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National Grid AMIC 10032 1 of 16 Capital/Revenue Investment Proposal – Summary APPLICATION BY NIAGARA MOHAWK POWER CORPORATION TO INSTALL A 115kV GENERATOR ATTACHMENT FACILITY AND PERFORM MISCELLANEOUS FACILITIES WORK TO ACCOMMODATE THE CONSTRUCTION OF THE CAPE VINCENT WIND FARM GENERATION FACILITIES Transmission Line/Station, NMPC, Project No. B04627, CNYX59 (A sanction paper by Francis Kane and sponsored by Mary Ellen Paravalos – March 19, 2010) Description Approval is being requested for a total DOA of $2,999,000 to allow for the design, engineering and construction of attachment facilities and system upgrade facilities required to accommodate the interconnection of the BP Alternative Energy NA, Inc. (“BP Energy”) Cape Vincent Wind Farm (“Cape Vincent Wind”) to the National Grid Transmission System. The NYISO has determined National Grid to be the connecting Transmission Owner, as per the NYISO Open Access Transmission Tariff (OATT). Category: Mandatory Risk score: 49 - Customer Driven Finance Sanction Cost & Range $2,726,000 $2,453,000 to $2,999,000 Cost volatility: P20 cost: Not Available P80 cost: Not Available Probability that project cost will exceed 10% tolerance: Not Available Project included in approved Business Plan? Yes Project cost relative to approved Business Plan -$614,000 If cost > approved B Plan how will this be funded? Fully Reimbursable Other financial issues: This project has been included as a placeholder in the approved business plan, CNYX60. This project as presented is a decrease to the approved business plan. When the business plan was created the estimates were conceptual and have been better defined during the NYISO interconnection process.  All project costs are fully reimbursable from the developer.  Current planning horizon $m Yr 1 10/11 Yr 2 11/12 Yr 3 12/13 Yr 4 13/14 Yr 5 14/15 Yr 6+ 15/16 Total Lower Range P20 Upper Range P80 Proposed investment 0 0 .05 .94 1.1 .19 2.28 n/a n/a Resources Availability of internal resources to deliver project: Amber Availability of external resources to deliver project: Amber Operational impact on network system: Amber Note – Amber due to uncertainty of developer’s schedule
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National Grid AMIC 10032 

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Capital/Revenue Investment Proposal – Summary

APPLICATION BY NIAGARA MOHAWK POWER CORPORATIONTO INSTALL A 115kV GENERATOR ATTACHMENT FACILITY

AND PERFORM MISCELLANEOUS FACILITIES WORK TO ACCOMMODATE THECONSTRUCTION OF THE CAPE VINCENT WIND FARM GENERATION FACILITIES

Transmission Line/Station, NMPC, Project No. B04627, CNYX59

(A sanction paper by Francis Kane and sponsored by Mary Ellen Paravalos – March 19, 2010)

Description

Approval is being requested for a total DOA of $2,999,000 to allow for the design, engineeringand construction of attachment facilities and system upgrade facilities required to accommodatethe interconnection of the BP Alternative Energy NA, Inc. (“BP Energy”) Cape Vincent WindFarm (“Cape Vincent Wind”) to the National Grid Transmission System. The NYISO hasdetermined National Grid to be the connecting Transmission Owner, as per the NYISO OpenAccess Transmission Tariff (OATT).

Category: Mandatory 

Risk score: 49 - Customer Driven

Finance

Sanction Cost & Range $2,726,000 $2,453,000 to $2,999,000

Cost volatility: P20 cost: Not Available P80 cost: Not Available 

Probability that project cost will exceed 10% tolerance: Not Available 

Project included in approved Business Plan? Yes 

Project cost relative to approved Business Plan -$614,000 

If cost > approved B Plan how will this be funded? Fully Reimbursable 

Other financial issues: This project has been included as a placeholder in the approvedbusiness plan, CNYX60. This project as presented is a decrease to the approvedbusiness plan. When the business plan was created the estimates were conceptual andhave been better defined during the NYISO interconnection process. All project costs arefully reimbursable from the developer. 

