We Energies
231 W. Michigan Street
Milwaukee, WI 53203
www.we-energies.com

October 26, 2018

Delivered Via Electronic Mail

Ms. Elizabeth Hittman
Sustainability Program Coordinator
200 E. Wells Street, Room 603
Milwaukee, WI 53202
Re:

City of Milwaukee Interconnection Applications

Dear Ms. Hittman:
Wisconsin Electric Power Company (Wisconsin Electric) has completed its review of your applications to
interconnect seven distributed generation facilities as part of your ReFresh plan to replace fossil fuel
energy use with cleaner renewable resources at your facilities. Unfortunately, Wisconsin Electric cannot
legally grant the applications because the proposed purchase power agreement between the City and a
solar developer is not authorized under Wisconsin law.
Nonetheless, Wisconsin Electric values our relationship with City of Milwaukee. We would like to offer
the City the opportunity to participate in a pilot program that would allow the City to achieve its policy
objectives by hosting the same solar projects identified by the City within the confines of Wisconsin law.
This program would deliver additional benefits to the City in the form of long term revenue for hosting
solar facilities at your six preferred sites and avoid spending general purpose revenues to advance your
solar projects.
Interconnection Request
We have determined that the interconnection applications are not complete because they have not been
submitted by the proper applicant. The rules of the Public Service Commission of Wisconsin (PSCW)
relating to interconnection are found in Wis. Admin. Code § 119.02(2). That administrative rule requires
that the interconnection applicant be “the legally responsible person applying to a public utility to
interconnect a DG facility to the public utility’s distribution system.”
According to the materials the City recently provided to us, the developer will hold an 80% ownership
share in the facilities and will be 100% responsible for the construction, installation, operation and
maintenance of the facilities. The proposed solar service agreement between the City and the developer
also makes clear that the developer will be the actual owner responsible for ensuring that the facilities
meet the PSCW’s requirements for design, safety, certification and testing.
Although the agreement states that the City would hold a 20% ownership share of the facilities, the City
will have no other indicia of ownership. Furthermore, the agreement provides that the developer will
deliver to the City all of the capacity and energy produced by the proposed distributed generation
facilities. In exchange, the City will pay the developer an energy service fee for all capacity and energy
produced that will vary by the facilities’ actual output through an annual true-up adjustment.

 Ms. Elizabeth Hittman
October 26, 2018
Page 2
This arrangement constitutes a purchase power agreement where the third party developer is acting as the
public utility by selling electricity directly to the City. Because Wisconsin Electric already provides
electric service to you, the developer cannot act as the public utility in this circumstance and extend such
service to you. Such an arrangement is not authorized under Wisconsin law.
For these reasons, Wisconsin Electric cannot legally interconnect the proposed distributed generation
facilities.
Solar Now Program
Although we cannot legally grant these interconnection applications, we believe we have a practical
solution that would enable you to meet your policy objectives.
We would invite the City to participate in our proposed Solar Now Pilot program. Once approved by the
PSCW, the Solar Now program will allow our customers to host solar generation on their rooftops or
vacant land and, in exchange, receive a monthly lease payment. We believe the facilities you identified in
your RFP issued last May would fit nicely into this pilot. Attached is a copy of our request for approval
of our pilot program, which we submitted to the PSCW on October 12th.
We believe that having these facilities rolled into our proposed Solar Now program would offer several
advantages for the City. First, we estimate the City would save over $300,000 up front by eliminating the
need for the funding contemplated by the developer. Second, the City would avoid a long-term obligation
under the Solar Services Contract to pay almost $3.5 million in nominal dollars over the term of the
Contract in exchange for potential—and uncertain—savings on energy costs. Instead, we estimate the
City would receive lease payments of approximately $45,000 per year for the life of the lease at the six
proposed locations.
Combined with our active collaboration with the City for the last several months by working with you on
larger scale solar projects under our other proposed pilot program (the Designated Renewable Energy
Resource Pilot (“DRER Pilot”) also filed on October 12th) , we believe that the Solar Now tariff is a far better
approach to meeting your renewable energy goals. We look forward to discussing the Solar Now tariff with
you, and also to continuing our discussions on the City's participation in utility-scale solar generation under the
DRER Pilot.
Please contact me at (414)-221-4737 if you have any questions.
Sincerely,

Theodore T. Eidukas
Vice President
State Regulatory Affairs
Enclosure
cc: Tom Miller and Erick Shambarger

