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      <span style="text-transform: uppercase"><font size="6"><b><br>
      So what exactly is risk management?</b></font></span></p>
      <font FACE="Arial-ItalicMT" SIZE="3"><i>
      <p ALIGN="LEFT">By Paul Wielgus, Managing Director, GDS Associates, Inc.</i></font><span style="color: black"><font size="2"><br>
      </font></span><font size="2">(<em>originally published by PMA OnLine Magazine: 
      May 21, 2006</em>)<br>
      <br>
      <a href="So%20What%20Exactly%20is%20Risk%20Mgmt.pdf">Download Article in 
      Adobe PDF</a></font><br>
&nbsp;</p>
      <font SIZE="3">
      <p ALIGN="LEFT">Buyers, sellers, and others in the energy business need to 
      understand the risks in this very uncertain environment in order to 
      maintain their responsibility to their stakeholders and to protect their 
      bottom line. Organizations can achieve their goals and objectives in this 
      uncertain business environment by developing a comprehensive risk 
      management program. At GDS, we understand that risk management is more 
      than energy price management, more than regulatory compliance, and that 
      each client faces a unique set of challenges and risks. To fully 
      understand and mitigate the risks that can affect your business and your 
      cost structure, your leadership team must have a complete view of&nbsp; 
      these exposures.</p>
      </font><font SIZE="4">
      <p ALIGN="LEFT">At Risk<b><i><br>
      </i></b></font><font SIZE="3">One does not have to wait long during a 
      conversation with others involved in the power industry to hear the word
      <b>&quot;risk&quot; </b>or the phrase <b>&quot;risk management</b>.<b>&quot; </b>Many of us 
      have a general idea of what the words risk management mean, but how they 
      can impact your organization may not be so obvious. </p>
      <p ALIGN="LEFT">With a great deal of attention being paid to the area of 
      risk management, it is easy to become overwhelmed or confused about what 
      it really means. A lot us focus that attention to managing or fixing the 
      price of our power and or fuel, kind of the trading model definition. <i>
      So, what exactly is Risk Management? </i>A simple way to define risk 
      management is: <i><b>The process of identifying, evaluating, and 
      mitigating the risks that threaten the strategic and financial goals of 
      your business.</p>
      </b></i>
      <p ALIGN="LEFT">Every business is vulnerable to a wide array of risks that 
      may or may not be specific to its particular industry, although only some 
      choose to actively acknowledge and address those risks in an attempt to 
      reduce exposure to them. Since the power industry is an inherently risky 
      one, the focus on risk management will only continue to increase as a 
      response. In our business, risks can be identified in virtually all 
      segments of the power supply industry, not just that risk associated with 
      the price of our power or fuels. These segments and can be divided more 
      simply into the three general categories: <b>1) supply side; 2) demand 
      side; </b>and <b>3) business-related. <br>
      <br>
      </b>Effective risk management encourages decision-makers to examine their 
      business process across the board to identify the various risks that can 
      affect it, and to begin thinking about how the exposure to these risks can 
      be best mitigated or minimized.</p>
      </font><font SIZE="4"><i>
      <p ALIGN="LEFT">At Risk...</i>Supply-Side<br>
      </font><font SIZE="3" COLOR="#202020">Supply-side risks generally fall 
      under one of the following four categories: 1) generation; 2) market; 3) 
      transmission; and 4) counterparty.</p>
      </font><font SIZE="3"><b>
      <p ALIGN="LEFT">Generation<br>
      </b></font><font SIZE="3" COLOR="#202020">You may be an owner in a power 
      plant or you may buy power under a unit purchase agreement tied to a 
      particular resource. Regardless, you could be confronted with several 
      potentially costly risks. These risks and associated potential costs can 
      arise during the construction phase of a project if you are involved 
      during that time, or during the operational period.</p>
      <p ALIGN="LEFT">As with any construction project, the biggest risk is the 
      project's schedule being delayed or extended. In most cases, a delayed 
      schedule results in an increase of interest-duringconstruction, and most 
      likely further increases in the capital costs. If the schedule is delayed 
      too long and the expected commercial operational date or COD is missed, 
      the delay could force an owner to go to the market and purchase 
      replacement power, most likely at a price different than what was planned. 
