the - ky psc home cases/2013-00221/20130711...2013/07/11 · 2013-00221 response to the kentucky...

Legal Counsel.

Dinsmôre.DINSMORE & SHOHL uy101 South Fifth Street Suite 2500 Louisville, KY 40202www.dinsmore.com

Edward I. Depp502-540-2347

up.depp(dinsmore.com

VIA HAND DELIVERYJeff DerouenKentucky Public Service Commission211 Sower Blvd.P.O. Box 615Frankfort, KY 40602-06 15

July 11,2013

, fl—.’.

JUL 112013

‘L. Li

U U [vi ‘vi S ON

Re: butt Application ofKeitergy Corp.and Big Rivers Electric Corporationfor Approval of Contract andfor aDeclaratory Order

Enclosed are an original and ten copies of Kenergy Corp. and Big Rivers ElectricCorporation’s: (1) Response to the Commission Staffs Initial Request for Information; (2)Response to the Office of the Attorney General’s Initial Request for Information; (3) Response tothe Kentucky Industrial Utility Customers, Inc.’s Initial Request for Information; (4) Petition forConfidential Treatment; and (5) Motion for Deviation in the above-referenced matter.

I certify that on this date a copy of these documents has been served on all persons on theattached service list by hand-delivery or by Federal Express.

ETD/lbEnclosures

cc: Mark A. BaileyBillie J. Richert

Dear Mr. Derouen:

))))

Case No. 2013-00221

Sincerely,

Edward T. Depp

1087006v I

Jennifer B. HansLawrence- W. CookDennis G. Howard, IIAssistant Attorneys General1024 Capital Center Dr.Suite 200Frankfort, KY 40601

Michael L. Kurtz, Esq.Kurt J. Boehm, Esq.Boehm, Kurtz & Lowry36 E. Seventh St., Suite 1510Cincinnati, Ohio 45202

Bernard F. Lovely, Jr.Bowles Rice LLPSuite 1700333 West Vine StreetLexington, KY 40507

Michael EarlyCorporate Energy DirectorCentury Aluminum1300 SW Fifth Avenue, Suite 1750Portland, Oregon 97201

Robert A. Weishaar, Jr.McNees Wallace & Nurick LLC777 N. Capitol St., NESuite 401Washington, DC 20002-4292

G. Kelly NuckolsPresident and CEOJackson Purchase Energy Corporation2900 Irvin Cobb DriveP.O. Box 4030Paducah, KY 42002-403 0

Melissa D. YatesDenton & Keuler, LLP555 Jefferson StreetSuite 301Paducah, KY 42001

Burns MercerMeade County RECC1351 Hwy. 79P.O. Box 489Brandenburg, Kentucky 40108

Thomas C. Brite, Esq.Brite & Hopkins, PLLC83 Ballpark RoadHardinsburg, KY 40143

Gregory StarheimPresident & CEOKenergy Corp.3 111 fairview DriveP.O. Box 1389Owensboro, KY 42302-1389

J. Christopher Hopgood, Esq3 1 8 Second StreetHenderson, Kentucky 42420

Joe ChildersJoe F. Childers & Associates300 Lexington Building201 West Short StreetLexington, Kentucky 40507

Shannon FiskSenior AttorneyEarthj ustice1617 John F. Kennedy Blvd., Suite 1675Philadelphia, PA 19103

a Service ListPSC Case No. 2013-00221

BIG RIVERS ELECTRIC CORPORATION

JOINT APPLICATION OF KENERGY CORP.AND BIG RIVERS ELECTRIC CORPORATION

FOR APPROVAL OF CONTRACTS ANDFOR A DECLARATORY ORDER

CASE NO. 20 13-00221

VERIFICATION

I, Robert W. Berry, verify, state, and affirm that I prepared orsupervised the preparation of the data responses filed with this Verification,and that those data responses are true and accurate to the best of myknowledge, information, and belief formed after a reasonable inquiry.

dYkI%Robert W. Berry

COMMONWEALTH OF KENTUCKY)COUNTY OF HENDERSON )

SUBSCRIBED AND SWORN TO before me by Robert W. Berry on thisthe ?‘ day of July, 2013.

Notary Public, KP State at LargeMy Commission Expires_______

y Public, Kentucky State-At-Largemmlssiofl Expires: JuIy 3, 2074

._) 4i951




CASE NO. 2013-00221

VERIFICATION

I, Billie J. Richert, verify, state, and affirm that I prepared or supervisedthe preparation of the data responses filed with this Verification, and thatthose data responses are true and accurate to the best of my knowledge,information, and belief formed after a reasonable inquiry.

Billie J. Ric ert


SUBSCRIBED AND SWORN TO before me by Billie J. Richert on thisthe day of July, 2013.

Notary Public, Ky. State at LargeMy Commission Expires /-J-/7

.




CASE NO. 2013-00221

VERIFICATION

I, Gregory J. Starheim, verify, state, and affirm that I prepared orsupervised the preparation of the data responses filed with this Verification,and that those data responses are true and accurate to the best of myknowledge, information, and belief formed after a reasonable inquiry.

Gregory J. Starheim


SUBSCRIBED AND SWORN TO before me by Gregory J. Starheim onthis the 4day of July, 2013.

Notary Pu lic, Ky. tate at LargeMy Commission Expires

.

ORIGINAL.

COMMONWEALTH OF KENTUCKY

BEFORE THE PUBLIC SERVICE COMMISSION OF KENTUCKY

In the Matter of:

JOINT APPLICATION OF KENERGY CORP. AND )BIG RIVERS ELECTRIC CORPORATION FOR

C N 2013 00221APPROVAL OF CONTRACTS ANDase O

FOR A DECLARATORY ORDER )

Response to the Kentucky Industrial Utility Customers’Initial Request for Information

dated July 2, 2013

.

FILED: July 11,2013

ORIGINAL

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JOINT APPLICATION OF KENERGY CORP. ANDBIG RIVERS ELECTRIC CORPORATION

FOR APPROVAL OF CONTRACTS AND FOR A DECLARATORY ORDERCASE NO. 2013-00221

Response to the Kentucky Industrial Utility Customers, Inc.’sInitial Request for Information

dated July 2, 2013

July 11, 2013

Item 1) Refer to page 29 lines 1344 of Mr. Berry’s Direct Testimony wherein states

that the Century witt pay Big Rivers for MISO charges that inclttde “SSR costs relating to

that [HawesvitteJ node.”

a. Please confirm that MISO may designate only one Coleman unit as an

SSR or as many as all titree of tite Coleman units as SSRs. Please

describe how MISO will make tite decision on how many units and

which units to designate as SSRs.

b. If the Company is required by MISO to continue operation of only one

or two of tite €‘oleman ttitits as SSRs, then does the Company plan to

idle the other an its?

c. Please list and describe the specflc costs that MISO will reimburse Big

Rivers (“make whole payments fMISO designates one or more of the

Coleman units as SSRs.

d. Provide a quantjfication of the make whole paymentsfor Coleman from

MISO to reimburse Big Rivers fMISO designates one or ntore of the

Coleman units as SSRs based on the test year costs included in the

Company’s revenue requirement in Case No. 2012-00535. Provide this

information by unit. Provide a cop]’ of alt workpapers aitd source

Case No. 2013-00221Response to KIUC 1-1

Witness; Robert W. BerryPage 1 of 6




dated July 2, 2013

July 11, 2013

1 docul7zents, including, bttt not limited to, electronic spreadsheets with

2 formulas intact.

3 e. Please provide a quantjflcation of the specific costs for Coleman that

4 MISO wilt not reimburse Big Riversfor fMISO designates one or more

5 of the Coleman till its as SSRs based on the test year costs included in the

6 €‘ompany ‘s revenue requirement in Case No. 2012-00535. Provide this

7 information by unit. Provide a copy of at! workpapers and source

8 documents, including, but hot limited to, etectroitic spreadsheets wit!;

9 formulas intact.

10 f Please provide a quanilfication of the specic costs for Coleman by unit

11 and plant that are included in the company’s revenue requirement in

12 Case No. 2012-00535 and a quantfIcation of the costs that colt be

13 avoidedfor each unit that is idled. Provide a copy of all workpapers and

14 source documents, including, but not limited to, electronic spreadsheets

1 5 with formulas iittact.

16 g. Please explain specifically how andfrom whom MISO will recover the

17 make whole payments made to Big Rivers for the coleman units


Witness: Robert W. BerryPage 2 of 6



Response to the Kentucky Industrial Utility Customers, Inc.’sInitial Request for Information -

dated July 2, 2013

July 11, 2013

I designated as SSRs. Explain how titese costs wilt be allocated to and

2 recoveredfrom each relevant Local Balancing Area, LSE or node.

3 h. Please confirm that under the MISO Attachment Y-2 Study Report,

4 91.63% of the Coleman SSR costs will be allocated to and recovered

5 from Big Rivers. If this is not correct, then please explain the

6 signIcance of tlte 91.63% setforth in Table 2 of the Report.

7 1. Will the Hawesville it ode be considered an LBA? Please explain why or

8 why hot.

9

10 Response)

11 a. Confirmed. Please see the MISO Tariff Section 38.2.7.c, “Evaluation of

12 SSR Unit Application.” This MISO Tariff section is provided as an

13 attachment to this response.

14 b. Yes. Big Rivers’ current plan is to idle the other Coleman units until such

15 time as the market will support the total production cost of the unit or until

16 Big Rivers finds sufficient replacement load, or enters into a bilateral

17 contract or contracts that justify operating the units.

1$ c. Please see the MISO Tariff section 38.2.7.h, “SSR Unit Compensation.”






dated July 2, 2013

July 11, 2013

1 d. Make whole payments cannot be quantified until Big Rivers enters into an

2 approved SSR agreement with MISO. Section 4.1 (a) of the Direct

3 Agreement requires Century to pay all cost incurred by Big Rivers if Big

4 Rivers is required to operate one or more of the Coleman units until the

5 SSR is approved.

6 e. Make whole payments cannot be quantified until Big Rivers enters into an

7 approved SSR agreement with MISO. Section 4.1 (a) of the Direct

• 8 Agreement requires Century to pay all cost incurred by Big Rivers if Big

9 Rivers is required to operate one or more of the Coleman unit/units until

10 the SSR is approved. The MATS capital equipment will not be

11 reimbursed by MISO or Century unless the SSR agreement is extended

12 beyond June 1,2014.

13 f. As stated in Case No. 20 12-00535, all costs associated with Coleman were

14 included in Big Rivers’ revenue requirement; however, the avoidable costs

15 of Wilson were not included, as Wilson was originally assumed to be

16 idled. As described in Exhibit Berry Rebuttal-2 in Case No. 2012-00535,

17 the fixed operating costs savings associated with idling Coleman is

1 8 approximately $90,000 ($91,426) greater than the fixed operating costs




FOR APPROVAL OF CONTRACTS AND FOR A DECLARATORY ORDERCASE NO. 20130O221


dated July 2, 2013

July 11, 2013

1 savings included in the requested rate adjustment, thus there is essentially

2 no rate impact due to the idling of Coleman in the case. This is the

3 difference in Big Rivers’ total cost of service with Coleman idled instead

4 of Wilson. As such, it should be assumed that no avoidable costs for

5 Coleman are included in the rate request. The depreciation, taxes, and

6 interest associated with Coleman plant were included in the requested rate

7 adjustment and are not avoidable even if the unit is idled. The

$ CONfIDENTIAL must-run analysis for the Coleman plant is provided in

9 an attachment to Big Rivers’ response to AG 1-1. This analysis shows

10 detailed costs for the Coleman Station. Costs by unit are not available.

11 g. MISO will utilize section 38.2.7.j of its tariff to determine how and from

12 whom it will recover the make whole payments made to Big Rivers for the

13 Coleman units designated as SSRs. The areas identified in the non-

14 binding Attachment Y-2 report for the cost allocation are Big Rivers

15 Electric Corporation (BREC) (91.63%), Southern Indiana Gas & Electric

16 (SIGE) (4.52%), Ameren Illinois (AMIL)(3.75%) and Duke Energy

17 Indiana (DEl) (0.10%). Please see response to KIUC item 1-2 for the

18 redacted version of the Coleman Attachment Y-2 report.






dated July 2, 2013

July 11, 2013

1 h. The 91.63% is the potential SSR cost allocation MISO provided in the

2 Attachment Y-2 request, which is a non-binding study. The final cost

3 allocation will be determined by MISO as part of the Attachment Y,

4 “Notification of Potential Resource/SCU Change of Status,” and

5 Attachment Y-1, “Standard Form Support Supply Resource (“SSR”)

6 Agreement” process. The 91.63% is the amount allocated to the Big

7 Rivers load node (BREC.BREC), which includes Century’s share of the

8 costs. After the Century load node is effective on August 20, 2013,

9 Century’s share of the 91.63% will be charged to its load node.

10 1. No, the Hawesville node is a commercial pricing node. Local Balancing

11 Authority designations are based on the transmission owner level of the

12 physical transmission system and are not determined based on how load or

13 generation is assigned to a particular commercial pricing node.

14

15 Witness) Robert W. Berry

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38.2.7 System Support Resources Version: 2.0.0 Effective: 9/24/2012

System Support Resource (SSR) procedures provide a mechanism for the Transmission

Provider to enter into agreements with Market Participants that own or operate Generation

Resources or Synchronous Condenser Units (SCUs) that are required by the Transmission

Provider to maintain reliability of the Transmission System, if all or a specified portion of the

capacity of such Generation Resources or SCUs would otherwise either Retire or Suspend.

The SSR procedures include: (a) a requirement that any Market Participant planning to

Retire or Suspend, all or a portion of a Generation Resource or SCU located within the

Transmission Provider Region for reasons other than a Generator Planned Outage must notifi

the Transmission Provider of such events by submitting a completed Attachment Y to the

Transmission Provider documenting the proposed plans for such Generation Resource or SCU, at

least twenty-six (26) weeks prior to taking such actions; (b) Market Participants must submit all

necessary information to enable the Transmission Provider to evaluate whether SSR Unit status

is appropriate for such Generation Resource or SCU; (c) if the Transmission Provider determines

that SSR Unit status is justified for a Generation Resource or SCU, the Transmission Provider

and such Market Participant shall enter into an SSR Agreement, in accordance with the

Attachment Y-1 form of agreement; (d) the SSR Unit will be operated in accordance with the

terms of the SSR Agreement, which contains detailed terms and conditions regarding operation

and compensation of such Generation Resource or SCU and the allocation of costs; (e) costs to

compensate an SSR Unit will be allocated to the LSE(s) that benefits from the operation of the

SSR Unit; and (f) the Transmission Provider shall periodically review the reliability

requirements of the Transmission Provider Region and shall determine which, if any, SSR

Agreements should be extended..

a. SSR Unit Notification Procedures. A Market Participant shall complete and deliver to

the Transmission Provider Attachment Y, Notification of Potential Generation Resource or SCU

Change of Status, at least twenty-six (26) weeks prior to Retiring or Suspending all or a portion

of a Generation Resource or a SCU that it either owns or operates, except as provided below.

The provisions of Section 38.2.7 do not apply to: (1) Generation Resources and SCUs that are in

forced outage or forced derate status; (2) Generation Resources and SCUs that are requesting, or

are not available due to, a Generator Planned Outage; (3) Behind the Meter Generation

Resources; or (4) Generation Resources that are identified as needed for Blackstart by a

Transmission Operator. Section 38.2.7 shall not modifi or alter a Transmission Operator’s

obligations under the Tariff to identify Blackstart Units that are included in a System Restoration

Plan, or a Blackstart Unit Owner’s obligations to comply with the terms of any Blackstart Service

agreement, in accordance with Schedule 33, or the requirements of Commission approved

reliability standards.

Market Participants that own or operate Generation Resources or SCUs that are not directly

interconnected to the Transmission System shall notif,’ the Transmission Provider in accordance

with Section 3 8.2.7(a) if the Market Participant plans to Retire or Suspend such facilities. The

Transmission Provider shall coordinate with the entity to which the Generation Resource or SCU

is directly connected to determine whether the Generation Resource or SCU is necessary for

reliability of the Transmission System.

The Transmission Provider shall treat Attachment Y as Confidential Information until the

Attachment Y reliability analysis is completed and the study results are disclosed to the Market

Participant.

The Transmission Provider shall respond to the Market Participant within twenty (20) weeks

.2

with the results of the study completed in response to the Attachment Y. A Market Participant

certifies by submitting an Attachment Y that such Market Participant has made a definitive

decision to Retire or Suspend a Generation Resource or SCU and the Attachment Y shall be

executed by an officer of the owner or operator of the Generation Resource or SCU attesting to

the facts supporting that claim, who has the legal authority to bind such Market Participant.

The Transmission Provider shall notify the Market Participant prior to publicizing the

Attachment Y request and study results that the Attachment Y analysis is complete, however, the

Transmission Provider shall not provide any information related to the study or study results to

the Market Participant at that time. The Market Participant may rescind its Attachment Y

submission by notifying the Transmission Provider of such rescission via electronic

communication and certified mail not more than five (5) business days afler receiving notice

from the Transmission Provider that the Attachment Y analysis is complete, in which case the

confidentiality of the Attachment Y shall be preserved. If a Market Participant rescinds an

Attachment Y submission, then such Market Participant shall not receive the results of the study

and such Market Participant shall pay the Transmission Provider 100% of the costs that the

Transmission Provider has incurred in conducting an Attachment Y analysis up until the date of

such rescission. Once a response is provided by the Transmission Provider to the Market

Participant, the Transmission Provider shall promptly post on OASIS: (1) that an Attachment Y

was submitted; and (2) whether the Transmission Provide?s study concluded that the Generation

Resource or SCU was required for the reliability of the Transmission System. An owner or

operator of a Generation Resource or SCU that notifies the Transmission Provider of a definitive

decision to Suspend may only modify its decision to Suspend by submitting a request to the

Transmission Provider that demonstrates significantly changed legal, regulatory, or economic

.3

conditions justifying modification of an Attachment Y Suspend decision. fn determining

whether the Generation Resource or SCU may return prematurely from suspension, the

Transmission Provider will evaluate factors, including, but not limited to: (1) any reliability

impacts if the Generation Resource or SCU operates differently than planned for by the

Transmission Provider based on the Attachment Y notification; and (ii) costs that the

Transmission Provider, or other Market Participants, may incur as a result of such modified

operations. After the Transmission Provider has posted on OASIS that a Generation Resource or

SCU is required for the reliability of the Transmission System, the owner or operator of such

facility may modify the effective date of a definitive decision to Retire or Suspend if: (I) the

Transmission Provider has determined that demand response, generation or transmission

expansion alternatives are required; and (2) the owner or operator of the Generation Resource or

SCU agrees in writing with the Transmission Provider to continue to operate the facility without

entering into an SSR Agreement until the alternative(s) have been implemented to maintain the

reliability of the Transmission System.

b. Notification of the Outage Scheduler After Submittal of Attachment Y. After receipt

of an Attachment Y, the Transmission Provider shall schedule such outage notification through

the Transmission Provider’s Control Room Operations Window (“CROW”) outage scheduling

system, or successor system, to coordinate the outage planning of a Generation Resource or SCU

through CROW, on behalf of the Market Participant.

c. Evaluation of SSR Unit Application. The Transmission Provider will perform an

Attachment Y reliability analysis to determine whether the Generation Resource or SCU is

necessary for the reliability of the Transmission System based on the criteria set forth in the

Business Practices Manuals, but will not determine in this initial analysis the available

.4

alternatives to designating the Generation Resource or SCU as an SSR Unit. The Transmission

Provider shall post the determination of reliability need on the Transmission Provider’s OASIS.

