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Massachusetts Renewable Energy RFP Questions Amended RFP dated September 2, 2010 National Grid Responses Question Number 09-02-01: Are MA solar renewable energy certificates (SRECs) included in this RFP proposal process? Or, are only Class 1 RECs included (as was the case in the previous RFP in which responses were submitted in February, 2010)? NGRID Response: As in the previous RFP, all Eligible Facilities shall be evaluated in the same manner using the same criteria, including the same Class I REC price forecast. Question Number 09-02-02: Can we reuse our submissions from last February? Can we add more submissions? NGRID Response: Please refer to footnote 9 on page 17 of the RFP. In summary, complete proposals must be submitted in this round. Bidders should refer to the RFP for direction regarding their submissions. This solicitation does not prohibit multiple bids. Each bid submitted must meet the requirements of the RFP. Question Number 09-07-01: Is there any way to join the Bidders Conference via a conference call? NGRID Response: Please refer to RFP website http://www.massachusettsrenewableenergyrfp.com, for call-in number for the Bidders Conference. The number of lines will be limited. Question Number 09-07-02: For projects located in ISO-NE but not in Massachusetts how do we demonstrate enhanced reliability specifically within Massachusetts as opposed to ISO-NE as a whole (section 5.6 in Appendix B)? NGRID Response: Please refer to Section 188.8.131.52 of the RFP. Question Number 09-08-01: Do behind the customer meter renewable energy projects qualify as an eligible bidder, facility and product. Specifically is a behind the meter project considered a load reducer? NGRID Response: The term “load reducer” as used in the RFP is apparently not a defined term under ISO New England or NEPOOL rules. Rather, the term is used generally to refer to any Class I eligible generation unit that is connected to the electrical system on the end-use customer’s side of a retail electric meter. Thus, unlike a Settlement Only Generator (SOG), the resource would not be in the ISONE settlement system, but would have the effect of reducing load. Question Number 09-08-02: Will the Distribution Companies consider contracting for S-RECs above the Class I ACP in this RFP? NGRID Response: This RFP includes all eligible MA RPS Class I resources. Solar Carve-Out renewable generation may be bid into the RFP as a Class I renewable generation unit and will be evaluated along with all other renewable generation using a common REC price forecast. Question Number 09-10-01: will you be providing a copy of the sign-in sheet from the bidders conference to all parties? NGRID Response: No. Question Number 09-12-01: My client owns an existing Mass Class I generating unit which was placed in service after 1/1/98 but before 1/1/08. May this generation unit enter a bid in this RFP? NGRID Response: Please refer to the Eligibility Requirements in Section 184.108.40.206 of the RFP. Question Number 09-12-02: My client owns an existing Mass Class I generation unit that was placed in-service after 1/1/08. May it submit a bid in this RFP? NGRID Response: Please refer to the Eligibility Requirements in Section 220.127.116.11 of the RFP. Question Number 09-12-03: My client owns an existing Mass Class I generation unit that has a vintage waiver and was placed in-service before 1/1/98. May this generation unit submit a bid in this RFP? NGRID Response: Please refer to the Eligibility Requirements in Section 18.104.22.168 of the RFP. Question Number 09-12-04: My client owns an existing hydro-electric dam that is being upgraded so that its additional electrical production will be classified as Mass Class I. Does this unit qualify to submit a bid for this RFP? NGRID Response: Please refer to the Eligibility Requirements in Section 22.214.171.124 of the RFP. Question Number 09-13-01: 1) Assuming an MDPU-approved PPA, when, and under what conditions, is the Development Period Security released back to the generating facility owner? 2) Assuming commercial operation, when, and under what conditions, is the Operating Period Security released back to the generating facility owner? 3) What conditions would cause all or portions of either the Development Period Security or the Operating Period Security to be forfeited by the generating facility owner? 