CMTF Tariff Language Clarification 1

Parking Lot Question Is the Planning Reserve Margin requirement meant to be maintained throughout the whole calendar year?  Will deficiency payments be for 12 months or just the 4 months of the Summer Peak Season? Proposed Tariff language:  The PRM Requirement shall be maintained for twelve (12) consecutive months starting October 1, but enforcement of the PRM Requirement is based on compliance during the Summer Peak Season. 2

Parking Lot Question Are LREs expected to maintain planning reserves for load that is external to the SPP BA?  The definition of an LRE states that it is responsible for load and firm Export Interchange Transactions, which is load external to the BA and not pseudo tied in Proposed Tariff language:  If an LRE serves load both internal and external to the SPP Balancing Authority Area, compliance with the PRM Requirement contained in this Attachment XX is not intended to affect an LRE’s obligation to maintain distinct and separate amounts of resources to cover its applicable planning reserve obligation for its load located external to the Transmission Provider. Does firm Export Interchange Transactions need to be removed from the LRE definition?  Export Interchange Transaction definition: A Market Participant schedule for exporting Energy out of the SPP Balancing Authority Area. Proposed Tariff Language:  An LRE will not be subject to the PRM Requirement for load pseudo-tied out of the SPP Balancing Authority Area or load external to the Transmission Provider that is served by a firm Export Interchange Transaction. 3

Parking Lot Question If a Generation Owner does not submit a workbook by Feb. 15 th and an LRE has contracted with that GO for a Deliverability Study contract, is the contract still valid if SPP cannot validate the transaction from the GO’s workbook?  Should the LRE be harmed by the GO not meeting its requirement for submitting the applicable information? Proposed Tariff Language:  A Generator Owner shall submit a Workbook to be utilized by the Transmission Provider to (i) determine the amount of the generation capacity that is already committed through firm transmission service, and (ii) verify the amount of generation capacity available for purchase that has been deemed deliverable through the Deliverability Study. To determine the amount of a Resource’s deliverable capacity, the Generator Owner shall subtract the amount of a Resource’s committed capacity, as determined from the Generator Owner’s Workbook, from the Resource’s total deliverable MWs. A Generator Owner that does not submit a Workbook that contains the amount of generation capacity available through the Deliverability Study shall not be entitled to sell its non-committed generation capacity to an LRE for the purposes of satisfying the PRM Requirement without going through an additional transmission service study. 4

Parking Lot Question If an LRE does not submit a workbook by May 15 th they will be issued a deficiency payment.  Should that payment be for the peak load obligation plus the PRM Requirement or just the PRM Requirement amount? Proposed Tariff Language:  For a Market Participant that doesn’t provide its LRE’s Workbook, the Deficient Planning Reserve Margin shall be the LRE’s Peak Demand plus the PRM Requirement for the Peak Demand. The Transmission Provider shall utilize the LRE’s previous year’s Peak Demand to calculate the Deficient Planning Reserve Margin. For a Market Participant who provides its LRE’s Workbook that does not demonstrate sufficient capacity to satisfy both the LRE’s Peak Demand and the PRM Requirement, the Deficient Planning Reserve Margin shall be the difference between the Peak Demand plus the PRM Requirement and the LRE’s acquired capacity. Planning Reserve Assurance Policy Whitepaper Language:  The term “PRM deficiency” includes the entire capacity deficiency of an LRE with regard to its failure to meet SPP’s PRM requirement, which includes both capacity required to meet an LRE’s peak load as well as the capacity required to meet an LRE’s PRM requirement above peak load. 5

Parking Lot Question If and LRE or GO retires a generator after Feb 15 th that is to be decommissioned before June 1 st or during the Summer Peak Season and an LRE can no longer meet the PRM requirement, is the LRE still compliant?  The LRE can count capacity for generators before Feb 15 th even if the GO takes outages after Feb 15 th, but for retirements does the LRE need to cure the deficiency? 6