      And if higher than planned, the costs can be very unfavorable.</p>
      <p ALIGN="LEFT">Delays during the construction phase of a project can 
      arise from any number of potential problems. Some major ones include; 
      unforeseen environmental issues related to permitting and siting, problems 
      with the interconnection and supply of fuel, transmission service and 
      interconnection, water, performance issues related to the contractor, and 
      operating problems with the plant itself during commissioning<b>. </b>The 
      adage, </font><i><font SIZE="3" COLOR="#202020">�Time is money,&quot; </font>
      </i><font SIZE="3" COLOR="#202020">is especially true during the 
      construction phase of a power project, and virtually all of these risks 
      are inherent to the construction phase of any generation resource. 
      However, with proper management and well thought out contingency plans, 
      these risks can be properly measured and mitigated, thereby reducing the 
      likelihood of unforeseen and especially unfavorable consequences.</p>
      <p ALIGN="LEFT">Once the unit is operational, the owner must contend with 
      unscheduled outages, the risk of day-to-day operations, unforeseen capital 
      expenditures, and possible accidents. There is also the risk of 
      technological obsolescence of an owned generating plant resulting in lost 
      opportunity for cheaper alternatives. Long-term water and fuel supply 
      arrangements are typically settled prior to the operational start date, 
      but there is always the risk of the supply being temporarily interrupted 
      due to pipeline or other transportation problems, or even force majeure. 
      Here again, with proper management and well thought out contingency plans, 
      these risks can be properly measured and mitigated.</p>
      </font><font SIZE="3"><b>
      <p ALIGN="LEFT">Market Prices<br>
      </b></font><font SIZE="3" COLOR="#202020">There are aspects of buying or 
      generating power that are always in a state of change. The market prices 
      of fuel and power are good examples of this. The exposure to fuel and 
      power price volatility is the most significant supply-side risk faced by 
      most participants in this market. In the past few years, we have seen 
      tremendous increases in the cost of natural gas, and we�ve seen almost the 
      same in increases in the cost of coal, not to mention the issues of coal 
      transported by rail. The price of fuel is driven by many factors: the 
      balance of supply and demand, industry production capacity, storage 
      levels, market dynamics, as well as others. These factors all contribute 
      to the risk associated with supplying fuel for power plants. Market prices 
      for power are similarly driven by supply and demand, the cost of fuel both 
      today and in the future, and transmission and congestion issues.</p>
      <p ALIGN="LEFT">Diversifying your generation portfolio with various fuel 
      types, suppliers, and geographic locations are natural hedges to fuel and 
      power market risks. Other tools to mitigate your risk exposure, or hedge 
      your position, include a wide array of financial products that are 
      available in the marketplace. The use of futures and forwards can lock in 
      a set price of fuel or power for several years if you desire. 
      Additionally, many financial counterparties are willing to provide you 
      with collars or swaps that also provide more certainty about the cost you 
      will pay for fuel or power in the future. The fundamental idea is to adopt 
      a longterm resource planning and evaluation process that will lead you to 
      a well thought out, more diversified and secure power supply portfolio in 
      the long run.</p>
      </font><font SIZE="3"><b>
      <p ALIGN="LEFT">Transmission &amp; Market Design</b></font><font SIZE="3" COLOR="#202020"><br>
      Transmission issues are huge in today's transmission-constrained power 
      supply environment. In many markets today, it is difficult if not 
      impossible, to obtain long term firm transmission service. Transmission 
      access and pricing may be the most unfamiliar area to many in the 
      industry, almost viewed as a �black box� by some, so it can pose a serious 
      risk to your ability to provide reliable low cost power. Without a way to 
      deliver the power to the load, your issues can begin to compound.</p>
      <p ALIGN="LEFT">During the planning and construction phase of a power 
      project, most transmission issues such as routing and siting, 
      environmental regulations, or landowner and citizen opposition, are 
      identified and need addressing. However, it is during the operational 
      phase that a fair number of risks can become apparent. For example, there 
      are risks associated with the variable rates and penalties associated with 
      ancillary services and transmission scheduling. </p>
      <p ALIGN="LEFT">Congestion costs may be the driver for many problems and 
      concerns in the future as new market designs attempt to more directly 