4) What entity holds the securities and can you please provide some brief information about the purpose of the securities? NGRID Response: Please refer to the Security Requirements in Section 126.96.36.199 of the RFP and Sections 3.1(c), 3.2(c), 6 and 9.3(b) of the Model Power Purchase Agreement. National Grid will include additional provisions in any power purchase agreement it executes that provide additional details on the retention and return of credit support. Question Number 09-13-02: Our hydro plant in Pawtucket Rhode Island is partially MA Class 1 from incremental improvement. Can we participate in the RFP with the portion of our RECs that are Mass Class 1 even though the entire plant does not qualify as a new resource? NGRID Response: Please refer to the Eligibility Requirements in Section 188.8.131.52 of the RFP. Question Number 09-13-03: Is this RFP open to Canadian assets/bidders, more specifically in Quebec and New Brunswick? NGRID Response: Please refer to the Eligibility Requirements in Section 184.108.40.206 of the RFP. Question Number 09-15-01: Are the Participants considering transactions where the counterparty may be a financial institution or market participant, other than a developer, that is purchasing energy and RECs from qualified resources under long-term agreements? NGRID Response: Section 220.127.116.11 of the RFP defines Eligible Bidder as the owner of an Eligible Facility or the development rights to an Eligible Facility. Question Number 09-15-02: Referring to page 2 of the RFP, how will the utilities determine whether proposals submitted are cost effective? NGRID Response: The evaluation process described in the RFP was developed to assist in making this determination. But there is no formulaic approach. Question Number 09-15-03: Please provide examples or a description of PPA terms and conditions that would place an unreasonable burden on the company’s balance sheet? NGRID Response: No additional examples beyond the one provided in footnote 6 to Section 18.104.22.168 will be provided. This will be an internal Company determination. Question Number 09-15-04: Why is National Grid participating in this RFP if its GCA obligations are fully met with its contract with Cape Wind? NGRID Response: Because National Grid wishes to consider other proposals. Question Number 09-15-05: Will you provide the ?quantitative scoring system? described on page 3, and the ?common price forecast? described on page 12? NGRID Response: No. Question Number 09-15-06: In the third stage review, the statement appears ”whether the PPA sought would facilitate the financing of the proposed project.” Please explain what is meant by the word ”financing.“ Does this encompass both internally and externally supplied capital? Is this a threshold requirement? How will ”financing“ affect proposal evaluation? NGRID Response: In the context of Section 83 of the Green Communities Act, National Grid has understood the requirement that the long term contract "facilitate financing" to mean that the long term contract should only be offered if the developer would not otherwise be able to obtain the capital necessary to construct the project without a long term contract. If a party is using internal funds, this would be one factor taken into consideration as to whether the standard is met. This will be a project-specific determination. Question Number 09-15-07: In the third stage review, ”diversity of resources“ is an objective. Does ”diversity“ refer to resource diversity on a New England-wide basis or rather diversity among proposals selected in this RFP? NGRID Response: This term was intended to refer to diversity among proposals, and was not meant to have any geographic connotation. Question Number 09-15-08: On page 3, it states ?the DOER will submit its assessment of (a) the process followed by the Distribution Company resulting in the execution of the PPA, and (b) the merits of the particular PPA proposed for approval.? Will this assessment be open for public review? NGRID Response: This question will be addressed by DOER. Question Number 09-15-09: On page 8 it is stated that the reliability criteria can be satisfied ”by bidder’s agreement to commit any qualifying capacity to ISO New England.” If the project doesn”t meet the requirements necessary to provide qualifying capacity, is it eligible to participate in this RFP? NGRID Response: Section 22.214.171.124 of the RFP clearly states that a bidder may propose to sell energy and/or RECs from an eligible facility, and that bids for sale of capacity will also be considered. Section 126.96.36.199 states that commitment of any qualifying capacity to the ISONE FCM is one way of demonstrating contribution to electric reliability, but that other demonstrations will be considered. Question Number 09-15-10: What is the earliest PPA start date and how would bids with different start dates be compared? NGRID Response: The RFP does not define an “earliest PPA start date.” See response to Question Number 09-15-13 for how bids with different start dates would be compared. Question Number 09-15-11: Please provide more information on capacity bids; is there a preference to procure and how would they be evaluated? NGRID Response: See response to Question Number 09-15-09. If capacity is offered, the bundled pricing, capacity, energy, and RECs would be compared to the market price forecast, which will include all three products. Question Number 09-15-12: Are there any conditions under which the RFP would procure more than 1.5% of the utility’s load up to the maximum 3%? NGRID