Southwest Power Pool BUSINESS PRACTICES WORKING GROUP Conference Call/Web Cast April 21, SUMMARY OF ACTION ITEMS-

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1 Southwest Power Pool BUSINESS PRACTICES WORKING GROUP Conference Call/Web Cast April 21, SUMMARY OF ACTION ITEMS- # ACTION ITEMS ASSIGNED TO 1 SPP Staff will edit BPR001 and BPR002 to present to the BPWG at a future meeting. Staff will also edit proposed Tariff language and add a disclaimer regarding the presence of a seams agreement and have Katy Onnen/Susan Polk the edits reviewed by Wright and Talisman. 2 SPP Staff will send BPR018 to MOPC Exploder list for review and Clint Savoy suggested revisions. 3 BPWG Members and participants will review BPR021 and prepare comments for next scheduled meeting. BPWG Members 4 BPR020, and Examples of Simultaneous Submission Window Clint Savoy Allocation will be added to the agenda for the next meeting. 5 6

2 Southwest Power Pool BUSINESS PRACTICES WORKING GROUP Conference Call/Web Cast April 21, 2011 AGENDA ITEM 1 ADMINISTRATIVE ITEMS a) Grant Wilkerson called the meeting to order at 1:04 p.m. There were 24 people present representing 9 members, 10 SPP Staff members, and 4 guests. (Attachment 1-Attendance record) b) Kevin Pera was recognized as proxy for Jessica Collins. Mark Foreman was recognized as a proxy for Kara Whillock. c) The minutes from the March 9-10, 2011 meeting were revised and approved after motion from Robert Walker and second from Ed Hammons. (Attachment 2- Minutes_Revised) d) The revised agenda was reviewed and accepted. (Attachment 3- Agenda_Revised) AGENDA ITEM 2 REVIEW OF PAST ACTION ITEMS The following updates were given for the past action items: a. Mr. Womack will request clarification from SPP Staff (John Mills or Charles Hendrix) regarding cost allocation and NRIS. This item was placed on this meeting agenda. b. Mr. Savoy will provide specific examples of the different methods of random capacity allocation for TSRs submitted during a simultaneous submission window. This item was placed on this meeting agenda. c. Mr. Womack will provide an update to Daily Non-firm On-peak/Off-peak transmission service. This item was placed on this meeting agenda. d. If time allows, SPP Staff will present BPR002 to the RTWG prior to the April 12, 2011 MOPC meeting. BPR002 is on the agenda for this meeting. e. Mr. Womack will add BPR002, BPR014, BPR018, and BPR019 to the April 12, 2011 MOPC agenda. Updates from the MOPC meeting is on the agenda for this meeting. AGENDA ITEM 3 BPR001 - SPP TSR COORDINATION WITH THIRD PARTY SYSTEMS Katy Onnen explained to the group the current status of BPR001. The language added to Attachment D is no longer applicable because Long Term Transmission Service no longer goes through the System Impact Study Process. The correct Attachment for the Business Practice to reference is Attachment Z1. Subsection e will be added to Attachment Z1 due to BPR001. This item was tabled until the next BPWG meeting to allow SPP Staff to edit the BPR and Tariff language and allow FERC counsel to review the revisions. AGENDA ITEM 4 BPR002 THIRD PARTY TSA COORDINATION Katy Onnen explained to the group the current status of BPR002. FERC Order 890 requires Transmission Providers to notify any third party affected systems so that the affected systems may perform transmission system studies. Steve Purdy expressed the only concern he had for this BPR was that it conflicted with an existing Seams agreement. This item was tabled until the next BPWG meeting to allow SPP Staff to edit the BPR and Tariff language and allow FERC counsel

3 to review the revisions and conflicts with current Seams agreements. (Attachment 4- BPR002_Revised) AGENDA ITEM 5 BPR018 GENERATION INTERCONNECTION Charles Hendrix and Carrie Bumgarner presented revisions to the BPR following discussions from the MOPC meeting. The revisions will be sent to the MOPC Exploder list for review and feedback. AGENDA ITEM 6 BPR020 NRIS Charles Hendrix explained that the 20% TDF threshold was a benchmark used by other RTO/ISOs to determine major impacts on the transmission system during generator interconnection studies. Suggestions for alternatives to the word nameplate were discussed and any alternatives should be sent to Grant Wilkerson or Jimmy Womack. This BPR was tabled until the next meeting, when it will be voted on and sent to other working groups. (Attachment 5- BPR020_Revised) AGENDA ITEM 7 BPR021 AUTHORIZATION TO PLAN Katherine Prewitt presented the proposed Business Practice to the group. James Hotovy echoed his concern from the previous meeting that ATP projects should not be included in any models past the ITP10. BPWG Members are to submit comments regarding BPR021 and be prepared for a vote at the next scheduled meeting. AGENDA ITEM 8 DAILY NON-FIRM ON/OFF PEAK TRANSMISSION SERVICE UPDATE Jimmy Womack reported that the requested clarifications were filed with FERC and SPP is awaiting a ruling. AGENDA ITEM 9 MOPC ACTION ITEMS BPR018 was sent back to the BPWG for revisions. BPR014 and BPR019 were approved, with approval of BPR019 pending review by the ORWG. AGENDA ITEM 10 SIMULTANEOUS SUBMISSION WINDOW ALLOCATION EXAMPLES This item was tabled until the next meeting due to time constraints. AGENDA ITEM 11 ACTION ITEMS Action items are as follows: 1) SPP Staff will edit BPR001 and BPR002 to present to the BPWG at a future meeting. Staff will also edit proposed Tariff language and add a disclaimer regarding the presence of a seams agreement and have the edits reviewed by Wright and Talisman. 2) SPP Staff will send BPR018 to MOPC Exploder list for review and suggested revisions. 3) BPWG Members and participants will review BPR021 and prepare comments for next scheduled meeting. 4) BPR020, Update to Daily Non-firm On/Off-Peak Service, and Examples of Simultaneous Submission Window Allocation will be added to the agenda for the next meeting. AGENDA ITEM 10 NEXT MEETING The next meeting will be a conference call/webcast scheduled for May 19, 2011 from 1:00 pm to 4:00 pm CPT.