Before entering into an SSR Agreement with any Generation Resource or SCU, the Transmission

Provider shall assess, in an open and transparent planning process in accordance with the

provisions of the Transmission Expansion Planning Protocol Attachment fF to the Tariff,

feasible alternatives to the proposed SSR Agreement. The list of alternatives to SSR Unit status

that the Transmission Provider shall consider and expeditiously approve as applicable include

(depending upon the type of reliability concern identified): (i) redispatchlreconfiguration

through operator instruction; (ii) remedial action plans; (iii) special protection schemes initiated

upon Generation Resource trips or unplanned Transmission Outages; (iv) committed demand

response or Generator alternatives; and (v) transmission expansions. In assessing applicability

for SSR status, the Transmission Provider will not require continued operation when the

continued operation of a portion or all of Generation Resources or SCUs would be contrary to

applicable law, regulations, or court or agency orders (such as a settlement with an

environmental agency or a consent decree approved by a court). In performing the Attachment

Y reliability analysis and any planning studies to assess feasible alternatives to an SSR

Agreement, the Transmission Provider shall collaborate with the affected Transmission Owners

and NERC-registered Transmission Planners, and if appropriate, may consult with a retained

consultant. The Transmission Provider will appropriately identify any Confidential Information

regarding a Retire or Suspend decision before the Transmission Provider transfers such

information to any entity. An entity that receives Confidential Information must agree in writing

to maintain such confidentiality, to comply with any confidentiality obligations owed to

Transmission Provider under the Tan ff or pursuant to a related non-disclosure agreement. and to

.5

comply with applicable Standards of Conduct found in 18 C.F.R. § 358. The Transmission

Provider will reasonably assist the owner or operator of a potential SSR Unit in working with

regulatory agencies to obtain environmental waivers or exemptions to the extent necessary to

maintain the reliability of the Transmission System. The Market Participant that owns or

operates the Generation Resource or SCU subject to review under this section shall provide the

Transmission Provider in a timely manner with all necessary data, including but not limited to,

engineering data required to enable the Transmission Provider to evaluate whether such

Generation Resource or SCU qualifies as an SSR Unit.

d. Execution of SSR Agreement. The Transmission Provider shall enter into an SSR

Agreement with the Market Participant owning or operating an SSR Unit in accordance with

Attachment Y-1. The Transmission Provider wilt file an SSR Agreement with the Commission

for approval if the Transmission Provider’s analysis determines that the Generation Resource or

SCU is required for reliability of the Transmission System. All potentially affected parties will

receive notification of such Commission filing. During the period that a Generation Resource or

SCU is subject to an executed Attachment Y-1 agreement, it shall qualify as an SSR Unit. SSR

service is a contracted service between the Market Participant that owns or operates an SSR Unit

and the Transmission Provider and shall be for a term of twelve (12) months, unless the

Transmission Provider requires a different term. The Transmission Provider must have available

the entire capacity specified in the SSR Agreement of each SSR Unit.

e. Operation of SSR Unit. Once the Transmission Provider has entered into an SSR

Agreement with a Generation Resource or SCU, the Transmission Provider shall have the right

to dispatch the SSR Unit at any time for reliability of the facilities within the Transmission

Provider Region. The Transmission Provider shall make every attempt to minimize the use of an

.6

SSR Unit. The Transmission Provider will dispatch the SSR Unit as early as possible once

conditions are identified that require the use of the SSR Unit and will make best efforts to

minimize the uneconomic dispatch of the SSR Unit(s). The SSR Agreement found in

Attachment Y to this Tariff shall provide for equitable compensation to an SSR Unit when it is

dispatched by the Transmission Provider.

f. Scheduling Rules for SSR Units. No later than 1000 hours EST the day prior to the

Operating Day, the Transmission Provider shall notify Market Participants with SSR Units as to

the quantity (in MW andlor MVAR) and time period of Energy, Operating Reserve and/or Other

Ancillary Services required from each SSR Unit.

g. SSR Unit Participation in Markets. A Market Participant may offer Energy or

Ancillary Services from SSR Units into the Day-Ahead Energy and Operating Reserve Market,

RAC, or Real-Time Energy and Operating Reserve Market during times when the Transmission

Provider has not requested the Market Participant to run the SSR Unit at full capacity unless this

would impair the ability of the SSR Unit to provide the Energy, Operating Reserve or Other

Ancillary Services when requested by the Transmission Provider.

Market Participants that own or operate an SSR Unit shall not use the SSR Unit to: (i)

participate in Interchange Schedules; (ii) except for plant auxiliary Load obligations under

the SSR Agreement, use the SSR Unit as a Self-Scheduled Resource to submit Self-

Schedules for Energy and/or Operating Reserve; (iii) submit Self-Schedules for Other

Ancillary Services, if applicable, to the extent that Other Ancillary Services are required by

the Transmission Provider under this Section; and (iv) participate in the Energy and

Operating Reserve Markets, except for incremental Offers of additional Capacity beyond

the amount designated by the Transmission Provider as necessary for reliability purposes

.7

to the extent allowed in the SSR Agreement.

h. SSR Unit Compensation.

i. The Transmission Provider will propose appropriate compensation for the

Market Participant owning the Generation Resources or SCUs deemed to be SSR Units.

Prior to the execution of the SSR Agreement, the Transmission Provider will negotiate with

the Market Participant to determine the level of compensation due the Market Participant

for the SSR Unit. The Market Participant will receive appropriate compensation for any

fixed operations and maintenance expenses that could have been avoided throngh a Retire

or Suspend decision for the entire period of time that an SSR Agreement is in effect for a

portion or all of the Generation Resource or SCU that is required for reliability of the

Transmission System as an SSR Unit. Compensation for an SSR Unit shall commence on

the date that the Generation Resource or SCU commences operation as an SSR Unit.

ii. The SSR Agreement will provide compensation only for going forward costs.

The Transmission Provider will evaluate, at a minimum, the following factors in

negotiating compensation for an SSR Unit: (a) fixed and variable operating and

maintenance costs to existing equipment; (b) applicable state, federal, local or property

taxes; and (c) non-capital costs of any environmental waivers, allowances, and/or

exemptions that are obtained by the SSR Unit and not otherwise recoverable by the SSR

Unit owner or operator. Any compensation to the SSR Unit will be reduced by payments

under Schedule 2 of this Tariff, payments under resource adequacy programs, infra

marginal rents from Energy and Operating Reserve Market transactions, and any other

compensation paid under the market or via other contractual arrangements.

.8

i. Termination of Interconnection Rights. Except as provided in Attachment X or any

applicable agreement for the interconnection of the Generation Resource or SCU, the

Transmission Provider shall tile with the Commission to terminate the interconnection

rights to the Transmission Provider’s system held by an owner or operator of a Generation

Resource or SCU that certifies by submitting an Attachment Y that it plans to Retire a

Generation Resource or SCU upon the latter of: (1) the current termination date specified

in an SSR Agreement, even if the Transmission Provider gives prior notice of an earlier

termination of an SSR Agreement; or (2) the Retire date certified by a Market Participant

in Attachment Y. The owner or operator of such resource may retain its interconnection

rights and continue to operate after the conclusion of an SSR Agreement or the Retire date

certified in the Attachment Y if: (1) substantial changes to applicable law, regulations, or

court or agency orders pursuant to which the owner or operator of the Generation

Resource or SCU originally relied upon in submitting the Attachment Y, occur either

during the term of the SSR Agreement or during the time between the submission of an

Attachment Y and the specified Retire date that significantly affect the economic operation

of the resource; or (2) the owner or operator of an SSR Unit planning to Retire a facility

simultaneously submits with Attachment Y a request for interconnection pursuant to

Attachment X of another facility or an increase in capacity of an existing facility at the

identical point of interconnection, with a Commercial Operation Date within thirty-six (36)

months of the Retire date of the existing Generation Resource or SCU, in which case the

interconnection rights may be transferred to the new facility upon successful completion of

the applicable interconnection procedures under Attachment X. If the owner of an

Generation Resource or SCU that submitted an Attachment Y to Retire falls to terminate

.9

operation of such facility and the Transmission Provider has approved construction of

Transmission System upgrades that were necessitated by such facility’s Retire plans (and

such upgrades were approved by the Transmission Provider’s Board of Directors as

Appendix A projects), then the owner of the Generation Resource or SCU that planned to

Retire shall be allocated the costs of such Transmission System upgrades necessitated by

the planned unavailability of the facility.

j. Allocation of SSR Unit Costs. The costs pursuant to the SSR Agreement shall be

allocated to LSE(s) which require(s) the operation of the SSR Unit for reliability purposes, and

shall be specified in the SSR Agreement. For the purposes of this Section, any SSR Unit costs

allocated to the footprint of the American Transmission Company shall be allocated to all Market

Participants within the footprint of the American Transmission Company on apro rata basis.

k. Annual Review of SSR Unit Status. On at least an annual basis, the Transmission

Provider will review Generation Resource or SCU characteristics to determine whether the

Generation Resource or SCU is qualified to remain as an SSR Unit in coordination with a review

of the Transmission Provider’s annual regional transmission expansion plan in accordance with

Attachment FF. If an SSR Unit continues to be required for reliability of the Transmission

System, then the Transmission Provider will have the unilateral right to enter into a subsequent

SSR Agreement by providing the Market Participant at least ninety (90) days advance notice

prior to the termination date of the existing SSR Agreement and by negotiating and filing a new

SSR Agreement at the Commission. If not, the SSR Agreement will expire by its own terms and

the Generation Resource or SCU will lose its SSR Unit status and will either Retire or resume

suspension in accordance with the Attachment Y request.

I. Time Limitations on Suspension. A Market Participant owning or operating a

.10

Generation Resource or a SCU may request suspension pursuant to the provisions of this Section

38.7.2 for a maximum of 36 cumulative months during any five (5) year period. A Market

Participant owning or operating a Generation Resource or a SCU that had been granted a

suspension pursuant to an Attachment Y request for less than thirty-six (36) cumulative months,

or that has been operating under an SSR Agreement for less than thirty-six (36) cumulative

months, may request an extension to such time limits by submitting a new Attachment Y request

twenty-six (26) weeks prior to the end of the originally granted period or the termination date

specified in the SSR Agreement, provided that the combined period of the originally granted

period, or the period of operation under an SSR Agreement, and the extension is not greater than

thirty-six (36) months.

m. Non-Binding Informational Studies. A Market Participant owning or operating a

Generation Resource or a SCU may complete Attachment Y-2 to request that the Transmission

Provider conduct a study to determine whether it is likely that a portion or all of such Generation

Resource of SCU would qualify as an SSR Unit. The Transmission Provider will collaborate

with the affected Transmission Owners and NERC-registered Transmission Planners, and if

appropriate, will consult with a retained consultant to evaluate whether the facility is required for

the reliability of the Transmission System. The Transmission Provider will appropriately

identify any Confidential Information regarding a Retire or Suspend decision that the

Transmission Provider transfers to any entity. An entity that receives Confidential Information

must agree in writing to maintain such confidentiality, or to any confidentiality obligations owed

to Transmission Provider under the Tariff or related non-disclosure agreement, and to comply

with applicable Standards of Conduct found in 18 C.f.R. § 358. The Market Participant will not

be bound to the change of status indicated in an Attachment Y-2 request. Along with a

.II

completed Attachment Y-2, such Market Participant shall submit a study deposit of $70,000 to

the Transmission Provider for the reasonable costs and expenses of such study. The

Transmission Provider shall invoice such Market Participant for all costs and expenses incurred

in addition to the deposit amount, or shall refund any unused portion of such deposit upon

completion of the study. The Transmission Provider shall use reasonable efforts to submit the

results of such study to the Market Participant upon its completion within 75 days of receipt of

the deposit and completed Attachment Y-2, unless an alternative period is mutually agreed to.

The Transmission Provider shall treat Attachment Y-2 as Confidential Information until the

Attachment Y-2 reliability analysis is completed and the study results are disclosed to the Market

Participant. The Transmission Provider shall notify the Market Participant prior to publicizing

the Attachment Y-2 study results that the Attachment Y-2 study is completed, however the

Transmission Provider shall not provide any information related to the study or study results to

the Market Participant at that time. The Market Participant may rescind its Attachment Y-2

submission by notifying the Transmission Provider of such rescission via electronic

communication and certified mail not more than five (5) business days after receiving notice

from the Transmission Provider that the Attachment Y-2 study is complete, in which case the

confidentiality of the request for an Attachment Y-2 study shall be preserved. If a Market

Participant rescinds an Attachment Y-2 study request, then such Market Participant shall not

receive the results of the study and the Market Participant shall pay the Transmission Provider

100% of the total costs incurred in conducting the study up until the date of such rescission.

Once a response is provided by the Transmission Provider to a Market Participant, the

Transmission Provider shall promptly post on OASiS the fact that an Attachment Y-2 request

was made and the determination by the Transmission Provider k’hether the Generation Resource

.12

or SCU was required for the reliability of the Transmission System. The results of such study

will provide the Market Participant with the outcome if the Market Participant elects to submit

an Attachment Y to request SSR status in the future and does so in accordance with Section

38.2.7(n).

The Transmission Provider shall maintain regional power flow models on its public website,

pursuant to Section l.A of Attachment Ff, for use by a Market Participant owning a Generation

Resource or a SCU choosing to conduct a study.

n. Submission of Attachment V Following Non-Binding Reliability Studies Under Y-2.

An Attachment Y that is submitted by a Market Participant within 30 business days after receipt

of a response from the Transmission Provider for the same Generation Resource or SCU

pursuant to an Attachment Y-2 study, may request a change of status of the Generation Resource

or SCU commencing on a date 26 weeks from the date of receipt by the Transmission Provider

of the related Attachment Y-2 study request. To the extent practicable, the Transmission

Provider will use Y-2 study results in preparing the Attachment Y analysis.

.13




dated July 2, 2013

July 11, 2013

1 Item 2) Refer to page 5 tines 9-11 of Mr. Berry’s Rebuttal Testintony lit Case No.

2 2012-00535 wherein he states that Big Rivers converted its Attachment Y-2 into an

3 Attachment Y seeking permission to idle the Coleman Station.

4 a. Please provide a copy of tite company’s Attachment Y-2.

5 b. Please indicate when the company expects to obtain a decision oit the

6 Attachment Y-2 request.

7

8 Response)

9 a. Please see a redacted version of the Attachment Y-2 report for the

10 Coleman Plant, attached to this response. Please note that the confidential

11 critical infrastructure information in this document has been redacted, and

12 that the remaining contents of the document are not confidential.

13 b. Big Rivers expects MI$O to provide the Base Load amount within the

14 next two weeks.

15

16


18



Attachment Y-2 StudyColeman Units 1, 2 & 3: 443 MW Coal29 Month Suspension $/20/2013 — 1/1/2015

• ATTACHMENT Y-2STUDY REPORT

May 2, 2013

.CONTAINS CONFIDENTIAL AND

CRITICAL ENERGY INFASTRUCTUE INFORMATION (CEll)

DO NOT RELEASE

. CONFIDENTIAL

This document contains confidential information and should only be shared with direct recipients on a need to know basis. All contents ofthe following document are confidential and proprietary to MISO. Information cannot be shared with outsiders without explicitauthorization.

EXECUTIVE SUMMARY

MISO received an Attachment Y-2 Request for Non-Binding Study Regarding Potential SSRStatus (Attachment Y-2 Request) from Big Rivers Electric Corporation (BRPS) on December 18,2012. The request was for MISO to determine the reliability impact of the potential Suspensionof Coleman Units 1 & 2 & 3 from August 20, 2013 to January 1, 2015. Attachment Y-2 analysisis performed as a non-binding assessment of potential reliability issues due to the Suspension orRetirement of a Generation Resource. The results of the study are not definitive and the analysisis intended only to provide information to the Market Participant (MP) to assist them inevaluating their options. However, it does not commit the Market Participant to proceed withplans for Suspension or Retirement.

The study results indicate that potential reliability issues exist that would require the need forColeman Units 1, 2 and 3 to enter into an System Support Resource (SSR) Agreement if amitigation plan is not developed and implemented prior to the potential unit change of status, inaccordance with Section 3 8.2.7 of the MISO Open Access Transmission, Energy & OperatingReserve Markets Tariff (“Tariff’). In addition to determining if reliability issues result from thesuspension, further analysis was performed to identify the areas that are subject to allocation ofthe SSR costs. The areas identified for the cost allocation are Big Rivers Electric Corporation(BREC), Southern Illinois Gas & Electric (SIGE), Ameren Illinois (AMIL), and Duke EnergyIndiana (DEl).

2

ContentsI. Introduction 4II. Study objectives 5III. Models and Assumptions 5

a. Model Assumptions 5b. Transmission Projects 5c. Table of Models 6

IV. Study Criteria and Methodology 6a. Applicable Reliability Planning Criteria 6b. MISO Transmission Planning BPM - SSR Criteria 8c. Contingencies 9

V. Study Results 9a. Branch Results (Appendix A Table 1 a) 9b. Voltage Results (Appendix A Table ib) 9

VI. Potential SSR Agreement Cost Allocation 10VII. Conclusion 10VIII. Appendices 11

.2

I. INTRODUCTION

.

Big Rivers Electric Corporation, submitted an Attachment Y-2 “Request for Non-Binding StudyRegarding Potential SSR Status”. Unlike the Attachment Y, an Attachment Y-2 Request is foran informational study to evaluate the potential for a unit to be designated as an SSR and doesnot commit the Market Participant to proceed with plans to Retire or Suspend. This study of theColeman Generation Units 1, 2 and 3 determined the reliability impacts that would occur if theseunits were to be removed from service on August 20, 2013 and return to service on January 1,2015. With Coleman generation unavailable during this period of time, the study will alsoaddress the reliability impacts of two scenarios: 1) Century Aluminum ceases operation onAugust 19, 2013 and 2) Century Aluminum continues normal operations.

Location: Hawesville, KentuckyNumber and type of generating units: (3) coal fired, steam turbine unitsPlant and unit numbers: Coleman Unit #1(150 MW), Unit #2 (138 MW), and Unit #3 (155MW)

Figure 1: General Location of the Coleman Plant in Northern Kentucky

4

II. STUDY OBJECTIVES

Under Section 3 8.2.7 of MTSO’s Tariff, SSR procedures maintain system reliability by providinga mechanism for MISO to enter into agreements with Market Participants that own or operateGeneration Resources or Synchronous Condenser Units (SCUs) that have requested to eitherRetire or Suspend, but are required to maintain system reliability.

The principal objective of an Attachment Y-2 study is to determine if the units for which achange in status is requested are necessary for system reliability based on the criteria set forth inthe MJSO Business Practices Manuals. The study work included monitoring and identifying thesteady state thermal/voltage violations on transmission facilities due to the unavailability of theGeneration Resource. The relevant MISO Transmission Owner andlor regional reliabilitycriteria were used for monitoring such violations.

III. MODELS AND ASSUMPTIONS

Corresponding to the anticipated suspension of the Coleman Units 1, 2, & 3 the following powersystem analysis source models were used for the study:

• 2014 SummerPeak• 2017 SummerPeak• 2017 Shoulder

The Attachment Y study models were created following the MISO Transmission PlanningBusiness Practice Manual (BPM-020-r$) Section 6.2.2. This includes creating a set of modelsfrom each source model in which the units being studied are at full generation or taken out ofservice.

a. Model Assumptions

1. Load Sensitivity to Century Aluminum Plant (485 MW)

b. Transmission Projects

1. LGEE / KU Matanzas 161 kV Substation The new Matanzas 161 kV Substation has ananticipated in-service date of December 1, 2012. This new substation will be included in the2014 and 2017 models since the substation will be in-service during the time ColemanGeneration is unavailable.

