12 power marketers, 10independent...feb 05, 2016 · the honorable kimberly d. bose february 5,...

February 5, 2016 The Honorable Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C. 20426

Re: Southwest Power Pool, Inc., Docket No. ER16-____ Submission of Tariff Revisions Regarding Frequently Constrained Areas

Dear Secretary Bose: Pursuant to section 205 of the Federal Power Act1 and Part 35 of the Regulations of the Federal Energy Regulatory Commission ("Commission" or "FERC"),2 Southwest Power Pool, Inc. ("SPP"), as authorized by its independent Board of Directors, submits revisions to its Open Access Transmission Tariff3 necessary to update the Tariff’s list of Frequently Constrained Areas ("FCAs") in accordance with the findings of the SPP Market Monitoring Unit’s ("MMU") recent reevaluation. SPP requests that the Commission accept the proposed revisions for filing and allow the revisions to become effective April 5, 2016. I. BACKGROUND A. SPP SPP is a Commission-approved Regional Transmission Organization ("RTO").4 It is an Arkansas non-profit corporation with its principal place of business in Little Rock, Arkansas. SPP currently has 94 members, including 16 investor-owned utilities, 14 municipal systems, 20 generation and transmission cooperatives, 8 state agencies, 13 independent power producers, 12 power marketers, 10 independent 1 16 U.S.C. § 824d.

2 18 C.F.R. § 35.13.

3 Southwest Power Pool, Inc., Open Access Transmission Tariff, Sixth Revised Volume No. 1 ("Tariff").

4 Sw. Power Pool, Inc., 109 FERC ¶ 61,009 (2004), order on reh’g, 110 FERC ¶ 61,137 (2005).

The Honorable Kimberly D. Bose February 5, 2016 of 6 transmission companies, and 1 federal agency. As an RTO, SPP (1) administers, across the facilities of SPP's Transmission Owners, open access transmission service over approximately 56,000 miles of transmission lines covering portions of Arkansas, Iowa, Kansas, Louisiana, Minnesota, Missouri, Montana, Nebraska, New Mexico, North Dakota, Oklahoma, South Dakota, Texas, and Wyoming, and (2) administers the Integrated Marketplace,5 a centralized Day-Ahead6 and Real-Time Energy and Operating Reserve market with locational-marginal pricing and market-based congestion management. B. SPP Integrated Marketplace On February 29, 2012,7 as amended on May 15, 2012,8 SPP submitted to the Commission proposed revisions to its Tariff to transition from its Real-Time Energy Imbalance Service ("EIS") Market to the Integrated Marketplace in March 2014. The Integrated Marketplace design approved by the Commission, which went live according to schedule on March 1, 2014, includes Day-Ahead and Real-Time Energy and Operating Reserve Markets as well as a Transmission Congestion Rights ("TCR") Market. C. Stakeholder Approval The proposed revisions were analyzed and approved through the SPP stakeholder process, including: (1) a meeting of the Market Working Group ("MWG")9 on December 15, 2015; (2) Regional Tariff Working Group ("RTWG")10 5 Sw. Power Pool, Inc., 146 FERC ¶ 61,130 (2014) (order approving the start-

up and operation of the Integrated Marketplace effective March 1, 2014).

6 All capitalized terms not otherwise defined in this filing shall have the definitions assigned by the Tariff.

7 Submission of Tariff Revisions to Implement SPP Integrated Marketplace of Southwest Power Pool, Inc., Docket No. ER12-1179-000 (Feb. 29, 2012) ("Integrated Marketplace Filing").

8 Amendatory Filing of Tariff Revisions to Implement SPP Integrated

Marketplace of Southwest Power Pool, Inc., Docket No. ER12-1179-001 (May 15, 2012).

9 The MWG is responsible for the development and coordination of the changes necessary to support any SPP administered wholesale market(s), including energy, congestion management, and market monitoring, consistent with direction from the SPP Board of Directors.

10 The RTWG is responsible for development, recommendation, overall implementation, and oversight of SPP’s Tariff. The RTWG also advises SPP

The Honorable Kimberly D. Bose February 5, 2016 of 6 on December 17, 2015; (3) a meeting of the Market Operations and Policy Committee ("MOPC")11 on January 12, 2016; and (4) a meeting of the SPP Members Committee12 and Board of Directors on January 26, 2016. While SPP recognizes that stakeholder approval does not by itself cause a filing to be just and reasonable, SPP requests that the Commission extend appropriate deference to the wishes of SPP’s stakeholders, consistent with Commission precedent.13 II. DISCUSSION OF REVISIONS FCAs are portions of the SPP Integrated Marketplace footprint that (1) experience high levels of congestion and (2) are associated with a dominant or pivotal

staff on regulatory and implementation issues not specifically covered by the Tariff or issues where there may be conflicts or differing interpretations of the Tariff.

11 The MOPC consists of a representative officer or employee from each SPP Member and reports to the SPP Board of Directors. Its responsibilities include recommending modifications to the SPP Tariff. See Southwest Power Pool, Inc., Bylaws, First Revised Volume No. 4 ("Bylaws") § 6.1.

12 The Members Committee currently consists of up to 24 representatives of the Transmission Owning Member and Transmission Using Member sectors of SPP’s Membership. This committee provides input to and assists the SPP Board of Directors with the management and direction of the general business of SPP. See Bylaws § 5.1.

13 The Commission has previously recognized that provisions approved through RTO stakeholder processes are due deference. See Sw. Power Pool, Inc., 127 FERC ¶ 61,283, at P 33 (2009) (noting that the Commission "accord[s] an appropriate degree of deference to RTO stakeholder processes"); New Eng. Power Pool, 105 FERC ¶ 61,300, at P 34 (2003) (Commission approval of transmission cost allocation proposal based upon an extensive and thorough stakeholder process); Policy Statement Regarding Regional Transmission Groups, 1991-1996 FERC Stats. & Regs., Preambles ¶ 30,976, at 30,872 (1993) (the Commission will afford the appropriate degree of deference to the stakeholder approval process). The Commission’s deference to RTO stakeholder processes has been upheld by the courts. See Pub. Serv. Comm’n of Wis. v. FERC, 545 F.3d 1058, 1062-63 (D.C. Cir. 2008) (noting the Commission often gives weight to RTO proposals that reflect the position of the majority of the RTO’s stakeholders) (quoting Am.Elec. Power Serv. Corp. v. Midwest Indep. Transmission Sys. Operator, Inc., 122 FERC ¶ 61,083, at P 172 (2008)).

The Honorable Kimberly D. Bose February 5, 2016 of 6 supplier.14 The current designation of FCAs is set forth in the Tariff as Addendum 1 to Attachment AF. The current designation is based on a 2014 study performed by the MMU. Section 3.1.1.3 of Attachment AF requires the MMU to reevaluate, on an annual basis, the designation of FCAs set forth in said Addendum 1.15 Accordingly, the revisions proposed herein are based on a 2015 study the MMU has completed ("the 2015 Study"). A copy of the December 2015 report of the MMU’s findings (the "December 2015 Report") is attached to this Transmittal Letter as Exhibit A. As reflected in the December 2015 Report, the MMU has reviewed and reevaluated the current FCA designation. Currently, only the Texas Panhandle is identified in the Tariff as an FCA. The proposed revisions to Addendum 1 of Attachment AF reflect the MMU’s determination that the Texas Panhandle should retain its FCA designation and that Woodward, Oklahoma, should also be designated 14 See Tariff at Attachment AF, Section 3.1.1, which defines FCAs as follows:

A Frequently Constrained Area is an electrical area identified by the Market Monitor that is defined by one or more binding transmission constraints or binding Reserve Zone constraints that are expected to be binding for at least five-hundred (500) hours during a given twelve (12)-month period and within which one (1) or more suppliers are pivotal. All Frequently Constrained Areas shall be listed in Addendum 1 of this Attachment AF. Any new or modifications to existing Frequently Constrained Areas are subject to prior Commission approval.

