# EPC / Energy / Infrastructure Lexicon

English terminology for (a) engineering, procurement and construction contracts (EPC),
turnkey contracts, construction agreements, balance of plant (BOP) contracts, operations
and maintenance agreements (O&M); and (b) energy and infrastructure agreements — power
purchase agreements (PPAs), grid connection, offtake agreements, concession agreements,
regulatory and tariff matters, renewables, and related instruments.

This consolidated lexicon unifies the construction and commissioning terminology with
the operational, regulatory and commercial energy / infrastructure terminology. Many
terms cross the interface between the two contract families (performance guarantees,
availability guarantee, taking over vs. commercial operation date, change in law,
liquidated damages, concession step-in) and should be treated as one terminology system.

## Core EPC Terms

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| EPC contract / turnkey contract | A contract covering engineering, procurement, and construction as a single package | — |
| construction contract / building contract | A contract for construction works | — |
| works contract | A contract for the execution of works | — |
| subcontract | A contract between the main contractor and a subcontractor | — |
| balance of plant (BOP) | All supporting systems and infrastructure beyond the primary equipment (e.g., electrical, civil works, interconnection) | — |
| O&M agreement | Agreement for operations and maintenance of a facility | — |
| contractor / EPC contractor | The party responsible for performing the works | — |
| subcontractor | A party performing part of the works under the main contractor | — |
| employer / owner / principal | The party commissioning the works | "Employer" (FIDIC) is default for international contracts |
| engineer (FIDIC) | The independent professional administering the contract on behalf of the employer under FIDIC contracts | "works director" (calque), "director of works", "works supervisor" |
| employer's representative / owner's engineer | The employer's designated contact for contract administration; used in contracts without an independent Engineer role, or as the employer's on-site supervisory appointee | "works supervisor" |
| back-to-back | Principle of passing obligations and liabilities from the main contract down to the subcontract on matching terms | — |

## Core Energy Terms

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| power purchase agreement (PPA) | Fundamental energy sales contract; specify type (corporate, merchant, physical, virtual/synthetic) | energy purchase contract; energy supply contract (less precise) |
| corporate PPA | Long-term offtake by end-user/corporate buyer; often involves physical delivery to buyer's facility | merchant PPA; spot purchase |
| merchant PPA | Sale into wholesale market with variable pricing; generator bears market risk | corporate offtake; firm offtake |
| physical PPA | Energy physically delivered to agreed delivery points; actual power flows to buyer | virtual PPA; financial PPA |
| virtual PPA / synthetic PPA | Financial contract for difference (CFD) without physical delivery; serves as financial hedge | physical offtake; actual delivery agreement |
| energy supply agreement | Supply of energy to consumers/end-users; distinct from generator PPAs | PPA (confuses buyer offtake with generator sales) |
| offtake agreement | General term for energy sales agreement; often used in project finance | energy purchase; energy sales contract |
| bankability | Suitability of PPA or project structure for project finance debt; assessed by lenders | financeable; lendable (non-standard) |
| deemed generation / deemed energy | Notional output credited to generator when curtailed or prevented from generating; basis for compensation | lost generation; foregone energy (vague) |
| grid connection agreement | Technical and commercial terms for connecting generator/consumer to grid; critical for PPAs | network connection contract; grid access agreement |
| connection charge | Fee paid for grid connection infrastructure and maintenance | grid fee; access fee (less precise) |
| balancing / dispatch agreement | Management of real-time energy supply/demand equilibrium | dispatch contract; load-following agreement |
| grid curtailment / production curtailment | Temporary reduction of generation output due to grid constraints; may trigger constraint payments | supply restriction; reduction (too vague) |
| constraint payments / constraint costs | Compensation to generators for forced reduction due to grid congestion; UK term: "constraint payments"; US: "congestion costs" | congestion charges (ambiguous) |
| energy storage system / battery | Facility for storing electrical energy; important for renewable integration | accumulation facility; energy bank |
| distribution agreement | Supply of energy through local distribution grid; governed by DSO | retail supply agreement (confuses retail sales) |

