Southwest Power Pool PROJECT COST WORKING GROUP MEETING June 7, 2017 AEP Offices, Dallas, TX M I N U T E S

Transcription

1 Minutes No. [66] Southwest Power Pool PROJECT COST WORKING GROUP MEETING June 7, 2017 AEP Offices, Dallas, TX M I N U T E S Agenda Item 1 Administrative Items a. Call to Order & Introductions Chair Tom Hestermann (SECI) called the meeting to order at 9:00 a.m., welcomed those in attendance, and asked for introductions (Attachment 1 - PCWG Attendance ). b. Receipt of Proxies SPP Staff Secretary Bryce Bowie indicated there were four proxies: Jeff Kunkel (for Kenny Munsell), Scott Rainbolt (for Brian Johnson), Brenda Jessop (for Al Ackland), James Ging (for Larry Holloway). c. Review of Agenda The Chair asked the PCWG for edits or additions to the agenda (Attachment 1a - PCWG Agenda ) and there were none. John O Dell suggested a change to the agenda and requested that the group table item #12 until the July meeting. Tom Hestermann agreed that the item was tabled until July. Agenda Item 2 Review of Past Action Items (this was skipped until after Agenda item #5) The Staff Secretary led a review of the action item list for May (Attachment 2 - PCWG Action Items ). Art Weise stated that Action Item #166 should include the 2.5% applied to Q1. Agenda Item 3 Consent Agenda Tom Hestermann called upon the group to review the consent agenda and asked for modifications. Scott Rainbolt mentioned that Brian Johnson had requested wording changes to escalation. Tom Hestermann indicated that Brian should send the requested changes to SPP staff. Staff will include the May 3 Meeting Minutes in the background materials for the July meeting. Agenda Item 4 RR Process Update Tom Hestermann called on Aaron Shipley (via telephone) to present the RR process document to the group. Brian Studenka informed the group that his group had abstained during the vote concerning the RR process document at BPWG, and that he would be abstaining if this were to come to a vote during the PCWG meeting for consistency. Tom Hestermann stated that he was open to ideas for change if anyone had ideas. He then asked for a motion to endorse the document. No motion was made and there were no objections. Aaron Shipley concluded this segment. Agenda Item 5 Review of NTC Re-evaluation and Cost Estimate Flowchart John O Dell led a discussion and asked the group how they would like to proceed. He mentioned that the timing would be determined by the scope, but that the scope was not yet approved. Brenda Jessup echoed concern that we can t know the timing if the scope is not approved. Discussion ensued. The

2 Minutes No. [66] group indicated that they would like graphics/visuals to be added. SPP Staff was charged with taking the addition of a flowchart as an action item. Agenda Item 6 Quarterly Report Review (Approval Item)* Tom Hestermann requested the review of the quarterly report. John O Dell led a discussion regarding the report. Scott Rainbolt asked if SPP staff had corrected the numbers in Appendix 1. John O Dell confirmed the corrections had been made. Brenda Jessup suggested that the font color of the numbers (negative and positive) should be red (negative) and black (positive). John O Dell made the change. Brian Studenka centered discussion briefly on the Potash Junction to Road Runner project. Brenda Jessup wanted to know when escalation stopped. Discussion ensued regarding escalation. An action item was taken by SPP staff to determine what flag stops escalation. John O Dell continued the discussion about the Quarterly Report and more minor changes were requested, such as, a change of font color in the Active Applicable Projects Summary by Source Study Agenda Item 7 XFR - Ft Smith 500/161 kv Ckt 3 Review (Approval Item)* John O Dell led the discussion of this project with input from Peter Day. After a lengthy discussion of the reasons why the project was out of bandwidth, action items were taken. SPP staff was tasked with identifying this as a Legacy Project and was also charged with determining the source(s) of funding. Boyd Trester (on the phone) mentioned that this needed to be added to the report, and Tom Hestermann tasked SPP staff to ensure that it would be added. Tom Hestermann asked for a motion to accept the project as presented. Art Wiese moved and Brian Studenka seconded to approve the project as presented. Jeff Kunkel abstained from the vote. The motion passed with no opposition. Agenda Item 8 Multi - Chisholm - Gracemont 345 kv Review (Approval Item)* John O Dell led the discussion of this project with input from Scott Rainbolt. After discussion, Tom Hestermann asked for a motion to accept the project as presented. Art Wiese moved and Jeff Kunkel seconded to approve the project as presented. The motion passed unanimously. Agenda Item 9 Multi - Hoskins - Neligh 345 kv (Approval Item)* John O Dell led the discussion of this project with input from Art Wiese. After discussion, Tom Hestermann asked for a motion to accept the project as presented. Scott Rainbolt moved and Peter Day seconded to approve the project as presented. The motion passed unanimously. Agenda Item 10 Multi - Viola 345/138kV Transformer and 138 kv Lines (Approval Item)* John O Dell led the discussion of this project with input from Brenda Jessup. After discussion, Tom Hestermann asked for a motion to accept the project as presented.

3 Minutes No. [66] James Ging moved and Art Wiese seconded to approve the project as presented. The motion passed unanimously. At the conclusion of the project review, Tom Hestermann charged SPP staff with updating the report to include the out-of-bandwidth projects and the PCWG recommendations to the Quarterly Report and sending it back out to the group for review and an vote by the 13 th of June. The PCWG is to have all suggestions back to SPP by June 19 th. SPP staff is to have all suggested changes made by June 21 st, and voting ends on June 27 th. Tom Hestermann asked for a motion to approve the plan and dates for the voting process. Peter Day moved and Art Wiese seconded to approve the plan and dates for the voting process as presented. The motion passed unanimously. Agenda Item 11 Review of Estimate Aging and +/- 10 Projects report sections Bryce Bowie led a discussion regarding the Estimate Aging report. John O Dell was tasked with creating a spreadsheet with which SPP staff could ask for updated estimates from projects with estimates that have not changed for some time. Discussion ensued regarding updates in TAGIT/SCERT. Brenda Jessup requested that communication to the PCWG for specific UIDs commence for projects with less than 24 months to in service date that have no cost estimate changes submitted. It was suggested that progress should be made before the next PCWG call regarding this effort. Agenda Item 12 Discussion of Quarterly Project Tracking Schedule* This item was tabled until the July, 2017 PCWG call. Agenda Item 13 Other Items Tom Hestermann asked the group for other items to be discussed. No items were raised. Agenda Item 14 Summary of Action Items SPP staff to determine what change in the QPT process stops escalation of baseline cost estimate Staff to research creation of a report that identifies projects 24 months or less from in-service date for which cost estimates have not been updated Staff to identify XFR-Ft. Smith 500/161 kv Ckt 3 as Legacy Project in the PCWG report and verify funding source Staff to provide revision of PCWG report draft by 6/13/2017, collect revision requests by 6/19/2017, and provide final copy for vote to PCWG by 6/21/17. Votes for approval of the report will be returned to staff by 6/27/2017 for inclusion in MOPC materials Staff to verify that NDAs are on hand for all PCWG members. Staff will request NDAs from those SPP does not have on file Agenda Item 15 Develop Agenda for Next Meeting Tom Hestermann stated three specific items to be discussed at the next meeting: 1. The Quarterly Project Tracking Schedule 2. The NTC Re-evaluation Flowchart

