February 23, 2015 VIA ELECTRONIC FILING

Transcription

1 February 23, 2015 VIA ELECTRONIC FILING The Honorable Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C Re: Southwest Power Pool, Inc., Docket No. ER Compliance Filing of Southwest Power Pool, Inc. to Amend Market-to- Market Procedures Dear Secretary Bose: Pursuant to section 206 of the Federal Power Act ( FPA ), 16 U.S.C. 824e, and the Commission s order issued on January 22, 2015 in this proceeding, 1 Southwest Power Pool, Inc. ( SPP ) submits revisions to the Joint Operating Agreement ( JOA ) between SPP and the Midcontinent Independent System Operator, Inc. ( MISO ) 2 in compliance with the January 22 Order. With this filing, SPP submits revisions to the JOA to include language as required by the Commission. SPP requests an effective date of March 1, 2015 for the JOA revisions submitted with this filing consistent with the effective date of Market-to-Market ( M2M ) Procedures granted in the January 22 Order. In addition, SPP provides the Commission with notice of its intent to file coincident to this compliance filing a separate motion requesting a limited extension of time of sixty (60) days to comply with one aspect of the January 22 Order. As will be explained in the formal motion, SPP requests the limited extension of time to allow for SPP and MISO to continue negotiating additional revisions to Section of Attachment 2 of the JOA as required by the January 22 Order. 1 2 Sw. Power Pool, Inc., 150 FERC 61,033 (2015) ( January 22 Order ). The formal name of the JOA is the Joint Operating Agreement between the Midwest Independent Transmission System Operator, Inc. and Southwest Power Pool, Inc. The JOA is a FERC-filed rate schedule of both MISO and SPP. The JOA is designated as MISO s Rate Schedule FERC No. 6; and as SPP s Rate Schedule FERC No. 9.

2 The Honorable Kimberly D. Bose February 23, 2015 Page 2 I. BACKGROUND In the Commission s order conditionally accepting SPP s request to implement centralized day ahead and real-time energy and operating reserve markets commonly known as the Integrated Marketplace, 3 the Commission instructed SPP to commence negotiations with MISO to develop M2M Procedures to address congestion management across the SPP-MISO seam. 4 The Commission directed SPP to file the M2M procedures as part of a Phase 2 (i.e., amended) JOA no later than June 30, In the March 21 Order, the Commission clarified that implementation of any agreed-to M2M procedures could be deferred until one year following the start-up of the Integrated Marketplace, or March 1, On June 28, 2013 SPP submitted its compliance filing. 7 The M2M Compliance Filing included new provisions to the JOA memorialized as Attachment 2- Interregional Coordination Process, in addition to revisions to the main body of the JOA. SPP and MISO modeled the procedures contained in the Phase 2 Joint Operating Agreement on similar procedures in effect between PJM Interconnection, L.L.C. ( PJM ) and MISO (the PJM-MISO JOA ). 8 The parties reached agreement on the majority of M2M Procedures proposed in the initial compliance filing. Consistent with the framework adopted in the PJM-MISO JOA, SPP s proposed M2M Procedures substantively adopt the four major components of M2M coordination: Interface Bus Price Coordination, Real-Time Energy Market Coordination, Day-Ahead Energy Market Coordination, and Auction Revenue Rights ( ARR ) Allocation/Financial Transmission Rights ( FTR )/Transmission Congestion Rights ( TCR ) Auction Coordination Sw. Power Pool, Inc., 141 FERC 61,048 (2012) ( Marketplace Order ), order on reh g, 142 FERC 61,205 (2013) ( March 21 Order ). Marketplace Order at P 364. Id. March 21 Order at PP 85, 88. Compliance Amendment to Joint Operating Agreement to Implement Market-to- Market Procedures in Response to Order in Docket No. ER of Southwest Power Pool, Inc., Docket No. ER (June 28, 2013) ( M2M Compliance Filing ). See M2M Compliance Filing at 4. SPP s proposed M2M Procedures are not identical to the procedures contained in the PJM-MISO JOA. As the Commission recognized in the Marketplace Order, SPP and MISO agreed to certain modifications of the template that would more accurately reflect the process being implemented between the parties. See also Marketplace Order at n. 535 See M2M Compliance Filing at 4-6.

3 The Honorable Kimberly D. Bose February 23, 2015 Page 3 SPP and MISO varied from the PJM-MISO template in one material respect by agreeing to defer implementation of the provisions that allow the parties to adjust their Firm Flow Entitlements ( FFE ) in the Day-Ahead Energy Market Coordination. Such deferment would allow the parties to continue discussions to jointly agree that the benefits to change systems and administrative costs outweigh the costs to implement the Day-Ahead FFE exchange process. 10 Additionally, SPP and MISO were unable to reach consensus on the unilateral ability of one Regional Transmission Organization ( RTO ) to designate new M2M Flowgates outside of a mutually-agreed timeframe except in extreme circumstances. 11 As a result, SPP filed language in its proposed M2M Procedures to preclude such designation of new M2M Flowgates absent compensation to mitigate the costs of redispatch the other RTO incurred as a result of the new M2M Flowgate designation. 12 MISO did not support the proposed revisions and filed a timely protest of the inclusion of these terms in the M2M Procedures. 13 Multiple other parties filed interventions and comments both in support and protest which are a part of the official record of the docket, and therefore, SPP will not address them in this compliance filing. 14 On July 11, 2014, the Commission issued an order establishing a technical conference to provide an adequate record to consider issues raised in the M2M Compliance Filing. 15 The technical conference was to address three issues related to SPP s proposed M2M Procedures: (1) the implementation of Interface Bus Pricing; (2) the creation of M2M Flowgates; and (3) the deferred implementation of a Day- Ahead FFE exchange process. 16 The technical conference was held on September 22, Major participants included Commission staff, SPP, MISO, PJM, and the MISO Independent Market Monitor ( IMM ). In addition, many interested third parties were in attendance and were provided opportunities to comment Id. at 6. Id. at 7. See M2M Compliance Filing at Proposed JOA Attachment 2, Sections 3.1 and Motion to Intervene and Protest of the Midcontinent Independent System Operator, Inc., Docket No. ER (July 19, 2013). PJM and Exelon Corporation filed comments in support of the M2M Compliance Filing. MidAmerican Energy Company, Northern Indiana Public Service Company, Potomac Economics, and the Southwest Power Pool Transmission Owners filed protests in response to the M2M Compliance Filing. Numerous other parties filed motions to intervene. Sw Power Pool, Inc., 148 FERC 61,019 (2014), at P 9 ( July 11 Order ). See July 11 Order at P 1.