4 AGENDA ITEM 11 ADJOURNMENT The meeting was adjourned at 3:01 p.m. Respectfully submitted, Clint Savoy On behalf of Jimmy Womack BPWG Secretary

5 BUSINESS PRACTICES WORKING GROUP Meeting Attendance April 21, 2011 NAME ATTENDANCE STATUS COMPANY E MAIL PHONE Clint Savoy X S SPP csavoy@spp.org Jimmy Womack X S SPP jwomack@spp.org Charles Hendrix X S SPP chendrix@spp.org Chris Mann X S SPP cmann@spp.org Katy Onnen X S SPP konnen@spp.org Steve Purdy X S SPP spurdy@spp.org David Duhart X S SPP dduhart@spp.org Katherine Prewitt X S SPP kprewitt@spp.org Carrie Bumgarner X S Wright & Talisman Matt Binette X S Wright & Talisman Grant Wilkerson X M Westar Grant.L.Wilkerson@westar.com Robert Walker X M Cargill Robert_Walker@cargill.com James Hotovy X M NPPD jrhotov@nppd.com Randy Gillespie X M Kelson Energy Randy.gillespie@kelsonenergy.com Ed Hammons X M GRDA ehammons@grda.com ext 1351 Richard Ross X M AEP rross@aep.com David Adamczyk X M KCPL David.Adamczyk@kcpl.com Kevin Pera X P Xcel Energy kevin.m.pera@xcelenergy.com Mark Foreman X P Tenaska Jim Krajecki X G Customized Energy Solutions Shawn McBroom X G OKGE Lloyd Kolb X G Golden Spread Robert Anklam X G Cargill Mitch Williams X G Western Farmers Status: M Member P Proxy S SPP Staff G Guest

6 Southwest Power Pool BUSINESS PRACTICES WORKING GROUP MEETING March 9-10, 2011 AEP Offices, 1201 Elm Street, 8 th floor Dallas, TX Summary of Action Items # ACTION ITEMS ASSIGNED TO 1 Request clarification from SPP Staff (John Mills or Charles Hendrix) regarding cost allocation and NRIS. Jimmy Womack 2 Provide an update to Daily Non firm On peak/off peak transmission service. Jimmy Womack 3 Present BPR002 to the RTWG prior to the April 12, 2011 MOPC meeting, if time allows. Jimmy Womack 4 Add BPR002, BPR014, BPR018, and BPR019 to the April 12, 2011 MOPC agenda. Jimmy Womack 5 Provide specific examples of the different methods of random capacity allocation for TSRs submitted during a simultaneous submission window. Clint Savoy 6 Page 1 of 5

7 Southwest Power Pool BUSINESS PRACTICES WORKING GROUP MEETING March 9-10, 2011 AEP Offices, 1201 Elm Street, 8 th floor Dallas, TX MINUTES Agenda Item 1 Administrative Items a. BPWG Chair Grant Wilkerson called the meeting to order at 1:06 pm on March 9, There were 15 people present or on the phone representing 8 members, 1 guest, and 6 SPP Staff members. (Attachment 1-Attendance record for 3/9) Mr. Wilkerson called the meeting to recess at 5:05 p.m. On March 10, Mr. Wilkerson called the meeting back to order at 9:05 a.m. There were 12 people present or on the phone representing 8 members, 2 guests, and 2 SPP Staff members. (Attachment 2-Attendance record for 3/10) b. Ann Scott was recognized as a proxy for Kara Whillock on 3/9. Mark Foreman was recognized as a proxy for Kara Whillock on 3/10. c. Following a motion by Richard Ross and a second by Jessica Collins, the minutes from the BPWG meeting held on 12/8/2010 were approved. d. The agenda was reviewed and revised. (Attachment 3-Revised Agenda) Agenda Item 2 Review Previous Action Items a. MOPC Action Items Update i. BPR019 DTO Process this action item was discussed during this meeting as agenda item 7. ii. BPR014 Abnormal System Conditions this action item was discussed during this iii. meeting as agenda item 12. BPR021 ATP Process this action item was discussed during this meeting as agenda item 4. b. Review of Attachment O of the SPP OATT this action item was discussed during this meeting as agenda item 9. c. Daily On-Peak/Off-Peak Product update the FERC issued a Notice of Deficiency with regards to Docket No. ER in which SPP requested the ability to offer the Daily Non-firm On-Peak and Daily Non-firm Off-Peak products. The FERC requested SPP: i. Correct an error regarding the timing requirements of submitting transmission service requests for the new products, ii. iii. Explain how the daily curtailment priority afforded daily non-firm on-peak and off-peak Point-to-Point transmission service is communicated in the SPP Tariff, as well as the product s curtailment priority relative to daily 24-hour service and hourly service, Explain which rates in Attachment T of the SPP Tariff apply to daily non-firm on-peak and off-peak Point-to-Point transmission service and how this is communicated in the SPP Tariff, as well as how the SPP Tariff communicates the application of the terms on-peak and off-peak to this product with regard to the rates in Attachment T. SPP will provide the requested information to the FERC prior to the March 28, 2011 deadline. An update will be provided at the next BPWG meeting. Page 2 of 5

