Competitive Transmission: The Next Big Thing April 1, 2015 William S. Scherman, Gibson Dunn Justin M. Campbell, Edison Transmission Joshua Burkholder, AEP Transmission & Transource Energy Steven R. Herling, PJM Interconnection Harry Singh, Goldman Sachs William R. Hollaway, Gibson Dunn <Presentation Title/Client Name> MCLE Certificate Information This program has been approved for credit in accordance with the requirements of the New York State Continuing Legal Education Board for a maximum of 1.5 credit hours, of which 1.5 credit hours may be applied toward the areas of professional practice requirement. This course is NOT approved for transitional credit. Gibson, Dunn & Crutcher LLP certifies that this activity has been approved for MCLE credit by the State Bar of California in the amount of 1.5 hours. Gibson, Dunn & Crutcher LLP is authorized by the Solicitors Regulation Authority to provide in-house CPD training. This program is approved for CPD Credit in the amount of 1.5 hours. Regulated by the Solicitors Regulation Authority (Number 324652). Application for approval is pending with the Texas, Virginia, and Washington State Bars. Attorneys viewing the webcast as a group will need to sign a CLE attendance sheet. Prior to the start of the webcast, please contact Jeanine McKeown (National Training Administrator) at 213-229-7140 or jmckeown@gibsondunn.com to request the CLE attendance sheet. Most participants should anticipate receiving their certificates of attendance via e-mail in approximately 3 to 4 weeks following the webcast. <Presentation Title/Client Name> Today’s Moderator William S. Scherman Partner Gibson, Dunn & Crutcher LLP Washington, D.C. Tel: 202.887.3510 WScherman@gibsondunn.com William S. Scherman is a partner in the Washington, D.C. office of Gibson, Dunn & Crutcher LLP and chairs the Energy, Regulation and Litigation practice group. Mr. Scherman has served as general counsel for the Federal Energy Regulatory Commission and was chief of staff and senior legal and policy advisor for the FERC beginning in 1987. He was the only private practice lawyer named to SNL Energy’s 10 Most Influential People of 2014. The list features individuals who had significant impact on the electric power, natural gas and coal sectors over the past year. Mr. Scherman advises companies on litigation, commercial, regulatory and legislative matters relating to the U.S. and international energy markets. He has litigated high-profile energy investigation and enforcement matters before the FERC and in the federal courts and represents large electric utilities before the FERC and state regulators. Mr. Scherman was a partner with Skadden Arps from 1993 – 2013. Before that, he served as the General Counsel of the FERC from 1990 to 1993 and as the Chief of Staff from 1987 to 1993. During his tenure at the FERC, he played a key role in major policy initiatives, including the Energy Policy Act of 1992 and Order No. 636, which reformed the natural gas pipeline industry. As FERC’s chief legal officer, he was responsible for the agency’s litigation strategy before federal appellate courts. During the last several years, Mr. Scherman has been heavily involved in very high-profile trials before the FERC. He utilizes his experience in market power issues in advising companies on mergers and acquisitions. Mr. Scherman has defended clients in extended trials addressing cutting-edge issues. This includes a six-month trial before the FERC regarding whether certain affiliated company power supply arrangements are in the best interest of the utilities customers. Mr. Scherman received his Juris Doctor degree from the University of Louisville School of Law where he was an Articles Editor of the Law Review. He received his B.A. degree from George Washington University in 1980. 