10 Krey Boulevard  Rensselaer, NY 12144

August 1, 2014

By Electronic Delivery

Kimberly D. Bose, Secretary

Federal Energy Regulatory Commission 888 First Street N.E.

Washington, D.C. 20426

Re: New York Independent System Operator, Inc.’s and New York Transmission
Owners’ Compliance Filing; Docket Nos. RM13-2-000, ER14-___________

Dear Ms. Bose:

In compliance with the Federal Energy Regulatory Commission’s (“Commission’s”)

Order No. 792,1 the New York Independent System Operator, Inc. (“NYISO”) and the New

York Transmission Owners (“NYTOs”)2 (together, the “Filing Parties”) respectfully submit

revisions to the Small Generator Interconnection Procedures (“SGIP”) and Small Generator

Interconnection Agreement (“SGIA”) set forth in Attachment Z of the NYISO Open Access

Transmission Tariff (“OATT”).3 The NYISO and the NYTOs, as the Transmission Providers in
New York State,4 are collectively filing this compliance filing to fulfill their obligations under

1 Small Generator Interconnection Agreements and Procedures, Order No. 792, 78 Fed. Reg. 73,239 (Dec. 5, 2013), 145 FERC ¶ 61,159 (2013) (“Order No. 792”), order on clarification, Order No. 792-A, 146 FERC ¶
61,214 (2014) (“Order No. 792-A”).

2 The NYTOs are Central Hudson Gas & Electric Corporation, Consolidated Edison Company of New York, Inc., Long Island Lighting Company d/b/a LIPA (“LIPA”), New York Power Authority (“NYPA”), New York State Electric & Gas Corp., Niagara Mohawk Power Corp. d/b/a National Grid, Rochester Gas & Electric Corp., and Orange & Rockland Utilities, Inc. The Filing Parties note that LIPA and NYPA, as transmission owners not subject to the Commission’s jurisdiction under section 205 of the Federal Power Act, have voluntarily
participated in the development of this filing.

3 Capitalized terms that are not otherwise defined in this filing shall have the meaning specified in

Attachment Z of the NYISO OATT, and if not defined therein, in Attachment X of the NYISO OATT and Section 1 of the NYISO OATT.

4 The term “Transmission Provider” as used in Order No. 792 is defined in the Commission’s pro forma SGIP as: “The public utility (or its designated agent) that owns, controls, or operates transmission or distribution facilities used for the transmission of electricity in interstate commerce and provides transmission service under the Tariff. The term Transmission Provider should be read to include the Transmission Owner when the Transmission Owner is separate from the Transmission Provider.”

Kimberly D. Bose, Secretary August 1, 2014

Page 2 of 15

Order No. 792 and request that the Commission direct a subsequent compliance filing of the
accepted tariff revisions to reflect the ordered effective date, as requested in Section VIII.5

The Filing Parties propose revisions to Attachment Z of the NYISO OATT to incorporate
the pro forma revisions set forth in Order No. 792 with a limited number of variations described
below.6 The proposed variations conform the pro forma revisions to the definitions and
terminology of the NYISO OATT previously accepted by the Commission and make certain
additional enhancements. The proposed variations are consistent with or superior to the pro
forma SGIP and SGIA for the reasons discussed in detail in Section IV, infra. The Filing Parties
respectfully submit that with this compliance filing they fully comply with the requirements set
forth in Order No. 792. The NYISO reviewed the proposed revisions with its stakeholders and
did not receive any objections.

I.DOCUMENTS SUBMITTED

1.This filing letter;

2.A clean version of the proposed revisions to the NYISO’s OATT

(“Attachment I”); and

3.A blacklined version of the proposed revisions to the NYISO’s OATT

(“Attachment II”).

II.COMMUNICATIONS

All communications, pleadings, and orders with respect to this proceeding should be sent to the following individuals:

5 Order No. 792 at P 269. Order No. 792 requires that each public utility Transmission Provider submit a compliance filing to demonstrate that it meets the requirements set forth in the order.

