Exelon West Medway II SEP 30 2016 App.Pdf

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PUBLIC VERSION Pursuant to the Commission’s Regulations Regarding Requests for Privileged Treatment of Documents, 18 C.F.R. § 388.112, Information Contained in Attachment D of This Submission Constitutes Privileged, Protected, and Confidential Information and Has Been Redacted from This Public Version

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION

Exelon West Medway II, LLC ) Docket No. ER16-___-000

APPLICATION OF EXELON WEST MEDWAY II, LLC FOR ORDER ACCEPTING MARKET-BASED RATE TARIFF FOR FILING AND GRANTING WAIVERS AND BLANKET APPROVALS

Pursuant to section 205 of the Federal Power Act (“FPA”),1 Rule 205 of the Rules

of Practice and Procedure of the Federal Energy Regulatory Commission (“FERC or

Commission”),2 and Part 35 of the Commission’s regulations under the FPA,3 Exelon

West Medway II, LLC (“Applicant”) hereby petitions the Commission for: (1)

acceptance of Applicant’s market-based rate (“MBR”) tariff effective October 1, 2016,

one day from the date of this filing; (2) waiver of certain Commission regulations under

the FPA; and (3) the granting of certain blanket approvals.

I. REQUEST FOR PRIVILEGED TREATMENT

Applicant requests privileged treatment pursuant to Section 388.112 of the

Commission’s regulations for hourly load data, which is accessible via links to the work

papers of Julie Solomon contained in the market screens submitted as part of Attachment

D. The work papers contain information about confidential, commercially sensitive load

data that could harm Applicant if publicly released. Pursuant to Section 35.37(f) of the

1 16 U.S.C. § 824d (2012). 2 18 C.F.R. § 385.205 (2016). 3 Id. Part 35.

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Commission’s regulations, a proposed protective order is included herewith as

Attachment B. Communications concerning this request for privileged treatment should

be directed to Jane Rueger at 202-626-6534 or Harold Bulger at 202-637-6182.

II. COMMUNICATIONS

Communications with regard to this filing should be addressed to:

Vincenzo Franco* David O. Dardis* Associate General Counsel Senior Vice President & Exelon Corporation General Counsel – Constellation 111 Market Place, Exelon Corporation Suite 500 111 Market Place, Baltimore, MD 21202 Suite 500 (410) 470-2593 Baltimore, MD 21202 [email protected] (410) 470-3416 [email protected]

Jane E. Rueger* Christopher A. Wilson Harold W. Bulger, III Director, Federal Regulatory Affairs White & Case LLP Exelon Corporation 701 Thirteenth Street, NW 101 Constitution Avenue, NW Washington, DC 20005 Suite 400 East (202) 626-6534 Washington, DC 20001 [email protected] (202) 347-7507 [email protected]

* Persons denoted with an asterisk are those designated for service pursuant to 18 C.F.R. § 385.2010. Applicant respectfully requests waiver of 18 C.F.R. § 385.2010(k) so that it may designate three persons to receive service on its behalf.

III. LIST OF DOCUMENTS SUBMITTED WITH THIS APPLICATION

Applicant includes the following attachments with this Application:

. Proposed FERC Electric Tariff (Attachment A and filed concurrently in RTF format);

. Proposed protective order (Attachment B);

. Appendices in the format set forth in Appendix B to 18 C.F.R. Part 35, Subpart H listing by balancing authority area and geographic region: (1) all affiliates that have MBR authority and all reportable generation assets owned by Applicant or its affiliates; (2) all reportable long-term power purchase agreements of Applicant or its affiliates; and (3) all electric transmission

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facilities and natural gas intrastate pipelines and/or gas storage facilities owned or controlled by the Applicant or its affiliates (Attachment C).

. Affidavit of Julie R. Solomon of Navigant Consulting, Inc. (“Solomon Affidavit”) that includes horizontal market power indicative screens and related documents (Attachment D).

IV. DESCRIPTION OF APPLICANT AND RELEVANT AFFILIATES

A. Applicant

Applicant is developing and will own and operate an approximately 195 MW

(summer rating) electric generation facility located in Medway, Massachusetts

(“Facility”). The Facility will be interconnected to the transmission system owned by

NSTAR Electric Company and operated by ISO-New England, Inc. (“ISO-NE”). It is

currently anticipated that sale of test power from the Facility could begin as early as

December, 2017 and commercial operation is expected to occur in April, 2018.

Applicant will file a notice of exempt wholesale generator (“EWG”) status under the

Public Utility Holding Company Act of 2005 (“PUHCA”) prior to the Facility’s

commercial operation date. Applicant does not own any transmission facilities, except

for the limited and discrete equipment necessary to interconnect the Facility to the grid.

Applicant is a wholly owned subsidiary of Exelon New England Holdings, LLC

(“Exelon New England Holdings”), which is owned by Exelon Generation Company,

LLC (“Exelon Generation”). Exelon Generation is a wholly owned subsidiary of Exelon

Corporation (“Exelon”). Exelon is a publicly traded company headquartered in Chicago,

Illinois and has operations and business activities in 48 states, the District of Columbia,

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Canada, and the United Kingdom.4 Exelon is a holding company within the meaning of

PUHCA.

B. Exelon’s Franchised Public Utilities

Exelon’s indirect wholly owned subsidiaries Commonwealth Edison Company

(“ComEd”), PECO Energy Company (“PECO”), Baltimore Gas and Electric Company

(“BGE”), Potomac Electric Power Company (“Pepco”), Delmarva Power & Light

Company (“DPL”), and Atlantic City Electric Company (“ACE”) (collectively the

“Franchised Public Utilities”), are franchised public utilities within the meaning of 18

C.F.R. § 35.36(a)(5).

ComEd and PECO are owned by Exelon Energy Delivery Company, LLC

(“EEDC”), which in turn is owned by Exelon. BGE is owned by RF HoldCo LLC, which

in turn is owned by EEDC. Pepco, DPL, and ACE are owned by Pepco Holdings LLC,

which is owned by PH Holdco LLC. PH Holdco LLC is owned by EEDC. Together, the

Franchised Public Utilities own electric distribution systems through which they deliver

electricity to customers in Illinois, Pennsylvania, Maryland, the District of Columbia,

Delaware, and New Jersey. All of the Franchised Public Utilities’ retail customers have

access to competitively priced retail power and, as a result, are not considered captive for

purposes of the Commission’s market-based rate regulations.5

4 No individual shareholder of Exelon owns a 10% or greater interest in Exelon’s outstanding voting securities. 5 See Exelon Generation Co.¸126 FERC ¶ 61,031 at PP 43-48 (2009); Baltimore Gas & Elec. Co., Letter Order, Docket Nos. ER99-2948-012, et al. (Sept. 16, 2008); Exelon Generation Co., 93 FERC ¶ 61,140 at 61,425 (2000), on reh’g, 95 FERC ¶ 61,309 (2001); AmerGen VT, LLC, 90 FERC ¶ 61,307 at 61,995, on reh’g, Baltimore Gas & Elec. Co., 91 FERC ¶ 61,270 (2000); Potomac Elec. Power Co., et al., 93 FERC ¶ 61,240 at 61,781-82 (2000); Pepco Holdings, Inc., 141 FERC ¶ 61,034 (2012).

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The Commission granted each of the Franchised Public Utilities MBR authority.6

The Franchised Public Utilities do not own any electric generation facilities, except for

limited behind-the-meter facilities located at substation sites,7 and serve as default service

providers for those electric customers that do not choose competitive suppliers or whose

competitive supplier failed to deliver electric supply. ACE and DPL have long-term

power purchase agreements that, as a result of the refinements to the Commission’s

market-based rate program adopted in Order No. 816,8 are now included in the asset

appendix and in the market power analysis. ACE’s long-term power purchase

agreements obligate ACE to pay the generators for specified amounts of energy at a

specified price, and the costs are recovered from ACE’s retail customers. ACE bids the

energy into the PJM Interconnection, L.L.C. (“PJM”) market and credits retail customers

for all energy revenues received by ACE from PJM. ACE does not control those

generating units and cannot withhold the output of the units from the market. DPL’s

long-term power purchase agreements are fixed-price, must-run contracts, and DPL has

no ability to withhold this generation. None of the Franchised Public Utilities have long

term power purchase agreements with generators located in the ISO-NE balancing

authority area (“BAA”) or any of its first tier markets.

6 Commonwealth Edison Co., 82 FERC ¶ 61,317 (1998); PECO Energy Company, 74 FERC ¶ 61,336 (1996); Green Power Partners I, LLC, 88 FERC ¶ 61,005 (1999); Potomac Electric Power Company, 85 FERC ¶ 61,019 (1998); Delmarva Power & Light Company, 76 FERC ¶ 61,331 (1996); Atlantic City Electric Company, 75 FERC ¶ 61,167 (1996). 7 These behind-the-meter facilities have not been included in the indicative screens or asset appendix submitted with this application. See Refinements to Policies and Procedures for Market-Based Rates for Wholesale Sales of Electric Energy, Capacity and Ancillary Services by Public Utilities, Order No. 816, 153 FERC ¶ 61,065 at P 255 (2015), reh’g, Order No. 816-A, 155 FERC ¶ 61,188 (2016) (“[W]e clarify that qualifying facilities that are exempt from [Federal Power Act] section 205 and facilities that are behind-the-meter facilities do not need to be reported in the asset appendix or indicative screens.”). 8 See Order No. 816 at P 145.

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The Franchised Public Utilities own transmission facilities, but have transferred

operational control over such facilities to PJM, which provides transmission service

pursuant to an Open Access Transmission Tariff (“OATT”) on file with the

Commission.9 In addition, PECO and BGE own certain intrastate natural gas

transportation and distribution facilities used to distribute natural gas to customers in

Philadelphia and central Maryland and operate liquefied natural gas facilities and

propane-air facilities associated with their respective distribution activities that do not

offer services to third parties. Furthermore, DPL supplies and delivers natural gas to

retail customers and provides transportation-only services to retail customers that

purchase natural gas from another supplier. DPL owns intrastate natural gas

transportation and distribution facilities pipelines, and a liquefied natural gas storage

facility.

C. Exelon Generation and Relevant Subsidiaries

Exelon Generation is owned directly by Exelon. Exelon Generation is one of the

largest competitive power generators in the United States. Exelon Generation and its

subsidiaries operate one of the nation’s cleanest and lowest-cost power generation fleets,

with generation facilities located in a number of organized markets across the country. In

addition, Constellation, an Exelon Generation business unit consisting of subsidiaries and

divisions of Exelon Generation, is one of the nation’s leading marketers of electricity,

natural gas, and related products in wholesale and retail markets. Exelon Generation

serves as a supplier of energy to, among others, utilities and municipalities to meet their

native load obligations. Through various subsidiaries, Exelon Generation is also a retail

9 Commonwealth Edison Company of Indiana, Inc. (“ComEd of Indiana”), a wholly owned subsidiary of ComEd, also owns a small amount of electric transmission property in Indiana. As with ComEd, the transmission facilities owned by ComEd of Indiana, Inc. are under the operational control of PJM.

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competitive energy provider. The Commission granted Exelon Generation MBR

authority.10

In the ISO-NE BAA—the relevant market for Applicant’s market analysis—

Exelon Generation does not directly own any electric generation facilities. Exelon

Generation purchases approximately 621 MW from generation facilities located in the

ISO-NE BAA under long-term contracts that are included in the asset appendix and the

market power analysis pursuant to the criteria set forth in Order No. 816.11 As reflected

in the Solomon Affidavit, Exelon Generation and its affiliates also serve load in the ISO

NE BAA.

The following indirect subsidiaries of Exelon Generation own electric generation

facilities in ISO-NE:12

. Constellation Mystic Power, LLC (“Mystic”) is a wholly owned subsidiary of Constellation Holdings, LLC, which is a wholly owned subsidiary of Exelon Generation. Mystic owns the following generating facilities and related interconnection facilities, all of which are located in the ISO-NE BAA: (a) Mystic Unit 7, an approximately 571 MW (summer) oil and natural gas-fired facility in Everett, Massachusetts; (b) Mystic Jet, an approximately 9 MW (summer) oil facility in Everett, Massachusetts; and (c) Mystic Units 8 (at approximately 704 MW (summer)) and 9 (at approximately 714 MW (summer)), natural gas-fired facilities located in Everett, Massachusetts, with a total capacity of approximately 1,418 MW. The Commission has granted Mystic market-based rate authority.13 . Exelon Framingham, LLC (“Exelon Framingham”) is a wholly owned subsidiary of Exelon New England Holdings, which is owned by Exelon Generation. Exelon Framingham owns three fossil fueled plants with a combined capacity of

10 Exelon Generation Co., 93 FERC ¶ 61,140 (2000), reh’g denied, 95 FERC ¶ 61,309 (2001). 11 See Order No. 816 at P 145. 12 Consistent with Order No. 816, Applicant has not included in the asset appendix and the market power analysis subsidiaries of Exelon that own small qualifying facilities (“QFs”) exempt from section 205 of the FPA. Applicant includes in the long-term purchase agreement tab of the asset appendix, power purchase agreements from facilities that may be QFs and that may not have market-based rate authority. These power purchase agreements are included out of an abundance of caution because neither Applicant nor its affiliates own such QFs and cannot definitively represent that such QFs have market-based rate authority. 13 Constellation Mystic Power, LLC, Docket Nos. ER10-2281-000, et al. (unpublished delegated letter order issued Oct. 27, 2010).

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approximately 31 MW (summer) in Framingham, Massachusetts, in the ISO-NE BAA. The Commission has granted Exelon Framingham market-based rate authority.14 . Exelon New Boston, LLC (“Exelon New Boston”) is a wholly owned subsidiary of Exelon New England Holdings, which is owned by Exelon Generation. Exelon New Boston owns an approximately 16 MW (summer) fossil fueled plant in the ISO-NE BAA.15 The Commission has granted Exelon New Boston market-based rate authority.16 . Exelon West Medway, LLC (“Exelon West Medway”) is a wholly owned subsidiary of Exelon New England Holdings, which is owned by Exelon Generation. Exelon West Medway owns the following three fossil fueled plants located in the ISO-NE BAA: Jet 1 and Jet 2, with a combined capacity of approximately 82 MW (summer); and Jet 3, with a capacity of approximately 42 MW (summer), for a combined total across Jet 1, 2, and 3 of approximately 124 MW (summer). The Commission has granted Exelon West Medway market- based rate authority.17 . Exelon Wyman, LLC (“Exelon Wyman”) is a wholly owned subsidiary of Exelon New England Holdings, which is owned by Exelon Generation. Exelon Wyman owns a 5.89% interest in a fossil fueled plant with a total capacity of approximately 602 MW (summer) in the ISO-NE BAA. The facility is operated by FPL Energy Wyman IV LLC, which is a subsidiary of NextEra Energy Resources, LLC and is not an affiliate of Exelon. The Commission has granted Exelon Wyman market-based rate authority.18

14 Sithe New England Holdings LLC, 83 FERC ¶ 61,035 (1998) (accepting for filing the market-based rate tariff of Sithe Framingham LLC); Sithe Energies, Inc. and Exelon Generation Company, LLC, Letter Order, Docket No. ER01-513-004 (June 12, 2013) (accepting for filing tariff revisions reflecting the name change from Sithe Framingham LLC to Exelon Framingham, LLC). 15 The plant is currently expected to be retired shortly after October 1, 2016. 16 Sithe New England Holdings LLC, 83 FERC ¶ 61,035 (1998) (accepting for filing the market-based rate tariff of Sithe New Boston LLC); Sithe Energies, Inc. and Exelon Generation Company, LLC, Letter Order, Docket No. ER01-513-004 (June 12, 2013) (accepting for filing tariff revisions reflecting the name change from Sithe New Boston LLC to Exelon New Boston, LLC). 17 Sithe New England Holdings LLC, 83 FERC ¶ 61,035 (1998) (accepting for filing the market-based rate tariff of Sithe West Medway LLC); Sithe Energies, Inc. and Exelon Generation Company, LLC, Letter Order, Docket No. ER01-513-004 (June 12, 2013) (accepting for filing tariff revisions reflecting the name change from Sithe West Medway LLC to Exelon West Medway, LLC). 18 Sithe New England Holdings LLC, 83 FERC ¶ 61,035 (1998) (accepting for filing the market-based rate tariff of Sithe Wyman LLC); Sithe Energies, Inc. and Exelon Generation Company, LLC, Letter Order, Docket No. ER01-513-004 (June 12, 2013) (accepting for filing tariff revisions reflecting the name change from Sithe Wyman LLC to Exelon Wyman, LLC).

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In markets first-tier to ISO-NE, Applicant’s affiliates own, or purchase under

long-term firm contract from, approximately 1,457 MW (summer) of generation located

in the New York Independent System Operator, Inc. (“NYISO”) BAA.19

In addition, Exelon Generation indirectly owns the following power marketers: . Constellation Energy Commodities Group Maine, LLC (“CECG Maine”), which is owned by Constellation Energy Upstream Holdings, Inc. Constellation Energy Upstream Holdings, Inc. is owned by Exelon Generation. . Constellation NewEnergy, Inc. (“CNE”), which is owned by Constellation Energy Resources, LLC (“Constellation Energy Resources”). Constellation Energy Resources is owned by Exelon Generation. . Constellation Energy Services, Inc. (“CES”), which is owned by Constellation Energy Resources, whose upstream ownership is described above. CES was formerly known as Integrys Energy Services, Inc. and changed its name effective April 1, 2015. . Constellation Energy Services of New York, Inc. (“CES of NY”), which is owned by CES. CES of NY was formerly known as Integrys Energy Services of New York, Inc. and changed its name effective April 1, 2015. Each of these four marketers operates primarily as a competitive retail supplier

and has been granted MBR authority by the Commission.20 None of the four marketers

owns or controls any generation facilities, except for limited behind-the-meter facilities,

or any transmission facilities in the United States. CNE owns Pepco Energy Services,

Inc. (“PES”), which is primarily engaged in providing energy services, including

investment-grade energy audits and installation of energy conservation measures for

19 The generation facilities located in each first-tier market are identified in the asset appendix provided as Attachment C hereto. 20 See Constellation Power Source Maine, LLC, Letter Order, Docket No. ER02-699-000 (Feb. 26, 2002); NEV, L.L.C., 81 FERC ¶ 61,186 (1997) (granting Constellation NewEnergy, Inc. market-based rate authority); Wisconsin Public Service Corp., et al., 75 FERC ¶ 61,057 (1996) (granting Constellation Energy Services, Inc. market-based rate authority); Advantage Energy, Inc., Letter Order, Docket No. ER97-2758- 000 (July 14, 1997) (granting Constellation Energy Services of New York, Inc. market-based rate authority). In a letter order issued on June 23, 2015 in Docket Nos. ER15-1537-000, et al., the Commission accepted for filing the notice of succession reflecting the names changes from Integrys Energy Services, Inc. to Constellation Energy Services, Inc. and from Integrys Energy Services of New York, Inc. to Constellation Energy Services of New York, Inc.

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federal, state and local governments, specialized construction work for electric utilities,

and the delivery of thermal energy under long-term contracts. PES does not own any

electrical generation facilities, except for certain limited behind-the-meter generation

facilities, and has MBR authority.21

Except for the generation discussed above and for generation facilities that are

either located behind-the-meter or are QFs exempt from section 205 of the FPA, neither

Applicant nor any of its affiliates owns or purchases power under reportable long-term

contracts from any additional electric generation facilities located within the ISO-NE

BAA or first-tier markets.

Further, except for the transmission facilities owned by the Franchised Public

Utilities that are subject to PJM’s operational control, neither Applicant nor any of its

affiliates owns or controls any transmission facilities in the United States, other than

limited and discrete interconnection facilities required to connect individual generating

facilities to the transmission grid.

Except for the natural gas distribution facilities owned by PECO, BGE, and DPL

discussed above, neither Applicant nor any of its affiliates owns or controls any inputs to

electric power production in the United States, i.e., intrastate natural gas transportation,

intrastate natural gas storage or distribution facilities; physical coal supply sources and

ownership of or control over who may access transportation of coal supplies. As noted

above, Applicant is affiliated with the six Franchised Public Utilities but none of them

has captive customers.

21 Pepco Energy Services, Inc., 84 FERC ¶ 61,024 (1998).

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V. REQUEST FOR AUTHORIZATION TO SELL ENERGY, CAPACITY, AND ANCILLARY SERVICES AT MARKET-BASED RATES

A. Description of Applicant’s Rate Schedule

Applicant requests authorization under its proposed MBR tariff to sell energy,

capacity, and ancillary services to any purchaser for resale consistent with the terms of its

proposed MBR tariff.

B. Satisfaction of Criteria for Market-Based Rates

The Commission permits sales of energy and capacity at market-based rates if the

applicant and its affiliates (i) lack horizontal market power in the relevant geographic

market, i.e., they do not have (or have adequately mitigated) market power in generation;

and (ii) lack vertical market power in the relevant geographic market, i.e., they do not

have (or have adequately mitigated) market power in transmission and cannot erect

barriers to entry to competing suppliers through the control of inputs to electric power

production.22 As discussed below, because Applicant and its affiliates do not have

horizontal or vertical market power in the relevant market, Applicant meets the

Commission’s criteria and its MBR tariff should be accepted for filing.

1. Applicant Lacks Horizontal Market Power

The Commission reviews horizontal market power by assessing the market power

of the applicant and any of its affiliates that own generation or control generation in the

relevant market through tolling agreements, energy management agreements, or other

22 See Market-Based Rates for Wholesale Sales of Electric Energy, Capacity and Ancillary Services by Public Utilities, Order No. 697, FERC Stats. & Regs. ¶ 31,252, clarified, 121 FERC ¶ 61,260 (2007), order on reh’g, Order No. 697-A, FERC Stats. & Regs. ¶ 31,268, clarified, 124 FERC ¶ 61,055, order on reh’g, Order No. 697-B, FERC Stats. & Regs. ¶ 31,285 (2008), order on reh’g, Order No. 697-C, FERC Stats. & Regs. ¶ 31,291 (2009); see also Heartland Energy Servs., Inc., 68 FERC ¶ 61,223 at p. 62,060-63 (1994); Enron Power Enterprise Corp., 52 FERC ¶ 61,193 at p. 61,708 (1990); FirstEnergy Servs., Inc., 94 FERC ¶ 61,052 (2001).

