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RSC Workshop on the Integration of WAPA, Basin, Heartland April 4, 2014

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Page 1: RSC Workshop on the Integration of WAPA, Basin, Heartland slides for rsc 4-4-14 is... · Basin Electric • Basin Electric Power Cooperative (Basin Electric) is one of the largest

RSC Workshop on the Integration of WAPA, Basin, Heartland

April 4, 2014

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AGENDA

I. Impact of IS Joining SPP

II. Cost Allocation

III. Potential Clarification to RSC Bylaws

IV. SPP Bylaw and Membership Agreement Changes

V. Tariff Changes

VI. Other Business and Closing Comments/Adjournment

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OVERVIEW OF THE IS Western, Basin, and Heartland

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R35ESTYP

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Basin Electric

• Basin Electric Power Cooperative (Basin Electric) is one of the largest electric generation and transmission (G&T) cooperatives in the United States. They are the parent company of eight subsidiaries.

• A not-for-profit generation and transmission cooperative incorporated in 1961 to provide supplemental power to a consortium of rural electric cooperatives

• Diverse energy portfolio: coal, gas, oil, nuclear, distributed, and renewable energy, including wind power

• Consumer owned by 137 member cooperative systems

• Members' service territories comprise 540,000 square miles in nine states

• By end of year 2013 Basin Electric will operate 4,824 megawatts (MW) of wholesale electric generating capacity and have 5,289.2 MW of capacity within its generation portfolio

• Owns 2,165 miles and maintains 2,250 miles of high-voltage transmission, and owns and maintains equipment in 70 switchyards and 149 telecommunication sites

• Serves 2.8 million electric consumers

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Basin Electric Power Cooperative

• Consumer owned by 137 Member Cooperatives

• 11 Districts in 9 states

• Service Territories Comprise 540,000 square miles

• Serves 2.8 million electric consumers

• 5,289 MW of capacity within its generation portfolio

• 2,000 employees

• 8 subsidiaries 6

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Generation Portfolio

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Transmission Systems

IS

CUS

BEPW

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Sheridan Burke-

Divide

Mountrail-

Williams

McCone

Lower

Yellowstone McKenzie

Goldenwest

Roughrider

Slope

Southeast

Upper

Missouri

North

Central

Verendrye

McLean

Northern

Plains

Capital

Dakota Valley

Central

Power

MT ND

SD Grand

Williston

Basin

1300 MW

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Prairie Winds 2009

Blaisdell 2012

Pioneer 2013

Culbertson 2010

Lonesome Creek 2013

2010

2012

2011

Wheelock 2012

2014

2015

2014

2016

2013

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Page 12: RSC Workshop on the Integration of WAPA, Basin, Heartland slides for rsc 4-4-14 is... · Basin Electric • Basin Electric Power Cooperative (Basin Electric) is one of the largest

Heartland Background

• Non-profit public power district headquartered in Madison, South Dakota – Staff of 12

• Public corporation and political subdivision of the State of South Dakota – Formed in 1969 under South Dakota’s Consumers Power

District statutes – Title 49, Chapters 35-40 – Similar in structure to Nebraska public power entities

• Wholesale power supplier to 29 municipal system in SD, MN and IA, five South Dakota state institutions and one cooperative – mostly supplemental to WAPA

• Minority owner of the Integrated System • Most assets jointly owned with other public entities

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Heartland Customers and Resources

35 Customers (140 MW, 900 GWh)

Primary Resources

Laramie River

Station Unit 1

Whelan Energy

Center Unit 2

Wessington

Springs Wind

Energy Center

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Heartland’s Governance

• Powers of the district are vested in the Board of Directors – Ultimate decision-making

authority – Not state PUC or FERC

jurisdictional

• Board of Directors – 10 directors from subdivisions

in eastern South Dakota – Elected during general

elections – Six-year staggered terms – Non-partisan positions

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Western Area Power Administration

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Western Area Power Administration

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Where We Get The Power Western-UGP

Congressionally Authorized Project Purposes: • Flood Control • Navigation • Irrigation • M&I Water Supply • Hydropower • Recreation • Fish & Wildlife (includes endangered species)

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Western-UGP Stats:

• 378,000 square miles of service area

• 118 substations and 7,920 miles of transmission lines (Federal owned)

• 360+ power and transmission customers

• 2,675 MW installed capability (2 BOR, 6 COE facilities)

• Approx. 10,000 Gwh’s of energy produced in median year.