6 The Filing Parties respectfully request that the Commission waive the compliance requirements set forth
in Order No. 792-A to the extent they require the Filing Parties to make two separate filings: (i) to submit the
revisions to Attachment Z of the NYISO OATT to adopt the pro forma language established in Order No. 792, and
(ii) to propose the limited variations described in this compliance filing that are consistent with or superior to the pro
forma language.

Robert E. Fernandez, General Counsel
Raymond Stalter, Director of Regulatory Affairs *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
rstalter@nyiso.com

skeegan@nyiso.com

*Ted J. Murphy

Hunton & Williams LLP
2200 Pennsylvania Avenue, NW Washington, D.C. 20037
Tel: (202) 955-1500

Fax: (202) 778-2201
tmurphy@hunton.com

Kevin W. Jones

*Michael J. Messonnier, Jr. Hunton & Williams LLP 951 East Byrd Street

Richmond, VA 23219
Tel: (804) 788-8200
Fax: (804) 344-7999
kjones@hunton.com

mmessonnier@hunton.com

For the New York Transmission Owners8

(1) Counsel to the New York Transmission Owners:

*Elias G. Farrah

*Erica E. Stauffer

Winston & Strawn LLP 1700 K St., N.W.

Washington, DC 20006-3817

efarrah@winston.com

estauffer@winston.com

And

(2) *Company Representatives Listed on Attachment A at the end of the filing. 9

*Designated to receive service.

7 Waiver of the Commission’s regulations (18 C.F.R. § 385.203(b)(3)(2014)) is requested to the extent necessary to permit service on counsel for the NYISO in both Virginia and Washington, DC.

8 Waiver of the Commission’s regulations (18 C.F.R. § 385.203(b)(3)(2014)) is requested to the extent

necessary to permit service on counsel for the New York Transmission Owners in both New York and Washington,
DC.

9 Waiver of the Commission’s Regulations (18 C.F.R. § 385.203) is requested to the extent necessary to permit the inclusion on the service list of all of the parties on Attachment A.

Kimberly D. Bose, Secretary August 1, 2014

Page 4 of 15

III.BACKGROUND

In its Order No. 2006, the Commission established the pro forma SGIP and SGIA to set forth the terms and conditions under which public utilities must provide interconnection service to Small Generating Facilities of no more than 20 MW.10 In compliance with Order No. 2006, the Filing Parties incorporated the SGIP and SGIA in Attachment Z of the NYISO OATT, with certain proposed variations to the pro forma requirements - variations accepted by the
Commission under the “independent entity” standard.11

Since incorporating the SGIP and SGIA into its OATT, the NYISO has made periodic
enhancements to these procedures pursuant to Section 205 of the Federal Power Act12 and Part

35 of the Commission’s regulations.13 In 2011, for example, the NYISO proposed tariff

revisions that would add a definition of Local System Upgrade Facilities to its SGIP in order to
more equitably allocate study costs and to eliminate the need for certain Small Generating
Facilities - those that trigger no System Upgrade Facilities or only Local System Upgrade
Facilities - to have to be evaluated as a member of a Class Year Interconnection Facilities Study
under the NYISO’s Standard Large Facility Interconnection Procedures (“LFIP”).14

On November 22, 2013, the Commission issued Order No. 792 to amend the pro forma SGIP and SGIA. The Commission identified as the impetus for the order the growth in gridconnected solar photovoltaic generation and small generator interconnection requests driven by state renewable portfolio standards.15 The Commission found that such growth could cause inefficient interconnection queue backlogs and require some Small Generating Facilities to
undergo a more costly study process.16

10 Standardization of Small Generator Interconnection Agreements and Procedures, Order No. 2006,

FERC Stats. & Regs. ¶ 31,180, order on reh 'g, Order No. 2006-A, FERC Stats. & Regs. ¶ 31,196 (2005), order on clarification, Order No. 2006-B, FERC Stats. & Regs. ¶ 31,221 (2006).

