Clean Power Call Q&As

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Questions from Proponents registered for the Request for Proposals (RFP) on the RFP, the RFP process or related documents and BC Hydro's answers to them will be posted on this page.

The Q&As presented on this page will be numbered chronologically based on the date of posting. Most recent Q&As will be posted first.

You must be registered as a Proponent to submit a question. BC Hydro's answers to Proponent's questions are for general information only, do not constitute legal or other advice and do not amend or form part of the RFP, unless confirmed by Addendum or revised RFP documents. For further information on the Q&A process, refer to section 9 of the RFP.

Note to Proponents: Proponents needing an answer to their questions prior to the Proposal Submission deadline are requested to submit their questions on or before Tuesday November 11, 2008.

November 19, 2008

192. As you are aware, we are currently in the midst of a deep global financial crisis. Due to this unforeseen and unprecedented global financial crisis, it is currently extremely difficult for renewable energy developers to obtain project financing on stable and predictable terms. We therefore request that BC Hydro extends the November 25, 2008 Clean Power Call deadline by 60 to 90 days. An extension will give time for financial markets to settle and return to a more stable state. A return to stability will allow developers to return to "business as usual" and provide more competitive pricing to BC Hydro. We firmly believe that an extension is in the best interests of BC Hydro, the Government of B.C., all British Columbians and the renewable energy industry.
The deadline for Proposals submission remains unchanged at 4:00 p.m. PPT November 25, 2008. BC Hydro is mindful of the current financial situation and the uncertainty as to when circumstances may change. To date, it appears that there remains significant interest in the Clean Power Call. BC Hydro will review the Proposal submissions received on November 25, 2008 and will evaluate the Proposals based on the evaluation criteria described in the RFP. To the extent that BC Hydro determines that any Proposals provide cost-effective energy supply, BC Hydro intends to award Electricity Purchase Agreements. Ultimately, any EPAs awarded under the Clean Power Call RFP will be subject to filing with the BCUC pursuant section 71 of the Utilities Commission Act and the BCUC will determine whether the EPAs are in the public interest.

191. For projects which begin operation part way through a year, will the revenues be paid based upon a monthly CPI escalator until the new year? In the current model, the price is escalated monthly.
For a project with a COD part way through a year, the pre-COD escalation terminates on the first of the month that the earlier of COD and Guaranteed COD occur and post-COD escalation takes over thereafter. However, the Firm Energy price is adjusted for post-COD escalation only once a year, on the first day of the calendar year. This means that once a project reaches COD, there will be no further escalation for the balance of the year. The next Firm Energy adjustment occurs on January 1^st of the year following COD using the post-COD escalation factor.

190. In the EPA, will the CPI esclator always lag by one year, as the CPI adjustor on January 1 will reflect the prior year's inflation?
The Firm Energy price adjustment following COD is an annual adjustment on the first day of each calendar year using the post-COD escalation factor. Other than the time of delivery adjustment, the Firm Energy price following an annual adjustment remains constant for the balance of that year, meaning that Firm Energy delivered in the last month of the calendar year will be paid the same Firm Energy price as at the start of the calendar year.

189. Is it required, or is it advantageous, that a Proponent attaches a "letter of opinion" from TerraChoice Environmental Marketing stating that the project being proposed would likely qualify for certification under the Environmental Choice Program?
Proponents of projects that use a clean or renewable resource or technology as described in the "British Columbia's Clean or Renewable Electricity Definitions" are not required nor is there an advantage, to attach a "letter of opinion" from TerraChoice Environmental Marketing stating that the project being proposed would likely qualify for certification under the Environmental Choice Program.

188. Will BC Hydro be using the price levelization methodology as outlined in the sample calculation spreadsheet to compare projects? If yes, will the calculation parameters as shown in the model (inflation, discount rate, etc.?) be used for the comparison? If not, which factors will be used?
For purposes of the Clean Power Call price evaluation, BC Hydro is planning to use the same price levelization methodology as outlined in the Sample Calculations – Updated Price Levelization Model issued on September 22, 2008. As of the date of this posting, BC Hydro intends to use the same inflation and discount rate assumptions as those used in the sample calculation spreadsheet; however BC Hydro reserves the right to use the best information available at the time of the evaluation, which could include changes to those assumptions.

187. According to the Proposal Letter (Schedule 8) guidelines, Proponents are required to provide an update showing changes to the Disclosure Statement (Schedule 4) submitted upon registration. Is an updated Disclosure Statement required for each Project or will a single Disclosure Statement for the Proponent be sufficient?
Disclosure Statements should clearly identify if and how any disclosures differ for each Project submitted by a Proponent. As such, the Proponent may choose to submit separate Disclosure Statements for each Project.

186. Is it acceptable to include the Project Description, Energy Source Data and Variations Proposal in the same binder, for a total of 4 binders? Or, would BC Hydro prefer each document in a separate binder, for a total of 12 binders?
BC Hydro's preference is that the Variations Proposal not be bound with other Proposal documents. The Project Description and Energy Source Data can be placed in the same binder, as long as each respective element is clearly identified.

185. Regarding section 2.14 of the Project Description Requirements (Schedule 10), please provide more specific details as to what BC Hydro expects wind developers to include in a permanent wind data collection system. Typically, permanent met towers are installed as a part of the wind forecasting program. The cost and number of met towers would depend on the site size and complexity of the site as well on the company that performs the forecasting. Would the developer be required to contract a company to provide wind forecasting and install towers, or would a SCADA system installed at the wind turbines be sufficient?
Proponents are not required to perform, or contract a company to perform, wind power forecasting, given that BC Hydro intends to implement a centralized wind power forecasting system. In support of the forecasting function, a permanent wind data collection system should include SCADA data (including but not limited to wind speed and direction, power output, and turbine availability) and measurements from at least one permanent hub-height met tower. The permanent met tower(s) should provide wind speed and direction measurements at multiple heights, as well as measurements of temperature, pressure and relative humidity.

184. In subsection 2.9.3 (a)(ii) of the Project Description Requirements (Schedule 10), does the following text apply to all required permits, whether or not already applied for, or only to those permits that have been applied for, but not yet received?

"As an Exhibit to the Project Description a copy of any pending permit application with a copy of letter of receipt or acknowledgement from the respective agency, a description of the status of the application, any known opposition or impediment to the issue of the permit and the expected impact thereof on the permitting schedule and any planned measures which the Proponent intends to implement to avoid or mitigate any anticipated delay in issue of the permit"

Subsection 2.9.3 of Schedule 10 applies to all required permits that have not yet been received, whether or not they have been applied for. In the case of permits not yet applied for, it is acknowledged that it will not be possible to provide an Exhibit containing a pending permit application.