## Design and Engineering Terms

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| design / engineering | The process of producing technical designs and specifications | — |
| as-built drawings | Drawings produced AFTER construction showing what was actually built; distinct from the "construction design" produced before construction | as-built documents (imprecise); final drawings (ambiguous — could mean final design or as-built) |
| procurement | The process of sourcing and purchasing materials and equipment | — |
| construction | The physical building/installation work | — |
| technical specifications | Detailed technical requirements for the works | — |
| employer's requirements | The document specifying what the employer wants built and to what standards (FIDIC Yellow/Silver Book) | "client's specifications" |
| contractor's proposal | The contractor's response to the employer's requirements, detailing how it will design and build the works (FIDIC Yellow/Silver Book) | "contractor's offer", "technical offer" |

### Design Stage Hierarchy (Critical)

| Stage | Correct English | Avoid |
|---|---|---|
| Stage 1 — conceptual | preliminary design | "preliminary project" |
| Stage 2 — intermediate | detailed design | "definitive project" (calque), "preliminary design" (WRONG STAGE) |
| Stage 3 — construction-ready | construction design | "executive project" (calque), "detailed design" (reserve for Stage 2) |

**WARNING**: Confusing Stage 2 (detailed design) with Stage 1 (preliminary design) is a
material error. The hierarchy is: Preliminary Design → Detailed Design → Construction Design.

## Commissioning and Acceptance Terms

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| commissioning | The process of testing and starting up a completed facility | — |
| acceptance test | The formal test to verify works meet specifications | "testing" (too vague) |
| provisional acceptance test / taking over | The initial acceptance test at the end of construction | — |
| final acceptance test | The test at the end of the defects liability period | — |
| taking-over certificate (FIDIC) / PAC | Certificate confirming provisional acceptance | — |
| final acceptance certificate / FAC | Certificate confirming final acceptance | — |
| mechanical completion | The point when all mechanical/electrical systems are installed and ready for testing | — |
| substantial completion | The point when the works are sufficiently complete for their intended use | — |
| defects liability period (FIDIC 1999) / defects notification period (FIDIC 2017) / warranty period | The period after taking over during which the contractor must remedy defects | — |
| taking over | The employer's acceptance of the completed works | — |
| site handover / access to site | The employer giving the contractor access to the construction site | — |
| punch list / snag list | List of outstanding minor items to be completed or corrected after substantial completion | — |
| outstanding works | Works not yet completed at the date of taking over | — |
| commercial operation date (COD) | The date from which the facility begins commercial operation under the PPA / offtake agreement; typically follows taking over / substantial completion | "entry into service" (vague) |
| performance testing | Validation that facility meets contracted performance standards (e.g., capacity factor, efficiency); may trigger retesting | — |

## Financial and Commercial Terms (EPC)

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| contract price | The total price payable for the works | — |
| lump sum price | A fixed price for the entire scope of works | — |
| unit price / re-measurable price | A price based on measured quantities | — |
| variation / variation order / change order | A change to the scope, design, or specifications of the works | — |
| employer's variation / instructed variation | A variation initiated by the employer | — |
| contractor's variation proposal | A variation proposed by the contractor | — |
| mandatory variations | Variations required by law or regulation | "necessary variations" |
| discretionary variations | Variations at the employer's option | "optional changes" |
| milestone | A defined point in the project schedule, often linked to a payment or deliverable | — |
| milestone payment | A payment triggered by the achievement of a specified milestone | — |
| progress payment / interim payment | Payment for work completed during a payment period | — |
| payment certificate | A certificate authorizing a progress payment | — |
| retention / retention money | An amount withheld from each payment as security for defects | — |
| release of retention | The return of retention money after defects are remedied | — |
| performance security (FIDIC) / performance bond / performance guarantee | Security provided by the contractor to guarantee performance of its obligations (FIDIC Sub-Clause 4.2) | — |
| advance payment guarantee | A bond securing the employer's advance payment to the contractor | — |
| warranty bond / defects liability guarantee | A bond covering the contractor's obligations during the defects period | — |
| bid bond / tender guarantee | A bond guaranteeing a tenderer's commitment to its bid | — |
| parent company guarantee (PCG) | A guarantee from the contractor's parent company guaranteeing the contractor's obligations | — |
| delay damages / liquidated damages for delay | Pre-agreed damages payable for late completion | "penalties for delay" |
| performance liquidated damages | Pre-agreed damages for failure to meet performance guarantees | "penalties for underperformance" |
| liquidated damages (LDs) | Pre-agreed damages for delay or underperformance | "penalties" |
| early completion bonus | Bonus payable for completing ahead of schedule | — |
| aggregate cap on liquidated damages | The maximum total liquidated damages payable | — |
| additional cost | Costs beyond the contract price that are reimbursable | — |
| claim | A formal request for additional time, money, or both | — |