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contractual arrangements.23 The Commission has indicated that the relevant geographic

market is the BAA, Regional Transmission Operator (“RTO”)/Independent System

Operator (“ISO”), or submarket, as applicable, where the Applicant’s generation is

physically located.24 Accordingly, Applicant is using the ISO-NE BAA as the relevant

geographic market for purposes of its request for MBR authority.

The Commission has authorized the submission of streamlined applications and

the use of simplifying assumptions, where appropriate.25 To perform its pivotal supplier

and market share screens, Applicant relies on the attached Solomon Affidavit, which

includes a market power analysis for the ISO-NE market for the study period December

1, 2014-November 30, 2015, which is the study period for the updated triennial market

power analysis that transmission owners in the Northeast region will file in December

2016.

As demonstrated below, Applicant passes the pivotal supplier and market share

screens for the ISO-NE BAA. In any event, Applicant commits to comply with all

applicable ISO-NE rules regarding market monitoring and mitigation.26

a. Pivotal Supplier Screen

The pivotal supplier screen compares the amount of uncommitted capacity owned

or purchased under long-term firm contract by an applicant and its affiliates in the

23 See Order No. 697 at P 232 n.261; AEP Power Mktg., Inc., 107 FERC ¶ 61,018 at P 73 n.63. 24 See Order No. 697 at P 37; see also AEP, 107 FERC ¶ 61,018 at P 41, order on reh’g, 108 FERC ¶ 61,026 at P 31 (2004). 25 See Order No. 697 at PP 321, 337, 1113 (permitting the use of simplifying assumptions and reliance on prior studies); AEP, 107 FERC ¶ 61,018 at PP 113-117. 26 The Commission has adopted a rebuttable presumption that existing Commission-approved RTO/ISO market monitoring and mitigation is sufficient to address any market power concerns. See Order No. 697- A at P 111; see also NextEra Energy Power Market, LLC, Letter Order, Docket Nos. ER09-832-004, et al. (Mar. 25, 2010).

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relevant market and the net uncommitted capacity in that market. If the applicant’s total

affiliated uncommitted capacity in the market is less than the difference between the total

uncommitted capacity in the market and the wholesale load, then the applicant passes the

screen.27

As demonstrated in the Solomon Affidavit, the sum of uncommitted capacity

owned or purchased under long-term firm contract by Applicant and its affiliates in the

ISO-NE BAA is 0 MW (actually negative). The net uncommitted capacity in ISO-NE is

8,300 MW. Therefore, Applicant passes the pivotal supplier screen in ISO-NE.

b. Market Share Screen

The market share screen calculates the applicant’s and its affiliates’ share of

uncommitted capacity in the relevant market during each of the four seasons. If an

applicant’s and its affiliates’ share of uncommitted capacity in the relevant market is

under 20% in each season, the applicant passes the market share screen. The market

share screen included in the Solomon Affidavit reflects the total share of uncommitted

capacity owned or controlled in the ISO-NE BAA by Applicant and its affiliates during

each of the four seasons. Their market share does not exceed 4.2% of the total

uncommitted capacity in any season. Therefore, Applicant passes the market share

screen.

2. Applicant Lacks Vertical Market Power

Except for the transmission facilities owned in PJM by the Franchised Public

Utilities,28 which are operated by PJM under its OATT, neither Applicant nor any of its

affiliates owns, operates, or controls facilities in the United States for the transmission of

27 AEP Power Mktg., Inc., 107 FERC ¶ 61,018 at P 99. 28 Including ComEd’s subsidiary, ComEd of Indiana.

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electricity in interstate commerce, other than limited and discrete equipment necessary to

interconnect individual generation facilities to the transmission grid. Applicant and its

affiliates that own limited and discrete interconnection customer interconnection facilities

affirm that they qualify for the blanket OATT waiver pursuant to section 35.28(d)(2) of

the Commission’s regulations.

Applicant’s affiliation with the natural gas distribution facilities owned by PECO,

BGE, and DPL does not raise any vertical market power concerns, because the

Commission has adopted a rebuttable presumption that ownership or control of such

inputs to electric power production does not allow an entity selling electricity at market-

based rates to erect barriers to entry.29 Except for the affiliation with the assets described

in Section IV above, neither Applicant nor any of its affiliates owns or controls any

inputs to electric power production, i.e., intrastate natural gas transportation; intrastate

natural gas storage or distribution facilities; physical coal supply sources; and ownership

of or control over who may access transportation of coal supplies. Applicant affirms that

Applicant and its affiliates have not erected barriers to entry in the relevant markets and

will not erect barriers to entry in the relevant markets. Therefore, Applicant and its

affiliates do not have vertical market power.

3. Affiliate Restrictions

The Commission has traditionally indicated its concern that a public utility having

a franchised service territory and an affiliate may be able to transact in ways that transfer

benefits from the captive customers of the franchised utility to the affiliate and its

shareholders. In Order No. 697, the Commission discontinued considering affiliate abuse

29 Order No. 697 at P 1018.

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as a separate “prong” of the market-based rate analysis and codified affiliate restrictions

in the Commission’s regulations as a condition of obtaining and retaining market-based

rate authority.

The Commission previously determined that the affiliate restrictions do not apply

to the relationship between the Franchised Public Utilities and their market-regulated

power sales affiliates, because the Franchised Public Utilities do not have any captive

wholesale or retail customers.30 Consistent with Commission precedent, waiver of the

affiliate restrictions with respect to Applicant is similarly appropriate.

The Commission’s regulations define “captive customers” as “any wholesale or

retail electric energy customers served by a franchised public utility under cost-based

regulation.”31 None of the Franchised Public Utilities has any wholesale electric

customers served under cost-based rates. While the Franchised Public Utilities serve

retail electric customers under cost-based rates, all of their retail customers have the

option to choose a competitive retail supplier. The Commission clarified that the

definition of “captive customers” does not include customers that have retail choice.32

Therefore, none of the Franchised Public Utilities has any retail captive customers.

Because none of Franchised Public Utilities has any captive customers, waiver of

the affiliate restrictions is appropriate. Applicant’s proposed tariff reflects waiver of the

affiliate restrictions in the Limitations and Exemption section of the tariff.

30 See Exelon Generation Co.¸126 FERC ¶ 61,031 at PP 43-48 (2009); Baltimore Gas & Elec. Co., Letter Order, Docket Nos. ER99-2948-012, et al. (Sept. 16, 2008); Exelon Generation Co., 93 FERC ¶ 61,140 at 61,425 (2000), on reh’g, 95 FERC ¶ 61,309 (2001); AmerGen VT, LLC, 90 FERC ¶ 61,307 at 61,995, on reh’g, Baltimore Gas & Elec. Co., 91 FERC ¶ 61,270 (2000); Potomac Elec. Power Co., et al., 93 FERC ¶ 61,240 at 61,781-82 (2000); Pepco Holdings, Inc., 141 FERC ¶ 61,034 (2012). 31 18 C.F.R. § 35.36(a)(6). 32 Order No. 697 at P 479.

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C. Ancillary Services

Applicant seeks authorization to sell certain ancillary services in the markets

administered by ISO-NE, PJM, NYISO, Midcontinent Independent System Operator, Inc.

(“MISO”), California Independent System Operator Corporation, Inc. (“CAISO”), and

Southwest Power Pool, Inc. (“SPP”). The Commission requires a separate study of the

ancillary services markets to support a market-based rate filing for ancillary services.

With respect to sales of ancillary services in the markets operated by ISO-NE, PJM,

NYISO, MISO, CAISO, and SPP, Applicant relies, in the same manner as other sellers,

on the studies submitted and accepted by the Commission in previous orders.33

In addition, Applicant seeks authorization to sell ancillary services at market-

based rates under requirements set forth in Avista Corp.,34 as modified by Order No. 69735

and 784,36 in markets for which the Commission has not accepted a market power study

and has not generically authorized the sale of ancillary services at market-based rates.

Applicant has included in its market-based rate tariff the applicable standard tariff

provisions adopted in Order Nos. 697, 697-A, and 784 for the proposed sales of ancillary

services described above.

33 See e.g., AES Redondo Beach, L.L.C., 83 FERC ¶ 61,358 (1998), order on reh’g, 85 FERC ¶ 61,123 (1998), order on reh’g, 87 FERC ¶ 61,208, order on reh’g, 88 FERC ¶ 61,096 (1999), order on reh’g and clarification, 90 FERC ¶ 61,036 (2000) (CAISO); see e.g. New England Power Pool, 85 FERC ¶ 61,379 (1998), reh’g denied, 95 FERC ¶ 61,074 (2001) (ISO-NE); see e.g., Cent. Hudson Gas & Elec. Corp., 86 FERC ¶ 61,062 (1999), order on reh’g and clarification, 88 FERC ¶ 61,138 (1999) (NYISO); see e.g., PJM Interconnection, L.L.C., 86 FERC ¶ 61,247 (1999); Atlantic City Elec. Co., 86 FERC ¶ 61,248 (1998), clarified, 86 FERC ¶ 61,310 (1999) (PJM); PJM Interconnection, L.L.C., 91 FERC ¶ 61,021 (2000); see e.g., Midwest Indep. Transmission Sys. Operator, Inc., 122 FERC ¶ 61,172 (2008), order on reh’g and clarification, 123 FERC ¶ 61,297 (2008) (MISO); Southwest Power Pool, Inc., 144 FERC ¶ 61,224 at PP 412-413 (2013) (SPP). 34 87 FERC ¶ 61,223 (1999), order on reh’g, 89 FERC ¶ 61,136 (1999). 35 See Order No. 697 at PP 1058-61. 36 Third-Party Provision of Ancillary Services; Accounting and Financial Reporting for New Electric Storage Technologies, Order No. 784, 78 Fed. Reg. 46,178 (July 30, 2013), FERC Stats. & Regs. ¶ 31,349 at PP 200-201 (2013); order granting reh’g, 146 FERC ¶ 61,114 (2014).

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D. Reporting Requirements

Applicant agrees to comply with the reporting requirements normally imposed on

sellers that are authorized to sell power at market-based rates. In particular, Applicant

will file Electric Quarterly Reports (“EQRs”) concerning its sales in conformance with

the Commission’s requirements.37 Pursuant to the requirements set forth in section 35.42

of the Commission’s regulations, Applicant agrees to file timely notices of material

changes in status that explain whether such changes reflect a departure from the

characteristics relied upon by the Commission in originally granting Applicant market-

based rate authority.38 To the extent Applicant is a Category 2 Seller in any region,

Applicant commits to file an updated market power analysis pursuant to the regional

schedule adopted in Order Nos. 697 and 697-A.

Applicant also agrees to comply with the Commission’s market behavior rules

codified at 18 C.F.R. § 35.41. In accordance with section 35.41(c) of the Commission’s

regulations, as amended by Order Nos. 768 and 768-A,39 to the extent Applicant engages

in reporting of transactions to publishers of electric or natural gas price indices it will

37 See 18 C.F.R. § 35.10(b); see also Revised Public Utility Filing Requirements, Order No. 2001, FERC Stats. & Regs., Regs. Preambles ¶ 31,127 (2002), order on reh’g, Order No. 2001-A, 100 FERC ¶ 61,074 (2002), order on reconsideration and clarification, Order No. 2001-B, 100 FERC ¶ 61,342 (2002), order directing filings, Order No. 2001-C, 101 FERC ¶ 61,314 (2002), order directing refiling, Order No. 2001- D, 102 FERC ¶ 61,334 (2003), order on filing requirements, Order No. 2001-E, 105 FERC ¶ 61,352 (2003), clarification order, Order No. 2001-F, 106 FERC ¶ 61,060 (2004), order adopting dictionary, Order No. 2001-G, 120 FERC ¶ 61,270 (2007), clarification order, Order No. 2001-H, 121 FERC ¶ 61,289 (2007), order revising EQR data dictionary, Order No. 2001-I, 73 Fed. Reg. 65,526 (Nov. 4, 2008), FERC Stats. & Regs. ¶ 31,282 (2008); Electricity Market Transparency Provisions of Section 220 of the Federal Power Act, Order No. 768, 77 Fed. Reg. 61,896 (Oct. 11, 2012), FERC Stats. & Regs. ¶ 31,336 (2012), order partially extending compliance date, 142 FERC ¶ 61,105 (2013); order on reh’g, Order No. 768-A, 78 Fed. Reg. 24,101 (Apr. 24, 2013), 143 FERC ¶ 61,054 (2013) (requiring market participants excluded from Commission jurisdiction under section 205 of the FPA that have more than a de minimis market presence to file electronic quarterly reports); Revisions to Electric Quarterly Report Filing Process, Order No. 770, 77 Fed. Reg. 71,288 (Nov. 30, 2012), FERC Stats. & Regs. ¶ 31,338 (2012). 38 See 18 C.F.R. § 35.42. 39 Order No. 768 at PP 137-138, 178; Order No. 768-A at PP 40, 47.

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identify in its EQRs the publishers of electricity and natural gas indices to which it

reports its transactions.

E. Determination of Category Seller Status

The Commission’s regulations define Category 1 Sellers as wholesale power

marketers and wholesale power producers that meet each of the following criteria: (1)

own or control 500 MW or less of generation in aggregate per region;40 (2) do not own,

operate, or control transmission facilities other than limited equipment necessary to

connect individual generating facilities to the transmission grid; (3) are not affiliated with

anyone that owns, operates, or controls transmission facilities in the same region as the

seller’s generation assets; (4) are not affiliated with a franchised public utility in the same

region as the seller’s generation assets; and (5) do not raise other vertical market power

issues.41 Market-based rate sellers that do not qualify as Category 1 Sellers are defined

as Category 2 Sellers.42 Once the Commission determines that a seller meets the criteria

for classification as a Category 1 Seller, such seller is not required to file updated market

power analyses, or evidence of Category 1 Seller status, as long as it continues to meet

the criteria for classification as a Category 1 Seller.43

Applicant is located in the Northeast region, where its affiliates own or control

more than 500 MW. Accordingly, Applicant is a Category 2 Seller in the Northeast

region. Applicant does not own or control generation in any region outside of the

Northeast region and therefore Applicant owns or controls less than 500 MW of

40 For purposes of this analysis, the regions are Central, Northeast, Northwest, Southeast, Southwest, and Southwest Power Pool. See Order No. 697-A at Appendix D. 41 18 C.F.R. § 35.36(a)(2). 42 Id. § 35.36(a)(3). 43 Order No. 697-A at P 376.

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generation in the aggregate in the Central, Northwest, Southeast, Southwest, and

Southwest Power Pool regions. Applicant also does not own, operate, or control

transmission facilities other than limited and discrete equipment necessary to interconnect

its individual generating facility to the transmission grid. Further, in the Central,

Northwest, Southeast, Southwest, and Southwest Power Pool regions, Applicant is not

affiliated with any entity that owns, operates, or controls transmission facilities, or is a

franchised public utility, in the same region as Applicant’s generation assets. Finally,

Applicant does not raise other vertical market power issues. Therefore, Applicant

respectfully requests a determination that it meets the criteria for classification as a

Category 2 Seller in the Northeast region and Category 1 Seller in all other regions –

Central, Northwest, Southeast, Southwest, and Southwest Power Pool regions.

VI. REQUEST FOR PRE-APPROVALS AND WAIVERS

Applicant seeks the same pre-approvals and waivers of Commission rules and

filing requirements previously granted to other sellers permitted to sell electricity at

market-based rates. This relief consists of:

• Waiver of Parts 41, 101, and 141 of the Commission’s accounting and periodic reporting regulations, except as to sections 141.14 and 141.15;

• Waiver of Subparts B and C of Part 35 of the Commission’s regulations, except as to sections 35.12(a), 35.13(b), 35.15, and 35.16; and

• Blanket approval under Part 34 for all future issuances of securities and assumptions of liability.

VII. REQUESTED EFFECTIVE DATE

Applicant has entered in to a Shared Interconnection Facilities Agreement

(“SIFA”) with its affiliate Exelon West Medway. The SIFA was filed and accepted by

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the Commission with an effective date of October 1, 2016.44 Applicant requests the same

effective date for this Application solely to ensure that the waivers and blanket approvals

requested in Section VI above are effective at the same time as the SIFA45. Therefore,

Applicant respectfully requests an effective date for its market-based rate tariff of

October 1, 2016, which is one day from the date of this Application. Pursuant to sections

35.3 and 35.11 of the Commission’s regulations,46 Applicant respectfully requests a

waiver of the 60-day prior notice requirement so that Applicant’s tariff may have the

same effective date as the SIFA.

VIII. CONCLUSION

WHEREFORE, for the reasons stated above, Applicant respectfully requests that

the Commission issue an order accepting for filing Applicant’s proposed MBR tariff

effective October 1, 2016, and granting Applicant’s request for waivers and blanket

approvals.

Respectfully submitted,

/s/ Vincenzo Franco /s/ Jane E. Rueger Vincenzo Franco Jane E. Rueger Associate General Counsel Harold W. Bulger, III Exelon Corporation White & Case LLP 111 Market Place, Suite 500 701 Thirteenth Street, NW Baltimore, MD 21202 Washington, DC 20005 Tel. (410) 470-2593 Tel. (202) 626-6534 [email protected] [email protected]

Counsel for Exelon West Medway II, LLC September 30, 2016

44 See Exelon West Medway, LLC, Docket No. ER16-2028-000 (unpublished delegated letter order issued Aug. 18, 2016); See also Exelon West Medway II, LLC, Docket No. ER16-2048-000 (unpublished delegated letter order issued Aug. 18, 2016). 45 As noted above, Applicant’s Facility is still under development and Applicant does not expect to make any sales under its market-based rate authority until Q4 of 2017. 46 18 C.F.R. §§ 35.3 and 35.11.

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Attachment A: Proposed FERC Electric Tariff

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Market-Based Rate Tariff

I. Availability

Seller makes electric energy, capacity, and ancillary services available under this tariff to any purchaser with whom Seller has contracted, except as prohibited below.

II. Rates

All sales shall be made at rates established by agreement between the purchaser and Seller.

III. Other Terms and Conditions

All other terms and conditions of sales shall be established by agreement between the purchaser and Seller.

IV. Compliance with Commission Regulations

Seller shall comply with the provisions of 18 CFR Part 35, Subpart H, as applicable, and with any conditions the Commission imposes in its orders concerning seller’s market-based rate authority, including orders in which the Commission authorizes seller to engage in affiliate sales under this tariff or otherwise restricts or limits the seller’s market-based rate authority. Failure to comply with the applicable provisions of 18 CFR Part 35, Subpart H, and with any orders of the Commission concerning seller’s market-based rate authority, will constitute a violation of this tariff.

V. Seller Category

Seller is a Category 2 Seller in the Northeast region and a Category 1 Seller in all other regions, as defined in 18 CFR § 35.36(a).

VI. Limitations and Exemptions Regarding Market-Based Rate Authority

In Exelon West Medway II, LLC, Docket No. ER16-___-000 (2016):

The Commission has granted waiver of its code of conduct and affiliate sales restrictions for transactions between Seller and its franchised public utility affiliates. See Exelon Generation Co., 93 FERC 61,140, at 61,425 (2000), on reh’g, 95 FERC 61,309 (2001); AmerGen VT, LLC, 90 FERC 61,307, at 61,995, reh’g denied, Baltimore Gas & Elec. Co., 91 FERC 61,270 (2000); Potomac Electric Power Co., 93 FERC 61,240 (2000).

Seller has received (1) waiver of Subparts B and C of Part 35, except for sections 35.12(a), 35.13(b), 35.15 and 35.16; (2) waiver of Parts 41, 101 and 141 except

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sections 141.14 and 141.15, and with the exception that waiver of the provisions of Part 101 that apply to hydropower licenses is not granted with respect to licensed hydropower projects; and (3) blanket authorization for all future issuances of securities or assumptions of liabilities pursuant to Part 34 of the Commission’s regulations.

VII. Ancillary Services

(A) PJM: Seller offers regulation and frequency response service, energy imbalance service, and operating reserve service (which includes spinning, 10- minute, and 30-minute reserves) for sale into the market administered by PJM Interconnection, L.L.C. (“PJM”) and, where the PJM Open Access Transmission Tariff permits, the self-supply of these services to purchasers for a bilateral sale that is used to satisfy the ancillary services requirements of the PJM Office of Interconnection.

(B) New York: Seller offers regulation and frequency response service, and operating reserve service (which include 10-minute non-synchronous, 30-minute operating reserves, 10-minute spinning reserves, and 10-minute non-spinning reserves) for sale to purchasers in the market administered by the New York Independent System Operator, Inc.

(C) New England: Seller offers regulation and frequency response service (automatic generator control), operating reserve service (which includes 10- minute spinning reserve, 10-minute non-spinning reserve, and 30-minute operating reserve service) to purchasers within the markets administered by the ISO New England, Inc.

(D) California: Seller offers regulation service, spinning reserve service, and non-spinning reserve service to the California Independent System Operator Corporation (“CAISO”) and to others that are self-supplying ancillary services to the CAISO.

(E) MISO: Seller offers regulation service and operating reserve service (which include 10-minute spinning reserve and 10-minute supplemental reserve) for sale to the Midcontinent Independent System Operator, Inc. (MISO) and to others that are self-supplying ancillary services to MISO.

(F) Southwest Power Pool: Seller offers regulation service and operating reserve service (which include 10-minute spinning reserve and 10-minute supplemental reserve) for sale to the Southwest Power Pool, Inc. (SPP) and to others that are self-supplying ancillary services to SPP.

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include the following: (1) sales to an RTO or an ISO, i.e., where that entity has no ability to self-supply ancillary services but instead depends on third parties; and (2) sales to a traditional, franchised public utility affiliated with the third-party supplier, or sales where the underlying transmission service is on the system of the public utility affiliated with the third-party supplier. Sales of Operating Reserve-Spinning and Operating Reserve-Supplemental will not include sales to a public utility that is purchasing ancillary services to satisfy its own open access transmission tariff requirements to offer ancillary services to its own customers, except where the Commission has granted authorization. Sales of Regulation Service and Reactive Supply and Voltage Control Service will not include sales to a public utility that is purchasing ancillary services to satisfy its own open access transmission tariff requirements to offer ancillary services to its own customers, except at rates not to exceed the buying public utility transmission provider’s OATT rate for the same service or where the Commission has granted authorization.