8 Agenda Item 3 Update on BPR001 Coordination with Third Party Katy Onnen reported to the group that SPP was ready to file the tariff language when it was noticed that the proposed tariff change would only be applicable to short term service. Since the intention of the BPR was to apply to long term transmission service, new tariff revisions must be approved. An update to this item will be given at the next BPWG meeting. Agenda Item 4 BPR021 Authorization to Plan (ATP) Process Katherine Prewitt presented the background for the Authorization to Plan and allowed for the group to ask questions and provide input. James Hotovy stressed that ATP projects should not be included in the ITP 20 model. The group recommended Ms. Prewitt work through the Transmission Working Group (TWG) to possibly draft a White Paper to be used in the further development of a Business Practice. Agenda Item 5 Generation Interconnection Questions Katherine Prewitt presented a scenario regarding generation interconnection to the group for input. The scenario was related to possibly altering the route of a planned transmission line that would pass close enough to a proposed generation station to allow the generator to connect directly to the line instead of building leads from the station to meet the originally proposed route of the transmission line. Grant Wilkerson proposed that the economics should ultimately determine the final outcome of each situation. Agenda Item 6 BPR018 Generator Interconnection Procedures Update Grant Wilkerson presented the comments from the review by the RTWG and TWG. The group discussed the comments and further revised the proposed Business Practice. Jim Hotovy made a motion to approve BPR018 as modified. The motion received a second from Robert Walker and was approved with one abstention. BPR018 will be presented to the MOPC at the meeting scheduled for April 12, Agenda Item 7 BPR019 Designated Transmission Owner Update Grant Wilkerson presented the comments from the review by the RTWG and TWG. The group discussed the comments. Grant Wilkerson made a motion to approve BPR019 as modified. The motion received a second from Robert Walker and was unanimously approved. BPR019 will be presented to the MOPC at the meeting scheduled for April 12, Agenda Item 8 BPR020 NRIS Update Grant Wilkerson presented the comments from the review by the RTWG and TWG. The group discussed the comments and further revised the proposed Business Practice. The group requested clarification of the reference to cost allocation referred to in Section 2 of the proposed Business Practice. This item will be added to the agenda of the next scheduled BPWG meeting for SPP Staff will provide clarification. Agenda Item 9 Attachment O Review Attachment O was reviewed to ensure that the attachment was correctly referenced throughout BPR019. The group agreed that Attachment O was correctly referenced throughout BPR019. Agenda Item 10 BPR002 Third Party TSR Coordination Wendy Reed of Wright & Talisman reviewed proposed changes to the suggested tariff language proposed by the BPWG through BPR002. BPR002 will be presented to the MOPC at the April 12, 2011 Page 3 of 5

9 meeting whether or not the RTWG has a chance to review the proposed tariff language. The MOPC report will state that the RTWG has not reviewed the suggested language if the RTWG does not have time to do so. Agenda Item 11 Update on Revisions to Business Practice 2.12 Renewal Rights Robert Walker reported to the group that he is waiting on the SPP Market Monitoring Unit (MMU) to complete an investigation of possible queuing practices before finalizing revisions to Business Practice Once the MMU investigation is complete and an official conclusion regarding the proper execution of preemption and competition rules with regards to renewal rights is reached, Mr. Walker will present a business practice revision request to the group. Agenda Item 12 BPR014 Abnormal System Conditions Procedures Jimmy Womack presented proposed revisions to Business Practice 6.1. Ed Hammons made a motion to send BPR014 to the MOPC as revised. The motion received a second from Jessica Collins and was unanimously approved. BPR014 will be presented to the MOPC at the meeting scheduled for April 12, Agenda Item 13 BPR022 Annulment of a TSR Clint Savoy presented proposed revisions to Business Practice 2.5. The group did not agree that a customer should not be required to pay in the event of a poor business decision, unless the reason for a short term reservation was the delay in a study. If a study delay causes the need for short term firm transmission service, it should be covered in Business Practice The group suggested possibly revising Business Practice 2.16 to include allowances for interim short term service in the event of a delay in a Delivery Point Transfer Study. Agenda Item 14 Simultaneous Submission Window Update Clint Savoy reported to the group that OATI, a provider of many SPP software systems, has a product that allocates transmission capacity to customers that submit transmission service requests (TSR) during a no earlier than simultaneous submission window. This product is an add-on module to a product that is currently being used by SPP and would increase SPP s compliance with the FERC requirement of all TSRs being submitted during a simultaneous submission window being deemed to have the same effective queued time. Mr. Savoy will provide specific examples of the different methods of random capacity allocation at the next scheduled BPWG meeting. Agenda Item 15 Business Practices Reformat Clint Savoy presented the SPP Staff proposed reformatting of the Business Practices, which would assign a new 4-digit number to each Business Practice as well as create a new categorization methodology. By allowing for the ability to insert new practices, this reformatting will prevent existing Business Practices from having to be renumbered going forward due to a new Business Practice being approved that fits between existing numbered practices. Agenda Item 16 DNR Deliverability in the Integrated Marketplace Jimmy Womack presented questions related to the deliverability of DNRs in the Integrated Marketplace to the group for input. It was pointed out that major changes in the methodology of determining AFC impacts would likely be necessary because the commonly dispatched generation methodology currently in use Page 4 of 5