      assign costs. New transmission lines can be built, but the process is a 
      long and costly one. Ultimately, taking an active role in this challenging 
      activity, understanding where the risks may be that could affect your 
      supply, and planning on contingencies can help mitigate a large portion of 
      the risk.</p>
      </font><font SIZE="3"><b>
      <p ALIGN="LEFT">Counterparty<br>
      </b></font><font SIZE="3" COLOR="#202020">The question of counterparty 
      reliability and accountability has become a major issue since Enron�s 
      collapse in late 2001. The importance of dealing with strong, creditworthy 
      counterparties is critical when you are involved in a shared ownership 
      position of a plant, or when you are a party to a power purchase agreement 
      with a supplier. By conducting credit analyses and factoring such analyses 
      into your decision criteria when choosing a counterparty, you may not 
      entirely eliminate, but can significantly reduce your exposure to 
      counterparty risks. It is fundamental to understand exactly who your 
      counterparty is and the long-term viability of that counterparty before 
      entering into any power supply arrangement�<b>no matter how good the price 
      may seem</b>. Proper financial analysis of a counterparty can be an 
      involved and detailed step in the process of supplying/buying power, but a 
      necessary one when you are trying to ensure low-cost and reliable power to 
      your customers. Not only should this be looked at prior to entering a 
      deal, but should be monitored during the deal.</p>
      </font><font SIZE="4">
      <p ALIGN="LEFT">At Risk�Demand-Side<br>
      </font><font SIZE="3" COLOR="#202020">Demand-side risks can fall under one 
      of two categories: 1) Forecasting; or 2) Load.</p>
      </font><font SIZE="3"><b>
      <p ALIGN="LEFT">Forecasting<br>
      </b></font><font SIZE="3" COLOR="#202020">One of the first tasks of power 
      supply planning is determining how much energy and capacity will be 
      required in future years. After all, you need to have a very good idea of 
      your power supply needs to effectively search for a way to meet them. This 
      is why a load forecast can be so critical to both the administration of a 
      well-balanced portfolio of power supply resources and the creation of a 
      comprehensive risk management strategy. There is the risk of being long or 
      short in physical energy.</p>
      <p ALIGN="LEFT">The accuracy of a peak demand and/or energy sales forecast 
      generally depends upon two primary factors: 1) the ability to quantify the 
      impacts of influential variables on power requirements, and 2) the skill 
      to project changes in these key influential variables (e.g. economic 
      outlook, weather conditions) over the forecast horizon. A base case 
      forecast typically presents the load and energy projections corresponding 
      to the expected, or most probable, outcomes of the key influential 
      variables. Of course, it is inevitable that future changes in the factors 
      that influence power requirements will deviate to some degree from what 
      was assumed when the load forecast was prepared. Therefore, it can be best 
      to develop forecast ranges that address high and low range scenarios. <br>
      <br>
      Range forecasts are useful for providing power requirement estimates for 
      extreme or specific market influences. However, range forecasts do not 
      necessarily provide probabilities for a range of projected power 
      requirements outcomes. Software tools available today provide the means 
      for developing probabilistic forecasts, where probabilities can be 
      assigned to a distribution of projected load and energy values. The power 
      supply planning is enhanced tremendously when the load forecast can be 
      presented as a probability distribution rather than as a series of 
      single-point projections for each time period in the forecast horizon. The 
      use of probability analysis is highly recommended and a key tool in the 
      risk management process.</p>
      </font><font SIZE="3"><b>
      <p ALIGN="LEFT">Load<br>
      </b></font><font SIZE="3" COLOR="#202020">Managing the uncertainty of your 
      load is difficult at best, but that does not mean it is impossible. This 
      can be a critical aspect of your business and it is important in helping 
      to achieve your strategic and financial goals.</p>
      <p ALIGN="LEFT">In order to mitigate the risk of abnormal loads, it is 
      important to try to better understand the forces that can cause high 
      variability. These drivers may include competition, catastrophic events, 
      industrial activity, or technological issues. Some of these areas can be 
      very difficult to predict, making it tougher but not impossible to 
      mitigate such risks in a cost effective manner. Although not always easy, 
      being up to speed in this area is part of risk management planning, 
      including catastrophe plans. You may also be able to exploit the savings 
      from an interruptible product or other demand-side management program 
