MANITOBA [IYDRO. Corporate Risk Management Middle Office Report Sept 2009



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MANITOBA [IYDRO Corporate Risk Management Middle Office Report Sept 2009 A. Credit On-going review and advisory support continued to be provided to PS&O (Power Sales and Operations) credit function to assist in revising and updating its credit policy and procedures. The policy and procedures (once approved by EPRMC and PSOMC) would result in revised counterparty credit limits. The revisions will be based on Global Credit Services credit scoring software and the revised policy and procedures. Corporate Credit Risk Management is also providing concurrent support to PS&O credit function. B. ICF Consulting Assignment - Independent Review of Export Sales and Associated Risks Middle Office continued coordinating additional information requirements and report drafts. The final report was provided by ICE on September 1 1th~ C. Long Term Export Sales Some procedures and processes could be futher improved and should be formally documented for long term export negotiations. Export Power Marketing has developed some preliminary improvements which have been discussed with Middle Office. Middle Office recommends development of the improvements be completed and implemented if possible prior to the Auditor General s Office conducting their audit. 0. MISO Market Conditions The average load in the MISO market declined 14.5% for July 2009 compared to July 2008. The decline in load for August 2009 compared to August 2008 lessened, down just over 6%. Average MISO system wide prices have declined more than 60% comparing July 2009 to July 2008 and 58% comparing August 2009 to August 2008. During July day ahead prices were negative at Minn Hub for a total of 9 hours due to high congestion. PIRA s most recent price outlook for Minn Hub during October, November, December 2009 has declined 24%, 10% and 15% respectively for each month.

Middle Office Report June 2009 2 E. Day AheadlReal Time Transactions We are unable to conduct risk assessment, transaction evaluation and trader compliance for day ahead and real time transactions due to the way Webtrader (the deal capture system) was set up for these transactions. These transactions are not captured by Webtrader in the same way as bilateral transactions are when traders enter into deals. This module was set up for billing/accounting purposes and the transactions are entered and identified by staff in Billing Services rather than being trader based. The deals are created at the time invoices are received from the MISC market and entered by the Billing Department of PS&C. Because of the way this module was designed it is difficult to determine the actual volume and price of an individual trade and who entered into the deal or if policy is being adhered. This module design presents a risk to the ability to conduct oversight and compliance. It should be noted that it may also present problems in the ability to set up an appropriate compliance program for FERC market manipulation. It would likely be costly to change at this stage. F. Short Term Transactions COMPLIANT The table below outlines total volumes and average price for contracts entered into by Power Trading during the period June to August 2009. Trade Secret and confidental

Middle Office Report June 2009 3 Short Term Transactions Up to the late of 5 months or next March 31st On-Peak Off-Peak Actual Projected Actual Projected MW per hour June July Aug Sept June July Aug Sept Forecast Supply 1 933 634 734 783 1,792 1,828 787 1,708 Volume Approved for Sale 500 400 400 500 500 500 300 200 Physical Bilateral Sales (New) 100-50 160 - - 25 25 Physical Bilateral Sales under existing Long Term Contracts Avg Price ($ US) 35.00-32.22 23.29 15 14.59 15 14.59 15 16.34 15 17.92 Financial Bilateral Sales (New) 0 0 0 0 0 0 0 0 Financial Sales under existing Long Term Contracts 150 Avg Price ($ US) - - 34.57 - - - - - Avg Index Price ($ US) 19.48 18.80 20.27 18.78 8.23 9.08 9.30 9.47 Remaining Surplus 400 400 200 340 485 485 260 160 Avg 50% Peak Risks associated with these transactions are primarily price and volume. Applicable policy/control requirements are outlined in Appendix A for reference. Trade secret and confidental

Middle Office Report June 2009 4 G. Surplus EnergylForward Position FORWARD POSITION REPORT October to December 2009 MWh Oct Nov Dec Dependable Book 241,515 221,025 230,230 Term Book 10,416 13,920 4,176 251,931 234,945 234,406 Avg Price Dependable Book2 $37.48 $36.62 $36.62 Avg Price Term Book2 28.00 31.00 32.00 Forecast Prices U.S. MWh3 $21.00 $30.75 $36.75 Includes On peak and Off peak 2 Avg Price On peak ~ On Peak as at Aug 9, 2009 Energy Surplus Position - Oct to Dec 2009 Surplus Quantities Approved for Sale MW per hour Oct Nov Dec ON PEAK Forecast Surplus Avg (50% Peak) 977 504 89 Peak 820 775 431 Quantitites Approved for Short Term Sales 500 300 200 New Short Term Sales Made To Date 21 29 0 Short Term Sales flowing under existing Long Term Contracts2 0 0 150 Remaining surplus from Quantities Approved 479 271 50 Forecast Surplus OFF PEAK ~yg (off-peak) 1,011 51 910 Quantitites Approved for Short Term Sales 100 100 100 New Short Term Sales Made To Date 21 29 29 Short Term Sales flowing under existing Long Term Contracts2 Remaining surplus from Quantities Approved 79 71 71 1 Various run dates used in decision-making 2These sales done based on availability of surplus Trade Secret and confidental

