the honorable kimberly d. bose - southwest power … 719-a compliance filing... · rtos and isos...

The Honorable Kimberly D. BoseOctober 27, 2009

approved the Tariff language for the EIS Market and ultimately certified SPP’s EIS Market for implementation on February 1, 2007.2 The provisions governing SPP’s EIS Market are contained in Attachment AE of the SPP Tariff.

B. Order Nos. 719 and 719-A

On October 17, 2008, the Commission issued Order No. 7193 to improve the operation of organized wholesale electric markets in the areas of demand response, long-term power contracting, market monitoring, and RTO and Independent System Operator responsiveness.4 Order No. 719 mandated that RTOs and ISOs, in consultation with stakeholders, submit a compliance filing to explain how existing Tariff language and practices comply with the reforms adopted in Order No. 719 or to specify plans to attain compliance.5 SPP submitted its filing to comply with Order No. 719 on April 28, 2009.6

On July 16, 2009, the Commission issued Order No. 719-A, denying in part and granting in part rehearing and clarification of Order No. 719. Specifically, Order No. 719-A modified certain Order No. 719 requirements, including:7 (i) acceptance of demand response bids by aggregators of retail customers (“ARC”) based upon the size of the retail utility serving such retail customers;8 (ii) development of mechanisms for sharing information about demand response resources with affected load-serving entities;9 and (iii) development and implementation of protocols allowing ARCs to

2 Sw. Power Pool, Inc., 118 FERC ¶ 61,055 (2007).3 Wholesale Competition in Regions with Organized Electric Markets, Order No.

719, III FERC Stats. & Regs., Regs. Preambles ¶ 31,281 (2008), as amended, 126 FERC ¶ 61,261, order on reh’g, Order No. 719-A.

4 Id. at P 2.5 Id. at P 8.6 Submission of Order No. 719 Compliance Filing Revising Tariff of Southwest

Power Pool, Inc., Docket No. ER09-1050-000 (Apr. 28, 2009) (“Order No. 719 Compliance Filing”). The Order No. 719 Compliance Filing is pending approval by the Commission.

7 The Commission granted rehearing of certain other aspects of Order No. 719, such as permitting RTO and ISO market monitoring units to provide monitoring services to market participants, which was prohibited in Order No. 719. Order No. 719-A at P 164. However, the Commission’s grant of rehearing on such issues does not require RTOs and ISOs to submit additional compliance filings unless an RTO or ISO elects to adopt such policies.

8 Id. at P 65-67.9 Id. at P 69.


operate in organized markets addressing concerns such as double-counting, deviation, underscheduling in the day-ahead market, metering, billing, settlement, information sharing, and verification measures.10 The Commission directed RTOs and ISOs to submit a compliance filing within 90 days addressing the first requirement in Order No. 719-A, and within 180 days addressing the second and third requirements.11

C. SPP Stakeholder Process

This filing has been developed through SPP’s stakeholder process, as described in more detail below. The Tariff revisions and market modifications proposed in this filing were discussed by the SPP Market Working Group (“MWG”)12 during its August 17, 2009 meeting and were accepted unanimously by the Regional Tariff Working Group (“RTWG”)13 during its August 27, 2009 meeting. The SPP MOPC14 reviewed the proposed Tariff revisions on October 13, 2009.

While SPP recognizes that stakeholder approval does not by itself cause a filing to be just and reasonable, SPP requests that the Commission extend appropriate deference to

10 Id. at P 70.11 Order No. 719-A requires RTOs and ISOs to submit compliance filings within 90

and 180 days of publication in the Federal Register, which occurred on July 29, 2009. Wholesale Competition in Regions With Organized Electric Markets, 74 Fed. Reg. 37,776 (July 29, 2009). Accordingly, compliance filings addressing Order No. 719-A requirements are due October 27, 2009 and January 25, 2010, respectively.

12 The MWG is responsible for the development and coordination of the changes necessary to support any SPP administered wholesale market(s), including energy, congestion management, and market monitoring, consistent with direction from the SPP Board of Directors and any applicable Commission Orders, Rules, and Regulations. The MWG reports directly to the SPP Markets and Operations Policy Committee (“MOPC”), which reports directly to the SPP Board of Directors.

13 The RTWG is responsible for development, recommendation, overall implementation, and oversight of SPP’s Tariff. The RTWG also advises 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 reports directly to the MOPC.

14 The MOPC consists of a representative officer or employee from each SPP Member and reports directly to the SPP Board of Directors. Among its responsibilities, the MOPC recommends modifications to the SPP Tariff. See Southwest Power Pool, Inc., Bylaws, Original Volume No. 4 § 6.1.


the wishes of its stakeholders regarding the Tariff modifications proposed herein, consistent with Commission precedent.15

II. DESCRIPTION OF TARIFF REVISIONS

In Order No. 719, the Commission directed each RTO and ISO to make a compliance filing proposing amendments to its Tariff to, among other things, accept bids from demand response resources in markets for ancillary services on a comparable basis to other resources16 and permit ARCs to bid demand response on behalf of retail customers directly into the organized ancillary services markets administered by RTOs and ISOs.17 In Order No. 719-A, the Commission affirmed many of its findings regarding demand response, but granted rehearing to require RTOs and ISOs to: (i) accept bids for demand response by ARCs based upon the size of the retail utility serving the ARC’s retail customers; (ii) develop through their stakeholder processes mechanisms for sharing information about demand response resources with affected load-serving entities; and (iii) develop with stakeholders and implement protocols for the operation of ARCs in organized markets.