## Program and Time Terms

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| construction schedule / program | The program/timetable for the works; "program" is standard FIDIC terminology, "construction schedule" is widely used in international practice | "timing plan", "construction program" (ambiguous — use "program" or "construction schedule") |
| critical path | The sequence of activities determining the minimum project duration | — |
| commencement date | The date when the contractor is authorized to begin work | — |
| completion date / time for completion | The contractual deadline for completing the works | — |
| extension of time (EOT) | Additional time granted for completion due to specified events | — |
| excusable delay | A delay entitling the contractor to an extension of time | — |
| compensable delay | A delay entitling the contractor to both time and money | — |
| suspension of the works | A temporary halt to the works | — |
| resumption of the works | Restarting work after a suspension | — |

## Site and Works Terms

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| site | The location where the works are performed | — |
| temporary works | Structures and installations needed during construction but removed afterwards | — |
| permanent works | The completed works forming part of the finished facility | — |
| materials and equipment | Physical items incorporated into or used for the works | — |
| unforeseeable (FIDIC) | Physical conditions or circumstances that an experienced contractor could not reasonably have foreseen (FIDIC Sub-Clause 4.12); a specific contractual threshold — do not replace with "unforeseen" | "unforeseen" (different legal threshold), "unexpected" |

## Operations and Maintenance (O&M)

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| operator | The party responsible for operating the facility | — |
| availability guarantee | Guarantee that the facility will be available for a minimum percentage of time | — |
| performance guarantee | Guarantee that the facility will meet specified performance parameters | — |
| performance ratio | The ratio of actual output to expected output under reference conditions | — |
| guaranteed capacity | The minimum capacity the facility must achieve under specified conditions | — |
| scheduled maintenance / planned maintenance | Maintenance carried out in accordance with a pre-agreed schedule | — |
| unscheduled maintenance / corrective maintenance | Maintenance carried out in response to a fault or failure | — |
| preventive maintenance | Maintenance carried out to prevent failure before it occurs | — |
| spare parts | Replacement components held in stock for maintenance purposes | — |
| major maintenance / overhaul | Significant planned maintenance requiring extended shutdown | — |
| handover | Transfer of the facility from the EPC contractor to the operator (or from operator back to owner at contract end) | — |

## Permits and Authorizations

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| permit / authorisation (UK) / authorization (US) | General term for government approval to construct/operate facility | license; approval (too vague) |
| single authorization | Consolidated permitting process combining multiple approvals | unified permit; combined approval |
| integrated environmental authorization (IEA) | Consolidated environmental permits for large industrial facilities | environmental license; pollution permit |
| environmental impact assessment (EIA) | Mandatory study of project's environmental effects on natural environment, human health, etc. | environmental study; impact report (less precise) |
| strategic environmental assessment (SEA) | Broader environmental assessment at policy/program level, not individual projects | environmental planning; program assessment |
| landscape authorization / landscape approval | Specific approval for visual impact in protected/scenic areas | aesthetic approval; visual permit |

## Environmental

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| environmental compliance certificate | Proof of meeting environmental standards for construction/operation | environmental clearance; environmental license |
| protected species assessment | Evaluation of project impact on endangered/protected flora and fauna | biodiversity study; species impact report |
| water permit / water discharge permit | Authorization for water use/discharge; UK: "water discharge consent"; US: "NPDES permit" | water license; aquatic authorization |
| noise impact assessment | Study of acoustic effects on surrounding areas, esp. wind farms | noise study; sound report |