Response: Yes, if the Company believes it is desirable to do so. Question Number 09-15-13: How will projects with different term lengths and start dates be compared? NGRID Response: The bid evaluation methodology will accommodate projects with different term lengths (subject to the requirements of Section 83 of the Green Communities Act) and start dates, and the market price forecast will be of sufficient duration to support this evaluation. Question Number 09-15-14: On page 30 of the RFP appears a blank for a discount rate. What is this value, and will this same value be used to generate levelized costs? NGRID Response: This reference is apparently to the Model PPA, not to the RFP, and the discount rate would be used in determination of the termination payment, in the event of contract termination. This discount rate would be set in the negotiation of a PPA, and has no bearing on the bid evaluation process. Question Number 09-15-15: Please provide some solar and wind pricing ranges ($/MWh) for the next year that you consider market rate. NGRID Response: National Grid will consider pricing submitted in proposals and has not established a predetermined “market rate” for any particular technology. Question Number 09-16-01: How is the "workbook for bid submittal", included in the RFP documents, intended to be included in the Bidder's submitted proposal? Should it be included as an attachment to the Bidder Response Forms? Should it be in excel format on the submitted CD or may it be in pdf format? NGRID Response: The workbook should be included as an attachment to the bidder response forms. This should be submitted via paper copy in your hard copy submittal and excel format on the CD. Question Number 09-16-02: Do only those bidders submitting proposals for wind energy projects need to fill out tab "12x24 Estimate" in the workbook (Section 6, Energy Resource Plan of the Bidder Response Forms), or do all bidders need to fill that tab out? NGRID Response: All proposals should include the "12x24 Estimate" as noted on the top of the worksheet “12x24 Estimate” in the "Workbook for Bid Submittal". Question Number 09-16-03: Upon selection of short-listed projects, would the utilities enter into negotiations for only the energy or REC portion of a proposal, even if the bidder submitted a proposal to enter into a PPA for both? NGRID Response: If bidder wishes to sell only energy or RECs or combination, the bidder should make clear what products are being offered in the bid response. All of the offers will be evaluated. Question Number 09-16-04: Since the GCA requires 2 solicitations, roughly when do you anticipate the second solicitation will be? I assume this Amended RFP is still considered the first solicitation. NGRID Response: The RFP issued on 9/2/10 is the first solicitation. No determination has been made about subsequent RFPs. Question Number 09-16-05: Given that the bidders conference call is over subscribed, preventing participation by some parties, could you confirm that a transcript of the discussion on the call will be posted for all bidders to view? NGRID Response: The bidders conference presentation is posted on the RFP website. No transcript is available. Question Number 09-16-06: In item 6 of the Bidder Response Forms, could you please provide additional clarification on the definitions of each technology/resource option (for instance, did the options come from a Mass DEP or DOER definition)? Specifically, if a project produces biogas, very similar to landfill gas, and combusts it in an engine to produce electricity, the biogas is in fact the fuel source. So would this fall under the "Landfill Gas" technology/resource option? Or, because the biogas is produced from the digestion of municipal organic waste, would it be a biomass project? NGRID Response: In section 6 of the Bidder Response Forms, please specify the project resource type exactly. The project must qualify as a MA RPS Class I resource per the eligibility requirements. Question Number 09-16-07: The conference line for the Bidders meeting was full even 10 mintues before the meeting started. Will it be possible to get the same information as other bidders either present at the meeting or on the phone? NGRID Response: Please see response to Question 09-16-05 . Question Number 09-17-01: With reference to 188.8.131.52 where Bidders must provide firm pricing, terms and conditions for 120 days from the due date for submissions; and, with reference to the ability to submit 100% of a Project's output to any number of Soliciting Participants (from one to all): Is retraction of the entire Bid from consideration of one or many of the Soliciting Participants allowable prior to the 120 days expiration? One example is that a Bidder submits 100% of their Project to all four Soliciting Participants. All four like the price and want the deal. The Bidder can obviously only close the deal with one party and therefore must withdraw the bid from the other three parties. Is this