11 See New York Independent System Operator, Inc. and New York Transmission Owners, Order on Small
Generator Interconnection Compliance Filing, 118 FERC ¶ 61,130 (February 20, 2007) (accepting compliance filing
in part and directing certain changes); New York Independent System Operator, Inc. and New York Transmission
Owners, Order Granting Rehearing in Part and Denying Rehearing in Part and Accepting Compliance Filing, 119
FERC ¶ 61,333 (June 29, 2007) (granting in part and denying in part request for rehearing, clarifying aspects of
February 2007 order, and accepting compliance filing in part and directing certain changes); New York Independent
System Operator, Inc. and New York Transmission Owners, Letter Order, Docket Nos. ER06-311-004 and ER06-
311-005 (March 3, 2008).

12 See 16 U.S.C. § 824d (2000).

13 18 C.F.R § 35 et seq. (2009).

14 See New York Independent System Operator, Inc., 135 FERC ¶ 61,014 (Apr. 8, 2011) (accepting tariff revisions subject to a compliance filing).

15 Order No. 792 at PP 21-23.

16 Order No. 792 at P 21.

Kimberly D. Bose, Secretary August 1, 2014

Page 5 of 15

To address these concerns, the Commission established, through Order No. 792, revisions
to the pro forma SGIP and SGIA to “reduce the time and cost to process small generator
interconnection requests for Interconnection Customers and Transmission Providers, maintain
reliability, increase energy supply, and remove barriers to the development of new energy
resources.”17 Specifically, Order No. 792 established a package of reforms to: (i) require the
Transmission Provider to provide the Interconnection Customer with a pre-application report; (ii)
revise the threshold for certain generators to be evaluated under the Fast Track Process; (iii)
revise certain requirements regarding the customer options meeting and supplemental review that
follow a generator’s failure of the Fast Track Process screens; (iv) revise the SGIP to specifically
permit the Interconnection Customer to provide written comments on the upgrades required for
the interconnection in the Facilities Study; (v) explicitly provide for energy storage devices in the
SGIP and SGIA; and (vi) make additional clarifications in the SGIP and SGIA.18 Order No. 792
directed Transmission Providers to submit a compliance filing to revise their SGIP and SGIA as
necessary to demonstrate that they satisfy the requirements set forth in the final rule.19

IV.COMPLIANCE REVISIONS

The Filing Parties propose revisions to Attachment Z of the NYISO OATT to amend the
NYISO’s SGIP and SGIA to adopt the pro forma revisions set forth in Order No. 792 with a
limited number of variations described below. Order No. 792 provides that a Transmission
Provider may request variations from the pro forma SGIP and SGIA where the revisions are
consistent with or superior to the pro forma SGIA and SGIP, including in instances in which the
Commission has previously accepted variations to the existing SGIP and SGIA.20

As described below, the variations to the pro forma SGIP and SGIA proposed by the Filing Parties for Attachment Z of the NYISO OATT are consistent with or superior to the pro forma language.

A.Allocation of NYISO and NYTOs Responsibilities as a Transmission

Provider

Both the NYISO and the NYTOs have responsibilities in the interconnection process in
New York that are assigned to the “Transmission Provider” in the pro forma SGIP and SGIA.
The Commission has previously accepted in the Order Nos. 2003 and 2006 proceedings the
Filing Parties’ proposed revisions to the pro forma term “Transmission Provider” that allocate
the Transmission Provider’s responsibilities between the NYISO and the NYTOs.21

17 Order No. 792 at P 3.

18 Order No. 792 at 1.

19 Order No. 792 at P 269.

20 Order No. 792 at P 269.

21 See, e.g., New York Independent System Operator, Inc. and New York Transmission Owners, Order

Granting Rehearing in Part and Denying Rehearing in Part and Accepting Compliance Filing, 119 FERC ¶ 61,333

Kimberly D. Bose, Secretary August 1, 2014

Page 6 of 15

Consistent with the existing allocation of the Transmission Provider’s responsibilities in
the NYISO’s SGIP and SGIA, the Filing Parties propose to replace the term “Transmission
Provider” as used in the pro forma revisions in Order No. 792 with the terms “NYISO,” and
“Connecting Transmission Owner,” or both (e.g., “NYISO, in consultation with the Connecting
Transmission Owner”) to clarify the respective roles and responsibilities of the NYISO and
NYTOs. Specifically, the Filing Parties’ proposed revisions make clear that the NYISO is the
lead party responsible for administering the process for interconnecting to the New York State
Transmission System or Distribution System,22 including taking the lead in the application and
study process. In this role, the NYISO directly interfaces with Interconnection Customers and,
to the extent it requires information from the NYTOs, consults with the NYTOs. The NYTOs
are responsible for providing required information to the NYISO and implementing the
interconnection, including procuring equipment and constructing upgrade facilities. The
proposed revisions reflect this division of responsibilities under the SGIP and SGIA previously
approved by the Commission. They are consistent with or superior to the pro forma language as
they make clear the respective roles and responsibilities of the NYISO and the NYTOs in the
NYISO’s SGIP and SGIA.