15 Section 3.1.1.3 of Attachment AF is entitled "Changes to Frequently Constrained Area Designation," and it states:

The Market Monitor shall reevaluate the Frequently Constrained Areas at least annually or more frequently as the Market Monitor deems necessary. The Transmission Provider may propose an area be designated or undesignated as a Frequently Constrained Area if the Transmission Provider believes that conditions have changed with respect to the binding transmission constraint or binding Reserve Zone constraints that define the Frequently Constrained Area. The Market Monitor shall evaluate any proposed change and seek comments from the Market Participants before recommending to designate, modify, or undesignate a Frequently Constrained Area. Subject to any applicable confidentiality requirements, the Market Monitor will provide any interested Market Participants with a description of its supporting analysis to allow comment on the proposed designation changes. The Market Monitor will recommend any changes to the Frequently Constrained Areas to the SPP Board of Directors for approval.

The Honorable Kimberly D. Bose February 5, 2016 of 6 as an FCA.16 These revisions are just and reasonable in that they are (1) required by the Commission-approved Tariff and (2) based on a detailed review and analysis as reflected in the December 2015 Report attached to this Transmittal Letter as Exhibit A. III. ADDITIONAL INFORMATION A. Information Provided Per Commission Regulations17

1. Documents submitted with this filing: In addition to this transmittal letter, the following documents

are included with this filing:

1) Clean and Redlined Tariff revisions under the Sixth Revised Volume No. 1; and 2) Exhibit A – Southwest Power Pool Frequently Constrained Areas – 2015 Study.

2. Effective date: SPP requests that the Commission allow the proposed revisions

to the Tariff to become effective April 5, 2016. 3. Service:

SPP has electronically served a copy of this filing on all its Members, Customers and Market Participants. A complete copy of this filing will be posted on the SPP web site, www.spp.org, and is also being served on all affected state commissions.

4. Requisite agreements: SPP's Board of Directors approved this filing at its meeting on January 26, 2016.

16 See Exhibit A at pp. 7-8.

17 Because the revisions to the Tariff submitted herein do not involve any changes in rates, the use of the abbreviated filing procedures as set forth in 18 C.F.R. § 35.13(a)(2)(iii) is appropriate.

The Honorable Kimberly D. Bose February 5, 2016 of 6 B. Communications Correspondence and communications with respect to this filing should be sent to, and SPP requests the Secretary to include on the official service list, the following:

Joseph W. Ghormley Senior Attorney Southwest Power Pool, Inc. 201 Worthen Drive Little Rock, AR 72223 Telephone: (501) 614-3368 Fax: (501) 482-2022 [email protected]

Nicole Wagner Manager, Regulatory Policy Southwest Power Pool, Inc. 201 Worthen Drive Little Rock, AR 72223 Telephone: (501) 688-1642 Fax: (501) 482-2022 [email protected]

IV. CONCLUSION For all of the foregoing reasons, SPP respectfully requests that the Commission accept the Tariff revisions proposed herein as just and reasonable, effective as discussed above. Respectfully submitted, /s/ Joseph W. Ghormley Joseph W. Ghormley Southwest Power Pool, Inc. 201 Worthen Drive Little Rock, AR 72223 Telephone: (501) 614-3368 [email protected]

Attorney for Southwest Power Pool, Inc.

CC: Penny Murrell

Michael Donnini John Rogers

Patrick Clarey Laura Vallance

mailto:[email protected]



Exhibit A

Southwest Power Pool Frequently Constrained Areas – 2015 Study

Frequently Constrained Areas – 2015 Study

December 2015

SPP Market Monitoring Unit

Frequently Constrained Areas – 2015 Study | ii

Disclaimer

The data and analysis in this report are provided for informational purposes only and shall not be

considered or relied upon as market advice or market settlement data. All analysis and opinions

contained in this report are solely those of the SPP Market Monitoring Unit (MMU), the

independent market monitor for Southwest Power Pool, Inc. (SPP). The MMU and SPP make no

representations or warranties of any kind, express or implied, with respect to the accuracy or

adequacy of the information contained herein. The MMU and SPP shall have no liability to

recipients of this information or third parties for the consequences that may arise from errors or

discrepancies in this information, for recipients’ or third parties’ reliance upon such information,

or for any claim, loss, or damage of any kind or nature whatsoever arising out of or in connection

with:

(i) the deficiency or inadequacy of this information for any purpose, whether or not

known or disclosed to the authors

(ii) any error or discrepancy in this information

(iii) the use of this information

(iv) any loss of business or other consequential loss or damage whether or not resulting

from any of the foregoing

Frequently Constrained Areas – 2015 Study | iii

Table of Contents

1. Executive Summary ................................................................................................................ 5

1.1. Introduction ............................................................................................................. 5

1.2. Results ..................................................................................................................... 6

1.3. Recommendation .................................................................................................... 7

2. Methodology ............................................................................................................................ 9

2.1. Data and Study Period ............................................................................................ 9

2.2. Study Process .......................................................................................................... 9

3. Analysis and Results ............................................................................................................. 12

3.1. FCA Candidates .................................................................................................... 12

3.2. Impact Analysis .................................................................................................... 19

Appendix A. FCA Constraints and Resources........................................................................ 22

Appendix B. Binding Constraint and Pivotal Supplier Data ................................................ 24

Frequently Constrained Areas – 2015 Study | iv

List of Figures

Figure 1-1 Candidates for the FCA Designation ............................................................................ 6

Figure 1-2 Impact Analysis Results ................................................................................................ 7

Figure 3-1 Top 10 Binding Conding Constraints ......................................................................... 12

Figure 3-2 FCA Candidate Areas ................................................................................................. 13

Figure 3-3 New Transmission in Western Part of Footprint 2012 – 2014.................................... 15

Figure 3-4 Primary Constraints and RLDF Cut-Offs ................................................................... 16

Figure 3-5 Candidate Resource Summary .................................................................................... 17

Figure 3-6 Candidate FCA Defining Constraints ......................................................................... 18

Figure 3-7 Impact Analysis Results .............................................................................................. 20

Figure 3-8 Impact Analysis Comparison with 2014 FCA Study .................................................. 21

Figure 3-9 Impact Threshold Sensitivity Analysis ....................................................................... 21

Frequently Constrained Areas – 2015 Study | 5

1. Executive Summary

1.1. Introduction

Frequently Constrained Areas are areas of the Integrated Marketplace footprint that experience

high levels of congestion and are associated with a dominant or pivotal supplier. Attachment AF,

Section 3.1.1 of the SPP Open Access Transmission Tariff defines Frequently Constrained Areas

as electrical areas with one or more binding transmission constraints or Reserve Zone constraints

that are expected to be binding for at least five-hundred (500) hours during a given twelve (12)-

month period and within which one or more suppliers are pivotal. Prior to the start of the

Integrated Marketplace, Potomac Economics Ltd., under contract with the SPP Market Monitor,

recommended the designation of three Frequently Constrained Areas: (1) the Kansas City area,

(2) the Northwest Kansas area, and (3) the Texas Panhandle area. A later study performed by the

SPP Market Monitor found that transmission upgrades and expansion in 2013 and 2014 had

significantly impacted congestion patterns and resolved some of the concerns with pivotal

suppliers. In January 2015, the SPP Market Monitor reported that the Kansas City and Northwest

Kansas areas no longer met the criteria to be designated as Frequently Constrained Areas. A

recommendation to maintain the Texas Panhandle as a Frequently Constrained Area and to

remove the designations for the Kansas City and Northwest Kansas areas was approved by the

SPP Board of Directors in January 2015.