Current planning horizon

$mYr 1

10/11Yr 2

11/12Yr 3

12/13Yr 4

13/14Yr 5

14/15Yr 6+15/16

Total Lower Range P20 

Upper Range P80 

Proposed

investment0 0 .05 .94 1.1 .19 2.28 n/a n/a

Resources

Availability of internal resources to deliver project: Amber

Availability of external resources to deliver project: Amber 

Operational impact on network system: Amber

Note – Amber due to uncertainty of developer’s schedule

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Key issues

• The total project cost to interconnect the Cape Vincent Wind Farm (“Cape Vincent”) to theNational Grid Transmission System is fully reimbursable by the customer. 

• This project will interconnect to the new 115kV Rockledge Station, which is being

constructed for the interconnection of the St. Lawrence project (AMIC 0964), via a singlebreaker tap arrangement. The point of interconnection will be the Rockledge Station tap onthe existing bus. The wind farm is located in the Town of Cape Vincent in Jefferson CountyNY. The project’s collector stations will interconnect to the Rockledge Station via adeveloper owned, 6 mile 115kV transmission line. The NYISO has determined National Gridto be the connecting Transmission Owner, as per the NYISO Open Access TransmissionTariff (OATT). 

• The total project cost and schedule are dependent on Rockledge Station being constructedand turned over to National Grid before the Cape Vincent project interconnection isconstructed. It is expected that System Delivery (internal RDV) will complete construction onthe National Grid work scope. This assignment will be made after the interconnectionagreement is signed. (See Appendix C for Draft Interconnection Agreement Milestone

Schedule.) • BP Alternative Energy NA, Inc. (“Developer”) is constructing a 210 MW wind generation farm

consisting of one hundred forty (140) GE 1.5 MW wind turbines which will be interconnectedin two phases. Phase I will comprise 95 turbines (142.5 MW) and Phase II will include theremaining 45 turbines (62.4 MW). The output from each turbine will be stepped up to 34.5kV through individual pad mount 690V/34.5kV, 1.75 MVA transformers. The 140 units will bedistributed over 13 radial 34.5-kV feeder lines which will be brought to two separatecollection stations, approximately 2 miles apart, one for each phase. At the collectionsubstations the power output will be transformed to 115 kV through two non-regulated, wye-grounded transformers, one for each phase. The Phase I and Phase II transformers will be115/34.5 kV, 95/127/160 MVA and 115/34.5 kV, 45/60/75 MVA, respectively.

• A new 115kV single breaker tap will be constructed at the Rockledge Station by NationalGrid and serve as the Delivery Point for the project. BP Energy will furnish and installmetering transformers and provide space for National Grid metering equipment, at itscollector station. The furnishing and commission of the RTU and Metering equipment will bedone at the customer’s expense per section 7.1 of LGIA. The project will also encompassrequired protection upgrades at National Grid’s Black River and Coffeen substations. Theseupgrades, as defined in the facilities study report, may require outages at the substations.

• All work performed by National Grid is 100% reimbursable as per the Large GeneratorInterconnection Agreement (“LGIA”) that the NYISO, BP Energy and NMPC are negotiatingand will execute, subject to Sanction Paper Approval. The LGIA is consistent with the Termsand Conditions of Attachment S and X of the NYISO OATT and will be filed at the FERCupon execution.

• The construction of the project is expected to be completed by October 2014. It isanticipated that the LGIA will be executed in the 3rd quarter 2010. 

• This project is in the fiscal year 10/11 business plan with budget dollars in fiscal years 11and 12. Budgeted dollars will need to move from FY 11/12, to FY 12/13, 13/14, 14/15 andFY 15/16. The total budgeted capital dollars is $615,000 more than the estimated projecttotal cost presented herein. Place holder funding numbers are CNYX60 and CNYX60R.