10 would no longer apply, causing a need for possible software and hardware changes. SPP Staff will continue to discuss these concerns both internally and with the MWG. Agenda Item 17 Summary of New Action Items i. Mr. Womack will request clarification from SPP Staff (John Mills or Charles Hendrix) regarding cost allocation and NRIS. ii. Mr. Savoy will provide specific examples of the different methods of random capacity allocation for TSRs submitted during a simultaneous submission window. iii. Mr. Womack will provide an update to Daily Non-firm On-peak/Off-peak transmission service. iv. If time allows, SPP Staff will present BPR002 to the RTWG prior to the April 12, 2011 MOPC meeting. v. Mr. Womack will add BPR002, BPR014, BPR018, and BPR019 to the April 12, 2011 MOPC agenda. Respectfully Submitted, Jimmy Womack Secretary Page 5 of 5

11 Southwest Power Pool, Inc. BUSINESS PRACTICES WORKING GROUP MEETING April 21, :00pm to 3:00pm CDT Conference Call w/webcast AGENDA 1. Administrative Items... Grant Wilkerson a. Call to Order b. Receipt of Proxies c. Approve minutes of 3/9-10/2011 meeting d. Review the Agenda 2. Review of previous Action Items... Jimmy Womack a. Mr. Womack will request clarification from SPP Staff (John Mills or Charles Hendrix) regarding cost allocation and NRIS. b. Mr. Savoy will provide specific examples of the different methods of random capacity allocation for TSRs submitted during a simultaneous submission window. c. Mr. Womack will provide an update to Daily Non-firm On-peak/Off-peak transmission service. d. If time allows, SPP Staff will present BPR002 to the RTWG prior to the April 12, 2011 MOPC meeting. e. Mr. Womack will add BPR002, BPR014, BPR018, and BPR019 to the April 12, 2011 MOPC agenda. 3. BPR001 SPP TSR Coordination with Third Party Systems... Katy Onnen/Matt Binnette 4. BPR002 Third Party TSA Coordination... Katy Onnen/Jimmy Womack 5. BPR018-Generation Interconnection... Charles Hendrix/Carrie Bumgardner 6. PR020-NRIS... Charles Hendrix 7. BPR021 Authorization to Plan... Katherine Prewitt 8. Daily Non-Firm On/Off Peak Transmission Service Update... Jimmy Womack

12 9. MOPC Action Items... Grant Wilkerson 10. Simultaneous Submission Window Allocation Examples... Clint Savoy 11. Future Meetings... Jimmy Womack a. Currently scheduled May 25, :00 pm-3:00 pm CDT (Same day as CWG/MWG Joint Face-to-Face in Little Rock) b. May 26, 2011 (Same day as CWG/MWG Joint Face-to-Face in Little Rock and RTWG teleconference) c. May 19, :00pm-4:00pm d. June 2, 2011 No other WG Meetings currently scheduled 12. Adjourn... Grant Wilkerson

13 Business Practice Revision Request COMMENTS BPR BPR002 Number Business Practice Section(s) Requiring Revision (include Section No., Title, and Protocol Version) Impact Analysis Required (Yes or No) MMU Report Required (Yes or No) Requested Resolution (Normal or Urgent) BPR Title Third Party TSR Coordination with SPP System New business practice Normal These comments are intended to address the guidance provided by the BPWG at its October 22, 2009 meeting as well as add proposed tariff language necessary to implement this business practice. The remaining comments in this box were included in the original submittal and are included as a reference: Revision Description Clarify actions SPP is to take when TSRs for service on a third party system may impact the SPP Transmission System. These comments are to supplement the initial request and are redlines to the 09/03/09 version of the document included in the BPWG meeting materials for 09/29/09. I have attempted to consistently refer to the other transmission provider as a Third Party Transmission Provider ( TPTP ); the TPTP s study as a Third Party Transmission Study ; the service they have requested on the TPTP s system as Third Party Transmission Service. Reason for Revision SPP s current practice is unclear. Page 1 of 8

14 Business Practice Revision Request COMMENTS Tariff Implications or Changes (Yes or No; If yes include a summary of impact and/or specific changes) Criteria Implications or Changes (Yes or No; If yes include a summary of impact and/or specific changes) Credit Implications (Yes or No, and summary of impact) Possible No No Name Address Company Company Address Phone Number Fax Number BPWG Sponsor Proposed Business Practice Language Revision 2 RESERVING TRANSMISSION SERVICE 2.XX Third Party TSR Coordination with SPP Similar to SPP s own requirements under its tariff, when Third Party Transmission Providers ( TPTP ) study the provision of long term firm transmission service on their system ( Third Party Service ), it may be necessary for the TPTP to coordinate with SPP to determine the impact and upgrades that may be necessary to the SPP Transmission System. This Business Practice is intended to define the process the SPP will implement to coordinate the review of these impacts on the SPP Transmission System from Third Party Service in accordance with proposed Attachment AS. Business Practice Page 2 of 8

