July 1, The Honorable Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street NE Washington, DC 20426

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1 The Honorable Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street NE Washington, DC July 1, 2011 RE: Southwest Power Pool, Inc., Docket No. ER11- Submission of Network Integration Transmission Service Agreement And Network Operating Agreements Dear Secretary Bose: Pursuant to section 205 of the Federal Power Act, 16 U.S.C. 824d, and section of the Federal Energy Regulatory Commission s ( Commission ) regulations, 18 C.F.R , Southwest Power Pool, Inc. ( SPP ) submits: 1) an executed, amended Service Agreement for Network Integration Transmission Service ( Service Agreement ) between SPP as Transmission Provider and KCP&L Greater Missouri Operations Company ( KCP&L-GMO ) as Network Customer ( Fourth Revised KCP&L-GMO Service Agreement ); 2) an executed Network Operating Agreement ( NOA ) between SPP as Transmission Provider and KCP&L-GMO as both Network Customer and Host Transmission Owner ( Fourth Revised KCP&L-GMO NOA ); and 3) an executed NOA between SPP as Transmission Provider, KCP&L-GMO as Network Customer and Host Transmission Owner, and Westar Energy, Inc. ( Westar ) as Host Transmission Owner ( Fourth Revised Westar NOA ). 1 The Fourth Revised KCP&L-GMO Agreements submitted in this filing modify the Service Agreement and NOA 2 accepted by the 1 2 The Fourth Revised KCP&L-GMO Service Agreement, Fourth Revised KCP&L- GMO NOA, and Fourth Revised Westar NOA are referred to collectively as the Fourth Revised KCP&L-GMO Agreements, and SPP, KCP&L-GMO, and Westar are referred to collectively as the Parties. The Fourth Revised KCP&L- GMO Agreements have been designated as Fourth Revised Service Agreement No See Submission of Network Integration Transmission Service Agreements of Southwest Power Pool, Inc., Docket No. ER (Nov. 1, 2010) ( November 1 Filing ).

2 The Honorable Kimberly D. Bose July 1, 2011 Page 2 Commission on December 21, 2010, in Docket No. ER SPP is submitting this filing because the Fourth Revised KCP&L-GMO Agreements include terms and conditions that do not conform to the standard forms of service agreements set forth in the SPP Open Access Transmission Tariff ( SPP Tariff ). 4 Background SPP filed the Third Revised KCP&L-GMO Agreements in the November 1 Filing because the agreements contained terms and conditions that did not conform to the pro forma Agreements. For example, Attachment 1 of the Third Revised KCP&L-GMO Service Agreement contains a new section clarifying that the delivery points listed in Appendix 3, which are attached to Westar s Transmission and Distribution System, will remain in the Westar Balancing Area until the delivery points are transferred to the KCP&L-GMO Balancing Area, at which time the delivery points will be pseudo-tied and the loads will transfer to the KCP&L-GMO Balancing Area. Section also specifies how ancillary services will be provided for these delivery points prior to and following the transfer of these delivery points to the KCP&L-GMO Balancing Area on June 1, The Commission accepted the Third Revised KCP&L-GMO Service Agreement, which contained the above language, in the December Letter Order. Since the December Letter Order, it has become necessary for the Parties to revise the Third Revised KCP&L-GMO Service Agreement to update the dates that the delivery points would transfer from the Westar Balancing Area to the KCP&L-GMO Balancing Area from June 1, 2011, to a future date to be determined. This revision is necessary because KCP&L and Westar were unable to meet the June 1, 2011 date for transfer of delivery points, and the revision affords the Parties flexibility on the date of the transfer. To facilitate this revision, SPP and KCP&L-GMO executed a new Service Agreement, which is submitted herein as the Fourth Revised KCP&L Service Agreement. 3 4 See Sw. Power Pool, Inc., Letter Order, Docket No. ER (Dec. 21, 2010) ( December Letter Order ). The agreements accepted in the December Letter Order are referred to collectively as Third Revised KCP&L-GMO Agreements and individually as Third Revised KCP&L-GMO Service Agreement, Third Revised KCP&L-GMO NOA, and the Third Revised Westar NOA. See SPP Tariff at Attachment F ( pro forma Service Agreement ) and Attachment G ( pro forma NOA ), collectively the pro forma Agreements.

3 The Honorable Kimberly D. Bose July 1, 2011 Page 3 Description and Justification for the Non-Conforming Language in the Fourth Revised KCP&L-GMO Agreements In addition to the non-conforming language in Section of Attachment 1 of the Fourth Revised KCP&L-GMO Service Agreement discussed above, the Fourth Revised KCP&L-GMO Agreements retain additional non-conforming language from the Third Revised KCP&L-GMO Agreements, which remains necessary to facilitate KCP&L-GMO s request for transmission service. First, included as Attachment B is an Agreement for the Provision of Transmission Service to Missouri Bundled Retail Load between SPP and KCP&L-GMO (hereinafter the Missouri Agreement ). The Missouri Agreement was negotiated as part of the Missouri Public Service Commission proceeding, Case No. EO , to allow KCP&L-GMO to transfer functional control of its transmission facilities to SPP. The principal purpose of the Missouri Agreement is to detail the rates, terms, and conditions that will or will not apply to KCP&L-GMO s bundled retail load. Language referencing the Missouri Agreement has been added to Sections 2.0 and 3.0 and Section 8.1 of Attachment 1 of the Fourth Revised KCP&L-GMO Service Agreement. Section 13.0 of both the Fourth Revised KCP&L-GMO and Fourth Revised Westar NOAs includes language that clarifies that Billing and Payments shall be in accordance with the Missouri Agreement. Further, Section 17.0 of both the Fourth Revised KCP&L-GMO and Fourth Revised Westar NOAs include language stating that, when there are conflicts between the NOA and the Tariff, the Tariff shall control except with regard to the provisions of the Missouri Agreement. The Commission has accepted identical revisions incorporating references to similar agreements in other Service Agreements and NOAs submitted by SPP, including the Third Revised KCP&L-GMO Service Agreement and NOA. 5 Second, Section 8.6 of Attachment 1 of the Fourth Revised KCP&L-GMO Service Agreement specifies that KCP&L-GMO shall replace distribution losses by delivery point in accordance with details in Appendix 3. The Parties also add details to Appendix 3 to specify loss percentages for the delivery points. The inclusion in Service Agreements of the type of information set forth in Appendix 3 is contemplated by Sections 8.5 and 8.6 of Attachment 1 of the pro forma Service Agreement. Further, the Commission previously has accepted Service Agreements submitted by SPP with similar language, including the Third Revised KCP&L-GMO Agreements See December Letter Order; See, e.g., Sw. Power Pool, Inc., Letter Order, Docket Nos. ER and ER (Jan. 16, 2007). See December Letter Order; Sw. Power Pool, Inc., Letter Order, Docket No. ER (Aug. 20, 2010); Sw. Power Pool, Inc., Letter Order, Docket No. ER (Aug. 20, 2010).