 PSC REF#:351616

Ms. Steffany Powell Coker
Secretary to the Commission
Public Service Commission of Wisconsin
P. O. Box 7854
Madison, WI 53707-7854

6630-TE-_____

Dear Ms. Powell Coker:
As the cost of renewable energy generation installations continue to decline, more of our
customers have expressed interest in working with us to develop renewable energy in Wisconsin.
In response to this customer interest, we have developed two new pilot programs. These pilot
programs will allow us to partner with our customers who choose to either (a) host a solar PV
system that the Company would own and operate – referred to as the Solar Now Pilot, or (b)
subscribe to a Wisconsin-based dedicated renewable energy resource — referred to as the
Dedicated Renewable Energy Resource Pilot — which is similar to a pilot approved for Madison
Gas & Electric Company last year.
Pursuant to Wis. Stat. §§ 196.19 and 196.20, Wisconsin Electric Power Company (“Wisconsin
Electric” or the “Company”) applies for approval to implement these two pilot programs for
customers in our service territory. Additionally, Wisconsin Electric requests that a new docket
be opened for its proposed Solar Now and Dedicated Renewable Energy Resource pilot program
tariffs and that the docket be entitled “Application of Wisconsin Electric Power Company for
Approval of its Solar Now and Dedicated Renewable Energy Resource Pilot Tariffs”.
Solar Now Pilot
For customers who wish to host a solar PV system, Wisconsin Electric requests that the Public
Service Commission of Wisconsin (“PSCW”):


Approve a pilot program, named Solar Now, which establishes a 2.25MW nameplate
capacity limit on each hosted solar PV system installation, with a total participation cap
of 35 MW with 10 MW being reserved for non-profit or government entities.

Public Service Commission of Wisconsin
RECEIVED: 10/12/2018 3:17:11 PM

October 12, 2018

 

Approve the tariff called Solar Now, as proposed in the attached Appendix A.



Approve the Company’s request to defer the cost of the installed solar systems and the
lease payments made to participating customers as part of this pilot program between the
date that this pilot program is approved and the implementation of the Company’s base
rate changes, as approved by the PSCW in the Company’s next rate case proceeding.

This Solar Now pilot program will allow the Company to:


Gain valuable knowledge, insight and experience operating distributed solar generation
and the Company’s existing distribution system with these distribution generation assets
deployed;



Identify characteristics of optimal sites that can utilize distributed generating assets to
avoid or defer future investments in the Company’s distribution system while
maintaining world-class electric service reliability;



Help meet its capacity needs while being responsive to customer requests for local
distribution-connected solar generation;



Partner with non-profit entities, which are not eligible for currently-available federal tax
credits, wanting to host utility-owned solar generating assets;



Partner with interested customers in hosting utility-owned solar generation projects; and,



Encourage and support the growth of carbon-free electricity generation in Wisconsin.

A customer participating in the Solar Now pilot program will receive a monthly lease payment
for hosting the solar PV system. The lease payment paid by the Company will be the value of the
capacity directly attributed to the solar PV system, each as defined in the tariff. The value of
capacity for a solar PV system will be available only to the extent the solar PV system receives
capacity accreditation from the Midcontinent Independent System Operator (“MISO”).
The lease payment will be paid in monthly installments equal to one twelfth (1/12th) of the
annual amount. Additionally, the value of capacity will be based on MISO’s Cost of New Entry
(“CONE”) for the relevant MISO Resource Adequacy Planning Year at the time the service
agreement is executed with the customer. All energy generated by a solar PV system subject to
this pilot will be delivered to the Company’s distribution system and all rights to renewable
energy attributes would remain with the Company.
2

 Other important aspects of the Solar Now tariff:


The customer will be required to enter into a written service agreement with the
Company.



Customers taking service under this pilot will be responsible for all rates, adjustments,
and credits specified in the customer's otherwise-applicable rate schedule.



Wisconsin Electric will retain ownership of and responsibility for the operation and
maintenance of solar PV systems subject to the pilot.



An individual customer (as defined by a tax ID number or a single unit of government)
may host multiple, aggregated systems up to the established 2.25 MW limit for each
installation.

For further details regarding the tariff, please see attached Appendix A.
Dedicated Renewable Energy Resource Pilot
For customers that wish to purchase a portion of a large-scale renewable energy project located
in Wisconsin, the Company requests that the PSCW:


Approve a pilot program, named the Dedicated Renewable Energy Resource Pilot, which
establishes a 150 MW nameplate capacity limit of total customer participation for
existing load without a limit to the number of customers that can participate in the
program.