183. As part of our First Nation engagement process, we have sent the First Nation impacted by our proposed project draft copies of Environmental Assessment filings, such as the project description and draft terms of reference. These drafts have been refined and revised copies of the filings have been sent to the First Nation. We would like to include the complete document of only the most recent version in our submission, along with the title page and table of contents of the earlier drafts. Would BC Hydro like to see all drafts in full?
BC Hydro does not require the Proponent to submit the earlier draft Environmental Assessment filings. A full copy of the most recent submission will suffice.

182. If a Proponent currently has committed lines of credit from credit worthy banking facilities that exceed the project cost, would BC Hydro accept evidence of these lines of credit (e.g., through audited annual financial statements) and therefore waive the requirement for a commitment letter of credit from a banking institution?
It should be noted that BC Hydro is not asking for a "commitment letter of credit from a banking institution", but rather a commitment letter from debt and equity providers. A commitment letter demonstrating a firm commitment from an equity or debt provider is not a Proposal requirement – it is a recommended element. A line of credit does not replace a commitment letter for debt or equity financing, unless it is accompanied by a letter from the lending institution indicating that (as noted in subsection 3.2.3(a)(i) of Schedule 10): "they have reviewed and evaluated the Specimen EPA, the Proponent's cost estimates and financing assumptions for the Project, and based on this evaluation confirm that they will provide a specified amount of financing, subject only to certain limited conditions as specified in the letter."

181. Is it sufficient to submit consolidated financial statements in support of a Proponent or project?
Subsection 3.2.5 (b) of the Project Description Requirements (Schedule 10) reads:

If the Proponent's financial information is consolidated with other entities, it is the Proponent's responsibility to extract and submit as separate documents all data and information solely related to the Proponent, including financial information, associated notes and all other information that would comprise a full financial report conforming to GAAP.

If a Proponent wishes to submit an annual report of any corporation, it is the Proponent's responsibility to identify to BC Hydro the relevant information contained within the report that demonstrates the financial strength or support that is relevant to the Proponent and the Project. The Proponent should also clearly specify the relationship between itself and the corporate entity for which the financial information is submitted.

180. Subsection 2.9.3(a)(i) of the Project Description Requirements (Schedule 10) asks for a permitting schedule. Does this need to be in Gantt chart form?
The permitting schedule does not need to be in Gantt chart form. Proponents may use their discretion as to the best format for presenting this schedule.

179. Subsection 2.9.3 of the Project Description Requirements (Schedule 10) refers to pending permits. Does it also include permits "Not applied for yet"?
Yes, the reference to pending permits in subsection 2.9.3 of Schedule 10 includes permits not applied for yet.

178. Does BC Hydro envision any scenario whereby a party that has a project being proposed into the RFP by one of its affiliates can:

1. hold discussions with other potential bidders; and/or
2. conduct a cursory level of due diligence on another bidder's project in advance of the bid submission date without running afoul of the non-collusion provisions?

BC Hydro cannot speculate on the circumstances, if any, in which it may consent to communications between unrelated Proponents or their Affiliates. Generally, BC Hydro expects that the provisions of the Confidentiality and Compliance Agreement will be observed by all Proponents, including protecting the confidentiality of discussions, if any, with BC Hydro and refraining from collusion among Proponents throughout the RFP process. Any waiver of these contractual obligations would be considered, if at all, only in limited circumstances where the integrity and competitiveness of the process is not threatened.

177. If a Proponent is considering the sale of a project for which it is intending to submit an independently prepared Proposal, under what conditions can the Proponent initiate due diligence and discussions regarding the proposed sale of its project shortly after Proposal submission (with the consent of BC Hydro such that the project's buyer will participate in the post-RFP discussions between the Proponent and BC Hydro) with a project buyer that is an affiliate of another registered Proponent?
BC Hydro will consider only Proposals from registered Proponents or their Affiliates, and registration must be complete before or on submission of the Proposal. Consequently, Proposals are not assignable by the Proponent, whether to its Affiliate or to another Proponent or its Affiliate, after Proposal submission. Also, Proponents are bound by the Confidentiality and Compliance Agreement, which includes in addition to obligations of confidentiality, a commitment to comply with the RFP rules relative to collusion and other matters. Consequently, a registered Proponent who submits a Proposal should not undertake discussions with any other Proponent, or Affiliate of any other Proponent, with a pending Proposal, that could violate these obligations, for example, by disclosing confidential discussions with BC Hydro and/or pricing or other competitively-sensitive information.

176. Is it possible for a Proponent to sell the rights to its proposed project to a third party, or an affiliate of a registered Proponent, prior to Proposal submission, thereby allowing the purchaser of the project to register as a Proponent and submit a Proposal? (Note that such a sale would be conditional upon receipt of certain consents and authorizations, including consent to assign the interconnection study agreement, which will not have been received prior to the bid submission deadline).
All Persons intending to submit a Proposal in the Clean Power Call must be registered as a Proponent. Registration requires filing of a Registration Form (Schedule 3), a Disclosure Statement (Schedule 4), two copies of a Confidentiality and Compliance Agreement (Schedule 5), an Interconnection Disclosure Consent (Schedule 6) (collectively "Registration Documents") and a registration fee. See section 5 of the RFP and relevant Addenda for further details. BC Hydro will consider only Proposals from registered Proponents or their Affiliates. See the definition of "Affiliate" in Schedule 1 of the RFP. A registration is not assignable. BC Hydro encouraged Proponents to register by August 12, 2008, but may accept late registrations up to the time for Proposal submission.

A registered Proponent may transfer Project assets to its Affiliate, and the Affiliate may submit a Proposal under the registration. The Affiliate should file an updated Disclosure Statement (Schedule 4), two copies of a Confidentiality and Compliance Agreement (Schedule 5), an Interconnection Disclosure Consent (Schedule 6) all in respect of the Affiliate, and those documents may be filed before or with submission of the Proposal.

If a registered Proponent transfers Project assets to a Person that is not an Affiliate of the registered Proponent, then the transferee should file a complete set of Registration Documents and a registration fee before or with the submission of the Proposal. The transferee would be required to meet all other eligibility requirements under the RFP.

