STRATEGIC PLANNING COMMITTEE MEETING

Transcription

1 Minutes No. 58 Southwest Power Pool STRATEGIC PLANNING COMMITTEE MEETING Policy matters on ITP and PP Wednesday November 18, 1PM 5P Thursday November 19, 8AM - NOON Arkansas Electric Cooperative Headquarters, Little Rock, AR MINUTES Agenda Item 1 Call to Order Ricky Bittle called the meeting to order at 1:00 p.m. SPC members participating in person were Jim Eckelberger (Director); Harry Skilton (Director); Mike Palmer (EDE); Mike Wise (GSEC); and Tim Woolley (Xcel). Members attending by phone included Les Evans (KEPCO); Josh Martin (Director) and Rob Janssen (Redbud). Other attendance is noted on the sign-up sheet (Attendance Attachment 1). Agenda Item 2 Priority Projects Ricky Bittle kicked off the discussion by referring to the October 2009 Board Resolution approving Priority Projects. He stated that the focus of the meeting is to look at the assumptions that staff and MOPC had developed to perform the Priority Project study effort. Bruce Rew presented a report on the study effort (Attachment 2) staff would be conducting on the Priority Projects. Discussion amongst the participants included whether the six projects were the correct projects to be studied. The discussion also focused on the issue of 345kv vs. 765kv construction for two of the six projects. Following debate, Les Dillahunty crafted a compromise proposal for consideration. The compromise would be that in addition to staff studying what the board had previously approved (see slide 11 in Attachment 2); staff would study Priority Projects 5 & 6 (Spearville-Comanche-Medicine, Lodge- Wichita and Comanche-Woodward District EHV) at 345kv double circuit as well as 765kv. Staff also proposed to add language in a footnote stating Intent to issue NTC s no later than May 15, 2010 for operations at 345kv but designed at 765kv standards with the potential to be built at double circuit 345kv or 765kv in the future pending the ITP analysis for completion in January After significant debate regarding the added footnote, the addition was shortened to state Intent to issue NTC s no later than May 15, The footnote was unanimously revised in the second day of meetings (Attachment 3). The footnote now reads: A significant group of stakeholders believe more rigorous analysis is needed to justify 765 kv transmission. In order to garner maximum consensus on the Priority Projects, Staff recommends the Board consider issuance of NTCs for construction as double-circuited 345 kv; designed to preserve the option to convert to 765 kv as the result of the ITP analysis expected to be completed in January Jay Caspary discussed slides 24 & 25 of Exhibit 1 regarding other benefit analysis of EHV transmission. There was support for hiring a consultant to help analyze benefits other than just adjusted production cost. Several participants offered assistance. Finally, agreement was reached on the timeline for the Priority Project study effort with the caveat that the effort should not jeopardize delaying the 2011 ITP deliverables.

2 SPP Strategic Planning Committee Minutes November 18-19, 2009 Agenda Item 3 Input from MOPC, ESWG, and TWG Bill Dowling presented the keys to obtaining MOPC concurrence on Priority Projects on behalf of the MOPC (Attachment 4). Alan Meyers outlined the ESWG concerns on behalf of the ESWG (Attachment 5). Significant discussions occurred regarding the ESWG recommendation that variable O & M cost for wind ranges from $6/MWh to $8/MWh. Further discussion reinforced the need to continue improving the benefit measure beyond that of just evaluating adjusted production costs. Dr. Proctor next provided his presentation on behalf of RSC (Attachment 6). Finally, Ronnie Frizzell spoke on behalf of the TWG and provided an update that the TWG set up a process to perform reliability assessments on the PP. Following presentations by the various other stakeholder groups mentioned above, the meeting returned to a discussion of the major assumptions to be used in the Priority Projects analyses. Ricky Bittle identified the items for consideration includes: o o o The amount of wind The incremental cost of wind Direction on deliverability Staff suggested 7GW of wind was the target for the study effort and after discussion agreement was reached that 7GW was the appropriate amount of wind to study and that the staff and ESWG would work out the questions of how that 7GW is distributed in the system. With respect to questions on deliverability of the wind, agreement was achieved that the base cost would be the 2008 STEP plus Balanced Portfolio. With respect to questions of wind variable O & M cost, after discussion assuring the wind representation participants that use of $8/MWh variable O & M would not lock them in for other purposes, consensus was reached to use $8/MWh on the Variable O & M for wind consumption. Agenda Items 4 & 5 were deferred to a subsequent meeting now scheduled for December 7, Agenda Item 6-Recap of Policy Decisions Following all the discussions, Ricky recounted the policy decisions that had been achieved over the course of the meeting. They are as follows: 1. Study the 6 projects the Board directed 2. Include the evaluation of the 6 PP modified as discussed in Exhibit GW wind assumption 4. Staff and ESWG to work out questions of how wind to be distributed in models 5. Generation limits to establish the minimum on deliverability 6. Variable wind O & M cost is $8/MWh 7. Evaluation of benefits to include other soft benefits 8. Breakpoint analysis for additional work that could be supported by the 6 upgrades (later) 9. Study schedule approved. With no further discussion the meeting adjourned. Respectfully Submitted, Michael Desselle