Approve the tariff called Dedicated Renewable Energy Resource Pilot, as proposed in
the attached Appendix B.

The Dedicated Renewable Energy Resource Pilot will allow the Company to:


Provide participating customers with specific renewable energy goals or needs with the
renewable energy that they have requested during the term of the service agreements;



Partner with participating customers wanting to acquire energy from local, renewable
resources;



Help meet the Company’s capacity needs while being responsive to customer requests
for local renewable generation;

3

 

Provide non-participating customers with a valuable, productive renewable energy
generation resource — at net book value — at the end of the service agreements with
participating customers; and,



Encourage and support the growth of carbon-free electricity generation in Wisconsin.

A customer participating in the Dedicated Renewable Energy Resource Pilot will pay all costs
associated with the associated renewable energy resource subject to each service agreement.
These costs include, but are not limited to, depreciation, return on invested capital and operations
and maintenance during the term of the service agreement.
Participating customers will receive, on a monthly basis, a credit equal to the value of the market
value of the energy generated by the portion of the renewable resource dedicated to their use and
a monthly capacity credit. The energy credit cannot exceed the amount of a customer’s load for
any 60 minute interval. If the dedicated renewable energy resource generates more energy than
the customer consumes during any 60 minute interval, that excess energy is provided to nonparticipating customers at no cost. Rights to renewable energy attributes will be assigned to
participating customers in accordance with tariff provisions.
The capacity credit will be applied in monthly installments equal to one twelfth (1/12th) of the
annual amounts. The value of capacity for a dedicated renewable energy resource will be
available only to the extent the dedicated renewable energy resource receives capacity
accreditation from MISO. Additionally, the value of capacity will be based on MISO’s CONE or
the MISO zone 2 Planning Resource Adequacy Auction clearing price for the relevant MISO
Resource Adequacy Planning Year, which will be determined with reference to the Company’s
capacity position during the MISO Resource Adequacy Planning Year at the time the service
agreement is executed with the customer.
If a long term capacity payment is not available, a participating customer will be provided a
short-term capacity payment and placed on the waiting list for a long term capacity payment on a
first come, first served basis.
Other important aspects of the Dedicated Renewable Energy Pilot are:

4

 

The customer will be required to enter into a written agreement with the Company that
will require PSCW approval;



Customers taking service under this rider will be responsible for all rates, adjustments,
and credits specified in the customer's otherwise-applicable rate schedule;



The company will own and maintain responsibility for the operation and maintenance of
each dedicated renewable energy resource used as part of this pilot;



An individual customer (as defined by a tax ID number or a single unit of government)
may enter into a service agreement up to their aggregated load; however, under no
circumstances will multiple customers be allowed to aggregate eligible accounts under a
single service agreement.

For further details regarding the tariff, please see attached Appendix B.
Additionally, the Company is interested in leveraging this pilot to learn how distributed
generation could be used as a cost effective way to maintain or enhance reliable and cost
effective delivery of electricity to its customers. Should you have any questions related to this
request, please contact Rich Stasik at richard.stasik@wecenergygroup.com or 414-221-3685.
Sincerely,

Theodore T. Eidukas
Vice President
State Regulatory Affairs
Attachments

5

 APPENDIX A
WISCONSIN ELECTRIC POWER COMPANY
Volume 19 – Electric Rates
Effective In All Areas Served In Wisconsin

