1 The Costs of Participating in Restructured Wholesale Markets American Public Power Association February 5, 2007 William M. Bateman Robert C. Smith

2 Introduction The presentation is an overview of the study. Study examined operational and administrative cost of 6 FERC Approved Regional Transmission Organizations (“RTO”). –Southwest Power Pool (“SPP”) –California ISO (“CAISO”) –ISO New England (“ISO-NE”) –Midwest ISO (“MISO”) –New York ISO (“NYISO”) –PJM Interconnection (“PJM”)

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4 Regional Transmission Organization (RTO) Created in Order 2000 by the Federal Energy Regulatory Commission (“FERC”) to further the Commission’s goal of creating competitive wholesale electric markets. RTOs are independent organizations that are responsible for the operation and reliability of the grid. Three Stages of Development –Pre-Day 1 –Day 1 –Day 2

5 Relative Sizes of RTOs 2005 Load (MWh) Miles of Transmission Generation Capacity (MW) PJM682,317,60756,070164,634 MISO652,763,61493,600162,981 CAISO236,925,18325,52655,039 SPP201,511,49452,30145,950 NYISO167,204,05510,77537,524 ISO-NE136,355,3098,00032,000

6 RTO Cost Recovery Costs are recovered through FERC approved charges in the RTO’s tariff. Charges are generally assessed on a per megawatt-hour basis. Mix of “Formula Rates” and “Stated Rates”. The number and type of charges vary widely among the RTOs. Some RTOs have one or two cost recovery mechanisms, or schedules, while others have a dozen or more.

7 Study Methodology The study examined RTO costs for Cost data taken from FERC Form 1 filed by each RTO. Each cost examined to determine how much it contributed the RTOs overall cost. Cost classified as either Operational or Administrative. –Operational costs are costs related to running the grid. –Administrative costs are other costs incurred by the RTOs. Cost are actual dollars as reported on the Form 1.

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9 Overall Results

10 Overall Results $/MWh Period2005AverageHighLow ISO-NE $0.912$0.721$0.912$0.497 NYISO $0.892$0.740$0.892$0.574 CAISO $0.724$0.829$0.963$0.683 MISO $0.419$0.296$0.419$0.196 PJM $0.393$0.583$0.873$0.393 SPP2005$0.240

11 Overall Results For the study period, the $/MWh cost for Day 2 RTOs ranged from $0.393/MWh to $0.963/MWh The Day 2 RTOs had a combined 5 year average cost of $0.658/MWh The total cost is about 75% Administrative and about 25% Operational.

12 Overall Results Categories with the Largest Costs Administrative –Depreciation Costs –Regulatory Costs –Consulting Fees/Outside Services –Administrative & General Salaries Operational –Load Dispatching

13 Overall Results There is a significant variation in costs between the RTOs. RTOs use different methods to account for and report costs. FERC Order 668 established a new set of FERC accounting codes. RTOs will begin using these new codes for calendar year 2006.

14 Southwest Power Pool (SPP) Day 1 RTO. Approved in October Only one year of data available: 2005 Average cost was $0.240/MWh 176 employees Administrative & General Salaries, Regulatory Costs and Consulting Fees/Outside Services were the largest expenses. SPP is implementing an Energy Imbalance Market. Expect that SPP’s operational cost will increase.

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16 California ISO (CAISO) Day 2 RTO. Started Data for Average cost was $0.829/MWh 489 employees Rents, Depreciation expense, Administrative & General Salaries, and load dispatching were the biggest expenses.

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19 ISO New England (ISO-NE) Day 2 RTO. Approved Effectively operated as a Day 2 RTO since Data for Average cost was $0.721/MWh 400 employees Administrative & General Salaries, Depreciation expense and Consulting fees/Outside services were the largest expenses.

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22 Midwest ISO (MISO) Day 2 RTO. Approved as Day 1 in December Approved as Day 2 in Data for Average cost was $0.296/MWh 646 employees Administrative & General Salaries, Consulting fees/Outside services, Regulatory debits, and Depreciation expense have been the largest expenses.

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25 New York ISO (NYISO) Day 2 RTO. Started Data for Average cost was $0.740/MWh 400 employees Administrative & General Salaries, Consulting fees/Outside services and Depreciation expense have been the largest expenses.

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28 PJM Interconnection (PJM) Day 2 RTO. Approved Data for Average cost was $0.583/MWh 500 employees Administrative & General Salaries, Load dispatching and Depreciation expense have been the largest expenses.

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31 Summary 1.Cost recovery is accomplished through various charges specified in the RTO tariff. 2.Total operational and administrative costs vary widely by RTO. 3.The Day 2 RTOs 5 year average cost was $0.658/MWh and the study period cost ranged from $0.393/MWh to $0.963/MWh. 4.Some RTO’s are seeing their $/MWh cost increase, while others are seeing it decrease. The overall $/MWh cost is stabilizing as the markets mature.