Constructability Analysis

Transcription

1 Artificial Islad-Red Lio 500kV Trasmissio Lie New Castle Couty, Delaware ad Salem Couty, New Jersey GAI Project Number: C May 2014 Prepared for: PJM Itercoectio, LLC 955 Jefferso Aveue Valley Forge Corporate Ceter Norristow, Pesylvaia Prepared by: GAI Cosultats, Ic. Pittsburgh Office 385 East Waterfrot Drive Homestead, Pesylvaia

2 Page i Table of Cotets 1.0 Executive Summary Project Overview Detailed Scope Descriptio Regulatory Risk Route Aalysis Approach Desktop Review Study Area Evirometal Features Rare, Threateed, ad Edagered Species Timig Costraits Cultural Resources Federal, State, ad Local Evirometal Permits Federal Permits State Permits Local Permits/Authorizatios Potetial Risks Project Complexity Schedule Aalysis ad Assessmet Cost Aalysis ad Assessmet Summary ad Closig Tables Figures 2014 GAI Cosultats, Ic.

3 Page ii LIST OF TABLES Table 1 Table 2 Table 3 Table 4 Table 5 Evirometal Features Summary by State Federally ad State Listed Threateed ad Edagered Species by State Prelimiary Permits, Authorizatios, ad Clearaces Egieer s Opiio of Probable Costructio Cost Costructability Review Summary

4 Page iii LIST OF FIGURES Figure 1 Figure 2 Figure 3 Figure 4 Evirometal Features Map Lad Use Map Natioal Register of Historic Places Properties ad Archaeological Sites Coceptual Project Schedule

5 Page Executive Summary I April 2013, PJM Itercoectio, LLC (PJM) requested techical solutios for improvig PJM operatioal performace i the Artificial Islad area uder a rage of aticipated system coditios ad to elimiate potetial plaig criteria violatios. I respose to the Artificial Islad-Red Lio Widow, PJM received coceptual desig level proposals from five (5) developers for the desig ad costructio of a 500kV trasmissio lie betwee Public Service Electric ad Gas Compay s (PSE&G s) Salem ad Hope Creek Substatios, which are located at Artificial Islad i Salem Couty, New Jersey (NJ), ad Delmarva Power & Light s Red Lio Substatio i New Castle Couty, Delaware (DE). The project is geerally referred to as the Artificial Islad-Red Lio 500kV Trasmissio Lie. GAI Cosultats, Ic. (GAI) was retaied by PJM to perform Coceptual Desig level costructability aalyses o the five (5) developers proposals that were received. The purpose of these aalyses was to verify overall costructability of the proposed projects withi the cost ad schedule provided ad to idetify sigificat risks ad impedimets to costructig the projects i the maer they are proposed. The assessmet of these proposals with regard to their ability to address electrical system eeds or reliability is ot icluded i the scope of this study. Based o our high-level review ad aalysis of the proposed projects it was determied that while costructio of the proposed trasmissio lie would most likely be feasible, the existece of several potetial risks to costructig the project could affect both the costs ad schedules that have bee proposed. These risk factors iclude potetial public oppositio, costructio difficulty, evirometal costraits, property acquisitio, ad outage availability. Also, the ladscape crossed by the lie route itroduces a umber of costructio challeges icludig: difficult access to structure locatios, where the extesive use of swamp mats will be required; the use of crae helicopters for structure istallatio; ad the istallatio of structures ad foudatios i the Delaware River. Proposed expasios ad/or modificatios to Red Lio, Salem, ad Hope Creek Substatios, which vary cosiderably betwee the proposals, appear to be feasible based upo the prelimiary desigs submitted. However, difficulty i obtaiig the outages that would be required to complete the costructio of these proposed facilities could jeopardize completio of the project withi the plaed schedule ad budget. Coordiatio with the icumbet substatio owers would be ecessary before a fial desig ca be developed. Detailed descriptios of all proposed modificatios are icluded i the Project Complexity sectio of this report. GAI also evaluated the proposed schedules ad cost estimates provided by each of the developers ad provided a opiio as to whether or ot each compoet was reasoable compared to idustry stadards, while also takig ito accout project-specific factors such as outage eeds, permittig duratios, ad difficult access to certai areas of the proposed projects. 2.0 Project Overview The proposed lie routes for all five (5) projects ru parallel to the existig Hope Creek-Red Lio 500kV trasmissio lie for essetially their etire 17-mile legths. The routes begi at Salem Substatio i Salem Couty, NJ ad exted approximately 12 miles to the orth before turig west ad cotiuig for approximately five (5) miles to Red Lio Substatio. The latter segmet icludes a 2.5-mile log crossig of the Delaware River. Withi the first 12 miles the lie crosses approximately six (6) miles of coastal wetlads, ad 2.5 miles of the lie passes through the Supawa Meadows Natioal Wildlife Refuge. Right-of-way (ROW) widths proposed by the developers raged from 145 to 200 feet.