4 The Honorable Kimberly D. Bose February 23, 2015 Page 4 In the days following the technical conference SPP and MISO participated in multiple discussions to seek consensus on the designation process for new M2M Flowgates. These meetings resulted in negotiated language that was satisfactory to both parties. With approval and support from SPP, MISO filed the agreed-upon language (constituting new Sections through of Attachment 2 to the JOA) in its post-technical conference reply comments, 17 and requested the Commission to order SPP to include the new language in the JOA as a compliance filing. 18 SPP and MISO both filed comments which agreed that the issues discussed in the technical conference related to Interface Bus Pricing and the FFE exchange process should not interfere with implementation of M2M Procedures on March 1, 2015, and the Commission should allow the parties to continue discussing the issues in other forums. On January 22, 2015, the Commission issued an order conditionally accepting in part, and rejecting in part SPP s proposed revisions to the JOA, subject to compliance filing. 19 In the January 22 Order, the Commission rejected SPP s proposed language in Attachment and of the JOA, and required SPP to include the SPP-MISO agreed upon language discussed above as a compliance filing 30 days from the issuance of the order. 20 In addition, the Commission required SPP to work with MISO to resolve the potential ambiguity raised by the MISO IMM in Section of the M2M Procedures related to SPP s and MISO s respective obligations pursuant to the requirement to minimize financial harm due to less than optimal dispatch. 21 The Commission directed SPP to submit the revised provision in a compliance filing. 22 External to the required compliance filing, the Commission required SPP to continue discussion with MISO on Interface Bus Pricing methodologies and the FEE exchange process and report on those efforts every six months until the issues are resolved Post-Technical Conference Reply Comments of Midcontinent Independent System Operator, Inc., Docket No. ER (October 22, 2014). See Initial Post-Technical Conference Reply Comments of Southwest Power Pool, Inc., Docket No. ER (October 22, 2014) at 6 (providing SPP does not oppose a Commission directive that require[d] SPP to include the negotiated language in the JOA pursuant to a compliance filing. ). January 22 Order at Ordering Paragraphs (A) and (B). Id. at PP 1, 36 and Ordering Paragraphs (A) and (B). Id. at P 43. Id. at P 1, 43 and Ordering Paragraph (B). See id. at Sections V.A and V.C.

5 The Honorable Kimberly D. Bose February 23, 2015 Page 5 II. DESCRIPTION OF COMPLIANCE FILING In compliance with the January 22 Order, SPP submits revisions to add new Sections through of Attachment 2 to the JOA. These new provisions specify the conditions under which one RTO will be held harmless by the other RTO for costs incurred due to the designation of a new M2M Flowgate by the other RTO. The terms apply a general hold harmless provision for the balance of the current operating day in which the M2M Flowgate is created for coordination by the Monitoring RTO as a result of planned outages for both the Monitoring RTO s and Non-Monitoring RTO s systems. The hold harmless provision will also apply to the next operating day as a result of a planned outage that is submitted for coordination subsequent to the cutoff for data submitted (i.e., the close of) the Monitoring RTO or Non-Monitoring RTO s Day-Ahead market as applicable. Sections through are designed as follows: A new M2M Flowgate shall be subject to a hold-harmless provision for the balance of the current operating day in which the M2M Flowgate is submitted for coordination by the Monitoring RTO as a result of a planned outage in the Monitoring RTO s system as provided below: a) If the Non-Monitoring RTO s integrated market flows are below its Firm Flow Entitlement for the hour, there will be a market-to-market settlement with a payment from the Monitoring RTO to the Non- Monitoring RTO for the hour. b) If the Non-Monitoring RTO s integrated market flows exceed its Firm Flow Entitlement for the hour, there will be no market-tomarket settlement for the hour. c) Notwithstanding the above provisions, these hold-harmless provisions shall not apply (i.e., a market-to-market settlement will occur) if the new M2M Flowgate was necessitated by an unplanned outage (forced, emergency, or urgent) that could not meet normal outage scheduling timeframes. Nothing in this section is intended to restrict either Party s ability to submit new M2M Flowgates for coordination using the real-time marketto-market coordination procedures The settlement provisions, including exceptions, contained in Section shall also apply for the next operating day when a new M2M Flowgate is submitted for coordination by the Monitoring RTO, as a result of a planned outage in the Monitoring RTO s system, subsequent to the cutoff for data submission of (i.e., the close of) the Non-Monitoring RTO s Day Ahead market.