3 Southwest Power Pool, Inc. STRATEGIC PLANNING COMMITTEE MEETING Policy matters on ITP and PP Wednesday November 18, 1 PM 5 PM Thursday November 19, 8 AM - NOON Arkansas Electric Cooperative Headquarters, Little Rock, AR AGENDA 1. Call to Order... Ricky Bittle 2. Priority Projects... Bruce Rew a. Analysis Methodology for Priority Projects b. Discussion Regarding Major Assumptions c. Discussion on non-adjusted Production Cost Benefit Calculations 3. Input from MOPC, ESWG and TWG... Bill Dowling, Alan Meyers, Ronnie Frizzell 4. Integrated Transmission Planning... Katherine Prewitt a. Overview of ITP transition b. Discussion Regarding Major Assumptions 5. Discussion on Scenarios... Bruce Rew 6. Recap of Policy Decisions... Ricky Bittle 7. Summary of Action Items... Michael Desselle

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7 Subject: SPC Meeting -----Original Message----- From: Perkins Jr, Mel Sent: Saturday, November 07, :28 PM To: Michael Desselle Cc: Crissup, Phil Subject: SPC Meeting Michael- As I informed you, I will be unable to attend the SPC meeting in Little Rock. Phil Crissup will attend and has my proxy. Thanks, Mel 1

8 SPP.org Priority Projects Strategic Planning Committee November, 2009 SPP.org 1

9 Priority Project Discussion items Where we have been, the road to priority projects Analysis methodology for Priority Projects Outstanding Major Assumptions Benefits of Priority Projects SPP.org 3 Synergistic Planning Project Team SPP struggling g with the Planning Process Board of Directors forms high level SPPT SPPT developed report with recommendations New Planning Process New Cost Allocation Transition plan, includes Priority Projects BOD approves SPPT Report in April, 2009 SPP.org 4 2

10 SPPT Priority Project Considerations Projects that are identified in the Cluster Studies for Grouped Generation Interconnection ti requests, Projects that routinely show up as needed in the Aggregate Study Process Projects that address known congestion, Projects needed to integrate SPP s west and east transmission systems. SPP.org 5 Priority Project Study effort SPP worked during the summer on Priority Project effort MOPC recommended 10 Priority Projects by studied Some projects included evaluating operating and constructing at different voltage levels TWG and ESWG provided d staff input on study process for evaluation of Priority Projects SPP.org 6 3

11 What staff attempted with Priority Projects Meet the goals of the SPPT Select Projects that created some semblance of balance within the SPP Attempted to judge a reasonable ratepayer impact leaving headroom for the future ITP projects SPP.org 7 Priority Project Update to MOPC BOD Workshop on September 29 reviewed first draft report Second Draft Priority Project completed early October October MOPC Review and Discussion Voted down Planning for 10 GW+ of wind (45%) Staff s recommended Priority Projects were not approved Voted dto have SPP restudy at t7&14gw of wind with transmission needed to deliver to SPP load. SPP.org 8 4

12 Priority Project Update to BOD Priority Projects reviewed with SPC Staff recommended 4 Priority Projects to BOD Significant discussion on Priority Projects at RSC and BOD meetings BOD developed recommendation on Priority Projects to study 6 projects SPP.org 9 Approve the following Priority Project package for further analysis and review on a regional basis with SPC oversight (in coordination with MOPC and its Working Groups) for approval by the January 2010 series of meetings. Valliant NW Texarkana (345 kv) - $131 million (MM) Cooper Sibley (345 kv) - $278 MM Riverside Tulsa Reactor (138 kv) - $842,000 Hitchland Woodward District EHV (345 kv double circuit) - $237 MM Spearville Comanche Medicine Lodge Wichita (765 kv construction 345 kv operation) - $478 MM Comanche Woodward District EHV (765 kv construction 345 kv operation) - $132 MM Total E&C is approximately $1.26 B Intent to issue NTCs no later than May 15, SPP.org 10 5