• The commercial terms and the project execution schedule are subject to the pendingapproval of the Large Generator Interconnection Agreement (“LGIA”) between NMPC, BPEnergy, and the New York Independent System Operator (“NYISO”) by the Federal EnergyRegulatory Commission (the “FERC”). 

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National GridMIC 10032

• Tax obligations associated with the project will be the responsibility of BP Energy, in

accordance with Article 5.17 of the LGIA.

• Outages will be required. These outages will be defined and outage and construction plans

created after the Interconnection Agreement is executed and BP Energy has issued the

authorization to proceed, as per step 2A of the playbook. Final e - igineering design, and

outage and construction plans will be completed so as to ensure minimization of outage

requirements.

Key milestones

• Engineering Start — October 2012

• Construction Start — April 2014

• Prepare Equipment Ratings — July 2014

• Facilities Ratings to NYISO — August 2014

• Commissioning — December 2014

• Completion — January 2015

• Project closure — June 2015

Climate change

Contribution to National Grid's 2050 80% emissions reduction target:eutral

Impact on adaptability of network for future climate change:eutral

Are financial incentives (e.g. carbon credits) available?ot known

Prior sanctioning history including relevant approved Strategies

• July 21, 2009 — AMIC 0964 Construction of the Saint Lawrence Wind Farm Generation

Facilities

RecommendationsThe Asset Management Investment Committee is invited to:

(a ) APPROVE the investment of $2,726,000 in the range $2,453,000 to 12,999,000 for

completion by January 2015. This includes DOA for procurement events associated

with these projects.

(b ) NOTE that Mary Ellen Paravalos is the Project Sponsor.

(c ) NOTE that Francis Kane is the Project Manager and has the approved financial and

procurement delegation to deliver the project.

(d ) APPROVE entering into a Large Generator Interconnection Agreement (LGIA) with BP

Energy and the NYISO.

90)ignature._.  .............. .............`)Mary Ellen Paravalos, Vice President Transmission Regulation and Commercial

Decision of the Asset Management Investment Committee

I hereby approve the recommendations made in this paper.

Signature.ate.... Yb.

Paul Renaud, VP Transmission'Asset Management

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Capital/Revenue Investment Proposal

APPLICATION BY NIAGARA MOHAWK POWER CORPORATIONTO INSTALL A 115kV GENERATOR ATTACHMENT FACILITY

AND PERFORM MISCELLANEOUS FACILITIES WORK TO ACCOMMODATE THECONSTRUCTION OF THE CAPE VINCENT WIND FARM GENERATION FACILITIES

Transmission Line/Station, NMPC, Project No. B04627, CNYX60

(A sanction paper by Francis Kane and sponsored by Mary Ellen Paravalos – March 19, 2010)

1. Background

In January 2006, BP Energy submitted an Interconnection Request to the NYISO for the CapeVincent Wind Farm Project (“Cape Vincent Wind”) to identify the means with which tointerconnect the 210 MW wind farm generating facility to the company’s transmission system.As per Attachment S and X of the NYISO OATT, the NYISO has deemed National Grid to bethe Transmission Owner for this project.

The total estimate for the company’s work on the Cape Vincent Wind Project is estimated to be$2,634,000. BP Energy is responsible for all actual costs.

An Interconnection Agreement is being negotiated between National Grid, BP Energy andNYISO. Sanction approval is required prior to National Grid entering into the agreement.Section 11.5 of the LGIA ensures full cost recovery for National Grid and payments by the

interconnecting customer.

2. Driver

BP Energy has filed an Interconnection Request in compliance with the NYISO OATT. NationalGrid has been deemed to be the Connecting Transmission Owner and is required to provide thetransmission interconnection for this project. A feasibility study, system reliability impact studyand facilities study have been performed to determine the technical requirements, cost andschedule for the proposed interconnection. An Interconnection Agreement is being negotiatedbetween National Grid, BP Energy and NYISO. Sanction approval is required prior to NationalGrid entering into the agreement.

This project is mandatory and has been given a risk score of 49, customer driven.