VIII. Effective Date

This Rate Schedule shall be effective as of the date specified by the Federal Energy Regulatory Commission.

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Attachment B: Proposed Protective Order

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UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION

Exelon West Medway II, LLC ) Docket No. ER16-___

PROTECTIVE ORDER

(Issued September __, 2016)

1. This Protective Order shall govern the use of all Protected Materials produced by, or on behalf of, any Participant. Notwithstanding any order terminating this proceeding, this Protective Order shall remain in effect until specifically modified or terminated by the Presiding Administrative Law Judge (“Presiding Judge”) or the Federal Energy Regulatory Commission (“Commission”).

2. This Protective Order applies to the following two categories of materials: (A) A Participant may designate as protected those materials which customarily are treated by that Participant as sensitive or proprietary, which are not available to the public, and which, if disclosed freely, would subject that Participant or its customers to risk of competitive disadvantage or other business injury; and (B) A Participant shall designate as protected those materials which contain critical energy infrastructure information, as defined in 18 C.F.R. § 388.113(c)(1) (“Critical Energy Infrastructure Information”).

3. Definitions -- For purposes of this Order:

(a) The term “Participant” shall mean a Participant as defined in 18 C.F.R. § 385.102(b).

(b)(1) The term “Protected Materials” means (A) materials (including depositions) provided by a Participant in response to discovery requests and/or filed with the Commission and, in each case, designated by such Participant as protected; (B) any information contained in or obtained from such designated materials; (C) any other materials which are made subject to this Protective Order by the Presiding Judge, by the Commission, by any court or other body having appropriate authority, or by agreement of the Participants; (D) notes of Protected Materials; and (E) copies of Protected Materials. The Participant producing the Protected Materials shall physically mark them on each page as “PROTECTED MATERIALS” or with words of similar import as long as the term “Protected Materials” is included in that designation to indicate that they are Protected Materials. If the Protected Materials contain Critical Energy Infrastructure Information, the Participant producing such information shall additionally mark on each page containing such information the words “Contains Critical Energy Infrastructure Information — Do Not Release.” In addition if the Protected Materials contain market sensitive information, public disclosure of which the disclosing Participant believes in good faith would competitively harm the Participant, the disclosing Participant shall additionally mark on each page containing such information the words “HIGHLY

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SENSITIVE PROTECTED MATERIALS.” Except for the more limited list of persons who qualify as Reviewing Representatives for purposes of reviewing Highly Sensitive Protected Materials, such materials are subject to the same provisions in the Protective Order as Protected Materials.

(2) The term “Notes of Protected Materials” means memoranda, handwritten notes, or any other form of information (including electronic form) which copies or discloses materials described in Paragraph 3(b)(1). Notes of Protected Materials are subject to the same restrictions provided in this order for Protected Materials except as specifically provided in this order.

(3) Protected Materials shall not include (A) any information or document contained in the files of the Commission (other than pursuant to this Protective Order), or any other federal or state agency, or any federal or state court, unless the information or document has been determined to be protected by such agency or court, or (B) information that is public knowledge, or which becomes public knowledge, other than through disclosure in violation of this Protective Order, or (C) any information or document labeled as “Non-Internet Public” by a Participant, in accordance with Paragraph 30 of FERC Order No. 630, FERC Stat. & Reg. & 31,140. Protected Materials do include any information or document contained in the files of the Commission that has been designated as Critical Energy Infrastructure Information.

(c) The term “Non-Disclosure Certificate” shall mean the certificate annexed hereto by which Participants who have been granted access to Protected Materials shall certify their understanding that such access to Protected Materials is provided pursuant to the terms and restrictions of this Protective Order, and that such Participants have read the Protective Order and agree to be bound by it. All Non-Disclosure Certificates shall be served on all parties on the official service list maintained by the Secretary in this proceeding.

(d) The term “Reviewing Representative” shall mean a person who has signed a Non-Disclosure Certificate (to the extent required by Section 9) and:

(i) For purposes of reviewing Protected Materials (other than Highly Sensitive Protected Materials), who is

(1) Commission Staff (“Staff”);

(2) an attorney who has made an appearance in this proceeding for a Participant;

(3) attorneys, paralegals, and other employees associated for purposes of this case with an attorney described in Subparagraph (2);

(4) an expert or an employee of an expert retained by a Participant for the purpose of advising, preparing for or testifying in this proceeding;

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(5) a person designated as a Reviewing Representative by order of the Presiding Judge or the Commission; or

(6) employees or other representatives of Participants appearing in this proceeding with significant responsibility for this docket.

(ii) For purposes of reviewing Highly Sensitive Protected Materials, who is: (1) Staff;

(2) Members or staff of any state or local utilities commission which is a Participant;

(3) An outside attorney who has made an appearance in this proceeding for a Participant;

(4) Attorneys, paralegals, and other employees of the firm of the outside attorney described in Paragraph 3(d)(ii)(3) working with such outside attorney for purposes of this case;

(5) An outside expert or an employee of an outside expert retained by a Participant for the purpose of advising, preparing for or testifying in this proceeding who is working under the direction of an attorney described in Paragraph 3(d)(ii)(2) or 3(d)(ii)(3);

(6) If, after a good faith effort, parties fail to agree on designating a specifically-named inside employee(s) of a non-governmental Participant as a Reviewing Representative for the review of specific Highly Sensitive Protected Material(s), a party may request that the Presiding Judge so- designate such a specifically-named inside employee(s) who, for example, is not directly involved in, or having direct or supervisory responsibilities over, the purchase, sale, or marketing of electricity (including transmission service) at retail or wholesale, the negotiation or development of participation or cost-sharing arrangements for transmission or generation facilities, or other activities or transactions of a type with respect to which the disclosure of Highly Sensitive Protected Materials may present an unreasonable risk of harm; or

(7) A person designated as a Reviewing Representative by order of the Presiding Judge or the Commission specifically ruling on and indicating each such person by name.

4. Protected Materials shall be made available under the terms of this Protective Order only to Participants and only through their Reviewing Representatives as provided in Paragraphs 7-9.

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5. Protected Materials shall remain available to Participants until the later of the date that an order terminating this proceeding becomes no longer subject to judicial review, or the date that any other Commission proceeding relating to the Protected Material is concluded and no longer subject to judicial review. If requested to do so in writing after that date, the Participants shall, within fifteen days of such request, return the Protected Materials (excluding Notes of Protected Materials) to the Participant that produced them, or shall destroy the materials, except that copies of filings, official transcripts and exhibits in this proceeding that contain Protected Materials, and Notes of Protected Material may be retained, if they are maintained in accordance with Paragraph 6, below. Within such time period each Participant, if requested to do so, shall also submit to the producing Participant an affidavit stating that, to the best of its knowledge, all Protected Materials and all Notes of Protected Materials have been returned or have been destroyed or will be maintained in accordance with Paragraph 6. To the extent Protected Materials are not returned or destroyed, they shall remain subject to the Protective Order.

6. All Protected Materials shall be maintained by the Participant in a secure place. Access to those materials shall be limited to those Reviewing Representatives specifically authorized pursuant to Paragraphs 8-9. The Secretary shall place any Protected Materials filed with the Commission in a non-public file. By placing such documents in a non- public file, the Commission is not making a determination of any claim of privilege. The Commission retains the right to make determinations regarding any claim of privilege and the discretion to release information necessary to carry out its jurisdictional responsibilities. For documents submitted to Staff, Staff shall follow the notification procedures of 18 C.F.R. § 388.112 before making public any Protected Materials.

7. Protected Materials shall be treated as confidential by each Participant and by the Reviewing Representative in accordance with the certificate executed pursuant to Paragraph 9. Protected Materials shall not be used except as necessary for the conduct of this proceeding, nor shall they be disclosed in any manner to any person except a Reviewing Representative who is engaged in the conduct of this proceeding and who needs to know the information in order to carry out that person's responsibilities in this proceeding. Reviewing Representatives may make copies of Protected Materials, but such copies become Protected Materials. Reviewing Representatives may make notes of Protected Materials, which shall be treated as Notes of Protected Materials if they disclose the contents of Protected Materials.

8. (a) If a Reviewing Representative's scope of employment includes the marketing of energy, the direct supervision of any employee or employees whose duties include the marketing of energy, the provision of consulting services to any person whose duties include the marketing of energy, or the direct supervision of any employee or employees whose duties include the marketing of energy, such Reviewing Representative may not use information contained in any Protected Materials obtained through this proceeding to give any Participant or any competitor of any Participant a commercial advantage.

(b) In the event that a Participant wishes to designate as a Reviewing Representative a person not described in Paragraph 3 (d) above, the Participant shall seek

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agreement from the Participant providing the Protected Materials. If an agreement is reached that person shall be a Reviewing Representative pursuant to Paragraphs 3(d) above with respect to those materials. If no agreement is reached, the Participant shall submit the disputed designation to the Presiding Judge for resolution.

9. (a) A Reviewing Representative shall not be permitted to inspect, participate in discussions regarding, or otherwise be permitted access to Protected Materials pursuant to this Protective Order unless that Reviewing Representative has first executed a Non- Disclosure Certificate; provided, that if an attorney qualified as a Reviewing Representative has executed such a certificate, the paralegals, secretarial and clerical personnel under the attorney’s instruction, supervision or control need not do so. A copy of each Non-Disclosure Certificate shall be provided to counsel for the Participant asserting confidentiality prior to disclosure of any Protected Material to that Reviewing Representative. NOTWITHSTANDING THE FOREGOING, A MEMBER OF THE COMMISSION’S ADVISORY STAFF REVIEWING PROTECTED MATERIAL OR HIGHLY SENSITIVE PROTECTED MATERIAL SUBJECT TO THIS AGREEMENT IN CONNECTION WITH ITS REVIEW OF APPLICANT’S MARKET-BASED RATE AUTHORIZATION SHALL NOT BE REQUIRED TO SIGN OR RETURN A NON- DISCLOSURE CERTIFICATE.

(b) Attorneys qualified as Reviewing Representatives are responsible for ensuring that persons under their supervision or control comply with this order.

10. Any Reviewing Representative may disclose Protected Materials to any other Reviewing Representative as long as the disclosing Reviewing Representative and the receiving Reviewing Representative both have executed a Non-Disclosure Certificate. In the event that any Reviewing Representative to whom the Protected Materials are disclosed ceases to be engaged in these proceedings, or is employed or retained for a position whose occupant is not qualified to be a Reviewing Representative under Paragraph 3(d), access to Protected Materials by that person shall be terminated. Even if no longer engaged in this proceeding, every person who has executed a Non-Disclosure Certificate shall continue to be bound by the provisions of this Protective Order and the certification.

11. Subject to Paragraph 18, the Presiding Administrative Law Judge shall resolve any disputes arising under this Protective Order. Prior to presenting any dispute under this Protective Order to the Presiding Administrative Law Judge, the parties to the dispute shall use their best efforts to resolve it. Any participant that contests the designation of materials as protected shall notify the party that provided the protected materials by specifying in writing the materials the designation of which is contested. This Protective Order shall automatically cease to apply to such materials five (5) business days after the notification is made unless the designator, within said 5-day period, files a motion with the Presiding Administrative Law Judge, with supporting affidavits, demonstrating that the materials should continue to be protected. In any challenge to the designation of materials as protected, the burden of proof shall be on the participant seeking protection. If the Presiding Administrative Law Judge finds that the materials at issue are not entitled

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to protection, the procedures of Paragraph 18 shall apply. The procedures described above shall not apply to protected materials designated by a Participant as Critical Energy Infrastructure Information. Materials so designated shall remain protected and subject to the provisions of this Protective Order, unless a Participant requests and obtains a determination from the Commission's Critical Energy Infrastructure Information Coordinator that such materials need not remain protected.

12. All copies of all documents reflecting Protected Materials, including the portion of the hearing testimony, exhibits, transcripts, briefs and other documents which refer to Protected Materials, shall be filed and served in sealed envelopes or other appropriate containers endorsed to the effect that they are sealed pursuant to this Protective Order. Such documents shall be marked “PROTECTED MATERIALS” and shall be filed under seal and served under seal upon the Presiding Judge and all Reviewing Representatives who are on the service list. Such documents containing Critical Energy Infrastructure Information shall be additionally marked “Contains Critical Energy Infrastructure Information — Do Not Release.” For anything filed under seal, redacted versions or, where an entire document is protected, a letter indicating such, will also be filed with the Commission and served on all parties on the service list and the Presiding Judge. Counsel for the producing Participant shall provide to all Participants who request the same, a list of Reviewing Representatives who are entitled to receive such material. Counsel shall take all reasonable precautions necessary to assure that Protected Materials are not distributed to unauthorized persons.

13. If any Participant desires to include, utilize or refer to any Protected Materials or information derived therefrom in testimony or exhibits during the hearing in these proceedings in such a manner that might require disclosure of such material to persons other than reviewing representatives, such participant shall first notify both counsel for the disclosing participant and the Presiding Judge of such desire, identifying with particularity each of the Protected Materials. Thereafter, use of such Protected Material will be governed by procedures determined by the Presiding Judge.

14. Nothing in this Protective Order shall be construed as precluding any Participant from objecting to the use of Protected Materials on any legal grounds.

15. Nothing in this Protective Order shall preclude any Participant from requesting the Presiding Judge, the Commission, or any other body having appropriate authority, to find that this Protective Order should not apply to all or any materials previously designated as Protected Materials pursuant to this Protective Order. The Presiding Judge may alter or amend this Protective Order as circumstances warrant at any time during the course of this proceeding.

16. Each party governed by this Protective Order has the right to seek changes in it as appropriate from the Presiding Judge or the Commission.

17. All Protected Materials filed with the Commission, the Presiding Judge, or any other judicial or administrative body, in support of, or as a part of, a motion, other

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pleading, brief, or other document, shall be filed and served in sealed envelopes or other appropriate containers bearing prominent markings indicating that the contents include Protected Materials subject to this Protective Order. Such documents containing Critical Energy Infrastructure Information shall be additionally marked “Contains Critical Energy Infrastructure Information – Do Not Release.”

18. If the Presiding Judge finds at any time in the course of this proceeding that all or part of the Protected Materials need not be protected, those materials shall, nevertheless, be subject to the protection afforded by this Protective Order for three (3) business days from the date of issuance of the Presiding Judge's determination, and if the Participant seeking protection files an interlocutory appeal or requests that the issue be certified to the Commission, for an additional seven (7) business days. None of the Participants waives its rights to seek additional administrative or judicial remedies after the Presiding Judge's decision respecting Protected Materials or Reviewing Representatives, or the Commission's denial of any appeal thereof. The provisions of 18 C.F.R. §§ 388.112 and 388.113 shall apply to any requests under the Freedom of Information Act. (5 U.S.C. ¶ 552) for Protected Materials in the files of the Commission.

19. Nothing in this Protective Order shall be deemed to preclude any Participant from independently seeking through discovery in any other administrative or judicial proceeding information or materials produced in this proceeding under this Protective Order.

20. None of the Participants waives the right to pursue any other legal or equitable remedies that may be available in the event of actual or anticipated disclosure of Protected Materials.

21. The contents of Protected Materials or any other form of information that copies or discloses Protected Materials shall not be disclosed to anyone other than in accordance with this Protective Order and shall be used only in connection with this (these) proceeding(s). Any violation of this Protective Order and of any Non-Disclosure Certificate executed hereunder shall constitute a violation of an order of the Commission.

Presiding Administrative Law Judge

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UNITED STATES OF AMERICA FEDERAL ENERGY REGULATORY COMMISSION

Exelon West Medway II, LLC ) Docket No. ER16-___

NON-DISCLOSURE CERTIFICATE

I hereby certify my understanding that access to Protected Materials is provided to me pursuant to the terms and restrictions of the Protective Order in this proceeding, that I have been given a copy of and have read the Protective Order, and that I agree to be bound by it. I understand that the contents of the Protected Materials, any notes or other memoranda, or any other form of information that copies or discloses Protected Materials shall not be disclosed to anyone other than in accordance with that Protective Order. I acknowledge that a violation of this certificate constitutes a violation of an order of the Federal Energy Regulatory Commission.

By: Title: Representing: Date: ______

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Attachment C: Asset Appendices

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Attachment D:

Affidavit of Julie R. Solomon

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UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION

Exelon West Medway II, LLC ) Docket No. ER16-___-000

AFFIDAVIT OF JULIE R. SOLOMON I. INTRODUCTION

My name is Julie R. Solomon. I am a Managing Director of Navigant Consulting, Inc. My business address is 1200 19th Street, N.W., Suite 700, Washington, DC 20036. A large portion of my consulting activities involves electric utility industry restructuring and the transition from regulation to competition. I have been involved extensively in consulting on market power issues concerning mergers, other asset transactions and market-based rate applications. I have filed a number of affidavits before the Federal Energy Regulatory Commission (the “Commission”) in connection with electric utility mergers, the purchase and sale of jurisdictional assets, applications for market-based rates, and triennial updates. Included among these, I have filed a number of affidavits with the Commission on behalf of relevant affiliates of Exelon Corporation (“Exelon”) with market-based rate authority in connection with past triennial updates. My resume is attached as Exhibit JRS-1.

I have been asked by counsel for Exelon West Medway II, LLC (“West Medway II”, or “Seller”, or “Applicant”) to perform an analysis of market power in connection with its application for market-based rates. My analysis is consistent with the Commission’s guidelines contained in Order No. 6971 and Order No. 816.2 Here I provide an evaluation of horizontal and vertical market

1 Market-Based Rates for Wholesale Sales of Elec. Energy, Capacity and Ancillary Servs. by Pub. Utils., Order No. 697, FERC Stats. & Regs. ¶ 31,252, clarified, 121 FERC ¶ 61,260 (2007), order on reh'g and clarification, Order No. 697-A, FERC Stats. & Regs ¶ 31,268, order on reh'g and clarification, 124 FERC ¶ 61,055, order on reh'g and clarification, Order No. 697-B, FERC Stats. & Regs ¶ 31,285 (2008), order on reh'g and clarification, Order No. 697-C, FERC Stats. & Regs ¶ 31,291 (2009), order on reh'g and clarification, Order No. 697-D, FERC Stats. & Regs. ¶ 31,305, order on clarification, 131 FERC ¶ 61,021, reh'g denied, 134 FERC ¶ 61,046 (2010), appeal docketed sub nom. Mont. Consumer Counsel v. FERC, Nos. 08-71827, et al. (9th Cir. filed May 1, 2008) (collectively, ”Order No. 697”) (codified at 18 C.F.R. pt. 35). 2 Refinements to Policies and Procedures for Market-Based Rates for Wholesale Sales of Electric Energy, Capacity and Ancillary Services by Public Utilities, Order No. 816, 153 FERC ¶ 61,065 (2015) reh’g, Order No. 816-A, 155 FERC ¶ 61,188 (2016).

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power issues for the relevant market in which Applicant will own generation facilities, namely the ISO New England, Inc. (“ISO-NE”) balancing authority area (“BAA”).

II. SUMMARY OF CONCLUSIONS

Based on the analyses discussed herein, I find that, under the Commission’s guidelines, Applicant satisfies the Commission’s horizontal market power screens. Applicant also does not have vertical market power in the relevant markets.

The analysis I have conducted is consistent with Order No. 697 and related orders. I have performed the two indicative horizontal market power screens required by the Commission, namely a pivotal supplier analysis based on the annual peak demand of the relevant market (“Pivotal Supplier Analysis”) and a market share analysis (“Market Share Analysis”) applied on a seasonal basis for the relevant study period of December 2014-November 2015. Consistent with Order No. 697, I examined the relevant default geographic market, where the generation owned by Applicant is physically located.

Applicant readily passes both the Pivotal Supplier Analysis and the Market Share Analysis in ISO-NE and therefore lacks horizontal market power. Applicant also lacks vertical market power. The only transmission facilities owned or controlled by the Applicant or its affiliates in ISO-NE consist of those necessary to connect their generating facilities to the grid and thus do not raise any vertical market power concerns.

Applicant and its affiliates cannot erect barriers to entry with respect to the inputs to production specified in the relevant regulations. They have no ownership or control of intrastate natural gas transportation or intrastate natural gas storage in ISO-NE. Applicant and its affiliates do not own or control sources of coal supplies or transportation of coal supplies in ISO-NE. There are no other issues that raise any relevant competitive concerns.

I understand that an affirmative statement on behalf of the Applicant and its affiliates is included in the Application to the effect that they have not erected barriers to entry and will not erect barriers to entry.

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III. DESCRIPTION OF WEST MEDWAY II

West Medway II is a wholly-owned, indirect subsidiary of Exelon Generation Company, LLC (“Exelon Generation”). West Medway II will own and operate an approximately 195 MW (summer rating) generating facility located in Medway, Massachusetts in ISO-NE. It is currently anticipated that sale of test power from the West Medway II Facility could begin as early as December 2017 and commercial operation is expected to occur in April 2018.

Exhibit JRS-2 provides a list of the generating units owned by West Medway II and its affiliates in ISO-NE, as well as long-term firm purchases by West Medway II affiliates in ISO-NE. As shown, West Medway II is affiliated with an additional approximately 2,800 MW of generation and long-term purchases in ISO-NE. The exhibit also includes generation owned by West Medway II affiliates in relevant first tier markets, namely in the New York Independent System Operator, Inc. BAA.

IV. HORIZONTAL MARKET POWER

Background and Analytic Approach

In Order No. 697, the Commission codified a methodology for assessing market power to be used by applicants requesting market-based rate authority under Section 205 of the Federal Power Act or making their required triennial market power update filings. The Commission applies two screens – the Pivotal Supplier Analysis and the Market Share Analysis – intended to demonstrate a lack of horizontal market power. If an entity fails to pass either of the screens, there is a presumption of horizontal market power and further analysis is required.