13 Approve the following Priority Project package for further analysis and review on a regional basis with SPC oversight (in coordination with MOPC and its Working Groups) for approval by the January 2010 series of meetings. Valliant NW Texarkana (345 kv) - $131 million (MM) Cooper Sibley (345 kv) - $278 MM Riverside Tulsa Reactor (138 kv) - $842,000 Hitchland Woodward District EHV (345 kv double circuit) - $237 MM Spearville Comanche Medicine Lodge Wichita (345 kv double circuit) - $356 MM * Comanche Woodward District EHV (345 kv double circuit) - $108 MM * Total E&C is approximately $1.12 B * Intent to issue NTCs no later than May 15, SPP.org 11 SPP.org 12 6

14 BOD Recommended Priority Projects: 345 kv double circuit line Hitchland - Woodward District EHV West East connection Relieves known congestion corridor Aggregate Study queue Improves transmission in major renewable development area Estimated cost of $237 Million SPP.org 13 BOD Recommended Priority Projects: 345 kv line Cooper - Maryville Sibley Relieves known congestion corridor Provided benefits in adjusted production cost analysis Suggested evaluation from Nebraska City Sibley Estimated cost of $278 million SPP.org 14 7

15 BOD Recommended Priority Projects: 345 kv line Valliant NW Texarkana West East Relieves known congestion corridor Aggregate Study queue Estimated cost of $131 million SPP.org 15 BOD Recommended Priority Projects: 138 kv reactor at Tulsa power station Identified in transmission service studies as a limit Estimated cost of $842,000 SPP.org 16 8

16 BOD Recommended Priority Projects: 345 kv line Spearville - Comanche County - Medicine Lodge - Wichita, constructed t at 765 kv 345 kv line Comanche County - Woodward District EHV, constructed at 765 kv Fills major hole in bulk transmission system Improves West to East connection Relieves known congestion corridor Aggregate Study queue 345kV constructed at 765 kv costs approx. $478 million 345 kv double circuit costs approx. $356 million SPP.org 17 Now what do we do? SPP.org 18 9

17 How to study Priority Projects? SPP.org 19 Original Priority Project Analysis Adjusted Production Cost Impact on Losses Environmental Impacts Reliability Impact Deliverability of Capacity and Energy to Load Local Economic Benefits SPP.org 20 10

18 Original Priority Project Study Staff worked with TWG and ESWG to develop study scope Study process included a 10 year time frame be used to analyze benefits 3 modeled years: 2009, 2014, 2019 In-between years calculated using a linear progression Wind included a 10% and 20% cases SPP.org 21 Original Priority Project Analysis Total of 10-year benefit used to create NPV Terminal value used to represent B/C from last year of analysis A 20 & 40 year financial result shown as extrapolated from data used in the 10 year analysis SPP.org 22 11

19 Updated Priority Project Analysis Limit future renewable scenarios, generation will included if under construction Complete APC review and approval Evaluate benefits used in original studies Provide benefits of SPPT Priority Project considerations SPP.org 23 Updated Priority Project Schedule SPP complete study scope design in November Staff setup models and run studies in December Staff finalize and issue report in January MOPC and BOD updates in January SPP members review and provide feedback in February Staff finalize report in March Priority Project approvals in April SPP.org 24 12

20 Other Benefits of EHV Transmission Enable future markets Additional transmission revenues Ability to lower reliability margins Facilitating access of premium renewables to major markets, with aggregation and better management of intermittent resources Increased competition in wholesale markets Improved efficiencies in utility operations SPP.org 25 Other Benefits of EHV Transmission (cont.) Dynamic Benefits market adjustments enabled by transmission expansion Static models are limited and only capture a portion of the real benefits of major EHV projects over a fraction of their useful lives Insurance benefits - ability to respond to manmade and natural disasters Optionality for future resource planning decisions A robust and flexible grid is an investment in the future Market efficiency improvements beyond APC such as Fuel Diversity Benefits SPP.org 26 13

