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Transmission Planning in
   an RTO Environment
        JT Smith
         9/16/2011
The continuing growth of the MISO’s value proposition
 depends on transmission expansion

1600
               Benefit by Value Driver1                               $605-$673              ($254)
                          (in $ millions)
1400
                                                                                                                  $1,253-
                                                                                                                   1,634
1200


1000
                                                   $34-$42
                              $546-$604

 800

                                                                                                                                       $648-$874
 600


 400
           $322-$482


 200


   0
       Improved Reliability Market Commitment   Wind Integration   Benefits Driven by   Midwest ISO Cost
                                                                                            MISO Cost        Total Net Benefits   Adjusted Total Net
                               and Dispatch                          Load / Supply          Structure
                                                                                             Structure                                 Benefits
                                                                       Balance



                                                                                        1Figures   shown reflect annual benefits and         2
                                                                                                        costs for 2010
MISO Planning Objectives
Fundamental               The development of a comprehensive expansion plan that meets
Goal                      reliability needs, policy needs, and economic needs


                          •    Make the benefits of an economically efficient energy market
                               available to customers by providing access to the lowest electric
                               energy costs
MISO                      •    Provide a transmission infrastructure that safeguards local and
Board of                       regional reliability and supports interconnection-wide reliability
Director                  •    Support state and federal energy policy objectives by planning for
Planning                       access to a changing resource mix
Principles*               •    Provide an appropriate cost mechanism that ensures the
                               realization of benefits over time is commensurate with the
                               allocation of costs
                          •    Develop transmission system scenario models and make them
                               available to state and federal energy policy makers to provide
                               context and inform the choices they face



              * As modified and approved by MISO Board of Directors System Planning Committee   3
              5/16/2011; pending full board approval
MISO’s transmission planning process is focused on minimizing
the total cost of delivered power to consumers: energy, capacity
and transmission

                 High Capacity Cost                              High Transmission Cost
                 Low Transmission Cost                                Low Capacity Cost


                                               Goal
                                          Minimum Total Cost:
                                          Energy, Capacity and
                                              Transmission
  Total
  Cost ($)




             H                             Capacity Cost                                  L

             L                           Transmission Cost                                H
Planning Model Evolution

          In order to achieve its planning objectives, MISO
    has transformed its transmission expansion planning model;
    this process will continue to mature as experience is gained


Reliability-Based Model               Value-Based Model
• Focused primarily on grid           • Focused on value while maintaining
  reliability                           reliability
• Typically considers a short time    • Reflects appropriate project time
  horizon                               scales
• Seeks to minimize transmission      • Seeks to identify transmission
  build                                 infrastructure that maximizes value
                                      • Identification of the comprehensive
                                        value of projects




                                                                              5
MISO Transmission Expansion Plan (MTEP)


                                                •   The MTEP is the culmination of all
             Top Down Planning                      planning efforts performed by
                                                    MISO during a given planning
                                                    cycle
                                                •   This planning process is
                                     Inter-         consistent with the Board of
  Policy
Assessment
             MTEP                  connection
                                     Queue          Directors Planning Principles
                                                •   Each of the four pillars of the
                                                    MISO Planning Approach informs
                                                    the other, resulting in a fully
                                                    integrated view of project value
                                                    inclusive of reliability, market
              Bottom Up Planning                    efficiency, public policy, and other
                                                    value drivers across all planning
                                                    horizons


                                                                                  6
MISO Value Based Planning

  STEP 1: MULTI-FUTURE
                            STEP 7: COST ALLOCATION
  REGIONAL RESOURCE
                                    ANALYSIS
     FORECASTING
                                                      •   Objective of value based
                                                          planning is to develop a
                                                          wide range of future
 STEP 2: SITE-GENERATION
AND PLACE IN POWERFLOW                                    scenarios
          MODEL

                                STEP 6: EVALUATE
                                                          – The “best” transmission plan
                            CONCEPTUAL TRANSMISSION
                                 FOR RELIABILITY
                                                            may be different in each
STEP 3: DESIGN CONCEPTUAL
                                                            policy-based future scenario
TRANSMISSION OVERLAYS BY
   FUTURE IF NECESSARY
                                                          – The transmission plan that is
                                                            the best-fit (most robust)
                                                            against all these scenarios
                                                            should offer the most future
 STEP 4: TEST CONCEPTUAL      STEP 5: CONSOLIDATE &         value in supporting the future
    TRANSMISSION FOR         SEQUENCE TRANSMISSION
       ROBUSTNESS                      PLANS                resource mix




