General

GEN 00001
Published On: 12/27/2016

Question: Has Mon Power secured capacity via the RPM auction through May 2020? Is Mon Power looking for generation assets that have not sold any capacity during this period?

Answer: Through this RFP, Mon Power is looking for resources to meet its expected energy and capacity needs.  To the extent that a resource bid into the RFP has sold a portion of its capacity rights to a 3rd party, it would need to be disclosed and would be considered in the evaluation of the bid.

GEN 00002
Published On: 12/27/2016

Question: Will there be any requirements for Mon Power to sell Bath County before finalizing an acquisition, for example, if the sale offers for Bath County are too low?

Answer: The Mon Power's capacity RFP is separate from the RFP to divest Mon Power's ownership interest in the Bath County pumped storage project. The outcome of one RFP is not dependent on the outcome of the other.

GEN 00003
Published On: 12/27/2016

Question: Would Mon Power consider acquiring only energy for periods prior to May 2020?

Answer: At this time, MonPower is not considering contractual agreements or bids that for arrangement that offer only energy or only capacity.

GEN 00004
Published On: 12/27/2016

Question: Would Mon Power consider a long term fixed price power purchase agreement instead of an acquisition (for both energy and capacity), where the fixed price would be significantly below the long term cost of an acquisition?

Answer: MonPower is looking to acquire a physical asset and, at this stage, is not considering contractual agreements.

GEN 00005
Published On: 12/27/2016

Question: How would Mon Power evaluate a proposal to acquire a facility that is less than 1300 MW, assuming there no options to purchase multiple plants that provide exactly 1300 MW?

Answer: The RFP Manager may select a single asset or a portfolio of multiple facilities to best meet the MW requirement even if the best asset(s) do not total exactly 1,300 MW.

GEN 00006
Published On: 12/27/2016

Question: Does Mon Power have a preference for baseload generation vs peaking? Coal vs gas?

Answer: Mon Power is looking for the asset or assets that best meet their needs.  Assets may be coal or natural-gas fired facilities.

GEN 00007
Published On: 12/27/2016

Question: Will Mon Power provide gas and coal price forward curves that they expect to use to evaluate proposals?

Answer: Mon Power does not anticipate providing the details of the market price forecasts used in the evaluation. 

GEN 00010 (revised 01/10/2017)
Published On: 01/06/2017

Question: Section 5.3.1 of the RFP states that compliance will be measured as the actual measured load at or below the Firm Contract Load. 1. Is the Firm Contract Load the same as PJM’s Firm Service Level? 2. What is the baseline? If it’s the customer’s Peak Load Contribution, how are line losses accounted for? The RFP also states that the Actual Measured Load will be determined by the highest measured load during the Emergency Curtailment Event. At what interval is that point measured? Is this to say that for a six (6) hour curtailment event if a customer reduces 10 MW but for thirty minutes they only reduce 2 MW, they will only get credited for 2 MW of actual measured load?

Answer: 1.  Yes

2.  If baseline is referring to the Firm Contract Load, there is no baseline. The Firm Contract Load shall be decided by the DR Supplier at the time the DR Agreement is executed and is the amount that the customer can curtail at or below during an emergency curtailment event.

Actual Measured Load is determined at the customer meter level.

A DR Supplier is compensated based on the Curtailable Capacity Amount defined in Article 1.1.11 of the Demand Resources Purchase Agreement.

The measured load is the highest thirty (30) minute clock half hour of integrated kw load occurring during the emergency curtailment event.

Actual measured load is not the amount the customer reduces during an emergency curtailment event. Actual measured load means, with respect to an emergency curtailment event, the highest kw of actual aggregated measured load of the program participants during such emergency curtailment event, as measured by company at every clock half hour. During an emergency curtailment event, a dr supplier must be at or below their firm contract load each clock half hour of the emergency curtailment event.

GEN 00011
Published On: 01/06/2017

Question: Section 5.3.1 of the RFP states that MonPower may call an unlimited number of emergency events with no restriction on duration at any time during the year. Can or will MonPower put any parameters on events? Can events be called at any hour of the day or night? Can MonPower call an Emergency Curtailment Event at 3am for a 24 hour duration? If so, is the load reduction expected to be the same at 3am as it would be at 3pm?