3 <Presentation Title/Client Name> Today’s Panelists Steven R. Herling Vice President, Planning PJM Interconnection Audubon, PA Tel: 610.666.8834 steve.herling@pjm.com Steven R. Herling is Vice President of Planning at PJM Interconnection. He is responsible for the oversight of the System Planning Division which includes Transmission Planning, Interregional Planning, Interconnection Projects, Interconnection Analysis, Infrastructure Coordination, and Resource Adequacy Planning. Mr. Herling has been involved extensively in the development of PJM’s regional transmission expansion planning process and resource adequacy planning process. Recently, he has been actively involved in the development of a number of new backbone transmission projects on the PJM system as well as efforts to enhance coordination of planning activities across ISO/RTO boundaries. Prior to joining PJM, Mr. Herling worked for the General Public Utilities Service Corporation in systems operations and the American Electric Power Service Corporation in bulk transmission planning. Mr. Herling earned a bachelor of science degree in electric power engineering and a master of engineering degree in electric power engineering, both from Rensselaer Polytechnic Institute. He is a licensed professional engineer in the state of Ohio. 4 <Presentation Title/Client Name> Today’s Panelists Justin M. Campbell Vice President Edison Transmission, LLC Rosemead, California Tel: 213.805.5752 justin.campbell@edisonenergy.com Justin Campbell is vice president and assistant treasurer of Edison Transmission, LLC, an indirect subsidiary of Edison International. He is responsible for strategy, business development, and policy for the company. Campbell has been in his current role since 2014 when Edison Transmission was founded. In 2010, Campbell joined Edison International’s utility subsidiary, Southern California Edison (SCE). As a member of SCE’s Transmission & Distribution group, he was responsible for portions of the company’s General Rate Case, leading a team charged with improving the company’s cost estimating for major projects, and managing an effort to re-baseline cost forecasts for 100+ capital projects representing $5 billion of investment. Subsequently, he joined Edison International’s strategic planning group, where his work contributed to the formation of Edison Transmission and other corporate strategic initiatives. Campbell’s career in the utility industry started at the U.S. Federal Energy Regulatory Commission (FERC) in 2003. At FERC, he worked on policy related to market-based rate sales of wholesale power and affiliate transaction rules. After serving at FERC, Campbell worked for the global investment bank Houlihan Lokey where he managed staff through complex financial analysis including valuation of public and private businesses for purposes including private equity portfolio valuation, goodwill impairment testing, and litigation support. He earned a master of business administration degree from the University of Southern California and a bachelor of science from Vanderbilt University, majoring in economics and engineering science. 5 <Presentation Title/Client Name> Today’s Panelists Joshua Burkholder Director Transmission Asset Strategy American Electric Power & Transource Energy Columbus, Ohio Tel: 614.716.2828 jburkholder@aep.com Joshua Burkholder, director of Transmission Asset Strategy for Transource Energy, a subsidiary of American Electric Power and Great Plains Energy, is responsible for securing competitive transmission projects within the PJM, SPP and MISO regions. In this role, Mr. Burkholder is leading Transource Energy’s efforts in PJM’s “Artificial Island” competitive process. Mr. Burkholder was previously manager of Transmission Strategy and Business Development and responsible for the development of AEP's new state transmission companies or "Transcos." In that role he was responsible for the strategic implementation of Transcos across AEP's eleven state service territory. He also has held the position of manager of Strategic Initiatives with responsibility for the overall content of AEP's strategic plan, strategic studies, corporate development and merger and acquisition analysis. Mr. Burkholder has served in Commercial Operations, working on business development projects and AEP's integration into PJM. Mr. Burkholder earned a bachelor's degree with honors in economics from University of Maryland, and a master's degree in business administration from The Ohio State University. 