6 The Honorable Kimberly D. Bose February 23, 2015 Page A new M2M Flowgate shall be subject to a hold-harmless provision for the balance of the current operating day in which the M2M Flowgate is submitted for coordination by the Monitoring RTO as a result of a planned outage in the Non-Monitoring RTO s system as provided below: a) If the Non-Monitoring RTO s integrated market flows exceed its Firm Flow Entitlement for the hour, there will be a market-to-market settlement with a payment from the Non-Monitoring RTO to the Monitoring RTO for the hour. b) If the Non-Monitoring RTO s integrated market flows are below its Firm Flow Entitlement for the hour, there will be no market-tomarket settlement for the hour. c) Notwithstanding the above provisions, these hold-harmless provisions shall not apply (i.e., a market-to-market settlement will occur) if the new M2M Flowgate was necessitated by an unplanned outage (forced emergency, or urgent) that could not meet normal outage scheduling timeframes. d) Notwithstanding the above provisions, these hold-harmless provisions shall not apply (i.e., a market-to-market settlement will occur) if the planned outage had been previously coordinated with the Monitoring RTO but the M2M Flowgate was submitted after the beginning of the current operating day by the Monitoring RTO. Nothing in this section is intended to restrict either Party s ability to submit new M2M Flowgates for coordination using the real-time M2M coordination procedures The settlement provisions, including exceptions, contained in Section shall also apply for the next operating day when a new M2M Flowgate is submitted for coordination by the Monitoring RTO as a result of a planned outage on the Non-Monitoring RTO s system, subsequent to the cutoff for data submission of (i.e., the close of) the Monitoring RTO s Day-Ahead market. 24 Due to the technical requirements of the etariff system, the language specifically rejected by the Commission in the January 22 Order constituting Sections and of Attachment 2 to the JOA will appear as stricken language in this compliance filing. SPP recognizes that the Commission rejected this language, and 24 See Proposed JOA Attachment 2, Sections

7 The Honorable Kimberly D. Bose February 23, 2015 Page 7 this filing will take the necessary administrative action to remove the rejected language from etariff. As the language proposed herein to be included (Sections through 8.4.6) and rejected (Sections and 8.1.4) is consistent with the January 22 Order, SPP requests the Commission accept the Tariff sheets for filing with an effective date of March 1, III. EFFECTIVE DATE SPP requests an effective date of March 1, 2015 for the revisions to the JOA proposed in this compliance filing, consistent with the effective date granted by the Commission in the January 22 Order. IV. ADDITIONAL INFORMATION A. Documents submitted with this filing: In addition to this transmittal letter, the following documents are included with this filing: Clean and Redline revisions to Attachment 2 of the JOA. B. Service: SPP has served a copy of this filing on all individuals listed on the service list compiled by the Commission s Secretary in this proceeding, as well as SPP Members, Customers, Market Participants, and all affected state commissions. A complete copy of this filing will be posted on the SPP website, REMAINDER OF PAGE LEFT INTENTIONALLY BLANK

8 The Honorable Kimberly D. Bose February 23, 2015 Page 8 V. CONCLUSION SPP requests that the Commission accept the filed language constituting Section through of Attachment 2 of the JOA as compliant with the requirements of the January 22 Order and grant an effective date of March 1, 2015 for the proposed revisions. Respectfully submitted, /s/ Matthew Harward Matthew Harward Erin Cullum Marcussen Southwest Power Pool, Inc. 201 Worthen Drive Little Rock, AR Telephone: (501) mharward@spp.org ecullum@spp.org Attorneys for Southwest Power Pool, Inc.

9 CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregoing document upon each person designated on the official service list compiled by the Secretary in this proceeding. Dated at Little Rock, Arkansas, this 23rd day of February, /s/ Michelle Harris Michelle Harris

10 3.1 Real-Time Energy Market Coordination Procedures The following procedure will apply for managing M2M Flowgates in the realtime energy market: 1. The RTOs will exchange topology information to ensure that their respective market software is consistent. 2. When any of the M2M Flowgates under a Monitoring RTO s control is identified as a transmission constraint violation, the Monitoring RTO will enter the M2M Flowgate into its security-constrained dispatch software, setting the flow limit equal to the Effective Limit required for reliability. 3. The Monitoring RTO will then notify the Non-Monitoring RTO of the transmission constraint violation and will identify the appropriate M2M Flowgate that requires mitigation. 4. When the M2M Flowgate first becomes a binding transmission constraint in the Monitoring RTOs Real-Time security-constrained economic dispatch, the Monitoring RTO will transmit the following information to the Non-Monitoring RTO: Constraint Shadow Price ($/MW) - output of the RTOs Real-Time market software. Current Market Flow contribution by the Monitoring RTO on M2M Flowgate (MW) - output of the Real-Time market software. Amount of MWs requested to be reduced from the current market flow of the Non-Monitoring RTO. This number will change throughout the iterative process to efficiently resolve constraints. 5. The Non-Monitoring RTO will enter the M2M Flowgate into its securityconstrained dispatch software, setting the flow limit on the M2M Flowgate equal to its current market flow minus the relief requested by the Monitoring RTO. (a) This means the Non-Monitoring RTO will attempt to manage the flow on the M2M Flowgate at its current Market Flow amount or less, such that it will not contribute any additional flow on the limited M2M Flowgate during this time period. 6. If the Non-Monitoring RTO has sufficient generation to be redispatched, it will redispatch its generation to control the M2M Flowgate until one of the following conditions is reached:

11 (a) (b) The Non-Monitoring RTO has provided the relief requested by the Monitoring RTO. The Non-Monitoring RTO has provided relief at a cost as high as the current shadow price from the Monitoring RTO. 7. The Non-Monitoring RTO will then transmit the following information to the Monitoring RTO: Constraint Shadow Price (S/MW) - Output of the RTOs Real-Time market software. (If the M2M Flowgate does not result in a binding constraint in the Non-Monitoring RTO s securityconstrained economic dispatch, then the shadow price is zero and the Flow Relief is zero for the Non- Monitoring RTO.) Current market flow contribution by the Non-Monitoring RTO on M2M Flowgate (MW) - Output of the RTO s Real-Time market software. 8. Over the next several dispatch cycles the Monitoring RTO may request the Non- Monitoring RTO to adjust its flow limit up or down. The Monitoring RTO will continue to control the M2M Flowgate respecting the Effective Limit of the facility required for reliability. 9. As the relief provided by the Non-Monitoring RTO is realized in the M2M Flowgate, the Monitoring RTO can control the M2M Flowgate at a lower shadow price since less relief is needed from the Monitoring RTO. The updated shadow price will be sent to the Non-Monitoring RTO. The Non- Monitoring RTO will then control the M2M Flowgate using the latest shadow price from the Monitoring RTO as the shadow price limit. 10. Throughout the period that the transmission constraint violation exists, the RTOs will continue to share the flow and constraint shadow price information that is described above. The shadow prices of the two RTOs will eventually converge towards the most cost-effective redispatch solution, provided both RTOs have sufficient redispatch capability. The information transferred via these data exchanges will be retained to provide the pertinent data for Market Settlements. 11. The Monitoring RTO will review the constraint shadow price comparison, make required adjustments, and communicate any such adjustments to the Non-Monitoring RTO. This process will continue until the Monitoring RTO determines that the cost of further adjustments to the dispatch of the Non-Monitoring RTO would exceed the cost of relieving the transmission constraint by adjusting the Monitoring RTO s own dispatch.

12 12. The start and stop times for such Constrained Operation events involving M2M Flowgates will be logged for Market Settlements purposes.

13 8 Appropriate Use of the Market-to-Market Process A subset of flowgates that meet the criteria as described in Section 1.1, impacted by market flows from the two RTOs energy markets, will be subject to the M2M process and called M2M Flowgates. This subset will be controlled using M2M tools for coordinated redispatch and additionally will be eligible for M2M settlements. In principle and as much as practicable, Parties agree that the goal is to control to the most limiting Flowgate using the actual Flowgate limit. The RTOs will record and exchange actual M2M Flowgate limits, the limit used to bind, and a reason for significant deviation. There are times when either Party, acting as the Monitoring RTO, will bind a M2M Flowgate different from its actual limit. The Parties have agreed in subsections 8.1 through 8.4 of this Section 8 to the conditions under which M2M settlement will occur even though a limit to which the Monitoring RTO is binding (limit control) is less than its actual limit. 8.1 Qualifying Conditions for Market-to-Market Settlement: Purpose of Market-to-Market. M2M was established to address regional, not local issues. The intent is to implement M2M coordination and settle on such coordination where both Parties have significant impact Minimizing Less than Optimal Dispatch. The Parties agree that, as a general matter, they should minimize financial harm to one RTO that results from M2M coordination initiated by the other RTO that produces less than optimal dispatch, which can lead to revenue inadequacy for FTR/TCR and impose the burden for such revenue inadequacy on one or both RTOs Use Market-to-Market Whenever Binding a M2M Flowgate. The M2M process will be initiated by the Monitoring RTO whenever an M2M Flowgate is constrained and therefore binding in its dispatch Most Limiting Flowgate. Generally, controlling to the most limiting Flowgate provides the preferable operational and financial outcome. In principle and as much as practicable, M2M coordination will take place on the most limiting Flowgate, and to that Flowgate s actual limit (thermal, reactive, stability). a. M2M events that involve the use of a limit control that is below 95% of the actual limit will be subject to an after-the-fact review, unless the lower limit was agreed to by the RTOs prior to the market-to- market binding event. The review will determine if normal market-to- market settlements are appropriate. If M2M settlements are determined by the Parties not to be appropriate, then settlements will not occur on the M2M Flowgate. Sufficient real-time and after-the-fact data will be exchanged to enable these reviews. The Parties may agree to change the trigger for review to a lower number for specific Flowgates, however, either Party may request

14 review of specific instances that are bound above the established binding percentage Substitute Flowgates. The Parties agree that, if the use of substitute Flowgates is minimized and the ability to coordinate on the most limiting Flowgate in the very near term is enabled, there should be very few instances where M2M coordination occurs without resulting settlement. a. Generally, M2M coordination without the normal market-to- market settlement will be limited to times when: (1) a substitute is used for a period in excess of that defined in Section (b) (ii) below, or (2) a substitute Flowgate (whether M2M or non-m2m) is used and the most limiting Flowgate is later determined to fail the M2M tests. b. Where the most limiting constraint (monitored/contingent element pair) is not a defined M2M Flowgate: i. Parties will add the Flowgate definition and activate market-tomarket coordination on that Flowgate (as opposed to a substitute) as soon as reasonably practicable; or ii. A substitute Flowgate may be used for a short time (generally less than an hour) until it is possible to coordinate using the most limiting Flowgate. Parties will attempt to use either: (i) the most limiting M2M Flowgate or (ii) the most limiting Flowgate that is modeled by both Parties, in that order of preference. If possible, the Parties should use another Flowgate that is limiting. Optimal choices are Flowgates with the same or very similar Market Flow impacts (sensitivities) resulting in a very similar redispatch and M2M settlement. c. A substitute Flowgate can be used in the M2M process pending the outcome of the coordinated Flowgate tests. The substitute Flowgate will be utilized only until the actual constraint can be entered in both the Monitoring and Non-Monitoring RTO systems as an M2M Flowgate. M2M settlement is dependent on the outcome of the coordinated Flowgate tests on the actual constraint and the RTO requesting the use of a substitute Flowgate will do so at its own risk that M2M settlement may not occur. d. A substitute M2M Flowgate will not be used to control for another constrained M2M Flowgate except in very limited circumstances and only where there is prior mutual agreement between MISO and SPP to do so. Mutual agreement is established only when it has been communicated and logged by the control center operators that the coordinated Flowgate is not the most limiting (i.e., it is a substitute Flowgate).