As indicated above, Order No. 719-A requires RTOs and ISOs to submit filings by October 27, 2009 to comply with the first requirement and to submit filings to comply with the second and third requirements by January 25, 2010.18 The instant filing consists of revisions to the SPP Tariff to address the Commission’s first compliance requirement, accepting demand response bids by ARCs based on the size of a retail customer’s retail utility. SPP will submit an additional compliance filing by January 25, 2010, addressing

15 The Commission has previously recognized that provisions approved through the

stakeholder processes of RTOs and ISOs are due deference. See New Eng. Power Pool, 105 FERC ¶ 61,300, at P 34 (2003), reh’g denied, 109 FERC ¶ 61,252 (2004) (Commission approval of transmission cost allocation proposal based upon extensive and thorough stakeholder process); Policy Statement Regarding Regional Transmission Groups, 1991-1996 FERC Stats. & Regs., Regs. Preambles ¶ 30,976, at 30,872 (1993) (the Commission will afford an appropriate degree of deference to the stakeholder approval process). The Commission’s deference to RTO stakeholder processes has been upheld by the Courts. See Pub.Serv. Comm’n of Wis. v. FERC, 545 F.3d 1058, 1062-64 (D.C. Cir. 2008) (noting that the Commission often gives weight to RTO proposals that reflect the position of the majority of the RTO’s stakeholders) (citing Am. Elec. Power Serv. Corp. v. Midwest Indep. Transmission Sys. Operator, Inc., 122 FERC ¶ 61,083, at P 172 (2008)).

16 Order No. 719 at PP 15, 47.17 Id. at PP 15, 154.18 See supra note 11 and accompanying text.


the remaining requirements in Order No. 719-A (i.e., demand response information sharing with load-serving entities and ARC protocols addressing double counting, deviation, metering, and other issues discussed in Order No. 719-A).

The proposed Tariff revisions are attached in clean and redlined versions as Exhibit I and II, respectively.19

A. Aggregation of Retail Customers Based on the Size of the Customer’s Retail Provider

1. SPP’s Order No. 719 Compliance Filing

As indicated above, SPP administers a real-time EIS Market, which is governed by Attachment AE of the SPP Tariff. In Order No. 719, the Commission directed RTOs and ISOs to permit ARCs to bid demand response on behalf of retail customers directly into the organized ancillary service markets administered by the RTOs and ISOs, unless the laws or regulations of the relevant electric retail regulatory authority do not permit retail customers to participate.20 The Commission indicated that permitting aggregation will eliminate barriers to demand response participation in the organized markets, expand the amount of resources available to the market, increase competition, reduce prices, and enhance reliability.21

In its Order No. 719 Compliance Filing, SPP proposed to modify its Tariff to permit aggregation of retail customers by adding a new Section 1.2.10 to Attachment AE to state that ARCs may aggregate demand response of multiple end-use customers unless participation in demand response by such customers is precluded by the laws or regulations of the relevant electric retail regulatory authority, including state-approved retail tariffs.22 The proposed language requires ARCs wishing to offer demand response in the EIS Market to execute all agreements necessary to become a Market Participant under the SPP Tariff and Attachment AE,23 and indicates that ARCs will be treated

19 Exhibit II reflects the Tariff changes proposed in this filing in redline, along with

language that is pending before the Commission in SPP’s Order No. 719 Compliance Filing, identified in italics.

20 Order No. 719 at PP 154-164.21 Id. at P 154.22 Order No. 719 Compliance Filing, Exhibit No. 2, Second Revised Sheet No. 998. 23 Id.


comparably to other Market Participants offering resources in the EIS Market.24 Proposed Section 1.2.10 also sets forth requirements for ARC bids.25

2. Order No. 719-A Requirements

In Order No. 719-A, the Commission granted rehearing to modify its requirement for RTOs and ISOs to accept demand response bids from ARCs for ancillary services. The Commission

direct[ed] RTOs and ISOs to amend their market rules as necessary to accept bids from ARCs that aggregate the demand response of: (1) the customers of utilities that distributed more than 4 million MWh in the previous fiscal year, and (2) the customers of utilities that distributed 4 million MWh or less in the previous fiscal year, where the relevant electric retail regulatory authority permits such customers’ demand response to be bid into organized markets by an ARC.26

The Commission added that

RTOs and ISOs may not accept bids from ARCs that aggregate the demand response of: (1) the customers of utilities that distributed more than 4 million MWh in the previous fiscal year, where the relevant electric retail regulatory authority prohibits such customer’s demand response to be bid into organized markets by an ARC, or (2) the customers of utilities that distributed 4 million MWh or less in the previous fiscal year, unless the relevant electric retail regulatory authority permits such customers’ demand response to be bid into organized markets . . .27

Together, these provisions require RTOs and ISOs to accept bids from ARCs for demand response provided by retail customers of large retail utilities (distributing more than 4 million MWh in the previous year) unless the relevant electric retail regulatory authority has prohibited such participation, and to accept bids from ARCs for the demand response provided by retail customers of small retail utilities (i.e., a utility distributing 4 million MWh or less in the previous year) only if the relevant electric retail regulatory authority affirmatively allows such retail customers to participate in demand response. Order No. 719-A requires RTOs and ISOs to submit a compliance filing by October 27,

24 Id.25 Id. at Second Revised Sheet No. 998 – Original Sheet No. 998A.26 Order No. 719-A at P 60 (emphasis added).27 Id. (emphasis added).