6 <Presentation Title/Client Name> Today’s Panelists Harry Singh Vice President Goldman, Sachs & Co. New York, New York Tel: 212.357.6449 harry.singh@gs.com Harry Singh is a Vice President in the US Power Trading group at Goldman Sachs and also currently serves as the Chairman of WSPP. He has been involved in power market design issues as well as origination of structured commercial transactions in power and environmental markets. Prior to his current position, he was with RBS Sempra Commodities. He also worked as a Senior Advisor at the Federal Energy Regulatory Commission (FERC) in the Office of Energy Market Regulation and the Office of Enforcement. He has held various positions at PG&E Corp and its regulated and unregulated subsidiaries. He holds a PhD in Electrical Engineering from the University of Wisconsin-Madison. 7 <Presentation Title/Client Name> Today’s Panelists William R. Hollaway, Ph.D. Partner Gibson, Dunn & Crutcher LLP Washington, D.C. Tel: 202. 955.8592 WHollaway@gibsondunn.com William R. Hollaway is a partner in Gibson Dunn’s Washington, D.C. office. Dr. Hollaway has extensive experience representing clients on a broad range of issues in the energy regulatory and energy transactional fields, including numerous proceedings and matters before the Federal Energy Regulatory Commission (FERC). His clients include independent power producers and independent transmission companies, as well as traditional regulated generation and transmission utilities. Dr. Hollaway's deep understanding of power generation and transmission technology has enabled him to work seamlessly with clients on virtually every type of power generating facility and transmission project. He has worked at length with wind power resources as well as more traditional generation powered by natural gas, nuclear, coal, and hydro. Dr. Hollaway has also worked on transmission projects, including both traditional Alternating Current projects and more recent High Voltage Direct Current transmission projects. He has in-depth knowledge of representing clients in matters relating to independent transmission development and interconnection agreements, including his ground-breaking work on the Neptune Regional Transmission System. Dr. Hollaway has litigated hearings before the FERC and has successfully negotiated beneficial settlements for clients in both informal and formal dispute resolution proceedings. He has negotiated and drafted a variety of contracts and other agreements, including long-term agreements for new nuclear power plants. Dr. Hollaway has represented clients in mergers and acquisitions in the power industry, including structuring of transactions to address regulatory requirements in establishing and performing due diligence reviews and obtaining approvals to close the transactions. Dr. Hollaway received his Juris Doctor degree, magna cum laude, from Georgetown University. Dr. Hollaway has three degrees in nuclear engineering. He earned his Ph.D. and Master of Science degrees in nuclear engineering from the Massachusetts Institute of Technology (M.I.T.). and a Bachelor of Nuclear Engineering degree, with highest honors, from the Georgia Institute of Technology. 8 <Presentation Title/Client Name> PJM Order 1000 Implementation: Proposal Window Process Steven R. Herling Vice President, Planning PJM Interconnection 9 <Presentation Title/Client Name> PJM as Part of the Eastern Interconnection • 27% of generation in Eastern Interconnection • 28% of load in Eastern Interconnection • 20% of transmission assets in Eastern Interconnection KEY STATISTICS PJM member companies 900+ millions of people served 61 peak load in megawatts 165,492 MWs of generating capacity 183,604 miles of transmission lines 62,556 2013 GWh of annual energy 791,089 generation sources 1,376 square miles of territory 243,417 area served 13 states + DC externally facing tie lines 191 21% of U.S. GDP produced in PJM 10 <Presentation Title/Client Name> PJM Backbone Transmission System 11 <Presentation Title/Client Name> RTEP Development Drivers 12 <Presentation Title/Client Name> RTEP Decision-Making Process 13 <Presentation Title/Client Name> RTEP Process - Details 14 <Presentation Title/Client Name> Competitive Solutions - Window Process Greater opportunities for transmission development by non-incumbents. One or more needs: reliability, market efficiency, operational performance, public policy If included in RTEP, project could be assigned to proposing entity to build. Competitive solicitation window duration based on project classes: − Long-lead projects: reliability or market efficiency driven upgrades needed in year six or beyond – 120 day window. − Short-term projects: reliability driven upgrades needed in year four or five – 30 day window. − Immediate-need projects: reliability driven upgrades needed in three years or less; window if possible, likely less than 30 days, nominally. 