                                                                                     7
Stakeholder Process

• FERC Order 890 Provides for Open and
  Transparent Planning

• Order 890 Planning Principles:
  •   Coordination           •   Comparability
  •   Openness               •   Dispute Resolution
  •   Transparency           •   Regional Participation
  •   Information Exchange   •   Congestion Studies




                                                          8
Conditions Precedent to Increased
       Transmission Build




                                    9
Required: Policy Consensus
Current State Renewable Portfolio Standards
As of 07/27/2011
                                              •   Renewable Portfolio
                                                  Standards passed by all
                                                  MISO states except
                                                  Kentucky
                                              •   Proposed federal
                                                  legislation would drive
                                                  additional homogeneity
                                                  around resource
                                                  requirements
                                                   –   Possible National
                                                       Renewable Portfolio
                                                       Standard of 15 - 20%
                                                   –   Carbon Reductions
                                              •   Increasing number of
                                                  states with demand
                                                  response and energy
                                                  efficiency programs

Planned and Existing Wind as of 3/28/3011




                                                                        10
Required: Cost Allocation and Recovery Mechanism

                                             The cost allocation goal is
             Multi Value Projects             – A fair system
                                              – Get transmission built to
Regional                                        address a wide variety of
                                                goals
                                              – Maintain the MISO Value
                                                Proposition

             • Reliability (RECB I)          State participation in the
 Local       • Market Efficiency (RECB II)    process reduces recovery
             • Generator Interconnection
                                              risk to the extent
               Projects                        – Investments are deemed
                                                 to be in the public interest
             • Other Direct Assigned
                                                 and
               Projects
                                               – The cost allocation is seen
                                                 as “fair”

                                                                        11
Required: Robust Business Case

• The following slides will walk through the
  RGOS/MVP process that utilized the MISO
  Value Based Planning Process as a framework
  for transmission development




                                                12
As an increasing number of renewable energy mandates were
passed by MISO states, analyses were performed to determine a
least cost generation siting methodology




                    Energy Zone Siting Approaches and Costs




           The least-cost approach to generation siting, when both
           generation and transmission capital costs are considered, is   13
           a combination of local and regional generation locations.
This methodology resulted in a set of energy zones
which were used as the locations for incremental
generation in continuing analyses

                       Incremental Energy Zones




        These energy zones were created by balancing relative wind
        capacities along with distances from natural gas pipelines and   14
        existing transmission infrastructure
Native Voltage Alternative




                             15
765 kV Voltage Alternative




                             16
How Do You Decide On a Strategy?

 • Robustness testing
    – How does an alternative perform in a variety of future scenarios?
    – Are significantly greater economic benefits projected in one case
      over the other?
 • Faith based scenario evaluation
    – What would you have to believe?
    – Actively test important assumptions
 • Delay choosing as long as possible
    – Without jeopardizing legal requirements
    – Without risking wasted investment




                                                                      17
What Would You Have To Believe…
• For the higher mileage lower voltage strategy to be
  superior ?
  • Energy policies will not expand beyond the current laws, thus the
    actual construction will “most likely” stop short of full
    implementation


• For the higher voltage lower mileage strategy to be
  superior?
  • Increasingly aggressive Energy Policy objectives will significantly
    expand the objective and thus providing a more robust system
    up front leads to significant flexibility and saved time




                                                                          18
Should We Wait to Build Until Consensus
           on Strategy is Achieved?
•    No - we can delay decision – for a bit
     - by making a set of investments with
     relatively low risk/reward ratio

•    Multi Value Project portfolio
     candidates would meet criteria such
     as the following:
                                                      Candidate
      – Support renewable integration at
          a level likely to still be required
                                                765     MVP        345
          under future policy shifts                   Portfolio
      – Retain the flexibility to support
          the choice of 345 kV or 765 kV
          as the overall strategy
      – Provide sufficient value to be in
          the public interest on a stand
          alone basis