allowable? If a Bid can be withdrawn from a Soliciting Party because the Bidder is finalizing a deal with another Soliciting Party, can a Bid be withdrawn within the 120 period for any other reason as well? Or, asked another way, are only the price, terms and conditions firm for 120 days but not the obligation to contract at those price, terms and conditions? Is the Bidder able to withdrawn the Bid at any time for any reason? NGRID Response: The price, terms and conditions of the bid are considered firm for 120 days from the due date of October 7, however, the obligation to contract is not firm. Question Number 09-17-02: Will the sign in sheets from yesterday's meeting be made available to everyone? NGRID Response: No Question Number 09-17-03: Do the utilities require a hard copy of the notice of intent to bid or will an electronic copy suffice? NGRID Response: Notice of Intent to bid should be submitted via hardcopy and/or electronic form. Question Number 09-17-04: Please define the following terms: Nameplate Capacity of the project (MW) Gross Capacity of the project (MW) Net Capacity of the project (MW) Installed Capacity (MW) Net Generating Capability Which of the above terms satisfies the minimum contract size requirement of 1 MW, as they all have the potential to be different? Please also define Contract Maximum Amount. NGRID Response: Refer to section 184.108.40.206 of the RFP for minimum contract size. The minimum contract size is 1 MW AC, as a net generating capability of the eligible facility. A specific determination of the Contract Maximum Amount would be developed in the negotiation of the PPA; this would generally be the maximum net output of the facility in MWh per hour. Question Number 09-17-05: Relating to section 5, On and Off peak hours. What are the NERC holidays mentioned in footnote 7? NGRID Response: See North American Electric Reliability Corporation website at nerc.com for definition of NERC holidays. Question Number 09-17-06: Would a significant capital investment in an eligible biomass power plant changing it to CHP count as a capacity expansion? NGRID Response: Refer to the eligibility requirements in section 2.2.2. Refer to the draft revisions of 225 CMR 14.00 issued on September 17, 2010 to address the specific question. Question Number 09-17-07: In regards to the term "Contract Maximum Amount" in the PPA, if a facility has a nameplate capacity of 50 MW and the maximum amount of kWh produced in any one hour is 50,000 kwh, is 50,000 considered the "Contract Maximum Amount" or is there a different meaning? NGRID Response: Per the definition in the Model PPA, Contract Maximum Amount shall mean the number of kWh per hour of Energy and a corresponding portion of all other Products. Question Number 09-19-01: In Section 5.1.1 of the bidder response forms, please clarify the meaning of "Net Capacity at Average Site Conditions." Are you asking for the typical maximum net output at average site conditions, the capacity quantity that has qualified/cleared in the ISO-NE FCM, the average output, or something else? NGRID Response: Net Capacity at average site conditions refers to the typical maximum net output. If capacity is being offered, the bidder response form should indicate the capacity expected to be qualified in the ISO-NE capacity market. Question Number 09-20-01: At the end of Section 2 of the Bidder Response Forms, what is meant by "Please indicate the Buyer's Percentage Entitlement (in %) associated with your proposal to the Distribution Company _______________%"? Is this asking whether the bid is offering 100% of the output of the facility or is it asking for something else? NGRID Response: Yes, this field is asking for how much of the project is being offered to the Distribution Company. Question Number 09-20-02: How would you like to see the escalation rate reflected in the Pricing Schedule of Section 4 of the Bidder Response Forms? Given that an energy price in $/MWh is requested for each year of the term along with an escalation rate, I am not sure how to fill this in. Please clarify. NGRID Response: Please list the $/MWh price for each year of the project. If the price escalates at a fixed or indexed rate, please indicate this in the appropriate field. Question Number 09-20-03: Section 7.2 of the Bidder Response Forms, asks for credit ratings of the entity which would provide a guarantee in support of Bidder. Is the guarantee described here the same as the security or is this something different? NGRID Response: The information requested in this section will be used as part of the financing portion of the non-price evaluation. The Model PPA contains separate and distinct security requirements. Question Number 09-20-04: Under 220.127.116.11 of the RFP document, peak hours are defined as (for the purposes of this RFP): 1pm-6pm June-Sept and 5pm-7pm Oct-May. However, under footnote 4 of the Bidder's Response forms, peak hours are defined as (for the purpose of this RFP): hours ending 8 through 23 