2009 proposing amendments to their tariffs or otherwise demonstrating how their existing tariff provisions and market design comply with this requirement.28

3. Proposed Tariff Revisions to Comply with Order No. 719-A

SPP proposes two sets of revisions to comply with this Order No. 719-A requirement. First, SPP proposes to revise Section 1.2.2 of Attachment AE governing asset application and registration requirements for participation in the EIS Market. In its Order No. 719 Compliance Filing, SPP added a new subsection (i) to Section 1.2.2 requiring Market Participants wishing to offer controllable load as a resource in the EIS Market to include in their application and registration a certification, by means of a declaration by the relevant electric retail regulatory authority, as applicable, that participation by the Market Participant’s controllable load resource is not precluded by the laws or regulations of the relevant electric retail regulatory authority.29

SPP proposes herein to add a new subsection (j) to Section 1.2.2 to clarify that ARCs must also comply with the new registration and certification requirements applicable to other demand response resources for participation in the EIS Market.30 By expressly requiring ARCs to comply with the same registration and certification requirements as other demand response resources, SPP will be able to ensure that it has the information necessary to determine whether the demand response bid by an ARC is eligible to participate in the EIS Market under the modified aggregation requirements of Order No. 719-A regarding the size of the retail customer’s distribution utility. Moreover, as the Commission has repeatedly indicated, RTOs and ISOs should not be in the position of having to interpret the laws or regulations of the relevant electric retail regulatory authority;31 therefore, requiring ARCs to comply with the same certification requirements applicable to Market Participants offering demand response will help to avoid placing SPP in the position of interpreting the laws and regulations of retail regulatory authorities in its region.32

28 Id. at P 64.29 Order No. 719 Compliance Filing at 7-8 and Exhibit No. 2, Original Sheet No.

995A.30 See Exhibit II, First Revised Sheet No. 995A.31 See, e.g., Order No. 719-A at P 50; Order No. 719 at PP 49 n.78 and 158 n. 212.32 Additionally, in Order No. 719, the Commission expressly indicated that RTOs

and ISOs could condition an ARC’s eligibility on the ARC providing a certification that “participation is not precluded by the relevant electric retail regulatory authority.” Order No. 719 at P 158. This proposed revision clarifies that certification requirements apply both to individual demand response resources and to ARCs.


Second, SPP proposes to revise Section 1.2.10 of Attachment AE governing aggregation of retail customers. As indicated above, SPP proposed revisions to Attachment AE in its Order No. 719 Compliance Filing to adopt Section 1.2.10 to allow aggregation of retail customers and to govern ARC bids.33 SPP proposes to revise Section 1.2.1034 to adopt the brightline distinction required by Order No. 719-A by adding language indicating that ARCs may aggregate demand response of:

(1) end-use retail customers of utilities that distributed more than 4 million MWh in the previous fiscal year, unless precluded by the laws or regulations of the relevant electric retail regulatory authority including state-approved retail tariff(s);35 and

(2) end-use retail customers of utilities that distributed 4 million MWh or less in the previous fiscal year, where the relevant electric retail regulatory authority, including any state-approved retail tariff(s), affirmatively permits such customer’s demand response to be bid into the SPP EIS Market by an ARC.36

These revisions codify the Order No. 719-A distinction between large and small distribution utilities for the purposes of accepting bids from ARCs while providing SPP with the information necessary to determine an ARC resource’s eligibility without having to interpret retail laws and regulations, and are therefore just and reasonable and should be accepted by the Commission.

33 See supra notes 22 through 25 and accompanying text; see also Order No. 719

Compliance Filing, Exhibit No. 2, Second Revised Sheet No. 998 – Original Sheet No. 998A.

34 See Exhibit II, Third Revised Sheet No. 998 (emphasis added).35 See id. (emphasis added). This language is retained from SPP’s Order No. 719

Compliance Filing, but is being modified to apply only to retail customers of utilities that distributed more than 4 million MWh in the previous year.

36 See id. (emphasis added); see also Order No. 719-A at P 67 (“For smaller systems under the [4 million MWh] size requirement, ARCs may aggregate retail customers only if affirmatively permitted to do so by the relevant electric retail regulatory authority.”) (emphasis added).


III. ADDITIONAL INFORMATION

A. Information Required by the Commission’s Regulations

1. Documents submitted with this filing:

In addition to this transmittal letter, the following exhibits are included in this filing:

Exhibit I Revised Tariff Sheets (Clean Version)

Exhibit II Revised Tariff Sheets (Redlined Version)

Exhibit III List of SPP Customers, Members and State Commissions

2. Effective Date:

SPP requests that the Commission accept the proposed Tariff revisions effective December 27, 2009.

3. Service:

SPP has served a copy of this filing on all its Members and Customers. A complete copy of this filing will be posted on the SPP web site, www.spp.org, and is also being served on all affected state commissions. SPP has also served a copy of this filing on all individuals listed on the service list established by the Commission in Docket No. ER09-1050, SPP’s Order No. 719 compliance docket.

4. Requisite Agreements:

None.

Southwest Power Pool First Revised Sheet No. 995AFERC Electric Tariff Superseding Original Sheet No. 995AFifth Revised Volume No. 1

Issued by: Heather H. Starnes, Manager, Regulatory Policy

Issued on: October 27, 2009 Effective: December 27, 2009

Filed to comply with order of the Federal Energy Regulatory Commission, Docket No. RM07-19-001, issued July 16, 2009, 128 FERC ¶ 61,059 (2009).

(i) A Market Participant wishing to offer controllable load as a

resource in the EIS Market must include in its application and registration

a certification by means of a declaration by the relevant electric retail

regulatory authority, as applicable, that participation in the EIS Market by

its controllable load resource is not precluded under the laws or

regulations of the relevant electric retail regulatory authority. Controllable

load resources must meet all application, registration and technical

requirements applicable to other resources offering imbalance energy in

the EIS Market. The Transmission Provider is not responsible for

interpreting the laws or regulations of a relevant electric retail regulatory

authority and shall be required only to verify that the Market Participant

has included such a certification in its application materials. The

Transmission Provider is not liable or responsible for Market Participants

participating in the EIS Market in violation of any law or regulation of a

relevant electric retail regulatory authority including state-approved retail

tariff(s).

(j) An aggregator of retail customers (“ARC”) offering controllable

load of one or more end-use retail customers as a demand response

resource in the EIS Market must be a Market Participant, satisfying all

registration and certification requirements applicable to Market

Participants as well as certification consistent with Section 1.2.10 of this

Attachment.