                                                                         19
Benefits of Candidate MVP Portfolio
• Evaluation of first Candidate MVP Portfolio is nearing completion
  including business case development to document the value provided
  by the portfolio.
• Goals of Multi Value Projects
    – facilitate the integration of large amounts of location constrained
      resources, including renewable generation resources
    – support MISO member and customer compliance with evolving state and
      federal energy policy requirements
    – enable MISO to address multiple reliability needs and provide economic
      opportunities through regional transmission development
• Benefits include reducing costs associated with: congestion and fuel,
  operating reserves, system planning reserves, transmission line
  losses; wind turbine investment, etc…
• Benefit of the portfolio as a whole is generally greater than the sum of
  the benefits of its parts; looking at one element in isolation gives an
  incomplete picture of the total benefits

                                                                               20
These evaluations culminated in the
recommendation of the 2011 MVP Portfolio
                                • The 2011 MVP Portfolio
                                  Analysis is the culmination of
                                  MISO’s planning efforts to
                                  meet the public policy
                                  mandates of the MISO states,
                                  while simultaneously
                                  minimizing the total cost of
                                  delivered power to consumers
                                • This analysis serves to justify
                                  and demonstrate the value of
                                  a regional portfolio of projects,
                                  which brings multiple benefits
                                  to stakeholders throughout the
                                  MISO footprint.
                                • B/C of 1.7/1 to 2.7/1 with
                                  sensitivity cases as high as
                                  5.4/1




                                                           21
CapX 2020
• Participants
    • Central MN Municipal Power Agency
    • Dairyland Power Cooperative
    • Great River Energy
    • Minnesota Power
    • Minnkota Power Cooperative
    • Missouri River Energy Services
    • Otter Tail Power Company
    • Rochester Public Utilities
    • Southern MN Municipal Power Agency
    • WPPI Energy
    • Xcel Energy
• Nearly 700 miles of transmission
• Costs estimated to be $1.9 billion
• Projects support local reliability and
regional transfer of energy
• Projects are a core assumption in the
MISO MVP development



                                                                  22
                   Information source: http://www.capx2020.com/
Eastern Interconnect Planning Collaborative (EIPC)

• DOE Objective
    – Facilitate the development / strengthening of capabilities to
      prepare analyses of transmission requirements under a broad
      range of alternative futures and develop long-term
      interconnection-wide transmission expansion plans.
• DOE Expectations
    – Improved
        • Regional, inter-regional, and interconnection-level coordination on long-term
          electricity policy and planning
        • Quality of information available to state and federal policymakers and
          regulators
        • Understanding by stakeholders of Long-term transmission requirements
          under a wide range of futures
    – Facilitation and acceleration of development of renewable or
      other low-carbon generation capacity
                                                                                     23
EIPC - Approach

 •   Establishment of a Multi-Constituency Stakeholder
     Process
 •   Roll Up and Analysis of Approved Regional Plans
 •   Development of Inter-Regional Resource
     Expansion Scenarios
 •   Development of Inter-Regional Transmission
     Expansion Options
 •   Prepare/Submit Reports to DOE




                                                     24
Continuing Evolution: FERC Order 1000 -
Transmission Planning and Cost Allocation
 • FERC issued Order 1000 on new transmission planning
   and cost allocation requirements to build on the
   principles identified in Order 890
    – Coordination; Openness; Transparency; Information Exchange;
      Comparability; Dispute Resolution; Regional Participation; Economic
      Planning Studies and Cost Allocation
 • The new rules address:
    – Participation in a regional planning process
    – Planning for public policy requirements, such as renewable mandates
    – Coordinated planning and improved cost sharing for interregional
      facilities
    – Elimination of federal “right of first refusal” for projects identified in a
      regional planning process with regional cost allocation
    – Principles for regional and interregional cost allocation


                                                                                25
Appendix




           26
MTEP Activities
              Top Down                  Bottom Up                   Interconnection            Policy
              Planning                  Planning                    Queue                      Assessment
Description   •Develop solutions for    Ensure plans identified     Evaluate specific          Analyze the impacts of
               outstanding needs,       by the member               interconnection requests   changes in state or
              •Test effectiveness of    Transmission Owners         and Place resulting        federal policy on the
               input plans and seek     are sufficient to address   upgrades in base           MISO system
               efficiencies             reliability standards and   expansion model
                                        form an efficient set of
                                        expansions to meet
                                        identified needs




Examples      Regional Generator        MTEP reliability analysis   Interconnection Studies,   EPA Regulations study,
              Outlet Study, Candidate                               System Planning and        Eastern Wind Integration
              MVP Portfolio, MTEP                                   Analysis, Detailed         Transmission Study
              economic analysis, Long                               Planning Phase
              Term Assessment