15 Business Practice Revision Request COMMENTS (1) The appropriate contact ( SPP Contact ) to evaluate third party impacts on the SPP Transmission System is as follows: Manager, Tariff Studies Southwest Power Pool 415 North McKinley, # 140 Plaza West Little Rock, AR Phone Fax This information may be revised from time to time by the SPP staff as necessary to reflect the current contact information and revisions do not require the approval of the BPWG or MOPC. (2) SPP will contact the appropriate transmission representative from each Third Party Transmission Provider (TPTP) for first and second tier interconnects to the SPP Transmission System and indicate: a. Request that the SPP Contact be notified of any studies of sales of Long Term Firm transmission service by the TPTP that may impact the SPP Transmission System or any planned changes to the TPTP s transmission system. b. Provide a the TPTP a copy of the SPP OATT, Business Practices and references to the sections addressing SPP s evaluation of the impacts of Third Party Service on the SPP Transmission System. c. Request that the TPTP notify its customers of SPP s requirements provided in item 2b of this Business Practice.. (3) When notified of a Third Party Service request that may impact the SPP Transmission System, the SPP will perform a review of the TPTP s study to determine if the study and modeling of the SPP system provides an accurate representation of the impact to the SPP Transmission System. After this review several outcomes are possible: a. If SPP determines the TPTP study does not accurately evaluate the impact of the Third Party Service on the SPP Transmission System, further study will be required as outlined in step 4 of this Business Practice. b. If SPP determines the TPTP study does accurately reflect the impact of the Third Party Service on to the SPP transmission System and the customer agrees to be bound by the TPTP study, then SPP may rely on the results of the study in lieu of conducting its own study. SPP will then tender a Sponsorship Agreement in accordance with Attachment J Section V Paragraph A, under which the Customer agrees to sponsor the construction of upgrades on the SPP Transmission System Page 3 of 8

16 Business Practice Revision Request COMMENTS identified by in the study. If the Customer executes the Sponsorship Agreement within 60 days, SPP will notify the third party transmission provider that the Customer has mitigated the impact on the SPP Transmission System caused by the Third Party Service. If the Customer fails to execute the Sponsorship Agreement within 60 days, SPP will withdraw the service agreement and notify the TPTP that the impact of the Third Party Service has not been mitigated. SPP shall also request that the TPTP notify the SPP Contact if any service agreements related to the Third Party Service are issued or filed at FERC. (4) Upon determination by SPP that the Third Party Service requires furthers study or indication that the customer does not agree with TPTP study, the SPP will provide the customer with two options under which it may proceed: a. Request stand-alone study independent of SPP s Aggregate Studies as outlined in step 5 of this Business Practice. b. Request that SPP incorporate the review into the aggregate study whose submission window is open at the time. To implement this option the Customer submitting an SPP Transmission Service Request on the SPP OASIS that will then be included into the currently open aggregate transmission service study. The SPP TSR should be of type sponsored. SPP will study the impact and assign costs for upgrades on the same basis as is utilized by SPP for requests for longterm firm service on the SPP system. When the aggregate study is complete, SPP will then tender a Sponsorship Agreement in accordance with Attachment J Section V Paragraph A, under which the Customer agrees to sponsor the construction of the Directly Assigned Upgrades on the SPP Transmission System identified in the study. If the Customer executes the Sponsorship Agreement within 60 days, SPP will notify the third party transmission provider that the Customer has mitigated the impact on the SPP Transmission System caused by the Third Party Service. If the Customer fails to execute the Sponsorship Agreement within 60 days, SPP will withdraw the service agreement and notify the TPTP that the impact of the Third Party Service has not been mitigated. SPP shall also request that the TPTP notify the SPP Contact if any service agreements related to the Third Party Service are issued or filed at FERC. (5) If the Customer request a stand-alone study: a. The Customer will execute a system impact and facilities study agreement under which it agrees to pay for the costs of performing the study. b. SPP will perform a system impact study and, if necessary, facilities study to determine the upgrades necessary on the SPP system ( Study ). Such an impact study will be completed within 60 days and, if necessary, will provide details of the costs and timeline for completion of upgrades on the SPP Transmission System. Page 4 of 8

17 Business Practice Revision Request COMMENTS c. If the Study determines there is no impact or that no upgrades are necessary, SPP will notify the TPTP that no further mitigation is necessary for the Third Party Service. d. If the Study determines upgrades are necessary, SPP will notify the third party transmission provider mitigation is necessary before the Third Party Service is confirmed. SPP shall also request that the TPTP notify the SPP Contact be notified if any service agreements related to the Third Party Service are issued or filed at FERC. e. SPP will then tender a Sponsorship Agreement in accordance with Attachment J Section V Paragraph A, under which the Customer agrees to sponsor the constructions of the Directly Assigned Upgrades necessary on the SPP Transmission System. f. If the Customer executes the Sponsorship Agreement within 60 days, SPP will notify the TPTP that the Customer has mitigated the impact on the SPP Transmission System caused by the Third Party Service. If the Customer fails to execute the Sponsorship Agreement within 60 days, SPP will withdraw the service agreement and notify the Customer that the study is no longer valid. Explanation / Rationale None Example None Proposed Tariff Language Revision 1.9b Directly Assigned Upgrade Costs: An Eligible Customer s share of the cost of a Service Upgrade or a Project Sponsor s share of the cost of a Sponsored Upgrade, determined in accordance with Attachments J, Z1 and AS, including: (i) any costs directly assigned to an Eligible Customer for a Service Upgrade in excess of the normally applicable transmission Formatted: Underline Page 5 of 8