## Renewables Terms

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| renewable energy | Energy from naturally replenishing sources (wind, solar, hydro, biomass, geothermal) | clean energy; green energy (less technically precise) |
| renewable source / renewable resource | Natural resource for energy generation | renewable input; energy source (too vague) |
| photovoltaic (PV) plant / solar PV facility | Facility generating electricity from sunlight using photovoltaic cells | solar facility; PV installation (less precise) |
| wind farm / wind energy plant | Facility with multiple wind turbines generating electricity | wind park; eolian facility |
| wind turbine | Individual electricity-generating turbine; specify capacity (MW, kW) | wind generator; wind device |
| biomass plant | Facility generating energy from organic matter; specify fuel type (forestry waste, agricultural residue, etc.) | bioenergy facility; biological fuel plant |
| hydroelectric plant / hydro facility | Facility generating electricity from water flow; specify type (run-of-river, reservoir, pumped-storage) | water power plant; dam facility (imprecise) |
| concentrated solar power (CSP) plant | Facility using mirrors/lenses to concentrate sunlight for heat generation; distinct from PV | thermal solar; solar thermal facility |
| energy storage system | Technology for storing electrical energy (batteries, pumped hydro, compressed air, thermal) | battery; storage facility (too vague) |
| installed capacity | Total maximum electrical output of facility under ideal conditions; measured in MW | rated power; nameplate capacity (less standard) |
| rated capacity / nameplate capacity | Manufacturer's specified maximum output under standard conditions | designed capacity; nominal power |
| capacity factor (%) | Actual energy output vs. theoretical maximum; e.g., 35% capacity factor for wind farm | efficiency ratio; output percentage (imprecise) |
| expected generation / expected output | Forecasted annual electricity production based on resource assessment | expected yield; estimated production |
| equivalent hours (full load hours) | Annual operating hours at rated capacity to produce actual annual output; used for performance assessment | effective hours; operating hours |
| capacity market | Market mechanism paying generators for availability rather than generation; typically used for grid stability | reserve market; standby payment (less standard) |
| ancillary services | Services supporting grid stability (voltage control, frequency regulation, reactive power); distinct from energy | grid services; system services (vague) |
| self-consumption | Direct use of generator's own production; important for rooftop PV and microgrids | self-use; onsite generation (imprecise) |
| energy community | Group of citizens/small businesses sharing renewable energy infrastructure; EU-defined concept | community energy; collective generation (vague) |
| green certificate | Financial instrument for renewable generation; largely superseded by GO and RECs | renewable certificate; eco-certificate |
| guarantee of origin (GO) | EU-wide certificate proving renewable energy source; tradable and transferable | renewable credit; origin certificate |
| renewable energy certificate (REC) / green energy credit | International equivalent of GO; US and Australian markets primarily; one REC = 1 MWh renewable energy | green tag; renewable energy credit (regional term) |
| white certificate / energy efficiency certificate | Financial instrument rewarding energy efficiency improvements; used in various EU member state markets | EEC; efficiency certificate |
| feed-in tariff (FIT) | Fixed price paid to generators for renewable energy; historical support mechanism in many countries | fixed feed-in payment; guaranteed price |
| feed-in premium / incentive tariff | Variable premium on top of market price for renewable generation | feed-in subsidy; price support |
| contract for difference (CfD) | Financial agreement where government pays difference if market price falls below strike price; modern support mechanism in UK | strike price agreement; price floor contract |
| net metering / net billing | Mechanism crediting self-consumption customers for excess generation fed to grid | smart metering; billing offset (less precise) |
| regulated offtake / dedicated offtake | Direct sale of generation to utility/offtaker at regulated rate; alternative to PPA or FIT | simplified sale; utility sale (vague) |