175. With reference to subsection 2.9.3 (Pending Permits) of the Project Description Requirements (Schedule 10), are project descriptions submitted to the BC Environmental Assessment Office (BCEAO) and Canadian Environmental Assessment Agency (CEAA) considered "permit applications"? If yes, for projects that are currently included in both types of assessments, should a copy of each project description be included in the RFP Proposal as an Exhibit even if both descriptions contain identical information and a significant number of identical maps and figures, which are also required in other sections of the Project Description Requirements?
One project description and one application are acceptable for the harmonized review of BC EAO and CEAA reviewed projects.

174. With regard to the information/documents provided as Exhibits to the Project Description, it appears that the same information/documents are requested in multiple sections of the Project Description. Should multiple copies of the same information be provided as separate Exhibits to the Project Description?
Where duplicate information is requested, it is acceptable to BC Hydro if Proponents include the requested information once in an Exhibit and provide a clear reference to that Exhibit in the relevant sections of the Project Description.

173. We are preparing our bid package and reviewing the Proposal contents guidelines. We anticipate that our bid will be in the range of five to six binders in size. Multiply that by four copies, and one box is not going to be big enough. Would it be acceptable to have one box for each copy of our submission (four boxes total)?
Yes, BC Hydro will accept Proposal(s) submitted in multiple boxes, as long as the contents of each box are clearly identified. Proponents are also reminded to mark the boxes containing the Proposal(s) with the Proponent name and return address.

172. For our proposed project, we anticipate scheduling a recurring maintenance program during either the System Freshet Season or the summer, a program that may be up to 3 weeks in duration every year. We would also anticipate scheduling these Planned Outages with the requested 90 days notice described in section 6.3 of the Specimen EPA. We are concerned that these Outages may cause Liquidated Damages or project costs of another nature. Can you please confirm that Planned Outages will not be considered deemed Eligible Energy, per section 7.8 of the Specimen EPA?
Subsection 7.7(a)(vi) of the Specimen EPA excuses the Seller from delivery obligations during Authorized Planned Outages and these Outages are backed out of the delivery shortfall Liquidated Damages calculation in section 13.2. The deemed Eligible Energy referred to in section 7.8 of the Specimen EPA is intended to provide payment to the Seller for Energy that could have been generated and delivered by the Seller's Plant but was prevented from doing so at the point of interconnection (POI) due to a Transmission System Outage not caused by either the Seller or events beyond the control of BC Hydro or the Transmission Authority. During an Authorized Planned Outage, there is no deemed Eligible Energy.

Can you describe how these Planned Outages are best presented in the Commercial Proposal and/or the Specimen EPA (refer to item #12 (d) in the Commercial Proposal, which states "Assume no Planned Outages (as defined in the Specimen EPA) in completing the table")? How do we complete the energy profile table in item 12 of the Commercial Proposal and/or the EPA without it causing Liquidated Damages and causing a "resetting" of the 5-year "Firm Energy adjustment" calculation? How would the 5-year adjustment calculation treat these Planned Outages?
In completing item #12 (d) in the Commercial Proposal, the Proponent should not make allowance for Planned Outages, as Firm Energy delivery obligations will be adjusted for these Outages over the term of the EPA. During Authorized Planned Outages, Firm Energy delivery obligations are excused and therefore, non-deliveries during these periods do not attract Liquidated Damages.

In resetting the "Firm Energy Amounts" at 5-year intervals, the "Total Energy Amount" used in the calculation is the sum of (i) the amount of Energy actually delivered to the POI and (ii) the amount of Energy that could have been generated and delivered to the POI, but for Outages of the Seller's Plant. In other words, a certain level of generation output will be assumed during an Outage period for the purpose of calculating the 5-year Firm Energy adjustments. Please refer to subsection 7.10(b) of the Specimen EPA for further details.

171. The Energy Source Data Requirements (Schedule 11), released on September 22, 2008, require that the submission follows "the numbers system and the headings set out in these instructions". Can you please be explicit as to what numbering system and headings this is referring to? Does it mean simply the headings "A. Hydrological Data" and "B. Wind Data", etc.? Or are there supposed to be more comprehensive headings similar to those in the revised Project Description Requirements (Schedule 10) released on October 21, 2008?
Proponents are strongly advised to follow the numbering system and the headings set out in the instructions to the Energy Source Data Requirements (Schedule 11). For example, for a hydro project, the heading "A. Hydrological Data" should be used along with the subheadings (a) through (h).

170. Regarding the Project Description Requirements (Schedule 10), we understand that BC Hydro strongly encourages Proponents to follow the numbering system and the headings as set out in item 3 of the General Instructions. However, can Proposals contain a more detailed numbering system than the one set forth in the Project Description Requirements document? For example, using 2.1.1 instead of the letter (a) under heading "2.1 Seller's Plant Description" would make it easier to generate a clear table of contents. Also, the bullets under 2.1(a) may be better served by assigning each a subheading (e.g., 2.1.1.1, 2.1.1.2 and so on), which would facilitate the organization of the Project Description. If the Proponent maintains the overall numbering system set forth in the Project Description Requirements and adds further numbered subheadings, will this be acceptable to BC Hydro?
In preparing the Project Description, Proponents are strongly advised to use the numbering system outlined in Schedule 10. Any subheadings below the prescribed outline are acceptable. For example, for information related to the Seller's Plant Description, the heading 2.1.(a) should be used. If necessary, further subheadings can be chosen by the Proponent, such as 2.1.a.1, 2.1.a.2, and so on. Proponents' cooperation in following this format will facilitate BC Hydro's evaluation of the received Proposals.

169. Regarding section 16.6 of the Specimen EPA, released on September 22, 2008, our understanding of the fundamentals behind calculating the "Gains, Economic Losses and Costs" is that the Terminating Party can recover the lost income resulting from termination of the EPA. In the case that the market situation does not allow the Terminating Party to obtain another EPA at the time of termination, will the Buyer pay to the Seller the present value of all lost income during the rest of the EPA term?
The last part of the question assumes the Seller is the Terminating Party in circumstances where the Seller is entitled to a Termination Payment from the Buyer. In that case, if the Seller can establish that the "Gains", as defined in subsection 16.6(f) of the Specimen EPA, are zero (e.g., the Energy previously contracted to BC Hydro has no value) then the Seller would be entitled to recover its "Economic Losses" as defined in subsection 16.6(f) of the Specimen EPA. See also Q&A No. 132 below. Proponents should seek their own legal advice concerning the interpretation and application of the Specimen EPA in various scenarios.