3. Project Description

The project includes engineering, design, and construction of a single break tap at theRockledge Station, protection upgrades at Coffeen and Black River substations, and installationof an RTU and revenue metering at the Cape Vincent Wind collection station.

The system upgrades at Coffeen substation are associated with the addition of Cape VincentWind substations and single breaker tap at the Rockledge Station. The Line 3 and Line 5 CTratios will be raised to 500/5, and existing line relays reset. To prevent islanding of the CapeVincent Wind Farm when the Coffeen R40 breaker opens, dual channel DTT transmit will beinstalled to trip the wind farm when the line breaker opens.

The system upgrades at the Black River substation are associated with the addition of the CapeVincent substations and single breaker tap at the Rockledge Station. The Line 3 CT ratio will beraised to 500/5, and existing line relays reset.

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Outages will be required for some of the work at the stations. These outages will be defined andoutage plans created after the Interconnection Agreement and Authorization to Proceed, as perstep 2A of the playbook. Final engineering design will be completed so as to ensureminimization of outage requirements.

National Grid will provide to BP Energy (at BP Energy’s expense) an RTU to be installed by BP

Energy at its collection substation.

New revenue metering and associated data links will be installed at the Rockledge station andCape Vincent collection station.

Engineering review and field inspection of Cape Vincent’s stations will be completed bycustomer facilities engineer.

Any and all National Grid transmission and distribution facility relocation costs caused by the

Project. National Grid will work with the developer to identify these areas as soon as possible.These costs have not been identified and are not included in this sanction paper.

4. Business Issues 

Consistent with the provisions of Attachment S and X of the NYISO OATT, this is a fullyreimbursable project for National Grid. National Grid has been deemed to be the TransmissionOwner. A Large Generator Interconnection Agreement (“LGIA”) is being drafted by the threeparties, and its terms and conditions with conform to the pro-forma language of Attachment X.The LGIA will be filed at the FERC.

A brief summary of some key Articles in the Large Generator Interconnection Agreement can befound in Appendix B to this sanction paper.

5. Options Analysis

- The project was studied by incorporating the procedures of the NYISO OATT, Attachment X -Large Generator Interconnection. As this connection is mandated under the NYISO FERCElectric Tariff, OATT, Attachment X, Large Generator Interconnection Procedures andAgreement (“Attachment X”), “Do Nothing” is not an option.

- Construct a new single breaker tap at the Rockledge Station to serve as the interconnectionfacilities for the Cape Vincent Wind Farm Project. This is the recommended option. 

6. Milestones

Developer Written Authorization to Proceed July 2010Engineering October 2012 thru January 2014Construction April 2014 thru November 2014Prepare Equipment Ratings July 2014Facilities Ratings to NYISO August 2014Complete all testing & verifications November 2014Commissioning (Project in service) December 2014Project Closeout June 2015

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7. Safety, Environmental and Planning Issues 

Substation work will be completed so as to minimize load impacts. Appropriate safetyprecautions will be taken to accomplish this work.

During the work at Rockledge, Black River and Coffeen substations, specific attention will begiven to any work that will be done around energized equipment in the control buildings.

All necessary permitting  and property rights (ROW, easements or land transfer) are theresponsibility of, and will be obtained by, BP Energy.

National Grid will make clear and separate distinction between the work done by BP Energy andthe Company so as to avoid potential environmental impacts during the course of the work.

BP Energy is responsible for obtaining all the necessary local and state approvals for the projectto go forth.

BP Energy’s 34.5kV and 115kV lines, including their communication circuits for protectionsystems, may be crossing National Grid-owned distribution circuits. All line outages will be

coordinated with Regional Control, in accordance with applicable Regional Control Procedures.

Outages will be required for some of the work at the stations. These outages will be defined andoutage plans created after the Interconnection Agreement and Authorization to Proceed, as perstep 2A of the playbook. Final engineering design will be completed so as to ensureminimization of outage requirements.