15 <Presentation Title/Client Name> RTEP Window Process 16 <Presentation Title/Client Name> Analytical Evaluation Which project most efficient, cost-effective? Proposal would solve/mitigate posted violation, system condition or economic constraint. Secondary benefits - addressing other system reliability, operational performance, market efficiency or public policy objectives. Other factors: − Cost effectiveness − Ability to complete project on time − Risk / delay to obtain required regulatory approvals. 17 <Presentation Title/Client Name> Analytical Evaluation Reliability Analyses Does project solve issue as proposed? Does it cause other reliability issues? Transient stability, voltage, thermal, and short circuit performance, NERC reliability planning criteria Similar analyses for operational performance issues Market Efficiency Analyses Congestion relief as proposed? Meet established 1.25:1 benefit-to-cost metric? Public Policy Analyses Ability to satisfy public policy objectives (e.g., renewable energy delivery to customer load within state) 18 <Presentation Title/Client Name> Company Evaluation Info submitted as part of the project proposal package Project specific experience: − Evidence of ability to secure financing − Engineering / design − Development / right-of-way acquisition − Construction − Operations − Maintenance 19 <Presentation Title/Client Name> Constructability Evaluation Assessment of project/construction risks: 20 <Presentation Title/Client Name> 2013 Proposal Windows Artificial Island • • • • Window opened on 4/29/2013 Closed on 6/28/2013 26 individual proposals addressing congestion from 7 entities Approx. $100M - $1.55B Market Efficiency • • • • • Window opened on 8/12/2013 Closed on 9/26/2013 17 individual proposals addressing congestion from 6 entities $0.19M - $528M 1 project selected - $8M 21 <Presentation Title/Client Name> 2014 RTEP Proposal Windows RTEP Window 1 - Reliability • Window opened on 6/27/2014 • Closed on 7/28/2014 • 106 individual proposals addressing congestion from 15 entities − 46 TO upgrade proposals: $0.02M to $139.2M − 60 greenfield Proposals: $10.2M to $1.4B • 22 projects approved - all upgrades - Total $82.03M RTEP Window 2 - Reliability • Window opened on 10/17/2014 • Closed on 11/17/2014 • 79 individual proposals addressing congestion from 14 entities − 45 TO upgrade proposals: $0.2M to $103.7M − 34 greenfield Proposals: $6.1M to $450M • 33 projects approved - 4 greenfield, 29 upgrades - all to incumbent 22 <Presentation Title/Client Name> 2014 RTEP Proposal Windows RTEP Window 2 Addendum - Reliability • • • • Window opened on 2/24/2015 Closed on 3/12/2015 10 individual proposals addressing congestion from 4 entities $0.96M - $25.5M 2014/15 Long-Term Window – Reliability, Market Efficiency • • • • Window opened on 10/30/2014 Closed on 2/27/2015 119 individual proposals addressing congestion from 22 entities $0.01M - $432.5M 23 <Presentation Title/Client Name> Lessons Learned Discussion Communications Evaluation Process 24 <Presentation Title/Client Name> Communications Issues Pre-Window Preparation • Case development and availability • Software tool issues • CEII clearance/restricted access on web site Problem Statement Detail • Problem definition • Applicable performance criteria Proposal Template • • • • Upgrades vs. greenfield projects Detail of cost estimates and treatment of contingency Redaction guidelines Cost capping/containment language 25 <Presentation Title/Client Name> Evaluation Issues Development of Most Effective Solution • Minor modifications to proposals • Combination of separable proposal elements Pre-defined, Formulaic Evaluation Template • Unique to each problem • Transparency Constructability Review • • • • Internal staff review vs. consultant review Review of cost estimates Qualifications of environmental/siting consultants Availability of consultants – many already working for transmission developers 26 <Presentation Title/Client Name> Process Issues Multi-Step Solicitation • Current process is sponsorship based • Consider developing most effective solution and then soliciting bids Sequencing of Windows During Planning Cycle • Separate window for each major body of