In Order No. 697, the Commission defines the default relevant market as the BAA or the RTO/ISO market, as applicable, where the seller is located.3 Where a generator is interconnected to a non-affiliate owned transmission system, the only relevant market is the BAA in which the generator is located.4 Accordingly, the default relevant market for purposes of this application is ISO-NE. The West Medway II Facility is not located in a relevant ISO-NE submarket.

3 Order No. 697 at P 231. 4 Id. at P 232 n.217.

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Pivotal Supplier Analysis

The Pivotal Supplier Analysis seeks to determine if load can be served without an applicant’s generation. Order No. 697 specifies a number of calculations for the Pivotal Supplier screen.5

First, Total Uncommitted Supply is calculated based on installed capacity (adjusted for long- term firm purchases and sales) plus imports less the BAA reserve requirement (i.e., operating reserves) less the average daily peak native load for the peak month.

Second, Wholesale Load is calculated based on the difference between the annual peak load (needle peak) for the BAA and the average daily peak native load for the peak month.

Third, Net Uncommitted Supply is calculated based on the difference between Total Uncommitted Supply and Wholesale Load. Seller’s Uncommitted Capacity is based on Seller’s Total Installed Capacity less its average daily peak native load.

If Seller’s Uncommitted Capacity is less than the Net Uncommitted Supply, the Pivotal Supplier Analysis is passed.

Market Share Analysis

The Market Share Analysis evaluates, for each of the four seasons, whether the applicant has a dominant position in the market, with dominance defined as a market share in excess of 20 percent.

Order No. 697 specifies a number of calculations for the market share screen.6

First, Seller and Affiliate Capacity is calculated based on installed capacity (adjusted for long-term firm purchases and sales) plus imports less planned outages. Non-Affiliate Capacity is calculated in a similar manner.

5 See Appendix A, Part I of Order No. 697. The format of the pivotal supplier screen was updated in Order No. 816. 6 See Appendix A, Part II of Order No. 697. The format of the market share screen was updated in Order No. 816.

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Second, Capacity Deductions are calculated based on average peak native load in the season (averaged over all days)7 plus operating reserves, and allocated between Seller and Others.

Third, Seller’s Uncommitted Capacity is calculated by subtracting the Capacity Deductions attributed to Seller from Seller and Affiliate Capacity; and Total Competing Supply is calculated by subtracting the Capacity Deductions attributed to others from Non-Affiliate Capacity. Total Seasonal Uncommitted Capacity is the sum of Seller’s Uncommitted Capacity and Total Competing Supply.

Finally, Seller’s Market Share is calculated as Seller’s Uncommitted Capacity as a percent of Total Seasonal Uncommitted Capacity.

If Seller’s Market Share is less than 20 percent in all seasons, the Market Share Analysis is passed.

Assumptions Relevant Geographic Market. ISO-NE is the only relevant geographic market.

Study Period. My analysis is based on a December 2014-November 2015 study period. The Clarification Order indicates that non-transmission owning applicants filing for initial market-based rate authorization should rely on data for the most recently available actual historical period. The study period I am using is the same as the period that will be used for the Northeast Region triennials that will be filed in December 2016.

Generating Capacity. Seasonal ratings for generation in ISO-NE are based on the EIA-860.8

Operating Reserves. ISO-NE operating reserves are based on the thirty minute reserve requirement in ISO-NE’s 2015 Annual Markets report.9

7 Consistent with the Clarification Order, 121 FERC ¶ 61,260 (2007) I used the following seasons for my analysis: Winter (December-February), Spring (March-May), Summer (June-August) and Fall (September-November). 8 http://www.eia.gov/electricity/data/eia860/ (early release data for 2015). 9 ISO New England’s Internal Market Monitor, 2015 Annual Markets Report, ISO New England Inc., Internal Market Monitor, May 25, 2016,

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Load Data. I used hourly load reported by Energy Velocity. For Exelon’s ISO-NE load, I used confidential load data provided by the Applicant.

Planned Outages. I used planned outages reported in the FERC Form No. 714.10

Simultaneous Import Limits (“SIL”). I used the SIL in the Northeast Region approved by the Commission in connection with the December 2013 triennials.11

Results of Analysis

Exhibit JRS-3 presents the results of the Pivotal Supplier Analysis and Exhibit JRS-4 presents the results of the Market Share Analysis, consistent with the Appendix A screen format contained in Order No. 816.12 Below I summarize the results of the Pivotal Supplier and Market Share Analyses. The indicative screens also are being provided in a workable spreadsheet format, as required under Order No. 816.13

Pivotal Supplier Analysis. West Medway II and its affiliates own 2,399 MW of generation in ISO- NE. West Medway II and its affiliates have 621 MW of long-term firm purchases, are attributed 614 MW of imports, and 4,000 MW of load. Thus, West Medway II’s affiliated Uncommitted Capacity in ISO-NE is zero (actually negative). Net Uncommitted Supply is 8,300 MW.

Because Seller’s Uncommitted Capacity is less than the Net Uncommitted Supply, the Pivotal Supplier Analysis is passed in ISO-NE. See Exhibit JRS-3.

http://www.iso-ne.com/static-assets/documents/2016/05/2015_imm_amr_final_5_25_2016.pdf. 10 Order No. 697 indicates that planned outages should be consistent with those reported in FERC Form No. 714, and that “[t]o determine the amount of planned outages for a given season, the total number of MW-days of outages is divided by the total number of days in the season.” Order No. 697 at P 43. However, the FERC Form No. 714 reports planned outages only at time of peak for the month, and hence it is not possible to determine the total number of MW-days of outages from these data. 11 New Brunswick Energy Marketing Corporation, Order On Simultaneous Transmission Import Limit Values For The Northeast Region, 147 FERC ¶ 61,190 (2014). 12 Order No. 816, 153 FERC ¶ 61,065 at P 74 (2015). The screen formats are provided electronically on the FERC website. http://www.ferc.gov/industries/electric/gen-info/mbr/OrderNo816/appendix-A.xls. 13 Id. at P 80.

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Market Share Analysis. West Medway II and its affiliates own 2,399 MW to 2,769 MW of generation in ISO-NE, and have 621 MW of long-term firm purchases. They are attributed 501 MW to 594 MW of imports, and 3,224 MW to 4,080 MW of load. Thus, West Medway II’s affiliated Uncommitted Capacity in ISO-NE ranges from zero (actually negative) to 675 MW. West Medway II and affiliates’ Market Share ranges from zero to 4.2 percent. Because Seller’s Market Share is less than 20 percent in all seasons, the Market Share Analysis is passed in ISO-NE. See Exhibit JRS- 4.

Thus, on the basis of the Commission’s screens, West Medway II does not have horizontal market power in ISO-NE.

Transmission

West Medway II and its affiliates own no transmission in ISO-NE other than the equipment necessary to connect their generation to the grid and thus there are no vertical concerns in relation to these facilities.

Barriers to Entry

West Medway II and its affiliates cannot erect barriers to entry with respect to the inputs to production specified in the relevant regulations. West Medway II and its affiliates have no ownership or control of intrastate natural gas transportation or intrastate natural gas storage in ISO- NE. Hence, no vertical concerns are present with respect to such assets. Also, in ISO-NE, West Medway II and affiliates do not own or control sources of coal supplies or the transportation of coal supplies other than private rail cars for the transport of coal supplies. There are no other issues that raise any relevant competitive concerns.

I understand that an affirmative statement on behalf of West Medway II and affiliates is included in their submission that they have not erected barriers to entry and will not erect barriers to entry.

Based on these facts, West Medway II and affiliates have demonstrated a lack of vertical market power.

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V. CONCLUSION

On the basis of the foregoing analysis, Applicant satisfies the Commission’s horizontal and vertical market power tests for market-based rate authority in ISO-NE.

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Exhibit JRS‐1

Julie R. Solomon

Julie R. Solomon Julie Solomon is a Managing Director at Navigant Consulting, Inc. in Managing Director the Energy Practice’s Power Systems, Markets & Pricing group. She Navigant Consulting has more than 20 years of consulting experience, specializing in the Suite 700 areas of regulatory and utility economics, financial analysis and 1200 19th Street NW business valuation. Ms. Solomon has participated in analysis of Washington, DC 20036 Tel: 202-481-8492 proposed regulatory reforms, supply options and utility industry Fax: 202 973-2401 restructuring in the gas and electric industries. She also has advised

[email protected] utility clients in corporate strategy and corporate restructuring, and consulted to legal counsel on a variety of litigation and regulatory Professional History matters, including antitrust litigation and contract disputes. She has  Managing Director, Navigant filed testimony in numerous proceedings before the Federal Energy Consulting - 2010-Present Regulatory Commission. Much of her current practice focuses on  Vice President, Charles River Associates - 2001-2010 regulatory and market power issues concerning mergers and  Senior Vice President, Putnam, acquisitions and compliance filings in the electricity market. Hayes and Bartlett, Inc. and PHB Hagler Bailly, Inc., Washington, DC - 1986-2000 » Advised clients in the electric and gas utility industry on  Economist, Economic Consulting competition issues, including the impact of mergers on Services, Inc., Washington, DC - competition. Directed a large number of analytic studies 1979-1986 relating to obtaining merger approval from regulatory  Economist, U.S. Department of Labor, Washington, DC - 1976-1979 authorities.

Education » Advised clients in the electric utility industry on restructuring  M.B.A. Finance, The Wharton School strategies, including potential mergers and acquisitions, University of Pennsylvania functional unbundling and cost savings.  B.A. Economics, Connecticut College

Testimony » Consulted in the electric and gas utility industries in a variety  Written testimony provided in more of regulatory and competition matters, including rate than 150 regulatory proceedings proceedings, prudence reviews, proposed regulatory reforms, analysis of supply options, privatization and restructuring.

» Advised utility and non‐utility clients on many aspects of the competitive independent power industry, including strategic and financial consulting assignments.

» Consulted legal counsel on a variety of litigation matters, including the development of expert testimony on liability issues and the calculation of damages in a variety of industries.

» Provided strategic and economic analyses for clients in trade regulatory proceedings such as dumping and subsidies.

» Provided financial and business valuation analyses in a number of transactions, including fair market value for taxation purposes and valuation of family‐owned businesses.

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Julie R. Solomon

Professional Experience

Electric and Gas Utilities Mergers and Acquisitions (Market Power and Competition Issues) » Advised clients and conducted analytic studies in connection with a large number of major electric and electric‐gas mergers and asset transactions of regulated companies. Provided testimony to FERC for a number of these types of transactions.

» Advised clients and provided confidential pre‐screening analyses for potential mergers and acquisitions.

» Conducted numerous analytic studies in connection with FERC market‐based rate applications and compliance filings for electricity sellers. Provided testimony to FERC for a number of these types of transactions.

» Conducted numerous analytic studies in connection with FERC market‐based rate applications and compliance filings for gas storage facilities. Provided testimony to FERC for a number of these types of transactions.

Utility Restructuring and Stranded Cost » Conducted analytic studies and provided litigation support in connection with state stranded cost proceedings in Ohio (Cincinnati Gas & Electric and Dayton Power & Light); West Virginia (Monongahela Power and Potomac Edison); Maryland (Potomac Edison) and Pennsylvania (West Penn Power).

» Provided analytic support evaluating the benefits of Public Service of Colorado’s proposed DC transmission line between Colorado and Kansas in support of a regulatory proceeding.

» Assisted in studies relating to privatization of the electricity industry in the United Kingdom, including development of a computer model to simulate electricity dispatch and project future prices, capacity needs and utility revenues under various scenarios. During temporary assignment to London office.

» Participated in antitrust litigation involving a utility and a cogenerator, including preparation of an expert report on liability and damage issues, preparation of expert witnesses for deposition, and assistance in preparation for depositions of opposing expert and in‐house witnesses.

» Assisted in the valuation of the interests of several firms in various cogeneration projects for the purpose of combining these interests into a new entity or selling interests to third parties.

» Analyzed the financial feasibility and viability of a large number of cogeneration projects, assisted in the preparation of presentations and filings and presented testimony to the relevant public utility commission. Ms. Solomon also assisted in the development of a PC‐based financial model to analyze various cogeneration projects.

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Julie R. Solomon

» Participated in a study to analyze the financial effects of a variety of restructuring options for a utility, including transfer and/or sale of assets and subsequent sale‐leasebacks, and debt restructuring alternatives. In addition, she developed a PC‐based financial model with applications to utility restructuring plans.

» Provided litigation support in major utility rate proceedings, including assisting in the preparation of responses to interrogatories and data requests, preparation of company and outside expert witnesses for deposition and hearings, and assistance in the deposition and cross‐ examination of intervenor witnesses.

» Participated in proceedings involving regulation of an oil pipeline, which included evaluating the business risks faced by the company.

Business Valuation » Participated in a valuation study involving the fair market value of a privately held company for purposes of an IRS proceeding.

» Participated in a valuation study in a divorce proceeding, where the assets being valued included a privately held business.

» Participated in two strategic engagements that developed business plans and identified potential acquisition candidates for the client.

» Provided advice to a client concerning the benefits and potential risks of developing a partnership with a competitor.

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Julie R. Solomon

Testimony or Expert Report Experience (2013‐July 2016)

» Supplemental Affidavit on behalf of Dynegy Inc. et al., Docket Nos. EC16‐93 and ‐94, July 8, 2016. » Affidavit on behalf of Arlington Valley, LLC et al., Docket No. ER10‐2756 et al., market‐based rate triennial filing, June 30, 2016. » Affidavit on behalf of Sundevil Holdings et al., Docket No. ER16‐2107 et al., market‐based rate triennial filing, June 30, 2016. » Affidavit (with Matthew E. Arenchild) on behalf of BHE Northwest Companies, Docket No. ER10‐3246 et al., market‐based rate triennial filing, June 30, 2016. » Affidavit on behalf of BHE Renewables, LLC, Docket No. ER13‐520 et al., market‐based rate triennial filing, June 30, 2016. » Affidavit on behalf of Atlantic Renewable Projects II LLC et al., Docket No. ER10‐2822 et al., market‐based rate triennial filing, June 30, 2016. » Affidavit on behalf of the Calpine MBR Sellers, Docket No. ER10‐2042 et al., market‐based rate triennial filing, June 30, 2016. » Affidavit on behalf of the NorthWestern Corporation, Docket No. ER11‐1858, market‐based rate triennial filing, June 29, 2016. » Affidavit on behalf of the ArcLight Energy Marketing et al., LLC, Docket No. ER16‐2014 et al., market‐based rate triennial filing, June 24, 2016. » Affidavit on behalf of River Bend Solar, LLC Docket No. ER16‐1913, application for market‐based rates, June 10, 2016. » Affidavit (with Matthew E. Arenchild) on behalf of Nevada Power Company et al., Docket No. EC16‐130, application for authorization of disposition of jurisdictional facilities, June 7, 2016. » Affidavit on behalf of Apple Energy, LLC, Docket No. ER16‐1887, application for market‐based rates, June 6, 2016. » Affidavit on behalf of Marshall Solar, LLC, Docket No. ER16‐1872, application for market‐based rates, June 3, 2016. » Affidavit on behalf of the Dominion Companies, Docket No. ER13‐2109 et al., notice of change in status filing, May 25, 2016. » Affidavit on behalf of Eastern Shore Solar LLC, Docket No. ER16‐1750, application for market‐ based rates, May 20, 2016. » Affidavit on behalf of Roswell Solar LLC and Chaves County Solar, LLC, Docket No. ER16‐1440 and ER16‐1672, applications for market‐based rates, May 20, 2016 and May 17, 2016. » Affidavit on behalf of Exelon MBR Entities, Docket No. ER10‐2997 et al., notice of change in status filing, April 22, 2016.

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Julie R. Solomon

» Affidavit on behalf of Live Oak Solar LLC, White Oak Solar, LLC, and White Pine Solar, LLC, Docket No. ER16‐1354, ER16‐1293 and ER16‐1277, applications for market‐based rates, April 6, 2016, March 30, 2016 and March 25, 2016. » Affidavit on behalf of Atlas Power Finance, LLC, Dynegy Inc., Energy Capital Partners III, LLC, and GDF SUEZ Energy North America, Inc., Docket No. EC16‐93, application for authorization of disposition of jurisdictional facilities, March 25, 2016. » Affidavit on behalf of Dynegy Inc. and Energy Capital Partners III, LLC, Docket No. EC16‐94, application for authorization of disposition of jurisdictional facilities, March 25, 2016. » Affidavit on behalf of Grande Prairie Wind, LLC, Docket No. ER16‐1258, application for market‐ based rates, March 22, 2016. » Affidavit on behalf of Florida Power & Light Company, Docket No. ER16‐628‐001, application for market‐based rates, March 21, 2016. » Affidavit on behalf of Essential Power, LLC, Docket No. EC16‐82, application for authorization of disposition of jurisdictional facilities, February 29, 2016. » Affidavit on behalf of Duke Energy Florida, LLC, Docket No. EC16‐69, application for authorization of disposition of jurisdictional facilities, February 10, 2016. » Affidavit on behalf of Nassau Energy, LLC, Docket No. ER16‐806, application for market‐based rates, January 21, 2016. » Affidavit on behalf of ECP MBR Sellers, Docket No. ER16‐72, market‐based rate triennial filing, December 31, 2015. » Affidavit on behalf of SDG&E Sellers, Docket No. ER14‐474, market‐based rate triennial filing, December 30, 2015. » Affidavit on behalf of New Harquahala Generating Company, Docket No. ER15‐2013, market‐ based rate triennial filing, December 30, 2015. » Affidavit on behalf of Exelon SPP Entities, Docket No. ER14‐474, market‐based rate triennial filing, December 29, 2015. » Affidavit on behalf of Florida Power & Light Company, Docket No. ER16‐628‐000, application for market‐based rates, December 23, 2015. » Affidavit on behalf of ENGIE Portfolio Management, LLC et al, Docket No. ER16‐581 et al., application for market‐based rates, December 18, 2015. » Affidavit on behalf of Marshall Wind Energy, LLC, Docket No. ER16‐438, market‐based rate triennial filing, December 18, 2015. » Affidavit on behalf of Marshall Wind Energy, LLC, Docket No. ER16‐438, application for market‐ based rates, December 1, 2015. » Affidavit on behalf of Calpine Granite Holdings, LLC, Docket No. EC16‐19, application for authorization of disposition of jurisdictional facilities, October 27, 2015.

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Julie R. Solomon

» Affidavit on behalf of Berkshire Hathaway, Inc., Docket No. EC16‐10, application for authorization of disposition of jurisdictional facilities, October 8, 2015. » Affidavit on behalf of Panda Patriot, LLC, Docket No. ER15‐2472, application for market‐based rates, September 29, 2015. » Affidavit on behalf of Talen Energy Corporation, Docket No. EC14‐112, Motion to Amend Mitigation Plan, September 25, 2015. » Affidavit on behalf of BHE MBR Sellers, Docket No. ER12‐162, notification of change in status, September 25, 2015. » Affidavit on behalf of Talen Energy Corporation, Docket No. EC14‐112, Motion to Amend Mitigation Plan, September 8, 2015. » Affidavit on behalf of BHE MBR Sellers, Docket No. ER13‐521, response to Commission Staff Deficiency Letter and Request for Additional Information, September 24, 2015. » Affidavit on behalf of BHE MBR Sellers, Docket No. ER13‐521, supplemental filing, September 8, 2015. » Affidavit on behalf of GDF SUEZ MBR Sellers, Docket No. ER14‐1699, notice of change, August 31, 2015. » Affidavits on behalf of PacifiCorp and NV Energy, Docket No. ER15‐2283, EIM analysis, July 27, 2015. » Affidavit on behalf of NorthWestern Corporation and Beethoven Wind, LLC, Docket No. EC15‐ 176, application for authorization of disposition of jurisdictional facilities, July 24 2015. » Affidavit on behalf of MidAmerican Energy Services, LLC, Docket No. ER15‐2211, application for market‐based rates, July 24, 2015. » Affidavit on behalf of The Empire District Electric Company, Docket No. ER10‐2738, market‐ based rate triennial filing, June 30, 2015. » Affidavit on behalf of Exelon MBR Sellers, Docket No. ER10‐2172 et al., market‐based rate triennial filing, June 30, 2015. » Affidavit on behalf of Oklahoma Gas & Electric, Docket No. ER11‐2105, market‐based rate triennial filing, June 30, 2015. » Affidavit on behalf of LG&E Energy Marketing, Inc., Docket No. ER10‐1714, market‐based rate triennial filing, June 30, 2015. » Affidavit on behalf of Westar Energy, Inc., Docket No. ER10‐2507, market‐based rate triennial filing, June 29, 2015. » Affidavit on behalf of the Alabama Power Company, et al., Docket No. EL15‐39, et al., response to show cause order, June 26, 2015. » Affidavit on behalf of Wisconsin Electric Power Company, Docket No. ER15‐2019 market‐based rate triennial filing, June 26, 2015.