Revision 0 Sheet xxxxx
Amendment No. xxx
SPS-EN
N

“SOLAR NOW” SOLAR PV SYSTEM HOSTING PILOT PROGRAM
AVAILABILITY
This pilot program is available to customers of Wisconsin Electric Power Company (the “Company”) who
desire to host a company-owned Solar PV System (defined for purposes of this pilot program as solar
panels, inverter(s), cabling, mounting, trackers – if applicable - and associated controls) with up to 2.25
MW ac nameplate capacity on their rooftop or ground mount site. There is a total cap of 35 MW ac available
for this pilot of which 10 MW ac of nameplate capacity will be reserved for non-profit customers (school
district, local government, church, etc.). Participation in this pilot program will be limited to customers on a
commercial or industrial rate.
RATE
A customer participating in this pilot program will receive a monthly payment for hosting the Solar PV
System. The lease payment paid by the Company to the customer shall be the value of the Midcontinent
Independent System Operator (“MISO”) accredited capacity of the Solar PV System multiplied by the
value of capacity, as defined below, up to the customer’s firm demand at the time the service agreement
is entered into. The lease payment shall be paid to the customer in monthly installments equal to one
th
twelfth (1/12 ) of the annual amount.
The value of capacity for a Solar PV System will be determined at the time the service agreement
between the Company and the customer is executed, as determined by MISO’s then current Business
Practice Manual (“BPM”), and will be fixed for the duration of the service agreement. The value of
capacity is the MISO zone 2 cost of new entry (CONE) for the MISO Resource Adequacy Planning Year
in which the service agreement is executed. This value of capacity definition is subject to change.
Customers entering into a service agreement under this pilot will be responsible for all rates, adjustments,
and credits specified in the customer's otherwise-applicable rate schedule. This includes, but is not
limited to, facilities charges; energy charges; fuel cost adjustment; on-peak and customer maximum
demand charges; and minimum charges, all based on the customer’s actual consumption for the billing
period, at the rates under their otherwise applicable rate schedule.
Nothing in this pilot program shall prevent a customer from taking service under schedules ERER-1,
ERER-2, ERER-3 or ERER-4, also known as the Company’s “Energy for Tomorrow” programs.
All energy generated by a Solar PV System subject to this pilot would be delivered to the Company’s
distribution system and all rights to renewable energy attributes would remain with the Company.

Issued: xx-xx-xx
Effective: For service furnished on and after xx-xx-xx
PSCW Authorization: Docket No. 6630-TE-xxx Order dated xx-xx-xx

 APPENDIX A
WISCONSIN ELECTRIC POWER COMPANY
Volume 19 – Electric Rates
Effective In All Areas Served In Wisconsin

Revision 0 Sheet xxxxx
Amendment No. xxx
SPS-EN
N

“SOLAR NOW” SOLAR PV SYSTEM HOSTING PILOT PROGRAM
CONDITIONS OF DELIVERY
1.

Participation in this pilot program requires a written service agreement between the Company and
the customer. Each written service agreement will address, among other topics, the following: (a)
duration of the service agreement, (b) size of the system, (c) basis of the lease payment, (d)
insurance requirements related to the Solar PV System, (e) the survival of the lease, and all
associated terms, if the property is sold or transferred during the term of the lease, and (f)
decommissioning of the Solar PV System at the end of its life.

2.

The Company will retain ownership of and responsibility for the operation and maintenance of
each Solar PV System subject to this pilot.

3.

An individual customer, which is defined by tax ID for non-governmental entities or a single unit of
government (e.g., municipality, county, school district, etc.) may host multiple Solar PV Systems
up to a total of 2.25 MW ac in aggregate. Customers hosting aggregated systems of this sort will
not be able to exceed the firm demand of each aggregating customer’s firm demand for purposes
of the pilot program. The details regarding aggregation and billing will be addressed in individual
service agreements.

4.

Participation in this pilot program may be limited by the Company. For example, the Company
reserves the right to limit customer participation in this pilot based on a customer’s bill payment
and collection history. Further, participation shall be subject to an assessment of the solar
resource and structural and environmental engineering suitability of the identified rooftop or ground
mount location.

5.

All other Conditions of Delivery of the customer’s applicable rate schedule(s) shall apply. If there
is a discrepancy between the base rate schedule and this tariff, this tariff shall govern.

Issued: xx-xx-xx
Effective: For service furnished on and after xx-xx-xx
PSCW Authorization: Docket No. 6630-TE-xxx Order dated xx-xx-xx

 APPENDIX B
WISCONSIN ELECTRIC POWER COMPANY
Volume 19 – Electric Rates
Effective In All Areas Served In Wisconsin

Revision 0 Sheet xxxxx
Amendment No. xxx
DRER Pilot
N

DEDICATED RENEWABLE ENERGY RESOURCE (DRER) PILOT PROGRAM
AVAILABILITY
Available to customers currently taking service under one of Wisconsin Electric Power Company’s (“the
Company’s”) general secondary, general primary or lighting rate schedules who wish to purchase all or a
portion of their electricity requirements from dedicated renewable energy resources as outlined below.
There is a participation limit of 150 MW ac of existing customer load and no limit if the customer’s load
applicable to this pilot is new to the Company’s system at the time of entering in to a service agreement.
RATE
A customer taking service under this pilot will be responsible for all rates, adjustments, and credits
specified in the customer's otherwise applicable rate schedule(s). This includes, but is not limited to,
facilities charges; energy charges; fuel cost adjustment; on-peak and customer maximum demand
charges; and minimum charges, all based on the customer’s actual consumption for the billing period, at
the rates under their otherwise applicable rate schedule. Additionally, a participating customer will pay the
cost of the dedicated renewable energy resource, as agreed upon in the corresponding Dedicated
Renewable Energy Resource (“DRER”) service agreement, and shall receive the following bill credits
associated with the energy production and capacity accreditation of each contracted dedicated renewable
energy resource:
1.

