. The
Commission accepted the EPC Agreement by letter order issued on April 29, 2011. National
Grid and Nine Mile entered into the EPC Agreement in accordance with Section 30.9 of the
Standard Large Facility Interconnection Procedures in Attachment X of the NYISO OATT,
which provides that prior to the execution of an interconnection agreement, the Developer and
Connecting Transmission Owner may enter into an engineering and procurement agreement for
the Connecting Transmission Owner to begin the engineering and procurement of long-lead time
items necessary for the establishment of the interconnection. The EPC Agreement will terminate
on the Commission-accepted effective date of the Nine Mile Agreement. The Parties have set
forth in Appendix C of the Nine Mile Agreement that any payments made by Nine Mile to
National Grid under the EPC Agreement shall reduce, on a dollar for dollar basis, Nine Mile’s
security posting and payment obligations under the Nine Mile Agreement for the new
Attachment Facilities for the Expansion Project.

7. Modifications to Reflect Existing Nine Mile Facility

As explained above in Section I.A of this filing letter, the Nine Mile Agreement will

supersede the Existing Interconnection Agreement for the interconnection of the Existing Nine
Mile Facility. The Parties have agreed to the following modifications to the Pro Forma LGIA to
describe existing facilities associated with the Existing Nine Mile Facility that are already in
place:

• Appendix A of the Pro Forma LGIA provides for a description of the new Attachment
Facilities needed as a result of the Interconnection Request. The Parties have revised
Appendix A to also include a description of facilities that were previously constructed
under the Existing Interconnection Agreement and are already in place.

• The Parties have also agreed to list, in Section 6 of Appendix C of the Nine Mile

Agreement, the existing transmission facilities in the Scriba Substation that are jointly owned by National Grid and NYSEG.

Honorable Kimberly D. Bose September 23, 2011

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• Section 5.16 of the Pro Forma LGIA establishes that if the Developer suspends

construction work by the Connecting Transmission Owner and does not request that the
Connecting Transmission Owner recommence that work within three years, the
agreement will be terminated. The Parties have revised Section 5.16 to clarify that if the
Expansion Project is suspended and not recommenced within three years, only the
Expansion Project will be terminated, and not the Nine Mile Agreement. The Nine Mile
Agreement will continue on and will be amended to reflect the termination of the
Expansion Project.

8. Modifications to Address New Attachment Facilities Not Part of the Expansion
Project

National Grid and Nine Mile have identified and agreed to certain additional upgrades to metering equipment that are not required to interconnect the Expansion Project, but that will
allow for the updating of certain metering equipment. The metering equipment Attachment
Facilities are listed in Sections 1(a)(iii) and 1(b)(iii) of Appendix A to the Nine Mile Agreement. National Grid and Nine Mile have agreed that National Grid will engineer, procure, construct,
install, test, and commission this new metering equipment on the milestone schedule set forth in Appendix B to the Nine Mile Agreement and that Developer will be responsible for the costs of these upgrades, which cost is estimated in Appendix A.1(c) of the Nine Mile Agreement.
Developer will pay operating and maintenance costs on such metering equipment in accordance with Section 10.5 of the Nine Mile Agreement.

9. Other Modifications

The Nine Mile Agreement also includes a small number of modifications to correct the following typographical errors in the Pro Forma LGIA:

• In the table of contents, the term “Interconnection” has been capitalized to make it
consistent with the other headings.

• In the preamble to Article 1, the reference to Section 30.1.0 has been modified to clarify
that the reference is to Section 30.1 of Attachment X of the NYISO OATT.

• In the final sentence of Section 9.6.3, the reference to “NPCC criteria A-3” has been
updated to “NPCC Directory #12.”

II. Proposed Effective Date and Request for Waiver of Notice Requirement

The Joint Filing Parties request September 8, 2011, as the effective date for the Nine Mile
Agreement, which is the date of execution. The Joint Filing Parties respectfully request that the
Commission waive the prior notice requirement in order to permit the requested effective date.