The SPP Market Monitor, as required by Attachment AF, Section 3.1.1.3, has again

reexamined the Frequently Constrained Area designations to determine if the current

designations still meet the criteria and if the designation of any new areas is warranted. The

contents of this report include an executive summary of the major findings and recommendations

in Section 1, a description of the study process in Section 2, and a detailed description of the

analysis in Section 3. Appendix A consists of the recommended changes to Addendum 1 of

Attachment AF. Appendix B is a list of constraints with corresponding binding and pivotal

supplier hours.


1.2. Results

Five areas are identified as candidates for the Frequently Constrained Area (FCA) designation.

Three of the five areas, Kansas City, Western Kansas, and the Texas Panhandle, are the same

three areas studied in the two previous FCA studies. The two new areas considered as candidate

FCAs are the Lubbock, Texas and Woodward, Oklahoma areas.

Figure 1-1 Candidates for the FCA Designation

The impact analysis, where we count the number of hours for which the price impact in

the candidate FCA exceeds the $25/MWh threshold, indicates that the Texas Panhandle and

Woodward areas warrant designation as FCAs. The other three candidate FCAs area are well

below the 500 hour threshold and do not warrant designation. This marks the third year in a row

that the Texas Panhandle area has had significant pivotal supplier hours. This year’s total of 536

hours is the lowest observed of the three FCA studies completed to this point. The study this year

more fully reflects the impacts of the 2012 through 2014 transmission expansion. This was also

the first FCA study that relied completely on historical data from the Integrated Marketplace;


hence all efficiency gains from the implementation of the Integrated Marketplace should be

reflected in this year’s results as well. Lower natural gas prices during the study period are also a

cause for the lower number of pivotal supplier hours in the Texas Panhandle.

Figure 1-2 Impact Analysis Results

FCA Candidate Binding Hours Pivotal Supplier Hours $25 Impact Threshold

Kansas City 668 36

Lubbock 1,036 133

Texas Panhandle 4,182 536

Western Kansas 248 23

Woodward 1,704 743

The Woodward area has been a highly congested area since the start of the Integrated

Marketplace. The congestion on the WDWFPLWDWTAT constraint was noted in the 2014 FCA

study but the pivotal supplier hours were relatively low.1 A new constraint was created in

November 2014, WDWFPLTATNOW2, in response to new congestion patterns in the area. The

limiting element in the area, the Woodward to FPL Switch (138 kV), is located near the

intersection of several 345 kV transmission lines that were energized in 2014. There was also

new wind generation added to the area; 500 MW of wind capacity located near the Tatonga 345

kV substation registered for the market in August 2014. The increase in congestion and pivotal

supplier hours correlates with the change in congestion patterns that appears to be the result of

transmission expansion in the western part of the SPP footprint and new wind generation in the

area.

1.3. Recommendation

The results of the analysis indicate that the Texas Panhandle area should remain designated

as a Frequently Constrained Area. The binding hours and pivotal supplier results show that

congestion and the resulting market power vulnerability still remains. The Woodward, OK area

1 The 2014 FCA study reported 793 binding hours and 111 pivotal supplier hours on the WDWFPLWDWTAT constraint (Woodward to FPL Switch (138 kV) for the loss of Woodward to Tatonga (345 kV)). 2 Woodward to FPL Switch (138 kV) for the loss of Tatonga to Northwest (345 kV); originally created as temporary constraint TEMP95_20633 on 11/11/2014 and promoted to permanent status on 1/6/2015.


has also experienced significant congestion during the study period and the pivotal supplier

results indicate market power vulnerability as well. The expectation of the Market Monitor is

that both areas will be vulnerable to the exercise of market power during the next twelve month

period. The Market Monitor recommends the Texas Panhandle area maintain the designation as

an FCA and that the Woodward area be designated as a new FCA. Table 1 in Appendix A is a

list of the defining constraints for each FCA and Table 2 in Appendix A contains a list of FCA

resources. The lists in Tables 1 and 2 should be used to update Addendum 1 to Attachment AF in

the SPP Open Access Transmission Tariff.


2. Methodology

2.1. Data and Study Period

The study period runs from September 1, 2014 through August 31, 2015. Real-time Balancing

Market (RTBM) congestion and dispatch data, and resource parameter offers for online

resources are used in the analysis. This year’s study is the first one based entirely on Integrated

Marketplace data.

2.2. Study Process

The study consists of the following six step process.

1. Binding Hours Computation: The number of binding hours is computed for each

modeled transmission constraint. A constraint is counted as binding in a five minute

interval if the loading on the constraint is within the greater of five megawatts (5 MW) or

2% of the effective constraint limit.

2. Pivotal Supplier Analysis: The number of pivotal supplier hours is computed for each

modeled transmission constraint. A constraint is counted as having a pivotal supplier

during a five minute interval if the supplier can cause a constraint to exceed the effective

constraint limit by decreasing generation on resources that provide congestion relief and

by increasing generation on resources that contribute to congestion. The re-dispatch of

the potential pivotal supplier’s resources is governed by the submitted ramp rates, and the

economic minimum and maximum capabilities. A thirty minute re-dispatch period is

considered. The ability of the market to react to the actions of the potential pivotal

supplier is accounted for by allowing a similar re-dispatch of all resources not owned or

controlled by the potential pivotal supplier.

3. Selection of FCA candidates: Candidates for designation as an FCA are chosen based

on the binding hours and pivotal supplier analyses. Constraints that are in the same

electrical proximity and have the same pivotal suppliers are grouped together; if the

aggregate number of binding and pivotal supplier hours is significant, then the area is

selected as a candidate FCA. A primary constraint for the candidate FCA is generally

selected as the constraint with the highest number of binding hours.


4. Identify the candidate FCA Resources: A resource is a candidate FCA resource if its

resource-to-load-distribution-factor (RLDF) relative to the candidate FCA primary

constraint is less than or equal to the candidate FCA RLDF cut-off. To determine the

RLDF cut-off we first compute the relief capability of the largest pivotal supplier relative

to the primary constraint. The RLDF cut-off is then set at the value corresponding to the

ninetieth percentile of the relief capability. In other words, ninety percent (90%) of the

largest pivotal supplier’s relief capability has an RLDF less than or equal to the candidate

FCA RLDF cut-off. For the 2015 FCA study, a cap of -3% has been put in place to

prevent the application of mitigation to resources with a very small impact on the primary

constraint. In cases where the RLDF value corresponding to the ninetieth percentile is

less than -3%, the RLDF cut-off is set to -3%.