October 21, 2008

121. Scenario: A Proponent intends to propose a Project of a certain MW capacity (e.g. 100 MW) as the "base proposal".  The Proponent would also like to propose, as an option, a potential expansion (e.g., +20 MW) to the capacity of the base Project, resulting in an overall larger capacity Project (e.g., 120 MW).  The capacity expansion would require additional assets and would be in excess of the 10% increase limit set under section 4.5 of the Specimen EPA.  The expansion capacity would occupy physical space adjacent to but separate from the physical space occupied under the "base proposal".  All would fall within the same overall area covered under the Project Permits.

Given the criteria for "Multiple Proposals / Projects from a Single Proponent" in Section 15 (page 12) of the RFP and the clarification provided in Addendum 1, Item 3, which of the following is the appropriate way to submit this expansion option?

1. A Value Variation to the "base proposal" within a single Proposal submission for a Project.  The Value Variation would provide a revised Firm Energy table and would require that the final EPA designate a different Firm Energy table in Appendix 2 from that which would be provided in the Proponent's submitted Commercial Proposal (completed Schedule 9 of the RFP).

   OR

2. A separately submitted "contingent" Proposal for the expansion capacity (e.g. the 20 MW addition). 

   OR

3. A separately submitted, "mutually exclusive" Proposal for the overall expanded capacity (e.g. 120 MW) as a separate Project. 

Also, could you please confirm that under the OATT requirement for a CEAP Interconnection Request to BCTC (i) the "base capacity" and (ii) the "overall expanded capacity" resulting from the expansion option would need to be submitted as two separate Interconnection Requests? 
A "base proposal" for a 100 MW plant capacity, with an associated Firm Energy profile and Firm Energy Price, and a Value Variation offering expanded capacity of an additional 20 MW and a replacement Firm Energy profile and Firm Energy Price covering the entire 120 MW Project, is considered one Proposal.  This approach gives BC Hydro the right to accept the "base proposal" only, or the "base proposal" as modified by the Value Variation.  In either case, only one EPA is awarded.  This approach should be used if the "base proposal" capacity can stand alone, but the "base proposal", as modified by the Value Variation (i.e., larger capacity, single consolidated Firm Energy profile and single Firm Energy Price) offers the best value to BC Hydro.

A separate Proposal for the expansion capacity, designated as "contingent" on an EPA award for the "base proposal" means that BC Hydro may accept the "base proposal" only, or both the "base proposal" and the contingent expansion capacity Proposal, but as these are two separate proposals, the contingent expansion capacity Proposal must have its own separate Firm Energy profile and Firm Energy Price applicable only to the expansion capacity.  Also, if both Proposals were successful, two EPAs would be awarded - one for the "base proposal" and one for the contingent expansion capacity.  This approach should be used only if the "base proposal" capacity and the expansion capacity can each stand alone as separate projects, with separate EPAs, but the Proponent would not proceed with the expansion capacity Proposal unless the "base proposal" is accepted. 

A "base proposal" and a separate Proposal for the expansion capacity, with both designated as "mutually exclusive", means that BC Hydro may accept the "base proposal" or the expansion capacity Proposal, but not both.  A single EPA for the successful Proposal would be awarded.  This approach should be used only if the "base proposal" capacity and the expansion capacity can each stand alone as separate projects with separate EPAs, but the Proponent is able to proceed with only one, but not both, Projects.

The Proponent may file an interconnection request based on 120 MW (i.e. "base proposal" capacity plus the expansion capacity), in which case a single study will be prepared.  However, this could result in the estimated interconnection costs for the "base proposal" being overstated, thereby affecting its competitiveness in the evaluation.  This risk can be avoided by filing two interconnection requests - one for the "base proposal" capacity, and a second for 120 MW.

120. Referring to subsection 8.4 of the Specimen EPA, in a situation where obtaining EcoLogo M Certification will cause the Seller to incur additional costs (not identified in this subsection) or results in a reduction in generation, will BC Hydro pay for the additional costs or provide compensation for the reduction in generation?
If BC Hydro requires the Seller to obtain EcoLogo M Certification, BC Hydro will compensate the Seller for the additional costs associated with the certification unless the Seller is required to obtain EcoLogo M Certification in the first place in order for the energy from the project to qualify as Clean or Renewable Electricity, in which case the Seller will be responsible for the costs.

119. Subsection 16.6(a) of the Specimen EPA states that "contract quantities" will be used to determine the Terminating Party's Gains, Economic Losses and Costs. Please clarify whether "contract quantities" refer to Firm Energy only or total energy (i.e. Firm Energy and Non-Firm Energy). If "contract quantities" refer to Firm Energy only, please explain why total energy is not used, particularly if the Seller chooses Option A for the price of Non-Firm Energy.
The "contract quantities" refer to Firm Energy only, as delivery of Non-Firm Energy is uncertain and there is no penalty associated with the non-delivery of Non-Firm Energy. Selecting Non-Firm Energy Pricing Option A implies only that if Non-Firm Energy is delivered, the Seller will know the price it will receive.

118. The Specimen EPA states in subsection 14.2(b) that the Interconnection Security is to be returned to Seller, "…on the earlier of: (i) the fifth anniversary of COD;" or, "(ii) the end of any four consecutive full Seasons in which the Seller has delivered an amount of Firm Energy not less than 95% of the Annual Firm Energy Amount for that four Season period,...".

The Specimen EPA, Appendix 3, Section 3.1 states that the Cost of Interconnection Security ("CIS") will be added to the post-COD Firm Energy Price and the sum will form the basis for the Escalated Firm Energy Price for the entire term of the EPA.

Will the Escalated Firm Energy Price include an amount for the CIS for the entire term of the EPA? For greater clarity, if the Interconnection Security is returned in full at some point no later than COD + 5 years, is the CIS still included in the Escalated Firm Energy Price from that point forward?
A Proponent is expected to include the cost of obtaining Interconnection Security in its Firm Energy Price. Since the amount of the Interconnection Security will be set at the estimated cost of the Interconnection Network Upgrades provided in the Final Interconnection Study Report and this study will not be commissioned until after EPA award, BC Hydro has introduced the concept of a Cost of Interconnection Security (CIS) that the Proponent may elect to submit in its Proposal.  The CIS represents a $/MWh amount per one million dollars of the Interconnection Security Amount that would be permanently added to the offered Firm Energy Price. 

By way of example, if a Proponent submits a Firm Energy Price of $80/MWh and a CIS of $0.30/MWh per one million dollars of the Interconnection Security Amount, and the Interconnection Security Amount is $2.5 million, then the total firm energy price would be $80/MWh + $0.3/MWh * 2.5 =  $80.75/MWh for the term of the EPA.