Answer: There are no specific parameters. It is at MonPower’s sole discretion when an emergency event may be called, when it is deemed that an emergency situation exists that may jeopardize the integrity of either the distribution or transmission system in the area.

Yes, it can be called any hour, day or night.

Yes, it could be called at 3am for 24 hours.

Yes. During an emergency curtailment event, the DR Suppliers’ Actual Measured Load must be at or below its Firm Contract Load for the entirety of the event, measured every clock half hour.

GEN 00012
Published On: 01/06/2017

Question: Section 5.3.2 of the RFP states that if the DR Supplier’s Actual Measured Load exceeds 110% of the Firm Contract Load the DR Supplier will be penalized: (i) forfeiture of its payment for the month, (ii) remit previous 12 months of payments, and (iii) pay an Emergency Curtailment Charge equal to the amount of load exceeding the Firm Contract Load multiplied by 300% of the applicable hour’s LMP. Can you expand on the part (iii) of that penalty? Why is 300% used? And if this is an RFP for capacity resources, why is the resource being penalized as an energy resource?

Answer: The 300% penalty is consistent with the practices and experience of Mon Power and its affiliates.

If a customer’s Actual Measured Load is not below their Firm Contract Load during an Emergency Curtailment Event as measured every clock half hour, the resource is responsible for the excess energy used during that period. This payment is to cover that excess energy usage.

GEN 00013
Published On: 01/06/2017

Question: Section 5.4.2 of the RFP states that a Proposal must include a description of the individual DR customer or if an aggregation of DR customers it must include the customer names and 20-digit account numbers. Can the CSP provide a description of the types of customers they will target to fill the MonPower obligation? As this program will not start until 2021/22 it will be very difficult to provide specific customers that we will enroll this far in advance.

Answer: Potential bidders can find required information for Planned Demand Resources in Section 5.4.2 of the RFP (page 33).

GEN 00014
Published On: 01/06/2017

Question: Section 5.3.1 of the RFP states that during Emergency Curtailment Events initiated by PJM, PJM will notify MonPower who will then notify the DR Supplier. DR Suppliers that have customers registered with PJM for PJM Emergency Load Management program are dispatched by PJM directly via an electronic signal that is set up through a mandatory required heartbeat with PJM. DR Supplier’s must be dispatched by PJM for the DR resources they register into the market. Is the MonPower dispatch signal a secondary or backup signal to PJM’s? Could you expand on how the dispatch would occur for PJM initiated events?

Answer: As stated in Section 5, a DR Supplier is defined as either a Mon Power or Potomac Edison-West Virginia customers (each a “Customer”) or Curtailment Service Provider(s) (“CSP”). In either case, for the Demand Side Resources contracted, Mon Power would be the PJM Curtailment Service Provider (PJM CSP) for participating DR Suppliers and would administer the registration process with PJM each delivery year in the PJM Emergency Load Management program. In that role, Mon Power would receive the PJM dispatch notices directly and then notify DR Suppliers. DR Suppliers would not receive the primary notice from PJM as they would not be the PJM CSP for the Emergency Load Management program.

As indicated in Section 5.3.1 “Mon Power will notify the DR Suppliers of an Emergency Curtailment Event by issuing an electronic message to a device or devices such as telephone, facsimile, or email, selected and provided by the DR Supplier and approved by Mon Power”. Event start and end notices will be provided for both PJM initiated Emergency Curtailment Events and Mon Power initiated Emergency Curtailment Events.

GEN 00015
Published On: 01/06/2017

Question: Section 5.4.3 of the RFP states that under any DR Agreement executed as a result of this RFP, MonPower shall acquire all rights, titles, and interests in the Demand Resources including all the potential capacity and energy revenues associated with that Demand Resource. Is the RFP stating that if a CSP delivers a customer to MonPower and fulfills the RFP, if that CSP also enroll that customer into PJM's Economic, Synch Reserves and/or Regulation programs, that MonPower will retain all revenues associated with that customer and those programs? If yes, can you please expand on why that is?

Answer: No. Mon Power would register eligible DR customers with PJM each delivery year in the PJM Emergency Load Management program as a Capacity Only DR Resource to receive the RPM Capacity Revenues.

CSPs can enroll participating DR customers in the PJM Economic, Synch Reserves and/or Regulation markets and receive those revenues.