Tools         Production Cost models    Load flow models            Load flow models           All
              (PROMOD), Generation      (PSS/E)                     (PSS/E)
              Expansion (EGEAS),
              Loss of Load (MARS)




                                                                                                                27
MISO Cost Allocation Overview
Allocation Category Driver(s)                                Allocation Overview

Baseline Reliability      NERC Reliability Criteria          Primarily shared locally through Line
Project                                                      Outage Distribution Factor
                                                             Methodology; 345 kV and above 20%
                                                             postage stamp to load

Generator                 Interconnection Request            Paid for by requestor; 345 kV and
Interconnection                                              above 10% postage stamp to load
Project

Market Efficiency         Reduce market congestion           Distribute to planning regions
Project1                  when benefits are 1.2 to 3         commensurate with expected benefit;
                          times in excess of cost            345 kV and above 20% postage stamp
                                                             to load
Multi Value Project       Address energy policy laws         100% postage stamp to load
                          and/or provide widespread
                          benefits across footprint


                                                      1. Market Efficiency Project cost allocation
                                                      methodology currently under review at the      28
                                                      RECBTF

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RTO transmission planning drives grid value

  • 1. Transmission Planning in an RTO Environment JT Smith 9/16/2011
  • 2. The continuing growth of the MISO’s value proposition depends on transmission expansion 1600 Benefit by Value Driver1 $605-$673 ($254) (in $ millions) 1400 $1,253- 1,634 1200 1000 $34-$42 $546-$604 800 $648-$874 600 400 $322-$482 200 0 Improved Reliability Market Commitment Wind Integration Benefits Driven by Midwest ISO Cost MISO Cost Total Net Benefits Adjusted Total Net and Dispatch Load / Supply Structure Structure Benefits Balance 1Figures shown reflect annual benefits and 2 costs for 2010
  • 3. MISO Planning Objectives Fundamental The development of a comprehensive expansion plan that meets Goal reliability needs, policy needs, and economic needs • Make the benefits of an economically efficient energy market available to customers by providing access to the lowest electric energy costs MISO • Provide a transmission infrastructure that safeguards local and Board of regional reliability and supports interconnection-wide reliability Director • Support state and federal energy policy objectives by planning for Planning access to a changing resource mix Principles* • Provide an appropriate cost mechanism that ensures the realization of benefits over time is commensurate with the allocation of costs • Develop transmission system scenario models and make them available to state and federal energy policy makers to provide context and inform the choices they face * As modified and approved by MISO Board of Directors System Planning Committee 3 5/16/2011; pending full board approval
  • 4. MISO’s transmission planning process is focused on minimizing the total cost of delivered power to consumers: energy, capacity and transmission High Capacity Cost High Transmission Cost Low Transmission Cost Low Capacity Cost Goal Minimum Total Cost: Energy, Capacity and Transmission Total Cost ($) H Capacity Cost L L Transmission Cost H
  • 5. Planning Model Evolution In order to achieve its planning objectives, MISO has transformed its transmission expansion planning model; this process will continue to mature as experience is gained Reliability-Based Model Value-Based Model • Focused primarily on grid • Focused on value while maintaining reliability reliability • Typically considers a short time • Reflects appropriate project time horizon scales • Seeks to minimize transmission • Seeks to identify transmission build infrastructure that maximizes value • Identification of the comprehensive value of projects 5
  • 6. MISO Transmission Expansion Plan (MTEP) • The MTEP is the culmination of all Top Down Planning planning efforts performed by MISO during a given planning cycle • This planning process is Inter- consistent with the Board of Policy Assessment MTEP connection Queue Directors Planning Principles • Each of the four pillars of the MISO Planning Approach informs the other, resulting in a fully integrated view of project value inclusive of reliability, market Bottom Up Planning efficiency, public policy, and other value drivers across all planning horizons 6