The outreach level for this project is considered low. Most National Grid work will be withinexisting substations. The developer will be responsible all permitting and rights of way.

National Grid will engineer, design, procure, construct and test all changes and upgrades atexisting facilities.

Investment Recovery

8. Investment Classification

This connection is mandated under the NYISO OATT, Attachment X, Large GeneratorInterconnection Procedures and Agreement (“LGIA”), as such procedures and agreements areregulated by FERC.

The project was studied as per the requirements of the NYISO OATT, Attachment X - LargeGenerator Interconnection Procedures and Agreement.

9. Regulatory Implications

This connection is mandated under the FERC mandated NYISO OATT, Attachment X, LargeGenerator Interconnection Procedures and Agreement. Upon sanction approval, the LargeGenerator Interconnection Agreement (“LGIA”) will be finalized, executed by NMPC, BP Energyand the NYISO, and filed at FERC.

10. Customer Impact

There is no significant impact to our customers.

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Financial Impact

11. Cost Summary

Current planning horizon

$m Yr 1(FY11)

Yr 2(FY12)

Yr 3(FY13)

Yr 4(FY14)

Yr 5(FY15)

Yr 6+(FY16)

Total 

Lower 

Range P20 

Upper 

Range P80 

Proposedsanction

0 0 .05 .94 1.1 .19 2.28 NA NA

Capitalplan

.08 2.73 0 0 0 0 2.81

Varianceto plan

-.08  -2.73  +.05  +.94 +1.1  +.19 -.53 

   C  a  p   i   t  a   l   I  n  v  e  s   t  m  e  n   t

Unit costallowance

NA  NA  NA  NA NA  NA NA 

   O   &   M  Proposed

Sanction.16 .08 .05 .09 .05 .02 .45

   R  e  m  o  v  a   l

ProposedSanction

0 0 0 0 0 0 0

ProposedSanction

($m)Material .490Labor .290Other .420Transportation .023Reimbursement 2.725Labor Adders .437Contractor .435AFUDC .181Salvage TBDRemoval 0

O&M .450Retirement TBDTotal 2.726

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12. Cost Assumptions

The estimates, cost responsibility, payment provisions and the project execution schedule aresubject to pending approval of the Large Generator Interconnection Agreement (“LGIA”)between NMPC, BP Energy, and the NYISO by the Federal Energy Regulatory Commission(“FERC”).

This estimate (±20%) is for the identified work. However, BP Energy is responsible for paying allof National Grid’s actual costs. Cost recovery is addressed in the LGIA, Article 11 – Performance Obligations, which includes, by reference, Attachment S and Attachment X of theNYISO OATT. If Congestion costs are incurred with this project, efforts will be made tominimize these costs to the furthest extent possible. The (LGIA) allows NG to petition forrecover of these costs from the developer.

The entire $2, 726,000 estimated cost will be paid in accordance with Article 11 and 12 -Performance Obligations and Invoice, respectively, of the LGIA by BP Energy. Article 17 of theLGIA addresses Default issues and Article 18 of the LGIA addresses Indemnity, ConsequentialDamages and Insurance, consistent with Attachment X of the FERC Electric Tariff NYISOOATT.

This project will not create an income tax liability for National Grid per Article 5.17 of the LGIA ,but it will create O&M, property tax and communications costs liabilities for National Grid as perSection 15 below. 

During the Interconnection study process BP Energy has posted security and National Grid hasbeen reimbursed for actual costs. Following Attachment S and X in accordance with the LGIA,BP Energy will post security and will make monthly payments of actual costs incurred byNational Grid.

13. Benefits Summary

The entire $2, 726,000 estimated cost will be paid by BP Energy in accordance with the LGIA,Article 11 Performance Obligations and Article 12-Invoice. Article 17 of the LGIA addressesDefault issues and Article 18 of the LGIA addresses Indemnity, Consequential Damages andInsurance, in compliance with Attachment X of the FERC Electric Tariff NYISO OATT.

This project has been included in the approved business plan.