6 Page Detailed Scope Descriptio The scope of this costructability aalysis for the proposed Artificial Islad-Red Lio 500kV Trasmissio Lie project was to idetify potetial risks ad impedimets to costructig the project i the maer proposed by the various developers. GAI evaluated each of the proposed coceptual desigs to idetify specific risks ad costraits that could adversely affect the ability of the developer to costruct the project withi the proposed schedule ad budget. We coducted a high-level evirometal due diligece review of the proposed project to idetify potetial key compliace issues ad idetify potetial regulatory risks, based o a desktop aalysis of publicly available data. Permits that will be complex ad require log lead times were idetified. The timeframes proposed by the developers for key activities were reviewed to determie if the duratios for ROW procuremet, permit acquisitio, regulatory approvals, material procuremet, ad costructio were cosistet with geeral idustry duratios. Fially, the proposed cost estimates were reviewed to determie if the proposed costs alig with idustry stadards. GAI also evaluated the costructability of the all proposed substatio modificatios at Red Lio, Salem, ad Hope Creek substatios, ad assessed the degree to which outages would be required i order to complete the work. 4.0 Regulatory Risk Our iitial high-level desktop aalysis was accomplished through a review of publicly available data as refereced below. No formal cotact has bee made with local, state, or federal agecies. Actual evirometal scope, schedule, ad costs would be subject to a broad rage of variables. To allow for the appropriate use of the iformatio i this report, supportig assumptios are provided, ad the resources ad approach used for specific aalyses are discussed. 4.1 Route Aalysis Approach The approach for regulatory aalysis of the proposed Artificial Islad-Red Lio 500kV route icluded three (3) primary tasks: 1) desktop review; 2) idetificatio of key evirometal permits ad authorizatios; ad 3) assessmet of potetial risks. These three (3) tasks are further discussed i the sectios that follow. 4.2 Desktop Review Usig the redigitized ad remapped ceterlie icorporatig the existig Hope Creek-Red Lio 500kV route aligmet show i Figure 1, quatitative evirometal feature iformatio was derived from several govermet databases ad collated by federal, state, ad couty. The databases icluded: Uited States Geological Survey (USGS) Lad Use/Lad Cover (LULC); USGS Natioal Elevatio Data; Uited States Fish ad Wildlife Service (USFWS) Natioal Wetlads Ivetory (NWI); ad Evirometal Systems Research Istitute (ESRI) Waterbodies. Quatitative iformatio (legths, acreages, ad/or umber of crossigs) derived from the above-listed databases pertaied to the followig features o the proposed ceterlie: state ad federal lad; wetlads ad forested wetlads; prime farmlad; forest lad; agricultural lad; residetial areas; commercial areas; ope water, pereial ad itermittet waterbodies; railroad crossigs; ad road ad highway crossigs Study Area Based o iformatio preseted i five (5) developers proposals received by PJM, the study area was defied as a 2,000-foot wide corridor cetered o the proposed Artificial Islad-Red Lio 500kV Trasmissio Lie. The study area is iteded to permit expasio of the existig Red Lio corridor ad accommodate aligmet adjustmets as eeded, regardless of which side of the existig 500kV lie the ew lie would be costructed.

7 Page Evirometal Features A quatitative aalysis of the proposed Artificial Islad-Red Lio 500kV Trasmissio Lie route was performed to assist the idetificatio of major evirometal features ad to provide a quatitative features base for the extrapolatio ad derivatio of future costructio, permittig, mitigatio, ad lad costs studies for the overall project. A summary of the quatitative evirometal features iformatio is preseted by state i Table 1. The database source for each type of iformatio is also listed. Those features that have a particularly sigificat direct or idirect bearig o the evirometal aspects of project developmet are discussed further below Collocatio with Existig ROW The proposed Artificial Islad-Red Lio 500kV Trasmissio Lie parallels the existig Red Lio-Hope Creek 500kV trasmissio lie corridor for the etire 17.3 miles. Collocatio of this extet has sigificat evirometally advatages from a impact reductio ad cosequet permit acquisitio stadpoit. Additioally, parallelig the existig electric trasmissio ROW will limit the eed to ivolve ew ladowers Public Lads Crossig of public lads, especially federal ad state maaged lads, ivariably raises cocers regardig regulatory requiremets, cosultatios, ROW approvals, ad subsequet operatio ad maiteace activities. This cocer is heighteed by the evirometal sesitivity attached to areas that support sesitive atural resources ad/or recreatioal usage. The proposed project study corridor crosses three (3) federally maaged properties located withi the NJ State boudaries: USFWS Supawa Meadows Natioal Wildlife Refuge, USFWS Artificial Islad ad Uited States Army Corps of Egieers (USACE) Killcohook Coordiatio Area (formerly Killcohook Migratory Bird Refuge). O October 30, 1998, the USFWS jurisdictio over Killcohook Migratory Bird Refuge was revoked (Public Law , Sec. 203). Killcohook Coordiatio Area is used by the USACE to deposit dredged soil. The proposed trasmissio lie crosses approximately 17,000 feet of federal lad, which accouts for approximately 19 percet of the overall trasmissio lie route. The followig publicly accessible state lads located i Salem Couty, NJ that are crossed by the proposed trasmissio lie route were idetified: Alloway Creek Restoratio Site (total crossig legth is approximately 10,900 feet), Abbotts Meadow Wildlife Maagemet Area (WMA) Site (total crossig legth is approximately 6,300 feet) ad Mad Horse Creek WMA Site (total crossig legth is approximately 8,600 feet). State lad crossigs total about 25,800 feet for approximately 28 percet of the overall trasmissio lie route. No crossigs of local govermet lad were idetified. I total, federal ad state lad crossigs accout for approximately 47 percet of the overall trasmissio lie legth. Potetial risks associated with the crossigs of the above-refereced public lads are discussed i Sectio 4.4 of this costructability report Wetlads NWI data were gathered for the proposed route ad orgaized by wetlad type ad acreage crossed for each state (See attached Table 1). I terms of the umber of crossigs, freshwater emerget wetlads (35), ad freshwater-forested wetlads (27) are essetially equally represeted; freshwater scrub-shrub wetlads (11) ad freshwater pods (11) are much less commo alog the project route. This patter is also reflected i total crossig distace, where emerget ad scrub-shrub wetlads are co-domiat (56,517 feet ad 52,589 feet, respectively) while forested wetlads accout for oly 4,967 feet.