18 Business Practice Revision Request COMMENTS access charges for the associated transmission service; (ii) any costs directly assigned to an Eligible Customer that are in excess of the Safe Harbor Cost Limit for Service Upgrades associated with new or changed Designated Resource; (iii) any costs directly assigned to a Project Sponsor for a Sponsored Upgrade; and (iv) any costs directly assigned to a customer necessary to mitigate the impact on the SPP Transmission System for service being requested on other transmission providers transmission systems. 1.36b Project Sponsor: One or more entities that voluntarily agree to bear a portion or all of the costs of a Sponsored Upgrade. 1.42a1 Sponsored Upgrades: Network Upgrades, requested by a Transmission Customer or other entity, which do not meet the definition of any other category of Network Upgrades. NEW OATT Attachment AS Affected System Study Procedures and Cost Allocation and Recovery for System Upgrades I. Introduction II. Attachment AS describes the process used to evaluate the impact of transmission services being requested on other transmission providers systems that may impact the Transmission System. In such situations, the Transmission Provider will request that either the other transmission provider or the customer requesting services from the other transmission provider ( Other Customer ) request that the Transmission Provider study the impact of the requested service on the Transmission System. Affected System Study Procedures In instances where service being requested from other transmission provider(s) impacts the Transmission System, the Transmission Provider will request that the Other Customer requesting the service enter into an Affected System Study agreement with the Transmission Provider to determine the impact to the Transmission System and, if necessary, identify construction upgrades necessary to mitigate the impact. Where the Other Customer executes the Affected System Study agreement tendered by the Transmission Provider, the Transmission Provider will perform the Affected System Study to determine any impact and identify any necessary Directly Assigned Upgrades to mitigate the impact using one of the following study methods as determined by the Transmission Provider and the Other Customer: Formatted: Underline Formatted: Centered Comment [CPS1]: Add disclaimer regarding this being only applicable where a comprehensive Seams Agreement does not exist. Formatted: Bullets and Numbering Deleted: This a Formatted: Indent: Left: 54 pt Deleted: which Deleted: SPP Deleted: SPP Deleted: the Deleted: will be required to Deleted: SPP Deleted: SPP Formatted: Numbered + Level: 1 + Numbering Style: I, II, III, + Start at: 1 + Alignment: Left + Aligned at: 18 pt + Tab after: 54 pt + Indent at: 54 pt Formatted: Bullets and Numbering Deleted: The Transmission Provider Formatted: Indent: Left: 54 pt Deleted: SPP will Deleted: monitors the services being requested and/or studied on adjacent transmission systems to identify requests that may impact line loading on the Deleted: SPP Deleted: Transmission System. Deleted: the Deleted: SPP Deleted: SPP Deleted: require Deleted: c Deleted: s Deleted: SPP Deleted: SPP Deleted: the Deleted: SPP Deleted: the Deleted: the Deleted: necessary Deleted: on Deleted: SPP Deleted: c Page 6 of 8

19 Business Practice Revision Request COMMENTS III. a. Utilize studies conducted by the other transmission provider if they are determined by the Transmission Providerto provide a valid representation of the impact to the Transmission System and if agreed to by the Other Customer; b. Conduct a Facilities Study pursuant to a Facilities Study agreement executed by the Other Customer c. Incorporate the request into an Aggregate Facility Study conducted by the Transmission Provider as part of the Aggregate Transmission Service Study procedures outlined in Attachment Z1. Sponsorship of Upgrades If the Affected System Study determines there are impacts and the Other Customer agrees to mitigation, the Other Customer will be responsible for the Directly Assigned Upgrade cost necessary to mitigate the impact to the Transmission System and become a Project Sponsor of the Directly Assigned Upgrade(s) as outlined in Attachment J Section V Paragraph A. Formatted: Numbered + Level: 2 + Numbering Style: a, b, c, + Start at: 1 + Alignment: Left + Aligned at: 54 pt + Tab after: 72 pt + Indent at: 72 pt Formatted: Bullets and Numbering Deleted: SPP o provide a valid representation... [1] of Deleted: stand alone f acilities y s tudy... [2] Deleted: a ggregate f acility s tudy conducted... [3] Formatted: Numbered + Level: 1 + Numbering Style: I, II, III, + Start at: 1 + Alignment: Left + Aligned at: 18 pt + Tab after: 54 pt + Indent at: 54 pt Formatted: Indent: Left: 54 pt Deleted: T he Other c ustomer will be... [4] IV. Upon completion of the study procedures outlined in Section II a or b, the Transmission Provider will tender to the Other Customer an agreement for a Sponsored Upgrade. The Other Customer will have 60 days to execute the agreement for a Sponsored Upgrade once tendered by the Transmission Provider. Upon completion of the study procedures outlined in Section II c, the Transmission Provider will tender to the Other Customer an agreement for a Sponsored Upgrade. The Other Customer will have the time outlined in Attachment Z1 and being applied to all Customers with requests in the applicable aggregate study to execute the agreement. Mitigation of Impacts and Notification to Other Transmission Provider In the event the Affected System Study conducted pursuant to Section II determines no mitigation is required or upon execution of an agreement for a Sponsored Upgrade pursuant to Section III, the Transmission Provider will notify the other transmission provider that the impact to the Transmission System has been mitigated. V. Withdrawal In the event the Other Customer refuses to study or mitigate any impact pursuant to this Attachment AS, the Transmission Provider will notify the other transmission provider that impacts have not been mitigated and will request that the other transmission provider notify the Transmission Provider of any service agreement for the service request on the other transmission provider s transmission system that is tendered to the Other Customer or filed at the Commission. Deleted: ely on of the study procedures outlined... [5] Deleted: other c Formatted: Bullets and Numbering Formatted: Indent: Left: 54 pt Deleted: s tudy conducted as outlined in... [6] Deleted: SPP Deleted: SPP ransmission s... [7] Formatted: Numbered + Level: 1 + Numbering Style: I, II, III, + Start at: 1 + Alignment: Left + Aligned at: 18 pt + Tab after: 54 pt + Indent at: 54 pt Formatted: Bullets and Numbering Formatted: Indent: Left: 54 pt Deleted: c ustomer requesting service on other... [8] Deleted: will consider the request withdrawn. [I am not sure what to do with this one. I do not think there will be a request on the SPP system to withdraw.] In such situations, Deleted: SPP Deleted: the Transmission Provider Deleted: the mpacts has e not been mitigated... [9] Page 7 of 8