This estimate (±20%) is for the identified work. However, BP Energy is responsible for paying allof National Grid’s actual costs. Cost recovery is addressed in the LGIA, Article 11 – Performance Obligations, which includes, by reference, Attachment S and Attachment X of the

NYISO OATT. Congestion costs may be incurred with this project. The (LGIA) allows NG topetition for recover of these costs from the developer.

During the Interconnection study process BP Energy has posted security and National Grid hasbeen reimbursed for actual costs. Following Attachment S and X in accordance with the LGIA,BP Energy will post security and will make monthly payments of actual costs incurred byNational Grid.

14. NPV

The project is not financially driven.

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15. Additional Impacts

FERC orders have deemed the assets related to the Rockledge station to be both attachmentfacilities that NG will be able to charge the customer the associated ongoing O&M, PropertyTaxes, and communication circuit costs and system upgrade facilities for which National Gridwill be responsible after Cape Vincent is operational. This additional yearly expenditure will bein the range of $100,000. Additional property taxes and O&M associated with the facilities

upgrades at the existing stations are expected to be negligible.

16. Execution Risk Appraisal

National Grid is in the process of negotiating, with BP Energy, a schedule that it considers to bea reasonable amount of time to complete its work. This schedule will be depicted in Appendix Bof the Large Generator Interconnection Agreement. In the event that project delays are incurred,there is a Reasonable Efforts Standard definition that applies. (A draft of the milestone scheduleis in Appendix C to this paper.) 

This project has a direct interaction with the St. Lawrence Wind Project (AMIC 0964), underwhich Rockledge Station is to be constructed. Delay in the construction and energization of the

Rockledge Station will delay the interconnection construction for Cape Vincent Wind. Aresanction will be required, should material changes in the Rockledge Station schedule occur.

In the event the actual cost exceeds the estimated cost, BP Energy is responsible for the actualcosts. A brief summary of some key Articles in the Large Generator Interconnection Agreementcan be found in Appendix B to this sanction paper.

If BP Energy abandons the project prior to completion, in accordance with LGIA, Article 5.14,BP Energy will be responsible for National Grid’s costs. A brief summary of some key Articles inthe Large Generator Interconnection Agreement can be found in Appendix B to this sanctionpaper.

Outage and construction plans will be created after the Interconnection Agreement is executedand BP Energy has issued the authorization to proceed, as per step 2A of the playbook. Theseplans will be incorporated into the Scope document, which will be reviewed and approved priorto completion of Step 2A. If the approved Scope document differs from the approved sanction,then re-sanction requirements will be evaluated, and re-sanction completed, if deemednecessary.

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17. Statements of Support

The Authors of this paper assure that is accordance with TGP 11. The supporters listed belowhave been consulted and each states that they support this proposal:

Director Transmission Finance Budget – Pam Viapiano• Manager Transmission Finance / Rates – Pam Viapiano• Director, Transmission Asset Strategy – Alan Roe• Director, Transmission Commercial Services – William Malee• Director, NY Control Room –Michael Schiavone• Director, Operation Planning & Review – Nabil Hitti• Director, Transmission Planning – Carol Sedewitz• Director, Transmission Investment Management – Thomas Sullivan• Director, Project Management – Peter Kohnstam• Director, System Delivery – David Way• Director, Regional Delivery – David Way• Manager, Substation Engineering & Design NY – Suzan Martuscello• Manager, Environmental Affairs NY – • Manager, Protection Engineering NY – Steven Fanning

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APPENDIX AOne Line Diagram 

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APPENDIX BBRIEF SUMMARY OF KEY ARTICLES IN THE

LARGE GENERATOR INTERCONNECTION AGREEMENT (LGIA)

REFERENCE: Business Issues, Section 4, page 5

• Article 1: Definitions- Reasonable Efforts: This section established that actionsrequired to be taken by parties under the LGIA are timely and consistent with GoodUtility Practice and are otherwise substantially equivalent to those a Party would useto protect its own interests.

