APPA RELIABILITY STANDARDS & COMPLIANCE SYMPOSIUM Case Study: City Utilities of Springfield, MO January 11, 2007

Overview Introduction NERC Functional Responsibilities Documentation and Review of Transmission Operator Function Conclusion

Service Area –Population 222,000 –Size (in square miles) 320 Electric System –Customers 104,853 –Hourly Peak demand 801 MWh –MWh Annual Growth 2.1% Natural Gas –Customers 81,610 –2006 System Sales10,434,889 Dth Water –Customers 78,943 –2005 System Sales 10,015,838,000 Gal Transit –2005 Riders 1,708,824 –Miles of Route 175 Telecommunications (Springnet) –High Level/Commercial Broadband Supplier –Secure Server/Remote Site Backup Service

Transmission System 345 kV Transmission miles –1 Substation –2 Points of Interconnection 161 kV Transmission –74 miles of 161 kV Transmission Circuits –13 Substations –4 Points of Interconnection 69 kV Transmission –90 miles of 69 kV Transmission Circuits –26 Substations

13.2 kV Distribution –1,934 Miles of 13.2 kV Distribution Circuits 1,437 Miles Overhead 497 Miles Underground –31 Distribution Substations Distribution System

City Utilities’ Power System Control Power Generation 5 Generating Sites 450 MW Coal-Fired 367 MW Oil & Gas-Fired 3.2 MW Landfill Gas 14 Generators Transmission & Distribution 40 Substations 208 Miles of Transmission Line 1,934 Miles of Distribution 104,853 Customers Security Coordinator SPP Market Agent TEA Balancing Authority SWPA

City Utilities’ NERC Registered Functions Distribution Provider Generation Owner Generation Operator Load-Serving Entity Purchasing-Selling Entity Resource Planner Transmission Owner Transmission Operator Transmission Planner

Operations - T & D - Maintenance - Testing - Vegetation Management Electric Supply - Dispatch - Generation - Transmission Planning Administration - Information Technology - Cyber Security Finance - Risk Management - Physical Security Board of Public Utilities John Twitty General Manager

Examples of Cross Area Responsibilities Standard EOP — Disturbance Reporting –3. Purpose: Disturbances or unusual occurrences that jeopardize the operation of the Bulk Electric System, or result in system equipment damage or customer interruptions, need to be studied and understood to minimize the likelihood of similar events in the future. –4. Applicability 4.1. Reliability Coordinators Balancing Authorities Transmission Operators Generator Operators Load Serving Entities Regional Reliability Organizations.

Examples of Cross Area Responsibilities Standard FAC — Coordination of Plans for New Facilities –3. Purpose: To avoid adverse impacts on reliability, Generator Owners and Transmission Owners and electricity end-users must meet facility connection and performance requirements. –4. Applicability 4.1. Generator Owner 4.2. Transmission Owner 4.3. Distribution Provider 4.4. Load-Serving Entity 4.5. Transmission Planner 4.6. Planning Authority

Examples of Cross Area Responsibilities Standard IRO — Reliability Coordination — Operations Planning –3. Purpose: Each Reliability Coordinator must conduct next-day reliability analyses for its Reliability Coordinator Area to ensure the Bulk Electric System can be operated reliably in anticipated normal and Contingency conditions. System studies must be conducted to highlight potential interface and other operating limits, including overloaded transmission lines and transformers, voltage and stability limits, etc. Plans must be developed to alleviate System Operating Limit (SOL) and Interconnection Reliability Operating Limit (IROL) violations. –4. Applicability 4.1. Reliability Coordinators 4.2. Balancing Authorities 4.3. Transmission Operators 4.4. Transmission Service Providers 4.5. Transmission Owners 4.6. Generator Owners 4.7. Generator Operators 4.8. Load-Serving Entities

Preparation Late Start –Company organization structure led to fractured approach Attended SPP Compliance Workshop Preparation for SPP and NERC Transmission Operation Audit in 2006 –Developed cross-area team to prepare all documentation Corporate-Wide Standards Review –Critical Assets –Division of Standards

Ongoing Identifying Overlap/Gaps in Standards Management NERC Standards Education Training Program Enhancement

Future Develop job description and hire/transfer new Standards Administrator Select Sr. Manager to oversee and manage CIP Standards Incorporate Corporate-wide Standards, update meetings to ensure compliance without overlap Determining level of compliance

Lessons Learned Start now System Operator certification, training and documentation are essential Internal and external training should be used Identify responsible area(s) for each applicable standard Document, document, document…… Establish formal document management program including management review and approval