Southwest Power Pool, Inc. Third Revised Sheet No. 998FERC Electric Tariff Superseding Second Revised Sheet No. 998Fifth Revised Volume No. 1




Market Effective Date, Balancing Authorities’ shall act as the meter agent

for all Market Participant Resources and load within the Transmission

Owners’ zone unless mutually agreed upon by the Balancing Authority

and Market Participant for another entity to perform the meter agent

function. Subsequent to the first calendar year following the EIS Market

Effective Date, a Market Participant may designate any qualified entity to

perform the meter agent function or perform this function on its own

behalf. Any entity performing the meter agent function for a Market

Participant must execute the Meter Agent Agreement specified in

Attachment AM prior to performing such function.

1.2.9 Calculation of Real-Time Demand Response from Variable Demand

Response Resources

The demand response provided by the Variable Demand Response

Resource is sent directly to the Transmission Provider. This value will

represent the actual net generation.

1.2.10 Aggregation of Controllable Load as a Resource

For purposes of participation in the SPP EIS Market, an ARC may

aggregate demand response of: (1) end-use retail customers of utilities that

distributed more than 4 million MWh in the previous fiscal year, unless

precluded by the laws or regulations of the relevant electric retail

regulatory authority including state-approved retail tariff(s); and (2) end-

use retail customers of utilities that distributed 4 million MWh or less in

the previous fiscal year, where the relevant electric retail regulatory

authority, including any state-approved retail tariff(s), affirmatively

permits such customer’s demand response to be bid into the SPP EIS

Market by an ARC. An ARC wishing to offer demand response in the EIS

Market must execute all agreements necessary to become a Market

Southwest Power Pool, Inc. First Revised Sheet No. 998AFERC Electric Tariff Superseding Original Sheet No. 998AFifth Revised Volume No. 1




Participant and to participate in the EIS Market under the SPP Tariff and

Attachment AE. ARCs shall be treated comparably to other Market

Participants offering Resources in the EIS Market.

Aggregations pursuant to this section shall be subject to the following

requirements:

(a) End-use customers aggregated into a single Resource must be

located at the same physical and electrically equivalent withdrawal

point from the Transmission System and must be served by the

same retail provider; and

(b) All end-use customers in an aggregation shall be specifically

identified.

1.3 Transmission Provider Obligations

1.3.1 Market Protocols

The Transmission Provider shall prepare, maintain and update the Market

Protocols consistent with this Tariff. The Market Protocols shall be posted

on the SPP website.

1.3.2 Scheduling and Dispatch

The Transmission Provider shall evaluate Resource Plans submitted by

Market Participants during the Day-Ahead Period and the Hour-Ahead

Period in accordance with Sections 2 and 3 of this Attachment.

Southwest Power Pool First Revised Sheet No. 995AFERC Electric Tariff Superseding Original Sheet No. 995AFifth Revised Volume No. 1



Filed to comply with order of the Federal Energy Regulatory Commission, Docket No. RM07-19-001, issued July 16, 2009, 128 FERC ¶ 61,059 (2009).Italicized language reflects language pending before the Commission in Docket No. ER09-1050 filed on April 28, 2009.

(i) A Market Participant wishing to offer controllable load as a

resource in the EIS Market must include in its application and registration

a certification by means of a declaration by the relevant electric retail

regulatory authority, as applicable, that participation in the EIS Market

by its controllable load resource is not precluded under the laws or

regulations of the relevant electric retail regulatory authority.

Controllable load resources must meet all application, registration and

technical requirements applicable to other resources offering imbalance

energy in the EIS Market. The Transmission Provider is not responsible

for interpreting the laws or regulations of a relevant electric retail

regulatory authority and shall be required only to verify that the Market

Participant has included such a certification in its application materials.

The Transmission Provider is not liable or responsible for Market

Participants participating in the EIS Market in violation of any law or

regulation of a relevant electric retail regulatory authority including

state-approved retail tariff(s).

(j) An aggregator of retail customers (“ARC”) offering controllable

load of one or more end-use retail customers as a demand response

resource in the EIS Market must be a Market Participant, satisfying all

registration and certification requirements applicable to Market

Participants as well as certification consistent with Section 1.2.10 of this

Attachment.

Southwest Power Pool, Inc. Third Revised Sheet No. 998FERC Electric Tariff Superseding Second Revised Sheet No. 998Fifth Revised Volume No. 1


Issued on: October 27, 2009 Effective: December 27, 2009Filed to comply with order of the Federal Energy Regulatory Commission, Docket No. RM07-19-001, issued July 16, 2009, 128 FERC ¶ 61,059 (2009).Italicized language reflects language pending before the Commission in Docket No. ER09-1050 filed on April 28, 2009.

Market Effective Date, Balancing Authorities’ shall act as the meter agent

for all Market Participant Resources and load within the Transmission

Owners’ zone unless mutually agreed upon by the Balancing Authority

and Market Participant for another entity to perform the meter agent

function. Subsequent to the first calendar year following the EIS Market

Effective Date, a Market Participant may designate any qualified entity to

perform the meter agent function or perform this function on its own

behalf. Any entity performing the meter agent function for a Market

Participant must execute the Meter Agent Agreement specified in

Attachment AM prior to performing such function.

1.2.9 Calculation of Real-Time Demand Response from Variable Demand

Response Resources

The demand response provided by the Variable Demand Response

Resource is sent directly to the Transmission Provider. This value will

represent the actual net generation.