      where appropriate. For market participants that are subject to weather 
      extremes, there are opportunities available to hedge weather risk through 
      the use of financial hedges that are designed to help protest against this 
      risk.</p>
      </font><b><font SIZE="4">
      <p ALIGN="LEFT">At Risk�Fundamental Business Risks<br>
      </font></b><font SIZE="3" COLOR="#202020">Fundamental business risks fall 
      under one of the following categories: 1) Regulation; 2) Financing; or 3) 
      Management.</p>
      </font><font SIZE="3"><b>
      <p ALIGN="LEFT">Regulation<br>
      </b></font><font SIZE="3" COLOR="#202020">As seen over the last several 
      years, the structure of the utility business and the regulation that 
      governs it is one of constant change. Regulation ranges from the Federal 
      Energy Regulatory Committee (FERC) or the Rural Utilities Service (RUS) at 
      the federal level, to the EPA of �05, to Independent System Operators like 
      ERCOT, Security Coordinators, Regional Transmission Organizations, Public 
      Utilities Commissions at the state level, and even city and county 
      governments at the local level. The sheer number of regulatory agencies, 
      coupled with the uncertainty and magnitude of potential requirements that 
      may be placed upon your business by these agencies, only increases the 
      need to understand the regulatory risks faced by our industry today. 
      Changes in the authority level of regulatory agencies, the time and 
      resources required for litigation, new environmental and nuclear 
      regulations, and market design and restructuring are only a few of the 
      major regulatory risks that should be of concern. Staying abreast of the 
      legislation and proceedings and getting involved with these agencies can 
      be expensive and time consuming, not to mention seemingly fruitless at 
      times as proposed changes come and go. Involvement with working groups or 
      panels can be an effective way in ensuring your position is well 
      represented, as well as gaining as much advance notice of potential 
      regulatory risks that may affect your business.</p>
      </font><font SIZE="3"><b>
      <p ALIGN="LEFT">Financing<br>
      </b></font><font SIZE="3" COLOR="#202020">Every business needs to borrow 
      money at some point in time, especially if you are on the supply side of 
      this business. Regardless of the purpose, you will desire to obtain 
      financing under the most favorable terms and conditions possible. This is 
      often hard to ensure, particularly because of the fluctuation in interest 
      rates and the demands on the market for money. It is impossible to know 
      whether rates will get better or worse in the future, so a balanced, 
      diversified portfolio of borrowing instruments often produces the most 
      favorable results over time. Furthermore, due to the recent uncertainty in 
      the energy industry, lending institutions are becoming more selective of 
      which entities they lend money. Lenders are now performing more rigorous 
      risk analyses on a borrower's financial condition to determine the 
      long-term viability of the borrower or project and the ability to meet 
      debt service payments. Equity requirements and debt covenants are also 
      becoming far more stringent than they have been in years past. Basically, 
      they�re doing their own risk management.</p>
      <p ALIGN="LEFT">Once the decision to obtain financing has been made, it is 
      important to conduct &quot;what if&quot; scenarios to study what the impact of 
      unexpected events could have on your business, as well as to understand if 
      your business has the potential for financial distress. Ultimately, 
      maintaining strong financials through proper rate structure and strong 
      liquidity and equity levels are essential to ensuring the availability of 
      low-cost financing for your organization in the future.</p>
      </font><font SIZE="3"><b>
      <p ALIGN="LEFT">Management<br>
      </b></font><font SIZE="3" COLOR="#202020">The makeup of an organization 
      can arguably be the most important factor in successfully operating a 
      business. Integrating and processing all of the various operational inputs 
      from your business to formulate a reliable and cost-effective power supply 
      portfolio is more than a challenge. Human capital and the aging of the 
      experienced work force is a topic much discussed today. By taking a 
      systematic approach to your business operations through better 
      understanding the drivers that cause change in your business, and through 
      the corresponding implementation of a comprehensive risk management 
      strategy, managers can take fundamental actions that can help mitigate 
      more effectively the risks associated with their business and have less 
      exposure to management and people issues. Turn in the human capital can be 
      offset by having a well developed process that can be somewhat immune from 
      having to rely on institutional knowledge of seasoned managers. 