15 e. A substitute M2M Flowgate will not be used to control for a non-m2m Flowgate that has failed the Flowgate study or has not been entered into the study process. f. Ay use of substitute Flowgate should be clearly logged by both RTO operators with the actual start time, the actual end time and the reason for using a substitute Flowgate. g. If the Monitoring RTO requests TLR on an M2M Flowgate but has not initiated the M2M process and is not binding its market for that Flowgate, the Non-Monitoring RTO is not required to bind its market for that Flowgate in order to meet the Non-Monitoring RTO s TLR relief obligation. It will be assumed that the Monitoring RTO is binding its market for the actual constraint and that the actual constraint is already active in the M2M process (if the actual constraint is an M2M Flowgate) Operating Guides that refer to M2M operation do so under the assumption that the Flowgates for which M2M operations take place are, or are expected to be, constrained. Operating Guides are written by operators and are not intended to result in settlement not otherwise contemplated by the JOA or this ICP. Safe Operating Mode (SOM) is reserved for abnormal conditions when existing operating guides and normal tool sets are not sufficient to manage abnormal operating conditions. After declaring SOM, operator actions may include using market-to- market tools in addition to direct dispatch. Operators may choose to use substitute M2M Flowgates with the dispatch tools to maintain reliable operations. Settlement determination will occur during the After-the-Fact Review set forth in Section 8.4 below. Generally, settlement for M2M coordination that takes place after SOM is declared will apply if the settlement would apply under normal conditions. 8.2 Specific Conditions Applicable to Section (Most Limiting Flowgate) Market-to-Market Events Not Requiring an After-the-Fact Review The MISO and SPP operators will model all M2M Flowgates facilities with actual limits in their respective EMSs. The MISO EMS model uses design thermal limits of equipment. The MISO limits are updated in UDS/RTBM following contacts with Transmission Owners prior to binding. The MISO and SPP operators will control the flows on these M2M Flowgates in their respective UDS/RTBM at a binding percentage that is 95% or greater of the M2M Flowgate actual limit Market-to-Market Events Requiring an After-the-Fact Review All M2M events that involve the use of a limit control that is below 95% of the actual limit will be subject to an after-the-fact review to determine whether this

16 was an appropriate use of the M2M process as determined by this Agreement and is subject to normal M2M settlement. The following criteria will be used in making such a determination: Reducing the UDS/RTBM Binding Percentage to Provide Necessary Constraint Control: a. A reduced UDS/RTBM binding percentage below 95% of the actual facility limit can be applied to an M2M Flowgate by the Monitoring RTO provided the monitored element (for the defined contingency condition) of the M2M Flowgate meets the following conditions: i. The monitored element is, or is expected to be, over its actual limit (post contingency if applicable) and the UDS/RTBMs are not providing the desired relief. ii. iii. iv. Transient system behavior necessitates controlling the M2M Flowgate to a target between 95% and 100% and providing some margin. To achieve this, in some instances, the UDS/RTBM percentage may need to be below 95%. The limit for the monitored element changes due to equipment switching out of service. For instance the actual limit of a line is reduced when one of the breakers in a breaker-and-half configuration is out of service, or only one parallel transformer remains in service at one of the line end terminals. A constraint with a very high loading volatility such that loading is expected to exceed 100% of the actual limit, even when the UDS/RTBM binding percentage is significantly below that value. b. The reduced UDS/RTBM binding percentage should only be applied for the time duration necessary to manage the initiating condition and shall be returned to normal as soon as possible. c. Each time the Monitoring RTO reduces the binding limit control of an M2M Flowgate below 95% for an actual or relevant post contingency overload, the Monitoring RTO operator will make a best effort to notify the Non- Monitoring RTO operator of the new limit control, the reason for the change, and when the limit control is expected to be returned to normal (if known). Both RTO operators will log the event. This notification only applies to an operating condition causing a limit control change; it does not

17 apply to the use of temperature adjusted limits, voltage limits or stability limits implemented as flow limits. i. A limit reported by a Transmission Owner on the operating day shall require an accompanying reason. If the limit is set to control for underlying facilities, this shall be called out specifically. Any reason other than those specifically called out herein shall be reported. d. The Monitoring RTO will operate to the most conservative limit when there are conflicting results between two different EMSs (either another RTO EMS or a Transmission Owner EMS) unless the reason for the difference is known Reducing the UDS/RTBM Binding Percentage of a M2M Flowgate for Prepositioning a. In some conditions system flows are expected to change quickly due to load pick-up, planned, and emergency outages, and the UDS/RTBM may not be accurately predicting a resulting overload on the M2M Flowgate in the near future. When a reduction in binding percentage is initiated by the operator to mitigate expected impacts on an M2M Flowgate from a planned outage, that action shall be taken to prepare the system consistent with the time submitted on the outage ticket or as revised by the equipment operator. This reduction should be for as short a time as practicable but may be extended if the outage is delayed. If possible, initiating the reduction in binding percentage shall be delayed until the outage begins. b. M2M Flowgates may be de-rated for a short period of time to preposition the system for an expected change. These expected changes can include: i. Change in unit status (anticipated as part of an upcoming outage, reacting to an imminent emergency outage, or change in commitment if the unit for which the commitment was changed cannot be adequately ramped to allow normal redispatch to manage any resulting constraints). ii. Transmission system topology change (either anticipated event or as part of an upcoming planned outage). In this case, every effort shall be made to add the expected