4 Minutes No. [66] 3. The continuation of the discussion regarding the Estimate Aging Report Josh Monroe was tasked with sending the NDA forms to the group to ensure that a Confidentiality Agreement was on file for all new people in the group. Agenda Item 16 Future Meeting Dates and Locations Tom Hestermann briefly discussed the next meeting dates and locations with the group. Tom Hestermann adjourned the meeting at 1:27.

5 PCWG Attendance June 7, 2017 X= In person P= Proxy T=Teleconference First Name Last Name Position Company Business Phone Attendance Tom Hesterman Chair Sunflower X Bryce Bowie Secretary SPP X Allen Ackland Member KCPL Peter Day Member OGE X Randy Diedi Member WAPA X Larry Holloway Member KPP David Insinger Member OPPD X Brian Johnson Member AEP Brenda Jessop Member Westar Energy X/P Jonah Martin Member Tri-State G&T X Kenny Munsell Member Xcel Energy Brian Studenka Member ITCGP X Boyd Trester Member Basin Electric T Art Wiese Member NPPD X

6 PCWG Attendance June 7, 2017 First Name Last Name Position Company Business Phone Attendance Liaison Shawnee Claiborn-Pinto Member Texas PUC X James Ging Guest KPP jging@kansaspowerpool.org P Scott Rainbolt Guest AEP skrainbolt@aep.com P Jeff Kunkel Guest Xcel Energy Jeffrey.R.Kunkel@xcelenergy.com P Clarence Suppes Guest Sunflower cdsuppes@sunflower.net X Angie Anderson Guest Sunflower aanderson@sunflower.net X Jason Chaplin Guest OCC X Bruce Cude Guest Xcel Energy bruce.cude@xcelenergy.com X Marisa Choate Guest SPP mchoate@spp.org T Chris Cranford Guest SPP ccranford@spp.org T Aaron Shipley Guest SPP ashipley@spp.org T Jason Mazigian Guest BEPC jmazigian@bepc.com T John O Dell Guest SPP jodell@spp.org X Josh Monroe Guest SPP jmonroe@spp.org X

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9 Southwest Power Pool, Inc. PROJECT COST WORKING GROUP Pending Action Items Status Report May 3, 2017 Action Item Date Originat ed Status Comments 13 As directed by MOPC at the January meeting, review and recommend any changes to the Quarterly Tracking Report process, including timing, data requested, format of data reporting, interaction with other project cost-related initiatives, etc. 163 Staff to modify the Quarterly Report, adding the following sections: February 7, 2012 Ongoing MOPC Action item complete. Ongoing project to identify improvements Estimate Aging Report Projects that are +/- 10 of the Baseline Estimate December 7, 2016 In Progress Agenda item for the June 2017 face-to-face meeting 166 Staff to develop: Flowchart of Cost Estimate timeline Timeline of the NTC Re-evaluation Process Add descriptor to chart for application of escalation 168 SPS to provide cost update for the Multi - Potash Junction - Road Runner 230/115 kv Ckt 1 project March 1, 2017 March 1, 2017 In Progress In Progress Agenda item for the June 2017 face-to-face meeting Timing concerns for cost estimates Cost update captured in the Q process 170 Staff to research creation of a report that identifies projects 24 months or less from in-service date for which cost estimates have not been updated. June 7, 2017 In Progress 171 Staff to identify which part of the QPT process triggers escalation of baseline to stop. June 7, 2017 In Progress 172 Staff to identify XFR-Ft. Smith 500/161 kv Ckt 3 as Legacy Project in the PCWG report and verify funding source. June 7, 2017 In Progress

10 Action Item Date Originat ed Status Comments 173 Staff to provide revision of PCWG report draft by 6/13/2017, collect revision requests by 6/19/2017, and provide final copy for vote to PCWG by 6/21/17. Votes for approval of the report will be returned to staff by 6/27/2017 for inclusion in MOPC materials. June 7, 2017 In Progress 174 Staff to verify that NDAs are on hand for PCWG members. Staff will request NDAs from those SPP does not have on file. June 7, 2017 In Progress

11 Southwest Power Pool, Inc. PROJECT COST WORKING GROUP NET CONFERENCE June 7, 2017 AEP Office, Dallas A G E N D A 9:00 am 3:00 pm 1. Administrative Items... (5 min) a. Call to Order & Introductions... Tom Hestermann b. Receipt of Proxies... Bryce Bowie c. Review of Agenda*... Tom Hestermann 2. Review of Past Action Items*... Bryce Bowie (5 min) 3. Consent Agenda (Approval Item)*... Tom Hestermann (5 min) a. Approval of Meeting Minutes May 3, RR Process Update*... Aaron Shipley (30 min) 5. Review of NTC Re-evaluation and Cost Estimate Flowchart... SPP Staff (30 min) 6. Quarterly Report Review (Approval Item)*... John O Dell (20 min) 7. XFR - Ft Smith 500/161 kv Ckt 3 Review (Approval Item)*... John O Dell (20 min) 8. Multi - Chisholm - Gracemont 345 Kv Review (Approval Item)*... John O Dell (20 min) 9. Multi - Hoskins - Neligh 345 kv (Approval Item)*... John O Dell (20 min) 10. Multi - Viola 345/138kV Transformer and 138 kv Lines (Approval Item)*... John O Dell (20 min) 11. Review of Estimate Aging and +/- 10 Projects report sections... All (30 min) 12. Discussion of Quarterly Project Tracking Schedule*... John O Dell (30 min) 13. Other Items... All 14. Summary of Action Items... Bryce Bowie (2 min) 15. Develop Agenda for Next Meeting... Tom Hestermann (5 min) 16. Future Meeting Dates and Locations... All (5 min) July 5 Net Conference August 2 Net Conference * Background Materials Included Relationship-Based Member-Driven Independence Through Diversity Evolutionary vs. Revolutionary Reliability & Economics Inseparable