8 Page 4 Alog the Delaware River coastlie, the approximate 35 estuarie ad marie deepwater/wetlads crossed are characterized by a estuarie system comprised of deepwater tidal habitats ad adjacet tidal wetlads that vary i saliity. Approximately 10 miles (58 percet) of the 17.3 mile trasmissio lie route is domiated by estuarie ad marie deepwater/wetlads. The attached Figure 1 reflects the wetlad types iheret to the Delaware River coastlie through which the proposed route crosses. I additio to the eed to adopt special costructio techiques for specific wetlad types ad field coditios, the type of wetlads ecoutered has sigificat implicatios from a permittig ad compesatory mitigatio perspective. I geeral, forested wetlads ted to be cosidered a more sesitive, higher quality resource tha other wetlads types because of their ecological diversity, comparative rarity, ad log recovery time followig clearig. Whereas ROW clearig of emerget ad scrub-shrub wetlads for power lie istallatio is usually (but ot always) cosidered temporary, clearig of forested wetlads is ofte regarded as permaet, because of the short- ad mid-term coversio to emerget or scrub-shrub form with oly a log term trasitio back to forested status. From a regulatory perspective, clearig of forested wetlads ca require o-site tree replatig ad off-site compesatory mitigatio ivolvig restoratio ad/or creatio of wetlads or purchase of credits i a wetlads mitigatio bak. Typically, replacemet acreages for forested wetlads are higher tha those for emerget or scrub-shrub wetlads, with ratios as high as 4: Waterbodies The umber of blue lie waterbodies crossed by the proposed trasmissio lie route through review of the USGS topographic route maps (1:24,000) is approximately 59. Table 1 lists, by State, the estimated umber of waterbody crossigs. Waterbodies crossed iclude Delaware River, Alloway Creek, Mill Creek, ad multiple uamed tributaries. However, the Delaware River is a major waterbody crossig that will require coordiatio with multiple agecies ad will ivolve protracted regulatory reviews ad attract public iterest. Agecies likely to review desig ad costructio plas specific to the Delaware River crossig iclude USACE, USFWS, Natioal Marie Fisheries Service (NMFS), Uited States Coast Guard (USCG), ad a host of state agecies. No Natioal Wild ad Sceic Rivers or 303(d) listed impaired waters are located withi the project study area Lad Use LULC digital data from the USGS Natioal LULC Database were overlai oto the route to idetify ad quatify lad use types by footage ad acreage. Lad use types iclude forested, agricultural, urba, ragelad, barre ad residetial. The LULC iformatio is summarized i Table 1. Mapped lad cover types are depicted o the attached Figure 2. The proposed trasmissio lie route, which is collocated with the existig Hope Creek-Red Lio 500kV trasmissio lie corridor, primarily crosses cultivated ad herbaceous lad cover. Agricultural ad ragelad together characterize approximately 64 percet of the proposed route. The cultivated lad is characterized by row crops such as cor ad soybea. The ragelad is primarily used for cattle grazig. The remaiig 36 percet is comprised of forested (9 percet), urba (12 percet), barre (1 percet) residetial (5 percet), commercial (2 percet) ad other (7 percet). The proposed trasmissio lie route crosses over oe (1) historic property as show o Figure 2. This property is discussed i Sectio Rare, Threateed, ad Edagered Species The assessmet sought to idetify federal ad state-listed threateed, edagered, ad special cocer species that may occur withi the proposed project study area. The review icluded

9 Page 5 publicly available databases maitaied by the USFWS, NJ Departmet of Evirometal Protectio (NJDEP)-Divisio of Fish ad Wildlife (DFW), ad DE Natural Resources ad Evirometal Cotrol (DNREC-DFW). Although o agecies were formally cosulted, database research cocluded that four (4) federally-listed ad 30 state-listed edagered, threateed, or cadidate species could potetially occur i the viciity of the proposed route. Of these 34 species, two (2) are both federally ad state-listed. The attached Table 2 lists threateed ad edagered species havig potetial to occur withi the project study area by state. Note that o public iformatio specific to New Castle Couty, DE was available. The listed species umbers idetified above for Salem Couty, NJ represet a worst case sceario, i so much as they are based o couty-wide listigs ad are ot ecessarily idicative of the umbers of species frequetig the arrower locale represeted by the proposed trasmissio lie corridor. Some of these species could be elimiated from further cosideratio at a early stage i the cosultatio process based o kow patters of spatial distributio ad habitat prefereces. For those species that have a higher probability of occurrig i the project area, USFWS ad/or state wildlife agecies may require field surveys to the cofirm the presece or absece of suitable habitat ad/or actual idividuals. The federal-listed species are cosidered higher probability species that could possibly, but ot ecessarily, require surveys ad/or additioal cosultatios. Surveys may be required for both wildlife ad plat species. Although there are o critical habitats idetified withi the project study area, if a protected species or suitable habitat is idetified durig field surveys, specific mitigatio measures may be required (e.g., timig restrictios, buffer zoes). However, i the absece of project-specific agecy cosultatio, the predictio of survey ad mitigatio requiremets is ucertai Timig Costraits Costructio schedules ca be iflueced by agecy-imposed timig costraits. Timig costraits are a form of mitigatio that avoids or miimizes potetial impacts to sesitive species by prohibitig or limitig the extet or ature of costructio i specific areas durig sesitive periods of the orgaism s life cycle (e.g., durig seasoal breedig, estig, or spawig seasos). Depedig o habitat prefereces, the area of cocer may be a wide regio, such as a migratory zoe, or a particular feature type, such as a coldwater stream or forested wetlad. Differet species have idividual time widows durig which costructio ca proceed, ca proceed with limitatios, or caot proceed. Comparable time widows may vary slightly for the same species based o regioal geography ad/or differig agecy iterpretatios ad requiremets. The USFWS ad/or state wildlife agecies may apply timig costraits if federally or state-listed species are preset i or ear the project area ad would be impacted by costructio Cultural Resources Desktop backgroud research revealed the presece of five (5) Natioal Register of Historic Places (NRHP) -listed properties mapped withi a approximate half-mile radius of the proposed trasmissio lie. These historic properties cosist of the Fi s Poit Natioal Cemetery/Fort Mott State Park, Fi s Poit Rear Rage Lighthouse, Samuel Urio/Yerkes Farmstead, Bejami Holmes House, ad Samuel ad Sarah Nicholso House. The proposed trasmissio lie crosses oe (1) NRHP-listed property boudary, the Samuel Urio/Yerkes Farmstead. I additio, review of USGS topographic quadragle maps ad aerial photography reveal the presece of potetial historical resources (50 years old or older) proximal to the proposed trasmissio lie. Additioally, kow archaeological resources, as well as areas maitaiig high potetial for cotaiig urecorded archaeological sites, are located withi or adjacet to the proposed udertakig. The NRHP properties ad high probability areas are