.5

c. Table of Models

n Model Coleman 1,2,3 Century Aluminum Contingency Categories1 2014SP off off B, Cl, C2, CS2 20145P off on B, Cl, C2, CS3 20145P on off B, Cl, C2, C54 20l45P on on B, Cl, C2, C55 2017SH off off B, Cl, C2, C3, C56 2017SH off on B, Cl, C2, C3, C57 20175H on off B, Cl, C2, C3, C58 2017SH on on B, Cl, C2, C3, C59 20175P off off B, Cl, C2, C5

10 20175P off on B, Cl, C2, C511 20175 P on off B, Cl, C2, C512 20175P on on B, Cl, C2, CS

IV. STUDY CRITERIA AND METHODOLOGY

Siemens PTI’s Power System Simulator for Engineering (PSS/E) and Managing and UtilizingSystem Transmission (MUST) were used to perform AC contingency analysis. Contingencyanalysis is the study of transmission system facility outages. Outages of transmission facilitiesare applied to a mathematical model of the transmission system in order to calculate the effectson the remainder of the system. The models were solved with automatic control of Load TapChangers (LTCs), phase shifters, DC taps, switched shunts enabled (regulating), and areainterchange disabled. The results are compared to determine if there were any criteria violationsdue to the change in the status for the unit(s).

a. Applicable Reliability Planning Criteria

MISO Transmission Owners

AMIL Transmission Planning Criteria applied for the thermal analysis:• For Category A contingencies, all thermal loadings exceeding 100% of the normal rating for

AMIL System• For Category B and C contingencies, all thermal loadings exceeding 100% of the emergency

rating for AMIL System

AMIL Transmission Planning Criteria applied for the voltage analysis:• For Category A contingencies, all substation voltages less than 95% or above I 05%• F or Category B and C contingencies, all substation voltages less than 9O% or above II 0%

.6

BREC Transmission Planning Criteria applied for the thermal analysis:• For Category A contingencies, all thermal loadings exceeding 100% of the normal rating for

BREC System• For Category B and C contingencies, all thermal loadings exceeding 1 00% of the emergency

rating for BREC System

BREC Transmission Planning Criteria applied for the voltage analysis:• For Category A contingencies, all substation voltages less than 95% or above 105%• For Category B and C contingencies, all substation voltages less than 90% or above 110%

DEl Transmission Planning Criteria applied for the thermal analysis:• For Category A contingencies, all thermal loadings exceeding 100% of the normal rating for DEl

System• For Category B and C contingencies, all thermal loadings exceeding 100% of the emergency

rating for BREC System

DEl Transmission Planning Criteria applied for the voltage analysis:• For Category A contingencies, >100 kV substation voltages less than 95% or above 105%• For Category B and C contingencies, >100 kV substation voltages less than 90% or above 105%

HE Transmission Planning Criteria applied for the thermal analysis:• For Category A contingencies, all thermal loadings exceeding 100% of the normal rating for RE

System• For Category B and C contingencies, all thermal loadings exceeding 100% of the emergency

rating for HE System

HE Transmission Planning Criteria applied for the voltage analysis:• For Category A contingencies, >100 kV substation voltages less than 95% or above 105%• For Category B and C contingencies, >100 kV substation voltages less than 90% or above 110%

SIGE Transmission Planning Criteria applied for the thermal analysis:• For Category A contingencies, all thermal loadings exceeding 100% of the normal rating for

SIGE System• For Category B and C contingencies, alt thermal loadings exceeding 100% of the emergency

rating for SIGE System

SIGE Transmission Planning Criteria applied for the voltage analysis:• For Category A contingencies, >100kV substation voltages less than 95% or above 105%• For Category 3 and C contingencies, >100 kV substation voltages less than 95% or above 105%

SIPC Transmission Planning Criteria applied for the thermal analysis:• For Category A contingencies. all thermal loadings exceeding 1 00% of t]ie normal rating for

SIGE System• • for Category B and C contingencies, all thermal loadings exceeding 100% of the emergency

rating for SIGE System

.7

SIPC Transmission Planning Criteria applied for the voltage analysis:• for Category A contingencies, >100 kV substation voltages less than 91% or above 105%• for Category B and C contingencies, >100 kV substation voltages less than 91% or above 105%

Non—MISO Transmission Owners

LGEE Transmission Planning Criteria applied for the thermal analysis:• For Category A contingencies, all thermal loadings exceeding 100% of the normal rating for

LGEE System• for Category B and C contingencies, all thermal loadings exceeding 100% of the emergency

rating for LGEE System

LGEE Transmission Planning Criteria applied for the voltage analysis:• for Category A contingencies, >100 kV substation voltages less than 95% or above 105%• for Category B and C contingencies, >100 kV substation voltages less than 90% or above 110%

TVA Transmission Planning Criteria applied for the thermal analysis:• For Category A contingencies, all thermal loadings exceeding 100% of the normal rating for

TVA System• For Category B and C contingencies, all thermal loadings exceeding 100% of the emergency

rating for TVA System

TVA Transmission Planning Criteria applied for the voltage analysis:• For Category A contingencies, >100 kV substation voltages less than 95% or above 105%• For Category B and C contingencies, >1 00 kV substation voltages less than 90% or above 110%

AECI Transmission Planning Criteria applied for the thermal analysis:• For Category A contingencies, all thermal loadings exceeding 100% of the normal rating for

AECI System• For Category B and C contingencies, all thermal loadings exceeding 100% of the emergency

rating for AECI System

AECI Transmission Planning Criteria applied for the voltage analysis:• for Category A contingencies, >100 kV substation voltages less than 95% or above 105%• for Category B and C contingencies, >100 kV substation voltages less than 90% or above 110%

Under category C contingencies, for the valid thermal and voltage violations as specified above,generation re-dispatch, system reconfiguration, and/or load shedding will be considered if applicable.

b. MISO Transmission Planning 3PM - SSR Criteria

As specified in MISO BPM-020-r8, the SSR criteria for determining if an identified facility isimpacted by the generator change of status will be:

• Under system intact and contingent events, branch thermal violations are only valid if theflow increase on the element in the “after” retirement scenario is equal to or greater than:

8

a) 5% of the “to-be-retired” unit(s) MW amount (i.e. 5% Power Transfer DistributionFactor (PTDf)) for a “base” violation compared with the “before” retirementscenario, orb) 3% of the “to-be-retired” unit(s) amount (i.e. 3% Outage Transfer DistributionFactor (OTDF)) for a “contingency” violation compared with the “before” retirementscenario.

• Under system intact and contingent events, high and low voltage violations are only validif the change in voltage is greater than 1% as compared to the “before” retirement voltagecalculation.

c. Contingencies

A subset of the MISO Transmission Expansion Plan (MTEP) contingencies in the central regionwas used for AC contingency analysis. Additional contingencies from TVA, LG&E, and AECIwere included in this analysis to provide coverage for events on those adjacent transmissionsystems.

The following North American Electric Reliability Corporation (NERC) Categories ofcontingencies were evaluated:

1. Category A when the system is under normal conditions.2. Category B contingencies resulting in the loss of a single element.3. Category C contingencies resulting in the loss of two or more (multiple) elements.4. Maintenance outage condition with forced outage during shoulder load conditions.

V. STUDY RESULTS

a. Branch Results (Appendix A Table Ia)

Table 1 a in Appendix A shows contingent conditions causing branch criteria violations withoutColeman Units I & 2 & 3 and the improvements resulting from the operation of Coleman UnitsI & 2 & 3. Contingent events causing branch violations include NERC Categories B, Cl, C2,and C3. While the study scenario with Century Aluminum off does indicate fewer constraints,there remain a few thermal loading issues resulting from Category C contingencies that exist inthe MISO Transmission system even with the load removed.

b. Voltage Results (Appendix A Table Yb)

Significant voltage criteria violations associated with the suspension of Coleman Units 1, 2, & 3and continued operation of Century Aluminum were identified when compared to the continuedavailability of the units. Table I in Appendix A shows contingent conditions causing criteriaviolations without Coleman Units 1, 2, & 3 and the improvements resulting from the operation ofColeman Units 1, 2, & 3. Contingent events causing voltage criteria violations include NERCCategories B, Cl, C2, and C3. The acceptable post-contingency voltage range is between 0.92per unit to 1 .07 per unit. Therefore, voltages less than 0.92 or greater than 1 .07 per unit are a

10

criteria violation. If Century Aluminum were to cease operations, with a load of 0 MVA, thevoltage issues within the MISO would be eliminated.

VI. POTENTIAL SSR AGREEMENT COST ALLOCATION

MISO utilizes a load shed methodology to determine the reliability benefits to each MISO LocalBalancing Area (LBA) of operation, without the SSR unit(s). Although load shed is notpermitted for NERC Category A or B events, this methodology determines the load shed amountneeded to relieve all Category B reliability issues and the most severe Category C reliabilityissues identified, as a proxy for the reliability benefit of the SSR unit operation. The potentialSSR Agreement LBA shares that were calculated for this Attachment Y-2 study are includedbelow in Table 2.

Table 2: Potential SSR Agreement LBA Shares

LBA Load Shed (MW) LBA ShareBREC 1541.84 91.63%SIGE 76.11 4.52%

AMIL 63.02 3.75%DEl 1.72 .10%Total 1682.69 100.00%

VII. CONCLUSION

The study results indicate that potential reliability issues exist which would require the need forColeman Units 1, 2 and 3 to enter into an SSR Agreement if a mitigation plan is not developedand implemented prior to the potential unit change of status, in accordance with Section 38.2.7 ofthe MISO Open Access Transmission, Energy & Operating Reserve Markets Tariff (“Tariff’). Inaddition to determining if reliability issues result from the suspension, further analysis wasperformed to identify the areas that are subject to allocation of the SSR costs. The areasidentified for the cost allocation are Big Rivers Electric Corporation (BREC), Southern IllinoisGas & Electric (SIGE), Ameren Illinois (AMIL), and Duke Energy Indiana (DEl).

.ii

VIII. APPENDICES

Appendix A: Steady-State AC Contingency Results

Table I a: Branch Results

Table 1 b: Voltage Results

12

Table 1 Results . .MISO Coleman Units 1, 2, & 3 Attachment Y-2 Study - Compare Branch ResultsCONFIDENTIAL I CEll - DO NOT RELEASE

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— 2698470010545W 690991#A4THORNTWN 1391 TR 639 841] 472 /394 ON/A UN/A #8/A — #6/A #6/A 1Vn/elo onsedbysu pano.cn26175P [AEDACTE CONTINGENCY] 24843507AW/VL1 16/25356610NTVL16 161 / 335 3428/ 248.6 /003 #6/A #04/A / ON/A #3/A brntdi000ausedby500perauau[REDACTED CONTINGENCY] .24843507NWTVL1 161 34O5S2SCOLEMAN 161 1 IN I 335 342.6[ 24#7 1023. UN/A #6/A #6/A #6/A /A JV6/alionceused bysusponmon20/701’ [REDACTED CONTINGENCY] 246435 076 1TVLI 161 25356/ 10NTVLI6 161 / LN I 335 354 5 2406 1008 ON/A ON/A #N/A ON/A #8/A 3/el Son eusod by sp on201751’ [OEDACTED CONTINGENCY] 248435 O7NWWL1 16/ 340552 SCOtSMAN 161 1 LN 335 354.51 24871 /008 UN/A ON/A I ON/A UN/A #6/A Vnbbooceusnd by ousponsnm2017SF .[REGACTEOCONTINGENCY[ 2404350/NWOIL1 16/ 253536 lONG//I/O /611 IN 497.5/ 2406: /40.5 UN/A , 66/6181//A #6//A #6/A oY]e4 bynuspencon.201751’ [REDACTED CONTINGENCY] 24843507NWP1L1 161 34N552SCOLEMAN 16/ 1 1.1 2400 1406. ON/A, 9.6415

..

UN/A V68abonssed bysuspensnm2N175P (6EOA TED CON/ NGENCY] 24 64207MG 45 600243/5/ STIecY 69 6901 IN 35 356 245/ 1023 UN/A #6/A #6/A 60/A ON/A Yol I nd by seep on2017SP .[REDACTED CONTINGENCY] 246435 07NWWL/ 166253539 1051V1/6 161 1 LN 335 457.6f 245.61 14#5. #6/A ON/Al AN/A ON/A #6/A VS/Hon caused by suspenson201701’ [REDACTED CONTINGENCY] 248435 0767/TOLl 161340552 5COCEMAN /61/ IN r 497712407 1486 UN/A #6/A UN/A FiN/A ON/A Viol ton on ed by ou p on2017SF [REDACTED CONTINGENCY] 240642 07A’OWAY 69 0243/61 N7TRY_69 690 / IN 35 356 243] /NZ3 UN/A AN/A #6/0 66/h #6/A V/clabuncaucndby 505peosse20175P IREDACTES CONTINGENCY] 24#435N7N/VP/U 16125353/106101/6 161 1 IN 335 497.6 2486 1485 ON/A IIA.l N/5_ ..Y01e50 bysuepnosse20/751’ [REDACTEOCON/INCENCY] 24543 67911011 161 408 25101//MAN 6/I IN 335 4977 2467 405 Uk/A #3/A J ON/A T U//A — — N/A VS/n. cea,n by,spe non201701’ [REDACTEOCONTINGENCY) 24864207600/NAY 690246551 DETRY_69 !0 1 IN 35 356 249 /02.3, UN/A IA UN/A ON/A #6/AU iVnioloncaooedbycuspnnson201761’ [AEOACT//DCON/INCENCY] 253510/05513 1302535/1 15N 72 1390, #5/A ON/A ON/A ON/A

. .

201701’ [REDACTEDCONTINGENCY] .240435N7NWTVII 15/25353/ /0690116 181 1 IN : 336 4976 2406 1485. UN/A #6/A UN/A - #6/A ON/A [V/ola/tonceused hysonpenson20176P [5 5511 3 COST NGENC\] 24 4350/5 11011 161343952 SCOIEUAN 161 1 15 335 4977 2467 1466 UN/A 02/8 #6/A US/A #6/A /,Inl In aued by aaopocson2T176P [REDAC060 CONTINGENCY] 248642 07610/NAY 690246061 O7TRY_69 690 / IN [ 249 /023 ON/A #3/A I 811/A 06/A #0/A VnI50onceasndbyauspnoson28/75P [RE06CTEG CONT/SGENCS] 208007090007105 590 20080US7MAV6PT 630 1 IN 25: 27.5] 2051 /009 ON/A ON/A UN/A/

ON/A VedHonceusod bysuspnnson20/ISP NSDACTE0 CONTI/.GEECS9 248807 O7DOG5%OD 6902466/0 O7MAUKPT 6901 IN 25 275/ 265 1600 UN/A #6/A UN/A ON/A — ON/A V laIn ed by speacs en20175P [REDACTED CON/INGENCY] 24#435N7NWTVI1 16125353/ /0610116 1611 .10 335. 3546 2486 1056 UN/A UN/A ON/A UN/A UN/A VnIe000 oaused by oospeoson201761’ tREDACTED CONTINGENCY] 246435 0797/TOLl /AI34/NS2SCOLEMAN 46/1 2d#7 4056 USIA #5/A ON/A 01//A #0/A Vn/Anne sedbycuspeoscn.20/TOP [REDACT//S CONTINGENCY] 240035 07671741/ /61 253539 INNWu6 161 / .LN l- 248.6 /48.5. UN/A , UN/A I #5/A ON/A #6/A VS/a/on caused buepenoon20/761’ [RED#CTED CONTINGEN 0) 240435 O7NNflVLl /61 304552 5COIEMAN 181 1 CN 335 4977 2407 1406 #3/A UN/A OS/A 0666 06/A V I on auond by 504 n500

1 of 6

Table 1

asResults . .

MISO Coleman Unite 1, 2, & 3 Attachment Y-2 Study - Compare Branch ResultaCONFIDENTIAL I CEll - DO NOT RELEASE

I LbnIbn5 Btmct c&,mas 1, 2. 5 3 OFF jcottm.n IA S 3 ON CnN IspadI I Base Laadin ILa B!Wae PTOF OTOFMadel Ooodngency OncdFdon J.. F,m Wit To boo ‘ cr typo a cootMvA Flow % jcoe4 WJAjflow IMoo I’ 5%t fr3%t taco Laments?917S_ [REOACTEDCOtfl1NGENCY] —--.—-+248t42O7MIDWAY69D2488t!O7TRYfit6aDt LN j5 358L.9iiN_ l_M tN/A tsonncainndbysusponsen2017SP IREDACTED CDNTILGENC’t9 3L2ttS2WATAUGA HPt9 0 362167 2ELIZAtETHTr 69 0 I LN J stIii 61 4 107 3 #N/A aNts uN/A #eie #NIA Vnlatn sad by poftono2al7SPCootot IREDACTED CONTINGENC1 • 24PW7O7DOGWOD 6902t8&bC7MhUKPT pa 0 1 26.21 27.2 112 8 ybtA . NyPA j by/A #NIA ‘ yPPA VinJon omisod by snopoeslno2OITSPC p fREDACTED CQNTINGENCP9 24yya7 O7000WOD by p 24bLa O7MAUKPT Lb U 1 LN 25 2b 2 27 2 1 12 t bVA #NIA #N/A tIN/A #WA Vol t misod by s.iopooni2Ol7SPContsff :IRETATTPO CONTINGENCT1 . . ?J? 2LOVRLTh bb.b3b24% 2WAURDADTNP9 01 .LN 5Z2 1.2 lce.5 #N/A HNIA ; #N/A PHIL #N/A :voat.on mood by onoponoon2D17SPC t P IPEDACTED CONTINGENC1 . 3b2124 2LOVELLTN tS 0 3t24yb 2WATTROAD TNbb 0 1 LN St 4 SD 0 ti 2 102 t btN!A SNIA SN/A #5/A SN/A Vo!yt p no od by no p no2DI7SPC I if ISESACTD CONTINGENCS] 352124 2LOVELLTN Ga 0 362495 2WAflROSD TNSS S t LN St 4 622 61 2’ 155 5 #515 ifN/A I USIA PS/A ifbEA Vm rn caunod by so pa no2St7S[ .lE0PTEpCO5TiNTEN.cy1 4SCHRSMCYW Isyt iN .:9 2 219.4 :° . . 9 3D24if3CTV&aboma eooroobyotmpo n sionTotysy

34SpoT7SAMSEY 34534506if 4RSMSSYCIPS fly 1 Tif 3m 3ifSPl a4.9 lot B: 371 0! SS.t. 97 1 ITS 4S432tVeIoinoncnonodby suspooscno2017SH _ IPPDACTEDCDNTINGENCYI 345O5T7SSMS5Y 345T4SSSif4RSMSEYCIPSt3SL Tej b2 Tifif3 t45 101 7 3b ySt ayo vt 4jVolatesodbysoopyooooToiPsif IPEDACTEDCONTINGENCYI .245435O7NVFNLt iyi 2535if0 IONWL1S 161 I IN l 335 434i 133.5; 12y6 PPPA PNIA JyNyA . #NIA ifNiA VoJobopoanondbysuopooono2ylysy .,IPEOACI PD coNTINDENcI 248435o7NwtvLy lift 34SS52SCOLEMAN 1 L ‘ 335 y3y 4 t33b 125 7 aNte #sis ypee Pb’S ye/S ....201TS5 IPLDACTPO CONTINGSNCl 24if542 DTMIDCSY La 0 24tif51 tyPifY ty Pa pi LN 35 37 I 24 if lOP 0 #NbA yPSA #NbA NIA #5/S lVd4eo ajsod byonop osino2ot7sy IPEOACTEOCONTINGENC1 a24pyy2yipDsTe bao32y7by2wALKpKu 690 I its 2W 2if.D tt if 153 5 iftstA PNIA #5/A I PN/A : yy lvoutbp onnoyd np onspono.no201P5H IREDACTED coNTtNDENcY 324P2t2MSRI S PS 0 324y2y2MyR05Ku Pif.O I TN 2ifi 2t 4 tS6 lois. ifNIA aN/A #NIA tN/S . PN/A Voto&noausnd bysuopoosenIPLOACTED CONTINGPNCS9 2LOSLLLTN t503P2456 2WAUPOAD TNPY 0 1 TN 54 61.Pj 62.7; Wif 5: #NIA PPM ifN/A yNby _ ifNIA jviolntoouuusod by suspension201709 )NEOACTEO CONTINGENCY) — 325677 bCOLEMAN TAP 101 325076 5P9D50W4 P91161 L.... — IN I — 245 2514 lift 21 1026 2360 — 1723) 043 — 104 3 47629NJTu64oa atuod by nospenoen‘204709 - )NEGACTEGCONTINGENCY) 3406166Ll0ING 161 32iN SMANOHAIIKY lift I ‘LN rn 230.1) 630, 104 B 214.2- 54.1) 961, 238 5.355033N)Viulaboncousodbysupeensen201709 )NESNCTEO CONTINGENCY) 34ON1N5LIVING 161 360326 ONANKLEY HP 181 I ‘1LN J23 26121 026 12612022 785) 1122 iàiiT7HIomn m 4 w me by so pa oGlSL1G C0NTINGINC 3.1.24?ii9Y1aT 1.9Y) 2WATTNOADTNN5 9 N 084 Y)-Y) 627 1056- 6614 NNiA I #NIA .6lI I13?33wn bysuspeonos201754 )NEGACTEO CONTINGENCY) 362124 2LOSELLTN 690362402 2WAUNOAD T660 Si LN 064 6171 62)1 1056- #916 6166 1 8 SIN # . 9405 VwIabonoauued by ouspoosen201764 IREONCTED CONTINGENCY) - 302124 2LO6ELTN 6933624% 2WATTNOAD TN60.0i ‘LN L5E& 63L 62.7 - 1606 #NM #616 #NIA201706 )NEGACTE0 CONTINGENCY) 3350T7 NCOLEMAN TAP lift 32547# OPyOuCy54 161111 LN j 240 2465 161 2 1016 2345 172 903 154 3476290 VolaIw wised by suop on‘201799 )NEGACTED CONTINGENCY) .340416 SLIVING lift 360416 SMANSHALL KY 161 1 )LN 223 232.51 630, 104.3 8 PtA 0616 6616 • #NIA 6 NIH Volasun unused by suspension201749 )N0GACTEG CONTINGENCY) 34O6165LMNG 161 364320 560NKLEY HP 161 I LN 223 27471 N2.6 123.2 2436: 785 1692$ 311 7520316)N&uldumedowurse bysuspaeoue‘20IT5H )NEGACTEO CONTINGENCY) 3621952W0T5005#P6903621N7 2EIIZASETHTNNN 01 .LN 50.4 606) 61.5’ 1026 0516 #NIA 6NJA 4610 6916 ‘6nJal,onsosod by suspension)2Ol756CenluH )NEGACTED CONTINGENCY) 348774 TSALGTyN 3453487762356KET9IL1340 I 06 I 960- 11770’ 6934, 1231 11615 692.21 121.5 15.5 34560713Vw56den,adnwurse bysuspenoun26l7SHCenIcO IIREENCTET CONTINGENCY) 305729 471 MT VERNW 1303460277W MT SEN I! 460 .11 3 244 13.6- 30490774 Vnleinn maduwurou bysuspenoso2OlTOHCentuO jREGACTEGCONT1NGENCY) 47O1B4EFFGHMNW l383470T44EFFI60HM 1391 LN TEN 2932’ 600 602 30133j 13) 30920004oiMKnrna4ew0rsebosuspenoon2T1TS6C I 0 )OEGACTEO CONTINGENCY) 347016 4EFFGNNIb11 36 347024 4EFFIEGHM 1381 LN 202 29351 606 1116 3707 602 106 4 136 — 31151242 V ii m dw on by a pa —

‘2Ol7SHCoeioO )REGACTEG CONTINGENCY) 347046 41066 134 340769 40CHRNMCY TP 1301 ,LN 1 202 2360) 395 1I69 2202 356) .1l0: 35665014Vwlu4uurnudew&sebysusponeino-2Ol7OHCenIu6 )NEGACTEG CONTINGENCY). 3487304MITW0YE 139 3407864TCHNHMCYTP 1301 IN [ 202 2603 735 1318 I fl:

70.21 1242- 153 34537246Volelonmauouurnoby oaspenwuu2Oi7SHCes)uH )%EGACTEG CONTINGENCY) 347946 41666 330346060 INAMSEYC1PS ITO I LN L 264 2644- 4 b 1026- 2b1.3 ¶39 902 ¶-3 .9:!!99! enoenTO1TSHCneIuH )NEGSCTEG CONTINGENCY) 3403677664006 345348066 4NAMTEYCIP2 1301 ‘TN 363 35Q9 055 1023 370.2 960’ 900 207 46726&2;Vwlalunoaunudbysuuyenono‘2Ol7SHCenIuif )N000CTEG CONTINGENCY) 347946 41050 136 346066 4NAMSET CIPS 3361 ‘INS 264 - 2603445’ 1029 2012 445) 9511 101 3.44u5RNIV.domuswusedbyoisp050no -

2T1TSHCnn1oO JNEGNCTEOCONT1NGENCY) ooot 76645EV 340340060 4NAMTEYCIP5 1361 362 3%4, 055! 1022 - 3606 900! 966 - 20.9- 45952596:Vedelueunusudbyuuspensino2Ol7THCenIuft -)NE0HCTEG CONTINGENCY)- 340774 7801TG’iN 3AS34NPN73ONNEY HILl 340 I IN 956 1604 N NT3 4 - - 1103 3999 692.2) 436 6’ - 106 3T600265VoiuI’uu madewurseby suspension -

7Ot7SHCneIu6 )NEGACTEGCONTINGENCY) 348776 70AIG1IIN 3IA3IOTTS46AWWIN 1301 - -TN 448 47T3j 2938- 1555 4583’ 387.1 1019 14.0 3 1bT27T9’VnIaI,unmadewurse bysuspenwue)2Sl7SHCeuIu# )NEGACTEG CONTINGENCY) -- 350204 IC6MPOEIIHII 139 350205 5CAMPOEIIHII 1611 ITO 224 3238 25 8 1445 - 2909’ 2291 132. 27.9 , 0 297568430u1e7on made worse by suspens:un2TI400CenIuO IREONCTEGCONTINGENCY) 302361 NRGONE 161 3024N33000NE 6951 ‘TN 112 260) 037’ 126 1116- 92.8) - 04) 144 - 3250564 3 Vw60enuuiued bysupeonuon120l756Ceu1sT )NEGACTEG CONTINGENCY) 324512 2EGTY P 690324653 2PRINCE N50I IN 64 67.8, 33.1 1360 4NI0 #100 I #6(0 - #NIA #6160 )violawe unused by suspensor2Tl7SHCnuIuO )NEGACTEGCONYINGENCY) - 3205122EOET P N9.D36291626YDAM 69.01 - IN - — TO’ 715’ - 356 102.1 #519 8616 1 #610 I #610 #610 !Vwlasunsaasndby suspension2Ol7SHCenIuH JNEGACTEGCONTINGENCY) - 365153 5PHI#p0 8 NP 161 3657565J565C34 TI 1613 — IN I 472.1492.1 3194 1042- 4787 - 3144) 1014’ 134 — 30240307Vedeliunmadewume bysuspeuwon2OlT0HCenIuO )NETACTED CONTINGENCY) - 362124210VE11TN - 6903624%2WAHRGADTN6TOI LN ) 58.4 - 61.6 627, -. 1055 9910 6NIA j #NIA 9930 #610 Vw60encausedbysuspeusonr2OlTSHCenluh :)NEGACTEG CONTINGEIICY) 340416 DINING 161 364016 540654011 KY 161 I ‘IN 1 223 2243’ 59.3 1046 #NIA #616 #516 #610 #010 yoledun unused by suspesoon2Ol7SHCneluO :)NETACTET CONTINGENCY) 34O616SUTIHG 161364326 5#HNKIEYHP 181 I ‘IN , 223- 261sF 839- 1174 2341 7091 1032: 31) 1 T I55T562’Vnlwuumudeonrsu bysospesoun,2TI7THCenIuH )OE000TEG CONTINGENCY) 362124 2LTVEILTN 6903624027W TTNOADTN690 LN 58.4 095 - 86)9

‘#616 #6(0 8846 #610 )b95uuonsausedbysuspesm2OlTSHCnnIu0 )REOACTEO CONTINGENCY) 362124 TIOTEIITN 69 0302406 2WHUNOAE TNG9.5 1 LN I 61.7) 105.7 96(0 : ...#N30 I

96I9 9930 ##‘SIuSun unused Y susyees:on‘2TlTS6Cenlu0 -)NEGACTED CONTINGENCY) 3406165I19ING 161 3EO32NSBANKIEYEP 161 I ‘IN I 223 255.21 839’ 1100: 3230 TON) 105.3) 31 T , 7 155T562VedaIwumthewussebysuspanoun,2#l700CenIuft )REDATTEOCONTiNGENCY) 3NT1242WVELITNN9O3624962WATT6OADTN60M1j33 j_, 504 617)61057 #6108100 I #6(0 1 #666 -#60A:Vedesuncnusedbyouspnr&no

2 #1 6

Table ‘tage Results

MISO Coleman Units 1, 2, & 3 Attachment Y-2 Study - Compare Voltage ResultsCONFIDENTIAL / CEll - DO NOT RELEASE

Umalrig Element Coleman 1, 2, & 3 OFF Coleman 1,2, & 3 ON

UnitImpact

Cow UppModel Contingency Description Bus # Bu Name KV Area Zone Limit Limit Cont Volt Base Volt Vial Cost Volt Base Volt viol (>0.01) MISO Comments20145P REDACTED CON11NGENCYI 4359W1Lj_ 161 20711207 09 i O85ThO9693L IA #N(A #NI.’ ct4/A VIolat3on causedby snsi2014SP [REDACTED CONflNGENCY1 248887O7NWTNVL 162O7i2Q7 09 11 0 8731 097931LNN/A #N/A N/A tIN/A Violationcausedbysuspenenn2014SP [REDACTED CONTINGENCY] 340552 5COLEMAN 161 3l4 1314 0 92 105F0 8125 0 96071L #tJIA tIN/A #tJ/A t#JIA Violation causedbysuspensiun2014SP (REDACTEDCONTINGENCYI — —— ——--—— —- Z5HE__._ os2io5ot214o966s1i #t1/A i#11A #NJA l$NIA Violationcausedbysuspension2014SP _ IREDACTEDCONTINGENCYI 34OS5W5SKILMAN iti 314 1314 0921 05108487 09798L l#l/ActJ/A #N/A ct/A Violationcausedbysuspension20145P [REDACTEDCONTINGENCYI 34O5595D1LS 161 314 1314092 O5 09081 O9B55 #N)A tN1ActIA #NIA Violalioncausedbysuspension2014SF [REDACTEDCONTINGENCY] 3405645NATAL 161 3l4 1314 092105 O8235 O97L #N/A#N/A MN/A #N1AViatinncausedbysuspensiuntf_ [REDACTEOCONTINGENCY] 340565 5NEWMAN i6I 314 1314 0 92 105 O895WO9743L#N/A#N/A#N/A #NIA Vctahoncausedby suspension2014SP REDACTED CONTINGENCVI 340621 5COLEEI-lV is; 314 1314 0 92 1 05 0 81?i 0 %76 C 154/A #NIA #t1/A #N/A Violation caused by suspension201 4SP IREDACTED CONTINGENCYJ 248435 O7NW1VL1 161 207 1207 0 9 1 1 0 BSl6 0 9693L#NIA #tJIA SN/A 4N/A Violufioncaused by 505penoinnQ1P IRE..p ACTEDCONTINGENCYI 24S887O7NWTNVL 2Oti2O7O91.t bNtAsIutoncauoedbysuspnnsisnIREDACTEDCONTINGENCYI ———. —.-——- 3405525C0LEMAN 161 314 1314 O921O5iO8l25Q95O7L ttt1/A #N/A #N/A NN/A Vctatinncanoedbyoospenoion2014SP REDACTED CONTINGENCYI 340557 5HANCO 161 314 1314 0 92 1 O5 0 82141 0 9669 L tIN/A ctIA #t4/A #N/A [Violation caused by suspension2014SP REDACTED CONTINGENCY] 340558 5SKtLMAN lGl 314 1314 0 92 1 05 0 8487 0 9798 L #N/A i#/A #NIA f #bJ/A Violation caused by suspension2014SP IREDACTED CONTINGENCYJ 340559 5DAVtS 161 314 1314 0 92 1 05 090811 Q 955i, ‘1/A #NIA ctIIA btt/A Violation caused bysuspension.. i 34o5t7caEN

#N1Atvctalioncausedbyssspennn2014SP lREDACED CONTINGENCY] — .- . — — 5NATAL 3l4i314 092 1 O5 082351 097 L tIN/A #N/A #EJ/Al #N/A Vislatisncausedbysuspensisn2014SP ]REDACTEDCONTINGENCY] 340565 5NEWMAN1E1 314 1314 092 iO5O8958] 09743]L #N/A#NIA tIN/A #NIA Vislahcncausedbysuspension]REDACTEDCONTGENCY] .. .-—-.-. — -.—-. — -— 3406215COLEEHV .L. #t1/AVctaboncausedbyouspension]p._ ]REDACTEDCONTJNGENCY] 248435O7NWTVL1161i2O12O7 oijO5i6! O69Lct/AbN/A#N/A2014SP ]REDACTED CONTINGENCY] . 248S87O7NWTNVL 161] 207i 1207 0.9 1.1 0.873] O.9793]L #11/A #N/A 1*1/A #N/A Vintatnn caused by suspension2014SP ]REDACTEDCONTINGENCY] 34O55Z5COLEMAN16l{31413l4O921OfO812T O96LIIN/A #N/A #t1fA #N/AjVctatisncnusedbysuspenonn2014SP ]REDACTED CONTINGENCYI 5HANCO i6lj 314 1314 0 92 1051 0 O69 L #EIIA #t1fA tt1IA #N/A Vislatinn cansnd bysuspension

L ON/A lviciassn caused by suspension2014SP IREDACTED CONTINGENCY] — — *

340559i545 lOu 314 1314 092 105_ otoi 09855 L — ON/A Ott/A Ott/A ON/A VOtubsn caused by suspension —2014SP CREDACTE.cONTINGENCL.. — ——- 34059 7COLEMAN 345 — 314 1314 092 1 05 0817(0 9928jL ON/A Ott/A ON/A ON/A lVOtabnn caused by suspension20145P ]REDACTED CONTINGENCY] — 34056415NATAL 101’ 13l4 092 iOS 08235] 097]L ON/A ON/A ON/A #N/AiVinlubuncausedbysuspensinn201 4SP REDACTED CONTINGENCY] 3405655NEwMAN 1tl 314’ 1314 092 105 0 8958i 9743 L ON/A ON/A ON/A ON/A Vislubsn caused by suspension2014SP ]REDACTED CONTINGENCY]

. 340621]5COLEEHV 161/ 314] 1314. 0.92 1.051 0.8171] 0.9676]L ON/A ON/A ON/A ON/A Violation caused by suspension2014SP :L Y — 34O559DAys lOll 3ij

5]5N09AN161L_iL1pj07j3uLZ #N/AjViolabuncaunedbysuspens,nn2014SP ]REDACTED CONTINGENCY] 340559DAVIS 161 314] 1314 0.92: 1.05] 0.9028] 0.985jL ON/A ON/A ON/A ON/A Violation caused by suspension14SP - 6EDACTEDCONflNGENCY] — 340565,5NEWMAN 161] 3141 1314 092 105108905 09743L*

ON/A Ot4/A ON/A 68 lVOtabnn Caused by suspension - -2O14SPIREDACTEDCON11NGENCYI — 3405595DAV 161314i 1314 092 10509028 99855L ON/A ON/A ON/A ON/A’VOtabsncausedbysnnpeniosn2014SP ]REDACTED CONTINGENCY] 340585]5NEWMAN 161 314/ 1314 0.92: l.O5 0.8905] 0.9743]L ON/A ON/A ON/A ON/A IVintutiun caused by suspension]2014SP REDACTEDCONflNGENCY] pptsl314! 1314 092 281 098551L ON/A ON/A ON ON/A VOtabon caused by suspension -20145P ]REDACTED CONTINGENCY]n__201 4SP - - i(REDACTEDCONflNGENC -- —— 3soy/s___ 1 1314 092 100 9028 - jL ON/A ON/A ON/A ON/A]VOtabuncassedbysuspenonn -]20145P i]REDACTED CONTINGENCY] 340565 AN 161] 314] 1314 0.92: 1.05] 0.8905] 0.9743]L ON/A . ON/A ON/A ON/A V/n/nOun caused bysoopenaisn12914$P [REDACTED CONTINGENCY] 248431!O7BRIStW /61/ 207i 1207 0.9, 1.1] oii 1.It ON/A Ott/A ON/A ON/A ]Vislatisncnasndbysuspensinni2314SP - EDACTED CONTINGENCY) - 43592N1101207I1W7091125 09 ON/AON/AONM ON/A Vctatsn caused by suspension --201 4SP {REDACTED CONTINGENCY] — —— 507TRY161 — — 161] 207/ 1207 09111 07926 0 9997 L ON/A ON/A Ott/A Ott/A Vinlabun caused by suspensiun — —i]i2NI!NGNCY]

- — —. zlNYL. .L.J1_?1 ONIA #84/A /]0 Poor —2014SP EDACTED CONflNGENCY] -— 340552 5COLEMAN 1611 314] 1314 092 lOS1 0637 7L Ott/A #8’1/A Ott/A #84/A lValabnncausedbysuspension -2014sP tREDACTED CONTINGENCY]. 248435!07NWTVLJ 161/ 207] 1207 0.9 11] 0.85161 0.9693]L ON/A ON/A ON/A ON/A V/n/alien caused by suspensionc9NIIENcL ,248887i07NNVL 101L297/12070.Oll] oii o.giL ON/A ON/A ON/A ON/A ]Va8on caused by suspunsion

—

3405525COLEMAN 161! ,i4] 1314 1.05[ [9p,/A_• ON!A JVlat saspen2014SP IREDACTED CONTINGENCY]. 340557]5HANCO . 181/ 3u4 1314 0.92’ 1.05] 0.8214] O.9669!C ON/A ON/A ON/A Vislabon caused by suspension2014SF ]REDACTED CONTINGENCY] 340558l55K1LMAN 161] 314/ 1314 0.92 1.05] 0.8487] 0.9798]L ON/A ON/A ON/A ON/A Vinlabun caused by suspension

3 of 6

Table 1tage Resufts cD .MISO Coleman Units 1, 2, & 3 Attachment Y-2 Study - Compare Voltage ResultsCONFIDENTIAL I CEll - DO NOT RELEASE

UnitLirnitUng Element Coleman I, 2, & 3 0FF Coleman 12. & 3 ON Impact

Low Upp Voff•VonModel ontingency Oencñption Bus It Bus Name Ky Area Zone Limit Limit Cont Volt Base Volt Viol Cant Volt Base Volt Viol 1>0.01) MISC Comments2014SP • [REDACTED CONTINGENCYI 340559 5DAVIS 16l 314 1314 0.92 1.05 09081 09855L #tJ/A tIN/A #N/A #N/A Violation caused bysuspension:2ol4sP __ IREDACTED CONTINGENCYI 340564 5NATAL 1tl 314 1314 0.92 1 05 08236 O97L bN/A J/A itN/A #N/A Violahon caused by suspension2014SP IREDACIED CONTINGENCY) 34O5655NEWMAN 161 314 1314 0.92 1.05 0 8959 0 9743iL fiN/A bN/A 4/A J/A itsIaIiso caused by suspension2014SP [REDACTEDCONTINGENCYI 34Ot215COLEEHV 1t1 314 1314 092 1.05 0.8172 O.9676L #PJIA l#/A J/A #N/A oIatioocausedbysuspemian2014SP • IREDACTED CONTINGENCYI

_

340566SMEADE iti 3i4 1314 O921.OO.8775, 0 985iL 4N/A#t1lA #N/A • #N/A VJalpsn caused bysuspensien201 4SP [REDACTED CONTINGENCYI 3406165N.HARD itfi 314 1314. 0.92 1.05 0 8t1t O.9957L 1/A itNIA #N/A litIIA Vislatisn caused by suspessisn2014SP • [REDACTED CONTINGENCY] 34o566:5MEADE 161j 314 1314 092 1051 O.6775 0 9851}L #NIA #tIIA tIN/A I tIN/A Vislutiuncausndbysuspeosinn2014SP [REDACTED CONTINGENCYI 34Ot1t5N.HARD L 16fl 314 1314 0.92 1.05 08616 O.9957iL IA #tJIA IIPIJA itPJIA Violalien caused bysuspunsion2014SP [REDACTED CONTINGENCYI 3405595DAVIS 1tI 314 1314 0 92 1.05: O.9O31 O9tSSiL WIIA ittIIA btIIA litIIA VsiaIiun caused by suspnnsisn1qj__..{REDACTEDCONT1NGENCYj

2014SP IREDACTEDCONTINGENCY] 248435O7NWlVLl lt1 2O712O7 E9 l.lO.8516O693iL . #NIAitN/AitNIA #t1/AiViolabsncausndbysuspensisn4sp REDACTED CONTlNGENCY 248887}D7NWTNVLi61j2O7i2O7 91.1O873 E979L#N1A#N/A itN/A1Aaboncausedbysuspenon2014SP [REDACTED CONTINGENCs9 34O5525COLEMAN 151 314 1314 O.92 1.05: O8l25 O96O7L #PIIA tIN/A #N/A I#JIA Violaliso caused bysuspension2014SP )IREDACTED CONTINGENCY]

___________ _________

340557i5HANC0 161i14j 1314. 0.92 1.O5 0.8214] O.961L ON/A ON/A ON/A #N/A Vie/at/on caused bysuspensiun2OSP EDACTEDCONNGENC- 34o55815sK/LMAN4 1314 092/ 105 OB4B7 09798)L ON/A ON/A ON/Ar#N/A Msioboncausndbysespunsiun

________

340559/5DAV/S 161] 314] 1314 0.92] 1.05] 0.908/i 0.9t55)L ON/A ON/A ON/A ON/A Violation caused by suspensionCONflNGENCY] 3405t7COLEMAN34 314] 131 0.92 t05j 0.9928L ON/A. ON/A ON/A ON/As/a/ion caused by suspension2014SP ]REOACTED CONTINGENCY]

_________ ________340564]5NATAL

161ij 13/4 O.92i 1.05) Q.6235j O.97]L ON/A I ON/A ON/A ON/A V/n/a/ion caused by suspensinn2O14SP1IREDACTEO CONNGENC/9 340565]5NEWMAN161 4L 14 092105 09743E ON/A. ON/A ON/A #N/AjV/nlahon caused by suspeusn2014SP REDACTEDCONflNGENC tCOLEEHV i314L 1314 0.92: 1.05) 071/6L#Ph/A ON/A #tii f#N/AVsi/atuoausedbysespenssin/2014SP ]REDACTED CONTINGENCY] 32413Yj5DORCHST 363] 379 0.9’ 1.1] 0.8032] 1.0034]L ON/A ON/A ON/A ON/A V/u/alien caused by suspension2014SP/]REDACTEDCQNT/NGENCYI

______________ ______32414915/MBODEN

161/ 363] 379 0.9/ 1.1] I -0.232Me/abun caused byuuspensisnj2014SP — ]REDACTEDCDNUNGENCY] —______

— -0243/V/a/abuncausnd by suspension2ol4sp ]REDACTED CONTINGENCY]

____________

32415OI5POCKET i it1 363] 379i 0.9/ 1.1] 0.0677] 1.0047iL 1.111! 1.0052H -0.243]Vislatiun caused bysuspension2O14SPCen/eU ]REDACTED CONflNGENCY 3243 I04SPENC ‘ 8010H 08823 0969LO871609699L 00/1Piuexsbn-2017SP ]REOACTED CONTINGENCYI — — 248437NWTVL1 I 161/ 20j_j07 09 11 — 08482! 0 9696 C — _/A ON/A ON/A N/j]bon cesed bs!pei2017SP ]REOACTED CONTINGENCY] 248867O7NWTNVL ,161[207] 1201 0.9 1.11 06697) O.979]L ON/A ON/A ON/A . ON/A V/slahsncaasedbysuspensiso2017SP IREDACTED CONTINGENCY]

— 340552)5COLEMAN 1t1j 3141 1314. 0.92/ 1.05] o.8065[ 0.9602]L ON/A ON/A ON/A ON/A ]Vielation canned by suspens/sn2OI7SPI]REDACTEDCONTINGENCY] 34O5S7JgHANCO 161] 314] 1314• 02 to5o.917r0.9064E0N/A ON/AON/AI ON/A JisIalisncausedbysuspension —2017SP [REDACIEDCONCNGNCYl 34O558SSKILMAN /161 3141 1314 09 105 08454 09791L ON/A ON/A ON/A1 ON/A /Viioa/Isncausedbyuuspension — -2017SP IREDACTED CONTINGENCY] 340550.5DAV/S 1t1314]. 1314 0.92] 1.05] 0.9049) 0.984L ON/A ON/A ON/A ON/A V/s/aboncausedbysuspensien2017SP— IREDACTED CONTINGENCY] — — — 340565NATAL — 161 314] 1314 092 105j_ 081971 09094L ON/A ON/A ON/A ON/A yis/abscaus!susfG_2017SP IREDACTED CONTINGENCY] 340565 5NEWMAN 161 31l 1314 0 92 jq 08928! 0 973jL #NIA ON/A ON/A ON/A Vislabon caused by suspension2017SP ]REDACTEDCONT/NGEN0YI