1.2.10 Aggregation of Controllable Load as a Resource

An aggregator of retail customers (“ARC”) For purposes of participation

in the SPP EIS Market, an ARC may aggregate demand response of:

multiple(1) end-use retail customers of utilities that distributed more than

4 million MWh in the previous fiscal year, unless precluded by the laws or

regulations of the relevant electric retail regulatory authority including

state-approved retail tariff(s); and (2) end-use retail customers of utilities

that distributed 4 million MWh or less in the previous fiscal year, where

the relevant electric retail regulatory authority, including any state-

approved retail tariff(s), affirmatively permits such customer’s demand

response to be bid into the SPP EIS Market by an ARC. An ARC wishing

to offer demand response in the EIS Market must execute all agreements

necessary to become a Market

Southwest Power Pool, Inc. First Revised Sheet No. 998AFERC Electric Tariff Superseding Original Sheet No. 998AFifth Revised Volume No. 1



Filed to comply with order of the Federal Energy Regulatory Commission, Docket No. RM07-19-001, issued July 16, 2009, 128 FERC ¶ 61,059 (2009).Italicized language reflects language pending before the Commission in Docket No. ER09-1050 filed on April 28, 2009.

Participant and to participate in the EIS Market under the SPP Tariff and

Attachment AE. ARCs shall be treated comparably to other Market

Participants offering Resources in the EIS Market.

Aggregations pursuant to this section shall be subject to the following

requirements:

(a) End-use customers aggregated into a single Resource must be

located at the same physical and electrically equivalent

withdrawal point from the Transmission System and must be

served by the same retail provider; and

(b) All end-use customers in an aggregation shall be specifically

identified.

1.3 Transmission Provider Obligations

1.3.1 Market Protocols

The Transmission Provider shall prepare, maintain and update the Market

Protocols consistent with this Tariff. The Market Protocols shall be posted

on the SPP website.

1.3.2 Scheduling and Dispatch

The Transmission Provider shall evaluate Resource Plans submitted by

Market Participants during the Day-Ahead Period and the Hour-Ahead

Period in accordance with Sections 2 and 3 of this Attachment.

SPP Customer List

Lundy KigerDirector of Gov't & Community RelationsAES Shady Point, LLCP.O. Box 1740Panama, OK 74951

Don MosierAmeren Energy Marketing Company1901 Choteau AvenueMail Code AME-902St. Louis, MO 63103

Shawn SchukarAmeren Services Company1901 Choteau AvenueMail Code AME-900St. Louis, MO 63103

Monique Rowtham-Kennedy, Senior CounselAmerican Electric Power 801 Pennsylvania Avenue, N.W.Suite 320Washington, D.C. 20004-2684

C. Richard Ross, Director Market DevelopmentAmerican Electric Power6705 E. 81st StreetSuite 160Tulsa, OK 74133

Ricky BittleArkansas Electric Cooperative Corp.P.O. Box 194208

Little Rock, AR 72219-4208

Chris BolickAssociated Electric Cooperative, Inc.2814 S. GoldenP.O. Box 754Springfield, MO 65801-0754

Vanessa KelloggBlue Canyon Windpower, LLC808 Travis StreetSuite 700Houston, TX 77002

Ms. Michelle HileyBarclays Bank PLC200 Park AvenueNew York, NY 10166

Greg BruceBP Energy Co.501 Westlake Park Blvd.Houston, TX 77079

Clifton KarneiBrazos Electric Power CooperativeP.O. Box 2585Waco, TX 76702-2585

Leon PigottBritish Columbia Power Exchange Corp.Suite 1400 – 666 Burrard StreetVancouver, British Columbia V6C2X8

Daniel WhyteBrookfield Power Corporation480 Boulevard de-la-CITEGatineau, Quebec J8T8R3

Brent HebertCalpine Energy Services L.P.717 Texas AvenueHouston, TX 77002

SPP Customer List

Gene BeckerCargill Power Markets, LLC12700 Whitewater DriveMS 151Minnetonka, MN 55343

Walter HornadayCielo Power Marketing, LP823 Congress AvenueSuite 500Austin, TX 78701

Robert Williams, General ManagerCarthage Water & Electric Plant149 E. 3rd StreetP.O. Box 611Carthage, MO 64836

Larry GatesCity of ChanuteP.O. Box 907Chanute, KS 66720

Jim SuttonCity of AugustaP.O. Box 489Augusta, KS 67010

John StephensCity Utilities of Springfield301 E. Central StreetP.O. Box 551Springfield, MO 65801

E. Leon DaggettCity of IndependenceP.O. Box 1019Independence, MO 64051

Mark MacDonald, Director FERC Regulatory AffairsCleco Support Group LLC2030 Donahue Ferry RoadPineville, LA 71360-5000

Mark MacDonald, Director FERC Regulatory AffairsCleco Power LLC2030 Donahue Ferry RoadPineville, LA 71360-5000

Wanda LeeCobb Electric Membership Corporation1000 EMC ParkwayMarietta, GA 30061

Tad JohnsenColumbia Water and Light DepartmentP.O. Box 6015Columbia, MO 65205

Dave VelazquezConectiv Energy Supply, Inc.P.O. Box 6066Newark, DE 19714-6066

Russell MartinsonConAgra Trade Group, Inc.Eleven ConAgra Drive, STE 11-160Omaha, NE 68102

Randall OsteenConstellation Energy Commodities Group, Inc.111 Market PlaceSuite 500Baltimore, MD 21202

SPP Customer List

Maria HendrixConoco Inc.600 North Dairy Ashford (CH1081)Houston, TX 77079

Barbara SchaubDominion Energy Marketing, Inc.120 Tredegar StreetRichmond, VA 23219

Diane DavisCoral Power909 Fannin, Plaza Level OneHouston, TX 77010

Supervisor Power Accounting and BillingDuke Energy139 East Fourth StreetP.O. Box 960Cincinnati, OH 45201

Marcia HissongDTE Energy Trading414 South Main StreetSuite 200Ann Arbor, MI 48104

Seth BrownEast Texas Electric Cooperative, Inc.P.O. Box 631623Nacogdoches, TX 75623-1623

Chris ArmitageEagle Energy Partners, L.L.P.4700 West Sam Houston Parkway N.Suite 250Houston, TX 77041