## Grid Terms

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| electricity grid / power grid | Interconnected system for generation, transmission, distribution of electricity | electrical system; power system (too vague); electrical network |
| transmission grid / high-voltage grid | System for long-distance electricity transport at high voltage (typically >100 kV) | transmission system; backbone network |
| distribution grid / low-voltage grid | Local grid distributing electricity to end users at lower voltage (typically <35 kV) | retail network; final-mile system |
| transmission system operator (TSO) | Entity managing transmission grid; has monopoly status in most jurisdictions | transmission grid operator; national grid |
| distribution system operator (DSO) | Entity managing distribution grid; typically municipal or regional utility | distribution utility; local grid operator |
| connection point / grid connection point | Physical location where generator/consumer connects to grid; critical for technical specifications | injection point (distinct); offtake point (distinct) |
| delivery point / offtake point / metering point | Location where energy is measured and transferred to buyer; defines measurement responsibility | consumption point; settlement point |
| injection point | Location where generated energy enters grid; for generators (distinct from delivery point) | export point; feed-in point |
| meter / electricity meter | Device measuring energy flow (MWh, kWh); specify type (analog, digital, smart) | measuring device; consumption counter |
| metering | Process of measuring electricity consumption/generation; foundation for billing and settlement | measurement; monitoring (less precise) |
| balancing / dispatch services | Services ensuring real-time supply/demand equilibrium; includes frequency regulation, reserve provision | grid support; system services (vague) |
| system charges / grid charges | Fees for maintaining grid infrastructure and operations; distinct from energy cost | network fee; transmission charge (imprecise) |
| transmission charge | Fee for using transmission grid; typically per MWh or monthly capacity fee | grid fee; access charge (ambiguous) |
| grid losses / network losses | Electricity lost as heat in transmission/distribution; typically 3-10% of total flow | system loss; transmission loss (less complete) |
| zonal price / nodal price | Wholesale electricity price at specific location on grid; varies by congestion | location price; regional price (imprecise) |
| day-ahead market (DAM) | Wholesale market for electricity delivery next day; primary price discovery mechanism | morning market; forward market (imprecise) |
| intra-day market (IDM) | Wholesale market for shorter-term electricity trading; allows last-minute adjustments | continuous trading; short-term market |
| balancing market / real-time market | Market for real-time balancing services; prices typically highest due to emergency nature | regulation market; frequency response market |
| balancing responsible party (BRP) | Entity financially responsible for imbalances between scheduled and actual energy flows; may be generator, supplier, or trader | balance responsible; scheduling agent (less precise) |
| frequency containment reserve (FCR) | Primary frequency response; automatic within seconds of frequency deviation | primary reserve; automatic frequency response |
| automatic frequency restoration reserve (aFRR) | Secondary frequency response; automatic restoration within minutes; centrally activated by TSO | secondary reserve; automatic generation control (AGC) |
| manual frequency restoration reserve (mFRR) | Tertiary frequency response; manually activated by TSO within 15 minutes | tertiary reserve; manual reserve |
| frequency reserve | General term for reserves maintaining grid frequency at 50 Hz (FCR, aFRR, mFRR); specify type | ancillary services (broader); grid services |
| mark-to-market (MtM) | Valuation of energy trading positions at current market price; used for collateral and margin calls | market valuation; fair value (accounting term) |
| collateral / margin | Security deposit required to cover potential losses on energy trading positions; may be cash or bank guarantee | security deposit; guarantee (too vague) |

## Tariff and Support Mechanisms

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| tariff / electricity tariff | Price per unit of energy (€/MWh, €/kWh) or fixed/variable charges; distinguish from all-inclusive tariff | pricing; rate (too vague) |
| tariff adjustment / tariff review | Mechanism for adjusting regulated tariffs; may be automatic or discretionary | price update; tariff modification (too vague) |
| all-inclusive tariff | Single price covering energy, grid charges, and taxes; simplifies billing for certain customer types | bundled tariff; all-in price |
| incentive tariff | Rate higher than market price, incentivizing generation; includes FIT and feed-in premium | support tariff; subsidy rate |
| daylight saving mechanism | Automatic adjustment for daylight hours; affects metering and generation calculations | seasonal adjustment; summer-winter adjustment |