B. Revisions to the Pre-Application Report Requirements

1. Fee for Pre-Application Report

Order No. 792 established a default fee of $300 for the Transmission Provider to prepare
the pre-application report.23 However, Order No. 792 also provided that the Transmission
Provider could propose an alternative fixed cost-based fee supported by cost justification because
it would be unjust and unreasonable for it not to recover its actual preparation costs.24
Accordingly, the Filing Parties propose in Section 32.1.2.2 to establish a fixed $1000 fee for
preparing the pre-application report and to set forth the process by which the NYTOs provide the
NYISO with readily available information required for the report and are paid their costs for
preparing such information.

The Filing Parties have determined that $1000 is a more accurate representation of their
actual costs in preparing the pre-application report. To make this determination, the Filing
Parties identified several Small Generator Facility projects previously included on the NYISO’s
interconnection queue and performed the work necessary to complete a pre-application report for

(2007) at P 34 (accepting compliance revisions filed by NYISO and NYTOs on March 22, 2007, in the Order No.
2006 proceeding, including the split of responsibilities between the NYISO and NYTO in the SGIP and SGIA.).

22 The term “Distribution System” was added to the NYISO’s SGIP pursuant to a Section 205 filing in Docket No. ER13-588-000 and defines the term as: “The Transmission Owner’s facilities and equipment used to distribute electricity that are subject to FERC jurisdiction, and are subject to the NYISO’s LFIG or SGIP under FERC Order Nos. 2003 and/or 2006. For the purpose of this Agreement, the term Distribution System shall not include LIPA’s distribution facilities.”

23 Order No. 792 at P 46.

24 Order No. 792 at P 46.

Kimberly D. Bose, Secretary August 1, 2014

Page 7 of 15

these projects. The Filing Parties reviewed the time and resources required to complete the

sample reports and using their standard rates billed for interconnection study work, determined that $1000 more accurately represents the actual costs of the work.

Specifically, the Filing Parties selected the following “test” projects for the above-

described exercise: (1) a 4.8 MW facility proposing to interconnect to distribution facilities

(ultimately determined not to be subject to Commission jurisdiction or the NYISO’s SGIP); (2) a

3.2 MW facility proposing to interconnect at 34.5kV; and (3) a 12.6 MW facility proposing to
interconnect at 115kV. For the first two facilities, the respective Connecting Transmission
Owners collected responsive information that was readily available to them, spending
approximately four (4) to five (5) hours. For the third project, because it proposed to
interconnect at a higher voltage level, the NYISO collected responsive information it had readily
available, spending approximately four (4) hours to do so. Multiplying the number of hours
required for the above projects by the average rates charged by the respective Filing Parties for
interconnection study work, the Filing Parties arrived at actual costs ranging from $660 to $750.
Recognizing that the above projects had already been studied by the Connecting Transmission
Owner and/or the NYISO, the Filing Parties determined that additional time would be needed to
collect such information for projects not previously evaluated. For such projects, the Filing
Parties determined that approximately seven (7) hours would be more likely the amount of time
required to pull the same information, with such time estimate equating to a range of $962.50 to
$1,155 in actual costs (using average study costs at the rates charged by the applicable
Connecting Transmission Owners and NYISO in current interconnection studies). Based on this
analysis, the Filing Parties determined that a pre-application report fee of $1000 would be more
appropriate and supported by the above-described cost justification.