10 Page 6 depicted o the attached Figure 3. Give the presece of kow historic properties, ad the possibility of urecorded historic properties, GAI recommeds that cosultatio be coducted with the NJDEP-Historic Preservatio Office ad the DE Divisio of Historical ad Cultural Affairs, uder Sectio 106 of the Natioal Historic Preservatio Act. Give the cultural sesitivity, cosultatio may result i the eed for ivestigatios to assess the project s potetial to impact sigificat cultural resources, icludig archaeological ad historic architectural properties withi the proposed project s Area of Potetial Effect. 4.3 Federal, State, ad Local Evirometal Permits Table 3 (attached) lists the evirometal permits, authorizatios, clearaces, ad cosultatios that will be required for the Artificial Islad-Red Lio 500kV Trasmissio Lie Project. For each authorizatio, the table idetifies the admiistratig agecy/authority, aticipated agecy review timeframe, permit fees, ad additioal iformatio to be cosidered. Give the physical ad jurisdictioal extet of the Artificial Islad-Red Lio 500kV Trasmissio Lie Project, ivolvig two (2) states ad multiple federal, state, ad local regulatory agecies, effective iteragecy coordiatio ad schedulig will be a overridig factor for successfully securig the ecessary govermetal approvals Federal Permits The proposed project would require several federal permits, authorizatios, ad cosultatios prior to costructio. These iclude, but are ot limited to: the USACE Sectio 404 permits for dredge ad fill activities i wetlads ad other waters of the Uited States, USACE Sectio 10 permits for costructio ad operatio of facilities i federally avigable waters, USFWS cosultatios/authorizatios uder Sectio 7 of the Edagered Species Act, NMFS cosultatios uder Maguso-Steves Fisheries Coservatio ad Maagemet Act, ad USCG aid to avigatio private permit. Regulatios for implemetig the procedural provisios of the Natioal Evirometal Policy Act (NEPA) allow for federal agecies to eter ito iteragecy cooperative agreemets for the purpose of documetig compliace with NEPA. These regulatios provide guidelies for determiig the lead federal agecy. The guidelies iclude factors such as the agecy s magitude of ivolvemet, project approval/disapproval authority, ad expertise cocerig the actio s evirometal effects (40 Code of Federal Regulatios ). For this project, it is aticipated that the USACE would be the lead federal agecy resposible for implemetig NEPA USACE Sectio 404 ad Sectio 10 Permits The USACE is the agecy delegated resposibility to implemet Sectio 10 of the Rivers ad Harbors Act of 1899 [33 Uited States Code (U.S.C.) 403] which prohibits the obstructio or alteratio of avigable waters of the Uited States without a permit. Additioally, the USACE has resposibility for Sectio 404 of the Clea Water Act (33 U.S.C. 1344) which regulates the discharge of dredged or fill material ito waters (icludig wetlads) of the Uited States. While the proposed project is located i two (2) states, it is wholly withi the jurisdictioal boudary of the Philadelphia District of the USACE. USACE permits pertaiig to electric trasmissio lie costructio fall ito two (2) mai categories: idividual ad atiowide. Natiowide permits (NWPs) are geeral permits coverig various commoly ecoutered activities. Electric trasmissio costructio is ofte authorized uder NWP No. 12 (NWP-12) for Utility Lie Backfill ad Beddig. NWPs ted to be faster-track permits tha idividual permits based o less extesive review ad public otice requiremets. The USACE is required to permit a project usig the least oerous permittig mechaism that ca be legally applied to a proposed activity. A idividual permit is

11 Page 7 required where a activity does ot meet a established threshold criterio (e.g., level of acreage impact) for NWP coverage. Whether idividual ad/or NWP coverage is grated is probably immaterial i terms of schedule. The atiowide permittig aveue is ostesibly fast track, with a 45-day turaroud specified by regulatio for a complete applicatio, while a idividual permit applicatio requires a 30-day public otice ad a more itesive review period of 90 to 120 days; however, for major electric trasmissio lie projects, NWP approvals ofte take as log as idividual permit approvals ad the overall review ad approval time frame may be ie (9) moths or loger. More importatly, either authorizatio is valid util state water quality certificatio is waived or grated ad the most sigificat delays may be associated with the latter process. To esure that USACE permits are secured prior to costructio start-up, early cosultatio with USACE-Philadelphia District is ecouraged to better defie the review process, iteragecy coordiatio ad applicatio requiremets USFWS Edagered Species Cosultatio ad Clearace For federally fuded or permitted projects, cosultatio with the USFWS is ecessary to esure that impacts to federally listed edagered or threateed species ad critical habitat are appropriately addressed uder Sectio 7 of the Edagered Species Act. Ulike the USACE, the regulatory boudary of the USFWS does ot exted across state lies, ad as a result will ivolve two (2) ecological services field offices: NJ ad DE Bay Estuary. Early cosultatio with each USFWS office will be of paramout importace. While publicly available data idetify federally listed species o a couty basis, more precise locatio iformatio ca be obtaied oly through formal agecy cosultatio. Agecy feedback, alog with iformatio acquired through prelimiary field recoaissace ad detailed review of maps ad aerial photographs, will be used to idetify the scope of ay subsequet species or habitat-specific field surveys that may be required. Give the limited seasoal time widows that exist for may such surveys, early plaig is vital. Likewise, costructio schedules ca be impacted by agecy-stipulated seasoal restrictios reflectig estig, breedig, ad other behavioral patters. I the absece of project-specific agecy cosultatio ad a prelimiary field assessmet of habitat availability alog the proposed project corridor, ay species-related impacts o costructio schedules caot be ascertaied. If costructio does ot start withi oe (1) year of USFWS authorizatio, the protected species assessmet must be revalidated through reewed cosultatio ad, potetially, additioal field surveys. No acute cocers relatig to edagered ad threateed listed species ad associated schedule were idetified State Permits Each of the states affected by the proposed project would require similar evirometal permits, cosultatios, clearaces, ad authorizatios, icludig: + State Historic Preservatio Office (SHPO) cosultatios ad clearaces; + Natioal Pollutat Discharge Elimiatio System costructio stormwater discharge permits; + Sectio 401 water quality certificatios; + stream ad wetlad crossig permits; + erosio cotrol permits; ad + state-protected species cosultatios.