GEN 00016
Published On: 01/10/2017

Question: Please describe the details of the rating system to be used in scoring alternative proposals submitted: Will the evaluation be performed under a scenario in which Bath County is not sold to deem if the proposed path may be superior?

Answer: The RFP Manager will evaluate the bids consistent with the evaluation criteria outlined in the RFP documents.

GEN 00017
Published On: 01/10/2017

Question: What is the energy shortfall Mon Power is looking to fill in corresponding to the sale of its interest in Bath County?

Answer: CRA and Mon Power do not anticipate disclosing the analysis associated with the potential divestiture of the Bath County facility.

GEN 00018
Published On: 01/16/2017

Question: We’ve received information back from the MonPower RFP Manager regarding Initial Collateral on how and where to post but nothing about when we would expect a return of the collateral. Does that occur upon delivery of all DR MW June 2021 or at the end of the RFP, May 2026?

Answer: The instructions for posting collateral include information on the return of collateral. Section 10.2 of the RFP states “DA Collateral posted by a DR Supplier shall be maintained during the term of the DR Agreement.” Once the term of the DR Agreement has ended in May 2026, DA Collateral will be returned.

GEN 00019
Published On: 01/16/2017

Question: If MonPower will be the curtailment service provider (CSP) of record with PJM for all DR customers we bring to the MonPower DR program, will the DR customers need to execute contracts with MonPower directly or will they be able to contract with the CSP?

Answer: MP will execute the contract with the winning bidder(s), which could either be a CSP or a Customer. If the winning bidder is a CSP, contracts would be executed with the CSP and not their customers. If the winning bidder is a Customer, the contract will be executed with the Customer.

GEN 00020
Published On: 01/16/2017

Question: For the Demand Response portion of the RFP, whom will be responsible for collecting meter data, MonPower or the curtailment service provider (CSP)?

Answer: Mon Power requires that utility metering be installed at customer sites during the term of contract regardless of whether the contract is executed with the CSP or Customer. MP will collect the utility meter data directly.

GEN 00021
Published On: 01/16/2017

Question: For the Demand Response portion of the RFP, will 100% of the PJM capacity revenue that MonPower receives from PJM on behalf of the DR customers we bring to the program be paid back to the CSP or is MonPower also taking a portion of the PJM capacity revenue?

Answer: Mon Power will retain 100% of the capacity revenue.

GEN 00022
Published On: 01/27/2017

Question: For a planned but not yet constructed facility, when would MonPower expect to take title of the asset? Prior to construction or at substantial completion? If prior to construction, would MonPower pay all required construction costs to build the facility, which would be included in the acquisition price?

Answer: Mon Power will not take title until final completion. This includes all construction and necessary testing. All costs prior to that point will be the responsibility of the bidder.

GEN 00023
Published On: 01/27/2017

Question: The transaction is structured as an asset purchase - how does MonPower anticipate handling the transfer of contracts, permits and approvals? Would MonPower be opposed to structuring the acquisition as a membership purchase rather than an asset purchase to more efficiently transfer ownership with all contractual and permit rights?

Answer: Through this RFP, Mon Power anticipates executing an APA consistent with what has been provided to all bidders for the purposes of formulating their bids.  To the extent that a bidder proposal is made under an alternative structure, the proposal may be considered non-conforming.  Proposals that are nonconforming may be deemed ineligible and may not be considered for further evaluation.  

GEN 00024
Published On: 01/27/2017

Question: Under what circumstances would the security be drawn upon prior to executing definitive documents?

Answer: As noted in RFP Section 10.2, DA Collateral is required to:

To secure the Respondent’s development efforts to satisfy interim milestones, establish consequences for failing to meet interim milestones, delay damages, final deadline for achieving commercial operation and possible step-in rights.

Mon Power's rights to draw upon the DA would include, but may not be limited to, unmet development milestones and/or Mon Power exposure to damages due to delays in the anticipated commercial operation date of a facility.  

GEN 00025
Published On: 01/27/2017

Question: For a planned generating asset, what role would MonPower have in the entry into project contracts, permits, approvals, development and/or construction activities?

Answer: Mon Power anticipates taking title to any planned generating asset upon final completion and testing.  All costs prior to that point will be the responsibility of the bidder.

GEN 00026
Published On: 01/27/2017

Question: Is Mon Power, taken together with its affiliates, permitted to acquire a completed or nearly-completed generation facility within or adjacent to its service territory, or do market-power issues present any regulatory impediment?