  • 7. MISO Value Based Planning STEP 1: MULTI-FUTURE STEP 7: COST ALLOCATION REGIONAL RESOURCE ANALYSIS FORECASTING • Objective of value based planning is to develop a wide range of future STEP 2: SITE-GENERATION AND PLACE IN POWERFLOW scenarios MODEL STEP 6: EVALUATE – The “best” transmission plan CONCEPTUAL TRANSMISSION FOR RELIABILITY may be different in each STEP 3: DESIGN CONCEPTUAL policy-based future scenario TRANSMISSION OVERLAYS BY FUTURE IF NECESSARY – The transmission plan that is the best-fit (most robust) against all these scenarios should offer the most future STEP 4: TEST CONCEPTUAL STEP 5: CONSOLIDATE & value in supporting the future TRANSMISSION FOR SEQUENCE TRANSMISSION ROBUSTNESS PLANS resource mix 7
  • 8. Stakeholder Process • FERC Order 890 Provides for Open and Transparent Planning • Order 890 Planning Principles: • Coordination • Comparability • Openness • Dispute Resolution • Transparency • Regional Participation • Information Exchange • Congestion Studies 8
  • 9. Conditions Precedent to Increased Transmission Build 9
  • 10. Required: Policy Consensus Current State Renewable Portfolio Standards As of 07/27/2011 • Renewable Portfolio Standards passed by all MISO states except Kentucky • Proposed federal legislation would drive additional homogeneity around resource requirements – Possible National Renewable Portfolio Standard of 15 - 20% – Carbon Reductions • Increasing number of states with demand response and energy efficiency programs Planned and Existing Wind as of 3/28/3011 10
  • 11. Required: Cost Allocation and Recovery Mechanism The cost allocation goal is Multi Value Projects – A fair system – Get transmission built to Regional address a wide variety of goals – Maintain the MISO Value Proposition • Reliability (RECB I) State participation in the Local • Market Efficiency (RECB II) process reduces recovery • Generator Interconnection risk to the extent Projects – Investments are deemed to be in the public interest • Other Direct Assigned and Projects – The cost allocation is seen as “fair” 11
  • 12. Required: Robust Business Case • The following slides will walk through the RGOS/MVP process that utilized the MISO Value Based Planning Process as a framework for transmission development 12
  • 13. As an increasing number of renewable energy mandates were passed by MISO states, analyses were performed to determine a least cost generation siting methodology Energy Zone Siting Approaches and Costs The least-cost approach to generation siting, when both generation and transmission capital costs are considered, is 13 a combination of local and regional generation locations.
  • 14. This methodology resulted in a set of energy zones which were used as the locations for incremental generation in continuing analyses Incremental Energy Zones These energy zones were created by balancing relative wind capacities along with distances from natural gas pipelines and 14 existing transmission infrastructure
  • 16. 765 kV Voltage Alternative 16
  • 17. How Do You Decide On a Strategy? • Robustness testing – How does an alternative perform in a variety of future scenarios? – Are significantly greater economic benefits projected in one case over the other? • Faith based scenario evaluation – What would you have to believe? – Actively test important assumptions • Delay choosing as long as possible – Without jeopardizing legal requirements – Without risking wasted investment 17
  • 18. What Would You Have To Believe… • For the higher mileage lower voltage strategy to be superior ? • Energy policies will not expand beyond the current laws, thus the actual construction will “most likely” stop short of full implementation • For the higher voltage lower mileage strategy to be superior? • Increasingly aggressive Energy Policy objectives will significantly expand the objective and thus providing a more robust system up front leads to significant flexibility and saved time 18
  • 19. Should We Wait to Build Until Consensus on Strategy is Achieved? • No - we can delay decision – for a bit - by making a set of investments with relatively low risk/reward ratio • Multi Value Project portfolio candidates would meet criteria such as the following: Candidate – Support renewable integration at a level likely to still be required 765 MVP 345 under future policy shifts Portfolio – Retain the flexibility to support the choice of 345 kV or 765 kV as the overall strategy – Provide sufficient value to be in the public interest on a stand alone basis 19
  • 20. Benefits of Candidate MVP Portfolio • Evaluation of first Candidate MVP Portfolio is nearing completion including business case development to document the value provided by the portfolio. • Goals of Multi Value Projects – facilitate the integration of large amounts of location constrained resources, including renewable generation resources – support MISO member and customer compliance with evolving state and federal energy policy requirements – enable MISO to address multiple reliability needs and provide economic opportunities through regional transmission development • Benefits include reducing costs associated with: congestion and fuel, operating reserves, system planning reserves, transmission line losses; wind turbine investment, etc… • Benefit of the portfolio as a whole is generally greater than the sum of the benefits of its parts; looking at one element in isolation gives an incomplete picture of the total benefits 20