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Julie R. Solomon

» Affidavit on behalf of Panda Liberty LLC, Docket No. ER15‐1841, market‐based rate application, June 2, 2015. » Affidavit on behalf of CCI U.S. Asset Holdings LLC, Docket No. EC15‐108, application for authorization of disposition of jurisdictional facilities, March 31, 2015. » Affidavit on behalf of Florida Power & Light Company, Docket No. EC15‐102, application for authorization of disposition of jurisdictional facilities, March 23, 2015. » Affidavit on behalf of Osprey Energy Center, LLC, Docket No. EC15‐96, application for authorization of disposition of jurisdictional facilities, March 13, 2015. » Affidavit on behalf of the Berkshire Hathaway Energy MBR Sellers, Docket No. EL15‐22, et al., response to show cause order, February 9, 2015. » Affidavit on behalf of ECP MBR Sellers, Docket No. ER13‐2477, notice of change in status, January 20, 2015. » Affidavit on behalf of NorthWestern Corporation, Docket No. ER11‐1859, market‐based rate triennial filing, December 30, 2014. » Affidavit on behalf of Exelon, Docket No. ER12‐2178, market‐based rate triennial filing, December 23, 2014. » Affidavit on behalf of Dynegy Inc., Docket No. ER14‐1569, market‐based rate triennial filing, December 23, 2014. » Affidavit on behalf of Northern Indiana Public Service, Docket No. ER10‐1781, market‐based rate triennial filing, December 23, 2014. » Affidavit on behalf of AES Corp, Docket No. ER10‐3415, market‐based rate triennial filing, December 22, 2014. » Affidavit on behalf of Ameren Illinois Company, Union Electric Company, and AmerenEnergy Medina Valley Cogen, L.L.C. Docket No. ER10‐1119, ER10‐1123, and ER10‐1103, market‐based rate triennial filing, December 19, 2014. » Affidavit on behalf of Duke Energy MBR Sellers, Docket No. ER10‐1325, market‐based rate triennial filing, December 19, 2014. » Affidavit on behalf of Duke Energy Progress, Inc., Docket No. EC15‐9, application for authorization of disposition of jurisdictional facilities, October 10, 2014. » Comments of Julie R. Solomon and Matthew E. Arenchild regarding NOPR on market‐based rate authority, Docket No. RM14‐14, September 23, 2014. » Affidavit on behalf of Dynegy Resource I, LLC, Docket No. EC14‐141, application for authorization of disposition of jurisdictional facilities, September 11, 2014. » Affidavit on behalf of Dynegy Inc., Docket No. EC14‐140, application for authorization of disposition of jurisdictional facilities, September 11, 2014. » Affidavit on behalf of Calpine Fore River Energy Center, LLC, Docket No. EC14‐135, application for authorization of disposition of jurisdictional facilities, September 5, 2014.

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» Affidavit on behalf of Seiling Wind, LLC; Seiling Wind II, LLC; Mammoth Plains Wind Project, LLC; and Palo Duro Wind Energy, LLC, Docket No. ER14‐2707‐10, market‐based rate applications, August 26, 2014. » Affidavit on behalf of ECP MBR Sellers, Docket No. ER10‐2302, notification of change in status, August 18, 2014. » Affidavit on behalf of Millennium Power Partners, L.P., Docket No. ER10‐3286, notification of change in status, August 4, 2014. » Affidavit on behalf of Granite Acquisition, Inc., Docket No. EC14‐125, application for authorization of disposition of jurisdictional facilities, August 15, 2014. » Testimony (Direct and Rebuttal), on behalf of Duke Energy Florida, Inc., Docket No. 140111‐EI before the Florida Public Service Commission, Petition for Determination of Cost Effective Generation Alternative to Meet Need Prior to 2018, May 27, 2014 and August 5, 2014. » Affidavit on behalf of LS Power Development, LLC, Docket No. ER13‐2318, notification of change in status, August 4, 2014. » Supplemental Affidavit on behalf of Powerex Corp., Docket No. ER11‐2664, market‐based rate triennial filing, July 25, 2014. » Supplemental Affidavit on behalf of Berkshire Hathaway Energy, Docket No. ER13‐1266, notification of change in status, August 17, 2014. » Affidavit on behalf of RJS Power Holdings LLC and PPL Corporation, Docket No. EC14‐112, application for authorization of disposition of jurisdictional facilities, July 15, 2014. » Affidavit on behalf of South Carolina Electric & Gas Company, Docket No. ER10‐2498, market‐ based rate triennial filing, July 14, 2014. » Affidavit on behalf of Consumers Energy Company, Docket No. EC14‐110, application for authorization of disposition of jurisdictional facilities, July 1, 2014. » Affidavit on behalf of J.P. Morgan Sellers, Docket No. ER10‐2331, market‐based rate triennial filing, June 30, 2014. » Affidavit on behalf of Duke Energy MBR Sellers, Docket No. ER10‐1325, market‐based rate triennial filing, June 30, 2014. » Affidavit on behalf of PPL Southeast Companies, Docket No. ER10‐1511, market‐based rate triennial filing, June 30, 2014. » Affidavit on behalf of NextEra Companies, Docket No. ER10‐1852, market‐based rate triennial filing, June 30, 2014. » Affidavit on behalf of NextEra Companies, Docket No. ER10‐1838, market‐based rate triennial filing, June 30, 2014. » Affidavit on behalf of Brookfield Companies, Docket No. ER11‐2292, market‐based rate triennial filing, June 30, 2014.

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Julie R. Solomon

» Affidavit on behalf of Calpine Corp, Docket No. ER10‐1944, market‐based rate triennial filing, June 30, 2014. » Affidavit on behalf of LS Northeast MBR Sellers, Docket No. ER13‐2318, market‐based rate triennial filing, June 30, 2014. » Affidavit on behalf of GDF SUEZ Northeast MBR Sellers, Docket No. ER10‐2670, market‐based rate triennial filing, June 30, 2014. » Affidavit on behalf of Safe Harbor Water Power Corp., Docket No. ER13‐395, market‐based rate triennial filing, June 27, 2014. » Affidavit on behalf of ECP MBR Sellers, Docket No. ER13‐2477, market‐based rate triennial filing, June 23, 2014. » Affidavit on behalf of Rockland Sellers, Docket No. ER12‐1436, market‐based rate triennial filing and notification of change in status, June 19, 2014. » Affidavit on behalf of Exelon Corp and Pepco Holdings, Inc., Docket No. EC14‐96, application for authorization of disposition of jurisdictional facilities, May 30, 2014. » Affidavit on behalf of Nevada Power Co and Nevada Sun‐Peak Limited Partnership, Docket No. EC14‐83, application for authorization of disposition of jurisdictional facilities, May 2, 2014. » Affidavit on behalf of Nevada Power Co and Las Vegas Cogeneration Limited Partnership, Docket No. EC14‐84, application for authorization of disposition of jurisdictional facilities, May 2, 2014. » Affidavit on behalf of NatGen Southeast Power LLC, Docket No. EC14‐81, application for authorization of disposition of jurisdictional facilities, April 28, 2014. » Surrebuttal Testimony on Behalf of Commonwealth Edison Company, Illinois Commerce Commission, Application for a Certificate of Public Convenience and Necessity, No. 13‐0657, April 9, 2014. » Affidavit on behalf of KMC Thermo, LLC, Docket No. ER14‐1468, market‐based rate application, March 12, 2014. » Affidavit on behalf of Trailstone Power, LLC, Docket No. ER14‐1439, market‐based rate application, March 6, 2014. » Affidavit on behalf of MACH Gen, LLC et al., Docket No. EC14‐61, application for authorization of disposition of jurisdictional facilities, March 4, 2014. » Affidavit on behalf of MidAmerican Geothermal, LLC, et al., Docket No. EC14‐59, application for authorization of disposition of jurisdictional facilities, February 20, 2014. » Affidavit on behalf of Green Mountain Power Corporation, Docket No. ER11‐1933, market‐based rate triennial filing, February 7, 2014. » Affidavit on behalf of NorthWestern Corporation, et al., Docket No. EC14‐41, application for authorization of disposition of jurisdictional facilities, January 10, 2014.

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Julie R. Solomon

» Affidavit on behalf of NorthWestern Corporation, Docket No. ER11‐1858, notification of change in status, January 10, 2014. » Affidavit on behalf of MidAmerican Energy, Docket No. ER10‐2475, notification of change in status, January 2, 2014. » Affidavit on behalf of Powerex Corp., Docket No. ER11‐2664, market‐based rate triennial filing, December 31, 2013. » Affidavit on behalf of TransAlta, Docket No. ER10‐2847, market‐based rate triennial filing, December 31, 2013. » Affidavit on behalf of Duquesne Light Company, Docket No. ER10‐1910, market‐based rate triennial filing, December 31, 2013. » Affidavit on behalf of Constellation Energy Nuclear Group, Docket No. ER10‐2179, market‐based rate triennial filing, December 30, 2013. » Affidavit on behalf of Exelon, Docket No. ER12‐2178, market‐based rate triennial filing, December 30, 2013. » Affidavit on behalf of Dominion, Docket No. ER13‐434, market‐based rate triennial filing, December 30, 2013. » Affidavit on behalf of Brookfield Companies, Docket No. ER10‐2895, market‐based rate triennial filing, December 30, 2013. » Affidavit on behalf of Oklahoma Gas & Electric, Docket No. ER14‐882, notification of change in status/tariff filing, December 30, 2013. » Affidavit on behalf of AES Corp, Docket No. ER10‐3415, market‐based rate triennial filing, December 26, 2013. » Affidavit on behalf of JPMorgan, Docket No. ER10‐2331, market‐based rate triennial filing, December 23, 2013. » Affidavit on behalf of Northeast Utilities, Docket No. ER10‐1801, market‐based rate triennial filing, December 20, 2013. » Affidavit on behalf of Iberdrola, Docket No. ER10‐2822, market‐based rate triennial filing, December 20, 2013. » Affidavit on behalf of PHI, Docket No. ER10‐2997, market‐based rate triennial filing, December 20, 2013. » Affidavit on behalf of Essential Power, Docket No. ER12‐952, market‐based rate triennial filing, December 20, 2013. » Affidavit on behalf of Empire District, Docket No. ER14‐793, notification of change in status/tariff filing, December 20, 2013. » Affidavit on behalf of Westar Energy, Inc., Docket No. ER14‐724, notification of change in status/tariff filing, December 19, 2013.

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Julie R. Solomon

» Affidavit on behalf of Alpha Gen Power, LLC, Docket No. ER14‐630, market‐based rate application, December 16, 2013. » Affidavit on behalf of Black Bear Hydro Partners, LLC, Docket No. EC14‐28, application for authorization of disposition of jurisdictional facilities, November 14, 2013. » Affidavit on behalf of Sierra Pacific Power Company, Docket No. ER10‐2474, notification of change in status, November 4, 2013. » Affidavit on behalf of ECP, Docket No. ER11‐3859, notification of change in status, September 30, 2013. » Affidavit on behalf of Steele Flats Wind Project, LLC, Docket No. ER13‐2474, market‐based rate application, September 27, 2013. » Affidavit on behalf of Tuscola Wind II, LLC, Docket No. ER13‐2458, market‐based rate application, September 26, 2013. » Affidavit on behalf of Pheasant Run Wind, LLC and Pheasant Run Wind II, LLC, Docket Nos. ER13‐2461‐2, market‐based rate applications, September 26, 2013. » Affidavit on behalf of TPF II and USPG Holdings, LLC, Docket No. EC13‐154, application for authorization of disposition of jurisdictional facilities, September 25, 2013. » Affidavit on behalf of Seneca Generation, LLC et al., Docket Nos. ER13‐2316‐9, market‐based rate applications, September 4, 2013. » Affidavit on behalf of Seneca Generation, LLC et al., Docket No. EC13‐143, application for authorization of disposition of jurisdictional facilities, September 4, 2013. » Supplemental Affidavit on behalf of MidAmerican Energy (Silver Merger Sub, Inc.), Docket No. EC13‐128, application for authorization of disposition of jurisdictional facilities, August 17, 2013. » Affidavit on behalf of Desert Sunlight 250, LLC and Desert Sunlight 300, LLC, Docket Nos. ER13‐ 1991‐2, market‐based rate applications, July 17, 2013. » Affidavit on behalf of MidAmerican Energy (Silver Merger Sub, Inc.), Docket No. EC13‐128, application for authorization of disposition of jurisdictional facilities, July 12, 2013. » Affidavit on behalf of Calpine Southwest MBR Sellers, Docket No. ER10‐1942, market‐based rate triennial filing, July 1, 2013. » Affidavit on behalf of NextEra Companies, Docket No. ER10‐1847, market‐based rate triennial filing, July 1, 2013. » Affidavit on behalf of Wayzata Entities, Docket No. ER10‐1777, market‐based rate triennial filing, July 1, 2013. » Affidavit on behalf of AES MBR Affiliates, Docket No. ER10‐3415, market‐based rate triennial filing, July 1, 2013. » Affidavit on behalf of Sierra Pacific Power Company, et al. under ER10‐2474, Docket No. ER10‐ 24744, market‐based rate triennial filing, July 1, 2013.

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» Affidavit on behalf of NorthWestern Corporation, Docket No. ER11‐1858, market‐based rate triennial filing, July 1, 2013. » Affidavit on behalf of SGOC Southwest MBR Sellers, Docket No. ER10‐2864, market‐based rate triennial filing, June 28, 2013. » Affidavit on behalf of GWF Energy LLC, et al. Docket No. ER10‐3301, market‐based rate triennial filing, June 28, 2013. » Affidavit on behalf of NV Energy, Inc., application for approval of internal reorganization, Docket No. EC13‐113, May 31, 2013. » Affidavit on behalf of Midwest Generation, LLC, Docket No. EC13‐103, application for authorization of disposition of jurisdictional facilities, May 6, 2013. » Affidavit of behalf of Nevada Power Company (with Matthew E. Arenchild), Docket No. EC13‐ 96, application for authorization of disposition of jurisdictional facilities, April 17, 2013. » Affidavit of behalf of Dynegy Inc., Docket No. EC13‐93, application for authorization of disposition of jurisdictional facilities, April 16, 2013. » Application on behalf of Florida Power & Light Company, Docket No. EC13‐91, application for authorization of disposition of jurisdictional facilities, April 12, 2013. » Affidavit on behalf of Blythe Energy LLC, et al., Docket No. EC13‐89, application for authorization of disposition of jurisdictional facilities, April 2, 2013. » Affidavit on behalf of New Harquahala Generating Company, LLC, Docket No. ER10‐3310, market‐based rate triennial filing, March 29, 2013. » Affidavit on behalf of Dominion Energy Brayton Point, et al., Docket No. EC13‐82, application for authorization of disposition of jurisdictional facilities, March 21, 2013. » Affidavit on behalf of Duke Energy Carolinas, LLC et al., Docket No. ER10‐2566, et al., notice of change in status, January 29, 2013. » Affidavit on behalf of CCI Roseton LLC, Docket No. ER13‐773, market‐based rate application, January 17, 2013. » Affidavit on behalf of CCI Roseton LLC, Docket No. EC13‐63, application for authorization of disposition of jurisdictional facilities, January 16, 2013.

Page 12 Exhibit JRS-2

20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM Generation Affiliated with Exelon West Medway II, LLC in ISO-NE and First-Tier Markets

Balancing Ownership Interest Authority Capacity (MW) Ownership (MW) Area Plant Name Summer Winter Share Summer Winter

ISO-NE 1/ ISO-NE West Medway 4-5 194.8 207.0 100.00% 194.8 207.0 ISO-NE Wyman (Yarmouth) 4 602.1 605.8 5.90% 35.5 35.7 ISO-NE Framingham Jet 31.4 43.4 100.00% 31.4 43.4 ISO-NE West Medway 1-2 81.8 124.5 100.00% 81.8 124.5 ISO-NE West Medway 3 42.0 62.4 100.00% 42.0 62.4 ISO-NE New Boston (L Street Jet) 16.0 21.8 100.00% 16.0 21.8 ISO-NE Mystic 7 570.8 559.8 100.00% 570.8 559.8 ISO-NE Mystic 8 703.4 841.6 100.00% 703.4 841.6 ISO-NE Mystic 9 713.9 858.5 100.00% 713.9 858.5 ISO-NE Mystic Jet 9.1 14.5 100.00% 9.1 14.5 ISO-NE Kleen Energy (purchase) 620.0 620.0 ISO-NE Ameresco Northampton (purchase) 0.8 0.8 Subtotal, ISO-NE 2,965.3 3,339.3 3,019.5 3,389.9

First-Tier Markets NYISO 1/ NYISO Nine Mile Point 2/ 1,692.3 1,703.8 50.01% 1,692.3 1,703.8 NYISO Ginna 582.0 583.0 50.01% 582.0 583.0 NYISO Sale to EDF 3/ (846.0) (851.7) NYISO Purchase (WM Renewable Energy, LLC) 28.8 28.8 Subtotal, NYISO 2,274.3 2,286.8 1,457.1 1,463.9

1/ Plant ratings based on 2015 (early release) EIA-860 data https://www.eia.gov/electricity/data/eia860/ 2/ Total capacity reflects 100% of unit 1 and 82% of unit 2. The remaining 18% of unit 2 is owned by Long Island Power Authority. 3/ A subsidiary of Electricite de France SA (“EDF”), which owns the other 49.99% of Constellation Energy Nuclear Group, Inc. ("CENG") (owner of the nuclear plants), purchases on a unit-contingent basis 49.99 percent of the nuclear plant output owned by CENG not sold to third parties. The sale represents 49.99% of CENG's share of Nine Mile Point. Exhibit JRS-3

Part I – Pivotal Supplier Analysis 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM Applicant-> Exelon West Medway II, LLC Market -> ISO-NE Data Year -> Dec 2014-Nov 2015 Row Generation Reference Seller and Affiliate Capacity (owned or controlled) A Installed Capacity (from inside the study area) 2,399 Exhibit JRS-2 A1 Remote Capacity (from outside the study area) 0 B Long-Term Firm Purchases (from inside the study area) 621 Exhibit JRS-2 B1 Long-Term Firm Purchases (from outside the study area) 0 C Long-Term Firm Sales (in and outside the study area) 0 D Uncommitted Capacity Imports 614 Wkp - Import Allocation

Non-Affiliate Capacity (owned or controlled) E Installed Capacity (from inside the study area) 28,290 Wkp- ISO-NE CELT Report less Row A (pluss West Medway) E1 Remote Capacity (from outside the study area) 0 F Long-Term Firm Purchases (from inside the study area) 0 F1 Long-Term Firm Purchases (from outside the study area) 0 G Long-Term Firm Sales (in and outside the study area) 621 Offset Row B

H Uncommitted Capacity Imports 3,934 147 FERC ¶ 61,190 (2014) less Row D above

ISO-NE Annual Markets Report, http://www.iso-ne.com/static- assets/documents/2016/05/2015_imm_amr_final_5_25_20 I Study Area Reserve Requirement 2,500 16.pdf J Amount of Line I Attributable to Seller, if any 0

K Total Uncommitted Supply (A+A1+B+B1+D+E+E1+F+F1+H-C-G-I-M) 13,116

Load L Balancing Authority Area Annual Peak Load 24,437 Wkp-ISO-NE Load M Average Daily Peak Native Load in Peak Month 19,621 Wkp-ISO-NE Load N Amount of Line M Attributable to Seller, if any 4,000 Wkp - Exelon ISONE Load Data

O Wholesale Load (L-M) 4,816

P Net Uncommitted Supply (K-O) 8,300

Q Seller's Uncommitted Capacity (A+A1+B+B1+D-C-J-N) 0

Result of Pivotal Supplier Screen (Pass if Line Q < Line P) Pass (Fail if Line Q > Line P)

Total Imports (Sum D,H), as filed by Seller -> 4,548 % of SIL for Seller's imported capacity -> 0.13 % of SIL for Other's imported capacity -> 0.87

SIL value -> 4,548 147 FERC ¶ 61,190 (2014) Do Total Imports exceed the SIL value? -> No 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM Exhibit JRS-4 Part II – Market Share Analysis

Applicant-> Exelon West Medway II, LLC Study Area -> ISO-NE Data Year -> Dec 2014-Nov 2015 As filed by the Applicant/Seller Row Winter Spring Summer Fall Reference (MW) (MW) (MW) (MW) Seller and Affiliate Capacity (owned, controlled or under LT contract) A Installed Capacity (inside the study area) 2,769 2,769 2,399 2,769 Exhibit JRS-2 A1 Remote Capacity (from outside the study area) 0 0 0 0 B Long-Term Firm Purchases (inside the study area) 621 621 621 621 Exhibit JRS-2 B1 Long-Term Firm Purchases (from outside the study area) 0 0 0 0 C Long-Term Firm Sales (in and outside the study area) 0 0 0 0 D Seasonal Average Planned Outages 0 0 0 0 E Uncommitted Capacity Imports 512 510 594 501 Wkp - Import Allocation

Capacity Deductions F Average Peak Native Load in the Season 18,391 15,604 18,719 16,307 Wkp-ISO-NE Load G Amount of Line F Attributable to Seller, if any 3,627 3,224 4,080 3,720 Wkp - Exelon ISONE Load Data H Amount of Line F Attributable to Non-Affiliates, if any 14,764 12,380 14,639 12,587

ISO-NE Annual Markets Report, http://www.iso-ne.com/static- I Study Area Reserve Requirement 2,500 2,500 2,500 2,500 assets/documents/2016/05/2015_imm_amr_final_5_25_2016.pdf J Amount of Line I Attributable to Seller, if any 0 0 0 0 K Amount of Line I Attributable to Non-Affiliates, if any 2,500 2,500 2,500 2,500

Non-Affiliate Capacity (owned, controlled or under LT contract) L Installed Capacity (inside the study area) 30,085 30,085 30,443 30,085 Wkp- ISO-NE CELT Report less Row A (plus West Medway) L1 Remote Capacity (from outside the study area) 0 0 0 0 M Long-Term Firm Purchases (inside the study area) 0 0 0 0 M1 Long-Term Firm Purchases (from outside the study area) 0 0 0 0 N Long-Term Firm Sales (in and outside the study area) 621 621 621 621 Offset Row B O Seasonal Average Planned Outages 1,127 3,234 236 2,960 Wkp-ISO-NE Outages

P Uncommitted Capacity Imports 4,036 4,038 3,954 4,047 147 FERC ¶ 61,190 (2014) less Row D above

Supply Calculation Q Total Competing Supply (L+L1+M+M1+P-H-K-N-O) 15,109 15,389 16,402 15,464 R Seller's Uncommitted Capacity (A+A1+B+B1+E-C-D-G-J) 275 675 0 171 S Total Seasonal Uncommitted Capacity (Q+R) 15,384 16,063 16,402 15,635

T Seller's Market Share (R÷S) 1.8% 4.2% 0.0% 1.1% Results (Pass if < 20% and Fail if ≥ 20%) Pass Pass Pass Pass

U Total Imports, as filed by Seller (E+P) 4,548 4,548 4,548 4,548 V SIL value* 4,548 4,548 4,548 4,548 147 FERC ¶ 61,190 (2014)

Do Total Imports exceed SIL value? (is U<=V) No No No No 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM

UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION

Exelon West Medway II, LLC ) Docket No. ER16-_ -000

AFFIDAVIT § District of Columbia § §

JULIE R. SOLOMON being duly sworn, deposes and states: that she prepared the Affidavit and Exhibits of Julie R. Solomon and that the statements contained therein and the Exhibits attached hereto are true and correct to the best of her knowledge and belief. w.: 'Q&~ JUlie R. Solomon

SUBSCRffiED AND SWORN TO BEFORE ME, this the3o day of September 2016.

