Re: Amendment To Connection And Site Agreement

Transcription

20121114-5147 FERC PDF (Unofficial) 11/14/2012 4:42:25 PMLegal Department411 Seventh Avenue, 16-1Pittsburgh, PA 15219Tel 412-393-6505Fax 412-393-5897kkubiak@duqlight.comKrysia M. KubiakAssistant General CounselNovember 14, 2012VIA EFILINGKimberly D. BoseSecretaryFederal Energy Regulatory Commission888 First Street, N.E.Washington, D.C. 20426Re:Amendment to Connection and Site AgreementDuquesne Light Company, Docket No. ER13- -000Dear Secretary Bose:Pursuant to Section 205 of the Federal Power Act (“FPA”),1 and Part 35 of theregulations of the Federal Energy Regulatory Commission (the “Commission”),2 Duquesne LightCompany (“Duquesne”) hereby submits for filing an amendment (the “Amendment”) to anexisting Connection and Site Agreement (the “Elrama Connection Agreement”), by and betweenDuquesne and GenOn Power Midwest, L.P. (“GenOn Midwest”), as successor in interest toOrion Power Holdings, Inc. (“Orion”), relating to the Elrama Generating Units.Duquesne respectfully requests that the Commission accept the Amendment for filingand requests any necessary waivers of the Commission’s regulations to permit an effective dateof January 13, 2013.116 U.S.C. § 824d (2006).218 C.F.R. Pt. 35; § 35.13 (2012).

20121114-5147 FERC PDF (Unofficial) 11/14/2012 4:42:25 PMKimberly D. BoseNovember 14, 2012Page 2I.COMMUNICATIONSAll communications and service related to this filing should be directed to the followingindividual:Krysia KubiakAssistant General CounselDuquesne Light Company411 Seventh Avenue, 16-1Pittsburgh, PA 15219(412) 393-6505 – Telephone(412) 393-5897 – FacsimileII.DOCUMENTS SUBMITTEDThis filing consists of the following:III.1.Transmittal Letter;2.Elrama Connection Agreement - Duquesne Light Company, RateSchedule FERC No. 35 (Attachment A);3 and3.Amendment to Elrama Connection Agreement (Attachment B).DESCRIPTION OF ELRAMA CONNECTION AGREEMENTDuquesne and Orion entered into the Elrama Connection Agreement on September 24,1999 in connection with Orion’s acquisition of the Elrama Generating Station from Duquesne.The Elrama Generating Station is an approximately 460 MW coal-fired generating facility,consisting of the Elrama Generating Units and associated facilities and equipment, located inElrama, Pennsylvania. The Elrama Connection Agreement was filed as part of an application forvarious authorizations pursuant to Sections 203 and 205 of the FPA4 relating to that transaction.5By letter order issued April 17, 2000, the Commission accepted the Elrama Connection3The Elrama Connection Agreement was previously accepted by the Commission, and is includedin this filing to provide a “parent” record for the Amendment in the etariff system, and to facilitate reviewof the Amendment.4516 U.S.C. §§ 824b, 824d (2006).See Application for Required Approvals Under Sections 203 and 205 of the Federal Power Actfor Sale of Facilities and Matters Related to Divestiture Transaction, Docket Nos. EC00-54-000, et al.(filed Feb. 2, 2000).