Byron M. Farnsworth, Jr.Energetix, Inc.755 Brooks AvenueRochester, NY 14619

Kelly WaltersEmpire District Electric CompanyP.O. Box 127Joplin, MO 64802

Andrea Weinstein, Assistant General CounselEntergy Power Ventures, LP101 Constitution Ave., N.W.Suite 200-EastWashington, D.C. 20001

Brooke SeimsEnergy Transfer Group3738 Oaklawn AvenueDallas, TX 75219

Matt WolfEntergy Services, Inc.Parkwood Two Bldg., Suite 30010055 Grogan’s Mill Rd.The Woodlands, TX 77380

Tom Reagan, President, Competitive OperationsEntergy Power Ventures, LP1661 Gravier StreetNew Orleans, LA 70112

Kristy AshleyExelon Generation Company, LLC1005 Congress AvenueAustin, TX 78701

SPP Customer List

Michael Kiefner, Chief Operating OfficerGrand River Dam AuthorityP.O. Box 409Vinita, OK 74301-0409

Mark W. Schwirtz President and General ManagerGolden Spread Electric Coop., Inc.P.O. Box 9898Amarillo, TX 79105

Mr. Jim DeTourHastings Utilities1228 N. Denver AvenueP.O. Box 289Hastings, NE 68902

Regulatory AffairsInterGen Services, Inc.15 Wayside RoadBurlington, MA 01803

Don TriggHigginsville Municipal UtilitiesP.O. Box 110Higginsville, MO 64037

Kathy BeniniJ. Aron & Company85 Broad Street26th FloorNew York, NY 10004

Cynthia NossanJ. Aron & Company1 New York Plaza, 38th FloorNew York, NY 10004

Vincenzo FrancoVanNes Feldman1050 Thomas Jefferson St., N.W.Washington, D.C. 20007

Daniel FeitJ. Aron & Company1 New York Plaza38th FloorNew York, NY 10004

Ronald BowenJonesboro City Water & LightP.O. Box 1289Jonesboro, AR 72403

Ms. Bridget PattiJW Prairie Wind Power645 MassachusettsSuite 300Lawrence, KS 66044

Patty DennyKansas City Power & Light CompanyP.O. Box 418679Kansas City, MO 64141-9679

Mr. Charles LockeKansas City Power & Light CompanyP.O. Box 418679Kansas City, MO 64141-9679

Robert D. BowserKansas Electric Power CooperativeP.O. Box 4877Topeka, KS 66604-0877

SPP Customer List

Neil RowlandKansas Municipal Energy Agency6330 Lamar Avenue, Suite 110Overland Park, KS 66202-4247

Mr. Colin WhitleyKansas Power Pool200 W. DouglasSuite 601Wichita, KS 67202

Bob AdamKC Board of Public Utilities312 N. 65th StreetKansas City, KS 66102

Frank LedouxLafayette Utilities Systems1314 Walker RoadP.O. Box 4017-C

Lafayette, LA 70502

Dennis FloromLincoln Electric System1040 O StreetLincoln, NE 68501

Doug CurryLincoln Electric System1040 O StreetLincoln, NE 68501

Eric RuskampLincoln Electric System1040 O StreetLincoln, NE 68501

Andrea Kraft, Manager of Wholesale PowerLuminant Energy Company, LLCEnergy Plaza1601 Bryan Street, Suite 11005BDallas, TX 75201

Anchalee DoMerrill Lynch Commodities, Inc.20 E. Greenway Plaza – 8th FloorHouston, TX 77046

William DowlingMidwest Energy1330 Canterbury RoadP.O. Box 898Hays, KS 67601-0898

Gregory C. SchaeferRegulatory Manager, Wholesale TradingMid-American Energy Company4299 Northwest Urbandale DriveUrbandale, IA 50322

Chuck LangstonMunicipal Energy Agency of NebraskaP.O. Box 951241111 O Street, Suite 200Lincoln, NE 68509-5124

Deborah HartMorgan Stanley Capital Group, Inc.Commodities2000 Westchester AvenuePurchase, NY 10577

Paul J. MaloneNebraska Public Power District907 West 25th StreetP.O. Box 608York, NE 68467-0608

SPP Customer List

Harold L. HadlandNebraska Public Power District1414 15th StreetP.O. Box 499Columbus, NE 68602-4099

Ronald F. Thompson, Jr.Nebraska Public Power District2060 W. Platte River Dr.P.O. Box 1000Doniphan, NE 68832-1000

Charles SchultzNextera Energy Power Marketing, LLC700 Universe Blvd.Juno Beach, FL 33408

Contract AdministrationNRG Power Marketing, Inc.211 Carnegie CenterPrinceton, NJ 08540

Bernie LiuSenior Transmission Tariff ConsultantNorthern States Power Company414 Nicollet MallMinneapolis, MN 55401

Gary D. ClearOklahoma Gas & Electric CompanyPost Office box 321, Mail Code GB58Oklahoma City, OK 73101-0321

Jean HallOccidental Power Services, Inc.P.O. Box 275705 Greenway Plaza, Suite 110Houston, TX 77227-7570

Cindy HolmanOklahoma Municipal Power AuthorityP.O. Box 1960Edmund, OK 73083-1960

Kimber L. Shoop, Senior AttorneyOklahoma Gas & Electric CompanyPost Office box 321, Mail Code 1208Oklahoma City, OK 73101-0321

Pat McDonieONEOK Power Marketing100 W. Fifth StreetSuite 1600Tulsa, OK 74103

Margaret SailorsOmaha Public Power District444 S. 16th Street, Mall, 10E/EP1Omaha, NE 68102

John HudsonPeople’s Electric CooperativeP.O. Box 429Ada, OK 74820

Bruce GlorvigenOtter Tail Power Company215 S. CascadeFergus Falls, MN 56537

Toan Nguyen, Legal DepartmentPPM Energy, Inc.1125 NW Couch StreetSuite 700Portland, OR 97209