analysis • One window to cover entire planning cycle 27 <Presentation Title/Client Name> Competitive Transmission Justin M. Campbell Vice President Edison Transmission, LLC 28 <Presentation Title/Client Name> Edison Transmission Introduction Established by Edison International (NYSE: EIX) to develop, acquire, own and operate transmission assets, including those subject to FERC Order No. 1000 Evaluating opportunities to bid on FERC Order No. 1000 projects, develop projects outside FERC Order No. 1000 processes, and acquire operating assets An affiliate of Southern California Edison, which has five million customers in a 50,000 square mile service territory Engaging in the California ISO, Midcontinent ISO, Southwest Power Pool, and PJM; currently evaluating participation in other markets 29 <Presentation Title/Client Name> Bids in the California ISO In 2014, Edison Transmission and Transource Energy formed Golden State Transmission, LLC and bid on two projects in California Estrella Substation Project • Four bidders: PG&E, NextEra, Brookfield, and Golden State Transmission • NextEra selected based in part on cost containment measures Wheeler Ridge Junction Substation Project • Four bidders: PG&E, NextEra, Brookfield, and Golden State Transmission • PG&E selected based in part on site control and ability to operate the facility 30 <Presentation Title/Client Name> Questions Competitive Opportunity: • Will there be meaningful investment in transmission? • If so, how much of that will be available to competition? Developer Selection: • How will the RTOs account for cost containment measures and other factors in selecting winning developers? 31 <Presentation Title/Client Name> Competitive Transmission Joshua Burkholder Director of Asset Strategy Transource Energy 32 <Presentation Title/Client Name> Introduction to AEP Transmission AEP is one of the largest electric utilities in the United States, producing and delivering electricity to more than five million customers across a 200,000 + square mile service territory 38,000 MW of generating capacity 39,000 miles of electric transmission lines 215,000 miles of electric distribution lines AEP is the largest owner of electric transmission infrastructure in the US Own, operate, and maintain transmission across every voltage class, including 2,100 miles of 765 kV and HVDC $1 - $1.5 billion of annual spend on transmission CAPEX Own or currently developing RTO-approved projects in 13 states Centralized business unit of ~2,100 employees providing low-cost services throughout the full lifecycle of transmission facilities AEP has a rich history of technology leadership in transmission History of success creating transmission partnerships within and beyond existing service territory Partners include: Duke, Exelon, MidAmerican, Great Plains Energy, Westar, Edison Transmission and AltaLink 33 <Presentation Title/Client Name> Introduction to Transource Energy • Transource Energy is a joint venture between AEP and GPE to pursue competitiveregulated transmission projects • Ownership structure: AEP 86.5% / GPE 13.5% • Transource is the exclusive vehicle through which AEP and GPE will pursue competitive-regulated transmission projects both within and beyond the respective utility service territories of each member • Transource has initiated its operations with two SPP-approved 345-kV transmission projects currently under construction in Missouri • Sibley-Nebraska City ($332 million) and Iatan-Nashua ($65 million) • Secured approval of formula rates (FERC) and state utility status (Missouri PSC) for Transource Missouri subsidiary in 2013 • Transfer of Missouri projects from GPE to Transource closed on January 2, 2014 • Transource is highly active in its core markets of PJM, MISO, and SPP • Finalist in PJM Artificial Island process and proposed multiple projects in other PJM “windows” • Participating in SPP and MISO transmission planning processes and pre-qualified to respond to competitive Requests For Proposals • Transource will evaluate participation in additional regions as markets continue to develop • Golden State Transmission partnership with Edison Transmission in CAISO • Athabasca Transmission partnership with AltaLink in Alberta, Canada 34 <Presentation Title/Client Name> Entries Into the Competitive Marketplace 2012 2013 2014 2015 • Companies created by non-utility