20121114-5147 FERC PDF (Unofficial) 11/14/2012 4:42:25 PMKimberly D. BoseNovember 14, 2012Page 3Agreement to be effective upon consummation of the transaction.6 The transaction wasconsummated, and the Elrama Connection Agreement took effect, on April 28, 2000.7On February 29, 2012, GenOn Midwest provided notice to PJM Interconnection, L.L.C.(“PJM”) of its intent to deactivate the Elrama Generating Units. The units had becomeuneconomic due to market conditions and would require significant capital expenditures by 2015and beyond to comply with existing and anticipated environmental regulations.8 On that sameday, GenOn Midwest provided notice to Duquesne of the permanent retirement of Units 1-4 onMarch 1, 2014.On November 6, 2012, Duquesne and GenOn Midwest entered into the Amendment inorder to address transitional issues surrounding the deactivation of the Elrama Generating Unitsand the termination of the Elrama Connection Agreement. Under the Amendment, GenOnMidwest agrees to pay 3 million to Duquesne and, possibly, to provide a parcel of land for thereconstruction of certain Duquesne equipment currently located at GenOn Midwest’s Elramasite. In addition, Duquesne and GenOn Midwest agree that the Elrama Connection Agreementwill terminate on February 28, 2014, unless Duquesne elects to delay termination for up to 10months. The Amendment further provides that GenOn Midwest shall be entitled to paymentfrom Duquesne of 166,000 per month if and to the extent GenOn provides specified servicesunder the Elrama Connection Agreement on or after March 1, 2014.IV.6OTHER FILING REQUIREMENTS AND REQUEST FOR WAIVERS1.18 C.F.R. § 35.13(b)(1) – A list of documents submitted with this filing isincluded herein at Section II.2.18 C.F.R. § 35.13(b)(2) – The date on which Duquesne proposes to make theAmendment effective is January 13, 2013 (i.e., 60 days after filing).9Duquesne Light Co., Docket No. ER00-1490-000 (Apr. 17, 2000) (unreported).7See Letter from Mary Margaret Farren to David P. Boergers, Docket No. EC00-54-000 (filedMay 9, 2000).8PJM subsequently determined that Elrama Generating Unit 4 would be required throughSeptember 2012 to maintain reliability pending completion of transmission reinforcements, and GenOnMidwest and PJM negotiated a reliability must-run agreement setting forth the terms and conditions underwhich PJM may dispatch, and GenOn Midwest will operate, the unit for reliability purposes (as well asanother unit at the Niles Generating Station also found to be needed for reliability) during that timeperiod. See GenOn Power Midwest, LP, 140 FERC ¶ 61,080 (2012) (accepting and suspending proposedagreement filing and establishing hearing and settlement procedures).9The Elrama Connection Agreement has an effective date of April 28, 2000. See Duquesne LightCo., Docket No. ER00-1490-000 (Apr. 17, 2000) (unreported letter order accepting Elrama ConnectionAgreement as of the closing date of the divestiture); Duquesne Light Company and Orion Power

20121114-5147 FERC PDF (Unofficial) 11/14/2012 4:42:25 PMKimberly D. BoseNovember 14, 2012Page 43.18 C.F.R. § 35.13(b)(3) – A copy of this filing has been sent to GenOn Midwest.4.18 C.F.R. § 35.13(b)(4) – A brief description of the rate change is provided inSection III.5.18 C.F.R. § 35.13(b)(5) – A statement of the reasons for the rate change isprovided in Section III.6.18 C.F.R. § 35.13(b)(6) – Duquesne hereby represents that no additionalagreement, by contract or otherwise, is required for the filing of this rate.7.18 C.F.R. § 35.13(b)(7) – Duquesne hereby represents that there are no expensesor costs included in this filing that have been alleged or judged in anyadministrative or judicial proceeding to be illegal, duplicative, or unnecessarycosts that are demonstrably the product of discriminatory employment practices.8.18 C.F.R. § 35.13(c)(2) – No specifically assignable facilities have been or will beinstalled in connection with the proposed rate schedule.Duquesne respectfully requests that the Commission grant waiver of the remainingPart 35 requirements, which are not applicable to this filing, and grant any other necessarywaivers to permit the Rate Schedule to become effective as requested.V.CONCLUSIONWHEREFORE, for the foregoing reasons, Duquesne respectfully requests that theCommission accept the Amendment to become effective on January 13, 2013, and grant thewaivers requested herein.Respectfully submitted,/s/Krysia KubiakCounsel for Duquesne Light CompanyAttachmentsMidwest, LLC, Docket No. EC00-54-000 (filed May 9, 2000) (notifying the Commission that the transferof jurisdictional facilities occurred on April 28, 2000). Because the eTariff system will not permit aneffective date prior to Duquesne’s baseline effective date, the metadata in the attached eTariff record forthe Elrama Connection Agreement specifies an effective date of January 13, 2013 (the effective daterequested for the Amendment). Thus, the effective date for the “paper period” of the agreement is April28, 2000, and the effective date for the “electronic period” of the agreement will be January 13, 2013.