Mon-Fri, excluding NERC holidays. Please clarify which definition should be used by bidders when responding NGRID Response: Section 18.104.22.168 references hours used in ISO New England’s Forward Capacity Market for determining Qualified Capacity for Intermittent Resources. Each project must contribute to moderating system peak load requirements. For the bidders response form Section 4, please use the definition in footnote 5. Question Number 09-20-05: Please provide the intent of NGRID regarding their commitment to participate in the current proposed RFP, especially in light of their suspension of any further action under the last RFP. NGRID Response: See response to Question Number 09-15-04. Question Number 09-20-06: From the Model Power Purchase Agreement, in Section 4.1(b) under "Delivery of Products," can the Buyer choose to accept delivery of the Products that exceed the Contract Maximum Amount? And if the Buyer can choose to accept, will it be purchased at 100% of the contract price set forth in the PPA? If Buyer does not accept the Products that exceed the Contract Maximum Amount, can the Seller sell the Products to a third party? NGRID Response: This would be discussed during the PPA negotiation phase. Question Number 09-20-07: The RFP document provides for the generation project to be located outside of the Commonwealth of Massachusetts, as long as the 'Delivery Point' for electrical energy is located at an 'ISO-NE Pool Transmission Facility'. Could you please confirm what delivery information would be required to support an RFP submission from a generator proposing to connect to an adjoining ISO network? Our project is in the final stages of interconnection study by an adjoining ISO but we will not have a deliverability analysis, performed by said control authority, until mid next year. In the absence of an ISO deliverability analysis, what level of analysis is required to support such a submission from a generator proposing to connect to an adjacent control area? NGRID Response: Please supply the load zone and the specific node the project will deliver to on the ISO-NE pool transmission facility. Also, provide a detailed description of the proposed method and contractual provisions pertaining to deliveries of energy and associated RECs from the subject generation unit to the ISO-NE Control Area and how such deliveries would comply with the requirements of this RFP (including Section 22.214.171.124 (Contribution to Electricity Reliability)), applicable ISO rules, and applicable Department of Energy Resources requirements for MA RPS Class I RECs (including 225 CMR 14.05(1)(e) (Capacity Obligation) and 225 CMR 14.05(5) (Special Provisions for a Generation Unit Located in a Control Area Adjacent to the ISO-NE Control Area)). Question Number 09-20-08: Please provide the intent of NGRID regarding their commitment to participate in the current proposed RFP, especially in light of their suspension of any further action under the last RFP. NGRID Response: Please see response to Question 09-20-05. Question Number 09-20-09: Could you provide a more extensive definition of "Contract Maximum Amount in kWh per hour". NGRID Response: Please see response to 09-17-07. Question Number 09-20-10: For the purpose of conservation of natural resources, is it acceptable to only send a CD of the proposal to the utilities, rather than hard copy printouts? NGRID Response: For National Grid, one (1) loose leaf hardcopy of the proposal in a three-ring binder and two (2) CDs would be acceptable for project proposal submittals. Question Number 09-20-11: Section 126.96.36.199 of the RFP states that ?An Eligible Bidder is the owner of an Eligible Facility or the development rights to an Eligible Facility, i.e., the developer of the Eligible Facility.? If a bidder is a corporate affiliate of the entity which owns the Eligible Facility and/or the development rights to the Eligible Facility, such affiliate owns the rights to the Products generated by the Eligible Facility, and the bid/proposed PPA is both unit specific and unit contingent to the Eligible Facility, does the bidder qualify as an Eligible Bidder? NGRID Response: The Eligibile Bidder must be the owner of an Eligible Facility or the owner of the development rights to an Eligible Facility. Question Number 09-20-12: Section 2.5 of the RFP states that ?Bidders selected for negotiations by the Distribution Companies will be required to indicate in writing to the Distribution Companies whether they intend to proceed with their proposal within five business days of being notified.? A. Please confirm that it is permissible pursuant to the RFP to bid the same Products from a facility to more than one Distribution Company. B. Please confirm that a bidder is not bound to proceed with its bid if it is selected for negotiations. NGRID Response: A. It is permissible for a Bidder to bid the same Products from a facility to more than one Distribution Company. B. Please see response to Question 