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

FERC Order 890 Attachment K OVERVIEW STRAWMAN –Presented FERC Little Rock technical conference. –White Paper DRAFT ATTACHMENT K –Presented FERC Atlanta technical conference. –Solicited additional feedback prior to summit.

Cleco Power Annual Transmission Planning Process

FERC Order 890 Attachment K Definitions Base Case Model Critical Energy Infrastructure Information (CEII) Confidential Information Planning Criteria Construction Plan

FERC Order 890 Attachment K Definition Comments Comment - Confidential Information –Definition too broad Cleco Response –Cleco disagrees. Consistent with FERCs model of Protective Order & confidentiality provisions of OATT. Comment - Construction Plan –What is construction plan limited to 5 years Cleco Response –Five year time frame came from Clecos budgeting dept. Cleco agrees that a plan should exist to include proposed projects up to 10 years.

FERC Order 890 Attachment K Definition Comments Comment -Base Case Model – Specify time period –Indicate changes & discrepancies in SPP & SERC models –Stakeholders should have input into SPP & SERC Cleco Response –MMWG set model time frame –Cleco submits data for Clecos CA –Data same for Cleco in both SPP & SERC –Stakeholders need to participate through SPP & SERC process not Cleco.

FERC Order 890 Attachment K Planning Process Model Development including input by stakeholders. 10 year plan (Construction Plan 1-5, Proposed Plan ). Coordinated regional planning with adjacent transmission owners.

FERC Order 890 Attachment K Planning Process Comments Comment - Input into planning criteria. –Cleco response. Planning criteria is industry accepted. Comment - Coordinated regional planning with adjacent transmission owners. –Cleco response. Agree. Only adjacent systems are monitored. Change Attach K to transmission owners.

FERC Order 890 Attachment K Coordination Stakeholders may request formation of committee. Open & welcome input from stakeholders. Post calendar of events on OASIS as well as exploder to keep stakeholders up to date on planning process as well as allow comments and input. Affected systems

FERC Order 890 Attachment K Coordination Comments Comment - Summit is to inform stakeholders rather than solicit input & no follow up. Cleco Response - Section 5.1 clearly states stakeholders may comment and provide input. Flow chart shows posting pre & post summit. Comment – Company & affiliates cant hold more than one seat on stakeholder committee Cleco Response – Cleco agrees and language will be changed.

FERC Order 890 Attachment K Coordination Comments Comment – Stakeholder may request any issue related to transmission planning be considered by committee. Cleco Response – Cleco agrees and language will be changed.

FERC Order 890 Attachment K Openness Willing to share all information, but must protect confidential information including CEII. Require requester to sign confidentiality agreement.

FERC Order 890 Attachment K Openness Comments Comment – Signing a confidentiality agreement is too excessive. Cleco Response – consistent with OATT and we are referring ONLY to confidential information. Non confidential information does not apply.

FERC Order 890 Attachment K Transparency Cleco will allow stakeholder to request base case power flow models, planning criteria, as well as assumptions for verification and validation of studies provided appropriate confidentiality agreements are in place. Post construction plan on OASIS.

FERC Order 890 Attachment K Transparency Comments Comment - Stakeholder should be allowed to download information directly rather than make a request. Cleco response – White paper does not specify downloading, only process to obtain information. Cleco is evaluating technical options including eRoom or FTP server

FERC Order 890 Attachment K Information Exchange Firm PTP reservations will be modeled during active timeframe of TSR, unless it qualifies for rollover rights (5 years or more). Network customers (native load & non-native load) submit a 10 year load forecast & DNRs.

FERC Order 890 Attachment K Comparability All stakeholders are treated comparably whether network, Point to Point, or pre 888. Models and supporting data are available for replication & duplication of results.

FERC Order 890 Attachment K Dispute Resolution Any party may dispute planning process by providing written notice of such dispute. 1.Representatives of each party shall negotiate to resolve dispute within 10 business days 2.Executive management of each party (30 days) 3.Hire an external mutually agreed upon mediator 4.File section 206 complaint with commission

FERC Order 890 Attachment K Dispute Resolution Comments Comment – Should not apply to pre 888 agreements. Cleco response – Agree, it is an OATT attachment. Comment – Who is independent regional planning authority? Cleco response – SPP

FERC Order 890 Attachment K Regional Participation Cleco participates in SPP & SERC (Entergy) model development processes. Coordinate with affected systems Joint planning meetings w/ Entergy (SERC) & SPP. Voting member of SPP TWG.

FERC Order 890 Attachment K Economic Planning Studies Separate queue on OASIS for TSR & generator interconnection. Study annually three (3) highest priorities as established by stakeholders (previously 1)

FERC Order 890 Attachment K Economic Planning Studies Comments Comment – May be impracticable to submit data at time of economic study request. Cleco response – Disagree. Execute study, scope & details must be included. Comment – Confidentially of data. Cleco response – Agree. Language will be added for confidential information.

FERC Order 890 Attachment K Economic Planning Studies Comments Comment – Cost of studies above 3 will be assigned to requesting parties. Cleco response – Agree. Language will be modified. Comment – Requesting parties be billed as study cost are incurred rather than prepayment. Cleco response – Draft language to be consistent with OATT for study cost payments.

FERC Order 890 Attachment K Cost Allocation Reliability Upgrades – LPSC rate base for planning criteria violations. Economic Upgrades –Cost allocated to beneficiary.

FERC Order 890 Attachment K Cost Allocation Comments Comment – Stakeholders should have input into Planning criteria. Cleco response – Clecos planning criteria is in accordance with NERC reliability standards & SPP criteria. Comment – Clarity is needed is defining an economic study. Cleco response – Disagree. Clearly stated that if Clecos planning criteria is not violated which is reliability, then it is an economic upgrade.

FERC Order 890 Attachment K Recovery of Planning Cost Cleco will recover cost for three economic studies annually through existing rate structure. Requestor will pay for any additional studies.

FERC Order 890 Attachment K Recovery of Planning Cost Comments Comment – Parties should not be exposed to TPs cost exceeding estimate. Clecos response – Disagree. OATT requires TCs to pay for studies.

Questions