A bill credit for the renewable energy generated specifically for the customer by the dedicated
renewable energy resource. Such bill credit shall be determined based on the Energy Credit
Value applied to the lesser of the energy generated by the dedicated renewable energy resource
for the customer or the customer’s actual energy consumption, for each 60 minute interval in the
billing period. Any excess generation above a customer’s load for a given 60 minute interval will
be provided to non-participating customers at no cost. Energy Credit Values will be based on the
settled market value of the produced energy less any Midcontinent Independent System Operator
(“MISO”) charges established for a MISO pricing node, but in no case shall an hourly Energy
Credit value be less than zero. Pricing node to be determined and included in the DRER service
agreement.

2.

A bill credit based on the amount of capacity, as accredited by MISO and up to the customer’s
billed maximum demand, for any dedicated renewable energy resource subject to this pilot. The
th
capacity credit will be equal to one-twelfth (1/12 ) of the annual amount. The credit value will be
either a long term capacity credit or a short term capacity credit determined based upon the
Company’s capacity need/position during the MISO Resource Adequacy Planning Year (June 1
through the following May 31) in which a dedicated renewable energy resource is expected to
achieve commercial operation. The capacity credit will only be available to the extent the
dedicated renewable energy resource receives accreditation from MISO and it does not exceed a
customer’s maximum billed demand in each billing period.
A long term capacity credit will be available to a subscribing customer to the extent that the
Company has an unfilled capacity need starting in that MISO Resource Adequacy Planning Year
and there are no actively participating customers on the waiting list for a long-term capacity credit.

Issued: xx-xx-xx
Effective: For service furnished on and after xx-xx-xx
PSCW Authorization: Docket No. 6630-TE-xxx Order dated xx-xx-xx

 APPENDIX B
WISCONSIN ELECTRIC POWER COMPANY
Volume 19 – Electric Rates
Effective In All Areas Served In Wisconsin

Revision 0 Sheet xxxxx
Amendment No. xxx
DRER Pilot
N

DEDICATED RENEWABLE ENERGY RESOURCE (DRER) PILOT
RATE (continued)
If a long term capacity credit is not available, a participating customer will be provided a short-term
capacity credit and placed on the waiting list for a long term capacity credit, on a ‘first come, first
served’ basis. The long-term capacity credit is the MISO zone 2 cost of new entry (CONE) for the
MISO Resource Adequacy Planning Year in which the DRER service agreement is executed if the
DRER qualifies for a long-term capacity credit. The short-term capacity credit is the MISO zone 2
planning resource adequacy auction clearing price that is in effect on the date in which the service
agreement is executed. These capacity credit definitions are subject to change.
Renewable Energy Attributes
Participating customers will be assigned all renewable energy attributes, including Renewable Energy
Credits, equal to the amount of energy that is used to calculate the participating customer’s energy credit
as defined in paragraph “1.” within the “Rate” section above.
Minimum Charge
The charges from the customer’s otherwise applicable rate schedule plus any charges as defined in the
DRER service agreement.
Late Payment Charge
A one percent (1%) per month late payment charge will be applied to outstanding charges.
CONDITIONS OF DELIVERY
1.

Service under this pilot requires a written DRER service agreement between the Company and the
customer which provides for the dedication of a new (as defined in Condition of Delivery 3(i)
below) Wisconsin-based renewable energy resource that is owned by the Company and dedicated
to a specific customer and interconnected to either the American Transmission Company (“ATC”)
transmission system or the Company’s distribution system. The customer will be responsible for
all the costs associated with and identified in the DRER service agreement without limitation.

2.

References to MISO and ATC are as defined herein and shall also refer to their successors.

3.

The DRER service agreement shall not harm (1) other customers of the Company who are not
subject to the DRER service agreement, or (2) the shareholders of the Company. The DRER
service agreement must include, but is not limited to, the following:
a.