4 The Honorable Kimberly D. Bose July 1, 2011 Page 4 Finally, Section 8.9 of Attachment 1 of the Fourth Revised KCP&L-GMO Service Agreement contains language specifying that the cost support and monthly charges for Wholesale Distribution Service Charges are detailed in a new, nonconforming Appendix 4 to the Fourth Revised KCP&L-GMO Service Agreement. The inclusion of the cost support and monthly charges for Wholesale Distribution Service is consistent with Schedule 10 of the SPP Tariff, which requires cost support when Service Agreements containing Wholesale Distribution Charges are filed with the Commission. 7 The Commission previously has accepted other non-conforming Service Agreements submitted by SPP, including the Third Revised KCP&L-GMO Service Agreement, which contained similar language pertaining to Wholesale Distribution Service Charges, including the addition of a new Appendix detailing Wholesale Distribution Service Charges. 8 These modifications specify certain terms and conditions regarding the provision of network service to KCP&L-GMO that are necessary to accommodate KCP&L-GMO s request for transmission service. Therefore, this filing is consistent with the public interest and warrants acceptance by the Commission. Effective Date and Waiver SPP requests an effective date of June 1, 2011 for the Fourth Revised KCP&L- GMO Agreements. To permit such an effective date, pursuant to section of the Commission s rules and regulations, 18 C.F.R , SPP requests a waiver of the Commission s 60-day notice requirement set forth at 18 C.F.R Waiver is appropriate because the Fourth Revised KCP&L-GMO Agreements are being filed within 30 days of the commencement of service See SPP Tariff at Schedule 10 ( All rates and charges for Wholesale Distribution Service shall be on file with the appropriate agency as required by law or regulation. To the extent that a Service Agreement containing provisions for Wholesale Distribution Service is required to be filed with the Commission, the Transmission Provider, in consultation with the appropriate Transmission Owner, shall provide along with the filing, adequate cost support to justify the customerspecific rates and charges being assessed under this Schedule 10. ). See December Letter Order; Sw. Power Pool, Inc., Letter Order, Docket No. ER (Dec. 17, 2008). See Prior Notice and Filing Requirements Under Part II of the Federal Power Act, 64 FERC 61,139, at 61,983-84, order on reh'g, 65 FERC 61,081 (1993) (the Commission will grant waiver of the 60-day prior notice requirement if service agreements are filed within 30 days after service commences. ); see also18 C.F.R. 35.3(a)(2).

5 The Honorable Kimberly D. Bose July 1, 2011 Page 5 Additional Information A. Information Required by Section of the Commission s Regulations, 18 C.F.R : (1) Documents submitted with this filing: In addition to this transmittal letter, SPP includes the following: (i) (ii) A clean copy of the KCP&L-GMO Agreements; and A redlined copy of the KCP&L-GMO Agreements. (2) Effective Date: As discussed herein, SPP respectfully requests that the Commission accept the KCP&L-GMO Agreements with an effective date of June 1, (3) Service: SPP is serving a copy of this filing on the representatives for KCP&L-GMO and Westar listed in the Fourth Revised KCP&L- GMO Agreements. (4) Basis of Rate: B. Communications: All charges will be determined in accordance with the SPP Tariff and the Fourth Revised KCP&L-GMO Agreements. Copies of this filing have been served upon all parties to the Fourth Revised KCP&L-GMO Agreements. Any correspondence regarding this matter should be directed to: Heather Starnes, J.D. Manager Regulatory Policy Southwest Power Pool, Inc. 415 North McKinley, #140 Plaza West Little Rock, AR Telephone: (501) Fax: (501) hstarnes@spp.org Carrie L. Bumgarner Tyler R. Brown WRIGHT & TALISMAN, P.C G Street, N.W., Suite 600 Washington, DC Telephone: (202) Fax: (202) bumgarner@wrightlaw.com brown@wrightlaw.com

6 The Honorable Kimberly D. Bose July 1, 2011 Page 6 Conclusion For all the foregoing reasons, SPP respectfully requests that the Commission accept the Fourth Revised KCP&L-GMO Agreements with an effective date of June 1, Respectfully submitted, /s/ Tyler R. Brown Carrie L. Bumgarner Tyler R. Brown Attorneys for Southwest Power Pool, Inc. K:\SPP\Service Agreement Filings\Transmission Service Agreement Filings\KCPL-GMO NITSA SA 1765R4 Transmittal Letter.doc

7 Southwest Power Pool, Inc. Fourth Revised Service Agreement No SERVICE AGREEMENT FOR NETWORK INTEGRATION TRANSMISSION SERVICE BETWEEN SOUTHWEST POWER POOL AND KCP&L GREATER MISSOURI OPERATIONS COMPANY This Network Integration Transmission Service Agreement ("Service Agreement") is entered into this 1st day of June, 2011, by and between KCP&L Greater Missouri Operations Company ("Network Customer "), and Southwest Power Pool, Inc. ("Transmission Provider"). The Network Customer and Transmission Provider shall be referred to individually as Party and collectively as "Parties." WHEREAS, the Transmission Provider has determined that the Network Customer has made a valid request for Network Integration Transmission Service in accordance with the Transmission Provider s Open Access Transmission Tariff ("Tariff") filed with the Federal Energy Regulatory Commission ("Commission") as it may from time to time be amended; WHEREAS, the Transmission Provider administers Network Integration Transmission Service for Transmission Owners within the SPP Region and acts as agent for the Transmission Owners in providing service under the Tariff; WHEREAS, the Network Customer has represented that it is an Eligible Customer under the Tariff; and WHEREAS, the Parties intend that capitalized terms used herein shall have the same meaning as in the Tariff. NOW, THEREFORE, in consideration of the mutual covenants and agreements herein, the Parties agree as follows: Page 1 of 66