• Operate 2 Balancing Authorities (East and West systems)

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Integrated System Members

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History • 1963 – Missouri Basin Systems Group Pooling

Agreement signed,

– The Joint Transmission System (JTS) created

• 1998 – JTS was modified to become the Integrated System providing service under Western’s OATT

• 1995-2010 – Western and other IS transmission owners transmission facilities were a part of the Mid-Continent Area Power Pool (MAPP) Schedule F tariff for short-term point-to-point service

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Basin / Western / Heartland Integrated System (IS)

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And Other Facility Owners: Missouri River Energy Services

NorthWestern Energy

W/E

W/E

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IS PROCESS OF EVALUATING RTO MEMBERSHIP

Western, Basin, and Heartland

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IS PROCESS FOR EVALUATING RTO OPTIONS

• 10-15 years of study and discussions about any advantages for wider coordination

• September 2011 – Charles River Associates high level study showed RTO participation was beneficial.

• March 2013 – Brattle Study looking at:

– Standing alone

– Joining MISO

– Joining SPP

• SPP was best option

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SPP PROCESS OF EVALUATING IS MEMBERSHIP IN SPP

SPP

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Strategic Planning Committee

• Members adopted process within the SPC to assist SPP Staff with process of working with interested parties to explore membership in SPP.

• Used with all prospective members since Nebraska entities joined SPP.

• SPC appoints sub-group to assist Staff with regular reports to the SPC.

• Used during negotiations with Entergy on prospective membership

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IS Interest and SPC Role

• SPC chair appointed a sub-group in September, 2012 to assist SPP Staff with interest expressed by IS. This sub-group has met 10 times.

• SPP Staff reviewed progress with SPC in all meetings since then including three meetings (May 1, 2013, October 17, 2013 and January 16, 2014) that were in executive session including State Regulatory staff.

• In all these SPP Staff received comments and adjustments to the proposals in negotiations with the IS entities.

• SPP Staff validated with SPC the proposals provided to the IS parties in the negotiations.

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Integration Study

• As part of the discussions at the SPC, SPP Staff provided two analyses needed for the SPP members

– Cost/Benefit Analysis for SPP from IS joining SPP

– Transmission Analysis to insure that IS transmission facilities were up to SPP standards (SPP Criteria and SPP interpretation of NERC Standards) (See below)

Any facilities needed to upgrade to those standards would be the IS parties cost responsibility (some were identified that they were already planning to construct).

Additional the analysis provided the need-by dates for all IS construction expansion plans.

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February 24, 2014 SPP Stakeholder Workshop

• After the public announcements of the IS parties about pursuing joining SPP, SPP Staff scheduled a meeting for all stakeholders to review the proposed changes to SPP governing documents.

• The IS parties introduced themselves and SPP Staff walked through the SPP Bylaws, Membership Agreement and Tariff changes that were in the process of being edited for integrating the IS.

Presentation material is attached.

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IS Inclusion in the ITP Process

• The ITP 10-Y Assessment currently being considered includes the IS transmission facilities and generation

• IS transmission facilities will be included in all subsequent iterations of the ITP process

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WAPA/Basin/Heartland Transmission Integration Study

January 27, 2014

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Purpose

• Perform an evaluation of the Western/Basin/Heartland IS transmission system in the event a decision was made to join the SPP RTO.

– There were two main objectives of the Integration Study:

Evaluate the IS transmission system to determine whether it satisfies SPP’s Planning Criteria and NERC TPL Standards

Identify the SPP “need-by” dates of the transmission projects provided by the IS in relation to the assumed October 2015 integration date

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Stakeholder Involvement

• Seams Steering Committee (SSC) reviewed the study scope on September 5, 2013

• Transmission Working Group (TWG) reviewed the study scope on September 18, 2013

• Preliminary draft study report sent to TWG on September 30, 2013

• TWG reviewed final draft study report on October 23, 2013

– TWG endorsed the study as having been conducted in accordance with SPP’s planning criteria

• The IS provided input and information as needed throughout the process

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SPP and the Integrated System

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Study Process and Methodology

SPP started with 2014, 2015 and 2019 ITPNT models for the study

– 2014 winter peak, 2015 summer and winter peak, 2019 light-load, summer and winter peak

Data Inputs

37

Load Generation Resources

Model Topology

Transmission Service

Demand Response

Study Model

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Study Process and Methodology Cont.