5. Identify the candidate FCA secondary constraints: A constraint is eligible to be

defined as a secondary constraint for the candidate FCA if the candidate FCA resource

group contributes at least seventy percent (70%) of the total relief capability on the

constraint. Additional considerations for defining a constraint as a secondary constraint

consist of (i) electrical proximity to the candidate resource group identified in step 4, (ii)

an expectation that the constraint is not a short-term or temporary constraint, and (iii) an

expectation that the constraint will experience congestion in the upcoming year.

6. Impact Analysis: An impact analysis is employed to determine the number of hours for

which the candidate FCA resource group has significant impacts on prices in the

candidate FCA. For each five minute interval in the study period, the resource price

impacts on each defining constraint are calculated by multiplying the shadow price and

the candidate resource’s corresponding RLDF. The resource price impacts are then

summed over the candidate FCA defining constraints to obtain a five minute price impact

for each candidate resource. This calculation is similar to finding the contribution from

the candidate FCA defining constraints to the candidate resource’s marginal congestion

component of the LMP.

Any interval for which a candidate resource’s price impact exceeds the impact test

threshold is counted as an interval that is susceptible to the exercise of market power by a

pivotal supplier. The market impact test threshold used in the Integrated Marketplace

mitigation system transitioned from $15/MWh to $25/MWh on March 1, 2015. We


computed the impact analysis in this study at threshold levels ranging from $5/MWh to

$25/MWh in order to test the sensitivity of the results to the various impact threshold

levels.

As stated in Section 3.2 of SPP Tariff, Attachment AF, an area must have 500

hours with pivotal supplier impacts to be designated as a Frequently Constrained Area.

The importance of employing a threshold value such as $25/MWh is to account for the

times when there is low cost relief capability in the FCA. This low cost relief prohibits

the pivotal supplier from accruing significant benefits by pursuing a withholding strategy

in the FCA.


3. Analysis and Results

3.1. FCA Candidates

The initial phase of the study identified five candidates for the Frequently Constrained Area

designation; the identified areas are (1) Kansas City, (2) Lubbock, (3) Texas Panhandle, (4)

Western Kansas, and (5) Woodward. These five areas experienced significant congestion during

the study period, and each area has one or more pivotal suppliers. The identification of candidate

areas and associated primary constraints is based on the number of hours the constraints are

binding and the number of hours for which the constraints have a pivotal supplier.

Figure 3-1 Top 10 Binding Conding Constraints

Constraint Name Monitored Element Binding Hours Pivotal Supplier

Hours

OSGCANBUSDEA Osage Switch to Canyon East, 115 kV

3751 3749

WDWFPLTATNOW Woodward to FPL Switch, 138 kV

1704 875

SUNAMOTOLYOA Sundown to Amoco, 230 kV

896 857

IATSTRSTJHAW Iatan to Stranger Creek, 345 kV

668 192

TEMP56_21085 Tuco to Lubbock, 115kV

624 624

WDWFPLWDWTAT Woodward to FPL, 138 kV

505 191

ARCKAMARCNOR Arcadia to Memorial, 138 kV

488 428

TMP109_20517 Swissvale to West Gardner, 345 kV

467 398

NEORIVNEOBLC Neosho to Riverton, 161kV

430 319

TMP123_20529 Woodward to FPL, 138 kV

364 192


Number one on the top ten binding constraints list is the Osage Switch – Canyon East constraint.

This constraint is located in the Texas Panhandle and has been identified in two prior FCA

studies as the primary constraint for the Texas Panhandle FCA. Three constraints in the top ten

are located in the Woodward, Oklahoma area with each of three having the Woodard – FPL

Switch as the monitored constraint. Other areas of the footprint represented in the list in Figure

3-1 are Lubbock, Hockley County Texas, Kansas City, Oklahoma City, and Southeast Kansas.

There is also substantial congestion in the western Kansas area but the impacted constraints3 do

not show up in Figure 3-1. Figure 3-2 shows the FCA candidate areas on a RTBM price contour

map based on average LMPs during the study period.

Figure 3-2 FCA Candidate Areas

Three of the identified areas, Kansas City, Western Kansas, and the Texas Panhandle, have

shown up in each of the two previous FCA studies. The congestion in the Kansas City area is

due to limitations in the North-South and West-East transmission capability and the high demand 3 GGS, REDWILLMINGO, NPLSTOGTLRED had 295, 248, and 190 binding hours, respectively, in the study period. See Appendix B for additional details.


for power in the Kansas City area. Kansas City’s proximity to the eastern seam of the footprint

exacerbates the congestion issues in the area. Market-to-Market (M2M) coordination with MISO

should alleviate some of the congestion but the full impacts of market-to-market coordination are

not captured in the study period.

The Texas Panhandle continues to be the most congested area in the SPP footprint with

the limited North-South transmission capability and the growing wind capacity in the western

part of the footprint. The binding-hours totals for the Western Kansas area are lower than the

previous two FCA studies but are still at levels that require additional study.

Two new candidate areas are identified as Lubbock, Texas and Woodward, Oklahoma.

The binding-hours totals for the Lubbock area have risen to the point that the area is considered

as a new FCA candidate. The increase in congestion in this area may be related to line rating

changes and transmission expansion. It appears that there has been a southern migration of some

of the congestion that has historically been seen in the Texas Panhandle. The largest change in

congestion is in the Woodward, Oklahoma area. The increased congestion in this area is closely

tied to increases in wind generation capacity and the transmission expansion in 2013 and 2014.

The limiting element in this area is the Woodward to FPL Switch, a 138 kV transmission line.

Figure 3-3 is replication of a chart from the 2014 FCA report that shows the new transmission

lines energized in 2012 through 2014. The Woodward to FPL Switch is at the intersection of

three new transmission lines in Figure 3-3; a circle has been added to show the location of the

Woodward – FPL Switch (138 kV). Wind generation is significant in this area as variable energy

generation accounts for 40% of the relief capability on the WDWFPLTATNOW constraint.


Figure 3-3 New Transmission in Western Part of Footprint 2012 – 2014

Figure 3-4 shows the primary constraint and the resource-to-load-distribution-factor (RLDF) cut-

off for each candidate FCA. The primary constraint for each candidate area is the constraint with

the most binding hours and the RLDF cut-off is used to identify the candidate resources

associated with the candidate FCA. The cut-off for the Texas Panhandle area is lower this year

than in previous studies. The cut-off was -6.0% in 2013 and -5.3% in the 2014 study. It was

noted in last year’s report that the lower cut-off value is likely due to the transmission expansion

that has occurred in the last few years. It is not surprising to see still another drop in the cut-off

again this year as the full impact of the transmission expansion was not captured in the 2014

FCA study. The RLDF cut-offs for the Kansas City and Western Kansas areas in Figure 3-4 are

also lower than the corresponding values in the 2014 FCA study. The magnitude of the Lubbock

cut-off reflects the highly concentrated relief capability. Generators capable of relieving

congestion on the SUNAMOTOLYOA constraint reside southwest of the Lubbock area.


The process for determining the RLDF cut-off was amended for this study due to the

Woodward candidate FCA. Applying the standard logic as used on the other areas led to a cut-

off value for the Woodard area of -1.7%. Using -1.7% as the RLDF cut-off results in a large

number of low impact generators being included in the Woodward FCA. These low impact

resources, some with RLDFs less than -2%, would be subject to mitigation when the Woodward

FCA is binding. The MMU maintains that including such low impact resources in the FCA is not

warranted and recommends establishing a cap on the RLDF cut-offs at -3%. This cap is

consistent with prior studies and represents the lowest magnitude RLDF cut-off that has been

applied since the inclusion of the FCA methodology in the SPP Tariff. In the original FCA study

in 2013, the Lake Road to Alabama constraint was a primary constraint for the Kansas City FCA

and the corresponding RLDF cut-off was -3.0%.