18 constraint to the systems and bind on the expected constraint instead of using a substitute Flowgate. iii. Increase or decrease in wind generation output. c. Reducing the limit to pre-position the system will be considered an appropriate use of M2M tools but subject to settlement adjustment for substitute M2M Flowgates applying a hold harmless approach discussed in the After the Fact Review process set forth in Section 8.4 below. The time duration of such events shall be limited to that necessary to pre-position to avoid excessive impacts on market prices. 8.3 Specific Conditions Applicable to Section (Operating Guides) All op guides are subject to review by MISO and SPP through which either RTO can request removal of a reference to the M2M process. Where reference to the M2M process has been removed and not replaced by alternate congestion management actions, the use of SOM will be added to the op guide if it is not already included in the op guide. Before modifying existing op guides, MISO and SPP will agree to a mechanism to manage congestion that will avoid the need for repeated SOM declarations on the same constraint In the event of severe abnormal system conditions, such as storm damage to critical facilities, the Parties shall meet as soon as practicable to agree upon the response, which shall be incorporated into a temporary operating guide. 8.4 After-the-Fact Review to Determine Market-to-Market Settlement Based on the communication and data exchange that has occurred in real-time between the Monitoring RTO operator and the Non-Monitoring RTO operator, there will be an opportunity to review the limit change and the use of the M2M process to verify it was an appropriate use of the M2M process per this Agreement and good utility practice and subject to M2M settlement. The Monitoring RTO will initiate the review as necessary to apply these conditions and settlements adjustments. a. A review will verify that the limit used in the M2M coordination represented the actual limit of the monitored element of the original Flowgate that has passed one of the M2M Flowgate Studies. The Monitoring RTO will archive and make available data (including all UDS/RTBM solutions) that supports the decision to change the M2M Flowgate limit. The Parties will mutually agree upon, and document in writing and post on the Parties websites, the data that should be exchanged and/or archived to meet this requirement, and shall retain the

19 data for the period applicable to other data used to audit settlements inputs and market flow calculations under this agreement. b. A review will verify the outcome of the M2M Flowgate Studies and whether the potential Flowgate passed one of the M2M Flowgate Studies by both the Monitoring RTO and the Non-Monitoring RTO. The Monitoring RTO uses M2M tools before a M2M Flowgate is approved at its own risk regarding M2M settlement. After the M2M Flowgate Studies are complete, if the Flowgate did not pass at least one of the studies conducted by the Monitoring RTO and at least one of the studies conducted by the Non- Monitoring RTO, then settlements will be adjusted as follows. i. If the Non-Monitoring RTO s integrated market flows are below its Firm Flow Entitlement for the hour, there will be a normal M2M settlement with a payment from the Monitoring RTO to the Non- Monitoring RTO for the hour. ii. iii. If the Non-Monitoring RTO s integrated market flows exceed its Firm Flow Entitlement for the hour, there will be no M2M settlement for the hour. If the Monitoring RTO was requested to initiate the M2M process on the Monitoring RTO s Flowgate to assist the Non-Monitoring RTO, the Monitoring RTO will be held harmless as follows. a. If the Non-Monitoring RTO s integrated market flows are below its Firm Flow Entitlement for the hour, there will be no market-to- market settlement for the hour. b. If the Non-Monitoring RTO s integrated market flows exceed its Firm Flow Entitlement for the hour, there will be a normal market- to-market settlement with a payment from the Non-Monitoring RTO to the Monitoring RTO for the hour The Non-Monitoring RTO may request the Monitoring RTO to implement the M2M process on its behalf. There will be an after the fact review performed to determine whether this M2M event should be subject to settlement. If the review finds it is subject to settlement, the usual criteria will be applied. If the review finds it is not subject to settlement, the usual criteria will be applied except that the Monitoring RTO shall be held harmless. a. If the Non-Monitoring RTO s integrated market flows are below its Firm Flow Entitlement for the hour, there will be no M2M settlement for the hour.