• Non-contingency (base case), N-1, and select Category C contingency analysis was performed on the IS transmission system

– Facilities in the IS 69kV and above were monitored for potential violations of SPP Criteria and NERC TPL standards

• The IS provided mitigations and/or operating guides for the potential violations identified

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Costs Allocated under IS System

• Substation in Rapid City DC tie property – 230/115kV Dry Creek, with 200 MVA transformer and Rapid City- Dry Creek 115 kV line (4/1/2014)

• Ordway 1x20 MVAr 115 kV Capacitor (12/1/2014)

• Logan – SW Minot reconductor (12/1/2014)

• Replace Spencer KY1A, KY1B, Volt Reg with one 161/69 kV 150 MVA LTC Transformer (12/1/2014)

Cost Allocated under SPP’s Highway/Byway

• Phase I (12/1/2017) – AVS Switchyard, 345 kV – AVS to Charlie Creek 2, 345 kV Line – Charlie Creek Sub, 345 kV

• Phase II (12/1/2017) – Charlie Creek Sub to Indian Hills to Judson,

345 kV line – Judson Sub to Williston Sub, 230 kV – Judson Sub, 345/230 kV

• Phase III (Post 2019) – Gumbo Creek Sub, 345/115 kV – Gumbo Creek to Blue Butte to Indian Hill,

345 kV line – Blue Butte & Indian Hill Sub’s, 345/115 kV

• Phase IV (12/1/2017) – Jusdon Sub to Tande Sub 345 kV line – Tande Sub to Neset Sub 230 kV line – Tande Sub 345/230 kV – Neset Sub 230 kV

• Lower Brule 230 kV line & associated substation work (12/1/2016)

October 2015 Assumed Brightline

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Conclusion

42

• 24 potential reliability issues were identified

• 9 projects currently planned by the IS to address category A or B issues

– 4 are needed before the assumed integration date

– 4 are needed after the assumed integration date

– 1 was not identified as needed within the scope of the study

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OVERVIEW OF THE INTERCONNECTION BETWEEN SPP AND THE IS SYSTEM

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All ties from EI to

ERCOT and WI

via the SPP/IS

System

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Integration Comparison

47

IS to SPP MISO South to MISO

Load Additions (MW) 4000^ 23000^

Number of Transmission Ties 11* 1

Transmission Tie Capacity

(MW)3,000MW 1,000MW

Current + Addition + New

Total Load (MW)

51,000 + 4,000 =

55,000^

99,000+ 23,000 =

122,000^

*10 existing ties with 1 new tie to go in-service in 2018

^Annual peaks rounded to the nearest 1,000 MW

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ON-GOING SPP STAKEHOLDER PROCESS

SPP

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CGC Responsibilities • The SPP Corporate Governance Committee (CGC) is responsible for

overall governance structure of SPP. When necessary the CGC makes recommended changes to SPP governance structure. This responsibility is stated in the CGC Organizational Group Scope Statement dated October 29, 2013.

– Scope of Activities

The CGC is responsible for the overall governance structure, including nominations, for the company in accordance with its scope as approved by the Board of Directors.

– l) Review annually the structure of the Organizational Groups, and together with the Organizational Group Chairs, the charters of each Organizational Group, and recommend changes to the Board of Directors, as appropriate;

• 49

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SPP CGC Process for Integrating Western, Basin, & Heartland

Meeting Schedule February 27, 2014

Little Rock, AR Conference call

Date TBD March 31, 2014

Dallas, TX

Next Steps

Next Steps for CGC Recommendations

MOPC - April 15-16, 2014 Oklahoma City, OK

BOD/MC - April 29, 2014 Oklahoma City, OK

Areas of Changes to SPP Governance under consideration

SPP Membership Agreement

(1) Add “Federal Law” to pertinent sections; (2) Add references to “Federal Power Marketing Agencies” (FPMA) in

pertinent sections; (3) Addition of definitions to correspond with new definitions in OATT

(e.g. Upper Missouri Zone); (4) Add references to FERC's relationship with FMPA in ratemaking

context; (5) Add language about withdrawal and related obligations;

(6) Add language about assigning Membership Agreement; and (7) Party Specific Issues

SPP Bylaws (1) Add FPMA seats to the Members Committee and the CGC;*

(2) Added pertinent language about FPMA withdrawing as Members (Federal Law Matters)

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Changes to the SPP Membership Agreement (MA)