  • 21. These evaluations culminated in the recommendation of the 2011 MVP Portfolio • The 2011 MVP Portfolio Analysis is the culmination of MISO’s planning efforts to meet the public policy mandates of the MISO states, while simultaneously minimizing the total cost of delivered power to consumers • This analysis serves to justify and demonstrate the value of a regional portfolio of projects, which brings multiple benefits to stakeholders throughout the MISO footprint. • B/C of 1.7/1 to 2.7/1 with sensitivity cases as high as 5.4/1 21
  • 22. CapX 2020 • Participants • Central MN Municipal Power Agency • Dairyland Power Cooperative • Great River Energy • Minnesota Power • Minnkota Power Cooperative • Missouri River Energy Services • Otter Tail Power Company • Rochester Public Utilities • Southern MN Municipal Power Agency • WPPI Energy • Xcel Energy • Nearly 700 miles of transmission • Costs estimated to be $1.9 billion • Projects support local reliability and regional transfer of energy • Projects are a core assumption in the MISO MVP development 22 Information source: http://www.capx2020.com/
  • 23. Eastern Interconnect Planning Collaborative (EIPC) • DOE Objective – Facilitate the development / strengthening of capabilities to prepare analyses of transmission requirements under a broad range of alternative futures and develop long-term interconnection-wide transmission expansion plans. • DOE Expectations – Improved • Regional, inter-regional, and interconnection-level coordination on long-term electricity policy and planning • Quality of information available to state and federal policymakers and regulators • Understanding by stakeholders of Long-term transmission requirements under a wide range of futures – Facilitation and acceleration of development of renewable or other low-carbon generation capacity 23
  • 24. EIPC - Approach • Establishment of a Multi-Constituency Stakeholder Process • Roll Up and Analysis of Approved Regional Plans • Development of Inter-Regional Resource Expansion Scenarios • Development of Inter-Regional Transmission Expansion Options • Prepare/Submit Reports to DOE 24
  • 25. Continuing Evolution: FERC Order 1000 - Transmission Planning and Cost Allocation • FERC issued Order 1000 on new transmission planning and cost allocation requirements to build on the principles identified in Order 890 – Coordination; Openness; Transparency; Information Exchange; Comparability; Dispute Resolution; Regional Participation; Economic Planning Studies and Cost Allocation • The new rules address: – Participation in a regional planning process – Planning for public policy requirements, such as renewable mandates – Coordinated planning and improved cost sharing for interregional facilities – Elimination of federal “right of first refusal” for projects identified in a regional planning process with regional cost allocation – Principles for regional and interregional cost allocation 25
  • 26. Appendix 26
  • 27. MTEP Activities Top Down Bottom Up Interconnection Policy Planning Planning Queue Assessment Description •Develop solutions for Ensure plans identified Evaluate specific Analyze the impacts of outstanding needs, by the member interconnection requests changes in state or •Test effectiveness of Transmission Owners and Place resulting federal policy on the input plans and seek are sufficient to address upgrades in base MISO system efficiencies reliability standards and expansion model form an efficient set of expansions to meet identified needs Examples Regional Generator MTEP reliability analysis Interconnection Studies, EPA Regulations study, Outlet Study, Candidate System Planning and Eastern Wind Integration MVP Portfolio, MTEP Analysis, Detailed Transmission Study economic analysis, Long Planning Phase Term Assessment Tools Production Cost models Load flow models Load flow models All (PROMOD), Generation (PSS/E) (PSS/E) Expansion (EGEAS), Loss of Load (MARS) 27
  • 28. MISO Cost Allocation Overview Allocation Category Driver(s) Allocation Overview Baseline Reliability NERC Reliability Criteria Primarily shared locally through Line Project Outage Distribution Factor Methodology; 345 kV and above 20% postage stamp to load Generator Interconnection Request Paid for by requestor; 345 kV and Interconnection above 10% postage stamp to load Project Market Efficiency Reduce market congestion Distribute to planning regions Project1 when benefits are 1.2 to 3 commensurate with expected benefit; times in excess of cost 345 kV and above 20% postage stamp to load Multi Value Project Address energy policy laws 100% postage stamp to load and/or provide widespread benefits across footprint 1. Market Efficiency Project cost allocation methodology currently under review at the 28 RECBTF