Middle Office Report June 2009 5 H. Related Merchant Transactions POSSIBLE NON COMPLIANCE For the two months June and July Webtrader reports show surplus positions (more mwh purchased than sold). June is particularly significant at almost 27,000 MWh. Webtrader monthly reports shows a material loss of over $1 million for the month of June. We will report back on this issue once it has been resolved. It may be that non related transactions have been included in this book. The attached table summarizes relevant information on the transactions for the period. Applicable policy/control requirements are outlined in Appendix B for reference. The transactions involve trading energy purchased, not generated by the corporation. The volume of transactions is currently limited by the capacity of the related transmission positions (short and long term). Risks associated with this activity, include the risk that the energy may not be accepted by the Canadian market, pricing may change in the Canadian market between the time energy is purchased in the day ahead market in U.S. and delivery of the sale into Canadian market at hourly or pre-dispatch price). In addition, a net position other than zero (purchases net of sale) may result in financial exposure. We would consider it to be a pure merchant transaction, which have not been approved at this time. Trade Secret and confidental

Middle Office Compliance Report Related Merchant Transactions June to August 2009 June ~July August US!CDN Market Total Total Total Total Total Total MWh Settlement MWh Settlement MWI1 Settlement Purchases[1] Sales Net Position 64,144 37,216 26,928 1,817,426 88,364 1,021,807 83,906 4,458 1,724,018 60,371 2,628,686 60.371 0 940,451 1.7 13.393 Total Trading Gains/(Losses)[2] -795,619 904,668 772,942 Profit Share to Third Party Other[31 Purchases Sales Total Trading Gains/(Losses) 9,555 9,555 267,602 293,500 25,898 6,540 6,540 186,425 192,435 6,010 8,149 8,149 234,218 291,686 57,468 Profit Share to Third Party Transmission & Market Costs[4] Net Profitf(Loss) (1,206,424) 129,790 520.841 [ii CDN dollar sales converted to US at Webtrader rate [21 Before transmission and market costs [31 Purchases not accepted by CDN market and sold back into US [41 Source: Webtrader monthly summary Page 6

APPENDIX A Short Term Contracts - Related Policy A. System Energy & Related Products - Management Control Plan1 System energy products include physical bilateral contracts, day ahead market and real time market power transactions and related products. The underlying intent for these transactions is the physical delivery of power to or from Manitoba Hydro s system. Forward sales and purchase contracts, two weeks and longer in duration are formalized in writing in accordance with the applicable Master Agreement. The power trader or marketer negotiates these forwards sales using industry pricing indicators as a guide. Pricing As a minimum, Hydra will require recovery of 110% of its incremental costs in making any short term forward sale commitment. The power trader or marketer uses this information along with industry pricing indicators to negotiate forward contracts. Transaction Limits No specific limits established in the Management Control Plan for short term physical forward sales. B. System Financial Products Put and call options, swaps and bilateral contracts for differences for power or natural gas for the purpose of managing the uncertainty in available generation or load forecast or fuel supplies for Hydro s power supply assets. In addition, these products may be used to enter into favorable forward sales or to minimize exposure to price volatility on power and gas purchases. Permitted Financial Products Put and call options, swaps, and bilateral contracts for differences. Financial Transmission Rights, auction revenue rights, virtual bids and offers and bilateral contracts registered as financial schedules. Volume Limits Cannot exceed the projected underlying physical position. Approved by the Board of Directors November 22, 2007

APPENDIX A Page 2 C. Approval Authority Transactions from existing generation or purchase from 15 calendar days up to the later of 5 months or the next March 3?t: Power Sales & Operations Market Committee ~r Division Manager Power Sales & Operations for volumes for purchase or sale and, Manager, Power Trading or Financial Trading Supervisor for transactions. D. Confirmation Method Either orally or through electronic communication or approved electronic platform followed up by written confirmation. The Management Control plan states that written contracts are reviewed, approved, and signed in accordance with the approval authority requirements noted above. Trade secret and Confidental

APPENDIX B Related Merchant Transactions - Related Policy A. Merchant Transactions - Management Control Plan Resale of power purchased from third parties and which either flows over transmission owned or reserved by/for Manitoba Hydro or was purchased for Manitoba Hydro system requirements and has subsequently been deemed surplus. Transaction Limits a Maximum net power position of 1000 GWh - Fixed price to fixed price transactions may be entered into only if there is a positive profit margin All other transactions may be entered into only if there is a positive expected value and with a term no more than three days in duration. Maximum duration six months B. Approval Authority Merchant Energy Products up to and including 14 calendar days in duration: Manager, Power Trading or Division Manager, Power Sales & Operations Merchant Energy Products Day Ahead: Day Ahead Power Trader or Financial Trading Supervisor Merchant Energy Products Real Time: Day Ahead Power Trader or Financial Trading Supervisor or Real Time Power Trader or Physical Trading Supervisor Trade Secret and confidental

APPENDIX C Transactions Two Weeks or Less in Duration - Related Policy Includes physical bilateral transactions up to two weeks and Day Ahead and Real Time market bids and offers. Market bids and offers are subject to minimum sell and maximum buy prices determined using short term water conditions and forecasted energy supply requirements. Trade secret and canfidental