12 S P P R e v i s i o n R e q u e s t P r o c e s s October 6, 2016May 16, 2017 Market Operations and Policy Committee

13 Southwest Power Pool, Inc. Revision History Version Number Author Change Description 1.0 Market Design, Erin Cathey Initial Draft 2.0 Erin Cathey Process updates for clarity, grammatical updates, removal of BOD as required approver for changes to RR Process, additions to Qualified Entity definition, removal of timing to appeal MOPC decision to BOD 3.0 Erin Cathey Updating to include Criteria split to Operating and Planning Protocols 4.0 Erin Cathey Grammatical revisions, clarifying revisions, updates to actions allowed by Primary Working Groups, Secondary Working Groups, MOPC and BOD, added RR submission timeline, added comment submission timeline, added language to more clearly prescribe handoffs and responsibilities, added section to define table/postpone 5.0 Aaron Shipley Adding Project Cost Working Group as a Primary Working Group Adding the following documents to the Revision Request Process: The Minimum Transmission Design Standards for Competitive Upgrades; Revision Request Process; and ITP Manual Adding the following documents to the RR Process to be effective once approved by Primary Working Group and subject to MOPC appeal process: Reliability Coordinator and Balancing Authority Data Specifications ( RDS ), SPP Communications Protocols Page 2 of 13

14 Southwest Power Pool, Inc. Table of Contents Revision History... 2 SPP Revision Request Process... 4 Submission of a Revision Request...54 Review and Posting of Revision Requests... 5 Routing Criteria for a Revision Request... 6 Written Comments on a Revision Request... 6 Impact Analysis... 7 Primary Working Group Review and Action Secondary Working Group Review and Action... 9 Market and Operations Policy Committee Action SPP Board of Directors Review and Action Tabling or Postponing a Revision Request Withdrawal of an Revision Request Expedited Review Requests Urgent Action Requests Appeal of Decision FERC Filings Page 3 of 13

15 Southwest Power Pool, Inc. SPP Revision Request Process A request to make additions, deletions, revisions, or clarifications to the following governing documents SPP Business Practices, SPP Operating Criteria, SPP Planning Criteria, SPP Market Protocols, and SPP Tariff including any attachments and exhibits to these identified documents, except for Appendix F of the Market Protocols, is called a Revision Request ( RR ). Appendix F contains Settlement examples and will be updated by SPP as necessary. A request to make additions, deletions, or changes to the selected SPP documents and, unless noted their attachments, is governed by the SPP Revision Request Process outlined in this document. Any such changes are generally referred to as a Revision Request ( Revision Request or RR ). The SPP documents subject to this procedure, at this time, are: SPP Tariff SPP Operating Criteria SPP Planning Criteria SPP Market Protocols, eexcept for Appendix F Settlement examples which may be updated by SPP Staff as necessary SPP Business Practices SPP Minimum Transmission Design Standards for Competitive Upgrades ( MTDS ) SPP Integrated Planning Manual ( ITP Manual ) SPP Revision Request Process Unless specifically provided in other sections of these identified documents, aall changes to the Business Practices, Operating Criteria, Planning Criteria, Market Protocols and SPP Tariff to these identified documents shall follow the SPP Revision Request Process. The Business Practice Working Group ( BPWG ), Market Working Group ( MWG ), Operating Reliability Working Group ( ORWG ), Regional Tariff Working Group ( RTWG ), and the Transmission Working Group ( TWG ), and Project Cost Working Group ( PCWG ) will review and approve all changes to the SPP Revision Request Process prior to the Markets and Operations Policy Committee (MOPC) approval of the changes. Revision Requests to these documents will be presented to the SPP Working Groups as outlined in the Revision Request Routing Criteria, which can be found on spp.org.. This section lists the documents that have been placed under the Revision Request Process to facilitate changes, which are effective upon approval by the designated Primary Working Group and only subject to being appealed to MOPC. Such changes will be effective immediately upon approval by the Primary Working Group. Documents subject to this waiver are: Reliability Coordinator and Balancing Authority Data Specifications ( RDS ) SPP Communications Protocols Page 4 of 13

16 Southwest Power Pool, Inc. Submission of a Revision Request The following Qualified Entities may submit an RR: Any Market Participant; Transmission Customers or other entities that are parties to transactions under the Tariff; Any Entity that is an SPP Member; Any staff member of a governmental authority having jurisdiction over the SPP or any member company; SPP Staff; SPP Market Monitor; Any rostered individual of an official SPP Committee, Task Force or Working Group; Any entity designated by a Qualified Entity to submit a Revision Request on their behalf. Revision Request Procedure A description of the process is provided in the following subsections. Review and Posting of Revision Requests Revision Requests (RRs) shall be submitted to SPP by completing a Revision Request Submission Form, provided at the SPP website (RR Request/Comment Forms). All RRs, except those submitted by SPP staff, are to be submitted to the SPP Request Management System (RMS). Any RRs not submitted appropriately will not be processed. The RR shall include at least the following information: (1) Identification of the Submitter; (2) Primary SPP document requiring revision with a list of affected section numbers and an indication of affected documents, e.g., SPP Business Practices, SPP Operating Criteria, SPP Planning Criteria, SPP Market Protocols or SPP Open Access Transmission Tariff; (3) Complete and sufficient objective of the suggested change. Summary of the problem(s), proposed solution(s), and benefit(s) expected to be realized by the RR; (4) Proposed language changes (redlined). SPP shall evaluate the RR for completeness and shall notify the submitter, within three (3) business days of receipt if the RR is incomplete, including the reasons for such status. SPP may provide information and assistance to the submitter to ensure it is complete. A submitter must submit a complete version of the RR with all deficiencies corrected in order for the revision to be considered. An incomplete RR will not be processed. Page 5 of 13

