THE APPLICATION OF KENTUCKY POWER

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EXECUTIVE SUMMARY This report documents our study of the gross Cost of New Entry (“CONE”) for combustion turbine (“CT”) and combined-cycle (“CC”) power plants with a target online date of June 1, 2015, consistent with the 2015/16 delivery year in PJM’s capacity market. We prepared this study in cooperation with CH2M HILL, a major engineering procurement, and construction company with extensive experience in the design and construction of power plants, and Wood Group, a power plant operation and maintenance (“O&M’) service provider. Gross CONE includes both the capital and ongoing fixed operating costs required to build and operate a new plant. We present these estimates for consideration by PJM Interconnection and stakeholders as they update the administrative CONE parameters for PJM’s capacity market, the Reliability Pricing Model (“IWM”). The CT CONE parameter is used to define points of the Variable Resource Requirement (VRR) curve; both CC and CT CONE parameters are used for calculating offer price screens under the Minimum Offer Price Rule (“MOPR’) for new generation offering capacity into RPM. We provide separate CT and CC CONE estimates for each of the five administrative CONE Areas in PJM. Table 1 shows our recommended CONE for gas CT plants in each CONE Area based on levelized plant capital costs and annual fixed operation and maintenance (“FOM”) costs for the 2015/16 delivery year. The table shows the major components of the CONE calculation including overnight costs, plant net summer installed capacity (“ICAP”), annual ongoing fixed O&M costs, and the after-tax weighted-average cost of capital (“ATWACC”). Our CONE estimates are presented on a “level nominal” basis (i.e., equal payments over the plant’s economic life) as well as on a “level real” basis (i.e“p, ayments that start lower but increase with inflation over time). As we explain in our concurrent report, Second Performance Assessment of PJM’s Reliability Pricing Model, August 26, 2011 (“2011 I2PM Report”), we recoininend transitioning toward using a level-real CONE for MOPR purposes; for defining the VRR curve, we also recommend transitioning to level-real contingent on the implementation of several other recommendations. Our estimates differ by CONE area due to differences in plant configuration assumptions, differences in labor rates, and other locational differences in capital and fixed costs. In each CONE area, except for the Rest of RTO area, all plants are configured with dual fuel. In addition, the CT plants are fitted with Selective Catalytic Reduction (“SCR’) in each location except in Dominion, where the current Ozone attainment status does not yet require an SCR. We also provide costs for plants with dual-fuel capability and SCRs in each Area in case future developments necessitate such investments. The Eastern Mid-Atlantic Area Council (‘‘Eastern MAAC” or “EMAAC”) and Western MAAC regions have the highest CONE estimates at $112/kW-year ($307/MW-day) and $109/kW-year ($298/MW-day) respectively on a level real basis. The Southwest MAAC and Rest of RTO areas are somewhat lower, both at $1OYkW-year ($283/MW-day), primarily because of the non- union labor availability in Southwest MAAC and the lack of dual-he1 capability in the Rest of RTO region. The lowest CONE estimate is in Dominion at $93/kW-year ($254/MW-day), due 1

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