Based on the estimation that most of the readily available information responsive to the
pre-application request form will be available to the respective Connecting Transmission Owners
rather than the NYISO, the Filing Parties determined that dividing this proposed $1000 fee one-
third to the NYISO and two-thirds to the appropriate Connecting Transmission Owner is
consistent with the respective time and resources the parties will spend in preparing the pre-
application reports.

The Filing Parties’ proposed revisions are superior to the pro forma language as they

ensure that the NYISO and the NYTOs recover their actual costs in preparing the pre-application
report.

2. Coordination Required To Process Pre-Application Requests

The NYISO and the NYTOs both possess information necessary for the completion of
the pre-application report. While the NYISO will directly interface with the Interconnection
Customer seeking a pre-application report, much of the readily available information required to
complete the report is in the hands of the NYTOs. For this reason, the Filing Parties propose to
establish a process in Section 32.1.2.2 for the NYISO to obtain information from the NYTOs in
time to complete the pre-application report within the required 20 business days. Specifically,
the NYISO will provide a copy of the pre-application report request form to the appropriate

Kimberly D. Bose, Secretary August 1, 2014

Page 8 of 15

Connecting Transmission Owner within two business days of receiving the request, and the Connecting Transmission Owner will return the report with the readily available information within fifteen business days of receiving the request form.

The Filing Parties’ proposed revisions are superior to the pro forma language as they

establish explicit time frames for the NYISO and the NYTOs to coordinate the production of the
pre-application report in order to provide it to the Interconnection Customer in a timely manner.

3. Revisions to Pre-Application Request Form and Report

The Filing Parties also propose to make the following revisions to certain information in
the pre-application report request form and the pre-application report described in Sections

32.1.2.2 and 32.1.2.3 to:

• Request in a new Section 32.1.2.2.9 that the Interconnection Customer indicate whether it
intends to use its facility to engage in wholesale sales over the New York State
Transmission System or Distribution System. The NYISO, in consultation with the
appropriate NYTO, will use this information as described in Section 32.1.2.3 to assist its
determination as to whether the proposed project will interconnect to Commission-
jurisdictional facilities subject to the SGIP or should be directed to the appropriate state
procedures for interconnection.

• Insert the term “county” in the request form as described in Section 32.1.2.2 to assist the
NYISO and the appropriate NYTO in identifying the location of the proposed Point of
Interconnection.

• Replace the word “line” with “transmission line” in the pre-application report category
described in Section 32.1.2.3.5 to clarify that the required data includes “transmission
line nominal voltage.”

• Insert “station(s)” in Section 32.1.2.3.8 to clarify that the pre-application report will

provide peak load and minimum load data for the relevant line sections(s) or the relevant substation, as appropriate.

The proposed revisions are superior to the pro forma language for two reasons. First,

they enhance the ability of the NYISO and NYTOs to direct the Interconnection Customer to the appropriate interconnection procedures. Further, they provide the Interconnection Customer
with more precise information in its pre-application report that will only serve to better inform
the Interconnection Customer with regard to the interconnection of its proposed project. For
example, by advising an Interconnection Customer that its proposed interconnection is not
subject to the SGIP, the Filing Parties may save the Interconnection Customer considerable time that it might otherwise spend completing an Interconnection Request form, only to later find out that it is not subject to the NYISO SGIP.

Kimberly D. Bose, Secretary August 1, 2014

Page 9 of 15

C. Revisions Regarding Network Resource Interconnection Service

The Filing Parties propose not to adopt the revisions set forth in Order No. 792: (i)

clarifying the Order No. 2006 requirement that a Small Generating Facility using Network

Resource Interconnection Service interconnect through the LFIP,25 or (ii) the related revisions to
insert the definitions of “Network Resource” and “Network Resource Interconnection Service”
in the SGIP.

As an initial matter, the NYISO does not provide Network Resource Interconnection
Service.26 Rather, as accepted by the Commission, the NYISO’s interconnection process
provides for two levels of interconnection service in New York - Energy Resource
Interconnection Service27 and Capacity Resource Interconnection Service (“CRIS”).28 Small
Generating Facilities that elect CRIS are required to proceed through part of the LFIP - the Class
Year Interconnection Facilities Study.29 However, such projects are currently able to take
advantage of the SGIP with its lower study cost deposits and other efficiencies (including the
more abbreviated SGIA) for the remainder of the interconnection process.30 The Filing Parties
respectfully request that this Commission-approved variation from the Order No. 2006
requirement be permitted to remain.

