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Decision on FERC Order 741 Credit Reforms in Organized Wholesale Electric Markets Ryan Seghesio Ryan Seghesio Chief Financial Officer & Treasurer Board of Governors Meeting General Session May 18-19, 2011 y , FERC Order 741


  1. Decision on FERC Order 741 – Credit Reforms in Organized Wholesale Electric Markets Ryan Seghesio Ryan Seghesio Chief Financial Officer & Treasurer Board of Governors Meeting General Session May 18-19, 2011 y ,

  2. FERC Order 741 mandates all ISOs and RTOs adopt certain common credit practices. certain common credit practices. • The Federal Energy Regulatory Commission has long been actively interested in ISO and RTO credit practices actively interested in ISO and RTO credit practices. • Over time, varying credit practices have been adopted through respective ISO / RTO stakeholder processes. g p p • Defaults in one market can have a ripple effect in other markets. • ISO and RTO credit practices are recognized as being only ISO d RTO dit ti i d b i l as strong as the weakest credit practice. • Order 741 is designed to protect organized wholesale electric Order 741 is designed to protect organized wholesale electric markets from default by a market participant. Slide 2

  3. The Order requested stakeholder input on two credit reform items: reform items: • Minimum participation requirements for entry into the ISO markets markets • Circumstances leading to reduction or revocation of a market Circumstances leading to reduction or revocation of a market participant’s unsecured credit due to a material adverse change in their financial condition Slide 3

  4. Management proposes the following minimum participation requirements. participation requirements. • Annual officer confirmation of certain processes • Capitalization requirements (new and existing market participants) ( g p p ) – $1 million tangible net worth or $10 million total assets $10 million total assets or post $500,000 of secured collateral – Periodic review could reduce posting requirement to $100,000 Slide 4

  5. Management proposes enhancing its existing material adverse change provisions. adverse change provisions. • Rating agency or Moody’s equivalent rating downgrade to below investment grade below investment grade • Restating prior-year financial statements Restating prior year financial statements • A default in another organized market Slide 5

  6. Stakeholders are largely supportive of the proposed minimum participation requirements. minimum participation requirements. • Approximately 50 stakeholders participated in our public process with 20 offering comments process with 20 offering comments • Management believes the proposal strikes the right balance Management believes the proposal strikes the right balance of stakeholder demands • Proposal is largely consistent with other ISO / RTO minimum participation requirements ti i ti i t Slide 6

  7. Management recommends the Board approve these proposed credit policy enhancements. proposed credit policy enhancements. • Result of an extensive stakeholder process • Balances competing stakeholder needs benefiting the entire market entire market • Consistent with FERC’s objective to minimize the risk of a default in the market Slide 7

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