Notary~~ Pubhc, 1stnct of Columbia

My Commission Expires: 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM

FERC rendition of the electronically filed tariff records in Docket No. ER16-02708-000 Filing Data: CID: C005271 Filing Title: Initial MBR Tariff Filing Company Filing Identifier: 9301602 Type of Filing Code: 390 Associated Filing Identifier: Tariff Title: FERC Market Based Rates Tariff Tariff ID: 10 Payment Confirmation: Suspension Motion:

Tariff Record Data: Record Content Description, Tariff Record Title, Record Version Number, Option Code: 1., FERC Market Based Rate Tariff, 0.0.0, A Record Narative Name: 1. FERC Market Based Rate Tariff Tariff Record ID: 1 Tariff Record Collation Value: 100 Tariff Record Parent Identifier: 0 Proposed Date: 2016-10-01 Priority Order: 100 Record Change Type: New Record Content Type: 1 Associated Filing Identifier: Market-Based Rate Tariff

I. Availability

Seller makes electric energy, capacity, and ancillary services available under this tariff to any purchaser with whom Seller has contracted, except as prohibited below.

II. Rates

All sales shall be made at rates established by agreement between the purchaser and Seller.

III. Other Terms and Conditions

All other terms and conditions of sales shall be established by agreement between the purchaser and Seller.

IV. Compliance with Commission Regulations

V. Seller Category 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM

Seller is a Category 2 Seller in the Northeast region and a Category 1 Seller in all other regions, as defined in 18 CFR § 35.36(a).

VI. Limitations and Exemptions Regarding Market-Based Rate Authority

In Exelon West Medway II, LLC, Docket No. ER16-___-000 (2016):

Seller has received (1) waiver of Subparts B and C of Part 35, except for sections 35.12(a), 35.13(b), 35.15 and 35.16; (2) waiver of Parts 41, 101 and 141 except sections 141.14 and 141.15, and with the exception that waiver of the provisions of Part 101 that apply to hydropower licenses is not granted with respect to licensed hydropower projects; and (3) blanket authorization for all future issuances of securities or assumptions of liabilities pursuant to Part 34 of the Commission’s regulations.

VII. Ancillary Services

(A) PJM: Seller offers regulation and frequency response service, energy imbalance service, and operating reserve service (which includes spinning, 10-minute, and 30-minute reserves) for sale into the market administered by PJM Interconnection, L.L.C. (“PJM”) and, where the PJM Open Access Transmission Tariff permits, the self-supply of these services to purchasers for a bilateral sale that is used to satisfy the ancillary services requirements of the PJM Office of Interconnection.

(C) New England: Seller offers regulation and frequency response service (automatic generator control), operating reserve service (which includes 10-minute spinning reserve, 10-minute non-spinning reserve, and 30-minute operating reserve service) to purchasers within the markets administered by the ISO New England, Inc.

(E) MISO: Seller offers regulation service and operating reserve service (which 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM

include 10-minute spinning reserve and 10-minute supplemental reserve) for sale to the Midcontinent Independent System Operator, Inc. (MISO) and to others that are self-supplying ancillary services to MISO.

(G) Ancillary Services - Third Party Provider: Third-party ancillary services: Seller offers Regulation Service, Reactive Supply and Voltage Control Service, Energy and Generator Imbalance Service, Operating Reserve-Spinning, Operating Reserve-Supplemental, and Primary Frequency Response Service. Sales will not include the following: (1) sales to an RTO or an ISO, i.e., where that entity has no ability to self-supply ancillary services but instead depends on third parties; and (2) sales to a traditional, franchised public utility affiliated with the third-party supplier, or sales where the underlying transmission service is on the system of the public utility affiliated with the third-party supplier. Sales of Operating Reserve-Spinning and Operating Reserve-Supplemental will not include sales to a public utility that is purchasing ancillary services to satisfy its own open access transmission tariff requirements to offer ancillary services to its own customers, except where the Commission has granted authorization. Sales of Regulation Service and Reactive Supply and Voltage Control Service will not include sales to a public utility that is purchasing ancillary services to satisfy its own open access transmission tariff requirements to offer ancillary services to its own customers, except at rates not to exceed the buying public utility transmission provider’s OATT rate for the same service or where the Commission has granted authorization.

VIII. Effective Date

This Rate Schedule shall be effective as of the date specified by the Federal Energy Regulatory Commission. 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM

Asset Appendix: Generation Assets - September 2016 [A] [B] [C] [D] [E] [F] [G] [H] [I] [J] [K] [L] [M] Location

Capacity Raiting: Docket # Market / Capacity Capacity Methodology End Note Filing Entity and its Energy where MBR Generation Name Date Control Balancing Geographic In-Service Rating: Rating: Used in [K]: Number Owned by Controlled by Affiliates authority was (Plant or Unit Name) Transferred Authority Region Date Nameplate Used in Filing (N)ameplate, (S)easonal, (Enter text in granted Area (MW) (MW) 5-yr (U)nit, 5-yr (E)IA, End Note Tab) (A)lternative

Beebe 1B Renewable Energy, LLC ER14-2144 Beebe 1b WF Beebe 1B Renewable Energy, LLC Beebe 1B Renewable Energy, LLC N/A MISO Central 12/12/2014 50.40 50.40 S

Beebe Renewable Energy, LLC ER12-2311 Beebe 1a WF Beebe Renewable Energy, LLC Beebe Renewable Energy, LLC N/A MISO Central 1/17/2013 81.60 81.60 S

Exelon Generation Company, LLC ER00-3251 Clinton Exelon Generation Company, LLC Exelon Generation Company, LLC N/A MISO Central 11/1/1987 1138.30 1065.00 S ER12-2201 Harvest II Windfarm, LLC Harvest 2 WF Harvest II Windfarm, LLC Harvest II Windfarm, LLC N/A MISO Central 11/28/2012 59.40 59.40 S QF12-522 ER07-1246 Harvest Windfarm, LLC Harvest 1 WF Harvest Windfarm, LLC Harvest Windfarm, LLC N/A MISO Central 2/28/2008 52.80 52.80 S QF07-29 ER05-1511 Michigan Wind 1, LLC Michigan Wind 1 WF Michigan Wind 1, LLC Michigan Wind 1, LLC N/A MISO Central 12/16/2008 69.00 69.00 S QF05-228 Michigan Wind 2, LLC ER11-3989 Michigan Wind 2 WF Michigan Wind 2, LLC Michigan Wind 2, LLC N/A MISO Central 1/5/2012 90.00 90.00 S

Atlantic City Electric Company ER96-1361 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

Baltimore Gas and Electric Company ER99-2948 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

Commonwealth Edison Company ER98-1734 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A Constellation Energy Commodities ER02-699 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A Group Maine, LLC Constellation Energy Services of ER07-651 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A New York, Inc. Constellation Energy Services, Inc. ER07-650 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

Constellation NewEnergy, Inc. ER96-1387 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

Delmarva Power & Light Company ER96-2571 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

PECO Energy Company ER01-1147 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

Pepco Energy Services, Inc. ER98-3096 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

Potomac Electric Power Company ER98-4138 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

Constellation Mystic Power, LLC ER10-2281 Mystic 7 Constellation Mystic Power, LLC Constellation Mystic Power, LLC N/A ISO-NE Northeast 6/1/1975 617.00 575.48 S

Constellation Mystic Power, LLC ER10-2281 Mystic 8 GT1 Constellation Mystic Power, LLC Constellation Mystic Power, LLC N/A ISO-NE Northeast 4/14/2003 278.60 228.77 S

Constellation Mystic Power, LLC ER10-2281 Mystic 8 GT2 Constellation Mystic Power, LLC Constellation Mystic Power, LLC N/A ISO-NE Northeast 4/14/2003 278.60 229.97 S

Constellation Mystic Power, LLC ER10-2281 Mystic 8 STG1 Constellation Mystic Power, LLC Constellation Mystic Power, LLC N/A ISO-NE Northeast 4/14/2003 315.00 244.58 S

Constellation Mystic Power, LLC ER10-2281 Mystic 9 GT1 Constellation Mystic Power, LLC Constellation Mystic Power, LLC N/A ISO-NE Northeast 6/10/2003 278.60 231.40 S

Constellation Mystic Power, LLC ER10-2281 Mystic 9 GT2 Constellation Mystic Power, LLC Constellation Mystic Power, LLC N/A ISO-NE Northeast 6/10/2003 278.60 232.50 S

Constellation Mystic Power, LLC ER10-2281 Mystic 9 STG1 Constellation Mystic Power, LLC Constellation Mystic Power, LLC N/A ISO-NE Northeast 6/10/2003 315.00 247.24 S

Constellation Mystic Power, LLC ER10-2281 Mystic Jet Constellation Mystic Power, LLC Constellation Mystic Power, LLC N/A ISO-NE Northeast 6/1/1969 14.20 8.28 S

Exelon Framingham LLC ER98-1943 Framingham Jet 1 Exelon Framingham LLC Exelon Framingham LLC N/A ISO-NE Northeast 3/1/1970 14.20 10.15 S

Exelon Framingham LLC ER98-1943 Framingham Jet 2 Exelon Framingham LLC Exelon Framingham LLC N/A ISO-NE Northeast 9/1/1969 14.20 10.05 S

Exelon Framingham LLC ER98-1943 Framingham Jet 3 Exelon Framingham LLC Exelon Framingham LLC N/A ISO-NE Northeast 9/1/1969 14.20 11.25 S

Exelon New Boston, LLC ER98-1943 New Boston Jet Exelon New Boston, LLC Exelon New Boston, LLC N/A ISO-NE Northeast 9/1/1966 18.60 16.00 S

Exelon West Medway, LLC ER98-1943 West Medway Jet 1 Exelon West Medway, LLC Exelon West Medway, LLC N/A ISO-NE Northeast 7/1/1970 45.00 42.00 S

Exelon West Medway, LLC ER98-1943 West Medway Jet 2 Exelon West Medway, LLC Exelon West Medway, LLC N/A ISO-NE Northeast 3/1/1971 45.00 39.80 S

Exelon West Medway, LLC ER98-1943 West Medway Jet 3 Exelon West Medway, LLC Exelon West Medway, LLC N/A ISO-NE Northeast 7/1/1970 45.00 42.00 S

Exelon Wyman, LLC ER98-1943 Wyman 4 Exelon Wyman, LLC (5.9%) FPL Energy Wyman IV LLC N/A ISO-NE Northeast 1/1/1978 632.40 602.00 S 1

West Medway II, LLC Pending West Medway 4 West Medway II, LLC West Medway II, LLC N/A ISO-NE Northeast 6/1/2018 100.00 97.40 S

West Medway II, LLC Pending West Medway 5 West Medway II, LLC West Medway II, LLC N/A ISO-NE Northeast 6/1/2018 100.00 97.40 S Nine Mile Point Nuclear Station, Nine Mile Point Nuclear Station, Nine Mile Point Nuclear Station, ER01-1654 Nine Mile Point 1 N/A NYISO Northeast 12/1/1969 641.80 626.10 S LLC LLC LLC Nine Mile Point Nuclear Station, Nine Mile Point Nuclear Station, Nine Mile Point Nuclear Station, ER01-1654 Nine Mile Point 2 N/A NYISO Northeast 8/1/1988 1428.45 1289.60 S 2 LLC LLC LLC R. E. Ginna Nuclear Power Plant, R. E. Ginna Nuclear Power Plant, R. E. Ginna Nuclear Power Plant, ER04-485 Ginna N/A NYISO Northeast 7/1/1970 614.00 582.00 S LLC LLC LLC Clinton Battery Utility, LLC ER16-2194 Clinton Battery Project Clinton Battery Utility, LLC Clinton Battery Utility, LLC N/A PJM Northeast 10/31/2016 10.00 10.00 N

Criterion Power Partners, LLC ER10-1443 Criterion WF Criterion Power Partners, LLC Criterion Power Partners, LLC N/A PJM Northeast 2/4/2011 70.00 70.00 S

Exelon Generation Company, LLC ER00-3251 Braidwood 1 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM Northeast 7/1/1988 1224.90 1183.00 S

Exelon Generation Company, LLC ER00-3251 Braidwood 2 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM Northeast 10/1/1988 1224.90 1154.00 S

Exelon Generation Company, LLC ER00-3251 Byron 1 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM Northeast 9/1/1985 1224.90 1164.00 S

Exelon Generation Company, LLC ER00-3251 Byron 2 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM Northeast 8/1/1987 1224.90 1136.00 S

Exelon Generation Company, LLC ER00-3251 Dresden 2 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM Northeast 8/1/1970 1009.00 902.00 S

Exelon Generation Company, LLC ER00-3251 Dresden 3 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM Northeast 10/1/1971 1009.00 895.00 S

Exelon Generation Company, LLC ER00-3251 LaSalle 1 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM Northeast 1/1/1984 1170.00 1130.00 S

Exelon Generation Company, LLC ER00-3251 LaSalle 2 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM Northeast 10/1/1984 1170.00 1133.90 S

Exelon Generation Company, LLC ER00-3251 Quad Cities 1 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM Northeast 12/1/1972 1009.30 908.00 S 3

Exelon Generation Company, LLC ER00-3251 Quad Cities 2 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM Northeast 12/1/1972 1009.30 911.00 S 4

Exelon Generation Company, LLC ER00-3251 SeChicagoUnit 10 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM Northeast 5/24/2002 50.90 37.00 S

Exelon Generation Company, LLC ER00-3251 SeChicagoUnit 11 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM Northeast 5/24/2002 50.90 37.00 S

Exelon Generation Company, LLC ER00-3251 SeChicagoUnit 12 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM Northeast 5/24/2002 50.90 37.00 S

Exelon Generation Company, LLC ER00-3251 SeChicagoUnit 5 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM Northeast 5/24/2002 50.90 37.00 S

Exelon Generation Company, LLC ER00-3251 SeChicagoUnit 6 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM Northeast 5/24/2002 50.90 37.00 S

Exelon Generation Company, LLC ER00-3251 SeChicagoUnit 7 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM Northeast 5/24/2002 50.90 37.00 S

Exelon Generation Company, LLC ER00-3251 SeChicagoUnit 8 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM Northeast 5/24/2002 50.90 37.00 S

Exelon Generation Company, LLC ER00-3251 SeChicagoUnit 9 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM Northeast 5/24/2002 50.90 37.00 S

Fair Wind Power Partners, LLC ER15-2293 Fair Wind WF Fair Wind Power Partners, LLC Fair Wind Power Partners, LLC N/A PJM Northeast 11/24/2015 30.00 30.00 S ER14-2145 Fourmile Wind Energy, LLC Fourmile Ridge WF Fourmile Wind Energy, LLC Fourmile Wind Energy, LLC N/A PJM Northeast 1/15/2015 40.00 40.00 S QF14-721 Handsome Lake Energy, LLC ER10-2180 Handsome Lake 1 Handsome Lake Energy, LLC Handsome Lake Energy, LLC N/A PJM Northeast 7/31/2001 58.90 53.50 S

Handsome Lake Energy, LLC ER10-2180 Handsome Lake 2 Handsome Lake Energy, LLC Handsome Lake Energy, LLC N/A PJM Northeast 7/31/2001 58.90 53.50 S

Handsome Lake Energy, LLC ER10-2180 Handsome Lake 3 Handsome Lake Energy, LLC Handsome Lake Energy, LLC N/A PJM Northeast 7/31/2001 58.90 53.50 S

Handsome Lake Energy, LLC ER10-2180 Handsome Lake 4 Handsome Lake Energy, LLC Handsome Lake Energy, LLC N/A PJM Northeast 7/31/2001 58.90 53.50 S

Handsome Lake Energy, LLC ER10-2180 Handsome Lake 5 Handsome Lake Energy, LLC Handsome Lake Energy, LLC N/A PJM Northeast 7/31/2001 58.90 53.50 S PJM Bethlehem Renewable Energy, LLC ER07-903 Bethlehem Landfill Bethlehem Renewable Energy, LLC Bethlehem Renewable Energy, LLC N/A Northeast 3/1/2008 5.50 4.70 S 5004/5005 Calvert Cliffs Nuclear Power Plant, Calvert Cliffs Nuclear Power Plant, Calvert Cliffs Nuclear Power Plant, PJM ER00-2917 Calvert Cliffs 1 N/A Northeast 5/1/1975 918.00 866.00 S LLC LLC LLC 5004/5005 Calvert Cliffs Nuclear Power Plant, Calvert Cliffs Nuclear Power Plant, Calvert Cliffs Nuclear Power Plant, PJM ER00-2917 Calvert Cliffs 2 N/A Northeast 4/1/1977 910.70 841.80 S LLC LLC LLC 5004/5005 Constellation Power Source Constellation Power Source Constellation Power Source PJM ER00-1598 Gould Street 3 N/A Northeast 12/1/1952 103.50 97.00 S Generation, LLC Generation, LLC Generation, LLC 5004/5005 Constellation Power Source Constellation Power Source Constellation Power Source PJM ER00-1598 Notch Cliff 1 N/A Northeast 6/1/1969 18.00 14.00 S Generation, LLC Generation, LLC Generation, LLC 5004/5005 Constellation Power Source Constellation Power Source Constellation Power Source PJM ER00-1598 Notch Cliff 2 N/A Northeast 6/1/1969 18.00 14.00 S Generation, LLC Generation, LLC Generation, LLC 5004/5005 Constellation Power Source Constellation Power Source Constellation Power Source PJM ER00-1598 Notch Cliff 3 N/A Northeast 6/1/1969 18.00 14.00 S Generation, LLC Generation, LLC Generation, LLC 5004/5005 Constellation Power Source Constellation Power Source Constellation Power Source PJM ER00-1598 Notch Cliff 4 N/A Northeast 6/1/1969 18.00 14.00 S Generation, LLC Generation, LLC Generation, LLC 5004/5005 Constellation Power Source Constellation Power Source Constellation Power Source PJM ER00-1598 Notch Cliff 5 N/A Northeast 6/1/1969 18.00 14.60 S Generation, LLC Generation, LLC Generation, LLC 5004/5005

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Constellation Power Source Constellation Power Source Constellation Power Source PJM ER00-1598 Notch Cliff 6 N/A Northeast 6/1/1969 18.00 15.60 S Generation, LLC Generation, LLC Generation, LLC 5004/5005 Constellation Power Source Constellation Power Source Constellation Power Source PJM ER00-1598 Notch Cliff 7 N/A Northeast 6/1/1969 18.00 14.50 S Generation, LLC Generation, LLC Generation, LLC 5004/5005 Constellation Power Source Constellation Power Source Constellation Power Source PJM ER00-1598 Notch Cliff 8 N/A Northeast 6/1/1969 18.00 16.00 S Generation, LLC Generation, LLC Generation, LLC 5004/5005 Constellation Power Source Constellation Power Source Constellation Power Source PJM ER00-1598 Perryman 1 N/A Northeast 1/1/1972 53.10 52.00 S Generation, LLC Generation, LLC Generation, LLC 5004/5005 Constellation Power Source Constellation Power Source Constellation Power Source PJM ER00-1598 Perryman 3 N/A Northeast 4/1/1972 53.10 51.00 S Generation, LLC Generation, LLC Generation, LLC 5004/5005 Constellation Power Source Constellation Power Source Constellation Power Source PJM ER00-1598 Perryman 4 N/A Northeast 4/1/1972 53.10 52.00 S Generation, LLC Generation, LLC Generation, LLC 5004/5005 Constellation Power Source Constellation Power Source Constellation Power Source PJM ER00-1598 Perryman 51 N/A Northeast 6/1/1995 192.00 147.60 S Generation, LLC Generation, LLC Generation, LLC 5004/5005 Constellation Power Source Constellation Power Source Constellation Power Source PJM ER00-1598 Perryman 6 N/A Northeast 6/28/2015 141.00 109.80 S Generation, LLC Generation, LLC Generation, LLC 5004/5005 Constellation Power Source Constellation Power Source Constellation Power Source PJM ER00-1598 Philadelphia Road 1 N/A Northeast 8/1/1970 20.70 15.30 S Generation, LLC Generation, LLC Generation, LLC 5004/5005 Constellation Power Source Constellation Power Source Constellation Power Source PJM ER00-1598 Philadelphia Road 2 N/A Northeast 8/1/1970 20.70 16.00 S Generation, LLC Generation, LLC Generation, LLC 5004/5005 Constellation Power Source Constellation Power Source Constellation Power Source PJM ER00-1598 Philadelphia Road 3 N/A Northeast 9/1/1970 20.70 14.80 S Generation, LLC Generation, LLC Generation, LLC 5004/5005 Constellation Power Source Constellation Power Source Constellation Power Source PJM ER00-1598 Philadelphia Road 4 N/A Northeast 9/1/1970 20.70 14.80 S Generation, LLC Generation, LLC Generation, LLC 5004/5005 Constellation Power Source Constellation Power Source Constellation Power Source PJM ER00-1598 Riverside 7 N/A Northeast 9/1/1970 25.00 19.00 S Generation, LLC Generation, LLC Generation, LLC 5004/5005 Constellation Power Source Constellation Power Source Constellation Power Source PJM ER00-1598 Riverside 8 N/A Northeast 9/1/1970 25.00 20.00 S Generation, LLC Generation, LLC Generation, LLC 5004/5005 Constellation Power Source Constellation Power Source Constellation Power Source PJM ER00-1598 Westport 5 N/A Northeast 2/1/1969 121.50 115.80 S Generation, LLC Generation, LLC Generation, LLC 5004/5005 PJM Eastern Landfill Gas, LLC ER05-1054 Eastern Landfill Eastern Landfill Gas, LLC Eastern Landfill Gas, LLC N/A Northeast 10/26/2006 3.00 3.00 S 5004/5005 PJM Exelon Generation Company, LLC ER00-3251 TMI 1 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A Northeast 9/2/1974 980.90 802.80 S 5004/5005 Exelon Generation Company, LLC ER00-3251 Chester 7 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 2/7/1969 18.60 13.00 S

