Regulatory Flexibility Committee

1. INDIANA POWER OF WIND COALITION Regulatory Flexibility Committee Strategies for Procuring New Generation September 18, 2013

2. INDIANA POWER OF WIND COALITION The Challenge • There is no “free market” for procurement of energy and resources. • Utilities in regulated states are vertically integrated monopolies with a franchise agreement that entitles them to serve customers within the franchise area. • Currently, utilities develop integrated resource plans (IRP) which identify supply needs for customers. • Generally, utilities fulfill energy/capacity shortfall through request for proposals (RFP) and the utility typically chooses themselves.

3. INDIANA POWER OF WIND COALITION Other Challenges • Self build options don’t always take into account all transmission and interconnection costs. • Risk of construction delay and cost overruns are often not accounted for in self build options. • Utilities have the ability to recover additional costs from ratepayers. • Independent power producers (IPP) provide an all-in, binding cost when responding to request for proposals. • This includes all costs – including transmission and interconnection costs. • If the project is completed over budget, the risk is borne by the IPP as opposed to the ratepayer.

4. INDIANA POWER OF WIND COALITION Example of Utility Share of Supply Resources • Approx. 95% of all electricity comes from generation owned by the IOUs SOURCE: 2011 Utilities IRPs

5. INDIANA POWER OF WIND COALITION Comparison of Self-Build to Third Party Supply • Utilities receive no rate of return on power purchase agreement (PPA) and as a result forfeit potential returns for shareholders. • Lower cost to ratepayer for power purchase agreement, however this may not be the successful proposal. Current structure leads to inefficient outcomes 1 Lazard Levelized Cost of Energy Analysis Version 6.0, June 2012. Assumes Gas Combined Cycle at 40% capacity factor for 20 years at $61/MWh. 2 Lazard Levelized Cost of Energy Analysis Version 6.0, June 2012. Assumes Wind at 40% capacity factor for 20 years at $48/MWh.

6. INDIANA POWER OF WIND COALITION Example of Competitive Procurement Proposal • Allowing an earned rate of return still provides a lower cost to ratepayer. Ratepayer Savings: $98,392,320 Current structure leads to inefficient outcomes

7. INDIANA POWER OF WIND COALITION Benefits • Ensure ratepayer is served at lowest, efficient cost. Allow utility sector to balance the utility shareholder interests with the ratepayer’s desire for low cost energy. • Reduce ratepayer exposure to cost overrun risk. • Does not change the regulatory process that currently exists in each state. • Cooperative working relationships between utilities and independent power producers. • Alternative for utilities if capital constrained due to generation fleet retirement/retrofit costs, transmission expansion costs, and other system improvement costs. Leverage third parties to provide capital needed to maintain supply adequacy. • Provide appropriate human resources to support utilities in building new resources. Some utilities no longer have in-house capability for design, project management, and commissioning of new generation resources. The projected utility attrition rate is also a potential concern.

8. INDIANA POWER OF WIND COALITION Questions/Follow Up Speakers: Jason Minalga Manager, Regulatory Affairs Invenergy 312-582-1500 jminalga@invenergyllc.com Consultants: Tony Samuel President Samuel Solutions 317-403-2339 tsamuel@samuelsolutionsgroup.com