12 Page 8 Of the above-listed permits ad authorizatios, those with most potetial to impact schedule ad cost are SHPO cosultatios ad clearaces, Sectio 401 water quality certificatio, ad stream ad wetlad crossig permits. The other approvals are relatively straightforward i terms of applicatio preparatio ad agecy review schedules, with basic similarity i techical scope betwee the states. The extet to which SHPO cosultatio ad review ca impact project cost ad schedule is very much depedet o the umber, locatio, ad sigificace of ay cultural resource sites that are ecoutered i the project area. The eed to coduct Phase II ad Phase III level surveys beyod iitial Phase I recoaissace surveys, alog with ogoig cosultatio ad reportig, ca have a substatial impact o cost ad schedule. Phase III data recovery ca be a legthy process, the eed for which ca be determied oly after Phase I ad Phase II surveys have bee udertake ad the project is well-advaced. State Sectio 401 water quality certificatio or a waiver of certificatio is required for all Sectio 404 dredge ad fill activities permitted by the COE. Pre-approved Sectio 401 certificatio is available for certai Sectio 404 NWPs o a state-by-state basis. Ofte regioal coditios or exceptios apply. Agecy respose timeframes for Sectio 404 certificatio vary from state-to-state ad are ot ecessarily set by regulatio. Protracted resposes may occur, especially where the state works idepedetly from the USACE i prescribig or advocatig wetlad/waterbody crossig techiques or other mitigatio measures o a site-specific basis. I additio, state authorizatio of costructio i o-federally regulated isolated wetlads may be achieved directly through, or i parallel with, the Sectio 401 certificatio process. This ca add a extra layer of regulatory scrutiy to the approval process. As idicated i Table 1 ad depicted o Figure 2, the proposed project route would cross public lads maaged by the States of NJ ad DE. These iclude state wetlad restoratio sites, coservatio areas, ad WMAs. As with all properties o the proposed project route, the developer would eed to seek access permissio for pre-costructio egieerig ad evirometal surveys, as well as easemet rights before the project goes to costructio. Obtaiig survey permissio for public lad ofte ivolves a protracted bureaucratic applicatio process ad easemet acquisitio may ot be possible if the proposed project coflicts with govermet-madated use restrictios or evirometal plas. Irrespective of the sesitive atural resources or recreatioal aspects ofte associated with these areas, early cosultatio ad coordiatio is essetial. The DE River Basi Commissio (DRBC) have regulatory mechaisms i place that drive a overall state-level evirometal evaluatio i a similar fashio to a NEPA review uder Sectio 3.8 of the Delaware River Basi Compact. Additioally, NJ Board of Public Utilities Commissio (NJBPU) ad DE Public Service Commissio (PSC) will coordiate with NJDEP ad DNREC, respectively, through issuace of Certificate of Public Coveiece ad Necessity. The Artificial Islad-Red Lio 500kV Trasmissio Lie Project the permittig schedule should allow for sustaied Commissio participatio throughout the state ad federal permittig process Local Permits/Authorizatios Local evirometal permits ad authorizatios are restricted to govermetal etities withi Salem Couty, NJ ad New Castle Couty, DE where muicipalities have adopted ordiaces regulatig lad use. No specific schedule costraits are aticipated with respect to lad use approvals. 4.4 Potetial Risks Eight (8) critical costraits were idetified for the proposed Artificial Islad Red Lio 500-kV Trasmissio Lie Project route. Of these, the most problematic is likely to be crossig of the

13 Page 9 Supawa Natioal Wildlife Refuge ad the Delaware River because of the combiatio of techical ad regulatory complexities associated with the combied 4.6 mile crossig of the river ad the federally protected wildlife refuge, which cotais uamed tributaries to the Delaware River ad extesive floodplais. The other critical costraits ivolve permittig of state lads ad wetlads, cultural resources ivestigatios, ad demostratio of public eed. Although these will brig regulatory ad ROW acquisitio challeges, they will ot commad the same level of attetio from the public ad regulatory agecies as the Supawa Natioal Wildlife Refuge ad the Delaware River crossig. The major potetial risks are: The project requires coastal zoe maagemet approval from NJDEP ad DNREC which may ivolve a legthy review process depedig o costructio techiques ad proposed pathways to access the ROW. The project crosses approximately 350 acres of forested wetlads that may require clearig. Compesatory mitigatio ivolvig the purchase of credits from a wetlads mitigatio bak at ratios as high as 4:1 could potetially exceed $7 millio. Approval to cross the Delaware River would ivolve federal ad state agecies coordiatio as well as public ivolvemet. Additioally, the project will eed to demostrate that it will have miimal impact o the edagered Atlatic Sturgeo. If the project becomes cotroversial, the permittig process may exted well beyod the aticipated project schedule. A ROW Permit will eed to be obtaied from USFWS to cross Supawa Natioal Wildlife Refuge. The process for obtaiig easemets o federally maaged lads is typically legthy ad complex. Similarly, acquirig easemets o state public lads (i.e., coservatio easemets, wetlad restoratio sites, ad WMAs) typically ivolve multiple reviews ad coordiatio betwee state evirometal ad real estate divisios. Historic ad archaeological ivestigatios (Phase II ad Phase III) beyod iitial Phase I recoaissace surveys, alog with ogoig cosultatio ad reportig, ca have a substatial impact o schedule ad cost. Issuace of Certificate of Public Coveiece ad Necessity by NJBPU ad DEPSC will likely occur cocurretly with approvals from USACE, USFWS, ad the state agecies. The Commissios will be hesitat to approve the project without assurace that it is beig coordiated with NJDEP ad DNREC. The results of our research regardig the potetial use of emiet domai i Delaware are icoclusive. While a recetly promulgated bill allows the use of emiet domai for utility purposes, there is ambiguity as to what this term icludes. However, sice the Delaware portio of the proposed lie is oly 0.75-mile log, crosses oly two (2) properties, ad may be able to be costructed o existig ROW, this is ot cosidered to be a substatial risk item. 5.0 Project Complexity Each of the developers proposed projects was aalyzed with regard to the complexity of their trasmissio lie desig from substatio termial to substatio termial. This aalysis cosidered parameters such as crossigs of existig trasmissio lies, the eed for raisig existig trasmissio lie structures, proposed substatio modificatios, ad ay associated outage requiremets. It should be oted that due to the fact that the developers proposals are coceptual i ature, the exact locatios of ay required crossigs are ot kow at this time. It is assumed that durig detailed desig, these locatios would be selected i such a maer as to miimize outage requiremets to the greatest possible extet. Our observatios with regard to project complexity are highlighted below.