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Area of Change Description Locations of Changes

Definitions Federal Power Marketing Agency Federal Power – Western- UGP Statutory Load Obligations Upper Missouri Zone Western Area Power Administration – Upper Great Plains Region

1.0

Commitments, Rights, Powers and Obligations of

Member

Federal Exemption 3.0 (h)

Construction Coordinate construction with the appropriate Administrator of a FMA

3.3 (a)

Pricing Right to file rates at FERC under 10 CFR Part 903 and 18 CFR Part 300

3.10

No Waiver of Jurisdictional Immunity

FERC review of FPMA rates would be consistent with Delegation Order N0. 00-

037.00A

3.11

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Changes to the SPP MA (Cont.)

52

Area of Change Description Locations of Changes

Compliance with Federal or State Law

Non-jurisdictional member can not take action that is not consistent with Federal law. Adds language that compliance will

be determined by the FPMA Administrator

3.12

Events of Termination and Partial Termination

Clean up to add a reference to Section 8.2

4.1A.f.

Termination Procedures and Effective Dates

FPMA is not required to make a withdrawal deposit and will only pay

costs as provided at 4.3.2(e)

4.2.1 (b)

Effective Date of Termination (other Than Voluntary Withdrawal)

Provides for withdrawal of any member in less than 24 months and exit fees

required

4.2.2 (b)(v)

Regulatory and Other Authorities

Approval of participation is subject to respective federal authorities

5.1

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Changes to the SPP MA (Cont.)

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Area of Change Description Locations of Changes

Effectiveness as to Certain Members

Applicability of MA to a non-public utility to acquire waivers for financing

facilities

5.3

Governing Law Application of Federal Law for FPMA 8.1

Successors and Assigns Clean up language 8.2

Severability Clean up language 8.4

Specific Amendments for WAPA

Federal Service Exemption A1.2

Specific Amendments for WAPA

FPMA Termination of Agreement A1.11

Specific Amendments for Basin

Clean up language A1.-2.

Specific Amendments for Heartland

Clean up language A1.-2.

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Changes to SPP Bylaws

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Area of Change Description Locations of Changes

Definitions Define “Federal Power Marketing Agency”

1.0 Bylaws

Qualifications Opens membership to FPMA 2.1 Bylaws

Composition of Members Committee

Expand number from 19 to 21; increase state power agencies to

2; added 1 rep from FPMA

5.1.1.1 Bylaws

Corporate Governance Committee

Expand number from 9 to 10 to include a rep from a FPMA

6.6 Bylaws

Withdrawal Obligation Application of financial obligations to a FPMA

8.7.5 Bylaws

Amendments to Bylaws, MA, or Articles of

Incorporation

Application of changes in these documents to a FPMA

10.0 Bylaws

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RTWG Responsibilities

• PURPOSE

– The Regional Tariff Working Group (RTWG) is responsible for development, recommendation, overall implementation and oversight of SPP’s open access regional transmission service tariff (Tariff). The RTWG will further advise the SPP Staff on regulatory or implementation issues not specifically covered by the Tariff or issues where there may be conflict or differing interpretations of the Tariff. The RTWG provides policy input to the Market Operations Policy Committee (MOPC) and Board of Directors (BOD) and its committees, if requested.

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SPP RTWG Process for Integrating Western, Basin, & Heartland

Meeting Schedule March 12, 2014

Process Improvement Tariff TF Conference Call

OATT Changes Sent to RTWG Chair March 7, 2014

March 26-27, 2014 Dallas, TX

Next Steps

Next Steps for Tariff Language

MOPC - April 15-16, 2014 Oklahoma City, OK

RSC/BOD - April 28-29, 2014 Oklahoma City, OK

Areas of Changes to SPP OATT under consideration

OATT Changes

(1) Creation of New Pricing Zone, called the Upper Missouri Zone or "Zone 19," to cover the region in which the IS Owners and facilities are located;

(2) Defined "Federal Service Exemption" for WAPA/Western not being subject to certain charges for deliveries of federal power over the UMZ for purposes of fulfilling Western's statutory obligations and related changes to Schedule 11;

(3) Western is excluded from FERC Assessment costs in Schedule 12; and

(4) "Federal law" is added to pertinent references to state law obligations.