_______

340621]5COCEEHV /61314] /3140.92/ 1.05! 0.81321 0.9671L ON/A . ON/A ON/A ON/A V/s/absn caused by suspnns/nn]REDACTEDCON1ONGENCY] - —— 2)O7NW[VC1 161] 207 1207 0.9: ti] 0.9482) 09696]L .01//A 01/LA ON/A) ON/A V/n/at/on cauned bysuspenioun2017SP ]REDACTEO CONTINGENCY] — — 240607 07NWTNVC — 20J 1207 09 1 1 0869k 0 979]L ON/A ON/A ON/A ON/A Vislabun caused by suspension017SP1]REDACTED CONTINGENCY] —- .340552JCEMAN i61 314] 3214. 0.9k j 0.8005 0.9t02]L .ON/A,014/AON/AJON/A]Vi&aliuo s nuupunsnPi7SP IREDACTED CONTINGENCY] -- — — 340557 5HANCO j_ 092 105 081731 09C 014/A ON/A /liausedbysuuspe2017SP ]REDACTEDCONT/NGENCY] —— 3405585SK/LANjfl 314 1314 092 i0 08454 COiL ON/A ON/A ON/Aj ON/A Viulaboncausedbysuspermun2OI7SPIREDACTEDCON11NGENCY1 - — —- 3405595DAV/S -

- jj 314 1314 092 105 0904 — 0904L ON/A ON/A 014/Al ON/A Violatisucausedbysuspension2017SP — ]REDACTED CONTINGENCY] — — — 3405t317COtMAN 345] Th1L 1314 105 08132) 09921 C i/A ON/A ON/A1 ON/A V/s/alan caused by suspenuan2O17SP— IREDACTED CONTINGENCY] — 3405t4/5NATAC — 161 314 1314 092/ 105/ 08197] 09694 CON/A 01//A ON/Al ON/A V/siotiancaasedbysuspensiun2017SP IREDACTEO CONTINGENCY] —— — 340565 SNEMMN —— 161 31 1314 092 105 08928 0973 — ON/A ON/A 011/A ON/A Vs/a/ion causedbysuspensien — —2017SP - ]REDACTEDCONT/NGENCY] — — — — —_______ 3406215COLEEHV 161 314 1314 092 105 08132 09674 ON/A 01//A 01//A ON/A Viu/a/onceusedbysuspensan2017SP ]REOACTEOCONT/NGENCY] — - - 246435)O7NWVLI 161] 207] 12070.9] 1.1 00482) 0.9696]C ON/A ON/A ON/A ON/A V/o/ationcausndbysuspunsion2017SP ]REDACTED CONTINGENCY] ——

_________

— 253581110NWC13 — J31 210 1210 095 l05J 09354 QpjL ON/A ON/A ON/A ON/A /Vctatisncaasndbysuspunsan — ——2017SP — REDACTED CONTINGENCY] — ——

________—

— 340552/5COCEMAN —— 16]f 314 /314 092 105 08085/ 09t0C 01//A 014/A 01//J ON/A Va/a/ioncausedbysuopensisn ——2017SP— ]REOACTEDCON:/NGENCYI - -— 34055715HANCO —- 161/ 314 1314 092 08173 09662L ON/A ON/A ON/Al ON/A V/slaysncausedbysuspnnaon

_____

2017SP — ]REDACTEDCONT/NGENCY] 3405585SK1LMAN 161 314 1314. 0.! 1.05] 0.8454) 09791iL ON/A . ON/A ON/A I ON/A V/s/alan caused bysuspension

4 ol 6

Table 1 age Results(‘\

MISC Coleman Units I , 2, & 3 Attachment Y-2 Study - Compare Voltage ResultsCONFIDENTIAL I CEll - DO NOT RELEASE

_____________________________________ ___________________________________

UnitLimiting Element Coleman I, 2, & 3 OFF Coleman 1,2, &3 ON ImpactLow Upp I Voff-VonModet _ Contingncy Description Bus # Bui Name (V Area Zone Limit Limit Cant Volt Bane Volt Coat Volt Base Volt (>0.01 ) MISO Comments2O1JS . REDACTLD CONTINGENCY] 340559 5OAVIS 1611 314] 1314 092 1.05] 0.9049: O984L #NIA #N/A #N/A IINIA Violalion caused by suspension2017SP • :]REDACTED CONTINGENCY] 340563 7COLEMAN 345 314 1314 0.92 105] 0.8132] O.9921]L #El/A #N/A tJ/A /A Violation caused by suspension2017SP IREDACTEOCONTINGENCY] 36O564j5NATAL i613i41 J 092 1.05] O.8197O9694ILN/A tIN /A #N/ALtIN/AViolatisncausedbysuopenoien2017SP —.--———-- --- —— I34L L! #N/A]Viaboncausedbysuspenaon2017SP ]REDACTED CONTINGENCY] 34O62G5COLEEHV 161] 314] 1314. 092 l.O5 0.5132] O.967iL J/A EN/A el/A #NIA Violation caused bysuopensiun2O17SP [REDACTED CONTINGENCY] 34G5595DAVIS 161] 314] 0.92 105j O8924 O.984]L #NIA tIN/A #tJIA #NIA Vislation caused by suspension20178P _ [REDACTEDCONTINGENCY] 34O5655NEWMAN1 1611 31411314 092 1 o51 Q5jQ973 l/N/A#N/A #NIA I /A Viulationcauoedbysuspensiun2017SP ]REDACTEDCONTlNGENCY]34Q5595DM

•\ñoialancausudby suspenaonq17 IREDACTEDCONTCNGENC1

_

3405655NEWtMN 161j 314 1314O.9 1O5 O8O73#N/A bN1A)A I1/AyisIaIioncouoedbysuspnnsion2017SP ]REDACTED CONTINGENCY] 25358O1ONWL16 ltlj 210] 1210. 095 l.05I O.9349697]L #tJ/A tN/A #NIA #NIA Violation caused bysuupensiun2QJ7SP ]REDACTEDCONTINGENCY]

_________

34O559i5DAVIS 161] 314j 1314 092 1.05] #N

_____________

340565]5NEWMAN Z_jiL 1314 OY2 1.05] 0.861 O973L #tlfA #N!A #NIA#tlIAiolalioncausedbysuspensiun2017SP ]REDACTED CONTINGENCY] 34OjDlS ] 161] 314] 1314 0.92 l.O5 O8923J O.9841iE . tN/A dN/A tIN/A EN/A Violstisn caused bysuspeusion2017SP ‘]REDACTEDCON1NGENC]105 D88D97#N1A #AM dPUAiViutsban causedby suspunsan2017SP ]REDACTED CONTINGENCY]

— — 340559]5DAV 16 311314092 105] 089231. 09041L #NIA UA544IA #N!Auialabuocausedbysuspension2017SP — IREDACTED CONTINGENCY] — 340565jEWMAN ii 314i 1314 — 0921051 088 0973]L #N/A#N/A#NIA #NIA]Viulatiancuusedbysuspension2017SP — ]REDACTED CONTINGENCY] — ——- 248431I07BPSTW 6Th207 — 09 10012r #NIA #NIA #NIA #N/A JioIalen caused by suopenaon -

2017SP ]REDACTED CONTINGENCY] — —— — — — 248435107NWCVL1 161] 2071 09 i 1]o85o9686IL A#14/AUA #1/IA Vaboncaused bysuspenston —2017SP (REDACTED CONTINGENCY] 24886507TRY161 F16i 1207 0.9 Ti1 01892L08L N/A#N/A #N/A yistslioncausedbysusponuion -2017SP LREDACTEDCONTINGENCY]

________

248887]O7NWrNVL 16ip[_120TO.9 j0i568]0.979]L #1/IA#NIA#1/IAI#NIAVioIabsncausedbysuspensian2017SP ]REDACTEDCONTINGENCY]______ 3495525C0LEMAN 161] 3141 1314 092 1O5 06327] 096jiE 144/A #11/A #N/A #NIA Viulationcausedbysuspension —2917SP]fREDACTEDCONflNGENCYJ____

______

248435O7NWIVL1]161]207]2O17SP]REDACTEDCONflNGENCY]— - — . 248887]O7NWTNVL — 1611 f 1207 00111 080971 0979]L #1/IA 14IIA #14 #1/IA Mdatisncousedbysuspenan2017SP [REDACTED CONTINGENCY] — — — 34OSS215COLEMAN 161 314 1314 082 105] 080851 O96óT #1/IA 14//A #11/A #1/IA Violation caused by suspenoluo —

2017SP ]REOACTEDCONTINGENCY] 340557jHANCO — I 1611 31411314: 0.92. i.o510.917410.8662]L #NIA14/IA14I/A iaooiJ2017SP ]REDACTED CONTINGENCY] — —— — 340558 5SKILMAN 161] 314] 1314. 0.92 1.05] 0.84551 0.9791]L #11/A #14/A 14/IA 14IIA Viulation caused by suspenctsn2017SP — REDACTED CONTINGENCY]— 340559 5DAVIS 161 314t 1314 092 10& 09049 0984 L #11/A #8//A #14/A #14/A Violation caused bysuspeasion —

2017SP I]REDACTEDCONTO/GENCY] 34056415NATAL 1611 314 1314 092 i.05L 0.91811 96941L #NIA#N/A 14/IA #NIA]Viots0oncaasedbyuuoponon2017SP]REDACTEDCONflNGENCY] — — — 34056515NEWMAN 1611 314 1314 092 105] 08928] 0973]L — 14//A #11/A 14//A 14//A Viotsbsncauoedbysusponaun — ——2017SP ]REDACTEO CONflNGENCY] — — 340621 5COLEEHV 161 — 314 1314 092 lOs 1j 0967 L 144/A #1IIA rn//A1 #1/IA Vi&abancausedbyouspension2017SP -- ]REDACTED CONTINGENCY] — — - — 34056j5MEADE 161] 314] 1314. - OA2i5]86509B41 #1/IA #N/A #8/IA I201 7SP 1]REDACTED CONTINGENCY] — —— 340616 SN HARD 161] 314 - 1314 — 092 105] 08484 O9956_ #N/A — #1/IA #1/IA 14/IA Vislabun caused by suspension — —2017SP]REDACTED CONTINGENCY] —

— — - 253580]1ONWL16 I 161] 210] l21_ t0S 09367] 09697]L #1/IA - 14//A #1//A j 144/A friuiassn caused by suspension2017SP .:]E0cIEPfNCY]__ — 25358Oj10NWL16]16I 2101 1211 0951 1.05] O.936?j C96L #NIA 14/IA - ffl/IA #1/IA Viotsbun caused by suspension2017SP — ]REDACTED CONTINGENCY] — — 340566J5MEADE 161j 3l4 — 1314 - 092 — 1 OSi 08654 09846]L 14/IA 14/IA 141/A I 14//A Violation caused by suspension2917 —— ]REDACTEDCONTINGENCY] 340616]5N.HARD - 161] 314j134O.92i.05!O.84L0.9956]L#1/IA#1//A:96IA]#N/A/ViOIaIiuuCassedbYsusPeauion.17SP - ]REDACTEDCONNGENCY] 3405595DAViS] 161j 3141 1314 092105] 08952 0984 - #1/IA - #8/IA 14/IA - #NIA Vioiofl caused by suspension20175P]REDACTEDCONflNGENCY]

____

340it5NEWMAN 1611 3141 1314 092 8f0973_ #11/A - #11/A 14//A i #1//A Vlolabsncauoedbyuuopensiun__— —2017SP ]REDACTED CONTINGENCY] 24843Sj07NWWU 161] 207] 1207 09 -- - 01] 08482] 09696 #1/IA 14/IA 14/IA1 #14IA Vl&atian caused by suspenan2017SP ]REDACTED CONTINGENCY] 248887O7NWTNVL 1 161] 207] 1207 0.9 6.86871 0.979]L 14/IA #1/IA : 14/IA 1 140A ]Vislatinn cussed by suspensiun017SP - REDACTED CONflNGENCY] - —-

__

OOLEMAN13141314 086O2 AVioIoedbysuspensmn201 7SP ]REDACTEOCON11NGENCY] -- 340557]5HANCO 1611 31 4] 1314 092 105 081 73]095621L #1/IA #1/IA 14/IA #1/IA Viola sedbysuopenuioo20l7SP ]REDACTEDCONONGENCY] —- 340LL _j J61L._.i20P ]REDACTE000NTINGENCY]

- — - — 340558 5DAViS - —- 161] 314] 1314 092 105r 090491 098ê 96/A #1/IA #8/IA #1/IA Iabuncausedbysuopeflioon0l7SP ]REDACTED CONTINGENCY] - — — - — ‘7COLEvIAN 34j 3141 1314 092 IOSL C 81321 099214L 96/A 14//A14.9 14//A\I5 caused by suspansion ——2017SP - EDACTED CONTINGENCY] —— -- 34O564]5NATAL 1611 314 1214 - 092 1 05i 08197109694 L 144/A #1//A 14J/AI#N/A1V#1absncausedbysuopnnaun -2OI7SP - ]REDACTEDCON11NGENCYJ — — 3405)5NEWMAN l_ ij 314 l31 — Q9[_] 09731L s/IA 14/IA 9tabon1ed buo sIn_n — -2017SP - ]REDACTED CONtiNGENCY]— 5COLEEHVjj3i4J 092 105] 0 813 09671E 141/A #1/IA #1//Al #1/IA Violation cysaue -—2017SP ]REDACTLD CONTINGENCY] 36043O[HAR96ViAN TN 161] 347] 1261 01 Nfl 0i649Lt0426]L . 0j82t0427L-0017jPre-enshe —

5 ot 6

Table 1tage Results cN) .MISO Coleman Units 1, 2, & 3 Attachment Y-2 Study - Compare Voltage ResultsCONFIDENTIAL / CEll - DO NOT RELEASE

Umiting Element Coleman 1, 2. & 3 OFF Coleman 12, & 3 ONUnttImpact

I Low Upp [ IContingency Description Bush Bus Name KV ]Area Zone Limit Limit jCostVolt BaseVolt Viol ContVjBaseVotty (>0.01) MISO Comments..J—

-161_ 347136SO 1i Oi6j iO477L Oi8151477LIREDACTED CONTINGENCY] 3S114S5BLAJRRDTN 161 3471368O9 1 1 O751 0474 L 07812 10474 L 0 O17IPreexstIng2017SP IREDACTED CONTINGENCY] 360430 5HARRiAN TN 16 3471 1368C9l1O 6888 10426 L 07309 10427L 0 042 PreensUng2Di7SP REDACTEDCONTPNGENCY] 361O995BLAIRRDTP 161] 347] 1368 09 1.1] O6889i l.O477tL 01311 10477,L -O042]Pre-exsting2017SP REDACTEDCONTINGENCYL 151 ! 1368 0911 O6885 10474 C 07307 10474L 0042 Pm nosting

.36J383i5WOAKRIDGT 16l]347136O.9i 1.1] 0.689] t0479]L 01312:10479L -O42jPre-exstng2O17SPqREDAC1EDcONTINGENcY] 36O43O5NARRNTN 161j 347 1368O9u1O69791O426L Op9jD27L_ OD33Preexslingi_— IREDACTE000NT1NGENCYJ 36O6925ROANE B#2 i61 3471368 0 9 Th1069811 1 0479 L 07312 10479 L -OO331Preexstrng2Oi7SPREDACTEDCONTINGENCY] 351099]5BLAIRRDTP 161347I otigafi i.O477LOi3i11.O477L -0033]Pre-exsting1_ REDACTEDCONflNGENCY] 36H465BLRRDTh iI 1 61O4741L 07307 474L OO3eexsng3B13B3j5WOAKRIDGT l61]1368:: O.91.1! 0.6981] i.O479LO.73i2tO479L -OO33Pre-exstngl2Ol7SPCentcff [REDACTED CONTINGENCY] 36O43O5HARRIMAN TN 161j 347 1368 0.9 t1 07308] I.0426]L 0.6782 1.0426L OO53]Pre-exctnEDACTED CONflNGENC 3O995BLAIRRDW 34 68 0 jjO73i1O477 L Q4jq_ j3tiu146 5BLAIR RD TN 161 347 13680 9 I 1] 0 10474L 0 677910474 C I 0053]Pre-exsbng[O17SPCentcIfqREDACTEO CONTINGENCY) 3613S3I5WOAKRIDGT 1[347I 1368 O9’T[O73i] 1 04791. 06784 10479L I 0053]PreexsbngO17SPCenlofflREDACTEOCONTINGENCY] 3tiO43D5HARRtiANTNi61 347] 1368 09 111 O751O4261L 07821 10426L OO27tPre-exsting361099I5BLA1R RD TP 161]3471368. ot1joJ548 lM477ILO.7B14.1.O477L i______2Ol7SFCentott IREDACTEDCONTINGENCYI 3Sfl46j5eLAIRRDIN 161 347 1368; O.9. iii 07544] lO474jL 0781: 1.0474L -O.O27Pm-exstngOOl7SPCenloff REDACTEDCONflNGENCY1 36O43OHARRMAN TN 161[Th47 1368 9TO73O8 10426 L06782 0426L 0 O53Pre nesting2Ol7SPCentdfl ]REDACTED CONTINGENCY] 361099]5BLAIR RD TP 161 347 1368: 0.9] 1.11 0.731] 1.0477IL O6784 l.0477L OO53Pre-exsting2Ol7SPCentuff ]REDACTEDCONflNGENC9 — 360 465BLAIR RDTN oñTh 0474 L 06779 10474 L PmexstingOl7SPCentoff REDACTED CONTINGENCY] 361383I5WOAKRJDGT 161 347 136809] 1 1 31i 10479 L 96784 1 0479L — 9053 Pre-cxshng —12017SPCentoff]REDAC1D CON11NGENCY] i6lL ‘ QL 11! 05784 1 0104 LO 5537 10104L 0025 jPm exsbng201 7SH ]REDACTED CONTINGENCY] —— 40566a5MEADE 161f 314] 1314 092 1 0 0901!j 09887 L #11/A ON/A #11/A ON/A Violaben caused by suspension]REDACIE000NDNGENCY] 345N HARD 191 314 1314 0921 00 8889 9998 C — ON/A 014/A ON/A #N/AjViolabuncausedbysuspensisn29175H ]REDACTED CONTINGENCY] — 248435]O7NWIVL1 161 207] 1201 0.9], 1.1] 0.8438FTh9768]L 014/A ON/A ON/A ON/A jViolabon caused by suspension2017S REDACTED CONTINGENCY] 248865 O7TRY161

— 111207 1l jO99O2 L.... A 1absn caused by suspensionI28j tREDACTED CONTINGENCY] — 248887107NwrNVL 09 1008622] 09831L ON/A ON/A 014/A #11/A a/sin caused bysuspenson —12017SH PEDACTED CONTINGENCY] 340552i5COLEMAN 31 1314 892 1 05 08062j0 96991L ON/A 99/A ON/A ON/A V/u/a/ion caused by suspension —2017SH ]REDACTED CONTINGENCY] 34/b57 5HANCO 161! 3141314 092 105 99699L ON/A ON/A ON/A #11/A !Iai]en caused by suspension2017SH ]REDACTEDCON11NGENCY] —— 34055815SKILMAN 161] 314 1314 0921 051 08386 98241L 014/A ON/A ON/A ON/A iVin/atien caused by suspension2017SH ]REDACTED CONTINGENCY] — — 340559i5DAV1S 191 314] 1314 092/ 105 09O4 0990211. ON/A ON/A 99/A 014/A Violation causedbysuspensiun —201 7SH - ]REDACIEDCONTO4GENCY] 340563 7COLEMAN 3451 3Th4 092r 08062 0993L ON/A ON/A ON/A #NVedabsn caused by suspension2017511 ]REDACTED CONTINGENCY] 349594j5NATAL 1914.. 3i4 1314 0.92] 1.0510.8128]0.9724!L ON/A ON/A ON/A 011/A Violation caused by suspension2817SH ]REDACTEDCONT/NGENCY] — 340565]5NEWMAN 161/ 08933 097L ON/A ON/A 014/A ON/A iiocauoedbysuspension

---——————----—-—-———————±————- —— . ,-——--——4——-—-.--, .-———--———----—!2o;7SH]REDACTED CONTINGENCY] i05HARRIrvfAN TN 161I_L 1368 0.91 1.1] 0.757]t04225L_01804i.0424L -0.0231Pre-eust/n12017SH - [REDACTED CONTE1GENC 361 999 SBLAIR RD TP 161] 347 1368 09 11 0756 i04730 7797 1 0474L 0024exs/rng - -20175H ]REDACTED CONTINGENCY] 36146i5BIRRDTN.L 136809 1107558] 1047]L 97793 1 0472 L - 0924fxsbog2017511 — — ]REDACTED CONTINGENCY] — —— — 360430 5HARRIMAN TN 161 34i 1368 /1I0757i0422]L 07803104241. OO23iPreexs/ing —2017SH]]REDACTED CONTINGENCY] 36109915BIR RD TP 161] 3471 1368i 0.9 1.1] 0.7562] t047jL 01796- 1.0474-1. -0.O23IPre.exsting0017511 lREDACD CONTINGENCY] - 361145B//RRDTN 161] 347/ 1368 0911 07558rT047 L 07793 10472 C 002J Re eon/mg - - — —-2O17SHCerdoff ]REDACTED CONTINGENCY] - — 324310 4SPENC 11 87821 0jL 08646 09682 C Prexsting - — -2O17SHCenIo9 ]REDACThD CONTINGENCY] — — 360439 5HARRMAN TN Th1 347! 13o8 0911 9757t 19422 L — 0780310423 C -0023jPrexshng — - -Ol7SHCentsff ]REDACTED CONTINGENCY] 361099]5BLA/R RD TP 161] 347] 1368 0.8 ii] 0.7562 1.047L — 0.7790I 10474 L - -8023tPre-ess/ingI2D17SHCen/off]REDACTED CONTINGENCY] -— — 361145BLAIR RD TN ThU 3471368011/ 87558ri047Q 97793 10471L 0924]Preexsbng - — —- ——20VSHCentoffREDACTEDCONflNGENCY] 3600338UNION MS 500 347H 356 09 11 08606/10475 L 08793 1 0476 L 0 01Pre ens/ing— - —2Ol7SHCentoff ]REDACTED CONTINGENCY]— — 360430 5HARRIMAN TN 161] 136889 11 0757/10422 L 07803 19423L 0231Preeasling —— —2O17SHCen/ofl 1jREDACTED CONTINGENCY] — — — - 36/099 SECAIR RD TP 1611347/ 136809 11 0756j i0473L 07796 10474 C 0023]Preeaoting ——2Ol7SHCentofffREDACTEDCONflNGENCY] 36i1465BLAiRRDIN .iL.1 P.P L8Li.P71L 01793 t0471L -9.O24jPre-exofing

6 of 6




dated July 2, 2013

July 11, 2013

I Item 3) Refer to page 5 tines 12-17 of Mr. Berry’s Rebuttal Testimoity in Case No.