21 Considerations for final Priority Project Analysis Target for completing studies Future generation assumptions Financial extrapolation of future benefits Cost/Benefit Analysis for SPPT four key Priority Project considerations (slide 5) Staff flexibility to pursue these additional soft side evaluations SPP.org 27 Bruce Rew Vice President, Engineering SPP.org 14

22 Approve the following Priority Project package for further analysis and review on a regional basis with SPC oversight (in coordination with MOPC and its Working Groups) for approval by the January 2010 series of meetings. Valliant NW Texarkana (345 kv) - $131 million (MM) Cooper Sibley (345 kv) - $278 MM Riverside Tulsa Reactor (138 kv) - $842,000 Hitchland Woodward District EHV (345 kv double circuit) - $237 MM Spearville Comanche Medicine Lodge Wichita (765 kv construction 345 kv operation) - $478 MM (* 345 kv double circuit - $356 MM) Comanche Woodward District EHV (765 kv construction 345 kv operation) - $132 MM (* 345 kv double circuit - $108 MM) Total E&C is approximately $1.26 B (* $1.12 B) Intend to issue NTCs no later than May 15, * A significant group of stakeholders believe more rigorous analysis is needed to justify 765 kv transmission. In order to garner maximum consensus on the Priority Projects, Staff recommends the Board consider issuance of NTCs for construction as double-circuited 345 kv; designed to preserve the option to convert to 765 kv as the result of the ITP analysis expected to be completed in January SPP.org 1

23 12/3/2009 Priority Projects Process and Next Round of Studies Keys to Obtaining MOPC Concurrence Concerns Raised by MOPC Fossil unit dispatch must be reasonable, and underlying assumptions consistent with real world operations. This dispatch will be occurring in a world with a day 2 market, not today s world. Next report must make this clear. Don t have more than one variable moving at a time, i.e. wind energy output and new transmission assets. To the extent possible, base as many recommendations as possible on relative change in APC rather than absolute level of APC. 1

24 12/3/2009 Concerns Raised by MOPC Learn as much as possible from WITF analysis to date in modeling wind location/level, and required transmission to support such wind. Recommended construction should not only address wind levels of 7GW and 14GW, it should also solve existing problems related to flowgate loading, aggregate study upgrades, impediments to any new generation, etc. Continue to reference soft benefits such as economic development, job creation, etc., but recommendations based on direct benefits only. Concerns Raised by MOPC Next draft of report must clearly explain: Underlying assumptions regarding modeling of wind resources, dispatch of fossil resources, network topology, etc. Rationale for modeling and economic assumptions. Benefits of proposed construction, related to both wind integration and reliability/transmission service/interconnection service 2

25 12/3/2009 Other Issues How comprehensive is this analysis with respect to deliverability of wind energy? Absent a full deliverability analysis, will we look at FCITC to be certain Priority Projects do indeed improve the system? Is currently queued and contracted wind projects sufficient/appropriate criteria for selecting wind to include? 765kV vs. 345kV Directive from BOD includes V Plan built for 765kV but operated at 345kV. Assuming V Plan is in next recommendation: This allows us to buy some time. NTCs won t be issued until ~ April 10. No significant investments made or regulatory/siting processes concluded by January 11. ITP will likely re visit voltage issue in report due in January 11. Even if it recommends construction at 345kV no investment is lost. Easy to decrease voltage later. More difficult to increase voltage later. 3

26 Economic Studies Working Group Alan Myers Chair of ESWG ITC Great Plains 11/19/2009 SPP.org 1 Report to SPC Priority Projects 1

27 ESWG Outline of Report Economic model Issues Wind modeling issues Policy issues SPP.org 3 Reasons for Data Review Initial priority projects analysis was conducted using the economic model that was used for the Balanced Portfolio analysis and was thoroughly reviewed in that process Stakeholders have raised the following issues upon reviewing the results of the initial priority projects analysis Modeling of bi-lateral contracts especially for Lincoln Electric System WAPA contracts Unit minimum run levels Cycling of coal units SPP.org 4 2

28 Data Review Process Each TO s data has been provided for review on a password protected site SPP has contacted each TO individually ESWG has also discussed guidance for reviewing parameters Publicly available parameters for fuel prices, heat rate curves, O&M, etc. Company specific data for physical characteristics Balanced Portfolio load assumptions New generation to meet same criteria as used in the Balanced Portfolio SPP.org 5 Results of Data Review These are examples of updates to the data requested by the TOs. Modeling Nebraska s WAPA contracts as Joint Ownerships. One TO had an issue with their coal units not dispatching due to an issue with fuel assignment which has been corrected. Added a Nebraska wind farm which is currently in operation. Reassigned municipal units from Aquila to MKEC SPP.org 6 3