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Changes to SPP OATT

57

Area of Change Description of Changes

Definitions Modify “Base Plan Upgrades” to mark the “bright line” and specify certain Basin facilities as “Base Plan Upgrades” (facilities listed in Attachment J Appendix 1)

Definitions Define “Eastern Interconnection”

Definitions Define distinction between “Federal Power-Southwestern” and “Federal Power-Western-UGP”

Definitions Define “Federal Power Marketing Agency”

Definitions Define “Federal Service Exemption”

Definition of “GFA” expanded to include contracts executed prior to transferring control of facilities to SPP

Definitions Define “Statutory Load Obligations”

Definitions Define “Upper Missouri Zone”

Definitions Define “Western –UGP”

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Changes to SPP OATT (Cont.)

58

Area of Change Description of Changes

III. Network Integration Transmission Service

(Preamble)

Language added to state that NITS will be “coordinated with the Federal Service Exemption to allow Western-UGP to provide service”… “in accordance with its Statutory Load Obligations”.

IV. Special Rules on Use of the Tariff; 39.1

Clarify “Non-Public Utility” includes a FPMA and delete references to “public power”

IV. 39.3 (a)-(c) Replace “Western” with “Western-UGP”

IV. 39.3 (d) Insert language describing “Western-UGP Co-supply Arrangement”

IV. 39.3 (e) Insert language describing “Western-UGP Federal Service Exemption”

IV. 39.3 (f) – (g) Insert language describing “Federal Projects” and “Designated Resources”

IV. 39.3 (h) Insert language describing various natural resource laws Western-UGP must comply with

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Changes to SPP OATT (Cont.)

59

Area of Change Description of Changes

IV. Special Rules on Use of the Tariff (cont.); 39.3 (i),

(j), (k), and (l)

Insert language describing “Advance Funding”, “No Expansion of Jurisdiction, Waiver of Defenses, Liability for Penalties, or Inconsistent Obligations”, “Liability”, and “Western-UGP Rate Review” that are required to address WAPA-UGP specific issues as a FPMA.

Schedule 7 LT and ST Firm Point to Point Service

Insert “Zone 19: Upper Missouri Zone” under 1. Zonal Rates

Schedule 8 Non-Firm Point to Point Service

Insert “Zone 19: Upper Missouri Zone” under 1. Zonal Rates

Schedule 9 NITS Insert “Zone 19: Upper Missouri Zone” under 1. Zonal Rates

Schedule 11 Base Plan Charge and Region-wide Charge; I. Introduction

Insert language to describe the Federal Service Exemption for the Western-UGP for service within Zone 19

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Changes to SPP OATT (Cont.)

60

Area of Change Description of Changes

Schedule 12 FERC Assessment Charge; 2.

Applicability

Insert language to describe the Federal Service Exemption for the Western-UGP for the FERC Assessment Charge with regard to Pt-Pt and NITS

Attachment G Network Operating Agreement;

Section 15 - Assignment

Insert clarification regarding FPMA

Attachment H ATRR for NITS; Section I 1. and 2.

Insert language regarding cost recovery under the “Bright Line” date.

Attachment J Recovery of Costs Associated with New Facilities; Section III A. 2.

Insert language regarding Basin and cost recovery

Attachment J Recovery of Costs Associated with New

Facilities; Section V A.

Insert language to describe that Sponsored Upgrades built by a FPMA is only funded through a lump sum payment.

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Changes to SPP OATT (Cont.)

61

Area of Change Description of Changes

Attachment L Treatment of Revenues; Section II B. 2.

(f)

Insert clarification regarding SPP distribution of revenues for service outside a Network Customer’s system.

Attachment M Loss Compensation Procedure;

Section II

Insert language that Western-UGP losses will be settled in accordance with the Federal Service Exemption. Also included Zone 19 to Appendix 1

Attachment T Rate Sheets for Point to Point

Transmission Service

Insert language for rates for point-to-point service (firm and non-firm) for members of the Upper Missouri Zone

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FEDERAL SERVICE EXEMPTION

62

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Western-UGP Federal Service Exemption • Federal Statutes govern the functions and limitations of Western-UGP

– Federal Reclamation Law, largely contained in the Department of Energy Organization Act of 1977, the Reclamation Project Act of 1939, the Flood Control Act of 1944, and the Fort Peck Project Act of 1938

– Other Federal law as applicable, and specifically Western-UGP’s ability to join an RTO consistent with section 1232 of the Energy Policy Act of 2005

– Western has advised that consistent with its statutory obligations it cannot agree to: (1) involuntary cost allocation for third-party transmission facilities, which includes SPP’s cost allocation share under its tariff and (2) Western’s rates are subject to a different standard of review pursuant to the delegation of authority from the Department of Energy to FERC.