2 2012-00535 wherein lie provides three reasons why it is appropriate for Big Rivers to idle

3 Coleman Station, one of which is that €otemait has higher fuel costs titan other Big Rivers

4 an its.

5 a. If one or more of the ‘oleman units are designated as SSRs, then how

6 will this affect thefuel costs included in and recoverable from customers

7 throttgh the Company FA C?

8 b. Please provide a quantification of the effect on thefttel costs included in

9 the Company’s FA C and recoverable from customers f one or more of

10 the €‘oleman units are designated as SSRsfor the entirety of the test year

11 in Case No. 2012-00535.

12 c. Please explain how the MISO make whole payments compensate Big

13 Rivers for these increased fuel costs and whether the compensation

14 reflects dollarfor dollar recovery.

1 5 d. If one or nwre of the Coleman units are designated as SSRs, theit how

1 6 wilt this affect tite environmental consumables incltided in and

17 recoverable from customers through the €‘ompany ‘5 environmental

18 sttrcharge rider?






dated July 2, 2013

July 11, 2013

I e. Please provide a quanqflcation of the effect on the environmental

2 consumables included in the company’s environmental surcharge rider

3 and recoverable from customers if one or more of the coleman units are

4 designated as SSRs for die entirety of the test year in case No. 2012-

5 00535.

6

7 Response)

8 a. If one or more of the Coleman units are designated as $SR, the fuel costs

9 will be recovered through the SSR process and will not be included in Big

10 Rivers FAC filings.

11 b. All variable operating costs are reimbursed under the $SR agreement.

12 See, the MISO tariff section 38.2.7. The fuel costs will not be included in

13 Big Rivers’ FAC filings.

14 c. Big Rivers’ understanding is that all actual variable cost, (fuel, reagent and

1 5 disposal) will be recovered under the SSR agreement. Please refer to

16 section 38.2.7 of the MISO tariff.

17 d. If one or more of the Coleman units are designated as SSR, the

18 environmental consumable costs will be recovered through the SSR

Case No. 2013-0022 1Response to KIUC 1-3





dated July 2, 2013

July 11, 2013

process, and will not be included in Big Rivers’ environmental surcharge

2 rider.

3 e. Big Rivers’ understanding is that all actual variable cost, (fuel, reagent and

4 disposal) will be recovered under the SSR agreement. Please refer to

5 section 38.2.7 of the MISO tariff. Please see also, the response to subpart

6 (d), above.

7

$ Witness) Robert W. Berry

9






dated July 2, 2013

July 11, 2013

1 Item 4) Refer to page 5 lines 12-17 of Mr. Berry’s Rebuttal Testimony in Case No.

2 2012-00535 wherein he provides three reasons why it is appropriate for Big Rivers to idle

3 Coleman Station, one of which is that Coleman has the least amount ofpollution control

4 equipment installed

5 a. Please explain why this is a reason to idle €‘ole,nan Station and how this

6 affects the decision to idle Coleman Station.

7 b. If Big Rivers idles one or niore of the Coleman ttnits, does Big Rivers

$ plan to defer tile installation of any of the pollution control equipment

9 previottsly approved by the €‘ommission for recover through the

10 environmental surcharge rider? If it does not plan to do so, then please

11 explain why it shoitid not defer these capital expenditures ttnless and

12 until the tcnit is neededfor service at some later date in thteftttttre.

13

14 Response)

15 a. During Big Rivers’ evaluation to determine which unit (Coleman or

16 Wilson) to idle, it considered both current and future environmental

17 regulations. The cost to retrofit Coleman to comply with MATS is

18 approximately three times the cost for Wilson to comply with MATS.




FOR APPROVAL OF CONTRACTS AND FOR A DECLARATORY ORDERCASE NO. 2013-0022 1

Response to the Kentucky Industrial Utility Customers, Inc.’s- Initial Request for Information

dated July 2, 2013

July 11, 2013

Likewise, Wilson is compliant with both the proposed Coal Combustion

2 Residual (CCR) regulation and the proposed 316 (a) and (b) regulation,

3 whereas Coleman will potentially require capital investments to comply

4 with each of these proposed regulations.

5 b. At this time, if Big Rivers idles one or more of the Coleman units it will

6 not install the MATS equipment on the idled units unless the SSR extends

7 beyond June 1, 2014. The MATS equipment will be installed prior to

$ restart after April of 2015, if and when the economics support restart of

9 the unit.

10

11


13






dated July 2, 2013

July 11, 2013

1 Item 5) Refer to page 5 lines 18-22 of Mr. Berry’s Rebuttal Testimony in case No.

2 2012-00535 wherein Ite states that whether Coleman is idled or Big Rivers is required to

3 operate coleman as an SSR, “it wilt not cattse a meaningfitt financial impact on the rate

4 adjustment Big Rivers seeks in this proceedbtg.” Please describe and provide a copy of all

5 analyses that supports this statement.

6

7 Response) As stated in Section V of my Rebuttal Testimony, pages 17 through 20, the rate

8 adjustment requested in case No. 2012-00535 is based on Wilson being idled and Coleman

9 operating. Whether Coleman is idled or operating under an S$R, the financial impact for Big

10 Rivers is substantially the same, so the choice will not have a material effect on the requested

11 rate adjustment. The fixed operating costs savings associated with idling Coleman is

12 approximately $90,000 greater than the fixed operating costs savings included in the requested

13 rate adjustment.

14 I also testified during the evidentiary hearing on July 2, 2013, that the proposed

15 transaction has the potential to impact the requested rate adjustment depending on whether or

16 not a SSR is required of the Coleman plant. If a SSR is required then the severance costs

17 requested in Case No. 2012-00535 will be deferred until the SSR terminates. Also if Century

12 operates at the Base Load amount, Big Rivers will receive transmission revenue from Century.






dated July 2, 2013

July 11, 2013

I In either scenario, it is Big Rivers’ intention to pass along to its Members any benefit above

2 Big Rivers’ reasonable margins resulting from the Century transaction. Since the two

3 scenarios are uncertain and difficult to determine, no formal analysis has been performed.

4

5


7

$






-

dated July 2, 2013

July 11, 2013

1 Item 6) Refer to page 18 lines 13-16 of Mr. Berry’s Rebuttal Testimony in Case No.

2 2012-00535 whereiit he states that “(uJnder the SSR status, MISO retains the revenue from

3 the Coleman generatiolt to Itetp offset the operation cost so that, essentially, Coleman wilt

4 not be part of Big Rivers’porfolio.”

5 a. Please explain how it is that MISO retains the revenue from the

6 Coleman generation.

7 b. Please describe how the revenue is quantJIed, under what markets the

8 reven tie is obtained, and how that is reflected in the MISO make whole

9 payments to Big Rivers.

10

11 Response)

12 a. While Coleman is designated by MISO as an SSR unit, Big Rivers will not

13 receive revenues related to negotiated or market prices for generation

14 produced from Coleman. Instead, MISO wilt dispatch the unit as needed

15 to satisfy reliability needs. Pursuant to section 38.2.7(h)(ii) of the MISO

16 Tariff, Big Rivers will receive compensation from MISO based on Big

17 Rivers’ going forward costs of operating Coleman. Any revenue that is

18 generated by the unit in the day-ahead and real-time market is treated as






dated July 2, 2013

July 11, 2013

1 an offset to the SSR costs that are recovered from load, as discussed to (b),

2 below.

3 b. Revenue can be quantified as payments for resource adequacy and

4 revenues from energy market transactions. MISO’s pro forma SSR

5 agreement provides that MISO will conduct an annual true-up, or make-

6 whole payment, to match market and other revenues with the SSR unit’s

7 annual revenue requirements, which are based on its costs of operation.

I) 8 Through its market settlement process, MISO will issue make-whole

9 payments for hours in which the applicable market-clearing price for the

10 SSR unit is less than its applicable cost-based SSR payment, and will debit

11 the settlement statements for each hour in which the applicable market-

12 clearing price is above the applicable SSR payment.

13

14


16





Response to the Kentucky Industrial Utility Customers, Inc.’s• Initial Request for Information

dated July 2, 2013

July 11, 2013

1 Item 7) Refer to page 19 tines 17-22 of Mr. Berry’s Rebuttal Testimony in case No.

2 2012-00535 wherein lie states that the Commission should address the costs and revenues

3 related to Century in case No. 2013-00221. Mr. Berry further states that “Centttry has

4 agreed to pay Big Rivers for any additional out-of-pocket costs it btcurs or commits to in

5 connection with the century Transaction ‘

6 a. Please list and describe each of the costs that Century has agreed to pay

7 Big Rivers and the revenues that Century wilt provide Big Rivers.

8 b. Please describe how the company and century will qttanqfji each of the

9 costs and revenues identfled in response to part (a,) of this question.

10 c. Please provide a quanqfication of each of the costs that Big Rivers will

11 incttr and the related reventtes that century will pay to Big Rivers in the

12 test year ttsed in Case No. 2 012-00535. Please quantjfy the effect of

13 each of these costs and revenues on the revenue requirement in Case

14 No. 2012-00535.

15 ci. Please confirm that f the Wilson Station and the Cotentan Station

16 contin tie to operate, then Big Rivers wilt itot incur severance costs and

17 that the claimed revenue requirement in Case No. 2012-00535 should be






dated July 2, 2013

July 11, 2013

1 reduced to remove the severance-related amortization estimated to idle

2 the Wilson Station.

3 e. Please confirm that the MISO make whole payments wilt not provide

4 recovery of capital expenditures at the Coleman Station.

5 f. Please confirm that the designation of the coleman units as SSRs will

6 itot reduce or eliminate the market price risk associated the generation

7 from those an its.

8

9 Response)

10 a. Please see page 10, line 15 through page 11, line 14 of Mr. Starheim’s

11 Direct Testimony and page 29, line 7 through p. 33, line 11 of Mr. Berry’s

12 Direct Testimony.

13 b. The costs to be incurred and the revenues to be received by Big Rivers

14 generally are straightforward as to their quantification as nearly all of the

15 costs are amounts determined by reference to amounts invoiced to Big

16 Rivers (e.g., under a Bilateral Contract or from MISO under the MISO

17 Tariff). Big Rivers has the ability to allocate out-of-pocket costs incurred

1 8 or committed to by Big Rivers with respect to service to Kenergy for the






dated July 2, 2013

July 11, 2013

1 benefit of Century. To the extent known to the parties, those items and the

2 bases for allocation of those items are set forth in Exhibit B to the Electric

3 Service Agreement and the Direct Agreement and Exhibit A to the

4 Arrangement Agreement.

5 c. No formal quantification has been performed because Big Rivers does not

6 know whether Century will operate at the Base Load without Coleman

7 operating or if it will operate above the Base Load with Coleman

8 operating under an SSR status, or will operate under each scenario for

9 some period. Please also see Big Rivers’ response to AG 1-1.

10 U. If the Coleman plant is operated under an SSR then the severance costs

11 related to Case No. 20 12-00535 can be deferred until such time Coleman

12 is idled. An amortized portion of the severance costs associated with

13 idling the Wilson plant is included in the revenue requirement in Case No.

14 2013-00199.

15 e. Pursuant to the standard SSR Agreement set forth in Attachment Y-1 of

16 the MISO Tariff, the annual true-up is intended to match market and other

17 revenues with the SSR unit’s annual revenue requirement, which is based

18 on its costs. Through its market settlement process, MISO will issue






dated July 2, 2013

July 11, 2013

make-whole payments for hours in which the applicable market-clearing

2 price for the SSR unit is less than its applicable cost-based SSR payment,

3 and will debit the settlement statements for each hour in which the

4 applicable market-clearing price is above the applicable SSR payment. As

5 a general matter, the SSR payments are intended to provide recovery for,

6 among other things, going forward capital expenditures necessary to

7 operate the SSR unit. Accordingly, a portion of the make-whole payments

8 will cover going forward capital expenditures at the Coleman Station.

9 f. Confirmed.

10

11


13

14






-

dated July 2, 2013

July 11, 2013

I Item 8) Refer to page 7 tines 15-18 of Mr. Berry’s Rebuttal Testimony in case No.

2 2012-00535 wIt erein lie states: “MISO, through an SSR, will not pay for interest,

3 depreciatioit, proper!)’ tax, or property insuraizce for an SSR unit. MISO clearly states that

4 an entity wotttd incur those costs regardless of whether the unit was being usedfor reliability

5 purposes.” Please provide a copy of the MISO tarffs and at! other source documents relied

6 on for these assertions.

7

8 Response) Under Section 3 8.2.7 of the MISO tariff, the owner of the SSR unit will be

9 compensated for property taxes and insurance. But Big Rivers’ understanding from MISO has

10 been that property taxes will not be reimbursed. This issue must be resolved with MISO in the

II negotiation of the SSR Agreement. However, the rate will not include interest or depreciation,

12 or other cost components of a full cost-based rate.

13 Please refer to MISO Tariff section 3 8.2.7, a copy of which is attached to Big

14 Rivers’ response to KIUC 1-la. Big Rivers has also relied upon the following documents,

15 which are lengthy (total of over 350 pages), and were not copied because they are publicly

16 available in the eLibrary section of the FERC website.

17 • MISO, FERC Filing of SSR Agreement with DTE Elec. Co., Docket No.

18 ERI3-1226-000, at 12 (filed Apr. 2,2013).






dated July 2, 2013

July 11, 2013

• MISO, FERC filing of SSR Agreement with City of Escanaba, Docket

2 No. ER13-3$-000 (filed Oct. 5, 2012).

3


5

6




FOR APPROVAL OF CONTRACTS AND FOR A DECLARATORY ORDERCASE NO. 20 13-00221


dated July 2, 2013

July 11, 2013

1 Item 9) Refer to page 7 tine 22 through page 8 tine 2 of Mr. Berry’s Rebuttal

2 Testimony in case No. 2012-00535 wherein Ite states: “Centuiy — not Big Rivers or its

3 members — will pay for alt costs not reinthursed to Big Rivers related to operating the

4 coleman Station under SSR status.”

5 a. Please provide alt supportfor the referenced statement.

6 b. Please identify at! costs that Big Rivers wilt incur, operating aitd capital,

7 that century will not payfor fcoleman is designated an SSR.

$

9 Response)

10 a. Please see Section 4.1(a) and (d) of the Direct Agreement and the

11 definition of “SSR Costs” set forth in Section 1.1.87 of the Electric

12 Service Agreement.

13 b. The referenced testimony was discussing additional, incremental costs of

14 operating Coleman Station under an SSR agreement. In that context, there

15 are no additional costs that will be borne by Big Rivers; those costs will be

16 borne by Century, assuming that the question is intended to refer to

17 additional costs relating to Plant Coleman incurred as a result of Plant

1$ Coleman being designated as a SSR.






dated July 2, 2013

July 11, 2013

2 Witness) Robert W. BelTy

3

4

.



2

3

4

5

6

7

9

10

11

12

13

14

15

16

17




dated July 2, 2013

July 11, 2013

Item 10) Refer to page 44 tines 4-13 of Mr. Berry’s Direct Testimoity witerehi he states

thefollowing:

“Offsetting transmission revenue against Century ‘s SSR Costs obligation is

reasonable as proposed in tite Transaction documents because it wit!

potentially allow the Hawesvile Smelter to remain in operation tin til it can

install equipment to eliminate the SSR condition at the coleman Station. Big

Rivers would have received no transmission revenue from centtuy f it had

terminated smelting operations at the Hawesville Smeltem The advantage

Kenergy aitd Big Rivers negotiated in the Centumy Transaction is lb at Big

Rivers wilt receive tite Century transmission reveitue f and when titere is ito

requirementfor a SSR Agreement.”

a. Please explain how offsetting the transmission revenue against

century’s SSR Costs obligation wilt allow the Hawesville Smelter to

remain in operatiolt. Please be specic.

b. Please explain why Big Rivers and its non-Smelter customers should not

retain the Gentury transmission revenues regardless of whether the

Goleman units are designated as SSRs.






dated July 2, 2013

July 11, 2013

I c. Please confirm that the SSR costs are actual costs that Big Rivers wilt

2 incur due to tite operation of the Coleman un its as SSRs.

3 d. Please provide at! other reasons why the company believes that

4 offsetting the transmission revenue against C’entuiy’s SSR Costs

5 obtigation is reasonable.

6

7 Response)

$ a. For many years, Century has advised Big Rivers that the cost of electric

9 service to Century is the most important variable in the cost of production

10 of aluminum by the Hawesville Smelter and thus the most important

11 variable in determining whether the Hawesville Smelter can remain

12 economically viable. Offsetting the SSR cost with the transmission

13 revenue will allow Century to reduce the operating cost of the smelter

14 until such time as it can install the equipment necessary to allow the

15 Coleman plant to be temporarily idled. This was a very significant issue

16 for Century during the contract negotiations.

17 b. The negotiation of the Transaction Documents was a complicated

18 balancing act between the financial and operational requirements of Big






dated July 2, 2013

July 11, 2013

Rivers, Kenergy and Century. If the Hawesville Smelter closes, Big

2 Rivers will not receive the transmission revenue in question. Century is

3 obligated to pay all SSR Costs incurred by Big Rivers, even those

4 attributable to others if Big Rivers does not actually receive payment from

5 those other entities. Further, continued operation of the Hawesville

6 Smelter generates additional benefits to Big Rivers and Kenergy through

7 the indirect economic boost associated with continued operation of other

8 businesses in western Kentucky and the approximately 600 people who

9 retain their jobs. Ultimately, Big Rivers made a business judgment that

10 the financial consequence of the Hawesville Smelter closing outweighed

11 the offset of some transmission revenue credit during the SSR period.

12 c. The SSR Costs are costs that will be incurred by Big Rivers.

13 d. The referenced statement in my Direct Testimony states the reasons why

14 Big Rivers believes it is reasonable under the circumstances to allow

15 Century to offset SSR costs with transmission revenue received from

16 Century under this proposed transaction.

17



Witness: RobertW. BerryPage 3 of 3




dated July 2, 2013

July 11, 2013

1 Item 11) Please provide a copy of alt correspondence and documents between BREC

2 and Centttry since Jan amy 1, 2012 relating to Genttuy market access and/or the contracts

3 that BREC seeks approval of in this proceeding.

4

5 Response) Big Rivers objects to this item on the grounds that it is unduly burdensome and

6 overly broad. Without waiving that objection, please see the attached documents that are being

7 provided consistent with the agreement between counsel for Big Rivers and counsel for KIUC.

8 Some of these materials are being provided pursuant to a petition for confidentiality.

9

10


12






dated July 2, 2013

July 11, 2013

I Item 12) See the Application of Kenergy and Big Rivers at Section III, Item 9 on page

2 5, which states that alt legal authority for Kenergy to provide electric service to the

3 Hawesvitle Smelter wilt terminate on August 20, 2013.

4 a. Does Kenergy take the position that the existing Smelter Tariff tinder

5 which electric service is provided to the Hawesvitle Smelter co

6 terminates with the termination of the 2009 Retail Electric Services

7 Agreement behveen Kenergy and century? If so, what is the basis for

8 Kenergy to provide continuing electric service to the Sebree Smelter?

9 Explain Kenergy ‘s position in detail, citing applicable law.

10 b. Does Kenergy take the position that the Smelter Tarjff will no longer be

11 available to ceittury upon the termination of the 2009 Retail Electric

12 Services Agreement between Kenergy and centiny? If so, explain

13 Kenergy ‘s position in detail, citing applicable laws or regulations.

14 c. Does Kenergy take tite position titat jf it has no legal authority or

15 obligation to provide electric service to the Hawesville Smelter on or

16 after August 20, 2013, Centttr’ would have the rtgltt to seek electric

17 service from another electric supplier? If not, explain Kenergy ‘s

1 8 position in detail, citing applicable In ivs or regttlations.