17 Southwest Power Pool, Inc. Revision Requests must be submitted no less than eighteen (18) business days prior to the Primary Working Group s initial review. Upon receipt of a complete RR, SPP shall post the complete RR to the SPP website and distribute the RR to the SPP Revision Request exploder and the Primary Working Group exploder within three (3) business days. The Primary Working Group shall mean the SPP working group responsible for the primary document being revised. Primary Working Group governing document responsibility is as follows: The Market Working Group is responsible for approving and rejecting any proposed changes to the Market Protocols. The Operating Reliability Working Group is responsible for approving and rejecting any proposed changes to the SPP Operating Criteria. The Transmission Working Group is responsible for approving and rejecting any proposed changes to the SPP Planning Criteria. The Regional Tariff Working Group is responsible for approving and rejecting any proposed changes to the SPP Tariff. The Business Practices Working Group is responsible for approving and rejecting any proposed changes to the SPP Business Practices. The Project Cost Working Group is responsible for approving and rejecting any proposed changes to the Minimum Transmission Design Standards for Competitive Upgrades. The Secondary Working Group shall mean the SPP Working Group(s) responsible for documents or sections therein that may be impacted by the RR. Secondary Working Groups have a secondary approval responsibility, however any changes made by a Secondary Working Group must be accepted by the Primary Working Group prior to the MOPC and, where appropriate, the BOD review and approval. Routing Criteria for a Revision Request Revision Requests upon submission to the RMS shall be routed to the appropriate internal SPP department based on the document type identified, e.g., SPP Business Practices, SPP Operating Criteria, SPP Planning Criteria, SPP Market Protocols, or SPP Open Access Transmission Tariff, MTDS. The Primary Staff Secretary will assign an RR number and route the RR to the appropriate Primary and Secondary Working Group(s) according to the RR Routing Criteria and internal SPP review. Written Comments on a Revision Request Any interested entity may submit official comments on an RR in writing. All RR comments must be submitted using the Revision Request Comment Form provided on the SPP website. Comments on RRs, except those submitted by SPP staff, should be submitted to the SPP Request Management System (RMS). Comments may be submitted at any time prior to the MOPC review. However, comments for initial Primary Working Group review must be submitted no later than five (5) business days prior to the initial Page 6 of 13

18 Southwest Power Pool, Inc. Primary Working Group s scheduled review. SPP shall evaluate the RR Comment Form for completeness and shall notify the submitter, within three (3) business days of receipt if the RR Comment Form is incomplete, including the reasons for such status. SPP may provide assistance to the submitter to ensure it is complete. All complete comments received in the proper format will be posted to the SPP website within three (3) business days of receipt and distributed to the SPP Revision Request Exploder and the Primary Working Group Exploder. The comments shall include identification of the commenting entity. Any comments not submitted appropriately will not be processed. Impact Analysis SPP shall perform an Impact Analysis (IA) or indicate one is not necessary. The results of the evaluation will be documented on an IA form and posted in the applicable RR folder for review. A Revision Request IA should assess the impact of the proposed RR on SPP systems, processes, and SPP staffing needs, and shall contain the following information: (1) An estimate of any cost and budgetary impacts to SPP for both implementation and on-going operations; (2) The estimated amount of time required to implement the revised language; (3) The identification of alternatives to the original proposed language that may result in more efficient implementation; and (4) The identification of any manual workarounds that may be used as an interim solution and estimated costs of the workaround; (5) Primary Working Group rank for any RRs requiring a system, process and/or staffing change; and (6) A list of possible SPP and Member systems impacted. It will be at the discretion of the Primary Working Group to review and/or take action on an RR contingent upon review of a completed IA. Upon completion of the IA, the Primary Working Group may review actions taken on an RR prior to the completion of the IA and take additional action if necessary. An RR will not be submitted for review to the Secondary Working Groups or the MOPC before the completion of the IA except in the case of expedited review request or urgent action Revision Requests. In the case of expedited or urgent Revision Requests, the Revision Request will be submitted for review by Secondary Working Groups while the IA is completed. If the Primary Working Group approves an RR contingent upon review of an IA, SPP shall prepare an IA based on the RR Recommendation Report. Unless a longer review period is warranted due to the complexity of the proposed RR Recommendation Report or the quantity of approved RRs, SPP shall issue the IA for the recommended RR within thirty (30) calendar days after the Primary Working Group approval of the RR. SPP shall post the results of the completed IA on the SPP website. If a longer review period is required for SPP staff to complete a full IA, SPP staff shall submit a schedule for completion of the IA to the Primary Working Group chair. Page 7 of 13

19 Southwest Power Pool, Inc. Primary Working Group Review and Action The Primary Working Group will review timely submitted RRs during the next regularly scheduled meeting or as otherwise directed by the RR submitter. In the event an RR is submitted less than eighteen (18) business days prior to the Primary Working Group s review, the RR may be expedited following the guidelines for expediting RRs or reviewed at the next regularly scheduled Primary Working Group meeting. Primary Working Group approved RRs will be routed through the appropriate Secondary Working Group(s), the MOPC and, when required, the BOD for review. The Primary Working Group reserves the right to recommend action to the MOPC at any time subsequent to its initial action on an RR. The Primary Working Group may take action on an RR to: (1) Approve as submitted or modified. Approval may be subject to review of a IA or updated IA if such review is determined by the Primary Working Group to be necessary; (2) Reject. An RR shall be considered rejected if a majority of the Primary Working Group members fail to reject or approve the RR, either as submitted or modified; (3) Table/Postpone. To table or postpone an RR is to defer action pending some follow-up action. RRs approved by the Primary Working Group may not be tabled/postponed except by MOPC or BOD. The Primary Working Group may recommend to table/postpone a previously approved RR at any time prior to the MOPC scheduled review of the RR; (4) Withdrawal. Approved RRs may not be withdrawn except by MOPC or BOD. The Primary Working Group may recommend to withdraw a previously approved RR at any time to the MOPC; or (5) Refer the RR to another working group, committee, or task force as it deems appropriate. The RR may be referred to a task force created by the Primary Working Group and/or to one or more existing working groups or task forces of the MOPC for review and comment on the RR. Suggested modifications to an RR should be submitted as comments by the chair, or the chair s designee, on behalf of the working group, committee, or task force for consideration by the Primary Working Group. The Primary Working Group shall retain ultimate responsibility for processing RRs related to its respective document. Within three (3) business days after the Primary Working Group takes action, SPP shall post an RR Recommendation Report to the SPP website reflecting the Primary Working Group s action. The Primary Working Group staff secretary shall notify Secondary Working Group staff secretaries of the posting of RR Recommendation Report and applicable IAs. An RR Recommendation Report shall contain at least the following items: (1) Identification of submitter; (2) Modified SPP Business Practices, SPP Operating Criteria, SPP Planning Criteria, SPP Market Protocols or SPP Tariff language proposed by the Primary Working Group; (3) Estimated system cost and duration if applicable; Page 8 of 13