SPP Customer List

Anne LovettPPL EnergyPlus, LLC2 North Ninth Street PL7Allentown, PA 18101

David EubankPublic Service Company of New MexicoAlvarado Square MS-0604Albuquerque, NM 87158

Cynthia HenryRegulatory Administration ManagerPublic Service Company of Colorado550 15th Street, Suite 1000Denver, CO 80202

Robert JanssenRedbud Energy, LP6700 Alexander Bell DriveSuite 360Columbia, MD 21046

Rita LeppRainbow Energy Marketing Corp.Kirkwood Office Tower919 S. 7th Street, Suite 405Bismarck, ND 58504

John RitchRRI Energy Services, Inc.1000 Main StreetHouston, TX 77002

Mike RustumRedbud Energy, LP1825 Eye Street, N.W.Washington, D.C. 20006

Rick LandersSikeston Board of Municipal UtilitiesP.O. Box 370Sikeston, MO 63801

Grace TomczakSempra Energy Trading83 Commerce RoadStamford, CT 06902

Jessica CollinsMarket Operations ManagerSouthwestern Public Service Company550 15th Street, Suite 1000Denver, CO 80202

Tracey StewartSouthwestern Power AdministrationU.S. Department of EnergyOne West Third StreetTulsa, OK 74103

Steve FerrySunflower Electric Power CorporationP.O. Box 170Great Bend, KS 67530-0170

Ray Cunningham, CounselSuez Energy Marketing NA, Inc.1990 Post Oak Blvd., Suite 1900Houston, TX 77056

Michael KnauffTennessee Power Company4612 Maria StreetChattanooga, TN 37411-1209

SPP Customer List

Teri BrownTenaska Power Services Co.1701 E. Lamar Blvd.Suite 100Arlington, TX 76006

Edd Hargett, General ManagerTex-La Electric Cooperative of Texas, Inc.P.O. Box 631623Nacogdoches, TX 75963

Steve WatsonTennessee Valley Authority1101 Market Street, MR 2DChattanooga, TN 37402-2801

Rene DumstorfThe Energy Authority301 West Bay StreetSuite 2600Jacksonville, FL 32202

Mr. Chris MelleyThird Planet Windpower4239 SW High Meadow AvenuePalm City, FL 34990

Sterling KochTransAlta Energy Marketing (US) Inc.110 12 th Avenue S.W.Box 1900, Station “M”Calgary, Alberta T2P 2M1

Frederick KunkelWabash Valley Power Association, Inc.722 N. High School RoadIndianapolis, IN 46214

Suzanne Calcagno, Regulatory ComplianceUBS AG, London Branch677 Washington Blvd.C/O UBSW Energy – 6th FloorStamford, CT 06901

Dennis ReedWestar Energy, Inc.818 S. Kansas AvenueTopeka, KS 66612

Grant WilkersonWestar Energy, Inc.818 S. Kansas AvenueTopeka, KS 66612

Mr. John StonebargerWestern Area Power Administration (WAPA)P.O. Box 790Watertown, SD 57201

Mr. Pete KinneyWestern Area Power Administration (WAPA)P.O. Box 790Watertown, SD 57201

Gary RouletWestern Farmers Electric CooperativeP.O. Box 429Anadarko, OK 73005-0429

David KrupnickDirector Account ManagementXcel Energy/Southwestern Public Service Company600 South Tyler, Suite 2902Amarillo, Texas 79101

SPP Member List

Frank BristolAcciona Wind Energy USA LLC333 West Wacker DriveSuite 1500Chicago, IL 60606

Gary BraunAcciona Wind Energy USA LLC333 West Wacker DriveSuite 1500Chicago, IL 60606

Mr. Kip Fox, Manager RTO PolicyAmerican Electric Power1201 Elm StreetSuite 800Dallas, TX 75250

Gary VoigtArkansas Electric Cooperative Corporation8000 Scott Hamilton DrivePost Office Box 194208Little Rock, AR 72209

Brent HebertCalpine Energy Services L.P.717 Texas AvenueHouston, TX 77002

Gene BeckerCargill Power Markets, LLC12700 Whitewater DriveMS 151Minnetonka, MN 55343

Robert PriestCity of Clarksdale MississippiP.O. Box 70Clarksdale, MS 38614

E. Leon DaggettCity of Independence, MOP.O. Box 1019Independence, MO 64051

Jeff KnottekCity Utilities (Springfield, MO)301 E. CentralP.O. Box 551Springfield, MO 65801-0551

Mark MacDonald, Director FERC Regulatory AffairsCleco Corporation2030 Donahue Ferry RoadPineville, LA 71360-5000

Carl CosciaConstellation Energy Commodities Group, Inc.111 Market PlaceSuite 600Baltimore, MD 21202

Wilma ChinCoral Power LLC909 Fannin, Plaza Level OneHouston, TX 77010

Walter YeagerDuke Energy139 East Fourth StreetMail Code EA600Cincinnati, OH 45202

Bob BurnerDuke Energy526 South Church StreetCharlotte, NC 28202

SPP Member List

Barry Huddleston, Director Regulatory PolicyDynegy Power Marketing1000 Louisiana StreetHouston, TX 77002

Tambra OffieldEast Texas Electric Cooperative, Inc.P.O. Box 631623Nacogdoches, TX 75963-1623

William RobertsEdison Mission Marketing & Trading Inc.160 Federal StreetBoston, MA 02110-1776

Herbert Thompson, DirectorEdison Mission Marketing & Trading Inc.Grant Town Power PlantP.O. Box 159Grant Town, West Virginia 26574

Dennis PriceEl Paso Marketing, L.P.1001 Louisiana StreetHouston, TX 77002

Bill GipsonEmpire District Electric CompanyP.O. Box 127Joplin, MO 64802

Andrea Weinstein, Assistant General CounselEntergy Power Ventures, LP101 Constitution Ave., N.W.Suite 200-EastWashington, D.C. 20001