117. How is the Cost of Interconnection Security (CIS) used, if at all, in calculating the levelized Firm Energy Price?  If it is used in the example calculations provided in "Sample Calculations – Updated Price Levelization Model" posted on September 22, 2008, the inclusion of the CIS is not obvious.
In calculating the levelized Firm Energy Price for evaluation purposes, the Firm Energy Price that will be used in the calculation will be the sum of the offered Firm Energy Price plus the product of the CIS multiplied by 150% of the estimated cost of the Interconnection Network Upgrades from the initial interconnection studies (i.e. the Feasibility Interconnection Study in the case of Transmission System-connected projects and the Preliminary Interconnection Study in the case of Distribution System-connected projects), which will be issued after Proposal submission, but before EPA award.

116. It was stated that two individual projects (same Proponent) using a single transmission line and interconnection point could be considered a single project and receive one EPA. Could that or would that be a single bid submission or would it need to be two separate submissions that were labelled co-dependent?
The Proponent should submit one proposal if the intention is to have both projects under the same EPA.  However, if the intention is to have separate EPAs for the two projects, then the Proponent should submit the projects as separate Proposals.  The two Proposals should be labelled as co-dependent, if BC Hydro may accept both, but not less than both, of these Proposals.

115. Will BC Hydro accept two-tiered pricing similar to the F2006 Call? Could two-tiered pricing be attached as an option? If BC Hydro accepts two-tiered pricing will it provide an adjusted bid price calculation?
BC Hydro will accept a two-tiered pricing structure as a Value Variation, but not as an Essential Variation. BC Hydro is not planning to post sample calculations of the adjusted bid price for specific types of Value Variations, including those involving changes to the pricing structure described in the Specimen EPA.

114. Subsection 6.2(b) of the Specimen EPA states that, "...the Seller shall make commercially reasonable efforts to operate the Seller's Plant in a manner that ensures delivery of Energy at the POI at a uniform rate within each hour during which Eligible Energy is delivered." Certain projects, especially wind projects, intending to bid seasonally Firm Energy profiles will not have the capacity to control the delivery of energy at uniform hourly rates. Will the adaptations anticipated in the Specimen EPA Adaptations Guide with respect to wind projects remove or modify this EPA requirement?
If, for example, by the nature of the energy source or commercially available, proven technology, a project is unable to deliver energy at a uniform rate within each hour, then it is not expected to meet this requirement. The Proponent has an obligation to use commercially reasonable efforts to deliver energy at a uniform rate within each hour to the extent that the energy source, such as wind or water, would allow.

113. The Specimen EPA Adaptations Guide provides guidance as to how the "...Firm Energy profiles will be merged and consolidated with the profiles of preceding phases..." with respect to the In-service Dates of the various phases. Please provide guidance as to how the Firm Energy profiles of the different phases will be "phased out".
Using the example provided in Q&A 112, the Firm Energy profile will be 100 GWh/year from January 1, 2012 to January 1, 2014. On January 1, 2014, the two Firm Energy profiles will be merged such that the Firm Energy profile going forward will be 400 GWh/year. Note that in the Commercial Proposal, Proponents are required to submit Firm Energy profiles for each phase that represent the incremental energy associated with that phase (i.e., not the cumulative energy associated with prior phases).

112. The Specimen EPA Adaptations Guide states that for a Phased Project the "...Firm Energy Prices will be blended with the Firm Energy Prices of the preceding phases, so that one Firm Energy Price will apply until the next phase achieves its "In-service Date". How will the post-COD escalation apply to determine the effective Firm Energy Price? Will (a) the Firm Energy Price of each of the different phases be escalated annually and blended to determine the effective Firm Energy Price or (b) the "blended" Firm Energy Price be escalated to determine the effective Firm Energy Price or (c) some other method?
By way of an example, assume a project has two phases. Phase 1 has an expected in-service date of January 1, 2012 and an annual Firm Energy commitment of 100 GWh/year, and phase 2 has an expected in-service date of January 1, 2014 (which is also the Guaranteed COD) and an annual Firm Energy commitment of 300 GWh/year (i.e., incremental to phase 1). Further assume that the actual in-service dates are the same as the expected in-service dates.

In this example, on January 1, 2014, the Firm Energy price of phase 1 will have attracted three years of pre-COD escalation (i.e., from January 1, 2009 to January 1, 2012) and two years of post-COD escalation and the Firm Energy Price of phase 2 will have attracted five years of pre-COD escalation. On January 1, 2014, these two prices will be blended on a 25/75 basis, and going forward the blended price will escalate at the post-COD escalation rate.

111. Can you confirm that the Losses have been embedded in the Option A and Option B Non-Firm Energy prices as listed in the sample calculations for seasonal energy payments?
Yes, it should be assumed that the loss factor described above has already been embedded in the Non-Firm prices used in the sample calculations in the Seasonal Energy Payments spreadsheet issued August 15, 2008 on the RFP Website.

110. In the Specimen EPA, under subsection 13.2(c) and section 3.3 of Appendix 3, Losses have been identified to be 6.28%. Will 6.28% be used for determining the LD Factor and the Non-Firm Energy price for all projects regardless of their location.  Will 6.28% be used for Losses to determine the adjusted Firm Energy Prices for all projects or will the Losses be project-specific? Given that the line Losses directly impact a project's forecast revenues (through the [1-L] term applied to the Non-Firm Energy price), can BC Hydro provide some direction on the Losses that will be applied on a regional basis prior to Proposal submission?
Loss factors represent the incremental losses on the BC Hydro system associated with absorbing energy from a particular generator and typically vary from project to project. However, the results from the project-specific loss studies initiated by BC Hydro with BCTC for the Clean Power Call projects will not be available until well after Proposal submission.

A concern raised by several registered Proponents is that it would be difficult to establish at the time of Proposal submission, a Firm Energy Price without knowing what the loss factor will be for the Non-Firm Energy price. To address this concern, BC Hydro decided to apply a pre-determined loss factor (i.e., 6.28%), common to all projects, in the two sections of the EPA that require the use of a loss factor, namely the LD Amount for delivery shortfalls and the pricing for the Non-Firm Energy. The 6.28% factor represents an average loss factor for the entire BCTC transmission system and does not vary by region (please refer to BCTC's OATT Schedule 10, Real Power Losses). To determine the adjusted Firm Energy Price for evaluation purposes, BC Hydro will use the project-specific losses arising from the BCTC studies.

