Flender/Flender Gear Units/Bevel-helical gear Reduction Boxes B3
ong as Bicent operates the acility. Exhibit 1 to this Comp laint is copy of the ITSA, which is incorporated

by reference herein. 3. The parties agreed to enter int the ITSA for the purpose of nterconnecting the Generation Facility

[.., MGS] with the [Vernon] Distribution System and to set for the terms and conditions pursuant to which Ver non

will provide firm transmiss ion service to MGS Owner for the transmission of Products [.., nergy and ancillary services] from

the Generati ng Facility to the Southern California Edison Companys Laguna Bell substation. TSA Recital . 3. Because the Facility and the City Distribution System, which the ITSA defines as transmission and distribution acilities owned, controlled, an operated by Vernon, are electronically connected, power qua lity disturbances in the Cit ys system can (and have) had detrimental effects on the Facility. 3. Accordingly, the ITSA speci fically requires Vernon to: . Cause its Distribution System nd Interconnection Facilities be operated, maintained and controlled in afe and reliable manner and in accordance with the ITSA. . Take responsibility for protec tion of its facilities consisten with Good Utility Practice. 1 2 3 4 5 6 7 8 9 1 1 1 1 1 1 1 1 1 1 2 2 2 2 2 2 2 2 2 1 Case No. ____________ VERIFIED COMPLAINT . Take responsibility for protec tion of MGS and Bicents other eq uipment from such conditions as negative sequence currents, over- or nder- frequency, sudden load rejecti on, over- and under-voltage, and generator loss-of-field. . []erform routine inspection and testing of its facilities an equipment in accordance with Good Utility Pract ice as may be necessary to en sure the continued interconnect ion of the Generating Facility with the istribution System in safe and reliable manner. . Routinely, and following any appare nt malfunction[,] test, perate, and maintain equipment necessary protect MGS from faults or ot her electrical sy