I. CREDITWORTHINESS AND TOTAL CREDIT LIMIT A.



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I. CREDITWORTHINESS AND TOTAL CREDIT LIMIT A. Evaluation of Creditworthiness A Credit will be generated from the Transmission Provider s review and analysis of the information obtained through the initial and ongoing credit evaluation process described in Section I of this Credit Policy. Key factors in the scoring process include, but are not limited to, ratings from Rating Agencies, financial statements and Significant Trade References. The Transmission Provider will consistently apply the credit scoring process described in Section I.A of this Credit Policy in determining Credit s. 1) Credit Public Power Sector The Public Power analysis will be comprised of a Financial and Qualitative analysis. Each analysis is then weighted as shown below to build a total composite score. Analysis Weight Financial 40% Qualitative 60% Financial (40%) The financial score is comprised of the financial measures below. These measures will be calculated for each Public Power Market Participant. The calculated measures are then compared to industry benchmarks to assign a score of one (1) to six (6) for each measure. A score of one (1) indicates that the Market Participant has strong financial health with regards to the relevant measure, while a score of six (6) indicates poor financial health with regards to the relevant measure. These scores are then assigned a weighting to calculate a total financial score. Measure Weight Current Ratio 10% Working Capital 10% Tangible Net Worth 10% EBIT Interest Coverage 10% EBITDA Interest Coverage 10% Pre-tax Return on Equity 10% Long-term Debt / Equity 20% Total Debt / Total Capitalization 20% Public Power Ratios Current Ratio --Current Assets /Current Liabilities Working Capital -- Current Assets - Current Liabilities Tangible Net Worth -- Total Equity Restricted Cash Intangible Assets Goodwill Investment in High Risk Affiliates Receivables from High Risk Affiliates Net Value of Long Term Trading Book Nuclear Decommissioning Fund.

EBIT Interest Coverage -- (Interest Expense + Income Taxes + Net Income) /Interest Expense EBITDA Interest Coverage -- (Depreciation & Amortization + Interest Expense + Income Taxes + Net Income) /Interest Expense Total Debt to Equity -- Total Debt* / Total Equity Total Debt to Capitalization -- Total Debt* / (Total Debt* + Total Equity) Pretax Return on Equity -- (Income Taxes + Net Income) / Total Equity) * Total debt consists of Short-Term Debt, Current Portion of Long-Term Debt, Long- Term Debt, Preferred Stock, and Operating Leases.

Public Power Financial Benchmarks M (Thousand) MM (Million) Current Ratio Working Capital Working Capital or or 0.3x 6 100M 6 0.3x 0.8x 5 $100M $5MM 5 0.8x 1.3x 4 $5MM $10MM 4 1.3x 1.6x 3 $10MM $25MM 3 1.6x 1.9x 2 $25MM $40MM 2 1.9x 1 $40MM 1 EBITDA Int. Coverage Debt/Equity or or 1.7x 6 12.4x 6 1.7x 2x 5 7.9x 12.4x 5 2.0x 2.3x 4 3.4x 7.9x 4 2.3x 2.5x 3 2.3x 3.4x 3 2.5x 2.7x 2 0.1x 2.3x 2 2.7x 1 0.1x 1 Tangible Net Worth EBIT Int. Coverage or or $15MM 6 1.0x 6 $15MM $40MM 5 1.0x 1.1x 5 $40MM $65MM 4 1.1x 1.2x 4 $65MM $75MM 3 1.2x 1.3x 3 $75MM $85MM 2 1.3x 1.4x 2 $85MM 1 1.4x 1 Total Debt / Total Capital Pre-Tax ROE or or 100% 6 1.30% 6 90% 100% 5 1.3% 3.4% 5 80% 90% 4 3.4% 5.5% 4 70% 80% 3 5.5% 12.6% 3 10% 70% 2 12.6% 19.7% 2 10% 1 19.7% 1

Qualitative (60%) The qualitative score will assess all non-financial measure information about a Market Participant s financial health. The qualitative analysis will take into account a variety of information, but at a minimum will include the assessment of the following characteristics of each Public Power Market Participant: (i) the ability to set rates without seeking regulatory approval; (ii) the financial protections afforded unsecured creditors contained in the contracts and other legal documents related to the formation and governance of public power entities; (iii) the number and composition of members or customers of the entity; (iv) the exposure to energy price risk for load served by the entity; (v) rating agency ratings assigned to unsecured debt; and (vi) other non-financial measures of creditworthiness. To illustrate, assume the following: Public Power Qualitative = 3.0 Quantitative Measures: Value Weight Current Ratio = 0.63 5 10% Working Capital = ($43,234,000) 6 10% Tangible Net Worth = $253,229,110 1 10% EBIT Interest Coverage = 1.88 1 10% EBITDA Interest Coverage = 2.98 1 10% Debt-to-Equity Ratio = 0.58 2 20% Total Debt-to-Total Capital = 1.37 2 20% Pre-Tax Return on Equity = 6.11 3 10% Public Power Quantitative = (5 x 10%) + (6 x 10%) + (1 x 10%) + (1 x 10%) + (1 x 10%) + (2 x 20%) + (2 x 20%) + (3 x 10%) = 2.50 Public Power Composite = (60% x 3.0) + (40% x 2.5) = 2.80 2) Credit Non-Public Power Sector A Non-Public Power Composite shall be derived for each Participant that does not meet the definition of Public Power as defined in Module A. The Non- Public Power Analysis will be comprised of a Financial and Qualitative analysis. Each analysis is then weighted as shown below to build a total composite score. Analysis Weight Financial 60% Qualitative 40%

