Supplemental Project Planning Process Under Order 890 Within PJM Gary e. guy, assistant general counsel Exelon corporation - views expressed are solely those of Mr. guy - Energy Bar Association

Order 890 Finds a “Substantial Need for New Infrastructure” (P 3) FERC acts under Section 217 of the FPA to facilitate “the planning and expansion of transmission facilities to meet the reasonable needs of lse’s.” Order No. 890, p 425. Energy Bar Association 2

PJM Supplemental Projects Fall Within Order 890 Supplemental projects in pjm are defined as “expansion and enhancement projects” that are not among the categories that are subject to pjm board approval or mandated by states. PJM only has planning authority for certain categories of projects (Reliability, Congestion Mitigation, and Operational efficiency) that the to’s voluntarily ceded to pjm, and by law no rights can be involuntarily transferred from transmission owners to pjm. Atlantic city v. ferc, 295 F.3d 1 (d.c. cir. 2002). A project that might otherwise be a Supplemental Project is included as a PJM RTEP baseline project if it is listed under Transmission Owner-driven criteria on FERC Form No. 715. For example, each utility sets voltage limit criteria on bulk and lower voltage systems, and specialized criteria, such as that no single contingency shall cause a thermal overload, cause a state of instability, or exceed voltage reliability criteria. Energy Bar Association 3

A New Order 890 Planning Process is Getting Underway for Supplemental Projects In 2018, Ferc approveD a section 205 tariff filing by pjm Transmission owners to improve the order No. 890 planning process for supplemental projects subject to certain changes that Were submitted in a compliance filing that Was approved. Monangahela power co., 162 FERC ¶61,129 (2018); reh’g denied and compliance filing approved, 165 FERC ¶61,217 (2018). Energy Bar Association 4

New Attachment m-3 provides for the following steps for supplemental projects (First, assumptions): 20-day advance Posting of assumptions meeting information convening of assumptions meeting Stakeholder comments up to 10 days thereafter This meeting addresses planning criteria assumptions, prioritization for replacement, ranking of assets, and assessment methodologies. Energy Bar Association 5

New Attachment m-3 provides for the following steps for supplemental projects (Second, needs): 10-day advance posting of needs meeting with slides needs meeting for to and stakeholder needs presentations Comments up to 10 days thereafter Stakeholders learn the needs the PJM Transmission Owners have identified, and the Transmission Owners learn the needs of stakeholders. These needs include increased customer expectations on service reliability, degrading equipment performance and condition, improving the resilience and security of the grid to be able to protect against growing severe threats, and meeting the demands of economic growth. Energy Bar Association 6

New Attachment m-3 provides for the following steps for supplemental projects (third, solutions): 10-days advance posting of solutions meeting with slides solutions meeting for solutions presentations by transmission owners and stakeholders comments up to 10-days thereafter. Energy Bar Association 7

Attachment m-3 provides for the following steps (fourth, selection): Pjm no-harm analysis of potential solution posting of selected solution stakeholder comments up to 10-days prior to local plan submission submission of local plan to pjm for integration into rtep. Energy Bar Association 8

Five Supplemental Project Drivers # Driver Definition 1 Equipment Material Condition, Performance and Risk Degraded equipment performance, material condition, obsolescence, equipment failure, employee and public safety and environmental impact. 2 Operational Flexibility and Efficiency Optimizing system configuration, equipment duty cycles and restoration capability, minimize outages. Energy Bar Association 9

Five Supplemental Project Drivers (Cont’d) # Driver Definition 3 Infrastructure Resilience Improve system ability to anticipate, absorb, adapt to, and/or rapidly recover from a potentially disruptive event, including severe weather, geo-magnetic disturbances, physical and cyber security challenges, critical infrastructure reduction. 4 Customer Service Service to new and existing customers. Interconnect new customer load.  Address distribution load growth, customer outage exposure, equipment loading. 5 Other Meet objectives not included in other definitions. Energy Bar Association 10