## Concession and Infrastructure Terms

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| concession / concession agreement | Long-term (typically 20-50 years) government grant to operate infrastructure (dam, road, utility); includes public works and service concessions | concession contract; service contract (less precise) |
| public works concession | Concession for constructing and operating public infrastructure; risk allocation favors concession holder | construction concession; works concession |
| public service concession | Concession for providing public services (e.g., water utility, waste management); stricter regulatory oversight | service contract; utility concession |
| concession period / concession term | Duration of concession rights; typically 25-30 years for energy/water; defines asset life | concession duration; term (too vague) |
| concession fee / concession royalty | Annual or lump-sum payment to government for concession rights; may be fixed or variable | concession payment; license fee |
| concession assets / concessioned assets | Infrastructure/assets transferred to concession holder for duration of term | concessioned property; transferred assets |
| reversionary assets / assets reverting to authority | Assets/property automatically returning to government at end of concession; often in "as-is" condition | reversion assets; residual value assets |
| step-in right | Government's or lender's right to assume control of concession/project if operator defaults; critical for project finance | intervention right; takeover right (imprecise) |
| step-in value | Monetary value payable to concession holder upon government step-in; key bankability factor | intervention value; compensation amount |
| financial model / financial plan (PEF) | Detailed model of project revenues, costs, cash flows over entire concession period; basis for tariff setting | pro forma; financial forecast (less precise) |
| financial equilibrium / economic equilibrium | Commitment that concession remains viable despite changed circumstances; triggers tariff review | balance mechanism; viability clause |
| financial plan revision / tariff reset | Formal adjustment to tariff or financial model due to changed conditions (cost inflation, regulatory changes) | tariff adjustment; price reset |
| project bond | Bond financing repaid from project cash flows; typical in concession project finance | infrastructure bond; toll bond (less precise) |
| public contribution / government grant / government subsidy | Direct cash payment from government to project, improving returns (complements revenue from operations) | public funding; grant (too vague) |

## Project Finance Cross-Over Terms

Terms appearing in EPC/BOP/construction contracts and PPAs/offtake agreements within a
project finance structure. Use PF-standard English for consistency with the facility
agreement and other finance documents.

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| notice to proceed (NTP) | Formal notice authorizing the contractor to begin work | "start communication" |
| finance parties | The lending syndicate | "financing institutions" |
| change in law | A change in applicable legislation affecting the project | "legislative changes" |
| direct agreement | Agreement between lenders and a project counterparty (EPC contractor, offtaker, O&M operator) | — |
| termination for convenience | The employer's right to terminate without cause | "withdrawal" |
| termination for default | Termination triggered by the contractor's breach | "resolution for non-performance" |

## Miscellaneous / General Provisions

| Correct English term | Usage / meaning | Avoid |
|---|---|---|
| force majeure | See canonical definition in general-legal.md. Energy/EPC context: typically paired with a "relief event" regime (FIDIC Red/Yellow/Silver Book Clause 18). | — |
| intellectual property | Rights to technical data, know-how, patents; critical in energy contracts involving proprietary technology | technical IP; know-how (too vague) |
| liability cap / liability limitation | Maximum amount of damages one party can claim from other | damage cap; compensation limit (imprecise) |
| indemnification / indemnity | Party A agrees to compensate Party B for specified losses; common in energy PPAs. Default to "indemnification" for US drafting (the skill default); "indemnity" is the UK variant under --variant uk. | hold harmless (vague absent legal doctrine); compensation agreement (imprecise) |
| change of control | See canonical definition in finance-banking.md. Energy/infrastructure context: concession agreements typically require government consent; may trigger revocation. | — |
| articles of association (UK) / by-laws (US) | See canonical definition in corporate-ma-jv.md. Energy/infrastructure context: concession agreements typically restrict amendments to the SPV/project company's articles without contracting-authority consent. | — |

