Generation Interconnection System Impact Study Report. For. PJM Generation Interconnection Request Queue Position X1-114.

Generation Interconnection System Impact Study Report For PJM Generation Interconnection Request Queue Position X1-114 Sandyston January 2012

Preface The intent of the System Impact Study is to determine a plan, with approximate cost and construction time estimates, to connect the subject generation interconnection project to the PJM network at a location specified by the Interconnection Customer. As a requirement for interconnection, the Interconnection Customer may be responsible for the cost of constructing: Network Upgrades, which are facility additions, or upgrades to existing facilities, that are needed to maintain the reliability of the PJM system. All facilities required for interconnection of a generation interconnection project must be designed to meet the technical specifications (on PJM web site) for the appropriate transmission owner. In some instances an Interconnection Customer may not be responsible for 100% of the identified network upgrade cost because other transmission network uses, e.g. another generation interconnection or merchant transmission upgrade, may also contribute to the need for the same network reinforcement. The possibility of sharing the reinforcement costs with other projects may be identified in the Feasibility Study, but the actual allocation will be deferred until the System Impact Study is performed. The System Impact Study estimates do not include the feasibility, cost, or time required to obtain property rights and permits for construction of the required facilities. The project developer is responsible for the right of way, real estate, and construction permit issues. For properties currently owned by Transmission Owners, the costs may be included in the study. General Green Energy Partners, LLC, the Interconnection Customer (IC), has proposed a solar generating facility located at 11 Old Dingmans Road in Layton, New Jersey. The installed facilities will have a total capability of 2.0 MW with 0.76 MW of this output being recognized by PJM as capacity. This means that the remaining 1.24 MW will be curtailable should a system reliability constraint occur. Attachment facilities and local upgrades (if required) along with terms and conditions to interconnect X1-114 will be specified in a separate two party Interconnection Agreement (IA) between FirstEnergy and the Interconnection Customer as this project is considered FERC nonjurisdictional per the PJM Open Access Transmission Tariff (OATT). From the transmission system perspective, no network impacts were identified as detailed below. Point of Interconnection X1-114 will interconnect with the Jersey Central Power & Light system at the 12kV circuit #17302 from the Holiday Lakes substation. PJM Interconnection 2012. All rights reserved. 1 PJMDOCS-#683053-v1

FirstEnergy Analysis This area is presently served by Distribution circuit 17302; a 3-phase 12.47kV grounded Wye distribution circuit originating from JCP&L s Holiday Lakes substation located about 7.4 miles from the proposed site. Circuit protection and coordination Main Line To accommodate the proposed 2 MW capacity, JCP&L will replace 65 K fuse with 140 K at UT4-1/2SDH149 to coordinate with 100 K fuse of customer s service pole and we will replace existing 200 Amp Reclosure with a 400 Amp reclosure at UT2SDH234 pole. JCP&L will extend 150 of 3-phase line and install a service pole for IC. IC will coordinate his MV breaker protective relays with the upstream protective devices back to the Holiday Lakes substation. Take note: POI will be 1 span in from pole NJ70SD. From POI it will be the Developer s responsibility to get to his site. He will be responsible for ROW, Permits, Environmental issues & Environmental permits. He will also be responsible for building and maintaining the line. See map at end of report for details At Substation JCP&L will replace (2) existing electro-mechanical relay package with an (2) SEL-351 electronic relay on the 17301,17302 distribution circuits. JCP&L will remove the existing relays and wiring, provide cabling, test switches, auxiliary relays and conduit. Based on the MW capacity of the customer s system, it will not back feed to the JCP&L 34.5 KV system. At PV Facility SCADA Control System The Developer will be responsible for designing, furnishing and installing a SCADA RTU system connected to its interconnection breaker and install the telecommunication circuits necessary for the RTU to provide information to the JCP&L s Regional Dispatch Office. The Developer must be responsible to have trained technical personnel on RTU equipment. This is necessary to have discussions with JCP&L RTU technicians. RTU technicians have a language of their own which requires trained personnel. The information on the RTU will include, but not limited to: 1. Request to trip only (not to close) developer s breaker. 2. Status points as follows: a. open/closed indication on developer s breaker b. on/off indication for generation c. on/off indication for EMS/RTU d. transfer trip and/or comm. trouble status as required 3. Analog points are as follows: a. KW Total PJM Interconnection 2012. All rights reserved. 2 PJMDOCS-#683053-v1