20121114-5147 FERC PDF (Unofficial) 11/14/2012 4:42:25 PMCONFORMED COPYELRAMAGENERATING UNITSConnection and Site Agreementby and betweenDuquesne Light Companyas Transmission ProviderandOrion Power Holdings, Inc.as Generating CompanyDated as of September 24, 1999

20121114-5147 FERC PDF (Unofficial) 11/14/2012 4:42:25 PMTABLE OF CONTENTSPageARTICLE 1DEFINITIONS.1ARTICLE 2CONNECTION SERVICE.5ARTICLE 3OPERATION AND MAINTENANCE.7ARTICLE 4SERVICES.11ARTICLE 5METERING.12ARTICLE 6RELAYING .14ARTICLE 7NEW CONSTRUCTION AND MODIFICATIONS .16ARTICLE 8ACCESS TO FACILITIES.17ARTICLE 9NOTIFICATIONS AND REPORTING .18ARTICLE 10SAFETY .20ARTICLE 11ENVIRONMENTAL COMPLIANCE AND PROCEDURES .20ARTICLE 12BILLINGS AND PAYMENT .20ARTICLE 13APPLICABLE REGULATIONS AND INTERPRETATION.22ARTICLE 14REPRESENTATIONS .22ARTICLE 15FORCE MAJEURE .24ARTICLE 16LIABILITY.25i

20121114-5147 FERC PDF (Unofficial) 11/14/2012 4:42:25 PMARTICLE 17INDEMNIFICATION.26ARTICLE 18INSURANCE.27ARTICLE 19SEVERAL OBLIGATIONS.28ARTICLE 20CONFIDENTIALITY.28ARTICLE 21REMEDIES.30ARTICLE 22TERM .30ARTICLE 23ASSIGNMENT/CHANGE IN CORPORATE IDENTITY .31ARTICLE 24SUBCONTRACTORS .33ARTICLE 25DISPUTE RESOLUTION .34ARTICLE 26ADDITIONAL COST RESPONSIBILITIES .35ARTICLE 27MISCELLANEOUS PROVISIONS.35ii

20121114-5147 FERC PDF (Unofficial) 11/14/2012 4:42:25 PMCONNECTION AND SITE AGREEMENTThis Connection and Site Agreement (this "Agreement") is entered into as of the24th day of September, 1999, by and between Duquesne Light Company, a Pennsylvaniacorporation (hereinafter the "Transmission Provider"), having a place of business at 411 SeventhAvenue, Pittsburgh, Pennsylvania 15219 and Orion Power Holdings, Inc. ("GeneratingCompany"), a Delaware corporation, having a place of business at 7 East Redwood Street, 10thFloor, Baltimore, MD 21202 Transmission Provider and Generating Company are individuallyreferred to herein as a "Party" and collectively as the "Parties."WHEREAS, Duquesne Light Company and Generating Company have enteredinto an Asset Purchase Agreement ("APA"), dated as of September 24, 1999 for the sale of theFacility, as hereinafter defined; andWHEREAS, Transmission Provider and its Affiliates continue to operate theirtransmission and distribution businesses from their present locations; andWHEREAS, in the APA, Duquesne Light Company has agreed to transfer toGenerating Company certain designated real and personal properties, contracts and licensespertaining to the Facilities; andWHEREAS, the Facilities currently are connected to Transmission Provider'sTransmission System, and Generating Company will continue to connect the Units toTransmission Provider's Transmission System on the terms set forth herein; andWHEREAS, Transmission Provider needs access to parts of GeneratingCompany's assets, and Generating Company needs access to parts of Transmission Provider'sassets; andWHEREAS, Generating Company is willing to operate the Facilities inaccordance with Good Utility Practice in order to assist Transmission Provider in meeting itsown system reliability standards; andWHEREAS, the Parties have agreed to execute this mutually acceptableConnection and Site Agreement in order to provide Connection Service to Generating Companyand to define the continuing rights, responsibilities and obligations of the Parties with respect tothe use of certain of their own and the other Party's property, assets and facilities.NOW, THEREFORE, in order to carry out the transactions contemplated by theAPA and this Agreement, and in consideration of their respective commitments set forth herein,and intending to be legally bound hereby, the Parties covenant and agree as follows:ARTICLE 11.DefinitionsWherever used in this Agreement with initial capitalization, the following terms shallhave the meanings specified or referred to in this Article 1.1