20 Southwest Power Pool, Inc. (4) Comments submitted; (5) Voting record for the Primary Working Group, Secondary Working Groups, MOPC, BOD and RSC if applicable; (6) Primary Working Group rank for any RRs requiring a system, process and/or SPP staff change; and (7) Recommended action for the MOPC from the Primary Working Group. The Primary Working Group Chair shall notify the MOPC of RRs recommended to be postponed, tabled, or withdrawn, and RRs that have been approved or rejected by the Primary Working Group. Should any Qualified Entity disagree with an action taken or recommended by the Primary Working Group, such Qualified Entity may submit an alternate recommendation to the RMS using the RR Comment Form or such Qualified Entity may, in writing, appeal and submit an alternate recommendation to the MOPC. The appealing Qualified Entity shall send an detailing the appeal to both the Primary Working Group and the MOPC staff secretaries. Secondary Working Group Review and Action A final version of the RR Recommendation Report will be submitted for posting in the background materials seven (7) calendar days prior to the Secondary Working Group(s) next meeting. However, at the discretion of the Secondary Working Group, a waiver may be granted of the seven (7) calendar day rule. The Secondary Working Group(s) shall review the recommended changes to determine if the proposed changes conflict with requirements outlined in the Business Practices, Operating Criteria, Planning Criteria, Market Protocols, or SPP Tariff. In the event the Secondary Working Group(s) identifies conflicts, which have not previously been identified by the Primary Working Group, or issues regarding the proposed changes, the Secondary Working Group(s) will submit comments, using the RR Comment Form, to be considered by the Primary Working Group at its next regularly scheduled meeting, or by the MOPC and, where appropriate, the BOD. All submitted comments will be recorded in the RR Recommendation Report for working group, MOPC and, where appropriate, BOD consideration. The Secondary Working Group may take action on the RR to: (1) Approve as submitted or modified. If modified the Secondary Working Group must submit comments with the modified language to the Primary Working Group within 3 business days; (2) Reject. An RR shall be considered rejected if a majority of the Secondary Working Group members fail to reject or approve the RR as submitted or modified. The RR will move forward with the Secondary Working Group s rejection noted in the RR Recommendation Report; or The Primary Working Group must review and approve changes made by Secondary Working Groups. It is the responsibility of the Primary Working Group staff secretary to ensure RRs are appropriately routed through necessary Secondary Working Groups and to recommend action to the MOPC. Where an RR impacts multiple primary documents, the Primary Working Group shall be assigned based on which document has the most material impact or at the discretion of the impacted working group chairs. Page 9 of 13

21 Southwest Power Pool, Inc. All decisions of the Primary Working Group, the Secondary Working Group(s), the MOPC and the BOD with respect to any RR shall be posted to the SPP website within three (3) business days of the date of the decision. All such postings shall be maintained on the SPP website in the Open Revision Request folder until the RR is closed. An RR is considered closed if it has been implemented in the SPP Business Practices, SPP Operating Criteria, SPP Planning Criteria, SPP Market Protocols, or SPP Tariff, rejected, or withdrawn, or any system or process changes are complete. Closed Revision Requests shall be maintained on the SPP website in the Closed Revision Request folder. Should any Qualified Entity disagree on an action taken or recommended by the Secondary Working Group, such Qualified Entity may submit an alternate recommendation to the RMS using the RR Comment Form or such Qualified Entity may, in writing, appeal and submit an alternate recommendation to the MOPC. The appealing Qualified Entity shall send an detailing the appeal to both the Primary Working Group and the MOPC staff secretaries. Market and Operations Policy Committee Action The MOPC shall consider RRs submitted by the Primary Working Group, for which an RR Recommendation Report has been posted on the SPP website for at least six (6) days, or those accepted for urgent treatment by the MOPC. The following information must be included for each RR considered by the MOPC: (1) The RR Recommendation Report and IA, if any; and (2) Any comments timely received in response to the RR Recommendation Report. The MOPC shall take one of the following actions regarding the RR Recommendation Report: (1) Approve as recommended in the RR Recommendation Report or as modified by the MOPC; (2) Reject. An RR shall be considered rejected if the MOPC fails to reject or approve the RR Recommendation Report; (3) Table/Postpone. To table or postpone an RR is to defer action pending some follow-up action needed. In the event a tabled or postponed RR s deferral period requires additional time than originally approved by the MOPC, the Primary Working Group chair shall recommend a longer deferral period to the MOPC at their next regularly scheduled meeting; (4) Withdraw. The MOPC may vote to withdraw a previously approved RR; or (5) Remand the RR to the Primary Working Group with instructions. The MOPC s decision regarding approval or rejection of an RR shall be posted on the SPP website with the MOPC s minutes and in the recommendation to the BOD. Should any Qualified Entity want to appeal an action taken or recommended by the MOPC, such Qualified Entity may, in writing, submit comments within three (3) business days of the posting to the MOPC staff secretary for inclusion in the BOD recommendation. If the MOPC approves a change or changes to the Business Practices, Operating Criteria, Planning Criteria, Market Protocols, or SPP Tariff, such change(s) shall be incorporated into the appropriate Page 10 of 13

22 Southwest Power Pool, Inc. document and posted on the SPP website as soon as practicable, but no later than one (1) day before the effective date of the changes. SPP Board of Directors Review and Action If the RR requires SPP Operating Criteria, SPP Planning Criteria or SPP Tariff revisions, after an RR has been approved by the MOPC, it must be submitted to the SPP Board of Directors (BOD) for review and action. The BOD will review the RR at the next regularly scheduled meeting and take one of the following actions: (1) Approve the RR as recommended in the RR Recommendation Report or as modified by the SPP BOD; (2) Reject if the SPP BOD fail to reject or approve the RR as submitted or modified; (3) Table/Postpone. To table or postpone an RR is to defer action pending some follow-up action needed; (4) Withdraw. The BOD may vote to withdraw a previously approved RR; or (5) Remand the RR to the MOPC with instructions. Tabling or Postponing a Revision Request To table or postpone an RR is to defer action pending some follow-up action. A Primary Working Group may recommend to the MOPC that an RR be tabled or postponed. In the event a tabled or postponed RR deferral period requires additional time than originally approved by the MOPC, the Primary Working Group chair shall recommend a longer deferral period to the MOPC at their next regularly scheduled meeting. Withdrawal of an Revision Request Submitter Withdrawal Upon notice to the Primary Working Group, the RR submitter may withdraw the RR at any time prior to approval of the RR by the Primary Working Group. The Primary Staff Secretary shall create a RR Recommendation Report recording the submitter s withdrawal of a RR and post on the SPP website within three (3) business days of the submitter s notice to the Primary Working Group. Primary Working Group Withdrawal Upon notice to the RR submitter and any Secondary Working Group having taken a prior action on an RR, a Primary Working Group may recommend to withdraw a previously approved RR at any time to the MOPC. Expedited Review Requests The party submitting an RR may request that the RR be considered for expedited review when the submitter is requesting action from the Primary Working Group on an RR that has not met the minimum comment period. Page 11 of 13