• Joining SPP is based on the fixed nature of the generation resources committed to the preference customers of Western-UGP as well as the sufficiency of existing transmission Western-UGP built to meet its requirements.

• Any Western-UGP power marketing activity beyond federal resources to federal load will be subject to full SPP transmission service charges

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Application of Rate Schedules and FSE

64

Type of Customer

1(a)

1

7 - 9

11

12

IOU Yes Yes Yes Yes Yes

IPP Yes Yes Yes Yes Yes

COOP Yes Yes Yes Yes Yes

Marketers Yes Yes Yes Yes Yes

Municipals Yes Yes Yes Yes Yes

ITCs Yes Yes Yes Yes Yes

State Agencies Yes Yes Yes Yes Yes

IS Owners

Basin Yes Yes Yes Yes Yes

Heartland Yes Yes Yes Yes Yes

WAPA* Yes Yes Yes No No

Schedules

*WAPA exemption from schedule 11 (regional portion) and schedule 12 only for FSE to serve Federal load with

Federal resources

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Attachment J Provision

• Attachment J (at III.A.2. b)) is modified to include:

“If the Base Plan Upgrade …. b) is deemed to be an initial Base Plan Upgrade of Basin Electric Power Cooperative and included in Appendix 1 to Attachment J;”

• This reflects that the costs of the Basin facilities listed in Appendix 1, which have a need by date after October 2015, will be recovered under the Highway/Byway.

65

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Why are only Basin Projects Considered?

• Western – UGP

– No new resources

– No new “load” obligations

– Transmission in place is only transmission charges allowed for preference customers

• Heartland

– No new transmission needed in near future

• Basin

– All transmission expansion needed for and constructed by Basin

66

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REGIONAL STATE COMMITTEE (RSC) TOPICS

SPP-RSC

67

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IMPACTS ON HIGHWAY/BYWAY COST ALLOCATION & OTHER COST

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IS and SPP Investment with Regional Recovery

69

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IS and SPP Investment with Regional Recovery

70

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Transmission Project Cost Sharing

• Only SPP and IS Projects with a need-by date after the Oct 15, 2015 Join Date are considered

• All projects have a 2.5% construction inflation applied to costs (from a 2013 base estimate year)

• All project costs are forecasted over a 40 year life (2.5% annual depreciation)

71

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$-

$2,000,000

$4,000,000

$6,000,000

$8,000,000

$10,000,000

$12,000,000

$14,000,000

$16,000,000

$18,000,000

$20,000,000

$-

$50,000,000

$100,000,000

$150,000,000

$200,000,000

$250,000,000

$300,000,000

$350,000,000

$400,000,000

AEP WR SPS OGE NPPD KCPL OPPD GMO WFEC EDE MKEC GRDA LES CUS SEPC MIDW IS

2015 - 2024 Transmission Cost

W/O Integration With Integration Cost Change

Transmission Cost Impact

72 *Present Values

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SPP ADMINISTRATIVE FEE ANALYSIS

73

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SPP’s Administration Rate

• SPP Provided a Forecast of SPP’s Net Revenue Requirements by Year recovered through the Admin. Fee (Sch. 1-A)

• The Annual Fee was Allocated in the Study based on Fixed Ratios between the IS and SPP

• WAPA loads were included in the portion of Admin. Fees allocated to the IS

74

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$(27,500,000)

$(25,000,000)

$(22,500,000)

$(20,000,000)

$(17,500,000)

$(15,000,000)

$(12,500,000)

$(10,000,000)

$(7,500,000)

$(5,000,000)

$(2,500,000)

$- $-

$20,000,000

$40,000,000

$60,000,000

$80,000,000

$100,000,000

$120,000,000

$140,000,000

$160,000,000

$180,000,000

$200,000,000

$220,000,000

AEP OKGE SPS WR KCPL NPPD OPPD GMO WFEC EDE LES GRDA CUS MKEC SEPC MIDW IS

Schedule 1A 2015-2024 Present Value

W/O Integration With Integration Change *Present Values

Admin Fee Impact

75 *Does not account for grandfathered agreements

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W/O Integration

43.2

Cents

With Integration

37.9

Cents

2016 Admin Fee Rate Impact

76 *Does not account for grandfathered agreements

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$-

$1,000,000

$2,000,000

$3,000,000

$4,000,000

$5,000,000

$6,000,000

$7,000,000

$(20,000,000)