Witness: Gregory J. StarheimPage 1 of 2




dated July 2, 2013

July 11, 2013

1 Response)

2 a. No. Kenergy Tariff 33 does not terminate with the termination of the

3 2009 Retail Electric Service Agreement. The former Alcan Primary

4 Products Corporation (“Alcan”) smelter will continue to be served under

5 the 2009 contract between Alcan and Kenergy.

6 b. Yes. Kenergy Tariff 33 states that the tariff for service to Century

7 Aluminum of Kentucky General Partnership consists of the Retail Electric

8 Service Agreement dated as of July 1, 2009 (the “Century Retail

9 Agreement”). That tariff expires at the end of the day on August 19, 2013.

10 With the termination of the Century Retail Agreement, Century will no

11 longer receive power under this expired tariff.

12 c. No. Kenergy would still be the exclusive retail supplier for Century

13 pursuant to KRS 278.018(1), and have the right and the reasonable

14 obligation to serve Century’s load pursuant to KRS 278.030, subject to

15 Commission approval of an appropriate contract or tariff for service.

16

17 Witness) Gregory J. Starheim

18






dated July 2, 2013

July 11, 2013

I Item 13) See the Application of Kenergy and Big Rivers at Sectioit IV, Item 1S(c)

2 begimting at page 12.

3 a. ‘ite alt applicable sections of tile Loan contract between Big Rivers and

4 R US under which R US holds the right of approval for the €‘entuiy

5 Transaction.

6 b. Cite alt applicable sections of tite Loan contract between Big Rivers and

7 RUS that set forth the schedule for RUS to decide upon approval of the

8 Century Transaction, including the right of R US to defer its decision in

9 this matter.

10 c. Provide copies of all written communications between Big Rivers and

11 RUS addressing the proposed century Transaction or the reiationsIt4o

12 between Century Transaction and the credit enhaitcentent plan that Big

13 Rivers submitted to R US pursuant to the terms of the Loait contract

14 between Big Rivers and the RUS.

15 U. State whether Big Rivers’ management believes that RUS’ decision to

16 approve or decline to approve the proposed century Transaction will be


Witnesses: Billie J. Richert (a., b., c., d., f., g and h.), andGregory J. Starheim (e. and i.)

Page 1 of 7



Response to the Kentucky Industrial Utility Customers, Inc.’sInitia1 Request for Information -

dated July 2, 2013

July 11, 2013

1 inJluenced by the decision of the commission in the pending Case No.

2 2012-00535.

3 e. Does Keitergy take the positiolt that f R US approval of the Gentruy

4 Transaction is not graitted by A ttgust 19, 2013, Kenergy should have the

5 right to disconnect electric service to a retail customer located within its

6 franchise service territory? Explain Kenergy ‘s position in detail, citing

7 applicable laws or regulations.

8 f Describe in detail the creditor agreement default isstte, citing the

9 applicable sections of the Amended and Restated Revolving Credit

10 Agreement between Big Rivers and the National Rural Utilities

11 Cooperative finance corporation (“CfC’9 that cotild prevent Big

12 Riversfrom entering into the century Transaction.

13 g. Provide copies of all written communications between Big Rivers and

14 CfC from A ttgust 19, 2012, to the present that address or discuss the

15 creditor agreement default issue.

16 h. State whether Big Rivers’ management believes that the resolution of

17 the creditor agreement default issue between Big Rivers and CfC wilt


Witnesses: Billie J. Richert (a., b., c., d., f., g and h.), andGregory J. Starheirn (e. and 1.)

Page 2 of 7




dated July 2, 2013

July 11, 2013

1 depeitd upon or be influenced by the decision of the commission in the

2 pendbtg Case No. 2012-00535.

3 1. Does Kenergy take the position that f the creditor agreement default

4 isue between Big Rivers and CFC prevents Big Rivers from elttering into

5 the Century Transaction by August 19, 2013, Kenergy should have the

6 right to disconnect electric service to a retail cttstomer located within its

7 franchise service territory? Explain Kenergy ‘s positiolt in detail, citing

8 applicable laws or regulations.

9

10 Response)

11 a. Section 5.6(a)(ii), (iii) and (v) of the Loan Contract, relating to entry into

12 any contract for the purchase, exchange or sale of electric power or energy

13 that has a term exceeding two years, any contract for the purchase or sale

14 of transmission, ancillary services or similar power supply arrangements

15 that has a term exceeding two years, and any amendment or modification

16 of any wholesale power contract.

17 b. Section 8.1 of the Loan Contract provides that Big Rivers must give RUS

18 notice in writing of the Transaction. If RUS delivers written notice that it


Witnesses: Billie J. Richert (a., b., c., d., f., g and h.), andGregory J. Starheim (e. and 1.)

Page 3 of 7




dated July 2, 2013

July 11, 2013

objects to the transaction to Big Rivers within 60 days, then Big Rivers

2 cannot consummate the transaction without RUS approval. If RUS

3 objects, there is no specified time by which RUS must grant or give notice

4 of its failure to approve the transaction.

5 c. Please see the attached document. In the interest of economy, the copy of

6 the application in this matter and the extra copies of transaction documents

7 that are exhibits to the application that are attachments to that document

$ are not copied and attached to this information request response.

9 d. Big Rivers has no basis on which to express a belief on this question

10 beyond saying that if an order unfavorable to Big Rivers is entered in Case

11 No. 2012-00535, it may be more difficult to focus the attention of the RU$

12 on the Century transaction.

13 e. KR$ 278.160(2) prohibits a utility from providing electric service except

14 pursuant to approved rate schedules. If there is no approved rate schedule

15 in place prior to August 20, 2013, Kenergy would have no legal authority

16 to provide service. Kenergy may source wholesale power to provide retail

17 electric service to Century from any source it chooses. But contracting to

12 provide service to the Century smelting load is a complex process that


Witnesses: Billie J. Richert (a., b., c., d., f., g and h.), andGregory J. Starheim (e. and 1.)

Page 4 of 7




dated July 2, 2013

July 11, 2013

1 takes an enormous amount of time to properly document. There is no

2 Kenergy tariff under which Kenergy can provide retail electric service for

3 the Century smelting load after August 19, 2013. So the only alternative

4 for providing service to the Century smelting load upon the expiration of

5 the current agreement is under the proposed arrangements. If Century

6 ceases smelting, Kenergy would still need a contract like the Alternate

7 Service Agreement to provide electric service to Century. But if

8 Kenergy has no Commission-approved set of contracts in place on a

9 timely basis, Kenergy will have no authority to continue providing service

10 to Century upon the expiration of the current agreement.

11 If Century elects to continue smelting at Hawesville, then Kenergy

12 could supply retail electric service from a Market Participant other than

13 Big Rivers. However, with no such alternate Market Participant in place,

14 Kenergy caimot reasonably do so. Kenergy is only required to provide

15 service if it can reasonably do so pursuant to KRS 278.030, and only has a

16 right to do so if it has a Commission-approved rate schedule under which

1 7 the service can be provided.


Witnesses: Billie J. Richert (a., 5., c., d., f., g and h.), andGregory J. Starheim (e. and i.)

Page 5 of 7




dated July 2, 2013

July 11, 2013

f Big Rivers is seeking to amend the Amended and Restated Revolving

2 Credit Agreement between Big Rivers and National Rural Utilities

3 Cooperative Finance Corporation (“CFC Credit Agreement”) to eliminate

4 an event of default in that agreement that would result if the proposed

5 contracts (or any future contracts with Century) were entered into and then

6 terminated prior to their stated term. In the proposed contracts, Century

7 could terminate the Electric Service Agreement prior to the end of the

8 stated term which would terminate the Arrangement Agreement. If this

9 happened, under the current form of the CFC Credit Agreement, an event

10 of default would occur under that agreement that could then constitute an

II event of default under other credit agreements of Big Rivers.

12 g. Please see the attached documents.

13 h. If an order unfavorable to Big Rivers is entered in Case No. 2012-00535,

14 CFC may refuse to close the transaction amending the revolving credit

15 agreement to eliminate the default issue.

16 i. See response to part e., above.

17

18 Witnesses) Billie J. Richert (a., b., c., d., f., g. and h), and


Witnesses: Billie J. Richert (a., b., c., ci., f., g and h.), andGregory J. Starheim (e. and 1.)

Page 6 of 7




dated July 2, 2013

July 11, 2013

Gregory J. Starheim (e. and 1.)

2

.


Witnesses: Billie J. Richert (a., b., c., d., f., g and h.), andGregory J. Starheim (e. and i.)

Page 7 of 7

SULLIVAN, MOUNTJOY, STAINBACK & MILLER pscATTORNEYS AT LAW

f June 12, 2013nad M. Sullivan

Jesan I Mnuntjoy

Frank Stainback Rural Utilities ServiceJames M.Mflltr United States Department of Agriculture

Michael A. fiordils Room No. 51 35-S1400 Independence Avenue, $.W.

RMichaelSullivan Stop 1510EryanRReynolds Washington, D.C. 20250

TysonA.KnmufAttention: AdmmistratorMarkW. Smmcs

C. Ellsworth MountjoyRural Utilities Service

‘AisoLicensedinlndiana United States Department of AgricultureRoom No. 0270-S1400 Independence Avenue, S.W.Stop 1568Washington, D.C. 20250Attention: Power Supply Division

Subject: KY 62 Big Rivers Electric CorporationTransaction Involving Century Aluminum of Kentucky GeneralPartnership

Dear Sir or Madam:

We are counsel to Big Rivers Electric Corporation (“Big Rivers”). Big Riversand Kenergy Corp. (“Kenergy”), a Big Rivers member, are proposing atransaction by which Kenergy will provide a retail aluminum smeltercustomer, Century Aluminum of Kentucky General Partnership (“Century”),retail electric service with power acquired from the wholesale market that ispriced based upon market pricing (the “Century Transaction”). The CenturyTransaction will commence on and after the termination dateof the existingretail electric service agreement with Century and other related agreementsat 12:00 a.m. CDT on August 20, 2013 (the “Termination Date”). Thepurpose of this letter to the Rural Utilities Service (“RUS”) is to submitdocuments Big Rivers proposes to enter into in connection with the CenturyTransaction to the RUS for review pursuant to the Amended andConsolidated Loan Contract between Big Rivers and United States ofAmerica dated as of July 16, 2009, (the “Loan Contract”), Sections 5.6 and8.1.

Telephone (270) 926-4000

Telecopier (270) 683-6694 The documents Big Rivers submits for RUS review are described in detail inthe joint application Big Rivers and Kenergy have ified today with the

Ann Buiiding Kentucky Public Service Commission seeking necessary state regulatoryP0 727 approvals for the Century Transaction (the “Application”). A copy of the

Owenoboro, Keatuciry

4Z302-0727

wwwwesrkylavtcom

SULLIVAN, MOUNTJOY, STAIN BACK & MILLER psc

Rural Utilities ServiceJune 12, 2013Page 2

Application is enclosed for reference purposes, and to provide you with thebest available description of the Century Transaction and the documents forwhich Big Rivers seeks RUS review.

The documents submitted in draft form for RUS review are:

Arrangement and Procurement Agreement between Big Rivers andKenergy (Application Exhibit 5). This agreement is the basicwholesale power agreement between Big Rivers and Kenergy for theCentury Transaction. A summary of this agreement can be found inthe Application, pages 6 and 7. This agreement is further describedin the testimony of Big Rivers’ Chief Operating Officer, Robert W.Berry (Exhibit 3, pages 15, and 22-24). Mr. Berry’s testimony alsocontains details about the entire Century Transaction. TheArrangement and Procurement Agreement is a back-to-backagreement with the Electric Service Agreement, which is the retailservice agreement between Kenergy and Century. The ElectricService Agreement is described in the testimony of Kenergy’sPresident and CEO, Gregory J. Starheim (Exhibit 3, pages 7-14).

Direct Agreement between Big Rivers and Century (ApplicationExhibit 6). This agreement provides for Century to pay Big Riverscertain expenses incurred by Big Rivers, even if Big Rivers is nolonger the Market Participant under the Arrangement andProcurement Agreement and Kenergy is obtaining wholesale powerfor resale to Century from a source other than Big Rivers. Asummary of this agreement can be found in the Application, page 7.This agreement is further described in the testimony of Mr. Berry(Exhibit 3, pages 16, and 25 and 26).

Wholesale Letter Agreement (Application Exhibit 14). The WholesaleLetter Agreement supplements the all-requirements wholesale powercontract between Big Rivers and Kenergy in connection with BigRivers’ provision of wholesale electric service to Kenergy for deliveryunder the proposed Alternate Service Agreement with Century(Application Exhibit 13). The Alternate Service Agreement providesa reduced amount of retail electric service (10 MW) to the Centurysmelter facility if smelting operations cease. The Alternate ServiceAgreement and the Wholesale Letter Agreement are described in theApplication (pages 5 and 10-11), the testimony of Mr. Starheim

SULLIVAN, MOUNTJOY, STAINBACK & MILLER sc

Rural Utilities ServiceJunel2,2013Page 3

(Exhibit 2, pages 23-24) and in the testimony of Mr. Berry (Exhibit 3,page 21). The Alternate Service Agreement and the Wholesale LetterAgreement are forms of agreements that Kenergy and Big Rivers useregularly.

Enclosed with this letter are the following documents:

o Six certified counterparts of an excerpt from the minutes of themeeting of the Big Rivers board of directors on May 17, 2013, atwhich Big Rivers’ management was authorized to negotiate and enterinto documents in connection with the Century Transaction;

o Six certified counterparts of an excerpt from the minutes of themeeting of the Kenergy board of directors on June 11, 2013, at whichKenergy was authorized to sign the Wholesale Letter Agreement andthe Arrangement and Procurement Agreement;

o Six draft copies of the Arrangement and Procurement Agreement;

o Six draft copies of the Direct Agreement;

o Six draft copies of the Wholesale Letter Agreement; and

o Three copies of the Application.

Please note that the RUS Administrator has been provided one copy of thesedocuments, and the RUS Power Supply Division has been provided themultiple, original signed counterparts of the documents listed above.

Timing is very critical in the Century Transaction. The three documents forwhich RUS review is sought must be approved and executed by the partiesbefore the existing agreements under which Century is taking electricservice expire at the end of the day on August 19, 2013. When the existingagreements terminate, if other agreements have not been approved andexecuted by the parties, neither Kenergy nor Big Rivers have any legalauthority to continue providing electric service to Century, and by lawservice to Century’s smelter must be disconnected.

. Big Rivers understands that the documents presented for RUS review arepart of a complex transaction. If at any point it would be helpful for

.

SULL WAN, MOUNTJOY, STAINBACK & MILLER sc

Rural Utilities ServiceJune 12, 2013Page4

representatives of Big Rivers to review those documents or the CenturyTransaction with RUS staff, Big Rivers will be pleased to do so.

Please note that Section 8.1 of the Loan Contract provides that the RUS hassixty (60) days (or such shorter period as the parties shall agree to inwriting) after receipt of this notice letter in which to object to the proposedtransaction and require Big Rivers not to complete the transaction withoutRUS approval. By our calculation, this notice letter will be received by RUSon Thursday, June 13, 2013, and the sixtieth day following delivery of thisnotice letter to RUS will expire no later than midnight on August 12, 2013.

Please contact me with any questions you have regarding this request.

Sincerely yours,V

James M. MillerCounsel for Big Rivers Electric Corporation

cc: Billie J. Richert, Big Rivers Electric CorporationRobert Berry, Big Rivers Electric Corporation

EXCERPT FROM THE MINUTES OF REGULAR MEETINGOF THE BOAR]) OF DiRECTORS

Of BIG RIVERS ELECTRIC CORPORATIONHELD iN HENDERSON, KENTUCKY, ON

MAY 17, 2013

After considerable discussion, Director Denton moved adoption of the followingresolutions:

WHEREAS, Big Rivers, Kenergy and Century have reached non-binding agreement on aterm sheet that provides a framework for negotiation of definitive agreements to establish termson which Kenergy will provide retail electric service to Century from the wholesale powermarket after the termination of Century’s retail service agreement on August 20, 2013;

WHEREAS, Big Rivers is anticipated to participate in that structure as the transmissionprovider and, at least initially, as the Market Participant for Kenergy for wholesale power markettransactions; and

WHEREAS, timing of completion and approval of the transactions necessary toimplement retail service to Century under new agreements by August 20, 2013, is critical.

RESOLVED, that each of the following employees of the Corporation is an AuthorizedRepresentative: The President and Chief Executive Officer, the Vice President Accounting,. Rates and Cf0, and the Chief Operating Officer, and any other officer or employee of theCorporation designated as an Authorized Representative in writing by an AuthorizedRepresentative listed above.

fURTHER RESOLVED, that the proposed transactions between and among Big Rivers,Kenergy and Century described in the term sheet presented to the Board of Directors is approvedin all respects, including but not limited to the alternate service arrangements.

fURTHER RESOLVED, that the Authorized Representatives of Big Rivers be, and theyhereby are, and each of them hereby is authorized and directed for, and on behalf of Big Rivers,to negotiate and execute all such agreements, documents, instruments certificates, and otherpapers, and to do all such acts and things as may be necessary or desirable to complete thetransactions authorized hereby substantially on the terms contained in the term sheet, including,without limitation, the seeking and securing of all approvals or consents from Big Rivers’creditors and the Kentucky Public Service Commission, and the carrying out of the terms of thevarious agreements and document authorized or approved in the foregoing resolutions.

FURTHER RESOLVED, that the Authorized Representatives of Big Rivers be, and theyhereby are, and each of them hereby is authorized and directed for, and on behalf of Big Rivers,to prepare for the possibility that agreement may not be reached on definitive documents, or thatapprovals of the definitive documents may not be obtained timely, including as part of that

.

EXCERPT FROM THE MINUTES OF REGULAR MEETINGOF THE BOARD OF DIRECTORS

OF BIG RIVERS ELECTRIC CORPORATIONHELD IN HENDERSON, KENTUCKY, ON

MAY 17, 2013

preparation, without limitation, the seeking and securing of all necessary approvals or consentsfrom Big Rivers’ creditors and the Kentucky Public Service Commission to protect the interestsof the Corporation, and to comply with the Corporation’s legal obligations.

The motion was seconded, and adopted by unanimous vote.

I, Paula Mitchell, Executive Secretary ofthe Board of Directors of Big Rivers ElectricCorporation, hereby certify that the aboveis a true and correct excerpt from the minutesof the Regular Meeting of the Board ofDirectors of said Corporation held on5-17-13..

_______

KENERGY CORP

RESO LUTION

WHEREAS:

By letter dated August 20, 2012, Century Aluminum of Kentucky GeneralPartnership (“Century”) served notice to Kenergy Corp. (“Kenergy”) that itwas terminating its retail power contract with Kenergy;

2 Since that time Kenergy and its wholesale power supplier, Big RiversElectric Corporation (“BREC”), have been negotiating with Century toenable Century to acquire power from the wholesale market throughBREC as a market participant that would be distributed by Kenergy toCentury;

3. The negotiations have now resulted in contractual terms in the followingagreements involving Kenergy:

(a) Electric Service Agreement between Kenergy and Century;

(b) Arrangement Agreement between Kenergy and BREC;

(c) Tax Indemnity Agreement from Century to Kenergy protectingKenergy from negative tax consequences as a result of the transaction;

(d) Parent Guarantee by Century’s parent of Century’s obligations toKenergy;

(e) Protective Relay Agreement regarding system reliability;

(f) Capacitor Agreement involving system reliability;

(g) Century’s guarantee(s) to Kenergy of the Capacitor and ProtectiveRelay Agreements;

(h) Alternative Service Agreement between Kenergy and Century forCentury’s non-smelting load up to 10 megawatts should Century no longersmelt aluminum but still need power for non-smelting reasons;

(i) Wholesale letter agreement between BREC and Kenergy for thesupply of wholesale power of up to 10 megawatts that would be necessaryto serve Century’s non-smelting load; and

.

(j) Lockbox Agreement whereby Century’s payments for power areconveniently and securely processed through a bank account;

NOW, therefore, BE IT RESOLVED that the Board of Directors approves the foregoingcontracts and accepts the guarantees and authorizes Gregory Starheim to sign theforegoing documents on behalf of Kenergy, and submit the contracts to applicablelending and regulatory authorities for approval

I hereby certify that the foregoing is a true and correct copy of a resolutionadopted by the Board of Directors of Kenergy Corp. on June 11, 2013,and that said resolution has not been amended or modified and is in fullforce and effect, this the 1 1th day of June, 2013.