29 Data Review Results (continued) Added the Goodman Energy Center in MIDW which was not tin the model Other minor changes Majority of changes were items which were not included in the last data update. Issue with unit minimums was determined to be a misunderstanding of the data format SPP.org 7 Additional Generation added to the model Additional Generation which have a signed IA and firm transmission or are under construction Richardson County wind farm, Blue Canyon Wind 5, Elk City Wind 2, OU Spirit wind, Taloga Wind, No Man s Land wind, Lamar Stall, Antelope 1, Orme, Conestoga Wind, DWS Frisco Wind, Crofton Hills wind SPP.org 8 4

30 Next Steps Base case model inputs and outputs will be reviewed by TOs to verify their requested changes were made to the input data. SPP and the ESWG are requesting sign-off on the data which will be used in the Priority Project analysis. SPP.org 9 Wind Modeling Issues ESWG arrived at the following recommendations regarding wind modeling at its 11/3/09 meeting ESWG supports conducting priority project analysis at the existing in-service level of wind with the addition of projects under construction (see previous list) Analysis should be done with these wind projects in the base and change cases ESWG recommended that an additional change case with sufficient wind to produce a B/C of 1 be performed as time permits ESWG recommended changing the wind variable O&M cost from $6/MWH to $8/MWH to reflect intra-hour ancillary service costs. This cost is used to determine where wind dispatches economically in the model. SPP.org 10 5

31 Policy Issues for Priority Projects ESWG has encouraged SPP staff to provide greater detail in how the following gsppt criteria were applied for selecting priority projects Projects identified in generation cluster studies Projects that routinely show up in the Aggregate Study Process Projects that address known congestion (should be captured in APC calculation) Projects needed to integrate west and east transmission systems It would be useful for SPC to provide policy input to clarify how these criteria can be used in approving priority projects emphasis on no-regrets projects Policy on analysis on a Regional Basis Board resolution 10/27/09 SPP.org 11 Policy Issues - ITP Start with the EHV Overlay to begin ITP development and provide more clarity for Priority it Projects and Economic Analysis. Future analysis (no regrets policies) for the ITP that match with other SPP Strategic Planning Initiatives (High carbon future, High wind future, RPS, etc...) Consider alternatives that offer the most Flexibility or No Regrets regardless of options. SPP.org 12 6

32 Report to SPC on Priority Projects Nov 19, 2009 Mike Proctor Background on APC Metric 1. Should higher than existing wind be included in the change case? Balanced Portfolio used existing wind in the base and change case. The purpose of the BP was to measure the increased efficiency of the transmission system for existing resources. A key component to the BPanalysis was that all new resources included transmission required to deliver to load. The reason is that the BP was not meant to take the place of the Aggregate Study Process. CRA study used existing wind in the base case and new wind in the change case. The purpose of this study of the western figure eight at 765 kv was to measure the economic gain from integrating additional wind into the SPP region. A key economic measure in this study was a comparison of the revenues received by the new wind to the revenue requirements needed in order to justify the financial investment in these resources. 2. What level of wind is supported by the Priority Projects? Some have interpreted this as a question about delivery of wind, not just interconnection as an Energy Resource. For delivery there is no answer to this question because the SPP has not yet developed an approach (criteria)to measuring the delivery of wind into the footprint. The cluster studies attempted an approach to answer this question with respect to generation interconnection, but this is for Energy Resource Interconnection Service and does not address the level of transmission needed to integrate the wind into the footprint. 2 1

33 Background on APC Metric 3. Should additional wind be evaluated as benefits from the Priority Projects using the APC metric? Without t additional wind, it is unlikely l that t any of the priority it projects will produce benefits in excess of costs. Economic wind additions will create winners and losers using the APC metric. Results in additional conflict among stakeholders regarding approval. Balanced Portfolio is not a viable cost allocation under this scenario. 4. How much and where should the additional wind (if any) be added for benefits from the Priority Projects? The ESWG went with 10% and 20% additional wind the same as in the wind integration study and used the same locations. However, one of the focuses of priority projects was to move forward on generation interconnection projects. Thus, the question should have been asked, how much new wind can be interconnected with each priority project and that should have determined the location of the new wind. 3 Background: Priority Project Focus Priority Projects are intended to capture near term opportunities and needs related ltdto Flowgate congestion relief (CR); SPP s Aggregate TSR process SPP s GI processes; and Transfer capability between the SPP s western and eastern regions. 4 2