20121114-5147 FERC PDF (Unofficial) 11/14/2012 4:42:25 PM1.1Affiliate shall have the meaning set forth in Rule 12b-2 of the General Rules andRegulations under the Securities Exchange Act of 1934, as amended.1.2Auction Closing Date means the date on which the Auction Closing, as that termis defined in the APA and applies to the Facility, actually occurs.1.3Confidential Information shall have the meaning set forth in Section 20.1 hereof.1.4Connection Equipment is all the equipment necessary for the connection of theFacilities to Transmission Provider's Transmission System, which is identified inExhibit 1 hereto.1.5Connection Point shall mean the point at which the Facilities are connected to theTransmission Provider's Transmission System, as set forth in Exhibit 1 hereto.More than one Connection Point may be referred to in this Agreement collectivelyas the "Connection Points."1.6Connection Service shall mean the services provided by Transmission Provider toconnect the Units with Transmission Provider's Transmission System.Connection Service shall not mean any of the services listed in Section 2.3(a)through (c).1.7Defaulting Party shall have the meaning set forth in Section 21.2 hereof.1.8Delinquent Party shall have the meaning set forth in Section 21.1 hereof.1.9Disclosing Party shall have the meaning set forth in Section 20.1 hereof.1.10Dispute shall have the meaning set forth in Section 25.1 hereof.1.11Due Diligence shall mean the exercise of good faith efforts to perform a requiredact on a timely basis and in accordance with Good Utility Practice using thenecessary technical and manpower resources.1.12Easements shall have the meaning set forth in Section 8.2 hereof.1.13Easement, License and Attachment Agreement shall refer to the Easement,License and Attachment Agreement between Generating Company andTransmission Provider related to the Units.1.14ECAR shall mean the East Central Area Reliability Council, a regional reliabilitycouncil established pursuant to the East Central Area Reliability CoordinationAgreement, or its successor.1.15Emergency Condition means an imminent or occurring condition on theTransmission System, or on the system of a neighboring utility, or in the Facilitiesowned by Generating Company, that is likely to result in significant disruption of2

20121114-5147 FERC PDF (Unofficial) 11/14/2012 4:42:25 PMservice or damage to any of the foregoing, or is likely to endanger life, property,or the environment.1.16Facility or Facilities shall mean the Elrama Units and equipment related tooperating the Units and the Connection Equipment.1.17FERC shall mean the Federal Energy Regulatory Commission or its successorfederal agency.1.18Forced Outage means, in the case of the Facility, an immediate reduction inoutput or capacity or removal from service of the Facility, in whole or in part, byreason of an Emergency Condition or threatened Emergency Condition,unanticipated failure or other cause beyond the control of Generating Company,when such reduction in output or capacity or removal from service was notscheduled in accordance with Section 3.12. In the case of the TransmissionSystem, Forced Outage means the immediate removal from service of theTransmission System, in whole or in part, by reason of an Emergency Conditionor threatened Emergency Condition, unanticipated failure or other cause beyondthe control of Transmission Provider.1.19Force Majeure shall have the meaning set forth in Article 15 hereof.1.20Generating Company shall mean Orion Power Holdings, Inc.1.21Good Utility Practice shall mean any of the applicable practices, methods,standards, guides or acts:1.22(a)required by any Governmental Authority, regional or national reliabilitycouncil, or national trade organization, including NERC, ECAR, EdisonElectric Institute, or American Society of Mechanical Engineers, or thesuccessor of any of them, whether or not the Party whose conduct is atissue is a member thereof; or(b)otherwise engaged in or approved by a significant portion of the electricutility industry during the relevant time period which in the exercise ofreasonable judgment in light of the facts known or that should have beenknown at the time a decision was made, could have been expected toaccomplish the desired result in a manner consistent with law, regulation,good business practices, generation, transmission, and distributionreliability, safety, environmental protection, economy, and expediency.Good Utility Practice is intended to be acceptable practices, methods, oracts generally accepted in the region, and is not intended to be limited tothe optimum practices, methods, or acts to the exclusion of all others.Governmental Authority means any foreign, federal, state, local or othergovernmental, regulatory or administrative agency, court, commission,department, board, or other governmental subdivision, legislature, rulemakingboard, tribunal, arbitrating body, or other governmental authority.3