If the NYISO were to require a Small Generating Facility that elects CRIS to proceed

through the NYISO’s LFIP in its entirety, such process may unnecessarily increase the time and
expense of interconnecting the Small Generating Facility, which appears in direct conflict with
the intent of Order No. 792. If the Small Generating Facility were required to go through the
entire LFIP and execute a Standard Large Generator Interconnection Agreement, it would

25 Order No. 792 at P232 (noting that “this requirement was included in Order No. 2006 but was not made clear in the pro forma SGIP.”), citing, Order No. 2006, FERC Stats. & Regs. ¶ 31,180 at P 140.

26 See, e.g., New York Independent System Operator, Inc., and New York Transmission Owners, Order Conditionally Accepting Compliance Filing, 126 FERC ¶ 61,046 (January 15, 2009).

27 Energy Resource Interconnection Service (“ERIS”) is basic interconnection service that allows a

Developer to interconnect its facility to the New York State Transmission System or Distribution System in

accordance with the NYISO Minimum Interconnection Standard to enable the New York State Transmission System or Distribution System to receive electric energy from the facility.

28 CRIS is interconnection service that allows a Developer to interconnect its facility to the New York State
Transmission System or Distribution System in accordance with the NYISO Deliverability Interconnection standard,
which allows participation in the NYISO’s Installed Capacity market to the extent of the facility’s deliverable
capacity. As described in Attachment Z to the NYISO OATT, LIPA maintains a separate interconnection process
for generators interconnecting to LIPA’s distribution facilities. Developers electing CRIS under LIPA’s procedures
also are qualified to participate in the NYISO’s Installed Capacity market to the extent of the facility’s deliverable
capacity.

29 The Small Generating Facility must enter a Class Year to be evaluated for deliverability, and the

developer must make payments for any System Deliverability Upgrades required to make the facility deliverable.

30 Small Generating Facilities for which non-Local System Upgrade Facilities are required must also proceed through a Class Year Interconnection Facilities Study. See OATT, Attachment Z § 32.3.5.3.2.

Kimberly D. Bose, Secretary August 1, 2014

Page 10 of 15

potentially be subject to a longer study process, would be responsible for more costly study

deposits, could be responsible for greater cost in the Class Year Interconnection Facilities Study than it would in the Interconnection Facilities Study under the SGIP, and would be subject to additional stakeholder review.

For the reasons described above, the existing NYISO procedures are superior to the pro forma language that would require the Small Generating Facility to go through the entire LFIP and to incur the additional time and expense of that process.

D. Additional Clarifications and Ministerial Modifications

The Filing Parties propose the following minor clarifications and ministerial

modifications to the pro forma language established in Order No. 792. The proposed revisions
are consistent with or superior to the pro forma language as they align this language with the
definitions and terminology of the NYISO OATT previously accepted by the Commission,
clarify missing or unclear language, and correct a few inconsistencies and grammatical and
typographical errors.

Attachment ZReason for Modification

Tariff Section

§ 32.1.1.7Revised existing language to make clarifications required for the relevant

sentence to read logically.

§ 32.1.2.2.4Revised to make “type” lowercase, as “Generator Type” is not a defined term

in the NYISO OATT.

§ 32.2.1Revised to use “Fast Track Process,” which is a defined term in the NYISO

OATT.

§ 32.2.1Revised to make “supplemental review” lowercase as it is not a defined term

in the NYISO OATT.

§§ 32.2.2.4,Revised to capitalize term “Minor Modification,” which is a defined term in

32.2.3, 32.2.3.1,the NYISO OATT.

32.2.4.5.2,

32.2.4.5.3

§§ 32.2.3.2 andInserted that the NYISO will also provide an executable SGIA to the

32.2.4.5Connecting Transmission Owner, along with the Interconnection Customer,

as the SGIA is a three-party agreement among the NYISO, the Connecting

Transmission Owner, and the Interconnection Customer.