14 Page 10 Domiio Modificatios at Red Lio Substatio Domiio has proposed modificatios to Red Lio Substatio that would ivolve major recostructio of the statio icludig the istallatio of a ew termial o the orther ed of the substatio to serve the proposed trasmissio lie. More specifically, Domiio would istall a ew row of breakers orth of the existig Hope Creek termial ad relocate the existig Red Lio-Hope Creek 5015 lie to a ew termial positio. A ew backboe would be costructed to termiate the ew 500kV lie. Costructio of these modificatios would require multiple outages o the existig Red Lio-Hope Creek 5015 lie, the duratios of which would deped o the maer i which substatio costructio is phased. Modificatios at Hope Creek Substatio Domiio proposes to expad Hope Creek substatio to the orth to accommodate a third row of breakers as well as a ew termial locatio for the proposed 500kV lie to Red Lio substatio. A proposed ew 500kV tie lie to Salem substatio would termiate o the curret ope positio of the existig 500kV backboe. Although Domiio preseted o details regardig the maer i which this tie lie would be istalled, it appears that it will eed to cross the existig geerator leads. These proposed substatio modificatios ad additios would require sigificat outages. Modificatios at Salem Substatio Domiio proposes to termiate the ew 500kV tie lie from Hope Creek substatio oto the ope positio o the existig 500kV backboe. Oe (1) 500kV breaker would be istalled betwee the ew lie ad the bus. Agai, a outage would be required to perform this work. Proposed Hope Creek-Red Lio 500kV lie The combiatio of proposed tie-i poits to the respective substatios requires that the ew 500kV lie cross the 5015 lie at some poit alog its 17-mile legth. The crossig locatio has ot bee defied by Domiio, ad could require modificatios to existig structures o the 5015 lie, which would icrease the cost ad complexity of the project. Ay outages required for costructio of this crossig, would be of miimal duratio ad could be plaed to coicide with the aforemetioed outages required for the Red Lio Substatio modificatios. PSE&G Modificatios at Red Lio Substatio PSE&G s proposes to covert the existig rig bus at Red Lio Substatio to a double breaker, double bus cofiguratio. This modificatio would require a expasio of the orther ed of the statio ad would iclude the istallatio of two (2) ew breakers ad a ew lie termial. The existig Red Lio-Hope Creek 5015 lie would be moved to the ew termial ad the proposed ew 500kV lie would termiate at the vacated positio. Costructio of these modificatios would require umerous sequetial outages, icludig three (3) outages o the 5015 lie totalig 40 days i duratio. PSE&G s proposed modificatio to Red Lio substatio would be the most impactful of ay of the proposals. Modificatios at Hope Creek Substatio PSE&G proposes to expad Hope Creek substatio by addig a ew bay o the orth ed of the substatio, which would iclude a ew lie termiatio for the proposed 500kV lie to Red Lio. A ew gas-isulated bus would tie this ew bay to a ew termiatio structure i the

15 Page 11 middle of Salem substatio, which could possibly iterfere with the existig geerator leads. Outages would be required for the expasio work ad tie-is at both substatios. Proposed Hope Creek-Red Lio 500kV lie The combiatio of proposed substatio tie-i poits selected by PSE&G at Red Lio ad Hope Creek substatios requires that the ew 500kV lie cross uder the 5015 lie just outside of Red Lio substatio. Modificatios to existig structures o the 5015 lie may be required, ad this would icrease the cost ad complexity of the project. Ay outages required for costructio of this crossig would be of miimal duratio ad could be plaed to coicide with the aforemetioed outages required for the Red Lio Substatio modificatios. LS Power Modificatios at Red Lio Substatio LS Power has proposed the additio of a ew 500kV lie termial ad breaker i the ortheast corer of the existig rig bus at Red Lio Substatio. They would the move the existig Red Lio-Hope Creek 5015 lie to this ew termial ad use the existig termial for the proposed 500kV lie. Outages would be required for expasio of the bus ad to trasfer the 5015 lie to the ew termial. Modificatios at Salem Substatio LS Power proposes to expad Salem substatio by extedig the 500kV mai busses i the existig switchyard to the orth to accommodate the proposed 500kV lie to Red Lio substatio. The low level of detail provided makes it difficult to determie whether or ot there is sufficiet room for the proposed expasio. A 500kV breaker-ad-a-half cofiguratio will service the Salem-Hope Creek bus tie while the existig bus tie termial will provide service to the ew Salem-Red Lio 500kV lie. Outages will be required to expad the bus ad to relocate the Hope Creek bus tie to the ew termial. Proposed Salem-Red Lio 500kV lie The proposed Salem-Red Lio 500kV lie would exit the substatio at the curret Hope Creek bus tie positio; the existig lattice tower just outside of Salem substatio would have to be replaced sice the lie agle will be sigificatly reduced. The ew lie would the cross both the Hope Creek-Red Lio 5015 lie ad the Hope Creek-New Freedom 5023 lie. I order to meet required electrical clearaces, both of these lies will likely eed to be raised i this area, which would require outages o both lies. Trasource Modificatios at Red Lio Substatio Trasource proposes to modify the existig rig bus to add a ew 500kV lie positio at the orthwest corer of a expaded yard. This modificatio of the bus will require a exteded outage of the 5015 lie. Modificatios at Salem Substatio A ew lie termiatio poit will be created by tappig the 500kV west bus ad istallig a 500kV breaker. Oce this work is complete, the Salem-New Freedom 5024 lie would be relocated to this ew lie positio ad the Salem-Orchard 5021 lie would be relocated to the former New Freedom positio. This work would require sequetial outages o each of these lies. After these chages are made, the existig Salem- Orchard 5021 lie positio would be used for the ew Salem-Red Lio 500kV lie. Proposed Salem-Red Lio 500kV lie Trasource plas to utilize of the first five (5) existig spas of the existig Salem-New Orchard lie as part of the ew Salem-Red Lio 500kV lie. It is assumed that these spas would eed to be recoductored to match the lie ratig of the