20121114-5147 FERC PDF (Unofficial) 11/14/2012 4:42:25 PM1.23Interest Rate shall mean the interest rate calculated in accordance with themethodology specified for interest on refunds in the FERC regulations at 18C.F.R. § 35.19a(a)(2)(iii).1.24Joint Use Facilities shall mean equipment, identified as Joint Use Facilities inExhibit E to the Easement, License and Attachment Agreement, as may beamended from time to time, which are owned by either Generating Company orTransmission Provider and which are primarily used for generation operations butare also essential to the operational reliability of the Transmission System and are,therefore, jointly operated by the Generating Company and TransmissionProvider.1.25Knowledge means the actual knowledge of the corporate officers or Plantmanagers of the specified Person charged with responsibility for the particularfunction as of the date of this Agreement, or, with respect to any certificatedelivered pursuant to this Agreement, the date of delivery of the certificate.1.26NERC shall mean the North American Electric Reliability Council or itssuccessor.1.27Non-Defaulting Party shall have the meaning set forth in Section 21.2 hereof.1.28Non-Delinquent Party shall have the meaning set forth in Section 21.1 hereof.1.29Open Access Transmission Tariff or OATT shall mean the open accesstransmission tariff of the Transmission Provider on file with the FERC.1.30Out of Service shall mean the condition of a Unit when it is electricallydisconnected from the Transmission Provider's Transmission System.1.31Party shall mean either Transmission Provider or Generating Company, whereappropriate, when individually referred to herein.1.32Parties shall mean the Transmission Provider and Generating Company, whencollectively referred to herein.1.33Payment Balance shall have the meaning set forth in Section 2.4(c).1.34Person means any individual, partnership, limited liability company, joint venture,corporation, trust, unincorporated organization, or governmental entity or anydepartment or agency thereof.1.35Planned Outage shall mean action by (i) Generating Company to take the Facilityor any Unit thereof Out of Service, partially or completely, to perform work onspecific components that is scheduled in advance and has a predetermined startdate and duration pursuant to the procedures set forth in Section 3.12, or(ii) Transmission Provider to take its equipment, facilities and systems Out ofService, partially or completely, to perform work on specific components that is4

20121114-5147 FERC PDF (Unofficial) 11/14/2012 4:42:25 PMscheduled in advance and has a predetermined start date and duration pursuant tothe procedures set forth in Section 3.12.1.36Qualified Personnel shall mean individuals trained for their positions pursuant toGood Utility Practice.1.37Receiving Party shall have the meaning set forth in Section 20.1 hereof.1.38Representatives shall mean, as to any person, such person's Affiliates and its andtheir directors, officers, employees, agents and advisors (including, withoutlimitation, financial advisors, legal counsel and accountants). As used in thisdefinition, the term "person" shall be broadly interpreted to include, withoutlimitation, any corporation, company, partnership, other entity or individual.1.39RTUs shall have the meaning set forth in Section 3.9 hereof.1.40Services shall mean those services provided by Generating Company toTransmission Provider, as specified in Article 4.1.41System Control shall mean Transmission Provider's system control center, whichis responsible for the dispatch and operation of Transmission Provider'sTransmission System, including the direction and orders for switching andtagging Transmission Provider facilities.1.42Term shall have the meaning set forth in Section 22.1 hereof.1.43Transmission Provider shall mean Duquesne Light Company.1.44Transmission System shall mean all facilities of Transmission Provider that areclassified as part of the transmission function in the Transmission Provider'sOATT or its successor. The Transmission System does not include distributionfacilities of Duquesne Light Company.1.45Unit shall mean any of the following individual units or equipment: ElramaUnit 1, Elrama Unit 2, Elrama Unit 3, and Elrama Unit 4. Collectively, the unitswill be referred to herein as the "Units."ARTICLE 2Connection Service2.1Subject to the terms and conditions of this Agreement, Transmission Provideragrees to allow Generating Company to continue the connection of the Units toTransmission Provider's Transmission System at the locations identified inExhibit 1, upon Generating Company's acquisition of the Facility, and thereafterfor the Term of this Agreement.2.2The Connection Points for the Units are the disconnect switches described andshown on Exhibit 1 hereto. The voltage at these Connection Points shall be in the5