entities are beginning to emerge: • Grid Alliance was recently formed by Blackstone • Brookfield Transmission was recently formed by Brookfield Asset Management • Non-U.S. entities currently participating include: AltaLink, Elecnor, AWC, TBC, Pattern Energy, Clean Line (via National Grid), Isolux 35 <Presentation Title/Client Name> Competitive Transmission: The Next Big Thing? • Current Market Status: “Lots of Hounds and Few Foxes” • PJM: prolonged “tiebreaking” for Artificial Island; 100+ proposals submitted in 2014/2015 Market Efficiency Window with most addressing similar issues • SPP: 1,200+ project ideas (“DPPs”) received resulting in one competitive project in 2015 • No competitive projects in MISO in 2015 • Where are the foxes? • Natural lull in higher voltage, greenfield projects following period of build out • Long-term drivers for transmission remain strong (generation mix changes, aging infrastructure, congestion relief) • Policy makers need to be cautious of “short term planning” that avoids competitive projects • What’s Working? >>> Transmission customers are already seeing benefits • Innovative, cost effective project ideas • Emergence of cost containment (also represents a significant challenge in evaluating proposals and developer selection) • Market rules are being ironed out before next wave of investment 36 <Presentation Title/Client Name> Competitive Transmission Landscape Harry Singh Vice President Goldman Sachs & Co. Prepared by a Goldman Sachs sales and trading desk, which may have a position in the products mentioned that is inconsistent with the views expressed in this material. In evaluating this material, you should know that it could have been previously provided to other clients and/or internal Goldman Sachs personnel, who could have already acted on it. The views or ideas expressed here are those of the desk and / or author only and are not an “official view” of Goldman Sachs; others at Goldman Sachs may have opinions or may express views that are contrary to those herein. This material is not independent advice and is not a product of Global Investment Research. This material is a solicitation of derivatives business generally, only for the purposes of, and to the extent it would otherwise be subject to, CFTC Regulations 1.71 and 23.605. The views expressed here are those of the author and not attributable to Goldman Sachs 37 <Presentation Title/Client Name> Competitive Transmission Landscape Two Major categories for Independent Transmission Projects • Merchant projects • Order 1000 projects Other categories can include cost based “participant funded” projects Different drivers for transmission projects such as delivery of renewable energy to meet RPS targets and economic benefit (congestion relief) Policy focus on encouraging transmission investment at lowest cost 38 <Presentation Title/Client Name> Merchant Transmission Projects Merchant projects • Investor funds a new project or upgrade • Incremental Transmission capacity/rights created by merchant project are awarded to investor Projects within an RTO market • Entity funding merchant project or upgrade is awarded long-term Financial Transmission Rights (FTRs) or Incremental Auction Revenue Rights (IARRs) for 30 years or life of facility • Required under FERC Order 681 • Examples include projects/upgrades under Attachment S and Attachment EE of the PJM Tariff Projects across RTOs or outside of RTOs • Evolution of FERC policy to allow more flexibility on awarding up to 100 percent of capacity to anchor shippers including affiliates1 • Examples include HVDC links across RTOs (e.g. Neptune), projects for integrating renewables (e.g., Zephyr, Western Spirit, MATL) 1. Allocation of capacity on new merchant transmission projects – Final Policy Statement, Docket AD12-9 http://www.ferc.gov/whats-new/comm-meet/2013/011713/E-2.pdf 39 <Presentation Title/Client Name> Order 1000 Projects Order 1000 projects1 • Cost recovery in RTO Transmission Access Charge • Transmission rights created by project are awarded to Load Serving Entities that pay the Transmission Access Charge • Incumbent Transmission Owner (TO) no longer has Right of First Refusal (ROFR) subject to some exceptions (e.g., upgrades to existing projects, those using existing rights of way and local projects) • Project must meet certain conditions to be eligible