Figure 3-4 Primary Constraints and RLDF Cut-Offs

FCA Candidate Primary Constraint RLDF Cut-Off

Kansas City IATSTRSTJHAW -6.4%

Lubbock SUNAMOTOLYOA -32.1%

Texas Panhandle OSGCANBUSDEA -4.4%

Western Kansas REDWILLMINGO -6.2%

Woodward WDWFPLTATNOW -3.0%

The RLDF cut-offs in Figure 3-4 are used to identify the candidate resources associated with

the FCA candidates. Any resource with an RLDF that is less than the RLDF cut-off is an FCA

candidate resource. For example, the candidate resource group for the Texas Panhandle FCA

consists of all resources that have an RLDF corresponding to the OSGCANBUSDEA constraint

that is less than or equal to -4.4%. Figure 3-5 shows the number of resources included in each

FCA candidate and the corresponding capacity.


Figure 3-5 Candidate Resource Summary

FCA Candidate Number of Resources Total Capacity (MW)

Kansas City 82 9,700

Lubbock 18 2,300

Texas Panhandle 43 5,400

Western Kansas 112 11,700

Woodward 25 2,400

The next step in the process is to identify the secondary constraints for each FCA candidate.

The secondary constraints for each candidate FCA are shown in Figure 3-6. The identification of

secondary constraints is necessary because congestion in tightly constrained areas generally

impacts a group of constraints. Operators may activate a constraint in close proximity to the

designated primary constraint instead of activating the primary constraint. Without the

designation of the secondary constraints the market power mitigation logic will fail to recognize

that the FCA is binding and may not adequately protect against market power abuse. For a

constraint to be defined as a secondary constraint it must be determined that the FCA candidate

resource group makes up more than seventy percent (70%) of the total relief capability on the

constraint. For example, if the total relief capability on constraint XYZ is 1,000 megawatts and

the resource candidate group corresponding to the Kansas City area contributes 725 relief

megawatts, then the 70% threshold is exceeded and constraint XYZ may be included as a

secondary constraint for the Kansas City Area.

Additional considerations for including a constraint as a secondary constraint include (i)

electrical proximity to the candidate resource group, (ii) the expectation that the constraint is not

a short-term or temporary constraint, and (iii) the potential for the constraint to experience

significant congestion in the future. Application of the seventy percent (70%) test produced four

potential secondary constraints for the Kansas City Area. Three of the four were discarded due to

their proximity to the candidate resource group and the other constraint was a temporary

constraint that has been terminated. As a result, the Kansas City Area does not have any

secondary constraints. The application of the seventy percent secondary constraint test yielded

six constraints for the Lubbock area and 15 for the Texas Panhandle. With consideration of the


additional factors listed above, the list of secondary constraints was reduced to two for the

Lubbock area and five for the Texas Panhandle as shown in Figure 3-6.

Figure 3-6 Candidate FCA Defining Constraints

FCA CANDIDATE Type Constraint Monitored Element

Kansas City Primary IATSTRSTJHAW Iatan to Stranger Creek, 345 kV

Lubbock Primary SUNAMOTOLYOA Sundown to Amoco, 230 kV

Lubbock Secondary TEMP25_20579 Carlisle to Doud, 115 kV

Lubbock Secondary TEMP70_20629 Carlisle to Doud, 115 kV

Texas Panhandle Primary OSGCANBUSDEA Osage Switch to Canyon East, 115

kV

Texas Panhandle Secondary SPSNORTH_STH

Bushland to Deaf Smith, 230 kV

Potter Co to Newhart 230kV

Osage Switch to Canyon 115kV

Randall Co. to Palo Duro 115kV

Amarillo So. To Swisher 230kV

Texas Panhandle Secondary TEMP14_20279 Bushland to Deaf Smith, 230 kV

Texas Panhandle Secondary TEMP56_21085 Tuco to Lubbock, 115kV

Texas Panhandle Secondary TUCJONPLASUN Tuco to Jones, 230 kV

Texas Panhandle Secondary TUCJONTUCCAR Tuco to Jones, 230 kV

Western Kansas Primary REDWILLMINGO Redwillow to Mingo, 345kV

Woodward Primary WDWFPLTATNOW Woodward to FPL Switch, 138 kV

As in last year’s FCA study, the Western Kansas candidate FCA does not have any

secondary constraints. Most of the constraints identified by the 70% test are constraints in the

Texas Panhandle and Lubbock area. Thus, a large portion of the Western Kansas candidate

resource group resides to the north of the identified secondary constraints, and hence the

resources contribute to, rather than relieve, the congestion on these constraints. Therefore, these

constraints are not included as defining constraints of the Western Kansas FCA due to their

proximity to the candidate resource group. The application of the 70% test to the Woodward

candidate FCA did not yield any secondary constraint candidates.


3.2. Impact Analysis

The final step is to determine the number of hours each candidate FCA was both binding

and susceptible to the exercise of market power. This is done by applying a price impact test; the

price impact is calculated by multiplying the constraint shadow price and the candidate

resource’s RLDF relative to the defining constraints for each FCA. The price impacts were

computed for each five minute interval in the study period and if the price impact on a single

candidate resource exceeds the price impact threshold, then the candidate FCA is susceptible to

the exercise of market power. The results of this final test are displayed in Figure 3-7. The results

indicate that two of the candidate FCAs, Texas Panhandle and Woodward, meet the 500 hour

criteria for designation as FCAs. The remaining three candidates fall well short of the 500 hour

threshold.

The comparison with the 2014 study in Figure 3-8 shows a decrease in both binding

hours and pivotal supplier hours for the Texas Panhandle area. The 20% reduction in the binding

hours is likely linked to the transmission expansion in the western part of the SPP footprint. Also

contributing to the reduction are the efficiency gains due to the improved commitment and

dispatch decisions of the Integrated Marketplace. The 2014 FCA study period included six

months of EIS data.

Low natural gas prices experienced during the study period contributed to the decrease in

the pivotal supplier hours. Using a conservative estimate4 of gas price differences between the

2014 FCA study period and the 2015 FCA study period, we estimate $18 as the comparable

impact threshold for comparison with the 2014 FCA study results at the $25 threshold level. At

the $18/MWh threshold, the Texas Panhandle region has 773 pivotal supplier hours. While

substantial progress has been made in the Texas Panhandle region, the results indicate that the

area still merits designation as an FCA.

4 Natural gas prices have fallen 30-50% since early 2014 and we assumed a 30% drop in the calculation of the $18 threshold.


Figure 3-7 Impact Analysis Results

FCA Candidate Binding Hours Pivotal Supplier Hours $25 Impact Threshold

Kansas City 668 36

Lubbock 1,036 133

Texas Panhandle 4,182 536

Western Kansas 248 23

Woodward 1,704 743

The Woodward candidate FCA area exceeds the 500 hour threshold by a substantial

margin, meeting the criteria for designation as an FCA. The limiting element for this FCA is the

Woodward to FPL Switch (138 kV) transmission line. The line is located near the intersection of

several 345 kV lines that were part of the transmission expansion completed in 2014. In addition

to the new transmission in this area, there is also new wind generation. Five hundred megawatts

of wind generation, located near the Tatonga 345 kV substation in Dewey County, OK,

registered for the market in August 2014. These changes led to the need for a new constraint in

November 2014, WDWFPLTATNOW5. The pivotal supplier impacts on this new constraint

differ from impacts on other constraints in the area that have experienced significant congestion.

