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THE APPLICATION OF KENTUCKY POWER

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to lower non-union labor rates and avoiding an SCR. Avoiding an SCR in Dominion reduces Overnight capital costs by approximately $24 million, while avoiding dual-fuel capability in the Rest of RTO area reduces capital costs by approximately $19 million. These corresponding level-nominal costs are shown in Table 1. Table 1 also shows the CONE estimates Power Project Management (“PPM’) provided to PJM in 2008. PJM stakeholders agreed to use those estimates for setting points on the VRR curve by discounting them by 10 percent and then escalating them with the Handy-Whitman Index. To facilitate a more direct comparison of the PPM study to ours, we present the PPM results without discount, and inflation adjusted to 2015 dollars. As such, our level-nominal estimates are $19 to 23/kW-year ($53 to 62/MW-day) lower than the PPM estimates in the three CONE Areas reported. Ourestimatesarelowerprimarilyduetoreductionsinequipment,materials,aridlabor costs since 2008 relative to inflation, as well as economies of scale associated with the larger size of the GE 7FA.05 turbine compared to the previously examined GE7FA.03 turbine model. Finally, Table 1 also shows the CONE PJM has applied in its recent auction for the 2014/15 delivery year, escalated for one year of inflation to represent 2015/16 dollar values. Total Plant Capital Cost ($W Jiine I, 201.7 Oilline Date (201.7$) Net Summer Overnight Fixed O&M ($ltbV-y) $157 $15 8 $152 $15 1 $147 After-Tax WACC V%) 8 47% 8 49% 8 46% 8 44% 8 54% 8 07% 8 09% 8 11% Levelized Gross CONE Level Real Level Nominal PJM 2014/15 CT CONE ($/k PV-y) Escalated at CPI forI Yeat $142 1 $131 4 $135 0 $131 4 $131 5 CONE Area ICAP ( M y 390 390 390 390 392 Cost ($/kCV) $791 2 $7226 $7373 $7682 $6498 Brattle 2011 Estimate ($/k W y ) $1120 $1034 $103 I $1086 $928 ($/k FV-y) $1340 $1237 $123 5 $130 1 $1110 $154 4 $142 8 $146 1 1 Eastern MAAC 2 Southwest MAAC 3 Rest of RTO 4 Western MAAC 5 Dominion $308 3 $281 5 $287 3 $299 3 $254 7 Power Project Management, LLC 2008 Update Jiiiie 1.2005OnlineDate(EscalatedatCPlfioin2008$to2015$) 1 Eastein MAAC 2 Southwest MAAC 3 Rest of RTO $350 3 $322 1 $332 5 336 $1,0422 $172 336 $9584 $175 336 $9894 $153 Table 1 Recommended Gas CT CONE for 2015/16 Sozrrces atid Notes: Overnight costs are the sum o f nominal dollars expended over time and exclude interest during construction. Dominion estimate excludes an SCR; with SCR CONE increases to $100NkW-year level real and $120.6/kW-year level nominal. Rest of RTO CONE is for single fuel; dual-fuel CONE would be $llO.7/kW-year level real and $132.S/kW-year level nominal. PPM’s estimates shown here were discounted by 10% in settlement and escalated at the Handy-Whitman Index for setting the administrative gross CONE parameters over the 2012/13 through 2014/15 delivery years PJM Interconnection, L.L..C. (201 Id), p. IO; Power Project Management (2008). PPM’s numbers are escalated according to historical inflation over 2008-201 1 and at 2.5% inflation rate over 201 1-2015, see Federal Reserve Bank o f St. Louis (2011) and Section V1.A. Table 2 shows our recommended 2015/16 CONE for gas CC plants. These estimates are compared to the most recent estimates developed by Pasteris Energy for PJM in 2011. In each location, the gas CC plant is configured with an SCR. The plants have dual-fuel capability in all CONE Areas except in the Rest of RTO Area. Avoiding dual-fuel capability in the Rest of RTO Area reduces capital costs by approximately $18 million. 2

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