      Additionally, creating management policies and controls that administer 
      and measure your organization's performance can be advantageous to the 
      ongoing success of your business.</p>
      </font><font SIZE="4"><b>
      <p ALIGN="LEFT">Conclusion<br>
      </b></font><font SIZE="3" COLOR="#202020">It is clear that we are facing 
      challenges and uncertainty like never before. With that said, there is no 
      one &quot;right way&quot; to apply risk management principals to a business, or 
      silver bullet solution that will protect any of us from uncertainty. 
      Entity risk management is rather a methodology or approach that helps 
      identify risks to your business, evaluate the potential negative impact 
      those risks may have on your business, and create solutions to mitigate 
      the potential damage. With new challenges, often new tools can be 
      extremely helpful. We've summarized this suggested new approach below:</p>
      </font><b>
      <p ALIGN="LEFT">Risk Management Framework</p>
      <font SIZE="3">
      <p ALIGN="LEFT">1. </font><font SIZE="3" COLOR="#202020">Determine risk 
      profile<br>
      </font><font SIZE="3">� Risk exposures and tolerance<br>
      </font></b><font SIZE="3">� Identify � Evaluate � Mitigate</p>
      </font><b><font SIZE="3">
      <p ALIGN="LEFT">2. </font><font SIZE="3" COLOR="#202020">Define program of 
      clear goals and objectives<br>
      </font><font SIZE="3">� Strategic<br>
      � Financial</p>
      <p ALIGN="LEFT">3. </font><font SIZE="3" COLOR="#202020">Develop 
      comprehensive risk management strategy and tools</p>
      </font><font SIZE="3">
      <p ALIGN="LEFT">4. </font><font SIZE="3" COLOR="#202020">Implement 
      appropriate controls and support systems<br>
      </font></b><font SIZE="3" COLOR="#202020">It is easy to feel overwhelmed 
      by the variety and magnitude of risks that affect the supply of reliable 
      and economic power. These risks may not all apply to you and your 
      situation directly, but these risks are faced by some entity in the supply 
      chain of power. While completely protecting yourself is virtually 
      impossible, relying on a risk management framework is certainly the next 
      best thing. </font><b><font SIZE="3" COLOR="#202020">Without it, you don't 
      really know how much you don't know. </font></b>
      <font SIZE="3" COLOR="#202020">This proactive stance is carried out by 
      first determining your risk profile and then by developing and 
      implementing a comprehensive risk management plan. </font><b>
      <font SIZE="3" COLOR="#202020">By utilizing a risk management framework, 
      you will be best positioned to reliably serve your needs or your 
      customers� needs at a lower cost of service and greatly reduced price 
      volatility.</p>
      </font></b><font SIZE="3">
      <p ALIGN="LEFT">The GDS approach to designing risk management programs 
      incorporates quantitative and qualitative techniques to capture, assess, 
      measure, and mitigate the risks that can impact a business's strategic and 
      financial objectives, along with its operations, and ultimately the bottom 
      line. For more information about GDS and its Risk Management Services, 
      contact Paul Wielgus, Managing Director at the numbers below and visit <b>
      <a href="http://www.gdsassociates.com">www.gdsassociates.com</a></b>.</p>
      </font><font SIZE="2"><b>
      <p ALIGN="LEFT">Paul Wielgus </b>- Managing Director<br>
      <b>GDS Associates, Inc.<br>
      </b>1850 Parkway Place, Suite 800<br>
      Marietta, GA 30067<br>
      phone 770.425.8100 | fax 770.426.0303 | cell 281-797-8799<br>
      </font><font SIZE="2" COLOR="#1b1b1b">
      <a href="mailto:[email protected]">
      [email protected]</a></p>
      </font>
      <p class="MsoNormal" style="text-autospace: none">&nbsp;</p>
      <p><font face="Times New Roman"><br>
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