January 28, 2022
The Honorable Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE
Washington, DC 20426
Re: New York State Electric & Gas Corporation
Engineering and Procurement Agreement with Trelina Solar Energy Center, LLC
Docket No. ER22-___-000
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’s" or "FERC’s") regulations,2 New York State
Electric & Gas Corporation ("NYSEG") hereby submits for filing an executed Engineering and
Procurement Agreement ("E&P Agreement") by and between NYSEG and Trelina Solar Energy
Center, LLC ("Trelina"). The E&P Agreement is designated as Service Agreement No. 2684
under the New York Independent System Operator, Inc.’s ("NYISO") Open Access Transmission
Tariff ("OATT").
For the reasons set forth below, NYSEG respectfully requests that the Commission accept the E&P Agreement for filing effective October 8, 2021.
I. BACKGROUND AND DESCRIPTION OF THE E&P AGREEMENT
NYSEG is a public utility subject to the Commission’s jurisdiction that, among other
things, owns transmission facilities under the operational control of the NYISO. Trelina is a
Delaware limited liability company engaged in the business of developing an 80 MW
photovoltaic solar energy generating facility located on private land in the Town of Waterloo in Seneca County, New York ("Generation Facility").
Trelina is planning to construct the Generation Facility and has requested generator
interconnection service from NYSEG for the Generation Facility. In order to advance
1 16 U.S.C. §§ 824d.
2 18 C.F.R. Part 35.
Bracewell LLPT: +1.202.828.5800F: +1.800.404.3970
2001 M Street NW, Suite 900, Washington, DC 20036-3310 bracewell.com
AUSTIN CONNECTICUT DALLAS DUBAI HOUSTON LONDON NEW YORK SAN ANTONIO SEATTLE WASHINGTON, DC
Hon. Kimberly D. Bose
January 28, 2022
Page 2
implementation of the interconnection prior to the execution of an interconnection agreement, Trelina has requested that NYSEG coordinate with Trelina to begin certain engineering and procurement activities.
Trelina has elected the option to build under the NYISO OATT and will be responsible for
building the Trelina Point of Interconnection ("POI") substation (the "Trelina Solar Energy
Substation"). Attachment A to the E&P Agreement identifies Trelina’s attachment facilities,
which include a solar energy collector station, generator tie line, and the substation
(collectively, the developer’s attachment facilities or "DAFs"). Trelina has retained its own
engineers to perform the engineering, procurement and construction of the DAFs, with
oversight of the engineering, design, and project management to be completed by NYSEG’s
engineers. Attachment A also identifies NYSEG upgrades and upgrades on the Rochester Gas
and Electric Corporation system as an affected system identified by the Interconnection
Facilities Study.
Pursuant to the E&P Agreement, Trelina will pay all of NYSEG’s costs in performing its scope of work set forth in Attachment A to the E&P Agreement, which includes review and oversight of Trelina’s activities with the upgrades for which it is responsible.
II.EFFECTIVE DATE AND REQUEST FOR WAIVER
Consistent with the terms of the E&P Agreement, NYSEG respectfully requests that the
Commission accept the E&P Agreement effective as of October 8, 2021. The Commission has
previously held that pre-interconnection service agreements may be filed within 30 days of
service commencing rather than in advance of service commencement.3 The E&P Agreement is
being submitted more than 30 days after service commencement and, to the extent necessary,
NYSEG requests waiver of Commission requirements in order to permit acceptance of the E&P
Agreement, effective as requested. The NYISO OATT contemplates that agreements such as the
E&P Agreement may be part of generator interconnection service provided pursuant to the
OATT, and thus the E&P Agreement is an agreement under an umbrella tariff rather than a
stand-alone bilateral service agreement. While the E&P Agreement is being filed more than 30
days after service commencing, it is consistent with NYSEG’s provision of generator
interconnection service pursuant to the NYISO OATT and granting the requested effective date
will have no adverse effect on Trelina, who has executed the E&P Agreement. An October 8,
2021 effective date will ensure that the effective date of the E&P Agreement aligns with that
agreed upon by the parties. In addition, granting the requested effective date will have no
adverse effect on NYSEG or its other customers. NYSEG has focused on internal procedures
related to E&P Agreements to ensure that such agreements are submitted within 30 days of
service commencement and that this type of oversight does not occur again.
3 See, e.g., International Transmission Co. and Michigan Electric Transmission Co., LLC, 139 FERC ¶ 61,022, at P 14 & n.18. (2012)
Hon. Kimberly D. Bose
January 28, 2022
Page 3
III.LIST OF DOCUMENTS SUBMITTED WITH THIS FILING4
NYSEG is submitting the following documents with this filing:
1. This transmittal letter; and
2. The executed E&P Agreement.
IV.COMMUNICATIONS
Please direct all communications and correspondence in this proceedingto the
individuals indicated below:
Catherine P. McCarthyKenna J. Hagan
Boris B. ShkutaSenior Counsel
Bracewell LLPAvangrid Service Company
2001 M Street N.W., Suite 900180 Marsh Hill Road
Washington, DC 20036Orange, CT 06477
Phone: (202) 828-5800Phone: (605) 580-0239
Fax: (800) 404-3970kenna.hagan@avangrid.com
catherine.mccarthy@bracewell.com boris.shkuta@bracewell.com
V. PERSONS ON WHOM THIS FILING IS BEING SERVED
A copy of this filing will be served on Trelina and the NYISO.
VI.CONCLUSION
For the foregoing reasons, NYSEG respectfully requests that the Commission accept the
E&P Agreement for filing, as submitted, without modification or condition, effective October 8,
2021.
Respectfully submitted,
/s/ Catherine P. McCarthy
Catherine P. McCarthy
Boris B. Shkuta
Counsel for New York State Electric & Gas Corporation
Enclosure
4 18 C.F.R. § 35.13(b)(1).