## Section Headings

| Correct English heading | Avoid |
|---|---|
| SCOPE OF WORKS | "OBJECT OF THE CONTRACT" |
| SUBJECT MATTER / SCOPE | Object; Description of Works |
| CONTRACT PRICE AND PAYMENT | — |
| TIME FOR COMPLETION | — |
| DESIGN / ENGINEERING | — |
| CONSTRUCTION | — |
| TESTING AND ACCEPTANCE | — |
| COMMISSIONING | — |
| DEFECTS LIABILITY / DEFECTS NOTIFICATION PERIOD | — |
| VARIATIONS | — |
| PERFORMANCE GUARANTEES | — |
| OPERATIONS AND MAINTENANCE | — |
| PLANT / FACILITY | Installation (too generic); Equipment (narrower) |
| ENERGY OUTPUT | Generated Energy; Production |
| PRICE AND PAYMENT | Tariff; Pricing |
| PERMITS AND AUTHORIZATIONS | Licenses; Approvals |
| ENVIRONMENTAL | Environmental Compliance; Environmental Terms |
| GRID CONNECTION | Grid Access; Network Connection |
| METERING AND SETTLEMENT | Measurement; Billing |
| TARIFF AND SUPPORT MECHANISM | Incentive Structure; Commercial Terms |
| MAINTENANCE OBLIGATIONS | Operations; Upkeep |
| CONCESSION TERM | Duration; Term |
| REVERSIONARY ASSETS | Reversion; End-of-Term Assets |
| CHANGE OF CONTROL | — |
| SUBCONTRACTING | — |
| HEALTH AND SAFETY | — |
| LIABILITY AND WARRANTIES | — |
| TERMINATION | — |
| INSURANCE | — |
| FORCE MAJEURE | — |
| DISPUTE RESOLUTION | — |
| MISCELLANEOUS / GENERAL PROVISIONS | — |

## Notes

- **FIDIC alignment**: Many international EPC contracts follow FIDIC standard forms. Use
  FIDIC terminology where the source follows that structure: "Engineer" (not "Director of
  Works"), "Taking-Over Certificate" (not "Provisional Acceptance Certificate"), "Defects
  Notification Period" (FIDIC 2017 editions).

- **"Employer" vs "Owner"**: FIDIC uses "Employer"; many US contracts use "Owner". Default
  to "Employer" for international/European contracts.

- **Liquidated damages**: Always say "liquidated damages" (not "penalties") to preserve
  enforceability under English law.

- **BOT/BOOT/BOO**: For concession-based construction (Build-Operate-Transfer etc.),
  additional concession-specific terminology applies.

- **"Construction design" vs "as-built drawings"**: These are completely different things.
  Construction design documents are produced BEFORE construction; as-built drawings are
  produced AFTER construction showing what was actually built. Confusing them is a material error.

- **O&M and EPC interface**: The handover from EPC to O&M is a critical project milestone.
  Ensure terminology is consistent between the EPC contract and the O&M agreement,
  particularly for performance guarantees, defects liability, and warranty provisions.

- **Capacity vs. Energy**: Never confuse the two. Capacity = maximum output (measured in MW, GW). Energy = actual output over time (measured in MWh, GWh). A 100 MW wind farm produces ~350 GWh/year (at 40% capacity factor), not "100 MWh".

- **PPA Types**: Modern PPAs vary widely. Always specify: (1) Corporate vs. merchant offtake, (2) Physical vs. virtual/financial, (3) Fixed vs. variable pricing, (4) Tenor (typically 10–25 years).

- **Grid Curtailment**: Distinguish between (a) planned/scheduled curtailment (maintenance), (b) forced curtailment (grid constraints with compensation), and (c) spilling (water dams; no compensation).

- **Renewable Energy Certificates**: GO (Guarantee of Origin) is EU-specific. REC (Renewable Energy Certificate) is international standard, primarily used in US, Australia, India. In EU contracts, typically refer to GOs unless dealing with cross-border/international buyers.

- **Support Mechanisms**: Modern mechanisms include FIT (declining), feed-in premium (with market price floor), CfD (UK model), tender-based (auction), net metering (distributed generation), and simple sale (commodity rate). Identify which applies.

- **National Regulatory Bodies**: When translating contracts, keep national regulatory acronyms (e.g., GSE, GME, Terna, ARERA in Italy; Ofgem, National Grid ESO in UK; FERC, NERC in US) and explain on first use in English context. Sub-lexicon provides source-language mappings.