Tom Reagan, PresidentCompetitive OperationsEntergy Power Ventures, LP1661 Gravier StreetNew Orleans, LA 70112

Randall HelmickVice President of TransmissionEntergy Services Inc.P.O. Box 61000M-ELEC-8GNew Orleans, LA 70161

Ms. Diane AntonelliExelon Generation Company, LLC300 Exelon WayKennett Square, PA 19348

Mark W. Schwirtz President and General ManagerGolden Spread Electric Coop., Inc.P.O. Box 9898Amarillo, TX 79105

Michael Kiefner, Chief Operating OfficerGrand River Dam AuthorityP.O. Box 409Vinita, OK 74301-0409

Richard SpringKansas City Power & Light CompanyP.O. Box 418679Kansas City, MO 64141-9679

Todd FridleyKansas City Power & Light CompanyP.O. Box 418679Kansas City, MO 64106-9679

SPP Member List

Robert D. BowserKansas Electric Power CooperativeP.O. Box 4877Topeka, KS 66604-0877

Frank LedouxLafayette Utilities SystemP.O. Box 4017-CLafayette, LA 70502

Dennis FloromLincoln Electric System1040 O StreetLincoln, NE 68501

Doug CurryLincoln Electric System1040 O StreetLincoln, NE 68501

Eric RuskampLincoln Electric System1040 O StreetLincoln, NE 68501

Cordell GrandLouisiana Energy & Power Authority210 Venture WayLafayette, LA 70507-5319

Andrea KraftManager of Wholesale PowerLuminant Energy Company, LLCEnergy Plaza1601 Bryan Street, Suite 11005BDallas, TX 75201

William DowlingMidwest Energy Inc.1330 CanturburyP.O. Box 898Hays, KS 67601-0898

Paul J. MaloneNebraska Public Power District907 West 25th StreetP.O. Box 608York, NE 68467-0608

Harold L. HadlandNebraska Public Power District1414 15th StreetP.O. Box 499Columbus, NE 68602-4099

Ronald F. Thompson, Jr.Nebraska Public Power District2060 W. Platte River Dr.P.O. Box 1000Doniphan, NE 68832-1000

Richard M. TylerNortheast Texas Electric Cooperative1127 Judson RoadSuite 249Longview, TX 75601

The Assistant General Counsel, Regulatory AffairsNRG Power Marketing Inc.211 Carnegie CenterPrinceton, NJ 08540

Kimber ShoopOklahoma Gas and Electric CompanyPost Office box 321, Mail Code 1208Oklahoma City, OK 73101-0321

SPP Member List

David L. KaysOklahoma Gas and Electric CompanyPost Office Box 321Oklahoma City , OK 73101-0321

Cindy HolmanOklahoma Municipal Power AuthorityP.O. Box 1960Edmond, OK 73083-1960

Margaret SailorsOmaha Public Power District444 S. 16th Street, Mall, 10E/EP1Omaha, NE 68102

Jimmy WeverPublic Service comm. Of Yazoo City MS210 South Mound StreetP.O. box 660Yazoo City, MS 39194

Robert JanssenRedbud Energy, LP6700 Alexander Bell DriveSuite 360Columbia, MD 21046

Trent CarlsonRRI Energy Services, Inc.1000 Main StreetHouston, TX 77002

Nick BrownSouthwest Power Pool415 N. McKinleySuite 140Little Rock, AR 72205-3020

AdministratorSouthwestern Power AdministrationAttn: 1000-AdministratorOne West 3rd StreetTulsa, OK 74103

L. Earl WatkinsSunflower Electric Power CorporationP.O. Box 980Hayes, KS 67601

Trudy HarperTenaska Power Services Co.1701 E. Lamar Blvd.Suite 100Arlington, TX 76006

Mr. Edd Hargett, General ManagerTex-La Electric Cooperative of Texas, Inc.P.O. Box 631623Nacogdoches, TX 75963

Darrell DorseyThe Board of Public Utilities (Kansas City KS)312 N. 65th StreetKansas City, KS 66102

Dennis ReedWestar Energy, Inc.818 S. Kansas AvenueTopeka, KS 66612

Grant WilkersonWestar Energy, Inc.818 S. Kansas AvenueTopeka, KS 66612

SPP Member List

Gary RouletWestern Farmers Electric CooperativeP.O. Box 429Anadarko, OK 73005-0429

Tim Woolley, Senior Manager, RTO PolicyXcel Energy550 15th Street, Suite 700Denver, CO 80202

SPP State Commissions

NEW MEXICO PUBLIC UTILITY COMMISSION Roy E. Stephenson, Director, Utility Division P.O. Box 1269 Santa Fe, New Mexico 87504-1269 Phone number: (505) 827-6960

TEXAS PUBLIC UTILITY COMMISSION 1701 North Congress Avenue Austin, Texas 78711-3326 Phone number: (512) 936 7000

OKLAHOMA CORPORATION COMMISSION Jim Thorpe Office Building P.O. Box 52000 Oklahoma City, OK 73152-2000 Phone number: (405) 521-2211

KANSAS CORPORATION COMMISSION 1500 S.W. Arrowhead Road Topeka, Kansas 66604-4027 Phone number: (785) 271-3100 Fax number: (785) 271-3354

MISSOURI PUBLIC SERVICE COMMISSION 200 Madison Street P.O. Box 360 Jefferson City, Missouri 65102-0360 Phone number: (573) 751-3234 Toll free: 1 (800) 392- 4211

ARKANSAS PUBLIC SERVICE COMMISSION 1000 Center Building Little Rock, Arkansas 72201 P.O. Box 400 72203-0400 Phone number: (501) 682-2051

LOUISIANA PUBLIC SERVICE COMMISSION P.O. Box 91154 Baton Rouge, Louisiana 70821-9154 Phone number: (225) 342- 4404 Toll free: 1 (800) 256-2397 Fax number: (225) 342- 2831