Cleco Transmission Planning Summit

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• Cleco Transmission Planning Summit
• Attachment K
• November 15, 2007
• Terry Whitmore

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FERC Order 890 Attachment K OVERVIEW

• STRAWMAN
• Presented FERC Little Rock technical conference.
• White Paper
• DRAFT ATTACHMENT K
• Presented FERC Atlanta technical conference.
• Solicited additional feedback prior to summit.

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Cleco Power Annual Transmission Planning Process
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FERC Order 890 Attachment K Definitions

• Base Case Model
• Critical Energy Infrastructure Information (CEII)
• Confidential Information
• Planning Criteria
• Construction Plan

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FERC Order 890 Attachment K Definition Comments

• Comment - Confidential Information
• Definition too broad
• Cleco Response
• Cleco disagrees. Consistent with FERCs model of
  Protective Order confidentiality provisions of
  OATT.
• Comment - Construction Plan
• What is construction plan limited to 5 years
• Cleco Response
• Five year time frame came from Clecos budgeting
  dept. Cleco agrees that a plan should exist to
  include proposed projects up to 10 years.

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FERC Order 890 Attachment K Definition Comments

• Comment -Base Case Model
• Specify time period
• Indicate changes discrepancies in SPP SERC
  models
• Stakeholders should have input into SPP SERC
• Cleco Response
• MMWG set model time frame
• Cleco submits data for Clecos CA
• Data same for Cleco in both SPP SERC
• Stakeholders need to participate through SPP
  SERC process not Cleco.

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FERC Order 890 Attachment K Planning Process

• Model Development including input by
  stakeholders.
• 10 year plan (Construction Plan 1-5, Proposed
  Plan 6 - 10).
• Coordinated regional planning with adjacent
  transmission owners.

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FERC Order 890 Attachment K Planning Process
Comments

• Comment - Input into planning criteria.
• Cleco response. Planning criteria is industry
  accepted.
• Comment - Coordinated regional planning with
  adjacent transmission owners.
• Cleco response. Agree. Only adjacent systems
  are monitored. Change Attach K to transmission
  owners.

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FERC Order 890 Attachment K Coordination

• Stakeholders may request formation of committee.
• Open welcome input from stakeholders.
• Post calendar of events on OASIS as well as email
  exploder to keep stakeholders up to date on
  planning process as well as allow comments and
  input.
• Affected systems

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FERC Order 890 Attachment K Coordination Comments

• Comment - Summit is to inform stakeholders rather
  than solicit input no follow up.
• Cleco Response - Section 5.1 clearly states
  stakeholders may comment and provide input. Flow
  chart shows posting pre post summit.
• Comment Company affiliates cant hold more
  than one seat on stakeholder committee
• Cleco Response Cleco agrees and language will
  be changed.

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FERC Order 890 Attachment K Coordination Comments

• Comment Stakeholder may request any issue
  related to transmission planning be considered by
  committee.
• Cleco Response Cleco agrees and language will
  be changed.

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FERC Order 890 Attachment K Openness

• Willing to share all information, but must
  protect confidential information including CEII.
• Require requester to sign confidentiality
  agreement.

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FERC Order 890 Attachment K Openness Comments

• Comment Signing a confidentiality agreement is
  too excessive.
• Cleco Response consistent with OATT and we are
  referring ONLY to confidential information. Non
  confidential information does not apply.

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FERC Order 890 Attachment K Transparency

• Cleco will allow stakeholder to request base case
  power flow models, planning criteria, as well as
  assumptions for verification and validation of
  studies provided appropriate confidentiality
  agreements are in place.
• Post construction plan on OASIS.

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FERC Order 890 Attachment K Transparency
Comments

• Comment - Stakeholder should be allowed to
  download information directly rather than make a
  request.
• Cleco response White paper does not specify
  downloading, only process to obtain information.
  Cleco is evaluating technical options including
  eRoom or FTP server

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FERC Order 890 Attachment K Information Exchange

• Firm PTP reservations will be modeled during
  active timeframe of TSR, unless it qualifies for
  rollover rights (5 years or more).
• Network customers (native load non-native load)
  submit a 10 year load forecast DNRs.

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FERC Order 890 Attachment K Comparability

• All stakeholders are treated comparably whether
  network, Point to Point, or pre 888.
• Models and supporting data are available for
  replication duplication of results.

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FERC Order 890 Attachment K Dispute Resolution

• Any party may dispute planning process by
  providing written notice of such dispute.
• Representatives of each party shall negotiate to
  resolve dispute within 10 business days
• Executive management of each party (30 days)
• Hire an external mutually agreed upon mediator
• File section 206 complaint with commission

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FERC Order 890 Attachment K Dispute Resolution
Comments

• Comment Should not apply to pre 888 agreements.
• Cleco response Agree, it is an OATT attachment.
• Comment Who is independent regional planning
  authority?
• Cleco response SPP

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FERC Order 890 Attachment K Regional
Participation

• Cleco participates in SPP SERC (Entergy) model
  development processes.
• Coordinate with affected systems
• Joint planning meetings w/ Entergy (SERC) SPP.
• Voting member of SPP TWG.

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FERC Order 890 Attachment K Economic Planning
Studies

• Separate queue on OASIS for TSR generator
  interconnection.
• Study annually three (3) highest priorities as
  established by stakeholders (previously 1)

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FERC Order 890 Attachment K Economic Planning
Studies Comments

• Comment May be impracticable to submit data at
  time of economic study request.
• Cleco response Disagree. Execute study, scope
  details must be included.
• Comment Confidentially of data.
• Cleco response Agree. Language will be added
  for confidential information.

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FERC Order 890 Attachment K Economic Planning
Studies Comments

• Comment Cost of studies above 3 will be
  assigned to requesting parties.
• Cleco response Agree. Language will be
  modified.
• Comment Requesting parties be billed as study
  cost are incurred rather than prepayment.
• Cleco response Draft language to be consistent
  with OATT for study cost payments.

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FERC Order 890 Attachment K Cost Allocation

• Reliability Upgrades LPSC rate base for
  planning criteria violations.
• Economic Upgrades
• Cost allocated to beneficiary.

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FERC Order 890 Attachment K Cost Allocation
Comments

• Comment Stakeholders should have input into
  Planning criteria.
• Cleco response Clecos planning criteria is in
  accordance with NERC reliability standards SPP
  criteria.
• Comment Clarity is needed is defining an
  economic study.
• Cleco response Disagree. Clearly stated that
  if Clecos planning criteria is not violated
  which is reliability, then it is an economic
  upgrade.

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FERC Order 890 Attachment K Recovery of
Planning Cost

• Cleco will recover cost for three economic
  studies annually through existing rate structure.
• Requestor will pay for any additional studies.

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FERC Order 890 Attachment K Recovery of
Planning Cost Comments

• Comment Parties should not be exposed to TPs
  cost exceeding estimate.
• Clecos response Disagree. OATT requires TCs
  to pay for studies.

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Questions