Answer: Mon Power does not anticipate any market-power issues presenting regulatory impediments at this time.

GEN 00027
Published On: 01/27/2017

Question: When does MonPower expect to have WVPSC assurance of recovery of costs in MonPower’s rates, and does MonPower contemplate that any regulatory-out or regulatory-modification provisions will be at the Developer’s or Project’s risk?

Answer: As indicated in the RFP, Mon Power expects to file with the WV PSC in March, 2017. While Mon Power expects a decision later in 2017 as described in section 4.1.2.4, the actual timing of the decision is up to the PSC. All risks prior to transfer of title are borne by the bidder.

GEN 00028
Published On: 01/27/2017

Question: Does MonPower expect that the facility will be treated as a rate-base facility, and how will interconnection facilities and upgrade costs be allocated?

Answer: The bidder is required to deliver a completed, interconnected project. How Mon Power recovers its costs is not relevant.

GEN 00029
Published On: 01/27/2017

Question: For a new generator that is presently under development and may not be commercially operable until a date following the initial auction deadlines for the 2020/2021 CP DY, would MonPower accept within-year deliveries via an incremental auction and accept delay risk relating to a MonPower-affiliated transmission owner’s interconnection activities?

Answer: As described in the RFP section 4.1.2.5, the resource must qualify as a capacity resource for the 2020/2021 delivery year. This requires that the unit(s) qualifies for and is offered in the Base Residual Auction for the 2020/2021 delivery year.

RFP Rules

RUL 00002
Published On: 01/06/2017

Question: Section 10.1 of the RFP states that Demand Resources must post $35.71/kW of reduction as collateral. So if a CSP commits to 100 MW of DR, would they have to post $3,571,000 (100 MW * $35,710/MW)? When would this need to be posted and when would the CSP get this back? If the CSP currently serves 50 MW of MonPower customers in the PJM Emergency Load Management program, do they only need to post the collateral for the additional 50 MW as they have already have proven to deliver 50 MW of DR?

Answer: Yes, a CSP submitting a bid for 100 MW of DR would be required to post collateral of $3,571,000. Instructions for the posting and return of collateral will be sent to all bidders that are pre-qualified by CRA.

Yes, a CSP currently serving 50 MW of Mon Power customers would be required to post collateral in accordance with the amounts and process provided in the RFP.

RUL 00003 (revised 01/10/2017)
Published On: 01/10/2017

Question: Please describe the details of the rating system to be used in scoring alternative proposals submitted: What are the quantitative and qualitative evaluation components and what are the respective weightings to be applied to each evaluation component?

Answer: The evaluation components to be considered are shown on pages 21 through 26 in the RFP. CRA and Mon Power do not anticipate disclosing details of the rating system prior to the Proposal Due Date.

Required RFP Data

DAT 00001
Published On: 01/06/2017

Question: Under Section 1.2: Operating Data on the Information Form Addendum, does the term “Maintenance Rate (%)” refer to the maintenance outage rate?

Answer: Yes.  "Maintenance Rate (%)" refers to the maintenance outage rate.

Documents

AGR 00001 (revised 01/10/2017)
Published On: 01/10/2017

Question: Under section 1.6: CapEx on the Information Form Addendum, what is the definition, including a nominal dollar value, of “major upgrades”?

Answer: Major upgrades would include CAPEX expenditures in association with one time or infrequent projects that would not be representative of ongoing, routine CAPEX. There is no specific dollar value threshold on the expenditure.  Please include a description of any project along with the CAPEX amount.

AGR 00002
Published On: 01/16/2017

Question: The Asset Purchase Agreement provided with the RFP appears to be for an existing generation facility. Can you provide the Asset Purchase Agreement for a planned generation facility?

Answer: Mon Power believes the draft Asset Purchase Agreement (“APA”) attached as Appendix D covers all eligible resources, including planned generation facilities. Per Section 4.1.7.1 of the RFP, Mon Power reserves the right to not consider any separate APA submitted along with a bid. However, given that projects for new or planned resources are likely to be at different developmental stages, Mon Power may consider proposed changes to the draft APA to incorporate the specific factual details of the planned generation facility to the extent that the APA does not address issues specific to a Respondent’s Proposal for a new or planned generation resource.