20 b. If the Non-Monitoring RTO s integrated market flows exceed its Firm Flow Entitlement for the hour, there will be a normal M2M settlement with a payment from the Non-Monitoring RTO to the Monitoring RTO for the hour A new M2M Flowgate shall be subject to a hold-harmless provision for the balance of the current operating day in which the M2M Flowgate is submitted for coordination by the Monitoring RTO as a result of a planned outage in the Monitoring RTO s system as provided below: a) If the Non-Monitoring RTO s integrated market flows are below its Firm Flow Entitlement for the hour, there will be a market-to-market settlement with a payment from the Monitoring RTO to the Non-Monitoring RTO for the hour. b) If the Non-Monitoring RTO s integrated market flows exceed its Firm Flow Entitlement for the hour, there will be no market-to-market settlement for the hour. c) Notwithstanding the above provisions, these hold-harmless provisions shall not apply (i.e., a market-to-market settlement will occur) if the new M2M Flowgate was necessitated by an unplanned outage (forced, emergency, or urgent) that could not meet normal outage scheduling timeframes. Nothing in this section is intended to restrict either Party s ability to submit new M2M Flowgates for coordination using the real-time market-to-market coordination procedures The settlement provisions, including exceptions, contained in Section shall also apply for the next operating day when a new M2M Flowgate is submitted for coordination by the Monitoring RTO, as a result of a planned outage in the Monitoring RTO s system, subsequent to the cutoff for data submission of (i.e., the close of) the Non-Monitoring RTO s Day-Ahead market A new M2M Flowgate shall be subject to a hold-harmless provision for the balance of the current operating day in which the M2M Flowgate is submitted for coordination by the Monitoring RTO as a result of a planned outage in the Non- Monitoring RTO s system as provided below: a) If the Non-Monitoring RTO s integrated market flows exceed its Firm Flow Entitlement for the hour, there will be a market-to-market settlement with a payment from the Non-Monitoring RTO to the Monitoring RTO for the hour.

21 b) If the Non-Monitoring RTO s integrated market flows are below its Firm Flow Entitlement for the hour, there will be no market-to-market settlement for the hour. c) Notwithstanding the above provisions, these hold-harmless provisions shall not apply (i.e., a market-to-market settlement will occur) if the new M2M Flowgate was necessitated by an unplanned outage (forced, emergency, or urgent) that could not meet normal outage scheduling timeframes. d) Notwithstanding the above provisions, these hold-harmless provisions shall not apply (i.e., a market-to-market settlement will occur) if the planned outage had been previously coordinated with the Monitoring RTO but the M2M Flowgate was submitted after the beginning of the current operating day by the Monitoring RTO. Nothing in this section is intended to restrict either Party s ability to submit new M2M Flowgates for coordination using the real-time M2M coordination procedures The settlement provisions, including exceptions, contained in Section shall also apply for the next operating day when a new M2M Flowgate is submitted for coordination by the Monitoring RTO as a result of a planned outage on the Non- Monitoring RTO s system, subsequent to the cutoff for data submission of (i.e., the close of) the Monitoring RTO s Day-Ahead market. 8.5 M2M Data Exchange A data exchange will be established. Parties shall mutually agree upon data, format and frequency of exchanges. The data exchange must be updated to include, but not be limited to, the following data as soon as practicable if requested by either Party. a. actual Flowgate SE/SA flow from the approved case, b. UDS/RTBM solution %, c. operator entered binding %, d. actual Flowgate limit, and e. shadow price.

22 3.1 Real-Time Energy Market Coordination Procedures The following procedure will apply for managing M2M Flowgates in the realtime energy market: 1. The RTOs will exchange topology information to ensure that their respective market software is consistent. 2. When any of the M2M Flowgates under a Monitoring RTO s control is identified as a transmission constraint violation, the Monitoring RTO will enter the M2M Flowgate into its security-constrained dispatch software, setting the flow limit equal to the Effective Limit required for reliability. 3. The Monitoring RTO will then notify the Non-Monitoring RTO of the transmission constraint violation and will identify the appropriate M2M Flowgate that requires mitigation. 4. When the M2M Flowgate first becomes a binding transmission constraint in the Monitoring RTOs Real-Time security-constrained economic dispatch, the Monitoring RTO will transmit the following information to the Non-Monitoring RTO: Constraint Shadow Price ($/MW) - output of the RTOs Real-Time market software. Current Market Flow contribution by the Monitoring RTO on M2M Flowgate (MW) - output of the Real-Time market software. Amount of MWs requested to be reduced from the current market flow of the Non-Monitoring RTO. This number will change throughout the iterative process to efficiently resolve constraints. 5. The Non-Monitoring RTO will enter the M2M Flowgate into its securityconstrained dispatch software, setting the flow limit on the M2M Flowgate equal to its current market flow minus the relief requested by the Monitoring RTO. (a) This means the Non-Monitoring RTO will attempt to manage the flow on the M2M Flowgate at its current Market Flow amount or less, such that it will not contribute any additional flow on the limited M2M Flowgate during this time period. 6. If the Non-Monitoring RTO has sufficient generation to be redispatched, it will redispatch its generation to control the M2M Flowgate until one of the following conditions is reached:

23 (a) (b) The Non-Monitoring RTO has provided the relief requested by the Monitoring RTO. The Non-Monitoring RTO has provided relief at a cost as high as the current shadow price from the Monitoring RTO. 7. The Non-Monitoring RTO will then transmit the following information to the Monitoring RTO: Constraint Shadow Price (S/MW) - Output of the RTOs Real-Time market software. (If the M2M Flowgate does not result in a binding constraint in the Non-Monitoring RTO s securityconstrained economic dispatch, then the shadow price is zero and the Flow Relief is zero for the Non- Monitoring RTO.) Current market flow contribution by the Non-Monitoring RTO on M2M Flowgate (MW) - Output of the RTO s Real-Time market software. 8. Over the next several dispatch cycles the Monitoring RTO may request the Non- Monitoring RTO to adjust its flow limit up or down. The Monitoring RTO will continue to control the M2M Flowgate respecting the Effective Limit of the facility required for reliability. 9. As the relief provided by the Non-Monitoring RTO is realized in the M2M Flowgate, the Monitoring RTO can control the M2M Flowgate at a lower shadow price since less relief is needed from the Monitoring RTO. The updated shadow price will be sent to the Non-Monitoring RTO. The Non- Monitoring RTO will then control the M2M Flowgate using the latest shadow price from the Monitoring RTO as the shadow price limit. 10. Throughout the period that the transmission constraint violation exists, the RTOs will continue to share the flow and constraint shadow price information that is described above. The shadow prices of the two RTOs will eventually converge towards the most cost-effective redispatch solution, provided both RTOs have sufficient redispatch capability. The information transferred via these data exchanges will be retained to provide the pertinent data for Market Settlements. 11. The Monitoring RTO will review the constraint shadow price comparison, make required adjustments, and communicate any such adjustments to the Non-Monitoring RTO. This process will continue until the Monitoring RTO determines that the cost of further adjustments to the dispatch of the Non-Monitoring RTO would exceed the cost of relieving the transmission constraint by adjusting the Monitoring RTO s own dispatch.