b. KVAR Total c. Phase amps d. Phase volts FirstEnergy currently requires a 4-Wire Analog Data Circuit for SCADA communications. This is commonly referred to as an "FDDA" type circuit in the Verizon network, or as an "FDDX" circuit in the Century Link and Frontier networks. This is essentially a non-conditioned point-topoint 4-Wire circuit which is set up with 0dB transmit and -16dB receive transmission levels. Once installed, it is important to verify that the telephone company has performed end-to-end transmission testing to ensure circuit continuity and correct levels. In fiber optic applications, the DTE must be able to provide access to tap points for sealing current to drive the optics at the demarcation point (specify Westell models 4368-02, 5496LGI2, 5497FA I3, or Verizon # 934461). In all cases, the developer will need to obtain a street address for the substation in order to fulfill E911 requirements prior to placement of the circuit orders. The developer must install and maintain the SCADA control system equipment. Equipment needed inside JCP&L facilities will be installed by JCP&L personnel. Periodic testing of the system will be required and the system must be configured to fail in a trip condition- i.e. upon loss of communications, the system must trip the generator off line. The RTU, the communications channel and all related equipment will be furnished and maintained by the generator owner. The RTU must communicate with the FirstEnergy EMS via DNP 3.0 protocol. Typically, these systems utilize fiber optic or a leased phone lines. FirstEnergy will document this circuit in our system, so please provide a contact name / number for future maintenance and repair, as well as the circuit ID when it is obtained from the telephone company. A 202T type modem is required to interface to the SCADA circuit. Depending upon the type of RTU being installed, the developer may be able to have it configured with this modem functionality built in, so that an external modem is not required. If this is not the case, an external modem will be required, and will interface to a serial port on the RTU. FirstEnergy requires the RTU to support DNP3 protocol for interface with the EMS system. The developer will be provided with a coding sheet by our SCADA engineering group which will provide RTU point configuration information JCP&L must approve the system before purchasing equipment. Distributed Generation must not interfere with the proper detection and clearing of faults on the First Energy system. At PV Facility Anti-Island Protection The solar panel must be equipped with adequate protection to detect an island condition and disconnect from the FirstEnergy distribution system within two seconds of the formation of an island (per IEEE 1547). The anti-islanding requirement can be met by the inverter being certified to pass an antiislanding test. JCP&L to witness test this functionality. PJM Interconnection 2012. All rights reserved. 3 PJMDOCS-#683053-v1