109. In section 15 of the RFP, the Commercial Proposal requirements indicate that a Proponent must submit "The unit price adjustment to the offered Firm Energy Price that will apply to reflect the Proponent's cost of providing Interconnection Security, if required under the EPA …". How are Proponents to establish this, if they do not receive any feedback on these costs from BCTC prior to submitting Proposals to BC Hydro? In addition, how does this relate to the Interconnection and Transmission Impacts described in section 18, where it states that an adjuster will be applied to the Firm Energy Price taking into account " BC Hydro's estimate of the impact of any adjustment to the Firm Energy Price offered in the Commercial Proposal…"? Please provide further explanation of the expectations and requirements of Proponents to accommodate network upgrade and transmission impact costs in the Proposal document vs. adjusters to be added to the Firm Energy Price by BC Hydro during evaluation.
As stated in the Specimen EPA, Proponents are required to provide an Interconnection Security in the form of a letter of credit in an amount equal to the cost estimate for Interconnection Network Upgrades (INUs) to be set out in the Final Interconnection Study Report.  Given that the Final Interconnection Study Report will not be available until after EPA award, Proponents will therefore not know the cost of providing this security at the time of Proposal submission.

Item 10 of the Commercial Proposal (Schedule 9) provides Proponents the opportunity to state by how much the Firm Energy Price (item #7 of the Commercial Proposal) will be increased for every $1,000,000 of Interconnection Security provided by the Proponent after EPA award.  This $/MWh amount is called the Cost of Interconnection Security (CIS), and will vary from Proponent to Proponent. After the Final Interconnection Study Report is available, the Firm Energy Price in the EPA will be permanently increased by an amount equal to the CIS multiplied by the amount (expressed in millions of dollars) of the INU cost estimate from the Final Interconnection Study Report.

Since the Final Interconnection Study Report won't be available during the evaluation, BC Hydro will estimate the impact of the CIS on the Firm Energy price by using the information contained in the Initial Interconnection Study Report. Specifically, the adjustment to the Firm Energy Price (for evaluation purposes only) will be the CIS multiplied by 150% of the amount (expressed in millions of dollars) of the INU cost estimate from the Initial Interconnection Study Report.

In summary, Proponents should (1) factor the estimated cost of any interconnection facilities located on the Proponent's side of the POI into the Firm Energy Price at the time of Proposal submission, and (2) determine the $/MWh CIS for their project in anticipation of providing an Interconnection Security to BC Hydro after EPA award. Please refer to the RFP and the Specimen EPA for further details on matters related to interconnection.

October 8, 2008

108. There have recently been rumours that the Clean Power Call timelines may be further delayed. What is BC Hydro's commitment to keeping with the posted schedule?
BC Hydro remains committed to proceeding with the Clean Power Call as per Schedule 2 of the RFP.

107. Could you please address the following two scenarios:
A. Assume there are two projects entered into the Clean Power Call within the same area. One project is larger than the other. If the size of the large project is enough to trigger a transmission system upgrade and the smaller project does not necessitate an upgrade, how will this affect BC Hydro's relative evaluation of the two projects?
When studying projects on a stand alone basis, the cost of the transmission system upgrade will be applied to the levelized firm energy price (for evaluation purposes only) of the project that triggered the upgrade. Projects that do not trigger a transmission system upgrade would not receive such an adjustment. In situations where two or more projects are competing in the same area, in addition to the stand alone studies, BC Hydro may also decide to do cluster studies for various combinations of those projects, in which case the combined cost of the transmission system upgrades of the clustered projects would be applied to the blended firm energy price of those projects (for evaluation purposes only).
B. Assume there is a single project in a certain area. The project is sized such that it requires a transmission system upgrade. Would BC Hydro consider asking the Proponent to downsize the project in order to avoid the transmission system upgrade and the associated costs?
BC Hydro reserves the right to have post-Proposal submission discussions with any of the Proponents, and such discussions may include ways to minimize system upgrade costs. Note that due to the expected high volume of submissions and the limited time available for discussions, BC Hydro will be selective with respect to which Proponents, if any, it holds discussions with.

106. The eligibility requirement noted in Addendum 1 of the RFP states that the technical parameters of a project must be consistent with parameters forming the basis of the BCTC interconnection study. Ostensibly, material inconsistencies would result in the ineligibility of the project for the Clean Power Call.
Please further define 'material inconsistency'.

• For example, if a Proponent submits a project for an interconnection study on October 17, but the project is ultimately downsized for the bid Proposal on November 25, would this change be a material inconsistency?
• Similarly, if a Proponent submits a project Proposal with multiple facilities (a single POI) for an interconnection study on October 17, but the project is then downsized to include a reduced number of facilities for the bid Proposal on November 25, would this change be a material inconsistency?

In such situations, would the Proponent have the opportunity to discuss and explain any inconsistencies to BC Hydro before being deemed ineligible for the Clean Power Call?
Changes may be made to an interconnection study request (to be submitted October 7 and October 17, 2008 for Distribution and Transmission system-connected projects respectively) prior to filing the interconnection study agreement (to be filed November 7 and November 17, 2008 for Distribution and Transmission system-connected projects respectively). Any material changes to a project subsequent to filing the interconnection study agreement will result in a loss of the queue position and/or a study that is no longer materially consistent with the project.

In general, following the filing of an interconnection study agreement, a decrease in the project size or the number of facilities that results in the same, or a decrease to, the injected power to the system would not be considered a material change; however there is a risk that the interconnection costs may be overstated.

The Clean Power Call RFP provides the opportunity for BC Hydro to follow up with Proponents to seek clarification regarding their Proposal submissions; however this is not a requirement.

105. If there are benefits realizable under OATT would these be negotiated with BC Hydro or with BCTC as part of the interconnection process?
Given that BC Hydro is responsible for interconnection costs on the BC Hydro side of the POI, it follows that any system benefits (e.g., capital deferral or improved reliability) resulting from the interconnection would flow to BC Hydro. If such benefits can be identified during the evaluation phase, BC Hydro may choose to consider them in the selection process.

104. Will BC Hydro accept double-sided printing in Proposals?
BC Hydro encourages Proponents to submit their Proposals with double-sided printing.

103. In which of the following two ways will BC Hydro account for the Proponent's Direct Assignment (DA) costs as estimated by BCTC in the Feasibility Interconnection Study and provided to BC Hydro on February 23, 2009:

1. BC Hydro will add the DA costs to the firm energy price bid by the Proponent on November 25, 2008 in the price levelization process.
2. BC Hydro will NOT add the DA costs to the energy price bid by the proponent on November 25, 2008, because Proponents are expected to estimate the DA costs and incorporate them into the energy price bid by the Proponent on November 25.