8 1.0 The Transmission Provider agrees during the term of this Service Agreement, as it may be amended from time to time, to provide Network Integration Transmission Service in accordance with the Tariff to enable delivery of power and energy from the Network Customer s Network Resources that the Network Customer has committed to meet its load. 2.0 The Network Customer agrees to take and pay for Network Integration Transmission Service in accordance with the provisions of Parts I, III and V of the Tariff and this Service Agreement with attached specifications and subject to the terms of the Agreement for the Provision of Transmission Service to Missouri Bundled Retail Load ( Missouri Agreement ) attached hereto as Attachment B. 3.0 The terms and conditions of such Network Integration Transmission Service shall be governed by the Tariff, as in effect at the time this Service Agreement is executed by the Network Customer, or as the Tariff is thereafter amended or by its successor tariff, if any. The Tariff, as it currently exists, or as it is hereafter amended, is incorporated in this Service Agreement by reference. In the case of any conflict between this Service Agreement and the Tariff, the Tariff shall control except as provided in the Missouri Agreement. The Network Customer has been determined by the Transmission Provider to have a Completed Application for Network Integration Transmission Service under the Tariff. The completed specifications are based on the information provided in the Completed Application and are incorporated herein and made a part hereof as Attachment Service under this Service Agreement shall commence on such date as it is permitted to become effective by the Commission. This Service Agreement shall be effective through April 15, Thereafter, it will continue from year to year unless terminated by the Network Customer or the Transmission Provider by giving the other one-year advance written notice or by the mutual written consent of the Transmission Provider and Page 2 of 66

9 Network Customer. Upon termination, the Network Customer remains responsible for any outstanding charges including all costs incurred and apportioned or assigned to the Network Customer under this Service Agreement. 5.0 The Transmission Provider and Network Customer have executed a Network Operating Agreement as required by the Tariff. 6.0 Any notice or request made to or by either Party regarding this Service Agreement shall be made to the representative of the other Party as indicated below. Such representative and address for notices or requests may be changed from time to time by notice by one Party or the other. Southwest Power Pool, Inc. (Transmission Provider: Carl Monroe 415 N. McKinley, 140 Plaza West Little Rock, AR Address: cmonroe@spp.org Phone number: Network Customer: Scott Heidtbrink KCP&L Greater Missouri Operations Company Senior Vice President, Supply P.O. Box Kansas City, MO Address: scott.heidtbrink@kcpl.com Phone number: Page 3 of 66

10 7.0 This Service Agreement shall not be assigned by either Party without the prior written consent of the other Party, which consent shall not be unreasonably withheld. However, either Party may, without the need for consent from the other, transfer or assign this Service Agreement to any person succeeding to all or substantially all of the assets of such Party. However, the assignee shall be bound by the terms and conditions of this Service Agreement. 8.0 Nothing contained herein shall be construed as affecting in any way the Transmission Provider s or a Transmission Owner s right to unilaterally make application to the Federal Energy Regulatory Commission, or other regulatory agency having jurisdiction, for any change in the Tariff or this Service Agreement under Section 205 of the Federal Power Act, or other applicable statute, and any rules and regulations promulgated thereunder; or the Network Customer's rights under the Federal Power Act and rules and regulations promulgated thereunder. Page 4 of 66

11 9.0 By signing below, the Network Customer verifies that all information submitted to the Transmission Provider to provide service under the Tariff is complete, valid and accurate, and the Transmission Provider may rely upon such information to fulfill its responsibilities under the Tariff. IN WITNESS WHEREOF, the Parties have caused this Service Agreement to be executed by their respective authorized officials. TRANSMISSION PROVIDER NETWORK CUSTOMER Signature /s/ Carl Monroe Signature /s/ Scott Heidtbrink Printed Name Carl Monroe Printed Name Scott Heidtbrink Title EVP & COO Title Sr. Vice President, Supply Date 06/23/2011 Date Page 5 of 66

12 ATTACHMENT 1 TO THE NETWORK INTEGRATION TRANSMISSION SERVICE AGREEMENT BETWEEN SOUTHWEST POWER POOL AND KCP&L GREATER MISSOURI OPERATIONS COMPANY SPECIFICATIONS FOR NETWORK INTEGRATION TRANSMISSION SERVICE 1.0 Network Resources The Network Resources are listed in Appendix Network Loads The Network Load consists of the bundled native load or its equivalent for Network Customer load in the KCP&L Greater Missouri Operations Company Control Area as listed in Appendix 3. The Network Customer s Network Load shall be measured on an hourly integrated basis, by suitable metering equipment located at each connection and delivery point, and each generating facility. The meter owner shall cause to be provided to the Transmission Provider, Network Customer and applicable Transmission Owner, on a monthly basis such data as required by Transmission Provider for billing. The Network Customer s load shall be adjusted, for settlement purposes, to include applicable Transmission Owner transmission and distribution losses, as applicable, as specified in Sections 8.5 and 8.6, respectively. For a Network Customer providing retail electric service pursuant to a state retail access program, profiled demand data, based upon revenue quality non-idr meters may be substituted for hourly integrated demand data. Measurements taken and all metering equipment shall be in accordance with the Transmission Provider s standards and practices for similarly determining the Transmission Provider s load. The actual hourly Network Loads, by delivery point, internal generation site and point where power may flow to and from the Network Customer, with separate readings for each direction of flow, shall be provided. 3.0 Affected Control Areas and Intervening Systems Providing Transmission Service The affected control area is KCP&L Greater Missouri Operations Company. The intervening systems providing transmission service are none. Page 6 of 66

