EXHIBIT 99.524 INTER-SC TRADE ADJUSTMENT BIDS Modeling Adjustment Bids on Inter-SC Trades as Adjustment Bids on Loads INTER-SC SALE EXAMPLE o SC1 sells energy to SC2 in a zone. - SC1 is to be paid SC2's market price for the energy. - SC1 is willing to sell (and SC2 is willing to buy) 100 MWh at SC2's unconstrained market price of $25/MWh. o Congestion Management can cause SC2's market price in the zone to change. - If zonal price falls, SC1 wants to decrease its sale to SC2. - If zonal price rises, SC1 wants to sell more to SC2. CHANGE TO INTER-SC SALE MODELED AS A LOAD [GRAPHIC] ADJUSTING AN INTER-SC SALE... o SC1 specifies a load in SC2's portfolio in the zone. - SC1 submits an IPS of zero for this load. - SC1 can offer to buy back its inter-SC sale to SC2. o Submit an adjustment bid to increase the load if the price falls. - SC1 can offer to increase the sale to SC2. o Submit an adjustment bid to decrease the load (to negative load) if price rises. ... ADJUSTING AN INTER-SC SALE [GRAPHIC] INTER-SC PURCHASE EXAMPLE o SC1 buys energy from SC2 in a zone. - SC1 is to pay SC2's market price for the energy. - SC1 is willing to buy (and SC2 is willing to sell) 100 MWh at SC2's unconstrained market price of $15/MWh. o Congestion Management can cause SC2's market price in the zone to change. - If zonal price rises, SC1 wants to decrease its purchase from SC2. - If zonal price falls, SC1 wants to buy more from SC2. CHANGE TO INTER-SC PURCHASE AS A LOAD [GRAPHIC] ADJUSTING AN INTER-SC PURCHASE... o SC1 specifies a load in SC2's portfolio in the zone. - SC1 submits an IPS of zero for this load. - SC1 can offer to sell back its inter-SC purchase from SC2. o Submit and adjustment bid to decrease the load (to negative load) if the price rises. - SC1 can offer to increase the purchase from SC2. o Submit an adjustment bid to increase the load if price falls. ...ADJUSTING AN INTER-SC PURCHASE [GRAPH] REQUIREMENT o Only one SC involved in an inter-Sc trade may submit an adjustment bid for the inter-SC trade: - If SC1 submits the adjustment bid, SC1 will have a load in SC2's market to model the adjustment. - The prices in SC2's market govern how the CM process will adjust the inter-SC trade by adjusting SC1's load in SC2's market. EXAMPLE o Two zones, A and B and two SCs, PX and SC. o PX auction: - G1 bids to sell up to 110 MWh @ $20/MWh - G2 bids to sell up to 100 MWh @ $35/MWh - SC bids to sell up to 30 MWh @ $30/MWh in Zone A - L1 bids to buy 100 MWh @ $700/MWh - L2 bids to buy 100 MWh @ $700/MWh o PX UMCP = $35/MWh and SC sells 30 MWh via inter-SC trade. - SC wants to back out of trade if PX zonal price in zone A falls below $30/MWh. ADJUSTMENT BIDS [GRAPHIC] FINAL SCHEDULE [GRAPHIC] Results o PX zonal price in A falls to $20/MWh. - SC buys back the energy it sells to PX. o PX pays SC 30MWh * $20/MWh = $600 for inter-SC trade. o SC pays PX 30MWh * $20/MWh = $600 for load to buy back. o Increasing L(A,SC) to buy back inter-SC trade reduces flow from A to B. - This has the same impact on inter-zonal congestion as reducing G3 and reducing the inter-SC trade. o Real-time imbalances: - L(A,SC) is zero causing an imbalance of 30 MWh in load. - SC reduces G3 by 30 MWh to account for the buy-back producing a 30 MWh imbalance in generation. - SC's net imbalance is 0. CHANGING RESOURCES... o Suppose that SC1 models the adjustment bid on an inter-SC trade as a load in SC2's market: - The CM process will adjust SC2's resources to account for any change to the inter-SC trade. - SC1's resources will not be automatically adjusted to account for the change to inter-SC trade. o If the load that models the inter-SC adjustment is increased: - CM does not decrease SC1's generation to account for the decreased sale to (increased purchase from SC2). - SC1 would decrease its actual generation in real-time because of its decreased inter-SC sale (increased purchase). - In real-time, the imbalance due to SC1's load would match the imbalance due to the reduction in SC1 generation, so the imbalance charge would be zero. ...CHANGING RESOURCES o If the load used that models the inter-SC adjustment is decreased: - CM does not increase SC1's genereation to account for the increased sale to (decreased purchase from SC2) - SC1 would increase its actual generation in real-time because of its increased inter-SC sale (decreased inter-SC purchase). - In real-time, the imbalance due to SC1's load would match the imbalance due to the increase in SC1's generation, so the imbalance charge would be zero. LOCATION OF INTER-SC TRADE o SC1 wishes to submit an adjustment bid on its inter-SC trade with SC2 in Zone A. - SC1 should have resources on Zone A that it will use to account for any changes in the inter-SC trade. - This prevents SC1 from scheduling inter-zonal transmission capacity that it will not use.