The concept of Direct Assignment costs used in the F2006 Call for Tenders is no longer used by BCTC. Instead, for the Clean Power Call and subsequent calls, BCTC is using the OATT concept of Transmission Provider Interconnection Facilities (TPIF) and Network Upgrades (cost allocation based on location of POI). Specifically, TPIF are those interconnection facilities owned by BCTC that are located on the Proponent side of the POI. TPIF are identified in the system impact study report and/or the facilities study report, both of which are normally completed after EPA award. The identification of the TPIF is beyond the scope of the initial interconnection study.

Current BC Hydro policy on the cost allocation of interconnection costs is that Proponents are responsible for the cost of the TPIF and BC Hydro is responsible for the cost of the Network Upgrades. Proponents should therefore consider the need to incorporate a cost estimate for the TPIF into the firm energy price. Note that TPIF are typically limited to a single span of transmission line entering the substation from the substation boundary; however there may be project-specific situations that deviate from the typical requirements for TPIF.

102. Secton B of the Energy Source Data Requirements (Schedule 11) states that for a wind project, a Proponent must provide at least one year of raw hourly or 10 minute on-site historical data that has been used for the wind resource assessment of the site. However, several Q&A's, for instance Q&As No. 32 and 86, state that less than one year of on-site historical data is acceptable. Furthermore, Q&A No. 86 states that for wind projects with less than one year of on-site historical data, "the energy source data and the corresponding Firm Energy profile will be evaluated and the project may be assessed as having a higher delivery risk given that a limited amount of data is available for the evaluation." Please clarify the wind data requirement: will wind projects with less than one year of on-site historical data be eligible for an award under the Clean Power Call? Please explain how a "higher delivery risk" will be assessed in the context of a Proposal? What weighting is given to delivery risk? How does a higher delivery risk affect the overall scoring/assessment of a Proposal?
The minimum of one year of on-site historical data is not a Clean Power Call eligibility requirement. As such a Proponent not providing the requested one year of on-site data will not be disqualified.

However, as noted in Q&A No. 86, a project Proposal containing less than one year of data may be assessed as having a higher delivery risk as part of the overall assessment of the project. The impact will be commensurate with the risk identified upon consideration of factors such as the extent to which the source data clearly supports the proposed firm energy profile, the demonstrated ability to deliver energy under the terms of the EPA, the quality of the data set, and the uncertainty associated with making an assessment based on a limited data set. As per the RFP, the assessment of energy source data is one of numerous factors considered in the evaluation of Proposals and award of EPAs.

101. Section B of the Energy Source Data Requirements (Schedule 11) states that "on-site historical data" is required. Can the on-site data be measured from any source or combination of sources (SODAR, LIDAR, or re-analysis data), or must the on-site data be measured by a MET tower?
On-site data is considered to be any observational data obtained for the project location. This includes monitoring towers, SODAR and LIDAR. Re-analysis data is not considered to be observational on-site data.

100. Given the Specimen EPA includes a provision for the "reset" of the firm energy profile on 5-year intervals to ensure the delivery of committed energy amounts is met 80% of the time, can a Proponent bid an initial profile that may not meet this 80% level? Secondly, would bidding such a profle be deemed a "risk" in the risk assessment process?
A Proponent is encouraged to offer an initial firm energy delivery profile that meets the 80% delivery confidence level in its Proposal submission. If a Proponent proposes firm energy quantities that deviate from those expected, then this would be reflected in BC Hydro's risk assessment and may impact the likelihood of an EPA award. In addition, if an EPA is awarded and the firm energy commitment is not met by the Proponent, liquidated damages are payable.

99. If a Proponent with a project in the BC Hdyro service area changes its project specifications in a material respect after filing an interconnection study agreement, what impact will that have on a Proposal submitted for the project?
The Proposal will not be considered and will be disqualified. As per the Clean Power Call RFP documents:

• section 10 requires that all projects participating in the Clean Power Call be studied using the same base case (i.e. having the same queue position) and a common Base Case Date for the purposes of the interconnection study;
• Addendum 1 states that all technical parameters of a project as described in a Proposal must be consistent in all material respects with the parameters of the corresponding interconnection study.

Therefore, while changes may be made to an interconnection study request prior to signing an interconnection study agreement by November 7, 2008 and November 17, 2008 for Distribution and Transmission system-connected projects respectively, any material changes to the project subsequent to these dates will result in a loss of the queue position and/or a study that is no longer materially consistent with the Project.

98. What is the process for obtaining approval of a project phasing plan? Is the approval binding on BC Hydro through Proposal evaluation? Can an approved phasing plan be changed after approval?
Pre-approval by BC Hydro of a project phasing plan is not mandatory. However, a Proponent may obtain greater certainty that its proposed project phasing plan is consistent with the constraints on phasing set out in the RFP and in the Specimen EPA by seeking an approval of the plan by BC Hydro before Proposal submission. Proponents seeking such approval were to submit a written request to BC Hydro not later than September 30, 2008.

The request should have included all available details of the phased in-service plan, including the information noted in section 5.1 of the RFP, as amended by Addendum 3 (section 1, last paragraph). BC Hydro will review the submission and may seek further information or clarification before advising whether its approval is granted or withheld. BC Hydro will honour the approval in Proposal evaluation, provided that the Proposal does not disclose material inconsistencies with, or omissions in, the information on which the approval was based. A plan, once approved can be changed, but if the change is material the Proponent cannot rely on the approval.

97. I am planning to submit a Proposal under the Standing Offer Program. I am in the "first", or "a" position, regarding water license rights. Can a developer in the second place, or "b" position, enter the project into the Clean Power Call and be awarded an EPA or an interconnection agreement?
Under the Clean Power Call, any Proposal from a registered Proponent that meets the eligibility criteria stated under section 12 of the RFP will be considered. As such, the status of a water license application does not preclude the submission and consideration of a Proposal. However, as part of the Clean Power Call evaluation process, a risk assessment is conducted, which includes consideration of any obstacles to granting the required permits and licenses, including a water license and other competing applications. The Water Branch should be contacted directly for further information on how mutually exclusive water license applications are processed by the Branch. Please note, under the Standing Offer Program, a proponent must have a water license prior to being granted an EPA.