• Article 1: Definitions- Good Utility Practice: This section establishes the standard ofwork that will be used and is defined as good utility practice. “Good Utility Practiceshall mean any of the practices, methods and acts engaged in or approved by asignificant portion of the electric industry during the relevant time period, of any of thepractices, methods and acts which, in the exercise of reasonable judgment in light ofthe facts known at the time the decision was made, could have been expected toaccomplish the desired result at a reasonable cost consistent with good businesspractices, reliability, safety and expedition. Good Utility Practice is not intended to belimited to the optimum practice, method, or act to the exclusion of all others, butrather to delineate acceptable practices, methods, or acts generally accepted in theregion”

• Article 5.14: Suspension- This section provides for the reimbursement ofNMPC’s costs should Horizon Wind Energy abandon the project prior to completion.“ 5.14 Suspension. Developer reserves the right, upon written notice to TransmissionOwner and NYISO, to suspend at any time all work by Transmission Ownerassociated with the construction and installation of Transmission Owner’sAttachment Facilities and/or System Upgrade Facilities required for only thatDeveloper under this Agreement wit the condition that the New York StateTransmission System shall be left in a safe and reliable condition in accordance with

Good Utility Practice and the safety and reliability criteria of Transmission Owner andNYISO. In such event, Developer shall be responsible for all reasonable andnecessary costs and/or obligations in accordance with Attachment S to the NYISOOATT including those which Transmission Owner (i) has incurred pursuant to thisAgreement prior to the suspension and (ii) incurs in suspending such work, includingany costs incurred to perform such work as may be necessary to ensure the safety ofpersons and property and the integrity of the New York State Transmission Systemduring such suspension and, if applicable, any costs incurred in connection with thecancellation or suspension of material, equipment and labor contracts whichTransmission Owner cannot reasonably avoid; provided, however, that prior tocanceling or suspending any such material, equipment or labor contract,Transmission Owner shall obtain Developer’s authorization to do so.

Transmission Owner shall invoice Developer for such costs pursuant to Article 12and shall use due diligence to minimize its costs. In the event the Developersuspends work by Transmission Owner required under this Agreement pursuant tothis Article 5.16, and has not requested Transmission Owner to recommence thework required under this Agreement on or before the expiration of three (3) yearsfollowing commencement of such suspension, this Agreement shall be deemedterminated. The three-year period shall begin on the date the suspension isrequested, or the date of the written notice to Transmission Owner and NYISO, if noeffective date is specified”

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• Article 5. 15: Tax Implications- This section summarizes that “all payment orproperty transfers made by Developer to Transmission Owner for the installation ofthe Transmission Owner’s Attachment Facilities and the System Upgrade Facilitiesshall be non-taxable” and provides further detail on the indemnification of costconsequences of current tax liability as follows: “Developer shall protect, indemnifyand hold harmless Transmission Owner from the cost consequences of any currenttax liability imposed against Transmission Owner as the result of payments orproperty transfers made by Developer to Transmission Owner under thisAgreement….”

• Article 11: Performance Obligation- This section states that the Developer’sAttachment Facilities ( as outlined in Appendix A of the LGIA) will be designed,procured, constructed, installed, owned and/or controlled at the Developer’sexpense. Also, the Developer will pay for the Transmission Owner’s design,procurement, construction, installation of the Transmission Owner’s AttachmentFacilities ( also outlined in Appendix A of the LGIA). System Upgrade Facilities willbe designed, procured, constructed, installed and owned by the Transmission Owner( detailed in Appendix A of the LGIA) and costs assigned to the Developer inaccordance with Attachment S of the NYISO OATT”.

• Article 12: Invoice- This section outlines the responsibilities of both the TransmissionOwner and Developer to provide monthly invoices of amounts due for workperformed during the preceding month. “Each invoice shall state the month to whichthe invoice applies and fully describe the services and equipment provided”. Inaddition, “within six (6) months after completion of the construction of the TOAF andthe SUFs, Transmission Owner shall provide an invoice of the final cost of theconstruction of the TOAF and the SUF, in accordance with Attachment S to theNYISO OATT”. “Invoices shall be paid within thirty (30) Calendar Days of receipt”.