24 12. The start and stop times for such Constrained Operation events involving M2M Flowgates will be logged for Market Settlements purposes. 13. M2M Flowgates should not be permitted to be added outside of mutually agreed-upon scheduling timeframes except in extreme, extenuating circumstances or unless the RTO requesting the additional flowgate is willing to compensate the other RTO for any redispatch provided for that flowgate.

25 8 Appropriate Use of the Market-to-Market Process A subset of flowgates that meet the criteria as described in Section 1.1, impacted by market flows from the two RTOs energy markets, will be subject to the M2M process and called M2M Flowgates. This subset will be controlled using M2M tools for coordinated redispatch and additionally will be eligible for M2M settlements. In principle and as much as practicable, Parties agree that the goal is to control to the most limiting Flowgate using the actual Flowgate limit. The RTOs will record and exchange actual M2M Flowgate limits, the limit used to bind, and a reason for significant deviation. There are times when either Party, acting as the Monitoring RTO, will bind a M2M Flowgate different from its actual limit. The Parties have agreed in subsections 8.1 through 8.4 of this Section 8 to the conditions under which M2M settlement will occur even though a limit to which the Monitoring RTO is binding (limit control) is less than its actual limit. 8.1 Qualifying Conditions for Market-to-Market Settlement: Purpose of Market-to-Market. M2M was established to address regional, not local issues. The intent is to implement M2M coordination and settle on such coordination where both Parties have significant impact Minimizing Less than Optimal Dispatch. The Parties agree that, as a general matter, they should minimize financial harm to one RTO that results from M2M coordination initiated by the other RTO that produces less than optimal dispatch, which can lead to revenue inadequacy for FTR/TCR and impose the burden for such revenue inadequacy on one or both RTOs Use Market-to-Market Whenever Binding a M2M Flowgate. The M2M process will be initiated by the Monitoring RTO whenever an M2M Flowgate is constrained and therefore binding in its dispatch Addition of M2M Flowgates. At times additional M2M Flowgates may be added upon mutual consent of both Parties. If one Party does not agree to the submission by the other Party in 30 days to the new M2M flowgate, that submission is deemed rejected. M2M Flowgates should not be permitted to be added outside of mutually agreeable scheduling timeframes except in extreme, extenuating circumstances or unless the Party requesting the additional M2M Flowgate is willing to compensate the other Party for any redispatch provided for that flowgate Most Limiting Flowgate. Generally, controlling to the most limiting Flowgate provides the preferable operational and financial outcome. In principle and as much as practicable, M2M coordination will take place on the most limiting Flowgate, and to that Flowgate s actual limit (thermal, reactive, stability).

26 a. M2M events that involve the use of a limit control that is below 95% of the actual limit will be subject to an after-the-fact review, unless the lower limit was agreed to by the RTOs prior to the market-to- market binding event. The review will determine if normal market-to- market settlements are appropriate. If M2M settlements are determined by the Parties not to be appropriate, then settlements will not occur on the M2M Flowgate. Sufficient real-time and after-the-fact data will be exchanged to enable these reviews. The Parties may agree to change the trigger for review to a lower number for specific Flowgates, however, either Party may request review of specific instances that are bound above the established binding percentage Substitute Flowgates. The Parties agree that, if the use of substitute Flowgates is minimized and the ability to coordinate on the most limiting Flowgate in the very near term is enabled, there should be very few instances where M2M coordination occurs without resulting settlement. a. Generally, M2M coordination without the normal market-to- market settlement will be limited to times when: (1) a substitute is used for a period in excess of that defined in Section (b) (ii) below, or (2) a substitute Flowgate (whether M2M or non-m2m) is used and the most limiting Flowgate is later determined to fail the M2M tests. b. Where the most limiting constraint (monitored/contingent element pair) is not a defined M2M Flowgate: i. Parties will add the Flowgate definition and activate market-tomarket coordination on that Flowgate (as opposed to a substitute) as soon as reasonably practicable; or ii. A substitute Flowgate may be used for a short time (generally less than an hour) until it is possible to coordinate using the most limiting Flowgate. Parties will attempt to use either: (i) the most limiting M2M Flowgate or (ii) the most limiting Flowgate that is modeled by both Parties, in that order of preference. If possible, the Parties should use another Flowgate that is limiting. Optimal choices are Flowgates with the same or very similar Market Flow impacts (sensitivities) resulting in a very similar redispatch and M2M settlement. c. A substitute Flowgate can be used in the M2M process pending the outcome of the coordinated Flowgate tests. The substitute Flowgate will be utilized only until the actual constraint can be entered in both the Monitoring and Non-Monitoring RTO systems as an M2M Flowgate. M2M settlement is dependent on the outcome of the coordinated Flowgate tests on the actual constraint and the RTO requesting the use of a