For example, the 2014 and 2015 FCA studies both show binding hours in excess of 500 on the

WDWFPLWDWTAT6 constraint; but the pivotal supplier hours for this constraint do not exceed

200 hours for either study. The pivotal supplier impacts on WDWFPLTATNOW, apparently due

new transmission and new wind generation in the area, have risen to the level that the Woodward

area warrants designation as an FCA.

5 Woodward to FPL Switch (138 kV) for the loss of Tatonga to Northwest (345 kV); originally created as the temporary constraint TEMP95_20633 on 11/11/2014 and promoted to permanent status on 1/6/2015. 6 Woodward to FPL Switch (138 kV) for the loss of Woodward to Tatonga (345 kV).


Figure 3-8 Impact Analysis Comparison with 2014 FCA Study

FCA Candidate

2014 FCA Study 2015 FCA Study

Binding Hours

Pivotal Supplier Hours $25 Impact Threshold

Binding Hours


Kansas City 999 58 668 36

Lubbock n/a n/a 1,036 133

Texas Panhandle 5,234 1,258 4,182 536

Western Kansas 678 84 248 23

Woodward n/a n/a 1,704 743

The results of the sensitivity analysis are presented in Figure 3-9. There is no change in

the results at the $15/MWh threshold level; the three candidate FCAs with less than 500 pivotal

supplier hours at the $25 level are also well below the 500 hour level at the $15 threshold level.

At the $5/MWh threshold there is a different result with the Lubbock candidate area now

exceeding the 500 hour level.

Figure 3-9 Impact Threshold Sensitivity Analysis

FCA Candidate Pivotal Supplier Hours $5 Impact Threshold



Kansas City 100 48 36

Lubbock 552 253 133

Texas Panhandle 2,143 951 536

Western Kansas 123 43 23

Woodward 1,357 1,103 743


Appendix A. FCA Constraints and Resources

Table 1 – Defining Constraints for the Frequently Constrained Areas Line # Constraint Name Frequently Constrained Area

1 OSGCANBUSDEA TEXAS PANHANDLE 2 SPSNORTH_STH TEXAS PANHANDLE 3 TEMP14_20279 (Bushland to Deaf Smith) TEXAS PANHANDLE 4 TEMP56_21085 (Tuco to Lubbock) TEXAS PANHANDLE 5 TUCJONPLASUN TEXAS PANHANDLE 6 TUCJONTUCCAR TEXAS PANHANDLE

7 WDWFPLTATNOW WOODWARD

Table 2 – Units in Frequently Constrained Areas Line # PNODE Name Frequently Constrained Area

1 SPSCAPROCKUNWINDFARM TEXAS PANHANDLE 2 SPSCARLSBADUN5 TEXAS PANHANDLE 3 SPSCIRRUSUNCIRRUS_WIND TEXAS PANHANDLE 4 SPSCROSSRDSUNMILO_WIND TEXAS PANHANDLE 5 SPSCROSSRDSUNROSVELTWND TEXAS PANHANDLE 6 SPSCUNNSUBUN1 TEXAS PANHANDLE 7 SPSCUNNSUBUN2 TEXAS PANHANDLE 8 SPSCUNNSUBUN3 TEXAS PANHANDLE 9 SPSCUNNSUBUN4 TEXAS PANHANDLE

10 SPSDOLLARHIUNSUNE_SPS1 TEXAS PANHANDLE 11 SPSHOBBSPLT1 TEXAS PANHANDLE 12 SPSHOBBSPLT2 TEXAS PANHANDLE 13 SPSHOPI_SUBUNSUNE_SPS5 TEXAS PANHANDLE 14 SPSJONESSUBUN1 TEXAS PANHANDLE 15 SPSJONESSUBUN2 TEXAS PANHANDLE 16 SPSJONESSUBUN3 TEXAS PANHANDLE 17 SPSJONESSUBUN4 TEXAS PANHANDLE 18 SPSLEA_ROADUNSUNE_SPS3 TEXAS PANHANDLE 19 SPSLOVINGTOPLT1 TEXAS PANHANDLE 20 SPSLOVINGTOUNWILDCATWIND TEXAS PANHANDLE 21 SPSLP-BRND2UNBRANDON1 TEXAS PANHANDLE 22 SPSLP-COOP2UNLUBBOCK_WIND TEXAS PANHANDLE 23 SPSLP-HOLL2UNCOOKE_GT2 TEXAS PANHANDLE 24 SPSLP-HOLL2UNCOOKE_GT3 TEXAS PANHANDLE 25 SPSLP-HOLL2UNCOOKE_ST1 TEXAS PANHANDLE 26 SPSLP-HOLL2UNCOOKE_ST2 TEXAS PANHANDLE


Line # PNODE Name Frequently Constrained Area 27 SPSLP-MACK2UNMASSENG1 TEXAS PANHANDLE 28 SPSMADDOXSUUN1 TEXAS PANHANDLE 29 SPSMADDOXSUUN2 TEXAS PANHANDLE 30 SPSMONUMENTUNSUNE_SPS4 TEXAS PANHANDLE 31 SPSMSTNGPLT1 TEXAS PANHANDLE 32 SPSMSTNGUN4 TEXAS PANHANDLE 33 SPSMSTNGUN5 TEXAS PANHANDLE 34 SPSMSTNGUN6_GSEC TEXAS PANHANDLE 35 SPSPLXSUBUN1 TEXAS PANHANDLE 36 SPSPLXSUBUN2 TEXAS PANHANDLE 37 SPSPLXSUBUN3 TEXAS PANHANDLE 38 SPSPLXSUBUN4 TEXAS PANHANDLE 39 SPSQUAYCNTYUNQUAYCOUNTY1 TEXAS PANHANDLE 40 SPSSAN_JUANUNWINDFARM TEXAS PANHANDLE 41 SPSS_JALUNSUNE_SPS2 TEXAS PANHANDLE 42 SPSTOLKSUBUN1 TEXAS PANHANDLE 43 SPSTOLKSUBUN2 TEXAS PANHANDLE 44 CSWSDEMPSRDGUNDEMPSEY_WIND WOODWARD 45 CSWSELK_TAPUNELKCTY_WIND WOODWARD 46 CSWSHOBART_JUNROCKYRDG_WIND WOODWARD 47 CSWSROARKUNELKCTY2_WIND WOODWARD 48 CSWSWFRDGUNUN1_WFRDG WOODWARD 49 OKGEBRECKNR4UNBRECK_WIND WOODWARD 50 OKGEDEWEY1UNTALOGA_WIND WOODWARD 51 OKGEFPL_WINDUNUN1_FPL_OMPA WOODWARD 52 OKGEFPL_WINDUNUN1_FPL_WIND WOODWARD 53 OKGENARDINUNCOWBOY_WIND WOODWARD 54 OKGEOMKAWUN2 WOODWARD 55 OKGEOMKINGFUNOMPA_KNGFISHER WOODWARD 56 OKGEOMPONCAUNOMPONCA1_3 WOODWARD 57 OKGEOMPONCAUNOMPONCA2 WOODWARD 58 OKGEOMPONCAUNOMPONCA4 WOODWARD 59 OKGESONR1UN1 WOODWARD 60 WFECBUFBEAR2UNWINDFARM WOODWARD 61 WFECGOTEBOUNLITTL_ELK_WIND WOODWARD 62 WFECMOORLN1UNMOORELAND_1 WOODWARD 63 WFECMOORLN1UNMOORELAND_2 WOODWARD 64 WFECMOORLN1UNMOORELAND_3 WOODWARD 65 WFECOMLVRNEUNOMPA_LAVERNE WOODWARD 66 WFECOMMANGMUNOMPA_MANGUM WOODWARD 67 WFECREDHILLSUNWINDFARM WOODWARD 68 WFECSLP_BEARUNWINDFARM WOODWARD