23 Southwest Power Pool, Inc. A valid motion in a regularly scheduled meeting of the Primary Working Group is required to waive the minimum comment period and treat an RR with expedited review status. If approved for expedited review by the Primary Working Group, the RR will be treated the same as one that has met the minimum comment period. If the request for expedited review is rejected, the RR will be considered by the Primary Working Group after the minimum period; in most cases at the next regularly scheduled Primary Working Group meeting. Urgent Action Requests The party submitting an RR may request that the RR be considered for urgent action. Urgent action requests should be reserved for instances when existing Business Practices, Operating Criteria, Planning Criteria, Market Protocols, or SPP Tariff language is impairing or could imminently impair SPP system reliability or wholesale or retail market operations, or is causing or could imminently cause a discrepancy between any of SPP s governing documents. The Primary Working Group shall consider the urgent action RR at its earliest regularly scheduled meeting or at a special meeting called by the Primary Working Group chair. In some cases, an Urgent Action Request will occur concurrently with an expedited review request. A valid motion and vote of the Primary Working Group are required to designate the RR for urgent action. After approval, Urgent Action RRs shall be given priority high enough to ensure implementation within the timeline necessary to mitigate concerns about SPP system reliability or market operations under the unmodified language, or any other significant issues identified in the RR. If approved, SPP shall submit an urgent action RR Recommendation Report to the chair and staff secretary of the MOPC and the appropriate Secondary Working Groups within two (2) business days to address the urgency of the RR. The MOPC and Secondary Working Groups chairs may request action from the working groups to address the urgency of the RR. Appeal of Decision If the Primary Working Group rejects an RR, any Qualified Entity eligible to submit an RR may appeal directly to the MOPC. Notice of the appeal must be submitted to SPP within ten (10) business days after the date of the relevant decision. Appeals to the MOPC shall be posted on the SPP website within three (3) business days of receipt and placed on the agenda of the next regularly scheduled MOPC meeting, provided that the appeal is received in time to meet the MOPC meeting material posting deadline of seven (7) days prior to the meeting Should any Qualified Entity want to appeal an action taken or recommended by the MOPC, such Qualified Entity may, in writing, submit comments within three (3) business days to the MOPC staff secretary for inclusion in the BOD recommendation. FERC Filings In the event the FERC rejects the SPP Tariff modifications associated with an RR, the RR will be deemed rejected by the FERC action. In the event the FERC conditionally accepts with compliance requirements Page 12 of 13

24 Southwest Power Pool, Inc. the SPP Tariff modifications associated with an RR, SPP staff will prepare a new RR to conform the appropriate document(s) to the FERC order. Page 13 of 13

25

26 Project Review: XFR - Ft Smith 500/161 kv Ckt 3 PCWG 06/07/2017 2

27 XFR - Ft Smith 500/161 kv Ckt 3 3

28 Project Cost History $30.0 $25.0 Latest cost reported in 3Q $25,635,637 $20.0 Cost increase to $16.05 million reported in Q % $15.0 Baseline $10.0 Baseline reported in Q is $14 million -20% $5.0 $- 4

29 XFR - Ft Smith 500/161 kv Ckt 3 UID Owner Project Scope OGE Convert Ft. Smith 161KV to 1-1/2 breaker design and install 3rd KV transformer ban Cost Information UID Owner Latest Cost Baseline Cost Estimate (Including Escalation) Variance VarIance % OGE $ 25,635,637 $ 15,076,469 $ 10,559, % 5

30 XFR - Ft Smith 500/161 kv Ckt Factors Contributing to the Variance Variance 1 Rock encountered in area of 161kV breaker and a half expansion requiring significant site work. $4,446,763 Engineering and construction needed temporarily to keep 161kV lines energized throughout 2 project. $1,198,668 3 OG&E internal costs - overheads, taxes and AFUDC. $2,703,530 4 Additional cost of steel for substation structures and transmission structures above estimate. $569,337 5 Additional contingency above estimate. $1,264,169 6 Removal of old foundations unknown at estimate. $376,701 TOTAL $10,559,168 Upgrade Cost Estimates Baseline Cost Estimate ($) Updated Cost Estimate from Quarterly Update ($) Variance Amount (Updated less Baseline) ($) $15,076,469 $25,635,637 $10,559,168 Financial Mitigation Plans The cost of the security fencing can be absorbed by the remaining contingency amount. Identify Future Financial Risks OG&E Physical Security is requiring additional fencing around an elevated area outside of the substation to limit access to positions overlooking the transformer. Future Projection (Confidence Level) Estimate the probability that final cost will be within +/- 20% of updated cost estimate Low <50% chance Medium 50-80% chance High >80% chance X 6

31

32 Project Review: Multi - Chisholm - Gracemont 345 kv PCWG 06/07/2017 2

33 Multi - Chisholm - Gracemont 345 kv 3

34 Project 30361Cost History $250.0 Costs reported at $163 million since Q % $200.0 Baseline $ % $100.0 Baseline reported in Q is $167 million Latest cost reported in 3Q $127,678,129 $50.0 $- 4