Exelon Generation Company, LLC ER00-3251 Chester 8 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 5/20/1969 18.60 13.00 S

Exelon Generation Company, LLC ER00-3251 Chester 9 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 3/6/1969 18.60 13.00 S

Exelon Generation Company, LLC ER00-3251 Conowingo 1 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 3/1/1928 45.00 48.00 S

Exelon Generation Company, LLC ER00-3251 Conowingo 10 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 5/25/1964 55.60 65.00 S

Exelon Generation Company, LLC ER00-3251 Conowingo 11 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 5/4/1964 55.60 65.00 S

Exelon Generation Company, LLC ER00-3251 Conowingo 2 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 3/1/1928 36.00 36.00 S

Exelon Generation Company, LLC ER00-3251 Conowingo 3 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 3/6/1928 48.00 48.00 S

Exelon Generation Company, LLC ER00-3251 Conowingo 4 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 4/5/1928 47.70 48.00 S

Exelon Generation Company, LLC ER00-3251 Conowingo 5 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 6/1/1928 36.00 36.00 S

Exelon Generation Company, LLC ER00-3251 Conowingo 6 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 7/1/1928 47.70 48.00 S

Exelon Generation Company, LLC ER00-3251 Conowingo 7 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 6/1/1928 48.00 48.00 S

Exelon Generation Company, LLC ER00-3251 Conowingo 8 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 3/10/1964 55.60 65.00 S

Exelon Generation Company, LLC ER00-3251 Conowingo 9 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 3/25/1964 55.60 65.00 S

Exelon Generation Company, LLC ER00-3251 Croydon 11 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 6/18/1974 68.30 49.00 S

Exelon Generation Company, LLC ER00-3251 Croydon 12 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 6/18/1974 68.30 49.00 S

Exelon Generation Company, LLC ER00-3251 Croydon 21 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 6/18/1974 68.30 49.00 S

Exelon Generation Company, LLC ER00-3251 Croydon 22 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 6/18/1974 68.30 49.00 S

Exelon Generation Company, LLC ER00-3251 Croydon 31 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 8/6/1974 68.30 49.00 S

Exelon Generation Company, LLC ER00-3251 Croydon 32 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 8/8/1974 68.30 48.00 S

Exelon Generation Company, LLC ER00-3251 Croydon 41 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 7/24/1974 68.30 49.00 S

Exelon Generation Company, LLC ER00-3251 Croydon 42 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 7/24/1974 68.30 49.00 S

Exelon Generation Company, LLC ER00-3251 Delaware 10 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 5/7/1969 18.60 13.00 S

Exelon Generation Company, LLC ER00-3251 Delaware 11 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 4/19/1969 18.60 13.00 S

Exelon Generation Company, LLC ER00-3251 Delaware 12 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 5/12/1969 18.60 13.00 S

Exelon Generation Company, LLC ER00-3251 Delaware 9 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 7/24/1970 21.20 17.00 S

Exelon Generation Company, LLC ER00-3251 Eddystone 10 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 5/20/1967 18.60 13.00 S

Exelon Generation Company, LLC ER00-3251 Eddystone 20 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 10/11/1967 18.60 13.00 S

Exelon Generation Company, LLC ER00-3251 Eddystone 3 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 9/24/1974 391.00 380.00 S

Exelon Generation Company, LLC ER00-3251 Eddystone 30 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 3/7/1970 21.20 17.00 S

Exelon Generation Company, LLC ER00-3251 Eddystone 4 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 6/29/1976 391.00 380.00 S

Exelon Generation Company, LLC ER00-3251 Eddystone 40 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 6/21/1970 21.20 17.00 S

Exelon Generation Company, LLC ER00-3251 Fairless Hills A Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 12/1/1996 30.00 30.00 S

Exelon Generation Company, LLC ER00-3251 Fairless Hills B Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 12/1/1996 30.00 30.00 S

Exelon Generation Company, LLC ER00-3251 Falls 1 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 5/22/1970 21.20 17.00 S

Exelon Generation Company, LLC ER00-3251 Falls 2 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 6/10/1970 21.20 17.00 S

Exelon Generation Company, LLC ER00-3251 Falls 3 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 6/28/1970 21.10 17.00 S

Exelon Generation Company, LLC ER00-3251 Limerick 1 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 2/1/1986 1138.50 1119.70 S

Exelon Generation Company, LLC ER00-3251 Limerick 2 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 1/1/1990 1138.50 1122.10 S

Exelon Generation Company, LLC ER00-3251 Moser 1 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 6/9/1970 21.20 17.00 S

Exelon Generation Company, LLC ER00-3251 Moser 2 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 5/29/1970 21.20 17.00 S

Exelon Generation Company, LLC ER00-3251 Moser 3 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 6/11/1970 21.20 17.00 S

Exelon Generation Company, LLC ER00-3251 Muddy Run 1 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 4/10/1967 134.00 134.00 S

Exelon Generation Company, LLC ER00-3251 Muddy Run 2 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 4/10/1967 134.00 133.00 S

Exelon Generation Company, LLC ER00-3251 Muddy Run 3 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 6/1/1967 134.00 134.00 S

Exelon Generation Company, LLC ER00-3251 Muddy Run 4 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 6/1/1967 134.00 134.00 S

Exelon Generation Company, LLC ER00-3251 Muddy Run 5 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 10/11/1967 134.00 134.00 S

Exelon Generation Company, LLC ER00-3251 Muddy Run 6 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 10/11/1967 134.00 133.00 S

Exelon Generation Company, LLC ER00-3251 Muddy Run 7 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 2/10/1968 134.00 134.00 S

Exelon Generation Company, LLC ER00-3251 Muddy Run 8 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 2/10/1968 134.00 134.00 S

Exelon Generation Company, LLC ER00-3251 Oyster Creek 1 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 12/1/1969 550.00 607.70 S

Exelon Generation Company, LLC ER00-3251 Peach Bottom 2 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 7/5/1974 1244.80 1223.70 S 5

Exelon Generation Company, LLC ER00-3251 Peach Bottom 3 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 12/23/1974 1377.00 1226.70 S 6

Exelon Generation Company, LLC ER00-3251 Pennsbury 1 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 9/1/1996 3.00 3.00 S

Exelon Generation Company, LLC ER00-3251 Pennsbury 2 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 9/1/1996 3.00 3.00 S

Exelon Generation Company, LLC ER00-3251 Richmond 91 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 6/7/1973 65.80 49.00 S

Exelon Generation Company, LLC ER00-3251 Richmond 92 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 6/7/1973 65.80 49.00 S

Exelon Generation Company, LLC ER00-3251 Salem 1 PSEG (ExGen 42.59%) PSEG N/A PJM-East Northeast 6/30/1977 1251.40 1173.99 S 7

Exelon Generation Company, LLC ER00-3251 Salem 2 PSEG (ExGen 42.59%) PSEG N/A PJM-East Northeast 10/13/1981 1216.40 1158.02 S 8

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Exelon Generation Company, LLC ER00-3251 Salem 3 PSEG (ExGen 42.59%) PSEG N/A PJM-East Northeast 6/17/1971 41.80 37.57 S 9

Exelon Generation Company, LLC ER00-3251 Schuylkill 10 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 5/30/1969 18.60 13.00 S

Exelon Generation Company, LLC ER00-3251 Schuylkill 11 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 6/11/1971 21.20 17.00 S

Exelon Generation Company, LLC ER00-3251 Southwark 3 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 6/14/1967 18.60 13.00 S

Exelon Generation Company, LLC ER00-3251 Southwark 4 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 10/9/1967 18.60 13.00 S

Exelon Generation Company, LLC ER00-3251 Southwark 5 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 7/26/1967 18.60 13.00 S

Exelon Generation Company, LLC ER00-3251 Southwark 6 Exelon Generation Company, LLC Exelon Generation Company, LLC N/A PJM-East Northeast 11/7/1968 18.60 13.00 S ER10-75 Cassia Gulch Wind Park LLC Cassia Gulch WF Cassia Gulch Wind Park LLC Cassia Gulch Wind Park LLC N/A IPCO Northwest 3/31/2009 18.90 18.90 S QF05-180 ER12-2528 High Mesa Energy, LLC High Mesa WF High Mesa Energy, LLC High Mesa Energy, LLC N/A IPCO Northwest 8/28/2012 39.90 39.90 S QF13-77 ER10-87 Tuana Springs Energy, LLC Tuana Springs WF Tuana Springs Energy, LLC Tuana Springs Energy, LLC N/A IPCO Northwest 7/27/2010 16.80 16.80 S QF08-742 ER07-1223 Cow Branch Wind Power, L.L.C. Cow Branch WF Cow Branch Wind Power, L.L.C. Cow Branch Wind Power, L.L.C. N/A AECI Southeast 3/3/2008 50.40 50.40 S QF07-253 ER07-1222 CR Clearing, LLC Conception WF CR Clearing, LLC CR Clearing, LLC N/A AECI Southeast 5/1/2008 50.40 50.40 S QF07-248 ER07-1208 Wind Capital Holdings, LLC Wind Capital Holdings LLC WF Wind Capital Holdings, LLC Wind Capital Holdings, LLC N/A AECI Southeast 5/14/2007 56.70 56.70 S QF07-222 CER Generation, LLC ER10-662 Hillabee GT1 CER Generation, LLC CER Generation, LLC N/A SOCO Southeast 6/8/2010 258.40 234.40 S

CER Generation, LLC ER10-662 Hillabee GT2 CER Generation, LLC CER Generation, LLC N/A SOCO Southeast 6/8/2010 258.40 234.40 S

CER Generation, LLC ER10-662 Hillabee STG1 CER Generation, LLC CER Generation, LLC N/A SOCO Southeast 6/8/2010 306.00 283.90 S

AV Solar Ranch 1, LLC ER12-2178 Antelope Valley SF AV Solar Ranch 1, LLC AV Solar Ranch 1, LLC N/A CAISO Southwest 12/28/2012 253.00 241.50 S

Bluestem Wind Energy, LLC ER16-2363 Bluestem WF Bluestem Wind Energy, LLC Bluestem Wind Energy, LLC N/A SPP SPP 12/31/2016 198.00 198.00 N ER07-1202 Exelon Wind 4, LLC Exelon Wind 4 WF Exelon Wind 4, LLC Exelon Wind 4, LLC N/A SPP SPP 12/15/2006 79.80 79.80 S QF03-13 Shooting Star Wind Project, LLC ER00-3251 Shooting Star WF Shooting Star Wind Project, LLC Shooting Star Wind Project, LLC N/A SPP SPP 9/29/2012 104.00 104.00 S ER12-1223 Wildcat Wind, LLC Wildcat WF Wildcat Wind, LLC Wildcat Wind, LLC N/A SPP SPP 7/1/2012 27.30 27.30 S QF12-412

Page 3 of 8 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM

Asset Appendix: Long-Term Purchase Agreements - September 2016 [A] [B] [C] [D] [E] [F] [G] [H] [I] [J] Location End Note Market / Balancing Market / Balancing Type of PPA Amount of Geographic Start Date End Date Number (Enter Filing Entity and its Energy Affiliates Seller Name Authority Area Authority Area (Unit or PPA (MW) Region (Sink) (mo/da/yr) (mo/da/yr) text in End (Source) (Sink) System) Note Tab)

Exelon Generation Company, LLC Pioneer Trail Wind Farm, LLC 110 MISO MISO Central 2/15/2012 7/1/2020 Unit 10

Exelon Generation Company, LLC Tenaska Frontier Partners Ltd 160 MISO MISO Central 9/20/2000 8/31/2020 Unit 11

Exelon Generation Company, LLC Tenaska Frontier Partners Ltd 160 MISO MISO Central 9/20/2000 8/31/2020 Unit 12

Exelon Generation Company, LLC Tenaska Frontier Partners Ltd 160 MISO MISO Central 9/20/2000 8/31/2020 Unit 13

Exelon Generation Company, LLC Tenaska Frontier Partners Ltd 390 MISO MISO Central 9/20/2000 8/31/2020 Unit 14

Exelon Generation Company, LLC Ameresco Northampton, Inc 1 ISO-NE ISO-NE Northeast 3/13/2008 12/31/2017 Unit 15

Exelon Generation Company, LLC Kleen Energy Systems, LLC 186 ISO-NE Connecticut ISO-NE Connecticut Northeast 7/23/2011 12/31/2017 Unit 16

Exelon Generation Company, LLC Kleen Energy Systems, LLC 188 ISO-NE Connecticut ISO-NE Connecticut Northeast 7/23/2011 12/31/2017 Unit 17

Exelon Generation Company, LLC Kleen Energy Systems, LLC 246 ISO-NE Connecticut ISO-NE Connecticut Northeast 7/23/2011 12/31/2017 Unit 18

Exelon Generation Company, LLC WM Renewable Energy, LLC 6 NYISO NYISO Northeast 1/1/2012 12/31/2016 Unit 19

Exelon Generation Company, LLC WM Renewable Energy, LLC 3 NYISO NYISO Northeast 1/1/2012 12/31/2016 Unit 20

Exelon Generation Company, LLC WM Renewable Energy, LLC 6 NYISO NYISO Northeast 1/1/2012 12/31/2016 Unit 21

Exelon Generation Company, LLC WM Renewable Energy, LLC 2 NYISO NYISO Northeast 1/1/2012 12/31/2016 Unit 22

Exelon Generation Company, LLC WM Renewable Energy, LLC 6 NYISO NYISO Northeast 1/1/2012 12/31/2016 Unit 23

Exelon Generation Company, LLC WM Renewable Energy, LLC 2 NYISO NYISO Northeast 1/1/2012 12/31/2016 Unit 24

Exelon Generation Company, LLC WM Renewable Energy, LLC 3 NYISO NYISO Northeast 2/1/2013 12/31/2016 Unit 25

Delmarva Power & Light Company AES Armenia Mountain Wind LLC 50 PJM PJM Northeast 12/18/2009 12/19/2024 Unit 26

Delmarva Power & Light Company Chestnut Flats Wind LLC 38 PJM PJM Northeast 12/31/2011 12/29/2031 Unit 27

Delmarva Power & Light Company Roth Rock Wind Farm LLC 40 PJM PJM Northeast 12/31/2010 8/3/2031 Unit 28

Exelon Generation Company, LLC Backbone Mountain Windpower LLC 66 PJM PJM Northeast 12/20/2002 12/31/2022 Unit 29

Exelon Generation Company, LLC Bellefontaine Gas Producers, LLC 5 PJM PJM Northeast 3/5/2009 3/31/2019 Unit 30

Exelon Generation Company, LLC Cordova Energy Company, LLC 165 PJM PJM Northeast 12/30/2005 12/31/2019 Unit 31

Exelon Generation Company, LLC Cordova Energy Company, LLC 165 PJM PJM Northeast 12/30/2005 12/31/2019 Unit 32

Exelon Generation Company, LLC Cordova Energy Company, LLC 191 PJM PJM Northeast 12/30/2005 12/31/2019 Unit 33

Exelon Generation Company, LLC Elwood Energy, LLC 150 PJM PJM Northeast 6/15/2006 8/31/2017 Unit 34

Exelon Generation Company, LLC Elwood Energy, LLC 150 PJM PJM Northeast 6/15/2006 8/31/2017 Unit 35

Exelon Generation Company, LLC Forward Wind Power LLC 29 PJM PJM Northeast 4/11/2008 12/31/2017 Unit 36

Exelon Generation Company, LLC High Trail Wind Farm, LLC 99 PJM PJM Northeast 1/1/2010 12/31/2017 Unit 37

Exelon Generation Company, LLC Mill Run Windpower, LLC 16 PJM PJM Northeast 12/20/2001 12/31/2021 Unit 38

Exelon Generation Company, LLC Old Trail Wind Farm, LLC 198 PJM PJM Northeast 9/1/2008 12/31/2022 Unit 39

Exelon Generation Company, LLC Patton Wind Farm, LLC 16 PJM PJM Northeast 1/1/2013 12/31/2032 Unit 40

Exelon Generation Company, LLC Somerset Windpower, LLC 9 PJM PJM Northeast 12/19/2001 12/31/2021 Unit 41

Exelon Generation Company, LLC WM Renewable Energy, LLC 4 PJM PJM Northeast 3/1/2012 12/31/2016 Unit 42

Exelon Generation Company, LLC WM Renewable Energy, LLC 6 PJM PJM Northeast 6/1/2012 12/31/2016 Unit 43

Exelon Generation Company, LLC Green Gas Pioneer Crossing Energy, LLC 5 PJM 5004/5005 PJM 5004/5005 Northeast 11/10/2008 11/30/2021 Unit 44 Green Knight Economic Development Exelon Generation Company, LLC 3 PJM 5004/5005 PJM 5004/5005 Northeast 1/1/2012 12/31/2016 Unit 45 Corporation Exelon Generation Company, LLC Keystone Solar, L.L.C. 5 PJM 5004/5005 PJM 5004/5005 Northeast 5/4/2011 10/1/2027 Unit 46

Exelon Generation Company, LLC Waymart Wind Farm, L.P. 65 PJM 5004/5005 PJM 5004/5005 Northeast 10/20/2003 10/31/2023 Unit 47

Exelon Generation Company, LLC Ameresco Stafford, LLC 2 PJM AP South PJM AP South Northeast 5/19/2009 5/1/2019 Unit 48

Exelon Generation Company, LLC WM Renewable Energy, LLC 4 PJM AP South PJM AP South Northeast 12/1/2007 12/31/2016 Unit 49

Atlantic City Electric Company Chambers Cogeneration LP 188 PJM-East PJM-East Northeast 3/1/1994 3/15/2024 Unit 50

Atlantic City Electric Company Logan Generating Co LP 200 PJM-East PJM-East Northeast 9/1/1994 9/22/2024 Unit 51

Exelon Generation Company, LLC Ameresco Delaware Energy, LLC 3 PJM-East PJM-East Northeast 2/1/2007 1/31/2017 Unit 52

Exelon Generation Company, LLC Ameresco Delaware Energy, LLC 4 PJM-East PJM-East Northeast 10/24/2006 10/23/2016 Unit 53 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM

[A] [B] [C] [D] [E] [F] [G] [H] [I] [J] Location End Note Market / Balancing Market / Balancing Type of PPA Amount of Geographic Start Date End Date Number (Enter Filing Entity and its Energy Affiliates Seller Name Authority Area Authority Area (Unit or PPA (MW) Region (Sink) (mo/da/yr) (mo/da/yr) text in End (Source) (Sink) System) Note Tab)

Exelon Generation Company, LLC Calpine Mid Merit LLC 118 PJM-East PJM-East Northeast 6/1/2011 5/31/2017 Unit 54

Exelon Generation Company, LLC Calpine Mid Merit LLC 127 PJM-East PJM-East Northeast 6/1/2011 5/31/2017 Unit 55

Exelon Generation Company, LLC Calpine Mid Merit LLC 127 PJM-East PJM-East Northeast 6/1/2011 5/31/2017 Unit 56

Exelon Generation Company, LLC Calpine Mid Merit LLC 193 PJM-East PJM-East Northeast 6/1/2011 5/31/2017 Unit 57

Exelon Generation Company, LLC MF Mesa Lane LLC 3 PJM-East PJM-East Northeast 12/1/2008 11/30/2028 Unit 58

Exelon Generation Company, LLC The Energy Authority 2 BPA BPA Northwest 1/1/2016 12/31/2016 System 59

Exelon Generation Company, LLC Sagebrush Power Partners, LLC 101 BPA BPA Northwest 9/1/2012 12/31/2018 Unit 60 Public Utility District No. 1 of Chelan Exelon Generation Company, LLC 47 CHPD CHPD Northwest 2/16/2012 12/31/2017 Unit 61 County, Washington Public Utility District No. 1 of Chelan Exelon Generation Company, LLC 98 CHPD CHPD Northwest 2/16/2012 12/31/2017 Unit 62 County, Washington Exelon Generation Company, LLC Wind Power Partners 1993, LLC 17 CAISO CAISO Southwest 2/15/2012 12/31/2024 Unit 63

Exelon Generation Company, LLC Wind Power Partners 1993, LLC 6 CAISO CAISO Southwest 2/15/2012 12/31/2024 Unit 64

Exelon Generation Company, LLC Wind Power Partners 1993, LLC 9 CAISO CAISO Southwest 2/15/2012 12/31/2024 Unit 65

Exelon Generation Company, LLC Wind Power Partners 1993, LLC 11 CAISO CAISO Southwest 2/15/2012 12/31/2024 Unit 66

Exelon Generation Company, LLC Wind Power Partners 1993, LLC 8 CAISO CAISO Southwest 2/15/2012 12/31/2024 Unit 67

Exelon Generation Company, LLC Green Country Energy, LLC 261 SPP SPP SPP 2/11/2002 12/28/2021 Unit 68

Exelon Generation Company, LLC Green Country Energy, LLC 261 SPP SPP SPP 2/11/2002 12/28/2021 Unit 69

Exelon Generation Company, LLC Green Country Energy, LLC 261 SPP SPP SPP 2/11/2002 12/28/2021 Unit 70 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM

Asset Appendix: Transmission Assets/Natural Gas Asset - September 2016 [A] [B] [C] [D] [E] [F] [G] [H] [I] [J] Location