• Article 14: Regulatory Requirements and Governing Law – This section summarizesthat the LGIA is “governed by the laws of the state of New York”

• Article 15: Notices- Bill ing and Payments- This section establishes the deliverymethod appropriate for billing and establishes the appropriate addresses and contactpersons authorized to accept billing on behalf of the parties to the LGIA, inaccordance with Appendix F of the LGIA.

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APPENDIX CLARGE GENERATOR INTERCONNECTION AGREEMENT (LGIA)

DRAFT MILESTONE SCHEDULE

Milestone

Date

(mo/yr) Responsible

1.Execute Interconnection

Agreement07/2010 ALL

2.

Issue written authorization

to proceed with

engineering, design and

procurement of System

Upgrade Facilities

07/2010 Developer

3.

Provide security pursuant

to Section 6.3 of the IA 07/2010 Developer

4.Complete construction of 

Rockledge Substation07/2012

Saint Lawrence Wind (Acciona

Energy)

5.

Transfer ownership of 

Connecting Transmission

Owner Attachment

Facilities – Rockledge

Substation

09/2012

Saint Lawrence Wind (Acciona

Energy)/Connecting Transmission

Owner

6.

Start engineering and

procurement for System

Upgrade Facilities andTransmission Owner

Attachment Facilities.

10/2012 Transmission Owner

7.

Submit final design and

equipment specs for the

Developer Attachment

Facilities to the

Transmission Owner

10/2012 Developer

8.

Submit service request to

local Telco provider for all

required services

01/2013 Developer

9.

Complete review of, and

issue comments on, final

design and equipment

specs for Developer

Attachment Facilities 02/2013 Transmission Owner

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10

Submit relay coordination

study, ground grid design

calcs, corrected final

design, and final site and

plot plans for Developer

Attachment Facilities

05/2013 Developer

11.

Complete review of, andprovide comments on the

relay coordination study,

ground grid design calcs,

corrected final design and

final site and plot plans for

Developer Attachment

Facilities

08/2013 Transmission Owner

12.

Complete engineering and

procurement of System

Upgrade Facilities and

Transmission OwnerAttachment Facilities

01/2014 Transmission Owner

13.

Issue written authorization

to commence construction

of System Upgrade

Facilities and

Transmission Owner

Attachment Facilities

01/2014 Developer

14.

Start Construction of 

Developer Attachment

Facilities

09/2013 Developer

15.

Start Construction of System Upgrade Facilities

and Transmission Owner

Attachment Facilities

04/2014 Transmission Owner

16.

Submit energization

sequence and 6 week 

advance notice of 

functional test for

Developer Attachment

Facilities.

09/2014 Developer

17.

Complete Construction of 

Developer Attachment

Facilities

05/2014 Developer

18.

Complete Construction of 

System Upgrade Facilities

and Transmission Owner

Attachment Facilities

(dependent upon outage

availability)

10/2014 Transmission Owner

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19.

Energize the Transmission

Owner Attachment

Facilities

10/2014 Transmission Owner

20.

Complete all functional

tests and verifications for

Developer Attachment

Facilities, System UpgradeFacilities and

Transmission Owner

Attachment Facilities, and

documentation of punch

list

11/2014 Developer/Transmission Owner

21.

In Service (Developer

receives backfeed power

from Transmission Owner)

11/2014 Developer/Transmission Owner

22.Initial Synchronization and

start of Developer testing12/2014

Developer/Transmission

Owner/NYISO

23.Developer generator

testing completed01/2015 Developer

24.Commercial Operation

Date01/2015

Developer/Transmission

Owner/NYISO

25.

Complete and submit all

required documentation,

including As Builts 

04/2015 Developer/Transmission Owner

26.

Project close out

completed (including

completion of punch list 

items.) 

06/2015 Developer/Transmission Owner