09-17-01. Question Number 09-20-13: If a Project is operational and the development and construction phases are complete, can responses to questions 9.1, 9.2, 9.3, 9.4, 12.1, 13.1, 13.2, 13.3, 13.4, and 13.5 be omitted? NGRID Response: All sections of the bidder response forms should be filled out and reflect the current status of the proposed project. Question Number 09-20-14:Section 188.8.131.52 of the RFP states that the ”Delivery Point for electric energy must be (a) at an ISO-NE Pool Transmission Facility [PTF] Node,” and the utilities further stated in the bidders' meeting that bidders must be responsible for all costs of delivery up to the Delivery Point at a PTF. For PTFs where there are transmission constraints or congestion between the PTF and the given utility’s system, how is the cost of congestion or the transmission constraint evaluated? Put more directly, is a project that has a point of delivery in a location that is somewhere in ISO-NE but has transmission constraints and congestion charges between the point of delivery and the buyer’s system valued on an equal footing with a project that does not face such a transmission constraint or that has an advantaged position in relation to both nodal congestion and system load? NGRID Response: Projects will be evaluated against a market price forecast for the proposed Delivery Point. In addition, National Grid may have a specific need to use energy toward meeting Basic Service load requirements, in order to address financial accounting concerns. It would be useful in this regard for the bidder to provide alternative pricing that includes delivery to the Massachusetts Hub. Question Number 09-20-15: Section 4.5 of the PPA states that the Buyer accepts all transmission constraints and congestion charges after the Delivery Point regardless of the location of the Delivery Point, meaning that the Buyer may in fact pay higher costs for power delivered to a Delivery Point outside the utility’s service territory. A PPA could also offer a Delivery Point that does not involve such higher costs to the Buyer. How will the cost advantages of a lower cost Delivery Point be evaluated? NGRID Response: See response to Question 09-20-14. Question Number 09-20-16:Does your company favor generation and delivery of power in certain locations versus other locations? How are projects that are in transmission advantaged and low congestion zones evaluated against projects that face transmission constraints and/or congestion charges? NGRID Response: See response to Question 09-20-14. Question Number 09-20-17:If ISO-NE favors generation and delivery of power in certain locations vs. other locations (e.g., transmission-constrained, low-load locations), will this have a bearing on how you will evaluate bidders offering to delivery energy to one location vs. another? NGRID Response: See response to Question 09-20-14. Question Number 09-20-18: If your company will not be using the RFP to purchase energy for its own retail supply purposes and/or to purchase RECs for its own RPS compliance purposes, please explain why not, and why your company believes that purchases for resale in the wholesale market will be better for ratepayers. NGRID Response: This question is outside the scope of the RFP. Section 83 and the implementing regulations allow the utilities to sell the output into the wholesale market or to seek DPU approval to use the output for retail load. Question Number 09-20-19: If your company will be using the RFP to purchase energy for resale in the wholesale market, please explain how you will factor in the likely higher resale value of energy delivered to a Delivery Point that is less burdened by transmission constraints and congestion charges. NGRID Response: See response to Question 09-20-14. Question Number 09-20-20: Will your company accept phasing of a project?s generation unit commercial operation dates within the PPA? NGRID Response: This will be handled on a case by case basis, as long as the critical milestones in the model PPA are met. Question Number 09-20-21: Our reading of Section 3.4 of the PPA is that COD is whenever all of those criteria are satisfied, and there is no penalty or prejudice for a project that reaches COD earlier than expected. Is that correct? NGRID Response: Yes, there are no penalties. Question Number 09-20-22: Our understanding is, if for instance the Capacity factor is estimated at more than 20 but less than 50% and the nameplate capacity is 100 MW the most the unit would be able to produce in any hour is 100,000 kwh and the amount of security required to provide is $20 per kwh (because its capacity factor is between 20 and 50%) times 100,000 kwh = $2 million. Could you please confirm that this interpretation is correct? NGRID Response: The amount of security is determined based on the Contract Maximum Amount, not the nameplate capacity. Please refer to Section 6. Security for Performance of the Model PPA.
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