Appendix B. Binding Constraint and Pivotal Supplier Data

Constraint Name Monitored Element Binding Hours

Pivotal Supplier Hours

OSGCANBUSDEA Osage Switch to Canyon East, 115 kV 3751 3749 WDWFPLTATNOW Woodward to FPL Switch, 138 kV 1704 875 SUNAMOTOLYOA Sundown to Amoco, 230 kV 896 857 IATSTRSTJHAW Iatan to Stranger Creek, 345 kV 668 192 TEMP56_21085 Tuco to Lubbock, 115kV 624 624 WDWFPLWDWTAT Woodward to FPL, 138 kV 505 191 ARCKAMARCNOR Arcadia to Memorial, 138 kV 488 428 TMP109_20517 Swissvale to West Gardner, 345 kV 467 398 NEORIVNEOBLC Neosho to Riverton, 161kV 430 319 TMP123_20529 Woodward to FPL, 138 kV 364 192 IATSTRIATEAT Iatan to Stranger Creek, 345 kV 363 290 TEMP95_20633 Woodward to FPL, 138 kV 353 148 TEMP37_20355 WR_SMKHL to SUMM, 230 kV 331 201 BRKXF2BRKXF1 Brookline Xfr, 345/161 kV 314 250 GGS Gentleman to N. Platte, 230kV 295 2 TEMP67_20472 Renfrow 7 to Renfro WF, 138 kV 293 130 REDWILLMINGO Redwillow to Mingo, 345kV 248 212 SHAHAYKNOXFR South Hays to Hays, 115 kV 227 56 TEMP53_20459 Hoyt to Hoyt Jct. South, 115 kV 193 193 TMP185_20887 Shooting Star Tap to Greensburg, 115 kV 192 0 NPLSTOGTLRED North Platte to Stockville, 115 kV 190 88 TEMP66_20599 Fairport to Osborn, 161 kV 184 106 TEMP52_20619 Mooreland to Glass Mountain, 138 kV 175 0 HARPOTHARPOT HarrSub to Potter_S, 230 kV 171 54 TEMP12_20560 Seward3 to St John, 115 kV 158 8 TEMP15_20574 Beverly Tap to Ft Smith, 161 kV 151 0 COOPER_S Cooper to St. Joe, 345 kV 145 77 TEMP70_20629 Carlisle to Doud, 115 kV 144 144 TMP159_20868 Tecumseh Hill to Stull Tap, 115 kV 143 141 FULPATLONSAR Fulton to Patmos, 115 kV 143 0 TEMP50_20937 Wolfforth to Terry County, 115 kV 142 142 TEMP34_20443 Lawrence Hill to Mockingbird, 115 kV 134 35 FAIOSBSTJHAW Fairport to Osborn, 161 kV 134 91 TUBDOBBENGRI Tubular to Dobbin, 138 kV 129 0 TMP102_20671 TEC to Tecumseh Hill, 115 kV 127 32 WODFPLWODXFR Woodward to FPL, 138 kV 126 57 LUBXFMJONHOL Lubbock SE Xfr, 230/69 126 85 TEMP47_20353 Montrose to Archie, 161 kV 123 0 TMP152_20700 Buckner to Spearville, 345 kV 119 19 TEMP90_20777 South Hays to Mulgre2, 230 kV 117 90


Constraint Name Monitored Element Binding Hours

Pivotal Supplier Hours

ELKXFRSWEWHE Elk City Xfr, 230/138 kV 113 0 TMP144_20608 Arcadia to Memorial, 138 kV 111 67 TEMP24_20438 Siloam to Siloam Spring, 161 kV 105 97 TEMP48_20597 SETAB1 to SCOTCTY, 115 kV 103 88 IATXFRIATSTR Iatan Xfr, 345/161 kV 102 43 NEORIVASBLIT Neosho to Riverton, 161kV 94 75 TEMP14_20279 Bushland to Deaf Smith, 230 kV 91 88 HOBCARHOBALT Hobart to Carnegie, 138 kV 91 19 SILDIVNWSCIM Silver lake to Division, 138 kV 89 78 SMOSUMMULCIR Smokey Hills to Summit, 230 kV 78 33 TEMP92_21002 Oneta to BA_North, 138 kV 77 73 TEMP26_21133 MaddoxSU to Sanger_S, 115 kV 74 0 TMP114_20520 Sunset Corner to RS Kerr, 161 kV 73 0 ANOPLHANOMAB Arkansas Nuclear 1 to Pleasant Hill, 500 kV 72 71 HAWXFRHAWXFR Hawthorn Xfr, 345/161 kV 70 29 MINXFRMINSET Mingo Xfr, 345/115 kV 69 31 TMP131_21087 Lacygne to West Gardner, 345 kV 69 68 TMP127_20536 Seward3 to St John, 115 kV 68 0 TEMP56_20750 Okay to ASHD_REA, 64 15 TMP101_20769 Snake Creek to Alliance, 115 kV 63 0 CBLS56ROLMAD Council Bluff to SUB 3456, 345 kV 59 16 TEMP74_20773 Milan Tap to Clearwater, 138 kV 59 0 TEMP38_20360 Sun City to Medicine Lodge, 115 kV 56 0 CARLPDLUBWOL Carlisle to Doud, 115 kV 54 54 TMP142_20565 Nebraska City to Cooper, 345 kV 52 29 TEMP91_21112 BA_North to E_41_ST, 138 kV 52 38 TMP132_20546 FTSMT Xfr, 500/161 kV 51 45 TEMP05_20411 Bell to Miller, 230 kV 50 9 TEMP09_20424 GORD Xfr, 345/138 kV 49 37 TMP122_20835 Cooper to St. Joe, 345 kV 49 22 TMP133_20547 Benton to Chisolm, 138 kV 48 29 TEMP75_20645 Hale County to Tuco, 115 kV 48 37 TEMP99_20665 CUNNSUB Xfr, 230/115 kV 48 47 PENMUN87TCRA Pentagon to Mund, 115kV 47 33 TMP151_20687 Victory Hill to Crawford, 115 kV 47 0 GENTLMREDWIL Gentlemen to Redwillow, 345 kV 45 33 TEMP46_21084 Lawrence Hill Xfr, 230/115 kV 45 34 TEMP61_20948 Westmoore Tap to Westmoore, 138 kV 44 30 TEMP49_20921 Johnson 2 to Gosper, 115 kV 44 12 CBLS56FALGRI Council Bluff to SUB 3456, 345 kV 43 5 TMP179_20885 Hoxie to Ross Beach, 115 kV 43 3 SUBTEKFTCRAU SUB 1226 to Tekamah, 161kV 41 6