Honorable Kimberly D. Bose September 23, 2011

Page 9 of 11

The Commission has previously permitted interconnection agreements to become effective upon the date of execution.7

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, National Grid, with the concurrence of the other Parties, requests that the one-line

diagram designated as Figure A-1 in Appendix A of the Nine Mile Agreement be protected from
disclosure as Critical Energy Infrastructure Information (“CEII”). This one-line diagram
contains detailed, one-line schematics of transmission lines, the Scriba Substation, and the Large
Generating Facility that, if disclosed, could pose a threat to the reliability of the New York State
bulk power system and to the health and safety of New York residents. National Grid has
explained that the one-line diagram meets the definition of CEII set forth in 18 C.F.R. §
388.113(c) because (i) it includes detailed information regarding the physical attributes of the
bulk power system; (ii) it contains data that, if disclosed, could pose a threat to the security and
the reliability of the New York State bulk power system; (iii) it contains information exempt
from mandatory public disclosure under 5 U.S.C. § 552(b)(7)(F) because its disclosure could
endanger the life or physical safety of New York residents;8 and (iv) it provides more than
simply the general location of critical infrastructure. Moreover, the Commission has determined
that CEII is exempt from the mandatory public disclosure requirements of the Freedom of
Information Act (“FOIA”) under the exemption 5 U.S.C. 552(b)(7)(F).9 This material has been
omitted from the Public version of the Nine Mile Agreement included in this filing. The material
is included only in the CEII version of the Nine Mile Agreement in the filing.

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

William Malee

Director, Transmission Commercial Services National Grid

40 Sylvan Road

Waltham, MA 02451
Tel: 781-907-2422
Fax: 781-907-5707

Bill.Malee@us.ngrid.com

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).

8 FERC has indicated that CEII is exempt from mandatory disclosure under exemption 7(F) of FOIA. 5

U.S.C. § 552(b)(7)(F). See, e.g, In re Baumgardner, 122 FERC ¶ 62,068 (Jan. 25, 2008); In re Kritikson, 122 FERC ¶ 62,020 (Jan. 11, 2008); In re Hala Ballouz, 119 FERC ¶ 62,204 (June 8, 2007).

9 See id.

Robert E. Fernandez, General Counsel

* Karen Georgenson Gach, Deputy General Counsel 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

* - Designated to receive service.

For National Grid

*William Malee

Director, Transmission Commercial Services 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.

For NYSEG

*Mark A. Chier

Electric Transmission Services
New York Electric & Gas Corporation

18 Link Drive

Binghamton, NY 13904-3222 Tel: (607) 762-8073

Fax: (607)762-8666
machier@nyseg.com

* - Designated to receive service.

* J. Kennerly Davis
Michael J. Messonnier Jr.
Hunton & Williams LLP
951 East Byrd Street
Richmond, VA 23219
Tel: (804) 788-8559
Fax: (804) 788-8218
kdavis@hunton.com
mmessonnier@hunton.com

*Daniel Galaburda

Assistant General Counsel and Director

National Grid

40 Sylvan Road

Waltham, MA 02451-1120 Tel: 781-907-1847

Fax: 781-907-5701

Daniel.Galaburda@us.grid.com

*Jeffrey R. Clark

Bond, Schoeneck & King, PLLC 350 Linden Oaks, Suite 310

Rochester, NY 14625-2825 Tel: (585) 362-4721

Fax: (585) 362-4701 jrclark@bsk.com

Honorable Kimberly D. Bose September 23, 2011

Page 11 of 11

V.Documents Submitted

The Joint Filing Parties submit the following documents:

1. This filing letter;

2. A clean Public version of the Nine Mile Agreement (“Attachment I”);

3. A blacklined Public version of the Nine Mile Agreement showing the changes from
the body of the Pro Forma LGIA (“Attachment II”); and

4. a clean CEII version of the Nine Mile Agreement (“Attachment III”).

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 electric utility regulatory agency of New Jersey. In addition, the
complete public version of this filing will be posted on the NYISO’s website at www.nyiso.com.

VII. Conclusion

For the foregoing reasons, the Joint Filing Parties respectfully request that the

Commission accept this Nine Mile Agreement for filing with an effective date of September 8,
2011.

Respectfully submitted,

/s/ J. Kennerly Davis____________

J. Kennerly Davis

Counsel for the

New York Independent System Operator, Inc.

/s/ Daniel Galaburda____________

Daniel Galaburda

Counsel for

Niagara Mohawk Power Corporation d/b/a National Grid

/s/ Jeffrey R. Clark__________________________ Jeffrey R. Clark

Counsel for

New York State Electric & Gas Corporation

Enclosures