Details about the dedicated renewable energy resource facility, including but not limited to
(1) source (project description including equipment type, costs, location, etc.); (2) size in
kW and projected kWh energy produced; (3) total percentage of anticipated consumption
coincident with energy production); (4) project timeline.

Issued: xx-xx-xx
Effective: For service furnished on and after xx-xx-xx
PSCW Authorization: Docket No. 6630-TE-xxx Order dated xx-xx-xx

 APPENDIX B
WISCONSIN ELECTRIC POWER COMPANY
Volume 19 – Electric Rates
Effective In All Areas Served In Wisconsin

Revision 0 Sheet xxxxx
Amendment No. xxx
DRER Pilot
N

DEDICATED RENEWABLE ENERGY RESOURCE (DRER) PILOT
CONDITIONS OF DELIVERY (continued)
b.
c.
d.
e.
f.
g.
h.
i.

Details about the costs associated with the dedicated renewable energy resource facility,
without limitation, which are included in the DRER service agreement.
Nameplate capacity and the estimated applicable MISO accredited capacity value of the
dedicated renewable energy resource facility.
Provision to address early termination by either the Company or the customer.
Provision to address default by either the Company or the customer in fulfilling obligations
under the DRER service agreement.
Information regarding customer credit worthiness.
Specified DRER service agreement term.
The specific MISO pricing node that will be used to determine the Energy Credit Value.
Identification of whether the customer would qualify for the long-term or short-term
capacity credit at the time the associated dedicated renewable energy resource is
expected to achieve commercial operation (new) or when the dedicated renewable energy
resource is dedicated to the customer’s use (existing).

4.

The DRER service agreement must be filed with and approved by the Public Service Commission
of Wisconsin (PSCW) in accordance with Wis. Stat. 196.192. Any amendments to the
executed DRER service agreement must also be filed with and approved by the PSCW. If the
PSCW raises specific issues with a DRER service agreement, the Company and the customer will
be allowed a reasonable time period to address those issues before the PSCW approves or denies
the DRER service agreement.

5.

Within a reasonable time (30 days) after receiving a request from a customer the Company will
meet with the customer to begin discussions to determine if mutually agreeable terms can be
reached with respect to a dedicated renewable energy resource in accordance with Wis. Stat.
196.192.

6.

A customer, which is defined by tax ID for non-governmental entities or a single unit of government
(e.g., municipality, county, school district, etc.), with multiple accounts eligible for this pilot, may
aggregate any of its eligible accounts under a single DRER service agreement application with the
Company, up to a maximum number of accounts as determined by the Company on a case-by
case basis. The details regarding aggregation and billing will be addressed in the service
agreement. Under no circumstances will multiple customers be allowed to aggregate eligible
accounts under a single service agreement application.

7.

Any customer choosing to be served under this pilot thereby waives all rights to any billing
adjustments arising from a claim that the bill for the customer’s service would be cheaper on any
alternative rate schedule for any period of time, including any rights under Wis. Admin. Code PSC
113.0406(4).

8.

Pilot participation may be limited at the sole discretion of the Company. Additionally, the Company
reserves the right to limit customer specific participation on this pilot based on a customer’s bill
payment and collection history.

Issued: xx-xx-xx
Effective: For service furnished on and after xx-xx-xx
PSCW Authorization: Docket No. 6630-TE-xxx Order dated xx-xx-xx

 APPENDIX B
WISCONSIN ELECTRIC POWER COMPANY
Volume 19 – Electric Rates
Effective In All Areas Served In Wisconsin

Revision 0 Sheet xxxxx
Amendment No. xxx
DRER Pilot
N

DEDICATED RENEWABLE ENERGY RESOURCE (DRER) PILOT
CONDITIONS OF DELIVERY (continued)
9.

Customers shall be bound by, and receive and pay for service furnished hereunder in accordance
with (i) the rates, terms and conditions of the DRER; (ii) the rates, terms and conditions of their
otherwise applicable rate schedule(s), (iii) the Company’s Rules and Regulations; and (iv) any
future modifications of such rates, terms, conditions, and rules and regulations that may be
ordered or approved by the PSCW. To the extent that there are conflicts among any of the
foregoing, the specific provisions of this pilot shall govern.

Issued: xx-xx-xx
Effective: For service furnished on and after xx-xx-xx
PSCW Authorization: Docket No. 6630-TE-xxx Order dated xx-xx-xx