20 Business Practice Revision Request COMMENTS Deleted: Page 8 of 8

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24 Business Practice Revision BPR BPR020 Number Business Practice Section(s) Requiring Revision (include Section No., Title, and Protocol Version) Impact Analysis Required (Yes or No) MMU Report Required (Yes or No) Requested Resolution (Normal or Urgent) Revision Description BPR Title New BP No No Normal Network Resource Interconnection Service The purpose of this Network Resource Interconnection (NRIS) Business Practice is to establish the rules and procedures regarding the study process and the integration of NRIS facilities into the SPP Transmission System. The white paper will describe the differences between Energy Resource Interconnection Service (ERIS) and NRIS. Reason for Revision SPP staff identified the need to incorporate the NRIS rules and procedures into the Business Practices Tariff Implications or Changes (Yes or No; If yes include a summary of impact and/or specific changes) Criteria Implications or Changes (Yes or No; If yes include a summary of impact and/or specific changes) Credit Implications (Yes or No, and summary of impact) No changes, drafted from existing Tariff language No No Name Address Company Company Address Sponsor Jimmy Womack on behalf of SPP staff jwomack@spp.org SPP Page 1 of 5

25 Phone Number Fax Number Business Practice Revision Proposed Business Practice Language Revision X.XX NETWORK RESOURCE INTERCONNECTION SERVICE Network Resource Interconnection Service is provided by SPP pursuant to Section of the Generator Interconnection Procedures (Attachment V). Process and procedure guidelines have been established in order to attain a common understanding regarding the study process and the integration of NRIS facilities into the SPP Transmission System. Differences between Energy Resource Interconnection Service (ERIS) and NRIS are also identified. Deleted: By Deleted: section of the SPP OATT Business Practice CURRENT DAY RULES AND PROCEDURES: 1) Energy Resource Interconnection Service (ERIS) will be studied based on Attachment V of the SPP OATT, using various percentages of Generation Interconnection request values spread to the entire SPP footprint based on the load ratio share of the Transmission Owner zones. Upgrades required to interconnect the ERIS generating facility will be cost allocated based on 20% TDF. 2) Network Resource Interconnection Service (NRIS) facilities will be studied based on two different analyses through Attachment V of the SPP Open Access Transmission Tariff (OATT), 1) using the nameplate amount of the resource to the interconnection host zone. Upgrades required to interconnect for analysis will be identified and cost assigned based on 3% TDF and 2) using various percentages of nameplate values spread to the entire footprint based on the load ratio share of the Transmission Owner zones. Upgrades required to interconnect for analysis will be identified and cost allocated based on 20% TDF. 3) Once interconnection is complete, there is no difference between SPP Operations treatment of generating facilities regardless of generation interconnection type (NRIS or ERIS). Deleted: nameplate Comment [j1]: RTWG: Where is the 20% documented? Tariff, GI, AG study? Comment [CPS2]: What is meant by cost allocated? Why is assigned not used? Deleted: allocated Comment [j3]: Check the enumeration/punctuation of this paragraph. Comment [j4]: Same as comment 1, where is the 20% documented? Deleted: T Deleted: handling Comment [j5]: RTWG member comment: All ERIS are studied as future NR s per RTWG. This section may not be needed at all. Deleted: of Deleted: Deleted: and Deleted: generating facilities Deleted: NRIS shows the customer s intent to be a Designated Resource and ERIS does not. In addition, the Formatted: List Paragraph, Space After: 0 pt, Line spacing: single, No bullets or numbering Page 2 of 5