34 Background: Ranking Metrics Congestion Relief (CR) The congestion relief value was calculated by multiplying the average hourly shadow price (provided by the SPP markets group) by the total number of intervals breached or binding for an affected flowgate. Transmission Service Request (TSR) Impact The TSR impact value was calculated by taking reservation Transfer Distribution Factors (TDFs) and multiplying by the megawatts requested to obtain a total Megawatt Impact (MWI) value. MWI values for each reservation were then summed to get a total. The numbers used to obtain this sum were taken from the last five aggregate studies. ((R1: TDF1 x MW1=MWI1), (R2: TDF2 x MW2=MWI2), etc (MWI1 + MWI2 = Total)) Generator Interconnection (GI) Impact The GI impact value was calculated as the sum of all positive incremental flow impacts on such upgrades. (PTDF x MW requested = GI Impact) Economic Benefit (EB) The value for economic benefit attributed to each project was a Benefit to Cost (B/C) ratio as identified in recent economic studies. West East Transfer (WE) Each project received a value based on the kv level of the proposed solution that improved power transfers between SPP s west and east regions. 5 Background: Ranking Scores CR TSR GI EB EW Total H W S C W W C V T C M S R T

35 Key Benefit TSR Impact Only one of the proposed Priority Projects is associated with TSRs from SPP s existing (last five) Aggregate Studies. Difficult to put a dollar value on this metric, but if a problem is showing up on the existing system, this would tend to show an immediate need for an upgrade. 7 Key Benefit Congestion Relief Congestion Relief is properly measured by savings in Adjusted d Production Cost However, as with the Balanced Portfolio, congestion relief should be measured using existing wind in both the base and change cases. By itself, this metric is not likely to show benefits in excess of costs. 8 4

36 Key Benefit West to East Transfers Proposal that was not implemented because of time limitation: it ti Dollar savings from reducing LMP differences between wind (primarily located in the west) and load (primarily located in the east). ESWG will be considering additional metrics to directly measure increases in West to East Transfers. 9 Key Benefit Advancing GI There are two benefits from advancing GI: 1. Adding lower cost generation in the footprint Measured by reduction in APC with ihadded d wind din change case APC should be adjusted for any additional revenues needed to support new wind coming on as an economic resource Will result in winners and losers 2. Adding resource to meet renewable targets Measured by addition of wind needed to meet RES but under what assumptions? State vs. federal RES: Determines who gets benefits Local vs. regional location: Determines who gets benefits For RES, we don t have information on transmission needed to deliver wind generation to loads as DRs. In both cases, the addition of new wind resources MUST be ones directly associated with specific priority projects. SPC must decide if these determinations can reasonably be made at this time, or should wait for ITP process. 10 5

37 There are Significant Policy Issues Regarding Advancing GI 1. Amount of wind and location to meet renewable targets needs to be determined by individual utilities and states. a. It will take time for utilities and states to work through this issue. b. In the meantime, we can construct scenarios that represent the likely range of solutions for consideration under the ITP process. 2. Integration of large amounts of wind generation at remote locations may not be seen as beneficial by all SPP stakeholders. a. AsLow Cost Resource: Likely to have protestsif the economics show losers. b. As Renewable Resource: Likely to have protests if the ITP process is not followed on these types of upgrades. 11 Cost Allocation Current tariffs do not cover any of the Priority Projects. Proposed Highway/Byway tariff is based on ITP process that shows the need for no regrets upgrades under a variety of alternative futures. Implies that a waiver will be needed to allocate the costs of Priority Projects. Thus, the SPC should look at each of the projects and consider the arguments needed to support a waiver at FERC. 12 6

38 Key for Waiver: Immediate Opportunity/Need Immediate Benefits would be lowered by waiting for approval of project via the ITP process. This could be determined by measuring benefits with and without a delay. Related to CR, the lost benefits would be APC savings Related to Advancing GI, the lost benefits would be APC savings from introducing low cost generation Related to West to East Transfers, the lost benefits would be in congestion cost savings for existing generation. Needs cannot wait for the approval of the project via the ITP process. Related to TSR, the need has already shown up Related to Advancing GI, need to see schedule of needs for RES currently required by states CAWG is working on this for ITP. 13 7