Debra Hayde ,Assistant Secretary

•2

USDA

United Stkt.z D.pathn.nt of Aricutbjr.Rural Dov&opment

Rural Business-CooperaIie Serico • Rural Housing Service • Rural Utilities SoMeeWasingtrm, DC 2O2O

SUBJECT: Waiver of Provisions of RUS Loan DocumentsLarge Retail Power Contracts

TO: All RUS Electric Borrowers

FROM: BLAINE D. STOCKTON /‘Assistant Administrator /Electric Program —‘

Rural Utilities Service (RIJS) electric loan documents require the borrower to obtain RUSapproval prior to entering into certain large retail power contracts. Approval is necessarywhen the contract is for the sale of power and energy for periods exceeding two (2) yearsif the kWh sales or kW demand for any year covered by such contract shall exceed 25percent of the Borrower’s total kWh sales or maximum kW demand for the yearimmediately preceding the execution of such contract.1

Pursuant to its authority to waive compliance with provisions of RUS loan documents,2RUS hereby waives compliance with the requirement to obtain RUS approval prior toentering into a large retail power contract as described above. following execution of thecontract, the borrowers will be required, however, to submit an original signed copy ofthe contract along with an original signed certificate to the General Field Representative(GFR). The certificate is to be in the identical form that is enclosed with thismemorandum. The GfR will maintain the contract and certification in his/her file. TheGfR will also fax or forward a copy of the certification to the appropriate RegionalOffice in Washington.

Borrowers are reminded that this waiver applies solely to the rights of RUS under its loandocuments with the borrower and is not intended to and does not effect the rights of anythird parties, including other lenders or co-mortgagees that may have imposed limitationson distributions by the borrower. RUS reserves the right to withdraw this waiver Inwhole and in part and on a case-by-case basis by written notice to borrowers signed by Oron behalf of RUS.

In addition, Bulletin 112-6 which provides guidance for RUS approval of large retailpower contracts has been rescinded.

‘Paragraph B of Section 6.5. Limitations on Certain Types of Contracts, Appendix A to Subpart C to Pan1718-Model Form of Loan Contract for Electric Distribution Borrowers. 7 CfR 1718. 104.2 Section 9.10. Complete Agreement; Amendments, Appendix A to Subpart C to Port 1718-Mode] form ofthe Loan Contract for Electric Distribution Borrowers. 7 CfR 1718,104..

f’iiJal Delopm. s an Eot1i Oppoy LaCona c daun, culd baS.crs4 01 AgriI*w.. Waw,9cr,. 0020250

.

LARGE RETAIL POWER CONTRACT AND ASSOCIATED RATE(S)CERTIFICATE

Manager’s Certification

On behalf of [insert name and address of borrower), I, [manager’s name]certify, to the best of my knowledge and as of the date thereof, that:

hereby

1. [Borrower’s full legal name] and [large power load name] have executed a retaillarge power contract (Contract) dated [date].

2. The term of this Contract is for [insert number of years and final date, and includeinformation on any renewal opportunities or conditions].

3. The execution of this Contract between [borrower’s full legal name] will not haveany adverse effect on the [borrower’s full legal name], including, but not limitedto, [borrower’s full legal name] ability to meet all Rural Utilities Service (RUS)Mortgage and regulatory requirements,

4. I have reviewed the adequacy of the rate schedule(s) associated with the Contractand concluded that such rate(s) do/does not impose an undue burden on any otherrate classes or consumers. The rate schedule(s) to be used in conjunction withthis Contract is identified as [insert name and date of rate schedule and if it isageneral or special rate].

5. 1 have complied with all RUS required engineering approvals for the pians and/orconstruction of facilities to serve the new large power load.

6. 1 have determined that entering into this Contract for supplying this large powerservice will not interrupt the adequate power supply needed to meet the totaldemands of the system or cause any unusual fluctuations or disturbances, and that

.

the [borrower’s full legal name] has sufficient resources to serve this large powerload.

7. Any/all required or appropriate regulatory notification or approval in connectionwith the Contract or the rate(s) associated with the Contract have been obtained.

8. The cost of additional required facilities have been financed by [indicate with loanfunds, general funds, or aid in construction funds].

9. Any additional facilities required for this Contract are [indicate either dedicated ornot dedicated to the specific large power load] and the maintenance of thededicated facilities will be performed by the [borTower’s full legal name) at[indicate if the borrower or the large power load recipient is responsible for thecost of maintenance].

10. If the Contract is terminated by either party prior to its full term, the Contractcontains terms and conditions providing adequate financial protection for the[borrower’s full legal name], its consumers and the security of the Government’slien.

[Signature of Manager] [Date]

Billie Richert

From: Bilte RichertSent: Wednesday, June 12, 2013 4:56 PM

Thomas Hall; Dan Lyzinski [email protected])Mary Susan Bowles; Ralph Ashworth

ubJect: Joint Application of Kenergy Corp. and BREC for Approval of Contracts and for a Declaratory Order

Tom/Dan,

Today we delivered the above application to the PSC. We will FEDEX a copy of this application to you tomorrow.

&ifl jcirt CP.4, C9Ti’VP Accounting, Rates and CFOBig Rivers Electric Corporation201 Third StreetHenderson, KY 42420

Corporate: (270) 827-2561Office Direct: (270) 844-6190Mobile: (270) 577-6221

The information contained in this transmission is intended only for the person or entity to which it Is directly addressed or copied. It may contain material ofconfidential and/or private nature. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this information by persons orentities other than the intended recipient is not allowed, If you receive this message and the information contained therein by error, please contact the sender anddelete the material from your/any storage medium.

.

.1 Case No. 2013-00221

Attachment to MUC 1-13(g)Pagelof5

Billie Richert

From: Thomas Hall <Thomas.Hallnrucfc.coop>iNnt: Wednesday, June 12, 2013 7:24 PM

Billie Richertiubject: Re: Joint Application of Kenergy Corp. and BREC for Approval of Contracts and for a Declaratory Order

Thanks Billie.

CFC: Created and Owned by Americ&s Electric Cooperative Network

Thomas HallRegional Vice President

National Rural Utilities Cooperative Finance Corporation20701 Cooperative WayDulles, VA 20166Office: 703-467-2746Cell: 703-483-1398Fax: 703-467-5653

II From: I

()[email protected] I‘—

— IIITo: II>

—-----

IThomas Hall <[email protected]>, “Dan Lyzinski ([email protected]) <[email protected]>

>

I-—jCc:

I >

>— I

I Mary Susan Bowles <[email protected]>, Ralph Ashworth <[email protected]>

>

Ij Date:

I> Ij06/12/2013 05:56 PM>

>

)Ject: II>

— I1 Case No. 2013-00221

Attachment to KIUC 1-13(g)

Page2of5

Iioint Application of Kenergy Corp. and BREC for Approval of Contracts and for a Declaratory Order

Tom/Dan,


Billie Richert, CPA, CITPVP Accounting, Rates and CFOBig Rivers Electric Corporation201 Third StreetHenderson, KY 42420


The information contained in this transmission is intended only for the person or entity to which it is directly addressedor copied. It may contain material of confidential and/or private nature. Any review, retransmission, dissemination or-ther use of, or taking of any action in relianceupon, this information by persons or entities other than the intendedj,)pient is not allowed. If you receive this message and the information contained therein by error, please contact thesender and delete the material from your/any storage medium.

The information contained in this transmission is intended only for the person or entity to which it is directly addressedor copied. It may contain material of confidential and/or private nature. Any review, retransmission, dissemination orother use of, or taking of any action in reliance upon, this information by persons or entities other than the intendedrecipient is not allowed. If you receive this message and the information contained therein by error, please contact thesender and delete the material from your/any storage medium.

This may contain information that is confidential or privileged. If you are not the addressee indicated in this message (orresponsible for delivery of this message to such person), you should not copy or deliver this message to anyone or makeany other use of the information set forth herein. In such case, you should destroy this message and notify the sender bytelephone or e-mail.

.2 Case No. 2013-00221

Attachment to KIUC 1-13(g)Page3of5

Billie Richert

From: Dan Lyzinski <Dan. [email protected]>

Qnt: Wednesday, June 12, 2013 7:34 PM

Billie Richeftibject: Re: Joint Application of Kenergy Corp. and BREC for Approval of Contracts and for a Declaratory Order

Thanks Biflie.CFC: Created and Owned by America’s Electric Cooperative Network

Original MessageFrom: Billie Richert [BiIlie.Richertbigrivers.com]Sent: 06/12/2013 04:56 PM ESTTo: Thomas Hall; Dan LyzinskiCc: Mary Susan Bowles <[email protected]>; Ralph Ashworth <[email protected]>Subject: Joint Application of Kenergy Corp. and BREC for Approval of Contracts and for a Declaratory Order

Tom/Dan,


Billie Richert, CPA, CITPVP Accounting, Rates and CFO

Rivers Electric Corporationi. Third StreetHenderson, KY 42420




may contain information that is confidential or privileged. If you are not the addressee indicated in this message (orrrsnsible for delivery of this message to such person), you should not copy or deliver this message to anyone or make

1 Case No. 2013-00221Attachment to KIUC 1-13(g)

Page4of5

any other use of the information set forth herein. In such case, you should destroy this message and notify the sender bytelephone or e-mail.

2 Case No. 20 13-00221

Attachment to KIUC 1-13(g)

Page 5 of 5




dated July 2, 2013

July 11, 2013

1 Item 14) If Big Rivers were unable to obtain the approval of RUS for the Century

2 Transactions, or f Big Rivers were unable to enter into the Jentury Transactions upon a

3 failure to resolve the existiitg creditor agreement default issue between Big Rivers and CfC,

4 does Ken ergy believe that ttte proposed Centtiiy Transaction could be restructured with a

5 Member of MISO other than Big Rivers? Explain in detail whether such a restrttcturillg

6 with a Member ofMISO other thait Big Rivers would be possible.

7

8 Response) Kenergy, Big Rivers and Century spent much time analyzing how the proposed

9 transaction would be implemented in time for it to be effective prior to August 19, 2013. The

10 conclusion of all three parties was that the only way the transaction could be closed by that

11 date was through the structure set forth in the Transaction Documents with Big Rivers initially

12 serving as the Market Participant. Even given the advantage of the parties’ intimate history

13 and knowledge of each other, the transaction took more than five (5) months of intensive

14 negotiation and document drafting to put together the documents submitted with the

15 Application. To bring in a new party at this late date likely would require a substantial delay.

16 Any new commercial requirements of that party likely would disrupt the delicate balancing of

17 the parties’ interest in the documents. As an example, the handling of the must run condition

18 of Coleman was a critical part of the negotiations. Only Big Rivers has the ability to provide






dated July 2, 2013

July 11, 2013

I commitments relating to the operation of Coleman. The Transaction Documents do

2 contemplate that a Market Participant other than Big Rivers could succeed to that role

3 following compliance with the provisions relating to the appointment of a successor Market

4 Participant. Yet, even the selection of a Market Participant other than Big Rivers would not

5 affect the existence of term of the Direct Agreement and protections to Big Rivers relating to

6 the transaction. Of course, the Direct Agreement must be approved for it to be available for

7 Big Rivers to recover SSR costs charged to Big Rivers.

9


11






dated July 2, 2013

July 11, 2013

I Item 15) Assuming the consent of Century, would Kenergy and Big Rivers be witting to

2 agree to a temporary extension of the existing Retail Electric Services Agreement and the

3 existing Wholesale Electric Service Agreement for the purposes of (a,) allowing the

4 commission more time to examine the implications of the proposed century Transaction,

5 and (b) allowing time for Big Rivers to obtain the approval of RUS and to resolve the credit

6 agreement default issue with CFc?

7

8 Response) Assuming the consent of Century, Kenergy and Big Rivers would be willing to

9 agree to a temporary extension of the existing contractual arrangements. Any such extension

10 of those agreements would need to be submitted to RUS for its approval prior to their effective

11 date. Given the date, however, the RUS 60 day period to determine whether it objects to entry

12 into the agreements extending the current agreements would be problematic because absent

13 prior approval by RUS, Big Rivers would not be able to enter into any such arrangements.

14 Extension of the existing agreements would also require other creditor consents, arrangements

15 for credit support from Century, and Commission approval of all arrangements that come

16 under its jurisdiction. Kenergy and Big Rivers believe accomplishing amendment of the

17 agreements as suggested would be practically impossible given the short time left between now

18 and the termination of the current Century retail service agreement.


Witnesses: Robert W. Berry andGregory J. Starheim

Page 1 of 2

JOINT APPLICATION OF KENERGY CORP. ANDBIG RWERS ELECTRIC CORPORATION



dated July 2, 2013

July 11, 2013

2 Witnesses) Robert W. Berry and

3 Gregory J. Starheim

4

.


Witnesses: Robert W. Berry andGregory J. Starheim

Page 2 of 2




dated July 2, 2013

Ju1y 11, 2013

1 Item 16) Does Kenergy contemplate that the Commission would retain regulatory

2 oversigltt over the pricing and other contractual terms of a Bilateral Agreement between

3 Kenergy and a third party Market Participant? If so, explain whether the necessity of

4 obtaining Commission approval of a Bilateral Agreement would adversely affect the ability

5 of the Hawesvilte Smelter to obtain market based pricing.

6

7 Response) Kenergy believes the Commission would have jurisdiction over a Market

$ Agreement between Kenergy and a Market Participant. Kenergy does not believe that the

9 Commission would have jurisdiction over a bilateral agreement between a Market Participant

10 and a wholesale power market counterparty. If the Commission determines that it has

11 jurisdiction over a bilateral agreement, the answer as to whether this interferes with the ability

12 of the Hawesville Smelter to obtain market based pricing depends upon how quickly the

13 bilateral agreement must be in place. Approval of a multi-year bilateral agreement would not

14 hinder the ability of the Hawesville Smelter to obtain market based pricing once the bilateral

15 agreement is approved. But if access to market pricing is based upon short term or day-ahead

16 transactions that would be problematic to implement if Commission approval is required. This

17 could perhaps be alleviated by putting in place a process similar to how Supplemental Energy

18 Transactions are handled under Kenergy’s Tariff 57.






dated July 2, 2013

July 11, 2013


3

.






dated July 2, 2013

July 11, 2013

1 Item 17) If Big Rivers were to be successful in setting Plant Wilson, how would that

2 action affect the “must rttn” status of Plant Coleman or otherwise affect the economic

3 drivers that are embedded in the proposed (‘entury Transaction? Do the documents in the

4 proposed Century Transaction providefor appropriate modUlcations in ternis and conditions

5 upoit a sale ofPlant Wilson by Big Rivers? If not, why itot?

6

7 Response) The sale of the Wilson plant will have no effect on the “must run” $SR status of

8 the Coleman plant. The SSR determination of a specific plant is based on system reliability,

9 not ownership of the generating units. The Century Transaction does not provide for

10 modifications in terms and conditions due to the sale of the Wilson plant. The Wilson plant

11 has no direct impact to the Century Transaction, therefore, no terms were negotiated to modify

12 the agreements due to the sale of the Wilson plant.

13

14


16






dated July 2, 2013

July 11, 2013

I Item 18) If Big Rivers were to be sttccessfut in setting Plant Coleman, how wotttd that

2 action affect the “must run” status of Plant Coleman or otherwise affect tlte economic

3 drivers that are embedded in tite proposed Century Transaction? Do the documents in the

4 proposed Century Transaction providefor appropriate modfications in terms and coitditioits

5 upon a sate ofPlant Coleman by Big Rivers? Ifnot, why not?

6 Response) The sale of Plant Coleman would not affect the “must-run” status of the facility.

7 Whether the facility is required to operate for reliability purposes is not affected by who owns

8 the facility. A sale of Plant Coleman also would not affect the recovery by Big Rivers of any

9 SSR Costs under the Direct Agreement to the extent those costs are incurred by Big Rivers and

10 to the extent the Direct Agreement provides for the recovery of the particular costs from

11 Century. Century’s obligations to reimburse Big Rivers for the costs subject to the Direct

12 Agreement to the extent provided in the Direct Agreement do not terminate. Recovery of any

13 amounts flowing through the “Applicable RTO Charges” similarly would not be affected to the

14 extent Big Rivers remained the Market Participant. Further, the transaction documents also

15 contemplate circumstances where Plant Coleman is not operating. For these reasons, without

16 other assumptions regarding changes in circumstances, Big Rivers does not believe the

17 transaction documents would need to be modified if Plant Coleman was sold.

18






dated July 2, 2013

July 11, 2013

Witness) Robert W. Berry

2

e






dated July 2, 2013

July 11, 2013

1 Item 19) Explain in detail the purpose of the proposed capacitor Agreement among

2 Big Rivers, Kenergy and century. Such exptanatioit should address

3 a. whether the terms and conditions of the Capacitor Agreement wit! be

4 effective if Plant Coleman is running or only if Plant cotenian is not

5 running,

6 b. whether the existence of the contemplated capacitors at the Hawesvilie

7 Sntelter will affect the “must—run” status ofPlant coleman,

$ c. whether the existence of the contemplated capacitors will affect the costs

9 that Centuiy would be expected to bear with respect to Plant Colemaut,

10 d. the implicatioits for capacitor related costs f Big Rivers were to sell

11 Plant Wilson, and

12 e. the implications for capacitor related costs f Big Rivers were to sell

1 3 Plant coleman.

14

15 Response)

16 a. The Capacitor Agreement will become effective upon execution by the

17 parties to the agreement and will remain in effect until terminated

1$ notwithstanding the operational status of Plant Coleman. Under Section






dated July 2, 2013

July 11, 2013

2.15, Century’s obligations under specified sections of the agreement will

2 terminate if Century permanently ceases smelting operations at the

3 Hawesville Smelter (as defined in the agreement). The agreement does

4 not have a stated termination date, due to its purpose. That is, Big Rivers

5 and Kenergy intend to enter into the agreement solely to accommodate

6 Century’s desire to undertake the obligations set forth in the agreement

7 relating to the Capacitor Additions (as defined in the agreement) and to

$ protect Big Rivers and Kenergy from related risks. for example, a claim

9 relating to the Capacitor Additions could be made against Big Rivers or

10 Kenergy following cessation of the operation of Plant Coleman or even

I I the Hawesville Smelter. In such case, Big Rivers and Kenergy required

12 the Capacitor Agreement to remain in effect to protect them from any

13 resulting costs, or other potential exposures.

14 b. The Capacitor Additions are planned to provide voltage support in the

15 Hawesville area when the Coleman Plant is idled. The Capacitors will

16 only provide voltage support and will not mitigate any thermal issues

17 associated with the import capability with the Coleman Plant being

18 temporary idled. The “must run”, SSR status is evaluated by both thermal




FOR APPROVAL OF CONTRACTS AND FOR A DECLARATORY ORDERCASE NO. 20 13-00221


dated July 2, 2013

July 11, 2013

1 issues as well as voltage issues. Since the Capacitors will only provide

2 voltage support, they will not by themselves eliminate the SSR, “must

3 run” condition. Big Rivers and Kenergy intend to enter into the agreement

4 to accommodate the desires of Century relating to the Capacitor Additions

5 and to protect Big Rivers and Kenergy from any resulting risks. Recital D

6 to the agreement does note that “Century intends that the Capacitor

7 Additions will support serving its requirements for electric services under

8 an Electric Service Agreement. . . as part of the Transaction, in

9 circumstances where Big Rivers has idled its Kenneth C. Coleman Plant.

10

I I c. The Capacitor Agreement will not affect any allocation of costs for

12 Electric Services or recovery of SSR Costs amongst Big Rivers, Kenergy

13 and Century. It could change the level at which an S$R condition exists

14 and thus whether SSR Costs are incurred. The agreement would not affect

1 5 Plant Wilson or Plant Coleman if either were to be sold.

16 d. Please see the response to part c., above.

17 e. Please see the response to part c., above.

18






dated July 2, 2013

July 11, 2013

Witness) Robert W. Berry

2

.






dated July 2, 2013

July 11, 2013

Item 20) For Kenergy cttstomers who are presently provided MISO power oit a backup

2 basis, wilt their access to MISO backup power be adversely impacted in any way by the

3 Kenergy-Century agreement - with or without tite C’oteinan Station iii operation?

4

5 Response) Any Kenergy customer that presently receives MISO power as backup power

6 under its retail service agreement will not have their access to MISO backup power adversely

7 impacted by the Kenergy-Century agreement, with or without the Coleman Station in

$ operation.

9

10


12






dated July 2, 2013

July 11, 2013

1 Item 21) for Kenergy customers who are presently provided MISO power on a backup

2 basis, wilt these customers see any increased MISO costs as a result of SSR costs being

3 socialized?

4

5 Response) Backup power MISO costs to Kenergy customers will not be increased by

6 socialization of SSR costs in MI$O.

7

8


10


Witness; Robert W. BerryPage 1 of 1




dated July 2, 2013

July 11, 2013

1 Item 22) for Kenergy customers who are presently provided MISO power on a backup

2 basis, wilt these custonzers see any increased MISO costs not related to SSR as a resutt of the

3 Kenergy-Century agreement?

4

5 Response) Given the variability of timing and volumes of backup power taken by Kenergy

6 customers it is impossible for Big Rivers to predict whether these customers will see any

7 increased MISO costs as described in this information request.

•8

9


11