Cite to order accepting End Note OATT or order Market / Asset Name and Use Date Control Geographic Size: (length Number (Enter Filing Entity and its Energy Affiliates approving the transfer of Owned By Controlled By Balancing Transferred Region and kV) text in End Note transmission facilities to Authority Area Tab) an RTO or ISO 703.18 81 FERC ¶ 61,257 Baltimore Gas and Baltimore Gas and Electric Company Electric Transmission PJM 1998 PJM Northeast combined (1997) Electric Company 54.82miles 81 FERC ¶ 61,257 Baltimore Gas and Baltimore Gas and Electric Company Electric Transmission PJM 1998 PJM Northeast combined (1997) Electric Company 322.23miles 81 FERC ¶ 61,257 Baltimore Gas and Baltimore Gas and Electric Company Electric Transmission PJM 1998 PJM Northeast combined (1997) Electric Company 217.94miles 81 FERC ¶ 61,257 Baltimore Gas and Baltimore Gas and Electric Company Electric Transmission PJM 1998 PJM Northeast combined (1997) Electric Company 161.4miles Baltimore Gas and Baltimore Gas and Baltimore Gas and Electric Company N/A Intrastate Gas Transportation N/A PJM Northeast combined Electric Company Electric Company miles Baltimore Gas and Baltimore Gas and Baltimore Gas and Electric Company N/A Intrastate Gas Storage (LNG) N/A PJM Northeast 1,056 mmcf Electric Company Electric Company 13,398 Baltimore Gas and Baltimore Gas and Baltimore Gas and Electric Company N/A Intrastate Gas Distribution N/A PJM Northeast combined Electric Company Electric Company 90miles 107 FERC ¶ 61,087 Commonwealth Commonwealth Edison Company Electric Transmission PJM 2004 PJM Northeast combined (2004) Edison Company 2,656miles 107 FERC ¶ 61,087 Commonwealth Commonwealth Edison Company Electric Transmission PJM 2004 PJM Northeast combined (2004) Edison Company 2,904miles 107 FERC ¶ 61,087 Commonwealth Commonwealth Edison Company Electric Transmission PJM 2004 PJM Northeast combined (2004) Edison Company 446miles 81 FERC ¶ 61,257 PECO Energy PECO Energy Company Electric Transmission PJM 1998 PJM Northeast combined (1997) Company 548miles 81 FERC ¶ 61,257 PECO Energy PECO Energy Company Electric Transmission PJM 1998 PJM Northeast combined (1997) Company 156miles 81 FERC ¶ 61,257 PECO Energy PECO Energy Company Electric Transmission PJM 1998 PJM Northeast combined (1997) Company 200miles 81 FERC ¶ 61,257 PECO Energy PECO Energy Company Electric Transmission PJM 1998 PJM Northeast combined (1997) Company 0.47miles 81 FERC ¶ 61,257 PECO Energy PECO Energy Company Electric Transmission PJM 1998 PJM Northeast combined (1997) Company 30miles PECO Energy PECO Energy PECO Energy Company N/A Intrastate Gas Transportation N/A PJM Northeast combined Company Company miles PECO Energy PECO Energy PECO Energy Company N/A Intrastate Gas Storage (LNG) N/A PJM Northeast 1,200 mmcf Company Company PECO Energy PECO Energy PECO Energy Company N/A Intrastate Gas Stogare (LP) N/A PJM Northeast 125 mmcf Company Company 13,046 PECO Energy PECO Energy PECO Energy Company N/A Intrastate Gas Distribution N/A PJM Northeast combined Company Company miles 281 81 FERC ¶ 61,257 Atlantic City combined Atlantic City Electric Company Electric Transmission PJM 1998 PJM Northeast (1997) Electric Company miles 500kV lines 223 81 FERC ¶ 61,257 Atlantic City combined Atlantic City Electric Company Electric Transmission PJM 1998 PJM Northeast (1997) Electric Company miles 230kV lines 242 81 FERC ¶ 61,257 Atlantic City combined Atlantic City Electric Company Electric Transmission PJM 1998 PJM Northeast (1997) Electric Company miles 138kV lines 636 81 FERC ¶ 61,257 Atlantic City combined Atlantic City Electric Company Electric Transmission PJM 1998 PJM Northeast (1997) Electric Company miles 69kV lines 297 81 FERC ¶ 61,257 Delmarva Power & combined Delmarva Power & Light Company Electric Transmission PJM 1998 PJM Northeast (1997) Light Company miles 500kV lines 470 81 FERC ¶ 61,257 Delmarva Power & combined Delmarva Power & Light Company Electric Transmission PJM 1998 PJM Northeast (1997) Light Company miles 230kV lines 557 81 FERC ¶ 61,257 Delmarva Power & combined Delmarva Power & Light Company Electric Transmission PJM 1998 PJM Northeast (1997) Light Company miles 138kV lines 580 81 FERC ¶ 61,257 Delmarva Power & combined Delmarva Power & Light Company Electric Transmission PJM 1998 PJM Northeast (1997) Light Company miles 69kV lines 111 Delmarva Power & Delmarva Power & Light Company N/A Intrastate Gas Transportation PJM N/A PJM Northeast combined Light Company miles Delmarva Power & Delmarva Power & Light Company N/A Intrastate Gas Storage (LNG) PJM N/A PJM Northeast 248 mmcf Light Company 3,279 Delmarva Power & Delmarva Power & Light Company N/A Intrastate Gas Distribution PJM N/A PJM Northeast combined Light Company miles 142 81 FERC ¶ 61,257 Potomac Electric combined Potomac Electric Power Company Electric Transmission PJM 1998 PJM Northeast (1997) Power Company miles 500kV lines 821 81 FERC ¶ 61,257 Potomac Electric combined Potomac Electric Power Company Electric Transmission PJM 1998 PJM Northeast (1997) Power Company miles 230kV lines 89 81 FERC ¶ 61,257 Potomac Electric combined Potomac Electric Power Company Electric Transmission PJM 1998 PJM Northeast (1997) Power Company miles 138kV lines 38 81 FERC ¶ 61,257 Potomac Electric combined Potomac Electric Power Company Electric Transmission PJM 1998 PJM Northeast (1997) Power Company miles 115kV lines

Page 6 of 8 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM

Asset Appendix: End Notes - September-2016 [A] [B] [C] Sheet End Note (Generation, PPA Explanatory Note Number or Transmission) 1 Generation Exelon owns only 5.9% of the Wyman 4 generating unit 2 Generation Nine Mile Point Nuclear Stations, LLC owns only 82% of Unit 2 3 Generation Exelon owns only 75% of the Quad Cities 1 generating unit 4 Generation Exelon owns only 75% of the Quad Cities 2 generating unit 5 Generation Exelon owns only 50% of the Peach Bottom 2 generating unit 6 Generation Exelon owns only 50% of the Peach Bottom 3 generating unit 7 Generation Exelon owns only 42.59% of the Salem 1 generating unit 8 Generation Exelon owns only 42.59% of the Salem 2 generating unit 9 Generation Exelon owns only 42.59% of the Salem 3 generating unit 10 PPA Pioneer Trail WF 11 PPA Frontier GT1 12 PPA Frontier GT2 13 PPA Frontier GT3 14 PPA Frontier ST 15 PPA Northampton 16 PPA Kleen GT1 17 PPA Kleen GT2 18 PPA Kleen STG1 19 PPA Chaffee Landfill 20 PPA High Acres-I Landfill 21 PPA High Acres-II Landfill 22 PPA Madison County Landfill 23 PPA Mill Seat Landill 24 PPA Monroe-Livingston Landfill 25 PPA Oneida/Herkimer Landfill 26 PPA Armenia Mountain WF II 27 PPA Chestnut Flats WF I 28 PPA Roth Rock WF I 29 PPA Mountaineer WF 30 PPA Bellefontaine Landfill 31 PPA Cordova GT1 32 PPA Cordova GT2 33 PPA Cordova STG1 34 PPA Elwood CEG 7 35 PPA Elwood CEG 8 36 PPA Forward Wind WF 37 PPA High Trail WF 38 PPA Mill Run WF 39 PPA Old Trail WF 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM

Asset Appendix: End Notes - September-2016 [A] [B] [C] Sheet End Note (Generation, PPA Explanatory Note Number or Transmission) 40 PPA Patton WF 41 PPA Somerset WF 42 PPA Arden Landfill 43 PPA Lakeview Landfill 44 PPA Pioneer Crossing Landfill 45 PPA Grand Central Landfill 46 PPA Keystone Solar SF 47 PPA Waymart WF 48 PPA Stafford Landfill 49 PPA Bethel Landfill 50 PPA Carney Point 51 PPA Logan Generating Plant 52 PPA Central Landfill 53 PPA Southern Landfill 54 PPA York Delta GT1 55 PPA York Delta GT2 56 PPA York Delta GT3 57 PPA York Delta STG1 58 PPA Falls Solar SF 59 PPA Block Energy Deal PBP70IL 60 PPA Kittitas Valley WF 61 PPA Rock Island 62 PPA Rocky Reach 63 PPA Palm Springs Buckwind WF 64 PPA Palm Springs Carter WF 65 PPA Palm Springs Garnet WF 66 PPA Palm Springs Renwind WF 67 PPA Palm Springs Triad WF 68 PPA Green Country 1 69 PPA Green Country 2 70 PPA Green Country 3 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM

Exhibit JRS-2

Generation Affiliated with Exelon West Medway II, LLC in ISO-NE and First-Tier Markets

Balancing Ownership Interest Authority Capacity (MW) Ownership (MW) Area Plant Name Summer Winter Share Summer Winter

Exhibit JRS-3

Part I – Pivotal Supplier Analysis

Applicant-> Exelon West Medway II, LLC Market -> ISO-NE Data Year -> Dec 2014-Nov 2015 Row Generation Reference Seller and Affiliate Capacity (owned or controlled) A Installed Capacity (from inside the study area) 2,399 Exhibit JRS-2 A1 Remote Capacity (from outside the study area) 0 B Long-Term Firm Purchases (from inside the study area) 621 Exhibit JRS-2 B1 Long-Term Firm Purchases (from outside the study area) 0 C Long-Term Firm Sales (in and outside the study area) 0 D Uncommitted Capacity Imports 614 Wkp - Import Allocation

H Uncommitted Capacity Imports 3,934 147 FERC ¶ 61,190 (2014) less Row D above

K Total Uncommitted Supply (A+A1+B+B1+D+E+E1+F+F1+H-C-G-I-M) 13,116

O Wholesale Load (L-M) 4,816

P Net Uncommitted Supply (K-O) 8,300

Q Seller's Uncommitted Capacity (A+A1+B+B1+D-C-J-N) 0

Result of Pivotal Supplier Screen (Pass if Line Q < Line P) Pass (Fail if Line Q > Line P)

Total Imports (Sum D,H), as filed by Seller -> 4,548 % of SIL for Seller's imported capacity -> 0.13 % of SIL for Other's imported capacity -> 0.87

SIL value -> 4,548 147 FERC ¶ 61,190 (2014) Do Total Imports exceed the SIL value? -> No 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM

Exhibit JRS-4 Part II – Market Share Analysis

Applicant-> Exelon West Medway II, LLC Study Area -> ISO-NE Data Year -> Dec 2014-Nov 2015 As filed by the Applicant/Seller Row Winter Spring Summer Fall (MW) (MW) (MW) (MW) Seller and Affiliate Capacity (owned, controlled or under LT contract) A Installed Capacity (inside the study area) 2,769 2,769 2,399 2,769 A1 Remote Capacity (from outside the study area) 0 0 0 0 B Long-Term Firm Purchases (inside the study area) 621 621 621 621 B1 Long-Term Firm Purchases (from outside the study area) 0 0 0 0 C Long-Term Firm Sales (in and outside the study area) 0 0 0 0 D Seasonal Average Planned Outages 0 0 0 0 E Uncommitted Capacity Imports 512 510 594 501

Capacity Deductions F Average Peak Native Load in the Season 18,391 15,604 18,719 16,307 G Amount of Line F Attributable to Seller, if any 3,627 3,224 4,080 3,720 H Amount of Line F Attributable to Non-Affiliates, if any 14,764 12,380 14,639 12,587

I Study Area Reserve Requirement 2,500 2,500 2,500 2,500 J Amount of Line I Attributable to Seller, if any 0 0 0 0 K Amount of Line I Attributable to Non-Affiliates, if any 2,500 2,500 2,500 2,500

Non-Affiliate Capacity (owned, controlled or under LT contract) L Installed Capacity (inside the study area) 30,085 30,085 30,443 30,085 L1 Remote Capacity (from outside the study area) 0 0 0 0 M Long-Term Firm Purchases (inside the study area) 0 0 0 0 M1 Long-Term Firm Purchases (from outside the study area) 0 0 0 0 N Long-Term Firm Sales (in and outside the study area) 621 621 621 621 O Seasonal Average Planned Outages 1,127 3,234 236 2,960

P Uncommitted Capacity Imports 4,036 4,038 3,954 4,047

T Seller's Market Share (R÷S) 1.8% 4.2% 0.0% 1.1% Results (Pass if < 20% and Fail if ≥ 20%) Pass Pass Pass Pass

U Total Imports, as filed by Seller (E+P) 4,548 4,548 4,548 4,548 V SIL value* 4,548 4,548 4,548 4,548

Do Total Imports exceed SIL value? (is U<=V) No No No No 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM

Exhibit JRS-4

Reference

Exhibit JRS-2

Wkp - Import Allocation

Wkp-ISO-NE Load Wkp - Exelon ISONE Load Data

ISO-NE Annual Markets Report, http://www.iso-ne.com/static- assets/documents/2016/05/2015_imm_amr_final_5_25_2016.pdf

Wkp- ISO-NE CELT Report less Row A (plus West Medway)

Offset Row B Wkp-ISO-NE Outages

147 FERC ¶ 61,190 (2014) less Row D above

147 FERC ¶ 61,190 (2014) 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM

2015 Form EIA-860 Data - Schedule 3, 'Generator Data' (Prelim)

Plant Utility ID Utility Name Code Plant Name State 6035 Exelon Power 59882 Exelon West Medway II LLC MA 6035 Exelon Power 59882 Exelon West Medway II LLC MA 55951 Exelon Nuclear 2589 Nine Mile Point Nuclear Station NY 55951 Exelon Nuclear 2589 Nine Mile Point Nuclear Station NY 55951 Exelon Nuclear 6122 R E Ginna Nuclear Power Plant NY

49965 Constellation Mystic Power LLC 1588 Mystic Generating Station MA 49965 Constellation Mystic Power LLC 1588 Mystic Generating Station MA 49965 Constellation Mystic Power LLC 1588 Mystic Generating Station MA 49965 Constellation Mystic Power LLC 1588 Mystic Generating Station MA 49965 Constellation Mystic Power LLC 1588 Mystic Generating Station MA 49965 Constellation Mystic Power LLC 1588 Mystic Generating Station MA 49965 Constellation Mystic Power LLC 1588 Mystic Generating Station MA 49965 Constellation Mystic Power LLC 1588 Mystic Generating Station MA 6035 Exelon Power 1586 Exelon Framingham LLC MA 6035 Exelon Power 1586 Exelon Framingham LLC MA 6035 Exelon Power 1586 Exelon Framingham LLC MA 6035 Exelon Power 1587 Exelon L Street MA 6035 Exelon Power 1592 Exelon Medway LLC MA 6035 Exelon Power 1592 Exelon Medway LLC MA 6035 Exelon Power 1592 Exelon Medway LLC MA

31719 FPL Energy Wyman LLC 1507 William F Wyman ME 55993 Kleen Energy Systems, LLC 56798 Kleen Energy Systems Project CT 55993 Kleen Energy Systems, LLC 56798 Kleen Energy Systems Project CT 55993 Kleen Energy Systems, LLC 56798 Kleen Energy Systems Project CT 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM

Can Bypass Heat RTO/ISO Recovery LMP Steam Node Generator Technolo Prime Ownershi Duct Generator Designati County ID gy Mover Unit Code p Burners ? on Norfolk 4 Gas Fired GT S X X Norfolk 5 Gas Fired GT S X X Oswego 1 Nuclear ST J X X Oswego 2 Nuclear ST J X X Wayne 1 Nuclear ST J X X

Middlesex 7 Liquids ST S X X MYSTIC Middlesex GT1 Liquids GT S X X MYSTIC Middlesex GT81 Gas Fired CT G941 S X Y MYSTIC Middlesex GT82 Gas Fired CT G941 S X Y MYSTIC Middlesex GT93 Gas Fired CT G942 S X Y MYSTIC Middlesex GT94 Gas Fired CT G942 S X Y MYSTIC Middlesex ST85 Gas Fired CA G941 S Y X MYSTIC Middlesex ST96 Gas Fired CA G942 S Y X MYSTIC Norfolk GT1 Liquids GT S X X Norfolk GT2 Liquids GT S X X Norfolk GT3 Liquids GT S X X Suffolk GT1 Liquids GT S X X Norfolk GT1 Liquids GT S X X Norfolk GT2 Liquids GT S X X Norfolk GT3 Liquids GT S X X Cumberla Petroleum nd 4 Liquids ST J X X Middlesex ST Gas Fired CA CC01 S Y X 14614 Middlesex U1 Gas Fired CT CC01 S X N 14614 Middlesex U2 Gas Fired CT CC01 S X N 14614 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM

RTO/ISO Location Designati on for Reporting Wholesal Nameplat e Sales e Nameplat Summer Winter Data to Capacity e Power Capacity Capacity Effective Effective Current FERC (MW) Factor (MW) (MW) Status Month Year Month 100.0 0.900 97.4 103.5 L 6 2018 6 100.0 0.900 97.4 103.5 L 6 2018 6 641.8 0.850 637.0 637.0 1,259.3 0.900 1,287.0 1,301.0 614.0 0.920 582.0 583.0

MYSTIC 617.0 0.900 570.8 559.8 90.0 N MYSTIC 14.2 0.850 9.1 14.5 5.0 N MYSTIC 278.6 0.850 224.6 268.7 140.0 N MYSTIC 278.6 0.850 226.7 271.2 140.0 N MYSTIC 278.6 0.850 227.9 274.1 140.0 N MYSTIC 278.6 0.850 230.1 276.7 140.0 N MYSTIC 315.0 0.850 252.1 301.6 75.0 N MYSTIC 315.0 0.850 255.9 307.7 75.0 N 14.2 0.850 10.2 14.2 5.0 N 14.2 0.850 9.9 13.9 5.0 N 14.2 0.850 11.3 15.3 5.0 N 18.6 0.850 16.0 21.8 6.0 N 45.0 0.850 42.0 64.0 20.0 N 45.0 0.850 39.8 61.6 20.0 N 45.0 0.850 42.0 64.0 20.0 N

632.4 0.930 602.1 605.8 60.0 N 14614 295.0 1.000 268.0 233.0 177.0 N 14614 199.0 1.000 177.0 195.0 120.0 N 14614 199.0 1.000 177.0 195.0 120.0 N 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM

Associate d with Combine d Heat and Previousl Current Power Sector y Energy Energy Energy Energy Year System Name Sector Canceled Source 1 Source 2 Source 3 Source 4 2018 N CHP 2 N NG DFO 2018 N CHP 2 N NG DFO

OP X 6 1975 N CHP 2 SB Y 6 1969 N CHP 2 OP X 4 2003 N CHP 2 OP X 4 2003 N CHP 2 OP X 6 2003 N CHP 2 OP X 6 2003 N CHP 2 OP X 4 2003 N CHP 2 OP X 6 2003 N CHP 2 OP X 3 1970 N CHP 2 OP X 9 1969 N CHP 2 OP X 9 1969 N CHP 2 OP X 9 1966 10 2016 N CHP 2 OP X 7 1970 N CHP 2 OP X 3 1971 N CHP 2 OP X 7 1970 N CHP 2 IPP Non- OP X 1 1978 N CHP 2 OP X 7 2011 N CHP 2 OP X 7 2011 N CHP 2 OP X 7 2011 N CHP 2 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM

Turbines, Inverters, Other or Fluidized Pulverize Combusti Subcritic Supercriti Hydrokin Bed d Coal Stoker on al cal Energy Energy etic Technolo Technolo Technolo Technolo Technolo Technolo Source 5 Source 6 Buoys gy? gy? gy? gy? gy? gy? 1 1

X RFO NG NG X DFO DFO X NG NG X NG NG X NG NG X NG NG X NG NG X NG NG X DFO X DFO X DFO X DFO X DFO X DFO X DFO

X RFO DFO X NG DFO X NG DFO X NG DFO 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM

Switch Ultrasupe Solid Fuel Carbon Between rcritical Gasificati Capture Oil and Technolo on Technolo Natural Cofire gy? System? gy? Gas? Fuels? Y N N N Y N

NG N N OVER DFO N N 1H NG N N 12H N N 12H N N 12H N N 12H N N 12H N N 12H N 10M N 10M N 10M N 10M N 1H N 1H N 1H

N N OVER N N 12H N N 12H N N 12H 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM

Y Y N N N N N N N N N N N N N N

N N N N N Y N Y 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM

Wkp-Import Allocation

Import Allocation PST Winter Spring Summer

Page 14 of 231 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM

Wkp-Import Allocation

Allocation of Imports into ISO-NE A Seller's Uncommitted Capacity in NYISO 1,457 1,464 1,464 1,457 B Seller's Uncommitted Capacity in HQT C Seller's Uncommitted Capacity in NBSO D Seller's Uncommitted Capacity (SUM A-C) 1,457 1,464 1,464 1,457

E Total Uncommitted Capacity in NYISO 10,800 12,999 13,065 11,161 F Total Uncommitted Capacity in HQT G Total Uncommitted Capacity in NBSO - - - - H Total Uncommitted Capacity (SUM E-G) 10,800 12,999 13,065 11,161

I Seller's Share of Uncommitted Capacity into ISO-NE (D/H) 13.5% 11.3% 11.2% 13.1%

J Imports into ISO-NE 4,548 4,548 4,548 4,548 K Seller's Share of Imports into ISO-NE (I*J) 614 512 510 594

Page 15 of 231 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM

Wkp-Import Allocation

Fall

Page 16 of 231 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM

Wkp-Import Allocation

1,464

13,276

- 13,276

11.0%

4,548 501

Page 17 of 231 20160930-5394 FERC PDF (Unofficial) 9/30/2016 12:08:31 PM

Electric Generating Facilities and Assets

[A] [B] [C] [D] [E] [F] [G] [H] [I] [J] [K] [L] [M] Location

Capacity Raiting: Docket # Market / Capacity Capacity Methodology End Note where MBR Generation Name Date Control Balancing Geographic In-Service Rating: Rating: Used in [K]: Number (Enter Filing Entity and its Energy Affiliates Owned by Controlled by authority was (Plant or Unit Name) Transferred Authority Region Date Nameplate Used in Filing (N)ameplate, (S)easonal, text in End granted Area (MW) (MW) 5-yr (U)nit, 5-yr (E)IA, Note Tab) (A)lternative