Addendum 1 to Attachment AF

Frequently Constrained Areas

Table 1 – Constraints of Each Frequently Constrained Area

Line

# Constraint Name FCA

1 OSGCANBUSDEA TX Panhandle

2 SPSNORTH_STH TX Panhandle

3 TEMP14_20279 (Bushland to Deaf Smith) TX Panhandle

4 TEMP56_21085 (Tuco to Lubbock East) Tx Panhandle

5 TUCIJONPLASUN TX Panhandle

6 TUCJONTUCCAR TX Panhandle

7 WDWFPLTATNOW Woodward

Table 2 – Units in the Frequently Constrained Areas

Line

# PNODE Name FCA

1 SPSCAPROCKUNWINDFARM TX Panhandle

2 SPSCARLSBADUN5 TX Panhandle

3 SPSCIRRUSUNCIRRUS_WIND TX Panhandle

4 SPSCROSSRDSUNMILO_WIND TX Panhandle

5 SPSCROSSRDSUNROSVELTWND TX Panhandle

6 SPSCUNNSUBUN1 TX Panhandle




10 SPSDOLLARHIUNSUNE_SPS1 TX Panhandle

11 SPSHOBBSPLT1 TX Panhandle


13 SPSHOPI_SUBUNSUNE_SPS5 TX Panhandle

14 SPSJONESSUBUN1 TX Panhandle




18 SPSLEA_ROADUNSUNE_SPS3 TX Panhandle

19 SPSLOVINGTOPLT1 TX Panhandle

20 SPSLOVINGTOUNWILDCATWIND TX Panhandle

21 SPSLP-BRND2UNBRANDON1 TX Panhandle

22 SPSLP-COOP2UNLUBBOCK_WIND TX Panhandle

23 SPSLP-HOLL2UNCOOKE_GT2 TX Panhandle


25 SPSLP-HOLL2UNCOOKE_ST1 TX Panhandle


27 SPSLP-MACK2UNMASSENG1 TX Panhandle

28 SPSMADDOXSUUN1 TX Panhandle


30 SPSMONUMENTUNSUNE_SPS4 TX Panhandle

31 SPSMSTNGPLT1 TX Panhandle

32 SPSMSTNGUN4 TX Panhandle


34 SPSMSTNGUN6_GSEC TX Panhandle

35 SPSPLXSUBUN1 TX Panhandle




39 SPSQUAYCNTYUNQUAYCOUNTY1 TX Panhandle

40 SPSSAN_JUANUNWINDFARM TX Panhandle

41 SPSS_JALUNSUNE_SPS2 TX Panhandle

42 SPSTOLKSUBUN1 TX Panhandle


44 CSWSDEMPSRDGUNDEMPSEY_WIND Woodward

45 CSWSELK_TAPUNELKCTY_WIND Woodward

46 CSWSHOBART_JUNROCKYRDG_WIND Woodward

47 CSWSROARKUNELKCTY2_WIND Woodward

48 CSWSWFRDGUNUN1_WFRDG Woodward

49 OKGEBRECKNR4UNBRECK_WIND Woodward

50 OKGEDEWEY1UNTALOGA_WIND Woodward

51 OKGEFPL_WINDUNUN1_FPL_OMPA Woodward

52 OKGEFPL_WINDUNUN1_FPL_WIND Woodward

53 OKGENARDINUNCOWBOY_WIND Woodward

54 OKGEOMKAWUN2 Woodward

55 OKGEOMKINGFUNOMPA_KNGFISHER Woodward

56 OKGEOMPONCAUNOMPONCA1_3 Woodward

57 OKGEOMPONCAUNOMPONCA2 Woodward


59 OKGESONR1UN1 Woodward

60 WFECBUFBEAR2UNWINDFARM Woodward

61 WFECGOTEBOUNLITTL_ELK_WIND Woodward

62 WFECMOORLN1UNMOORELAND_1 Woodward



65 WFECOMLVRNEUNOMPA_LAVERNE Woodward

66 WFECOMMANGMUNOMPA_MANGUM Woodward

67 WFECREDHILLSUNWINDFARM Woodward

68 WFECSLP_BEARUNWINDFARM Woodward

Addendum 1 to Attachment AF

Frequently Constrained Areas

Table 1 – Constraints of Each Frequently Constrained Area

Line

# Constraint Name FCA

1 HARRANNICAMA TX Panhandle

21 OSGCANBUSDEA TX Panhandle

32 SPSNORTH_STH TX Panhandle



4 TEMP56_21085 (Tuco to Lubbock East) Tx Panhandle

5 TUCIJONPLASUN TX Panhandle

6 TUCJONTUCCAR TX Panhandle

7 WDWFPLTATNOW Woodward

Table 2 – Units in the Texas Panhandle Frequently Constrained Areas

Line

# PNODE Name FCA

1 SPSCAPROCKUNWINDFARM TX Panhandle

2 SPSCARLSBADUN5 TX Panhandle

3 SPSCIRRUSUNCIRRUS_WIND TX Panhandle

4 SPSCROSSRDSUNMILO_WIND TX Panhandle

5 SPSCROSSRDSUNROSVELTWND TX Panhandle





810 SPSDOLLARHIUNSUNE_SPS1 TX Panhandle



1113 SPSHOPI_SUBUNSUNE_SPS5 TX Panhandle





1618 SPSLEA_ROADUNSUNE_SPS3 TX Panhandle

1719 SPSLOVINGTOPLT1 TX Panhandle

1820 SPSLOVINGTOUNWILDCATWIND TX Panhandle

21 SPSLP-BRND2UNBRANDON1 TX Panhandle

1922 SPSLP-COOP2UNLUBBOCK_WIND TX Panhandle





27 SPSLP-MACK2UNMASSENG1 TX Panhandle



2630 SPSMONUMENTUNSUNE_SPS4 TX Panhandle

2731 SPSMSTNGPLT1 TX Panhandle



3034 SPSMSTNGUN6_GSEC TX Panhandle





3539 SPSQUAYCNTYUNQUAYCOUNTY1 TX Panhandle

3640 SPSSAN_JUANUNWINDFARM TX Panhandle

3741 SPSS_JALUNSUNE_SPS2 TX Panhandle



44 CSWSDEMPSRDGUNDEMPSEY_WIND Woodward

45 CSWSELK_TAPUNELKCTY_WIND Woodward

46 CSWSHOBART_JUNROCKYRDG_WIND Woodward

47 CSWSROARKUNELKCTY2_WIND Woodward

48 CSWSWFRDGUNUN1_WFRDG Woodward

49 OKGEBRECKNR4UNBRECK_WIND Woodward

50 OKGEDEWEY1UNTALOGA_WIND Woodward

51 OKGEFPL_WINDUNUN1_FPL_OMPA Woodward

52 OKGEFPL_WINDUNUN1_FPL_WIND Woodward

53 OKGENARDINUNCOWBOY_WIND Woodward

54 OKGEOMKAWUN2 Woodward

55 OKGEOMKINGFUNOMPA_KNGFISHER Woodward

56 OKGEOMPONCAUNOMPONCA1_3 Woodward



59 OKGESONR1UN1 Woodward

60 WFECBUFBEAR2UNWINDFARM Woodward

61 WFECGOTEBOUNLITTL_ELK_WIND Woodward




65 WFECOMLVRNEUNOMPA_LAVERNE Woodward

66 WFECOMMANGMUNOMPA_MANGUM Woodward

67 WFECREDHILLSUNWINDFARM Woodward

68 WFECSLP_BEARUNWINDFARM Woodward