13 4.0 Electrical Location of Initial Sources See Appendix Electrical Location of the Ultimate Loads The loads of KCP&L Greater Missouri Operations Company identified in Section 2.0 hereof as the Network Load are electrically located within the KCP&L Greater Missouri Operations Company Control Area. 6.0 Delivery Points The delivery points are the interconnection points of KCP&L Greater Missouri Operations Company identified in Section 2.0 as the Network Load. 7.0 Receipt Points The Points of Receipt are listed in Appendix Compensation Service under this Service Agreement may be subject to some combination of the charges detailed below. The appropriate charges for individual transactions will be determined in accordance with the terms and conditions of the Tariff. 8.1 Transmission Charge Monthly Demand Charge per Section 34 and Part V of the Tariff shall be treated pursuant to the Missouri Agreement. 8.2 System Impact and/or Facility Study Charge Studies may be required in the future to assess the need for system reinforcements in light of the ten-year forecast data provided. Future charges, if required, shall be in accordance with Section 32 of the Tariff. 8.3 Direct Assignment Facilities Charge 8.4 Ancillary Service Charges The following Ancillary Services are required under this Service Agreement. a) Scheduling, System Control and Dispatch Service per Schedule 1 of the Tariff. b) Tariff Administration Service per Schedule 1-A of the Tariff. c) Reactive Supply and Voltage Control from Generation Sources Service per Schedule 2 of the Tariff. d) Regulation and Frequency Response Service per Schedule 3 of the Tariff. Page 7 of 66

14 e) Energy Imbalance Service per Schedule 4 of the Tariff. f) Operating Reserve - Spinning Reserve Service per Schedule 5 of the Tariff. g) Operating Reserve - Supplemental Reserve Service per Schedule 6 of the Tariff. The Ancillary Services may be self-supplied by the Network Customer or provided by a third party in accordance with Sections through 8.4.4, with the exception of the Ancillary Services for Schedules 1, 1-A, and 2, which must be purchased from the Transmission Provider In accordance with the Tariff, when the Network Customer elects to self-supply or have a third party provide Ancillary Services, the Network Customer shall indicate the source for its Ancillary Services to be in effect for the upcoming calendar year in its annual forecasts. If the Network Customer fails to include this information with its annual forecasts, Ancillary Services will be purchased from the Transmission Provider in accordance with the Tariff When the Network Customer elects to self-supply or have a third party provide Ancillary Services and is unable to provide its Ancillary Services, the Network Customer will pay the Transmission Provider for such services and associated penalties in accordance with the Tariff as a result of the failure of the Network Customer s alternate sources for required Ancillary Services All costs for the Network Customer to supply its own Ancillary Services shall be the responsibility of the Network Customer The delivery points listed in Appendix 3, which are attached to Westar Energy s Transmission & Distribution System, will remain in the Westar Energy Balancing Area until such time as these delivery points are pseudo-tied and the loads are transferred to KCPL-GMO Balancing Area. a) Until these delivery points are transferred to KCPL-GMO Balancing Area: 1. Westar Energy will be providing Ancillary 1 (SC); therefore, Westar Energy OATT Schedule 1 Rate will be collected from KCPL-GMO and allocated to Westar Energy. Page 8 of 66

15 2. Westar Energy will be providing Ancillary 3 (RF); therefore, Westar Energy OATT Schedule 3 Rate will be collected and allocated to Westar Energy. 3. Westar Energy will be providing Ancillary 5 (OR-Spin); therefore, Westar Energy s OATT Schedule 5 Rate will be collected from KCPL-GMO and allocated to Westar Energy. 4. Westar Energy will be providing Ancillary 6 (OR-Supp); therefore, Westar Energy OATT Schedule 6 Rate will be collected from KCPL-GMO and allocated to Westar Energy. b) Effective as of the date that these delivery points are transferred to KCPL-GMO Balancing Area: 1. Ancillaries 1, 3, 5, and 6 will be supplied by KCPL-GMO. 2. Westar Energy will no longer provide Ancillary Services for the delivery points connected to Westar Energy s Transmission and Distribution System. 8.5 Real Power Losses - Transmission The Network Customer shall replace losses in accordance with Attachment M of the Tariff. 8.6 Real Power Losses Distribution For Delivery Points on Westar Energy Network System: The Network Customer shall replace losses by delivery point in accordance with details in Appendix Power Factor Correction Charge 8.8 Redispatch Charge Redispatch charges shall be in accordance with Section 33.3 of the Tariff. 8.9 Wholesale Distribution Service Charge For Delivery Points on Westar Energy Network System: The Wholesale Distribution Service Charge cost support and monthly charge is detailed in Appendix Network Upgrade Charges A. The Network Customer has confirmed the following supplemental Network Resources requiring Network Upgrades: Page 9 of 66

16 1. Crossroads, 300MW from POR EES, Source Crossroads to POD MPS, Sink MPS, as more specifically identified in transmission request Contingent upon the completion of required upgrades as specified below, designation of this network resource shall be effective on June 1, 2011 and remain effective through June 1, The requested service depends on and is contingent on completion of the following aggregate study SPP-2007-AG1 Service Upgrades by the required date as listed below. The costs of these upgrades are assigned to the Network Customer but are fully base plan fundable in accordance with Section III.A. Attachment J of the Tariff. Service Upgrades required for Crossroads Upgrade Name Upgrade Description Transmission Owner BARTLESVILLE SOUTHEAST - NORTH BARTLESVILLE 138KV CKT 1 COFFEYVILLE TAP - NORTH BARTLESVILLE 138KV CKT 1 Rebuild 8.37 miles of 795 ACSR with 1590 ACSR & reset BSE Rebuild miles of 795 ACSR with 1590 ACSR. COOK - ST JOE 161KV CKT 1 Conductor, Switch, Relay Craig 161kV 20MVar Cap Bank Upgrade REDEL - STILWELL 161KV CKT 1 Additional 20 MVAR to make a total of 70 MVAR at Craig Reconductor line with 1192 ACSS and upgrade terminal Date Required in Service AEPW 6/1/2009 AEPW 6/1/2009 SJLP 6/1/2010 KACP 6/1/2011 KACP 6/1/2009 Page 10 of 66