for competitive solicitation – e.g., new project and part of regional plan Details on which projects are eligible for competitive solution vary across RTOs • Whether or not a project is subject to competitive solicitation can depend on Timing of need (e.g. PJM), voltage level (e.g. CAISO, SPP), driver for project (MISO) • Some RTOs define need with competition among potential solutions (e.g. PJM) while others select the specific projects that are open to competitive solicitation (e.g., CAISO) Examples of projects subject to competitive solicitation include the Artificial Island project in PJM, Delaney Colorado River, Harry Allen, Gates-Gregg projects in CAISO2 1. FERC Order 1000 on Transmission Planning and Cost Allocation by Transmission Owning and Operating Public Utilities http://www.ferc.gov/industries/electric/indus-act/trans-plan.asp 2. See Gates-Gregg Project – Project Sponsor and Selection Report, California ISO, Nov 2013 http://www.caiso.com/Documents/Gates-GreggProject-ProjectSponsorSelectionReport.pdf 40 <Presentation Title/Client Name> CAISO Transmission Access Charge Source: CAISO https://www.caiso.com/market/Pages/TransmissionOperations/Default.aspx 41 <Presentation Title/Client Name> Some Issues for Discussion What is the role for merchant transmission? Can merchant and cost based projects co-exist within RTOs? How can a merchant developer hedge risk? 42 <Presentation Title/Client Name> Disclaimers . This message has been prepared by personnel in the Securities Division of one or more affiliates of The Goldman Sachs Group, Inc. ("Goldman Sachs") and is not the product of Global Investment Research. 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There is no representation that any transaction can or could have been effected at such terms or prices. Proposed terms and conditions are for discussion purposes only. Finalized terms and conditions are subject to further discussion and negotiation. © 2014 Goldman Sachs. All rights reserved. 44 <Presentation Title/Client Name> Competitive Transmission: The Next Big Thing William R. Hollaway Partner Gibson, Dunn & Crutcher LLP 45 <Presentation Title/Client Name> Gibson Dunn – Who We Are Large international law firm Partner Ph.D. in Nuclear Engineering from MIT Environmental Science Expertise in Project Development, Acquisitions, Corporate Structuring, Financing • One stop shopping • Regulatory, corporate, financing, real estate and land use, permitting, environmental, tax 46 <Presentation Title/Client Name> Competitive Transmission – What is It? Everything that isn’t given by right It has to be earned, on its own merits Order 1000 projects RFP projects Inter-regional projects – Seams Intra-regional projects – Customer funded projects Intra-regional projects – Creative projects Renewables projects • Super-highways • Offshore collectors Can be rate-based or bilateral 47 <Presentation Title/Client Name> Our Project Experience in Competitive Transmission 15 years of experience in competitive transmission, including: Neptune Regional Transmission System Hudson Transmission Poseidon Transmission Vermont Green Line Edison Transmission Golden State Transmission Customer funded upgrades 48 <Presentation Title/Client Name> Big Issues for Competitive Transmission How to Identify Projects • PJM model vs. California ISO model • Identification of Overloads or Identification of Projects • RTO identifies overloads, Bidders identify and implement projects (PJM) • RTO identifies projects, Bidders implement projects (California ISO) Role of Cost Containment • Methods • Weighting • Enforcing cost commitments Is there a Level Playing Field between Incumbents and Non-Incumbents? Continuing Role for Merchant Transmission 49 <Presentation Title/Client Name> Q&A 50 <Presentation Title/Client Name> Gibson Dunn Offices Beijing Unit 1301, Tower 1 China Central Place No. 81 Jianguo Road Chaoyang District Beijing 100025, P.R.C. +86 10 6502 8500 Brussels Avenue Louise 480 1050 Brussels Belgium +32 (0)2 554 70 00 Century City 2029 Century Park East Los Angeles, CA 90067-3026 +1 310.552.8500 Dallas 2100 McKinney Avenue Suite 1100 Dallas, TX 75201-6912 +1 214.698.3100 Denver 1801 California Street Suite 4200 Denver, CO 80202-2642 +1 303.298.5700 Dubai Building 5, Level 4 Dubai International Finance Centre P.O. 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