35 Multi - Chisholm - Gracemont 345 kv UID Owner AEP AEP AEP OGE Project Scope Build new single circuit 345 kv line from new Chisholm sub to interconnection with (OGE) towards Gracemont. AEP will construct approximately 70 of 100 miles from Chisholm to the OGE interconnection point. Construct new 345/230 kv Chisholm substation between existing 230 kv substations, Sweetwater and Elk City. Cut-in existing Sweetwater - Elk City 230 kv Ckt 1 line into new Chisholm substation and install any necessary 230 kv terminal equipment. Install new 345/ MVA transformer at new Chisholm substation. Install approximately 2 miles of 230 kv transmission line for a cut-in to existing 230 kv line from Sweetwater to Elk City, creating termination points at new Chisholm substation. Build new 30-mile single circuit 345 kv line from the Gracemont substation to the interconnection point with American Electric Power, toward the new Chisholm substation. Install any necessary terminal equipment at Gracemont. UID Owner Latest Cost Baseline Cost Estimate (Including Escalation) Variance VarIance % AEP $ 65,082,311 $ 103,053,724 $ (37,971,413) % AEP $ 17,471,695 $ 22,529,425 $ (5,057,730) % AEP $ 1,270,623 $ 5,879,705 $ (4,609,082) % OGE $ 43,853,500 $ 48,406,059 $ (4,552,559) -9.40% Total $ 127,678,129 $ 179,868,913 $ (52,190,784) % 5

36 UID Chisholm - Gracemont 345kV Ckt Factors Contributing to the Variance Variance 1 Revised cost estimate for shorter line route 1 ($14,263,576) 2 E & C costs of shorter route were slightly above revised estimate $2,942,771 3 Actual material costs below revised estimate ($12,629,868) 4 Reduction in project contingency ($4,328,604) TOTAL ($28,279,277) 1. The NTC estimate was based on an estimated 72-mile line length (equal to 120% of the assumed 60- mile straight line distance). The actual line routing, after Chisholm station site selection and final determination of the AEP/OGE interconnection point, was accomplished at 61-miles (109% of the 56- mile straight line distance). Future Financial Risks Abnormally wet spring conditions could lead to moderate increase in ROW restoration costs. Financial Mitigation Plans Cost risk included in project contingency budget. Upgrade Cost Estimates Baseline Cost Estimate ($) Updated Cost Estimate from Quarterly Update ($) Variance Amount (Updated less Baseline) ($) Future Projection (Confidence Level) Estimate the probability that final cost will be within +/- 20% of updated cost estimate Low <50% chance Medium 50-80% chance $93,361,588 $65,082,311 ($28,279,277) High >80% chance X 6

37 UID Chisholm 345/230 kv Substation Factors Contributing to the Variance Variance 1 Actual engineering labor lower than estimate ($306,129) Actual construction labor less than estimate due to competitive 2 construction market ($907,133) 3 Material costs (345/230 autotransformers) lower than ($3,311,752) 4 Actual property acquisition costs higher than estimate $80,789 5 AFUDC and contingency were omitted from original SCERT $1,505,373 TOTAL ($2,938,852) Future Financial Risks P&C and transformer assembly bids will come in greater than estimated costs. Financial Mitigation Plans Contingency included for these items. Additional Information Station land, below grade and above grade electrical work is complete. All major materials have been purchased. Upgrade Cost Estimates Baseline Cost Estimate ($) Updated Cost Estimate from Quarterly Update ($) Variance Amount (Updated less Baseline) ($) Future Projection (Confidence Level) Estimate the probability that final cost will be within +/- 20% of updated cost estimate Low <50% chance Medium 50-80% chance $20,410,547 $17,471,695 ($2,938,852) High >80% chance X 7

38 UID Chisholm 230 kv Factors Contributing to the Variance Variance 1 Revised cost estimate for shorter line length 1 ($3,995,042) 2 E & C labor costs above estimate $169,643 3 Material costs Lower than estimate - station located adjacent to 230kV line. ($354,578) 4 Other adjustments (ROW, contingency, etc.) $123,878 TOTAL ($4,056,099) 1. Based on station site purchase, line route for 230kV line was reduced from 2 miles to 0.5 miles. Future Financial Risks Clearance availability could cause second contractor mobilization to return in fall outage period. Financial Mitigation Plans Cost risk is addressed with contingency. Upgrade Cost Estimates Baseline Cost Estimate ($) Updated Cost Estimate from Quarterly Update ($) Variance Amount (Updated less Baseline) ($) Future Projection (Confidence Level) Estimate the probability that final cost will be within +/- 20% of updated cost estimate. Low <50% chance Medium 50-80% chance $5,326,722 $1,270,623 ($4,056,099) High >80% chance X 8

39

40 Project Review: Multi Hoskins Neligh 345 kv PCWG 06/07/2017 2

41 Multi Hoskins Neligh 345 kv 3

42 Project Cost History % 100 Baseline % Baseline reported in Q is $96.7 million Cost decrease from $98.7 million to $83.7 million during 2016 Latest cost reported in 3Q $81,544,

43 Multi Hoskins Neligh 345 kv UID Owner Upgrade Description NPPD NPPD Build a new 41-mile 345 kv line from Hoskins to Neligh. Build new substation at Neligh. Install a new 345/115 kv transformer and all necessary 345 kv equipment at Neligh NPPD Install necessary terminal equipment at the 115 kv bus in the new Neligh substation. Construct approximately 18 miles of new 115 kv transmission to tie Neligh East 345/115 kv into the existing 115 kv transmission system. UID Owner Latest Cost Baseline Cost Estimate (Including Escalation) Variance Var % NPPD $ 51,692,703 $ 74,062,375 $ (22,369,672) % NPPD $ 10,082,325 $ 13,050,368 $ (2,968,043) % NPPD $ 19,769,491 $ 19,173,906 $ 595, % Total $ 81,544,519 $ 106,286,649 $ (24,742,130) % 5

44 UID 50621: Neligh 115 kv Terminal Upgrades Major Factors Contributing to the Variance Variance 1 SPP escalation in addition to/on top of NPPD escalation $ (1,369,028) 2 Line construction (labor and material) more than budgeted (1) $ 3,611,652 3 Substation Engineering less than budgeted $ (12,389) 4 Substation construction less than budgeted $ (542,397) 5 Substation material less than budgeted $ (293,400) 6 Substation contingency not used $ (681,240) 7 Substation AFUDC less than budgeted $ (117,614) Additional information: TOTAL $595,584 (1)Original SCERT assumed constructing approximately 11 miles of new 115 kv line, approximately 7 miles of 115 kv rebuild, and removal of approximately 3 miles of existing 115 kv line. Following the line routing process, however, actual scope included approximately 10 miles of 115 kv rebuild, removal of ~1 miles of existing 115 kv line, and ~20 miles of new 115 kv line. Upgrade Cost Estimates Baseline Cost Estimate ($) Updated Cost Estimate from Quarterly Update ($) Variance Amount (Updated less Baseline) ($) $19,173,906 $19,769,490 ($595,584) Future Projection (Confidence Level) Estimate the probability that final cost will be within +/- 20% of updated cost estimate. Low <50% chance Medium 50-80% chance High >80% chance X 6