Financial (60%) The financial score is comprised of the financial measures below. These measures will be calculated for each Non-Public Power Market Participant. The calculated measures are then compared to industry benchmarks to assign a score of one (1) to six (6) for each measure. A score of one (1) indicates that the Market Participant has strong financial health with regards to the relevant measure, while a score of six (6) indicates poor financial health with regards to the relevant measure. These scores are then assigned a weighting to calculate a total financial score. The relative weight of the financial measures is as follows: Measure Weight EBIT Interest Coverage 35% Total Debt / Total Capitalization 30% CFFO/Total Debt 25% Tangible Net Worth 10% Non-Public Power Ratios EBIT Interest Coverage -- (Interest Expense + Income Taxes + Net Income) /Interest Expense Total Debt to Capitalization -- Total Debt* / (Total Debt* + Total Equity) CFFO/Total Debt -- Cash Flow from Operations/Total Debt* Tangible Net Worth -- Total Equity Restricted Cash Intangible Assets Goodwill Investment in High Risk Affiliates Receivables from High Risk Affiliates Net Value of Long Term Trading Book Nuclear Decommissioning Fund. * Total debt consists of Short-Term Debt, Current Portion of Long-Term Debt, Long- Term Debt, Preferred Stock, and Operating Leases.

Non-Public Power Financial Benchmarks EBIT Interest Coverage Total Debt/Total Cap. or or 0.4x 6 75% 6 0.4x 1.5x 5 61% 75% 5 1.5x 2.6x 4 54% 61% 4 2.6x 3.4x 3 48% 54% 3 3.4x 3.9x 2 20% 48% 2 3.9x 1 20% 1 CFFO/Total Debt Tangible Net Worth or or 8% 6 $500MM 6 8% 10% 5 $500MM $1.2B 5 11% 18% 4 $1.2B $1.8B 4 18% 23% 3 $1.8B $3.5B 3 23% 28% 2 $3.5 $7B 2 28% 1 $7B 1 Qualitative (40%) The qualitative score will assess all non-financial measure information about a Market Participant s financial health. The qualitative analysis will take into account a variety of information, but at a minimum will include the assessment of the following characteristics of each Non-Public Power Market Participant: (i) the ability to set rates without seeking regulatory approval; (ii) the financial protections afforded unsecured creditors contained in the contracts and other legal documents related to the formation and governance of non-public power entities; (iii) the number and composition of members or customers of the entity; (iv) the exposure to energy price risk for load served by the entity and/or obligations to provide power to other parties; (v) rating agency ratings assigned to unsecured debt; and (iv) other non-financial measures of creditworthiness

To illustrate, assume the following: Non-Public Power Qualitative = 3.0 Quantitative Measures: Value Weight EBIT Interest Coverage = 3.98 1 30% Total Debt-to-Total Capital = 0.52 3 35% Cash Flow From Operations to Total Debt = 0.22 3 25% Tangible Net Worth = $4.354 billion 2 10% Non-Public Power Quantitative = (1 x 30%) + (3 x 35%) + (3 x 25%) + (2 x 10%) = 2.20 Non-Public Power Composite = (40% x 3.0) + (60% x 2.2) = 2.52 B. Unsecured Credit Allowance The suggested Unsecured Credit Allowance for a Participant is the lesser of $25,000,000 or the value determined by multiplying the Participant s Credit by the percentage value in Table 1 applicable to the Credit and type of Participant (e.g., Public Power or Non-Public Power). To illustrate, assume a Public Power Participant with a Credit of 2.80 and Tangible Net Worth of $253,229,111 would have a suggested Unsecured Credit Allowance computed as follows: Unsecured Credit Allowance = Table 1 Percentage f(credit ) x Tangible Net Worth = 8.0% x $253,229,111 = $20,258,329 To further illustrate, a Non-Public Power Participant with a Credit of 2.52 and Tangible Net Worth of $4.354 billion would have a suggested Unsecured Credit Allowance computed as follows: Unsecured Credit Allowance = Table 1 Percentage f(credit ) x Tangible Net Worth = 4.5% x $4,354,000,000 = $195,930,000 > $25,000,000 Therefore, maximum Unsecured Credit Allowance in this example is limited to $25,000,000.

C) Maximum Unsecured Credit Allowance: The maximum Unsecured Credit Allowance for a Participant shall be the lesser of: 1. The dollar amount determined by multiplying the applicable percentage value from Table 1 based on the Participant s business segment and Credit by the Tangible Net Worth for the Participant; or 2. $25 million, the maximum Unsecured Credit Allowance permitted per Participant. In the event that the Participant provides a Corporate Guaranty, the Unsecured Credit Allowance is based on the financial review conducted by the Transmission Provider of the entity providing the Corporate Guaranty, with a $25 million maximum Unsecured Credit Allowance permitted.

Table 1 Percent of Tangible Net Worth Composite Credit Non-Public Power Public Power 1.00 to 1.66 10.0% 12.0% 1.67 to 2.00 9.0% 11.0% 2.01 to 2.33 8.0% 10.0% 2.34 to 2.66 7.0% 9.0% 2.67 to 3.00 6.0% 8.0% 3.01 to 3.33 5.0% 7.0% 3.34 to 3.66 4.0% 6.0% 3.67 to 4.00 3.0% 5.0% 4.01 to 4.33 2.0% 3.5% 4.34 to 4.66 1.0% 2.0% 4.67 to 5.00 0.5% 1.0% 5.01 to 6.00 0.0% 0.0%