16 Page 12 proposed lie, possibly ecessitatig replacemet of these structures due to icreased loadig. Just beyod these spas the ew lie will cross uder the existig Hope Creek-New Freedom 5023 lie before headig orthward parallel to the existig Hope Creek-Salem 5015 lie. I order to meet required electrical clearaces, two (2) structures o the 5023 lie may eed to be raised, which would require a outage o the 5023 lie. PHI/Exelo Modificatios at Red Lio Substatio PHI/Exelo proposes to expad the substatio from a four positio, four breaker rig bus arragemet to a six positio, seve breaker arragemet. The existig feced yard would be expaded by approximately 50 feet o the orthwest ad ortheast sides, all of which would be o existig PHI property. The existig Red Lio-Hope Creek 5015 lie would be moved to this lie termial, ad the existig termial would the be used for the ew Red Lio-Salem 500kV lie. This would ecessitate the istallatio of at least oe (1) ew trasmissio structure o the 5015 lie, ad would require ad exteded outage. Modificatios at Salem Substatio - PHI/Exelo proposes to expad the existig yard to the south for istallatio of a ew lie termial positio ad breaker to serve the proposed Salem- Red Lio 500kV lie. A outage will be required. Proposed Salem-Red Lio 500kV lie After exitig Salem substatio from the ew termial positio, the proposed Salem-Red Lio 500kV lie will the have to cross four (4) existig trasmissio lies: Salem-New Freedom 5024 lie, Salem-Orchard 5021 lie, Hope Creek-New Freedom 5023 lie, ad Hope Creek-Red Lio 5015 lie. PHI/Exelo states i their proposal that all of these crossigs would be costructed uder the existig lies sice the ew circuit is beig added to alleviate cocers durig a secod cotigecy outage. I order to meet required electrical clearaces, two (2) structures each of the four (4) lies that are beig crossed may eed to be raised. This would require exteded outages o each of these lies. Additioal complexities associated with all of the proposed projects iclude the difficulties associated with costructio work i wetlads, which will require extesive swamp mat costructio for access, as well as the usage of crae helicopters for costructio i areas where lad access is especially difficult. The istallatio of approximately 2.5 miles of 500kV overhead trasmissio lie across the Delaware River, while ot uprecedeted, poses sigificat costructio challeges icludig the costructio of uderwater foudatios ear a active shippig chael. Istallatio of protective feders ad/or rubble mouds will be required to protect the structures from river traffic. Navigatio ad aviatio lightig will also be required. 6.0 Schedule Aalysis ad Assessmet A high-level milestoe schedule of all major tasks required to complete the trasmissio lie project is preseted i the attached Figure 4. Timeframes ad project sequecig are based o GAI s experiece o similar projects ad are cosistet with geeral idustry duratios. Our coceptual schedule is based o the followig assumptios: Trasmissio lie costructio duratio is based o a average costructio rate of 0.75-mile per moth. All modificatios ad expasios to existig substatios will require shorter duratios tha the trasmissio lie costructio; therefore, these activities are ot o the critical path. ROW acquisitio would begi durig the regulatory approval process, with Optio Agreemets beig executed where possible.

17 Page 13 Log lead-time materials will ot be ordered util regulatory approval is obtaied, but will be ordered prior to obtaiig all required permits. The permittig ad regulatory approval activities (total aticipated duratio of 30 moths) icludes all time required for ay ecessary public hearigs. Costructio activities would be scheduled to coicide with available outages that are ecessary to complete that specific activity. Lack of outage availability will icrease the total project legth. The coceptual project schedule developed by GAI idicates that the project will take approximately 66 moths to complete, from project iitiatio to eergizatio. There are four (4) major activities o the critical path: Sitig ad Route Evaluatio, Prelimiary Egieerig for Permittig/Regulatory Approvals, Permit Reviews ad Approvals, ad Trasmissio Lie Costructio. Delays i completig ay of these activities would jeopardize completio the project withi the estimated 66 moths. ROW acquisitio for some of the developers may take loger tha the 36 moths that is estimated, but this should ot preclude startig costructio i areas where right-of-way has already bee secured, ad will ot become a critical path activity uless major difficulties are ecoutered i property egotiatios. Outage availability is a sigificat item of risk to completig this project o schedule, with the most risk beig assiged to proposals requirig the most outages. Estimates of total project duratios that were received from four (4) of the five (5) developers raged from 48 moths to 66 moths, all of which are withi plus or mius 30 percet of our estimated total project duratio. The sole outlier was Domiio with a total project duratio of 111 moths. Domiio s schedule icludes a duratio of 78 moths for property acquisitio ad a duratio of 81 moths for regulatory approvals, both of which seem excessively log compared to the other proposals as well as our high-level milestoe schedule. The proposed schedules provided by the developers varied greatly i level of detail. Preseted below are summaries of their estimated duratios for the key tasks required to complete the project, alog with appropriate clarificatio where required. Routig ad Prelimiary Egieerig GAI estimates that ie (9) moths will be required to perform routig studies ad prelimiary egieerig. The developers proposed duratios raged from six (6) moths (Trasource) to twelve moths (PHI/Exelo ad LS Power). Domiio s proposed schedule did ot address these tasks as a separate activity. Regulatory ad Permittig (Studies, Reviews ad Approvals) GAI estimates that evirometal studies, regulatory reviews, ad permittig will require 30 moths to complete, with all of these tasks ruig cocurretly. However, it should be uderstood that the regulatory ad permittig aspect of this project carries the most schedule-related risk of ay of the required activities. The developers estimated duratios for each of these activities are summarized below. It should be oted that several of the developers have assumed that costructio of the lie will begi prior to obtaiig every required permit. This is cosidered to be a reasoable assumptio give that obtaiig permits for some portios of the 17-mile lie will be less time-cosumig tha for others. Domiio estimated 23 moths for regulatory approvals ad 24.5 moths for permittig ad evirometal studies. These activities are ot overlappig. I their writte descriptio of aticipated permits, they state that the permittig will take up to 81 moths before