26 Business Practice Revision 4) Neither NRIS nor ERIS guarantees transmission service or deliverability pursuant to Part II or Part III of the SPP OATT. Transmission service must be requested and studied through the same process as any other Designated Resource wanting to deliver energy to a specified point (Point-To-Point Transmission Service) or to a specified Network (Network Integrated Transmission Service). 5) Base Plan funding determinations for Base Plan Upgrades are subject to limits stated in Attachments Z2 and J of the SPP OATT. Upgrades required to attain either NRIS or ERIS are not eligible for Base Plan funding. Future Procedure consideration: 1) Current business rules will change once the new SPP Day Ahead Market is implemented. Definitions Designated Resource: Any designated generation resource owned, purchased or leased by a Transmission Customer to serve load in the SPP Region. Designated Resources do not include any resource, or any portion thereof, that is committed for sale to third parties or otherwise cannot be called upon to meet the Transmission Customer's load on a noninterruptible basis. Energy Resource Interconnection Service: An Interconnection Service that allows the Interconnection Customer to connect its Generating facility to the Transmission System to be eligible to deliver the Generation Facility s electric output using the existing firm or nonfirm capacity of the Transmission System on an as available basis. Energy resource Interconnection Service in and of itself does not convey transmission service. Firm Transmission Service: The highest quality (priority) service offered to customers under a filed rate schedule that anticipates no planned interruption. Comment [j6]: Is this a true statement? If so make it more general, the acceptance may increase the ability to deliver, not necessarily be a DR. Deleted: <#> higher level of integration attained by an NRIS unit may increase the likelihood of becoming a DR over that of an ERIS unit through avoidance of necessary congestion mitigation. However, there is no guarantee that additional upgrades will not be required to attain service as a DR. Deleted: Base Plan funding determinations for Base Plan Upgrades are subject to limits stated in Attachments Z2 and J of the SPP OATT. Comment [j7]: Can the GI designate as a DR? Comment [j8]: Bad statement, any TC may request and receive service. Comment [j9]: Since this is for day 2 market this should be removed. Deleted: <#>NRIS and ERIS generating facilities have equal abilities to Deleted: <#>request and Deleted: <#>receive Long-Term Service as Designated Resources in accordance with Attachment Z1 of the SPP OATT. NRIS and ERIS generating facilities have equal abilities to request and receive Short-Term Service based on the methodology as described in Attachment C and the reservation processing method described in Attachment AC of the SPP OATT. <#>The new SPP Day Ahead Market will allow NRIS and ERIS generating facilities to use the hedging rights being considered as long as the generating facility has been granted Long-Term Service or Short-Term Service longer than a month. All Long-Term Service and Grandfathered Agreements or Transactions will be Deleted: <#>provided Deleted: <#>eligible for hedging rights on a yearly basis at the first of each SPP fiscal year. Any remaining hedging rights will be allocated on a first come first served basis to Short-Term Service of a month or longer. Comment [j10]: Are all of these in the Tariff? If so do they need to be here. Grandfathered Agreements or Transactions: Grandfathered Agreements or Transactions include (1) agreements providing long term firm transmission service executed prior to April 1, 1999 and Network Integration Transmission Service executed prior to February 1, 2000; (2) bundled wholesale contracts (that reserve transmission as part of the contract); (3) short-term firm and non-firm point-to-point transmission transactions which were accepted and confirmed prior to the Effective Date; (4) existing or new contracts entered into by the Southwestern Power Administration on behalf of the United States for the use of transmission facilities of the Southwestern Power Administration that are constructed or acquired by purchase or other agreement, as Page 3 of 5

27 Business Practice Revision authorized under Section 5 of the Flood Control Act of 1944, for the transmission of Federal Power; and (5) contracts executed before the Effective Date, regardless of term, entered into by the Southwestern Power Administration on behalf of the United States for the transmission of power or energy across transmission facilities owned and operated by the Southwestern Power Administration; (6)contracts entered into by a Nebraska publicpower entity prior to the transfer of functional control of its transmission facilities to the Transmission Provider; (7) existing contracts entered into by a Member which is a Nebraska public-power entity with any retail or wholesale electric utility customer that has a right under state law to obtain electric transmission service or energy service from such Member; and (8) new contracts entered into by a Member which is a Nebraska public-power entity with any retail or wholesale electric utility customer that has a right under state law to obtain electric transmission service or energy service from such Member to the extent that provision of service under the Tariff would not satisfy such Member s obligation under state law. These agreements are set forth on the list which is Attachment W to this Tariff. Umbrella service agreements are specifically not Grandfathered. Long-Term Service: Long-Term Firm Point-To-Point Transmission Service or Network Integration Transmission Service of one year or longer in duration. Network Integration Transmission Service: Service that allows an electric transmission customer to integrate, plan, economically dispatch and regulate its network reserves in a manner comparable to that in which the Transmission Owner serves Native Load customers. This transmission service is provided under Part III of the SPP Tariff. Network Resource Interconnection Service: An Interconnection Service that allows the Interconnection Customer to integrate its Generating Facility with the Transmission System in a manner comparable to that in which the Transmission Owner integrates its generating facilities to serve Native Load Customers as a Network Resource. Network Resource Interconnection Service in and of itself does not convey transmission service. Non-Firm Transmission Service: Transmission service that is reserved on an asavailable basis and is subject to curtailment or interruption. OATT: Open Access Transmission Tariff Part II: Tariff Sections 13 through 27 pertaining to Point-To-Point Transmission Service in conjunction with the applicable Common Service Provisions of Part I and appropriate Schedules and Attachments. Page 4 of 5

28 Business Practice Revision Part III: Tariff Sections 28 through 36 pertaining to Network Integration Transmission Service in conjunction with the applicable Common Service Provisions of Part I and appropriate Schedules and Attachments. Point-To-Point Transmission Service: The reservation and transmission of capacity and energy on either a firm or non-firm basis from the Point(s) of Receipt to the Point(s) of Delivery under Part II of the SPP Tariff. Short-Term Service: Short-Term Firm Point-To-Point Transmission Service or Network Integration Transmission Service of less than one year in duration. SPP: The Southwest Power Pool, Inc. Transmission System: The facilities used by the Transmission Provider to provide transmission service under Part II, Part III and Part IV of the SPP Tariff. SPP OATT References: Part II Part III Attachment C Attachment J Attachment V Attachment AC Attachment Z1 & Z2 Page 5 of 5