$(15,000,000)

$(10,000,000)

$(5,000,000)

$-

$5,000,000

$10,000,000

$15,000,000

$20,000,000

$25,000,000

$30,000,000

Combined Impact Sch 1A & 11 2015-2024

Change in Sch 11 Change in Sch 1A Savings

Combined Admin Fee & Transmission Cost

77

Net benefit

for each SPP

TO

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QUANTIFIED BENEFITS AND COST TO SPP MEMBERS

78

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79

Metric 10 Year Total NPV @ 8%

Schedule 1-A $179,908 $115,902

Schedule 1, 7 & 8 ($50,830) ($34,107)

Schedule 11 ($125,002) ($85,435)

Reserve Sharing Benefits $34,380 $23,069

Integrated Marketplace Benefits $272,375 $187,408

Net over 10 Years $310,831 $206,837

Effect of IS Joining SPP

(Thousands of $)

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CLOSER LOOK AT ADMIN FEE AND TRANSMISSION COSTS

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81

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82

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RSC MEMBERSHIP

83

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RSC Bylaws

• When the Nebraska entities joined SPP, at the April 2009 meeting, the RSC bylaws were changed to state (reflected in red and underlined):

Membership shall be open to all official governmental entities that:

(a) Regulate the retail electricity or distribution rates or approve retail service areas of transmission-owning members or transmission-dependent utility members of the SPP; or

(b) Are the primary regulatory agency responsible for siting electric transmission facilities in states where there are transmission-owning members of the SPP or independent transmission companies that own or operate transmission facilities associated with the SPP.

84

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States Analyzed • Iowa

• Minnesota

• Montana

• North Dakota

• South Dakota

• Wyoming

85

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Ratemaking and Approval of Retail Service Territory

• No state commission has authority over Western, Basin, or Heartland over ratemaking or service area determination

• State commission authority over transmission siting varies.

86

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State Ratemaking or Approval of Retail Service Areas

IS Owner Ratemaking Retail Service Area

Basin Electric Coop No No

Heartland Consumers Power District

No No

Western Area Power Administration

No No

87

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Analysis of State Siting Authority

• No state has siting authority over WAPA

• The SD PUC has siting authority over Heartland Consumers Power District

88

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State Siting Authority Over Basin State Siting Authority

Basin Owned Facilities Under the SPP OATT

Iowa UB Authority over “any person authorized to transact business in the state” and covers transmission lines 69 kV and greater

A single 69kV line; .57 mi.; 50% ownership

Minnesota PUC Authority for all transmission facilities that are: i) over 230 kV or ii) over 100 kV and 10 miles in length or iii) crosses a state line

None

Montana PSC No siting authority over IS owners. Montana EPA has siting authority.

A single 115 kV line, no siting obtained by Basin; does not

serve retail in MT

North Dakota PSC

Authority over facilities that exceed 115kV Numerous Facilities

South Dakota PUC

Authority over a person engaged in transmission of energy for facilities that are over 115 kV

Numerous Facilities

Wyoming PSC No siting authority over IS owners. Separate Industrial Siting Council has authority over industrial facilities costing at least $96,900,000.

Two 345 kV lines, 42.2% ownership, no retail

customers in WY, LES also has ownership share

89

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Bylaw Change for Consideration

Current language:

Membership shall be open to all official governmental entities that:

(a) Regulate the retail electricity or distribution rates or approve retail service areas of transmission-owning members or transmission-dependent utility members of the SPP; or

(b) Are the primary regulatory agency responsible for siting electric transmission facilities in states where there are transmission-owning members of the SPP or independent transmission companies that own or operate transmission facilities associated with the SPP.

90

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Bylaw Change for Consideration (Cont.)

Proposed language:

Membership shall be open to all official governmental entities that:

…..

(b) Are the Primary Regulatory Agency responsible for siting electric transmission facilities in states where there are transmission-owning members of the SPP or independent transmission companies that own or operate transmission facilities under the SPP tariff associated with the SPP. “Primary Regulatory Agency” is the agency that has exercised authority over facilities placed under the SPP OATT that are greater than 100 kV and where the majority of the facilities are owned by an SPP Member.

91

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QUESTIONS???

92