Revenue Metering Requirements: The FirstEnergy Revenue Metering Requirements may be found in the FirstEnergy Requirements for Transmission Connected Facilities document located at the following links: www.firstenergycorp.com/feconnect http://www.pjm.com/planning/design-engineering/to-tech-standards.aspx Attachment F : Titled FirstEnergy Revenue Metering Requirements for Generation Facilities Connected 46 KV and Lower. Right of Way Requirements JCP&L shall not be required to extend or relocate its facilities for the purpose of rendering Service to Applicants or Developers until rights-of-way or easements satisfactory to the Company have been obtained from government agencies and property owners to permit the installation, operation, and maintenance of the Company's lines and facilities. Individual Applicants or Developers and developers requiring an extension or relocation of the Company's facilities in order to obtain Service shall perform all initial vegetation clearance, Environmental Issues, and grant to or obtain for the Company, without charge, all necessary rights-of-way or easements for its lines and facilities to be placed upon, over, across, or under property as necessary to provide the Service. The Company shall also be granted the right to trim or remove vegetation and to remove structures or other obstructions that might subsequently interfere with such lines and facilities, the right of access and entry without notice for Company agents and equipment necessary in the exercise of privileges under the grant, and the right to use and extend the Company's lines and facilities, and install additional lines and facilities, as deemed necessary by the Company in order to provide Service to other Developers. Any right of way or permit fees, either initial or recurring, or charges in connection with rights of way for providing Service to an Applicant or Developer, shall be paid for by the Applicant or Developer. Reactive Power Capabilities This includes the provision of a reactive power capability sufficient to maintain a composite power delivery for the facility at the interconnection point at a power factor between.95 leading and.95 lagging. If this capability cannot be provided by the solar units, a dynamic device such as a STATCOM or SVC must be installed at the project substation at the customer s cost. Curtailment Issues The installed facilities will have a total capability of 2 MW with 0.76 MW of this output being recognized by PJM as capacity. This means that 1.24 MW will be curtailable at the direction of PJM or FirstEnergy. Customer Issues The generator shall not be a source of excessive harmonic voltage and current distortion and/or voltage flicker. If high/low voltage or objectionable flicker arises due to the normal operation of the generator or the frequent starting and stopping of the generator, the IC may be required to disconnect its generation equipment from FE system until the problem is fully resolved. The PJM Interconnection 2012. All rights reserved. 4 PJMDOCS-#683053-v1

percent voltage difference at the point of interconnection (POI) shall not be greater than 3% of the prevailing voltage level. Environmental Detailed environmental permitting assessments of the POI will need to be conducted. If extensive field work and permitting is required significant additional costs of up to 50k (plus gross up) will be added to the estimate. In addition, if it is determined that NJDEP permits are necessary at least 12 months lead time is required. The Developer is responsible for all permitting required for developer facilities up to the POI. Additional Requirements JCP&L will work with the developer to determine the exact interconnection point, based on existing infrastructure layout. Interconnect Customer will install a pole adjacent to JCP&L s pole as point of interconnection. On this pole the IC will install cutout fuses with load break capability, primary metering transformer bracket with associated equipment and wiring per the FE Construction Standards of page# 10-347 or 10-340. JCP&L will install and purchase the revenue metering CT s and PT s. which is based on the ratio and accuracy specifications of the developer load and generation levels. This cost is paid by the developer. IC provides all trenching, cables and conduit from JCP&L s point of interconnection pole to connect his PV generation facilities. IC must meet all applicable JCP&L/FirstEnergy standards and requirements which are included in the current Tariff for Service. IC s inverter-based generation must be UL listed or certified to comply with the requirements of IEEE 1547. IC s main breaker shall have a SEL 351 Multi-function relay (or equivalent) which is required for interconnection protection. The main breaker must be on the high side of the developer s transformer. All breakers, lightning protection etc. should meet JCP&L/FE s minimum BIL Ratings. The IC s transformer must have a grounded Wye connection to the Utility. IC must take the generator offline when requested by JCP&L / FE for emergency circuit repairs or similar activities. IC must meet requirements of N.J.A.C. 14:4-9 ( In front of meter all power sold to PJM and interconnection standards for Class I Renewable Energy Systems), as well as IEEE 1547, and IEEE 1547.1 IC must meet applicable FE Distributed Generation Technical requirements for the interconnection of generation to the FE Distribution system. The First Energy FE Distributed Generation Technical requirements can be found at : www.firstenergycorp.com/feconnect PJM Interconnection 2012. All rights reserved. 5 PJMDOCS-#683053-v1