17 equipment for 2000 amps The requested service depends on and is contingent on completion of the following reliability upgrades resulting from the SPP Expansion Plan or previous aggregate transmission service studies. These upgrades costs are not assignable to the Network Customer. Reliability Upgrades for Crossroads Upgrade Name Upgrade Description Transmission Owner DANVILLE (APL) - MAGAZINE REC 161KV CKT 1 AEPW DANVILLE (APL) - MAGAZINE REC 161KV CKT 1 OKGE EDMOND SUB Grandview East - Sampson - Longview 161kV Ckt 1 Loma Vista - Montrose 161kV Tap into K.C. South South Harper 161 kv cut-in to Stilwell-Archie JCT 161 kv line STRANGER CREEK - NW LEAVENWORTH 115KV STRANGER CREEK TRANSFORMER CKT 2 SUB RIVERSIDE 161KV Rebuild miles of 250 Copperweld with 1272 ACSR. Rebuild miles of 250 Copperweld with 1272 ACSR. Add a new 161/34.5 kv Sub at Edmond tapping the Cook to Lake Road 161 kv line Replace wavetraps at Grandview East and Longview. To tap the Montrose-LomaVista 161 kv Line into KC South 161 kv sub. To tap Stilwell-Archie JCT 161 kv line into South Harper 161 kv sub and make it two new 161 kv sections: Stilwell-South Harper and Archie JCT- South Harper. Rebuild mile Jarbalo-NW Leavenworth 115 kv line and tap in & out of Stranger 115 kv Install second Stranger Creek transformer Install 3 - stages of 22 MVAR each for a total of 66 MVAR capacitor bank at Riverside Sub # Date Required in Service AEPW 6/1/2009 OKGE 6/1/2009 MIPU 6/1/2009 MIPU 6/1/2009 MIPU 6/1/2009 MIPU 6/1/2009 WERE 6/1/2011 WERE 6/1/2009 EMDE 6/1/2011 Page 11 of 66

18 Upgrade Name Upgrade Description Transmission Owner BLUE SPRINGS EAST CAP BANK Add 50 MVAR cap bank at Blue Springs East Date Required in Service MIPU 6/1/2011 CLARKSVILLE - DARDANELLE 161KV CKT 1 #1 DARDANELLE - RUSSELLVILLE SOUTH 161KV CKT 1 SWPA #1 RALPH GREEN 12MVAR CAPACITOR Sooner to Rose Hill 345 kv OKGE Sooner to Rose Hill 345 kv WERE South Harper - Freeman 69 kv COFFEYVILLE TAP - DEARING 138KV CKT 1 AEPW COFFEYVILLE TAP - DEARING 138KV CKT 1 WERE MAGAZINE REC - NORTH MAGAZINE 161KV CKT 1 AEPW MAGAZINE REC - NORTH MAGAZINE 161KV CKT 1 OKGE Remove wavetrap. Install fiber SWPA 6/1/2012 Replace wave trap, disconnect SWPA 6/1/2009 switches, current transformers, and breaker. Bus will limit rating to 1340 amps. 12MVAR at Ralph Green MIPU 6/1/2010 New 345 kv line from Sooner to Oklahoma/Kansas New 345 kv line from Oklahoma/Kansas Stateline to Rose Hill re-set the overcurrent relay at South Harper 69 kv Bus to open SouthHarper-Freeman 69 kv line Tie Line, Reconductor 1.09 miles of 795 ACSR with 1590 ACSR. Tie Line, Rebuild 3.93 miles of 795 ACSR with 1590 ACSR. Rebuild 7.43 miles of 250 CWC with 795 ACSR Rebuild 7.43 miles of 250 CWC with 795 ACSR OKGE 6/1/2009 WERE 6/1/2009 MIPU 6/1/2009 AEPW 6/1/2009 WERE 6/1/2009 AEPW 6/1/2009 OKGE 6/1/2009 In addition, the Transmission Provider will make contractual arrangements for the construction of the following network upgrade on the Southwestern Power Administration (SWPA) system: (i) At Dardanelle, in circuit breaker bay 52 on the Dardanelle to Russellville South 161-kV transmission line, replace bus between the auxiliary bus and Motor Operated Disconnect (MOD) switch 57, between disconnect switch 57 and disconnect switch 53, and between disconnect switch 51 and the main bus. Upgrade is required in service by June 1, Page 12 of 66

19 (ii) At Norfork, in circuit breaker bay 62 on the Norfork to Calico Rock 161- kv transmission line, replace bus between MOD switch 67 and disconnect switch 63, reset metering CT ratio, and replace the wavetrap. Upgrade is required in service by June 1, Transmission Customer shall pay the actual costs for construction of these facilities. For the purpose of funding the construction of these upgrades, the Transmission Customer shall make cash payments of One Hundred Forty Five Thousand Dollars ($145,000) by November 1, Upon completion of construction of the SWPA upgrades, funding of their costs shall be reconciled and trued-up against actual construction costs and requisite, additional funding or refund of excess funding shall be made between the Transmission Provider and the Transmission Customer. In addition to all other applicable charges, Network Customer shall pay the monthly revenue requirements of $35.33 from October 1, 2010 June 1, 2016 over the 68 month term of this service. The requested service requires completion of the following network upgrades: Upgrade Name Upgrade Description Transmission Owner COFFEYVILLE TAP - DEARING 138KV CKT 1 WERE #2 NEOSHO - NORTHEAST PARSONS 138KV CKT 1 Replace Disconnect Switches, Wavetrap, Breaker, Jumpers Replace bus and Jumpers at NE Parsons 138 kv substation Date Required in Service WERE 6/1/2010 WERE 6/1/2011 These upgrades were required to provide firm Point-To-Point Service to the Cities of Richards and Eve, Kansas under transmission service request This service is now reflected as network service request and B. Upon completion of construction of the assigned upgrades, funding of their costs shall be reconciled and trued-up against actual construction costs and requisite, additional Page 13 of 66

20 funding or refund of excess funding shall be made between the Transmission Provider and the Network Customer. C. Notwithstanding the term provisions of Section 4.0 of this Service Agreement, Customer shall be responsible for paying all charges specified as its obligation in this Section 8.10 of this Attachment 1, for the term specified herein for each assigned upgrade Meter Data Processing Charge 8.12 Other Charges 9.0 Credit for Network Customer-Owned Transmission Facilities 10.0 Designation of Parties Subject to Reciprocal Service Obligation 11.0 Other Terms and Conditions Page 14 of 66