96. On the Sample Calculations – Price Levelization Model, the super-peak and peak hours are calculated for non-Sundays, and therefore include statutory holidays, whereas the EPA Term Sheet defines peak and super-peak hours as the listed hours, except for Sundays and holidays. Please confirm that off-peak hours include all Sundays and statutory holidays and please provide a list of the statutory holidays that are off-peak days.
As per page 4 of the EPA Term Sheet, for payment purposes off-peak hours are defined as all Sundays, BC statutory holidays, and the hours 00:00 to 06:00 and 22:00 to 24:00 Pacific prevailing time, Monday through Saturday, inclusive. The BC statutory holidays are as follows:

New Year's Day
Good Friday
Victoria Day
Canada Day
B.C. Day
Labour Day
Thanksgiving Day
Remembrance Day
Christmas Day

95. Is any notification to BC Hydro necessary if the project does not meet any of the pre-Proposal items as outlined in Addendum 3?
The RFP has identified several types of projects for which approvals or determinations should be obtained from BC Hydro prior to Proposal submission. If a Proponent's project does not fit into any of the project types identified in Addendum 3, then it is not necessary for the Proponent to make a pre-Proposal submission.

94. Will bidders be permitted to modify their bid price (after the November 25, 2008 Proposal submission date) once the results from their transmission interconnection requests are provided? If not, how does BC Hydro expect bidders to incorporate interconnection costs (including any network upgrade cost contributions) into their bid prices?
As stated in the EPA Term Sheet - Interconnection Costs, BC Hydro is responsible for the interconnection costs on the BC Hydro side of the POI. Accordingly, these costs do not need to be incorporated into the firm energy price, however, as stated in the EPA Term Sheet – Interconnection Security, Proponents are required to provide security, in the form of a letter of credit, to BC Hydro in the amount of the estimated network upgrade costs as set out in the interconnection facilities study to be completed after EPA award. To address the issue of establishing the firm energy price prior to knowing the amount of interconnection security to be provided, Proponents will be able to specify in their Proposal (see Schedule 9 - Commercial Proposal, Item 10) the amount by which their firm energy price will be permanently increased for every $1,000,000 of interconnection security provided to BC Hydro.

93. Will BC Hydro consider a Proposal for a project consisting of multiple, geographically diverse generating and other facilities that share a common POI, or must all generating and other facilities be located on the same or contiguous sites?
BC Hydro will consider the Proposal and treat the facilities as a single project, provided that there is a common POI that can accommodate connection of all facilities. Proponents should note that the project, if the Proposal is successful, will be contracted under a single EPA, with a single firm energy price and firm energy profile.

92. Will BC Hydro consider the interconnection of wind power facilities via existing POIs, for example, existing BC Hydro substations or private substations? If so, how is this reflected / assessed in the BCTC and CEAP process?
BC Hydro will consider the interconnection of generators to existing POIs and/or existing BC Hydro or BCTC facilities. This will be assessed by BCTC as part of the CEAP process. The interconnection of a generator to private substations, or to a third party line (which could be either a tap, new three-breaker switching station, or existing customer station) is an indirect connection. Any connections to non-BCTC/BC Hydro assets must have the asset owner (or authorized agent) make the interconnection request. This case will also be assessed by BCTC as part of the CEAP process.

91. Due to the current uncertainty in future raw materials pricing, equipment suppliers and contractors will apply individual commodity price indices to the pre-construction cost estimates between 2008 and start of construction, instead of BC CPI. Will this be considered by BCHydro as an "Essential Variation"? If not, please advise how proponents should address.
As noted in Addendum 4 of the RFP and Q&A No. 38, BC Hydro will not consider and may disqualify Proposals containing Essential Variations to the Specimen EPA that depart from the pricing structure, including the Consumer Price Index for British Columbia, All Items (Not Seasonally Adjusted), as published by Statistics Canada. However, variations to the pricing structure may be submitted and may be considered as Value Variations, provided that a priced and completed "base Proposal", excluding such variations is also submitted.

September 16, 2008

90. If we already have a BCTC feasibility interconnection study for our project that we obtained as part of the F2006 Call, do we need to submit a new feasibility interconnection study request to BCTC for this Call? Is the feasibility study obtained in 2006 still valid?
As per section 10 of the RFP, prior studies will not be accepted, unless in the case of projects located in the Fortis Service Area, the study has been validated in writing by FortisBC as of the Base Case Date. All proposed projects must be studied on the basis of the same base case and a common Base Case Date.

89. In regards to the posted Sample Calculations – Price Levelization Model worksheet, could you explain why the PV calculation table only goes out to December 2040 (rows 66 to 449)? For example, if a project contracts for a 40-year EPA with a COD of December 2012, the PV calculation should extend beyond 2040 (to 2052), thus lowering the levelized price.
The current spreadsheet posted on the Clean Power Call website can only calculate the levelized price for a contract term ending on or before December 2040. BC Hydro will shortly post a new spreadsheet to the Clean Power Call website that will allow users to calculate the levelized price for a contract term ending on or before December 2060.

88. Can you please help us interpret the posted Sample Calculations financial worksheets?

a) For hourly (rather than seasonal) projects, are LDs for delivery shortfalls and non-firm energy payments for excess power deliveries based on an hourly true-up, or a monthly true-up?
LDs for delivery shortfalls and non-firm energy payments for hourly projects are calculated on an hourly basis.

b) In the Sample Calculations – Seasonal Energy Payments spreadsheet, for seasonal projects each month's firm energy seems to be limited to 1/3 of the total firm energy for the quarter. Is this just during freshet, or during all parts of the year?
For the purpose of determining interim monthly payments, the total firm energy for each month in a particular season is assumed to be 1/3 of the seasonal firm energy amount for that season. This assumption is applied to all four seasons and not just the freshet season. The actual allocation of firm and non-firm energy for seasonal projects is done at the end of each season and it is on this basis that the seasonal payment is calculated. Payment for the last month of each season is the calculated seasonal payment less the two interim monthly payments.

c) All renewable projects will ramp up or ramp down their generation over a number of months during the year due to seasonal weather changes. Limiting firm generation during each month to 1/3 of the total quarter limit means that while ramping up, early months will owe LDs and later months will have non-firm energy. The opposite will happen when ramping down. The issue is that LDs will be owed even though the sum of generation during those three months may be exactly equal to the firm energy requirement for the season. This seems to be double jeopardy and does not recognize the nature of non-thermal, non-storage renewable energy projects. Was this BC Hydro's intention?
LDs for delivery shortfalls for seasonal projects are calculated at the end of each season and not on a monthly basis.

d) Will there be a training session on how to interpret and model the tariff for hourly and seasonal projects?
Yes, sample calculations will be reviewed during the Proponents' RFP Information Session scheduled for October 23, 2008. Further information about this information session will be posted to the Clean Power Call website later in September.

87. With the requirement that Environmen