45 UID 50440: Hoskins -Neligh 345 kv Ckt Factors Contributing to the Variance Variance 1 SPP escalation in addition to/on top of NPPD escalation $ (5,288,097) 2 Lines contingency not needed $ (5,165,711) 3 Steel pole contract less than budgeted $ (7,905,569) 4 Conductor contract less than budgeted $ (1,171,172) 5 labor and ROW costs less than budgeted $ (971,508) 6 Substation Engineering less than budgeted $ (80,098) 7 Substation construction less than budgeted $ (487,872) 8 Substation material less than budgeted $ (728,593) 9 Substation contingency not used $ (484,530) 10 Substation AFUDC less than budgeted $ (86,523) TOTAL ($22,369,673) Upgrade Cost Estimates Baseline Cost Estimate ($) Updated Cost Estimate from Quarterly Update ($) Variance Amount (Updated less Baseline) ($) $74,062,375 $51,692,702 ($22,369,673) Future Projection (Confidence Level) Low <50% chance Medium 50-80% chance High >80% chance Estimate the probability that final cost will be within +/- 20% of updated cost estimate X 7

46 UID 50441: Neligh 345/115 kv Substation Factors Contributing to the Variance Variance 1 SPP escalation in addition to/on top of NPPD escalation ($931,803) 2 Substation Engineering more than budgeted $ 223,740 3 Substation construction more than budgeted $ 599,341 4 Substation material less than budgeted $ (1,565,092) 5 Substation contingency not used $ (1,013,134) 6 Substation AFUDC less than budgeted $ (281,095) TOTAL ($2,968,043) Upgrade Cost Estimates Baseline Cost Estimate ($) Updated Cost Estimate from Quarterly Update ($) Variance Amount (Updated less Baseline) ($) $13,050,368 $10,082,325 ($2,968,043) Future Projection (Confidence Level) Estimate the probability that final cost will be within +/- 20% ofupdated cost estimate. Low <50% chance Medium 50-80% chance High >80% chance X 8

47

48 Project Review: Multi - Viola 345/138kV Transformer and 138 kv Lines to Clearwater and Gill PCWG 06/07/2017 2

49 Multi -Viola 345/138kV Transformer and 138 kv Lines to Clearwater and Gill 3

50 Project Cost History $120.0 $ % $ % $60.0 $40.0 Baseline reported in Q is $78 million Cost decrease to $72.07 million in Q Latest cost reported in 3Q $67,066,974 $20.0 $- 4

51 Multi - Viola 345/138kV Transformer and 138 kv Lines to Clearwater and Gill UID Owner WR WR WR WR Project Scope Install new 345/138 kv transformer at Viola substation. Build new 21.8-mile 138 kv line from new Viola substation to Clearwater 138 kv Build new 27.9-mile 138 kv line from new Viola substation to Gill 138 kv substation. Install 345 kv breakers at Viola substation. UID Owner Latest Cost Baseline Cost Estimate (Including Escalation) Variance Var % WR $ 13,331,670 $ 15,819,482 $ (2,487,812) % WR $ 31,492,903 $ 39,729,430 $ (8,236,527) % WR $ 17,234,744 $ 24,542,997 $ (7,308,253) % WR $ 5,007,657 $ 5,527,516 $ (519,859) -9.40% Total $ 67,066,974 $ 85,619,425 $ (18,552,451) % 5

52 UID Viola 345/138 kv Transformer Ckt Factors Contributing to the Variance Variance Engineering Construction Costs: plan to use existing poles on section of line reducing ROW Acquisition: exisiting substation site provided adequate room for Material: plan to use existing poles on section of line reducing material AFUDC/Contingency Adjustments ($1,000,000) TOTAL ($1,000,000) Upgrade Cost Estimates Baseline Cost Estimate ($) Updated Cost Estimate from Quarterly Update ($) Variance Amount (Updated less Baseline) ($) $14,331,670 $13,331,670 ($1,000,000) Identify Future Financial Risks Future financial risks include unforseen conditions during construction. Future Projection (Confidence Level) Estimate the probability that final cost will be within +/- 20% of updated cost estimate Low <50% chance Medium 50-80% chance High >80% chance X Describe Financial Mitigation Plans We kept contingency for any unknowns that may arise during construction. Additional Information The updated estimate only included a change to decrease contingency by $1M. 6

53 UID Clearwater - Viola 138 kv Ckt Factors Contributing to the Variance Variance Engineering Construction Costs: plan to use existing poles on section of line reducing construction costs. ROW Acquisition: exisiting substation site provided adequate room for expansion. Material: plan to use existing poles on section of line reducing material costs. AFUDC/Contingency Adjustments ($4,500,000) TOTAL ($4,500,000) Upgrade Cost Estimates Baseline Cost Estimate ($) Updated Cost Estimate from Quarterly Update ($) Variance Amount (Updated less Baseline) ($) $35,992,903 $31,492,903 ($4,500,000) Future Projection (Confidence Level) Estimate the probability that final cost will be within +/- 20% of updated cost estimate Low <50% chance Medium 50-80% chance High >80% chance X Additional Information The updated estimate only included a change to decrease contingency by $4.5M. 7

54 UID Gill - Viola 138 kv Ckt Factors Contributing to the Variance Variance 1 Engineering ($274,491) 2 Construction Costs: plan to use existing poles on section of line reducing construction costs. ($2,144,757) 3 ROW Acquisition: exisiting substation site provided adequate room for expansion. ($27,100) 4 Material: plan to use existing poles on section of line reducing material costs. ($2,290,513) 5 AFUDC/Contingency Adjustments ($263,139) TOTAL ($5,000,000) Upgrade Cost Estimates Baseline Cost Estimate ($) Updated Cost Estimate from Quarterly Update ($) Variance Amount (Updated less Baseline) ($) $22,234,744 $17,234,744 ($5,000,000) Identify Future Financial Risks Future financial risks include unforseen conditions during construction. Describe Financial Mitigation Plans We kept contingency for any unknowns that may arise during construction. 8