21 APPENDIX 1 Network Resources of KCP&L Greater Missouri Operations Company Page 15 of 66

22 APPENDIX 1 KCP&L GREATER MISSOURI OPERATIONS COMPANY NETWORK RESOURCES Maximum Net Dependable Capacity Network Resource Summer Winter Location/Term of Service Sibley Sibley Sibley Jeffrey EC Jeffrey EC Jeffrey EC South Harper South Harper South Harper Ralph Green Greenwood Greenwood Greenwood Greenwood Nevada TWA Jackson Co., MO Jackson Co., MO Jackson Co., MO Potowatomie Co., KS. Term of service 4/15/2009 to 7/1/2040. Potowatomie Co., KS. Term of service 4/15/2009 to 7/1/2040. Potowatomie Co., KS. Term of service 4/15/2009 to 7/1/2040. Cass Co., MO Cass Co., MO Cass Co., MO Cass Co., MO Jackson Co., MO Jackson Co., MO Jackson Co., MO Jackson Co., MO Vernon Co., MO Platte Co., MO TWA Platte Co., MO Iatan Platte Co., MO Iatan 2 Lesser of 18% of net Lesser of 18% of net dependable dependable Platte Co., MO capacity or 160MW capacity or Term of service 4/15/2009 to 6/1/ MW Page 16 of 66

23 Maximum Net Dependable Capacity Network Resource Summer Winter Location/Term of Service Cooper Nuclear Station Unit Participation Power Agreement between Nebraska Public Power District and Aquila Inc. Gray County Wind Energy Power Purchase Agreement Gray County Wind Energy Power Purchase Agreement Nemaha Co, NE Term of service 4/15/2009 to 1/19/2014. Lake Rd Buchanan Co., MO Lake Rd Buchanan Co., MO Lake Rd Buchanan Co., MO Lake Rd Buchanan Co., MO Lake Rd CT Buchanan Co., MO Lake Rd JE (6) Buchanan Co., MO Lake Rd JE (7) Buchanan Co., MO Gerald Gentleman Station Unit #1 Participation Agreement between Nebraska Public Power District and St. Joseph Light and Power Company Gerald Gentleman Station Unit #2 Participation Agreement between Nebraska Public Power District and St. Joseph Light and Power Company Crossroads Crossroads Crossroads Crossroads Westar Power Purchase 1 1 Gray Co., KS *20 MW of firm transmission Term of service 4/15/2009 to 10/1/2018 Gray Co., KS *40 MW of firm transmission Term of service 4/15/2009 to 10/1/2017 Lincoln Co., NE Term of service 4/15/2009 to 6/1/2011 Lincoln Co., NE Term of service 4/15/2009 to 6/1/2011 Coahoma Co., MS Term of service 6/1/2011 to 6/1/2031 Coahoma Co., MS Term of service 6/1/2011 to 6/1/2031 Coahoma Co., MS Term of service 6/1/2011 to 6/1/2031 Coahoma Co., MS Term of service 6/1/2011 to 6/1/2031 Page 17 of 66

24 Appendix 2 Receipt Points of KCP&L Greater Missouri Operations Company Page 18 of 66

25 APPENDIX 2 KCP&L GREATER MISSOURI OPERATIONS COMPANY RECEIPT POINTS Tieline / Plant Name Ownership Voltage (kv) Rating (MVA) Sibley 1 MIPU Sibley 2 MIPU Sibley 3 MIPU Jeffrey EC 1 WERE Jeffrey EC 2 WERE Jeffrey EC 3 WERE South Harper 1 MIPU South Harper 2 MIPU South Harper 3 MIPU Ralph Green 3 MIPU Greenwood 1 MIPU Greenwood 2 MIPU Greenwood 3 MIPU Greenwood 4 MIPU Nevada MIPU TWA 1 MIPU TWA 2 MIPU Iatan #1 KCPL Iatan #2 KCPL Lake Rd #4 MIPU Lake Rd #1 MIPU Lake Rd #2 MIPU Lake Rd #3 MIPU Lake Rd CT MIPU Lake Rd JE (6) MIPU Lake Rd JE (7) MIPU Gray County Wind Farm - (MPS) SECI/WPEK Gray County Wind Farm - (SJLP) SECI/WPEK Cooper-Fairport-St. Joseph MINT Line Members Cooper-Fairport-St. Joseph MINT Line Members Cooper-Fairport-St. Joseph MINT Line Members Westar Westar 69 Page 19 of 66

26 Appendix 3 Delivery Points of KCP&L Greater Missouri Operations Company Page 20 of 66

27 APPENDIX 3 KCP&L GREATER MISSOURI OPERATIONS COMPANY DELIVERY POINTS SPP Bus Number Delivery Point Name Ownership Voltage (kv) TWA#1 MIPU TWA#2 MIPU LAKERD3 MIPU SMTHVL MIPU BLSPE 5 MIPU PRALEE MIPU SEDALIA MIPU BLSPS 5 MIPU KCI 5 MIPU FRLVW 5 MIPU HLLMRK MIPU WINDSR MIPU RAYTOWN MIPU FROSTRD MIPU PLTCTY MIPU WSTELEC MIPU GRDVWE MIPU LNGVW 5 MIPU GRAINVL MIPU OAKGRV MIPU WBURGE MIPU LEESUM MIPU WAFB 5 MIPU DUNCAN MIPU RICHMND MIPU BLSPW 5 MIPU LKWOOD MIPU ADRIAN MIPU SEDEAST MIPU LKWINGB MIPU ORRICK MIPU KCSOUTH MIPU STROTHR MIPU LBRTYWT MIPU LBRTYST MIPU HOOKRD MIPU MARYVLE MIPU EAST 5 MIPU IND PRK MIPU COOK 5 MIPU WOODBIN MIPU TURNER MIPU STALEY MIPU LIBERTY MIPU SIBLEY MIPU LEXNTON MIPU &40 2 MIPU WBURGP MIPU WBURGE MIPU 69 Page 21 of 66