IC must review and comply with the FE Connection Requirements document and the Wholesale Generation Interconnection Manual. These documents can be found at: www.firstenergycorp.com/feconnect http://www.pjm.com/planning/design-engineering/to-tech-standards.aspx Infrastructure Upgrade Estimated Costs (By JCP&L): Total Estimated Costs (by JCP&L) is $408,944.00 This cost includes a CIAC (Contribution in Aid of Construction) Federal Income Tax Gross Up charge of $100,144.00 (approximately 32.43%) This tax may or may not be charged based on whether or not this project meets the eligibility requirements of IRS Notice 88-129. Breakdown is as follows: Approximate cost to install one span of three-phase conductor, one new tap pole, replace existing 65-k fuse (pole# UT4-1/2SDH149) with 140-k fuse and replace the reclosure is $84,623.00. Substation upgrade cost is $ 276,381.00. Metering costs is $34,432.00 non-refundable based on JCP&L installing and owning the equipment. Communication costs of installing SCADA system into our RDO center is $13,508.00 All JCPL costs are not subject to refundable provisions of the NJ-BPU Tariff for Electric service. All Right of Ways (ROW) are the responsibility of the IC to obtain. If, in the future, JCP&L changes it s voltage on these circuits due to upgrading to a higher voltage, the developer is responsible for any needed conversions to maintain their generation connection to JCP&L s system, i.e., new transformation and associated costs. This price is based on 2012 and 2013 labor costs and material costs. If project has work performed in 2014 additional escalation costs could occur. Note- this is an estimate based on similar work orders previously worked by JCP&L for the types of work described in the analysis above. It is accurate to within plus or minus 25 percent. Should the customer want to proceed with the connection of this facility a contract with JCPL will be developed based on these costs and a true-up of actual charges will be made at the completion of the project. PJM Interconnection 2012. All rights reserved. 6 PJMDOCS-#683053-v1

Timetable for Construction: Total time to complete this project is 12 months from receipt of Interconnect Agreement, Construction Agreement and receipt of Estimated Project Costs. JCP&L estimates 4 months after receipt of above for design work to be completed. JCP&L estimates it will require an additional 8 months to complete the identified infrastructure upgrades. PJM Interconnection 2012. All rights reserved. 7 PJMDOCS-#683053-v1

Network Impacts The Queue Project #X1-114 was studied as a 2.0MW (Capacity 0.8MW) injection into the Holiday 34.5 kv substation in the JCPL area. Project #X1-114 was evaluated for compliance with reliability criteria for summer peak conditions in 2015. Potential network impacts were as follows: Generator Deliverability (Single or N-1 contingencies for the Capacity portion only of the interconnection) Multiple Facility Contingency (Double Circuit Tower Line, Line with Failed Breaker and Bus Fault contingencies for the full energy output) Short Circuit (Summary form of Cost allocation for breakers will be inserted here if any) Not required. Contribution to Previously Identified Overloads (This project contributes to the following contingency overloads, i.e. "Network Impacts", identified for earlier generation or transmission interconnection projects in the PJM Queue) Steady-State Voltage Requirements Stability and Reactive Power Requirement (Results of the dynamic studies should be inserted here) None New System Reinforcements (Upgrades required to mitigate reliability criteria violations, i.e. Network Impacts, initially caused by the addition of this project generation) PJM Interconnection 2012. All rights reserved. 8 PJMDOCS-#683053-v1

Contribution to Previously Identified System Reinforcements (Overloads initially caused by prior Queue positions with additional contribution to overloading by this project. This project may have a % allocation cost responsibility which will be calculated and reported for the Impact Study) (Summary form of Cost allocation for transmission lines and transformers will be inserted here if any) Delivery of Energy Portion of Interconnection Request PJM also studied the delivery of the energy portion of this interconnection request. Any problems identified below are likely to result in operational restrictions to the project under study. The developer can proceed with network upgrades to eliminate the operational restriction at their discretion by submitting a Merchant Transmission Interconnection request. Only the most severely overloaded conditions are listed. There is no guarantee of full delivery of energy for this project by fixing only the conditions listed in this section. With a Transmission Interconnection Request, a subsequent analysis will be performed, which will study all overload conditions associated with the overloaded element(s) identified. PJM Interconnection 2012. All rights reserved. 9 PJMDOCS-#683053-v1