Amanda C. Downey

Counsel

July 11, 2014

The Honorable Kimberly D. Bose Secretary

Federal Energy Regulatory Commission 888 First Street, NE

Washington, DC 20426

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

Docket No. ER14-____-000

Small Generator Interconnection Agreement with WM Renewable Energy, L.L.C.

Dear Secretary Bose:

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

Federal Energy Regulatory Commission’s (“Commission”) regulations,2 Niagara Mohawk
Power Corporation d/b/a/ National Grid (“National Grid”) submits a Small Generator
Interconnection Agreement (“SGIA”) between National Grid and WM Renewable
Energy, L.L.C. (“WM Renewable”). The SGIA is designated as Service Agreement No.
2128 under the New York Independent System Operator, Inc.’s (“NYISO”) Open Access
Transmission Tariff (“OATT”), FERC Electric Tariff, Original Volume No. 1.

National Grid requests waiver of the Commission’s prior notice requirement to
allow the SGIA to become effective as of the date of execution, i.e., June 2, 2014.

I.Background

National Grid is a public utility subject to the Commission’s jurisdiction that owns transmission facilities located in New York.

WM Renewable owns a landfill gas recovery facility (the “Plant”) installed at the
Monroe Livingston landfill, located in the town of Scottsville, Monroe County, New
York. On June 16, 1986, Waste Management of North America, then the owner of the
landfill, filed a notice in Docket No. QF86-830-000 to self-certify the Plant as a qualifying
facility (“QF”). Notices of self-certification of QF status were filed in that docket on
December 30, 2004 by Waste Management Renewable Energy, LLC and on July 8, 2005
by WM Renewable.

16 U.S.C. § 824d.

18 C.F.R. Part 35.

The Honorable Kimberly D. Bose July 11, 2014

Page 2

The Plant is currently subject to a Small Generator Interconnection Agreement between National Grid and WM Renewable that the Commission accepted for filing effective June 23, 2011.3 National Grid will submit a separate filing to terminate the existing agreement effective June 1, 2014 conditioned upon the acceptance of the 2014 SGIA submitted in this filing.

II. Description of the SGIA and Filing Requirements

Like the currently effective Small Generator Interconnection Agreement between National Grid and WM Renewable, the SGIA contained in this filing generally conforms with the pro forma Small Generator Interconnection Agreement set forth in Appendix 9 of Attachment Z to the NYISO OATT, with only minor modifications. Those modifications include the elimination of the NYISO as a party to the agreement and revisions to reflect the fact that the Generating Facility is an existing facility.

The SGIA contained in this filing differs from the currently effective Small Generator Interconnection Agreement in the following respects:

The introductory provisions and Article 13 of the SGIA (entitled “Notices”)

include updated contact information for the National Grid representative.

The extraneous word “None” has been removed from the titles of Article 4

(entitled “Cost Responsibility for Interconnection Facilities and Distribution

Upgrades”) and Article 5 (entitled “Cost Responsibility for Network Upgrades”) of the SGIA.

Attachment 2 to the SGIA (entitled “Description and Costs of the Small

Generating Facility, Interconnection Facilities, and Metering Equipment”)

incorporates terms and conditions from a previously expired data services

agreement between National Grid and WM Renewable. Attachment 2 also

clarifies the ownership of the remote terminal units (RTU) used to remotely collect metering and status data, to perform remote control operations, and to output data required in remote locations. In addition, Attachment 2 clarifies the ownership of the telecommunications hardware and circuit associated with the RTU.

Attachment 3 to the SGIA (entitled “One-Line Diagram Depicting the Small

Generating Facility, Interconnection Facilities, Metering Equipment, and

Upgrades”) reflects the use of the defined terms Point of Interconnection and Point

of Change in Ownership included in Attachment 2 to the SGIA.

A number of non-material formatting changes have been made to the SGIA.

3 See Commission letter order, Docket Nos. ER11-4140-000 and ER11-4140-001 (Sept. 21, 2011). The Small Generator Interconnection Agreement is designated as Service Agreement No. 1164 under the NYISO OATT.

The Honorable Kimberly D. Bose July 11, 2014

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The SGIA states that it will become effective upon execution by the National Grid and WM Renewable, subject to acceptance by the Commission.4 The SGIA was executed on June 2, 2014.

Pursuant to the Commission’s order in New England Power Company,5 the

Commission’s standard interconnection rules promulgated in Order No. 2003, and the

procedures and agreements related thereto, including the Small Generator Interconnection Procedures set forth in Appendix Z to the NYISO OATT, do not apply in this case. In New England Power Company, 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 does not apply to generator interconnection
agreements because they are not “new interconnection requests.”6

The Plant is an existing facility, and there are no proposed increases in capacity or
material modifications to the characteristics of the facility. Thus, for the reasons
explained in New England Power Company, the Commission should also find here that
the standard interconnection rules promulgated in Order No. 2003, and the procedures and
agreements related thereto, including the NYISO Small Generator Interconnection
Procedures, do not apply in this case. Because this interconnection was not processed
under the NYISO Small Generator Interconnection Procedures, the NYISO is not a party
to the SGIA.

III. Effective Date and Request for Waiver

Pursuant to Section 35.11 of the Commission’s regulations,7 National Grid

respectfully requests waiver of the notice requirement contained in Section 35.3 of the

Commission’s regulations8 to the extent necessary to allow the SGIA to become effective upon the effective date set forth in the agreement, i.e., June 2, 2014.

Good cause exists for the Commission to grant this waiver. The SGIA was

executed last month. Granting the waiver will accord with the intent of National Grid and
WM Renewable to make the SGIA effective as of June 2, 2014, as stated in the SGIA.
Therefore, no prejudice will result to any party from granting the waiver. For these
reasons, the Commission should find that good cause exists to grant an effective date of
June 2, 2014.

SGIA, Section 3.1.

109 FERC ¶ 61,364 (2004).
Id. at P 13. See also Jersey Central Power & Light Company, 110 FERC ¶ 61,273, at P 11 (2005)

The Honorable Kimberly D. Bose July 11, 2014

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IV.Attachments

In addition to this transmittal letter, this filing includes the SGIA which is

provided in Attachment A hereto.

V.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 this proceeding:

Amanda C. Downey Counsel

National Grid USA
Service Company, Inc.

40 Sylvan Road

Waltham, MA 02451 (781) 907-2136

amanda.downey@nationalgrid.com

William L. Malee

Director, Transmission Commercial National Grid USA

40 Sylvan Road

Waltham, MA 02451 (781) 907-2422

bill.malee@nationalgrid.com

Sean Atkins

Bradley R. Miliauskas Alston & Bird LLP The Atlantic Building 950 F Street, NW

Washington, DC 20004 (202) 239-3300

sean.atkins@alston.com
bradley.miliauskas@alston.com

The Honorable Kimberly D. Bose July 11, 2014

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VI.Conclusion

For the reasons stated herein, National Grid respectfully requests that the Commission accept the SGIA effective as of June 2, 2014.

Respectfully submitted,

/s/ Amanda C. Downey

Amanda C. Downey
Counsel

National Grid USA

Service Company, Inc.

40 Sylvan Road

Waltham, MA 02451

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