20121114-5147 FERC PDF (Unofficial) 11/14/2012 4:42:25 PMform of three phase, approximately sixty hertz alternating current at the nominalvoltage of the equipment at the Connection Point.2.3Generating Company shall be responsible for (a) making arrangements under theOATT for transmission and any ancillary services associated with the delivery ofcapacity and/or energy produced by the Units, which services shall not beprovided under this Agreement, (b) obtaining capacity and/or energy to satisfy itsstation service, or other requirements, and (c) making arrangements underapplicable tariffs for transmission services, losses, and ancillary servicesassociated with the use of the Transmission Provider's Transmission System forthe delivery of capacity and energy to the Units for the purpose of supplyingstation service or for any other use by Generating Company. TransmissionProvider shall reasonably cooperate with Generating Company with respect tosuch agreements.2.4(a)Generating Company shall comply with the provisions of the OATTregarding notification to Transmission Provider of Generating Company'sexpected schedule into Transmission Provider's control area. Suchnotification shall include such information as is reasonably required byTransmission Provider and shall occur by no later than 10:00 a.m. of theday prior to the day Generating Company expects to schedule energy intoTransmission Provider's control area.(b)If Generating Company delivers an amount of energy that is less than itsscheduled amount, as such scheduled amount may be modified from timeto time in accordance with the OATT, without being directed to do so byTransmission Provider, Generating Company shall pay TransmissionProvider's out of pocket costs for such amount, measured in dollars permegawatt-hour, associated with providing the last MWH of energy onTransmission Provider's system in a given hour. If Generating Companydelivers an amount of energy that is more than its scheduled amount, assuch scheduled amount may be modified from time to time in accordancewith the OATT, without being directed to do so by Transmission Provider,Transmission Provider shall pay Generating Company a rate for suchamount equal to 90% of Transmission Provider's out of pocket costs,measured in dollars per megawatt-hour, associated with providing the lastMWH of energy on Transmission Provider's system in a given hour. Thenet energy flow pursuant to this Section 2.4(b) shall be calculated on anhourly basis.(c)The aggregate of amounts payable by Generating Company with respect toenergy delivered to Generating Company from Transmission Provider ineach hour of the month, and the aggregate of amounts payable byTransmission Provider with respect to energy received by TransmissionProvider from Generating Company in each hour of the month, shall beoffset (the remaining amount payable after such offset, the "PaymentBalance"), with the Payment Balance to be paid by the Party owing such6

20121114-5147 FERC PDF (Unofficial) 11/14/2012 4:42:25 PMPayment Balance to the Party owed such Payment Balance as provided inArticle 12.(d)ARTICLE 3Notwithstanding Article 15, any failure by Generating Company to deliveran amount of energy equal to its scheduled amount, as such scheduledamount may be modified from time to time in accordance with the OATT,shall not be excused by reason of Force Majeure and therefore shall notrelieve Generating Company of its obligation to make any paymentsrequired by this Section 2.4.Operation and Maintenance3.1Each Party shall operate any equipment that might reasonably be expected to havean impact on the operations of the other Party in a safe and efficient manner andin accordance with all applicable federal, state, and local laws, and Good UtilityPractice, and otherwise in accordance with the terms of this Agreement.Generating Company shall be required to comply with the requests, orders,directives and requirements of Transmission Provider to the extent such requests,orders, directives or requirements are (a) issued pursuant to Good Utility Practice,(b) not unduly discriminatory, and (c) otherwise in accordance with applicabletariffs or applicable federal, state or local laws. In the event Generating Companybelieves that a request, order or directive of Transmission Provider exceeds theselimitations, it shall nevertheless comply with the request, order or directive ofTransmission Provider pending resolution of the Dispute under Article 25. TheParties agree to cooperate in good faith to expedite the resolution of any Disputesarising under this Section 3.1.3.2Without limiting the generality of Section 3.1, Generating Company shall own,operate and maintain, at Generating Company's sole expense, any of its Facilitieswhich are connected to the Transmission System in a manner consistent withGood Utility Practice to prevent degradation of voltage or services ofTransmission Provider's Transmission System. Generating Company equipmentshall conform with industry standards for harmonic distortion and voltagefluctuation. Generating Company shall, upon the reasonable request ofTransmission Provider and consistent with Good Utility Practice, test, calibrate,verify or adjust the voltage regulator control settings as necessary to meet theperformance requirements of the bulk power system. The automatic voltageregulators will control voltages at the Connection Points consistent with the rangeof voltages or voltage schedules as established by System Control in accordancewith Good Utility Practice. In any event, Generating Company shall operate theFacilities with automatic voltage regulators to ensure that no more than a threepercent (3%) instantaneous variation in voltage shall occur at the ConnectionPoint during normal day-to-day operations of Generating Company's equipment.Further, Generating Company shall notify System Control as soon as possible inthe event a Unit reaches any generator operating limit, including a var limit or agenerator winding temperature limit, or there is a deviation from the voltage7

20121114-5147 FERC PDF (Unofficial) 11/14/2012 4:42:25 PMrequirements, or if any voltage regulation equi

Duquesne Light Company, Docket No. ER13- -000 Dear Secretary Bose: Pursuant to Section 205 of the Federal Power Act (“FPA”),1 and Part 35 of the regulations of the Federal Energy Regulatory Commission (the “Commission”),2 Duquesne Light Company (“Duquesne”) hereb