Modifications to Planning Charter Dan Woodfin Director, System Planning 06/18/2007

Planning Review Procedures Planning Charter was written in 2003 to define procedures and responsibilities Adjustment to procedures was made in 2004, but not incorporated into Charter document RPG now has significant practical experience implementing these procedures Some things work well Some things don’t Some issues aren’t currently addressed PUCT has made achieving appropriate level of ERCOT review a requirement for transmission projects in CCN and rate case filings RPG 06/18/2007

Goals of Modifications Clarify/modify project tiers and review process associated with each tier Implement Five-Year Plan process Enhance usability of Charter document RPG 06/18/2007

Define Four Tiers of Projects RPG Review and Comment ERCOT Independent Review ERCOT BOD Endorsement TIER 1 21 Day RPG Comment Period 28 Day Study Mode Period (if needed) 90 Day ERCOT Independent Review TAC Comment ERCOT Board Endorsement ERCOT Endorsement Letter RPG Review and Comment ERCOT Independent Review TIER 2 21 Day RPG Comment Period 28 Day Study Mode Period (if needed) 90 Day ERCOT Independent Review ERCOT Endorsement Letter RPG Review and Comment TIER 3 21 Day RPG Comment Period 28 Day Study Mode Period (if needed) ERCOT Endorsement Letter No ERCOT Review TIER 4 RPG 06/18/2007

Categorization of Projects Radial lines, repair equipment or add static reactive, add equipt that doesn’t change rating? This Amount is open for discussion n >$50M Capital Cost y RPG Review and Comment ERCOT Independent Review ERCOT BOD Endorsement TIER 1 Proposed Project n ≥345 kV? y 345 CCN Required? y y RPG Review and Comment ERCOT Independent Review TIER 2 n n CCN Required? y n RPG Review and Comment TIER 3 This Amount is open for discussion y No ERCOT Review TIER 4 <$10M Capital Cost? Unresolvable Study Mode or Congestion Issues? n n y RPG 06/18/2007

Categorization All projects over $50M go to BOD 345kV projects less than $50M also go to BOD if they need CCN 345kV projects less than $50M that do not need CCN do not go to BOD but get an EIR 138 and 69kV projects less than $50M that need CCN do not go to BOD but get an EIR 138 and 69kV projects less than $50M but greater than $10M and that do not need a CCN get an RPG review, but no EIR unless there are unresolved issues after the comment period and study mode 138 and 69kV projects that are less than $10M and do not need a CCN do not get ERCOT review The implication of this is that a $49 million 138kV upgrade project could be endorsed after only the 21 day stakeholder comment. Is this a sufficient review, or does the $50 million criteria need to be lowered? RPG 06/18/2007

Voltage level of project is based on highest rated-voltage element Clarifications Voltage level of project is based on highest rated-voltage element Improvements that need to be undertaken together in order to achieve desired result should be bundled into single Project ERCOT Staff can raise Tier of a project based on stakeholder comments, analysis and impacts RPG 06/18/2007

Five Year Plan Lists all projects that change existing topology, by year, including Tier 4 projects that do not require RPG review Identifies projects to meet identified needs for reliability and economic criteria Provides review similar to that required in RPG Review process for Tier 1 and Tier 2 (and Tier 3?) projects Will use similar process to last year EXCEPT: More two-way communication More posting of intermediate cases and binding constraints More focus on consensus decisions as to which projects are needed TOs convince ERCOT or ERCOT convinces TOs – but we should strive for agreement More on this process in separate presentation RPG 06/18/2007

Charter Changes for Five Year Plan Language to be added to Charter to explain Five-Year Plan development Projects that are included in Five Year Plan receive expedited processing when they reach decision point and are submitted RPG 06/18/2007

Expedited Review of 5-Yr Plan Projects RPG Review and Comment ERCOT Independent Review ERCOT BOD Endorsement TIER 1 TIER 2 TIER 3 21 Day RPG Comment Period 28 Day Study Mode Period 90 Day ERCOT Independent Review TAC Comment ERCOT Board Endorsement ERCOT Endorsement Letter 21 Day RPG Comment Period 28 Day Study Mode Period 90 Day ERCOT Independent Review ERCOT Endorsement Letter Projects that were evaluated in the Five Year Plan development skip the 90 Day ERCOT Independent Review However, if comments show that significant changes have occurred since 5-Yr plan was developed, or that there are relevant factors that were not considered in the Five Year Plan analysis, additional study may be done. 21 Day RPG Comment Period 28 Day Study Mode Period ERCOT Endorsement Letter RPG 06/18/2007

Process for Expedited Review Utility reaches “decision point” on project that is included in Five Year Plan Utility submits limited project proposal: Timing Estimated Cost “Parts List” Stakeholder review (<21 days?) occurs but no EIR unless comments require it RPG 06/18/2007

Special Categories of Reviews - 1 TO Criteria Projects Some transmission owners submit projects based on internal planning criteria that are more stringent than NERC and ERCOT criteria These projects will be reviewed in the appropriate Tier, except that projects normally falling in Tier 1 will be treated as Tier 2 ERCOT will not endorse these projects, but may concur that the project is the best way to meet the stated need, based on stakeholder comment and ERCOT Independent Review (if required) RPG 06/18/2007

Special Categories of Reviews - 2 Projects “associated with” Generation Interconnections There is currently a wide disparity between TOs as to what projects are considered to be “RPG-reviewable” projects and what projects are treated as “associated with generation interconnections” Current charter says “generation interconnection lines” more than five miles in length will be reviewed by RPG Proposals for clarifying which projects need open RPG review? Generation Interconnection Procedure changes tentatively scheduled for discussion at next RPG RPG 06/18/2007

Project Revisions Significant changes to planned Tier 1 and Tier 2 projects that have already received an endorsement from ERCOT should be communicated to ERCOT for review: Change of endpoint Addition or change of networked intermediate station Lower rating Change in scope of project (e.g. double rather than single circuit) A RPG comment period will be conducted if ERCOT determines that it is warranted. If comments are received, review will follow process for next lower project tier. RPG 06/18/2007

Revisions to Charter Document Changes necessary to include process changes described elsewhere in this presentation Elimination of “textbook” section, references to specific models and any reliability criteria Inclusion of economic planning criteria, as previously endorsed by TAC RPG 06/18/2007

CEII Considerations Descriptions for any contingencies that cause voltage collapse, instability or significant cascading should be redacted from project submissions and reviews. The non-redacted versions of these documents will be shared with ERCOT and transmission owner planning staffs via the new secure website RPG 06/18/2007