§ 32.2.4.4.1Revised to make lowercase “generating facility,” which is not a defined term

in Attachment Z of the NYISO OATT.

§ 32.2.4.4.1.1Clarified that the type of generation used by the Small Generating Facility

will be taken into account in calculating the load for the application of “this

screen,” rather than “screen 32.2.4.4.1.”

§ 32.2.4.4.3Revised to make lowercase “mainline,” which is not a defined term in the

NYISO OATT.

Kimberly D. Bose, Secretary August 1, 2014

Page 11 of 15

Attachment ZReason for Modification

Tariff Section

§ 32.2.4.4.3.2Inserted “is” in this section so that it states: “Whether the load along the line

section is uniform or even.”

§ 32.3.1.1 Conformed the description of projects participating in the regular Study

Process with the changes to the eligibility requirements for the Fast Track Process under Order No. 792 described in Section 32.2.

Appendix 1 Clarified the definition of “Fast Track Process” in the Glossary of Terms in

Appendix 1 of the SGIP to include “of the SGIP” after “Section 32.2.1.”

Appendix 8 Replaced the term “Interconnection Facilities Study Report” in Section 9.0 of

the Facilities Study Agreement with the term “facilities study report,” which is the term used elsewhere in the SGIP.

GlobalMade several non-substantive modifications to correct grammatical and

typographical errors. For example, added consistent punctuation after the
description of each pre-application report category in Section 32.1.2.2.

VIII. EFFECTIVE DATE

The Filing Parties respectfully request that the tariff revisions filed herewith become effective upon issuance of an Order by the Commission accepting this filing and that until the Commission so acts, the existing Commission-approved NYISO interconnection procedures and pro forma Small Generator Interconnection Agreement remain in effect. This requested
effective date is consistent with the effective date ultimately granted to the Filing Parties with respect to their Order Nos. 2006, 2006-A and 2006-B compliance filings.31 The Filing Parties request that the Commission direct a subsequent compliance filing of the accepted tariff
revisions to reflect the ordered effective date as requested above.

IX.SERVICE

The NYISO will send an electronic copy of this filing to the official representative of
each party to this proceeding, to the official representative of each of its customers, to each
participant on its stakeholder committees, to the New York Public Service Commission and the
New Jersey Board of Public Utilities. In addition, the complete public version of this filing will
be posted on the NYISO’s website at www.nyiso.com.

31 See New York Indep. Sys. Operator, Inc, 119 FERC ¶ 61,333, at P 13 (2007) (granting rehearing with respect to the effective dates for the Joint Filing Parties’ Order Nos. 2006, 2006-A and 2006-B compliance filings, and
granting the Joint Filing Parties’ request that the tariff sheets filed in the compliance filings become effective upon the date of Commission action.)

/s/ Sara B. Keegan

Sara B. Keegan

New York Independent System Operator, Inc.

10 Krey Boulevard

Rensselaer, NY 12144

skeegan@nyiso.com

Counsel for the New York Independent System Operator, Inc.

/s/ John Borchert

John Borchert

Senior Director of Energy Policy and Transmission Development

Central Hudson Gas & Electric Corporation 284 South Avenue

Poughkeepsie, NY 12601
Email: jborchert@cenhud.com

/s/ Jacqueline Hardy

Jacqueline Hardy

Assistant General Counsel
Power Supply Long Island

333 Earle Ovington Boulevard, Suite 403 Uniondale, NY 11553

Email: jhardy@lipower.org

/s/ R. Scott Mahoney

R. Scott Mahoney, Esq.

New York State Electric & Gas Corporation Rochester Gas and Electric Corporation

Durham Hall, 52 Farm View Drive New Gloucester, ME 04260

Email: scott.mahoney@iberdrolausa.com

/s/ Elias G. Farrah

Elias G. Farrah

Winston & Strawn LLP 1700 K St., N.W.

Washington, DC 20006-3817
Email: efarrah@winston.com

Counsel to the New York Transmission Owners

/s/ Susan Vercheak

Susan Vercheak

Assistant General Counsel

Consolidated Edison Company of New York,
Inc.

Orange and Rockland Utilities, Inc.