28 SPP Bus Number Delivery Point Name Ownership Voltage (kv) KNOSTER MIPU KELHYS MIPU PITTCRN MIPU SEDPLT MIPU COLECMP MIPU WARSAW MIPU HOLDEN MIPU RGREEN MIPU BRMALL MIPU GRDWCTY MIPU GRDWST MIPU RGAFB 2 MIPU BELTON MIPU BELTONS MIPU FREEMAN MIPU ANCONDA MIPU HSNVLW MIPU GRDNCTY MIPU POSTOAK MIPU CLNTPLT MIPU CLNTGRN MIPU URICH 2 MIPU APCITY MIPU NEVPLT MIPU METZ 2 MIPU M 2 MIPU LAMAR 2 MIPU HARRIS MIPU LONEJAC new delivery point in 2010 MIPU NRAYMOR MIPU BELTONS MIPU PECULR2 MIPU SAMPSON new delivery point in 2010 MIPU RTCHFLD new delivery point in 2010 MIPU RAYMORE MIPU POPE MIPU COOKING new delivery point in 2010 MIPU ALABAMA MIPU MRVL#2 MIPU BURLJCT MIPU TARKIO_ MIPU FAIRFAX MIPU CRAIG_2 MIPU MNDCITY MIPU BRWNCRV MIPU KELLOG_ MIPU MRVL#1 MIPU PICKRG_ MIPU 69 Page 22 of 66

29 SPP Bus Number Delivery Point Name Ownership Voltage (kv) NODAWAY MIPU FILMORE MIPU 69 Page 23 of 66

30 Delivery Points attached to Westar Energy Transmission & Distribution System* (a) (b) (c) (d) (e) (f) (g) (g) Delivery Ownership Point (Meter) Name SPP Bus Number / Name FTSCOTT kv FTSCOTT kv Voltage (Meter) (kv) (1) Transmission Loss (POR) Percentage (2) Distribution Loss (POR) Percentage (3) Total Loss (POR) Percentage (4) Total Loss (POD) Multiplier (5) Eve, Missouri Westar % 2.80% 5.74% Richards, Missouri Westar % 2.80% 5.74% (1) This represents the kv where the meter is physically located. (2) This represents the Point(s) of Receipt (POR) Transmission Loss Percentage as stated in SPP OATT Attachment M. (3) This represents the Point(s) of Receipt (POR) Distribution Loss Percentage as determined from the Westar Energy OATT Section (4) This represents the Total POR Loss Percentage to be applied. [ e + f ] (5) The meter values for loads are at the Point(s) of Delivery (POD) and not the POR; therefore, the Loss Percentages need to be converted to POD. In order to convert the POR Loss Percentages to POD multiplier, the following formula is applied to convert: [ 1 / (1 ( g / 100) ) ] These delivery points are currently within Westar Energy Balancing Area. These delivery points will be transferred to KCPL-GMO Balancing Area but remain on Westar Energy T&D System Page 24 of 66

31 Appendix 4 Westar Energy Wholesale Distribution Service Change Calculations Page 25 of 66

32 APPENDIX 4 WHOLESALE DISTRIBUTION SERVICE CHARGE Delivery Points attached to Westar Energy Distribution System Total Wholesale Distribution Service Charge = $ Page 26 of 66

33 ATTACHMENT B AGREEMENT FOR THE PROVISION OF TRANSMISSION SERVICE TO MISSOURI BUNDLED RETAIL LOAD This AGREEMENT FOR THE PROVISION OF TRANSMISSION SERVICE TO MISSOURI BUNDLED RETAIL LOAD (hereinafter the Agreement ) is entered into as of this day of 2009, by and between Southwest Power Pool, Inc. ( SPP ) and KCP&L Greater Missouri Operations Company ( KCP&L-GMO ). This Agreement shall be supplemental to the Network Operating Agreement ( NOA ) and Service Agreement for Network Integration Transmission Service ( NITSA ) to be executed by KCP&L-GMO and SPP under SPP s Open-Access Transmission Tariff ( OATT ) on file with the Federal Energy Regulatory Commission ( FERC ). The transmission service provided by SPP pursuant to the terms and conditions of the NOA and NITSA and any successor transmission service shall hereinafter be referred to collectively as Network Integration Transmission Service. SPP and KCP&L-GMO are referred to, jointly, as the Parties and, individually, as a Party. WITNESSETH: WHEREAS, SPP is a FERC-approved Regional Transmission Organization ( RTO ) with an open architecture that accommodates various forms of participation by transmission owning utilities; and WHEREAS, KCP&L-GMO currently maintains open-access transmission tariffs approved by the FERC; and Page 27 of 66

34 WHEREAS, KCP&L-GMO currently provides and will continue to provide Bundled Electric Service (including capacity, energy, transmission and distribution) to Missouri Bundled Retail Load pursuant to rates established by the Missouri Public Service Commission ( MoPSC ) and in accord with certain tariffs and rate schedules on file with the MoPSC; and WHEREAS, upon KCP&L-GMO receiving all necessary regulatory approvals for continued participation in SPP, including the approval of the transfer of functional control of KCP&L-GMO s transmission facilities pursuant to the Membership Agreement referred to below, KCP&L-GMO plans to utilize Network Integration Transmission Service from SPP, while this Agreement is in effect, in order to provide the transmission services necessary to furnish Bundled Electric Service to Missouri Bundled Retail Load; and WHEREAS, the FERC, in various orders 1 and in its White Paper, Wholesale Power Market Platform, issued April 28, 2003 ( White Paper ), contemplated, among other things, that a transmission owner and the RTO in which it holds membership may elect to enter into a service agreement that specifies that the wholesale rate for transmission service used to provide bundled retail electric service will be the transmission component of the bundled retail rates set by the state commission with retail jurisdiction over the transmission owner; and WHEREAS, the Parties hereto desire to codify the specific terms and conditions stated herein under which SPP will provide Network Integration Transmission Service to KCP&L-GMO to serve its Missouri Bundled Retail Load in addition to the terms and 1 Cleco Power, et al., 103 FERC 61,272 (2003), and Midwest Indep. Trans. System Operator, Inc., 102 FERC 61,192 (2003). Page 28 of 66