4 Irving Place, Room 1815-s New York, NY 10003

svercheak@coned.com

/s/ Andrew Neuman

Andrew Neuman, Esq.
New York Power Authority 123 Main Street

White Plains, NY 10601-3170
Email: andrew.neuman@nypa.gov

/s/ Amanda C. Downey

Amanda C. Downey Counsel

Niagara Mohawk Power Corporation d/b/a/ National Grid

National Grid USA Service Company, Inc.

40 Sylvan Road

Waltham, MA 02451-1120
Email: amanda.downey@nationalgrid.com

Kimberly D. Bose, Secretary August 1, 2014

Page 13 of 15

Attachment A

Erica E. Stauffer

Winston & Strawn LLP 1700 K St., N.W.

Washington, DC 20006-3817
Email: estauffer@winston.com

Central Hudson Gas & Electric Corporation

John Borchert

Senior Director of Energy Policy and Transmission Development Central Hudson Gas & Electric Corporation

284 South Avenue

Poughkeepsie, NY 12601

Email: jborchert@cenhud.com

Consolidated Edison Company of New York, Inc. and Orange and Rockland Utilities, Inc.

Richard B. Miller

Director, Energy Markets and Policy Group
Consolidated Edison Co. of New York, Inc.

4 Irving Place, Room 2315-s

New York, NY 10003

Email: millerrich@coned.com

Neil H. Butterklee

Assistant General Counsel

Consolidated Edison Co. of New York, Inc. Orange and Rockland Utilities, Inc.

4 Irving Place, Room 1875-s New York, NY 10003

Email: butterkleen@coned.com

Kristina Nifora, Esq.

Associate Counsel

Consolidated Edison Company of New York, Inc. Orange and Rockland Utilities, Inc.

4 Irving Place, Room 1850-s
New York, NY 10003
Email: niforak@coned.com

Kimberly D. Bose, Secretary August 1, 2014

Page 14 of 15

Long Island Lighting Company d/b/a LIPA

Stephen J. Cantore, CEM

Manager, Power Asset Management PSEG Long Island

175 E. Old Country Road - EOB, 2nd Flr Email: stephen.cantore@pseg.com

David Clarke

Director of Power Markets Policy Power Supply Long Island

99 Washington Avenue, 10th Floor Albany, NY 12210-2822

Email: dclarke@lipower.org

Jacqueline Hardy

Assistant General Counsel
Power Supply Long Island

333 Earle Ovington Boulevard, Suite 403 Uniondale, NY 11553

Email: jhardy@lipower.org

New York Power Authority

Andrew Neuman, Esq.

New York Power Authority 123 Main Street

White Plains, NY 10601-3170

Email: andrew.neuman@nypa.gov

Andrew Antinori

Director - Market Issues

New York Power Authority

123 Main Street, White Plains, NY 10601 Email: Andrew.Antinori@nypa.gov

New York State Electric & Gas Corporation

R. Scott Mahoney, Esq.

New York State Electric & Gas Corporation Durham Hall, 52 Farm View Drive
New Gloucester, ME 04260

Email: scott.mahoney@iberdrolausa.com

Kimberly D. Bose, Secretary August 1, 2014

Page 15 of 15

Niagara Mohawk Power Corporation d/b/a National Grid

David Lodemore

Senior Counsel

Niagara Mohawk Power Corporation d/b/a/ National Grid

National Grid USA Service Company, Inc.

40 Sylvan Road

Waltham, MA 02451-1120

Email: david.lodemore@nationalgrid.com

Amanda C. Downey

Counsel

Niagara Mohawk Power Corporation d/b/a/ National Grid

National Grid USA Service Company, Inc.

40 Sylvan Road

Waltham, MA 02451-1120

Email: amanda.downey@nationalgrid.com

Bart Franey

Director of Federal Regulation

Niagara Mohawk Power Corporation d/b/a National Grid 300 Erie Boulevard West

Syracuse, NY 13202

Email: bart.franey@us.ngrid.com

Rochester Gas and Electric Corporation

R. Scott Mahoney, Esq.

Rochester Gas and Electric Corporation Durham Hall, 52 Farm View Drive New Gloucester, ME 04260

Email: scott.mahoney@iberdrolausa.com