35 conditions set forth in SPP s NITSA and NOA except as otherwise stated in this Agreement. NOW, THEREFORE, in consideration of the premises and the mutual covenants and agreements herein contained, which each of the Parties hereto acknowledges to be sufficient consideration, SPP and KCP&L-GMO agree as follows: ARTICLE I - DEFINITIONS Terms not specifically defined in this Article or elsewhere in this Agreement have the same meaning as in the SPP OATT or the SPP Membership Agreement as these documents may be amended from time to time. Section 1.1. Bundled Electric Service: The provision of electric service as a single service that includes all component services (capacity, energy, transmission and distribution) as distinguished from the provision of electric service where some or all such components are sold and purchased as separate ( unbundled ) services. Section 1.2 Missouri Bundled Retail Load: The load of retail electric customers of KCP&L-GMO in the State of Missouri, on whose behalf and to whom KCP&L-GMO, by statute, franchise, regulatory requirement or contract, has an obligation to provide Bundled Electric Service. Section 1.3 SPP Membership Agreement: The Southwest Power Pool, Inc. Membership Agreement (SPP s Original Volume No. 3), as amended from time to time in accordance with its terms. Section 1.4 SPP OATT: The open-access transmission tariff of SPP (SPP s FERC Electric Tariff, Fifth Revised Volume No. 1), as amended from time to time. Page 29 of 66

36 ARTICLE II - FILING, EFFECTIVE DATE, INITIAL TERM AND TERMINATION Section 2.1 As soon as practicable following the execution of this Agreement, SPP shall file this Agreement with the FERC for acceptance or approval. If the FERC accepts this Agreement without conditions or modifications, this Agreement shall become effective on the date upon which KCP&L-GMO exercises the authorization provided by the Missouri Public Service Commission in Case No. EO (the Effective Date ). Each Party shall use its best efforts to gain prompt FERC acceptance or approval of this Agreement without modification or change, and agrees to provide support for this Agreement in public forums and elsewhere. Section 2.2 If the FERC accepts this Agreement for filing, but subject to modification or change, and requires a compliance filing by either or both of the Parties, the Parties shall evaluate whether such required compliance filing materially changes or frustrates the intent of this Agreement. If either Party determines, in good faith, that the changes or modifications required by the FERC constitute a material change or may frustrate the intent of the Agreement, the Parties agree to negotiate in good faith to establish new terms and conditions that place the Parties in the same position as bargained for in this Agreement. If within thirty (30) days after the FERC s conditional acceptance of the Agreement, or such other reasonable time period as may be mutually agreed to by the Parties, the Parties have not reached agreement on new terms and conditions or, if the amended Agreement is not subsequently unconditionally approved or accepted by the FERC, the Agreement shall be void, and neither Party shall have further obligations to the other Party hereunder. Page 30 of 66

37 Section 2.3 This Agreement shall remain in effect following the Effective Date for an initial term ending the earlier of: (i) the date that KCP&L-GMO withdraws from SPP, or (ii) at 12:00:01 a.m., on October 1, Subject to the termination provisions of this Section 2.3, the Initial Term shall automatically be extended from year to year (a Renewal Term ) unless either Party shall have given the other six (6) months written notice of termination prior to the end of the Initial Term, or the end of any Renewal Term if such notice is given at least six (6) months prior to the end of that Renewal Term. Section 2.4 Nothing in this Agreement shall in any way affect the rights or obligations of KCP&L-GMO with regard to withdrawal from SPP pursuant to the terms and conditions of the SPP Membership Agreement, Bylaws, and OATT, or any MoPSC order pertaining to KCP&L-GMO s participation in SPP. Nor shall anything in this Agreement affect in any way the rights or obligations of SPP to enforce or seek the enforcement of any terms in its Membership Agreement, Bylaws and OATT relating to any withdrawal by KCP&L-GMO. ARTICLE III - RATE FOR TRANSMISSION SERVICE TO SERVE MISSOURI BUNDLED RETAIL LOAD Section 3.1 Schedule 9 of the SPP OATT establishes a zonal transmission rate applicable to load within the KCP&L-GMO pricing zone that is taking Network Integration Transmission Service from SPP. Notwithstanding Schedule 9 and the rates therein, KCP&L-GMO does not concede that the FERC has jurisdiction over the transmission component of Bundled Electric Service provided to Missouri Bundled Retail Load using its own facilities, and does not voluntarily submit to such jurisdiction. KCP&L-GMO shall not pay the rate set forth in Schedule 9 of the SPP OATT for using its own facilities to serve its Missouri Bundled Retail Load, but will include Missouri Page 31 of 66

38 Bundled Retail Load in the total load used to calculate the zonal rate for the KCP&L- GMO zone. However, this provision shall not eliminate any obligation that KCP&L- GMO may have to pay applicable charges related to facilities owned by other entities in KCP&L-GMO s zone that are unaffiliated with KCP&L-GMO. Section 3.2 KCP&L-GMO, when taking transmission service from SPP in order to serve its Missouri Bundled Retail Load, shall not pay ancillary service charges pursuant to Schedules 3, 5 and 6 of the SPP OATT to the extent that KCP&L-GMO selfprovides such ancillary services pursuant to the NITSA consistent with Part III of SPP s OATT. With regard to Schedules 1 and 2, KCP&L-GMO shall not be required to pay SPP for the portion of those services for which it would receive the revenues from such services. If a portion of the revenues from Schedules 1 and 2 would be distributed to others, KCP&L-GMO shall be obligated to pay such portion to SPP. Section 3.3 Except as otherwise provided in Sections 3.1 and 3.2, KCP&L- GMO shall be subject to and shall pay to SPP all applicable SPP OATT charges associated with Network Integration Transmission Service taken by KCP&L-GMO to serve Missouri Bundled Retail Load. Such charges include, but are not limited to, Attachments H, J, K, M, U, V, Z, AE, and AK and Schedules 1A, 4 (to the extent Schedule 4 reflects the energy costs associated with SPP s Energy Imbalance Services market), 11, and 12 of the SPP OATT. Section 3.4 As a Network Integration Transmission Service customer of SPP serving its Missouri Bundled Retail Load, KCP&L-GMO shall be subject to all non-rate related terms and conditions under the SPP OATT applicable to Network Integration Transmission Service. Page 32 of 66