18 Page 14 costructio ca begi, but they do ot reflect this i their schedule. LS Power estimated a total of 48 moths, which icludes 30 moths for pre-costructio permittig ad 18 moths for costructio permittig. PHI/Exelo estimated 27 moths for both regulatory ad permittig approvals, with these activities ruig cocurretly. PSE&G estimated 14 moths for sitig approvals ad 40 moths for permittig. Note that GAI estimates moths to obtai the permit for crossig the Supawa Meadows Natioal Wildlife Refuge whereas PSE&G estimates 30 moths ad that GAI estimates 24 moths for the Delaware River Crossig whereas PSE&G estimates 30 moths. Trasource estimated 21 moths for sitig applicatios ad approvals ad 27 moths for permittig. Some evirometal studies tasks are icluded with the sitig applicatio process as eeded. All other evirometal ad permittig activities begi ear the ed of the sitig approval process, ad costructio is slated to begi 18 moths later. Right of Way (ROW) Acquisitio GAI estimates that up to 36 moths could be required to obtai all right of way required for the project. We assumed that ROW acquisitio would begi durig the regulatory approval process with Optio Agreemets beig executed, where possible, ad that costructio could start before all ROW was acquired if the ROW acquisitio takes the full 36 moths. Followig is a summary of the developer proposals with regard to ROW acquisitio: Domiio proposes istallatio of the ew 500kV lie i a 150' wide right-of-way (ROW) o the west side of the existig 5015 lie ROW. Domiio would eed to acquire ew ROW for the etire legth of the lie, ad estimates a 81 moth time frame. LS Power will eed to procure all ew ROW for the trasmissio lie, ad estimates a 18 moth time frame to do so. They state that they will eed to acquire easemets o 15 private parcels i New Jersey. PHI/Exelo curretly has owership, easemet rights, or joit owership rights to all plaed ROW for the project. PHI is part of the Lower Delaware Valley (LDV) Trasmissio Service Agreemet. PSE&G ows or has property rights i some of the proposed ROW s. They estimate a time frame of 18 moths will be required to obtai all required ROW. PSE&G is part of the LDV Trasmissio Service Agreemet. Trasource will eed to procure ew ROW for the etire legth of the trasmissio lie. They estimate that 15 moths will be required to accomplish this task. Egieerig ad Material Procuremet GAI estimates a total of 15 moths will be required for egieerig ad material procuremet, with the ie (9) moth material procuremet activity startig upo receipt of regulatory approval. The developers proposed duratios for these activities vary betwee 19 moths (PSE&G) to 57 moths (LS Power). Domiio icluded a 13-moth duratio for egieerig i their schedule but did ot specify a material procuremet duratio.

19 Page 15 Costructio GAI estimates that physical costructio of the 500kV trasmissio lie project, icludig the Delaware River crossig, will take approximately 24 moths. It should be oted that this timeframe could be shorteed by assigig icreased mapower to the project, but this would be depedet o the availability a sufficiet workforce. The developers proposed costructio duratios vary from 12 moths (LS Power) to 24 moths (Domiio). Existig substatio ad trasmissio lie modificatios, to the extets proposed by each of the developers, should i all cases have duratios that are sigificatly less tha 24 moths; therefore, the varyig degrees of work proposed by all of the developers do ot affect the critical path. Overall Schedule Summary As stated earlier, four of the five developers proposed timeframes for completig the project were withi 30% of the total project duratio estimated by GAI. We feel that this is a reasoable level of accuracy cosiderig the may variables ad risk factors that have bee idetified ad discussed above. The critical path activity that has the most risk associated with it is Permit Reviews ad Regulatory Approvals. It will be crucial to submit permit applicatios ad regulatory filigs as early as possible i order to help mitigate that risk. A sigificat amout of risk is also associated with the potetial lack of outage availability. 7.0 Cost Aalysis ad Assessmet As part of this study, GAI performed a high-level assessmet of the coceptual cost estimates that were icluded with the developers proposals for this project. The purpose of our assessmet was to determie if the proposed costs aliged with curret idustry stadards. It should be oted that while we relied o our curret ad recet trasmissio lie desig experiece i performig our assessmet, GAI performed o desig work for this project. GAI s estimate of probable costructio cost for the Artificial Islad-Red Lio 500kV lie is $230 millio. This figure is based o a high-level assessmet of probable costs for the curret coceptual desig ad is reflective of our previous experiece with 500kV trasmissio lie egieerig ad costructio. Table 4 (attached) presets a summary of the probable coceptual costs associated with: lie routig, sitig, ad permittig; evirometal remediatio; egieerig; material procuremet; costructio of the Artificial Islad-Red Lio 500kV lie; expasio of Red Lio Substatio; project maagemet; ad cotigecies. It does ot iclude Ower s overheads or Allowace for Fuds Used Durig Costructio (AFUDC). Estimates of project cost received from the five (5) developers cotaied varyig degrees of detail ad i some cases icluded costs of facility upgrades that are ot icluded i the scope of this study. These estimates, after beig appropriately modified to reflect similar scopes of work, raged from $123 millio to $297 millio. A summary of each developer s estimate alog with appropriate commets is preseted below. Domiio s total cost estimate is $199 millio. This figure icludes $186 millio for the trasmissio lie, $11 millio for modificatios to Red Lio substatio, ad $2 millio for modificatios to Salem substatio. It does ot appear that ay cotigecy was icluded i this estimate. LS Power s total cost estimate is $171 millio. This cost is broke dow ito trasmissio lie ($118 millio), switchyard modificatios ($11 millio), ower costs ($13 millio), ad cotigecy ($29 millio).

20 Page 16 PHI/Exelo s $157 millio cost estimate icludes a $100 millio lie item for the Delaware River Crossig (all iclusive) with o further breakdow provided. PSE&G s overall estimate of $297 millio icludes overhead costs ad a 25 percet cotigecy. PSE&G s estimate also icludes a $100 millio lie item for major river crossigs icludig sitig, lad acquisitio, egieerig, procuremet, ad costructio with o further breakdow of costs. This estimate is cosidered a outlier as it is 50 percet higher tha the ext highest estimate ad approximately 70 percet higher tha the average of all other developers proposed costs. Trasource provided a estimate ragig from $123 millio to $156 millio to complete the project. The rage reflects the applicatio of various percetages of the total project cost beig added i for Project ad Costructio Maagemet, Overheads, ad Cotigecy. No costs are icluded for relocatio of several spas of the Salem-Orchard 5021 lie that are required as part of their proposed solutio. It is further oted that: Two (2) of the developers cost estimates (PHI/Exelo ad PSE&G) icluded a $100 millio lie item for istallig the Delaware River crossig, but o further cost breakdow was provided. Noe of the proposals icluded estimated costs associated with potetial modificatios to existig trasmissio lies or the replacemet of existig trasmissio structures. Lad acquisitio costs will be substatially lower for PHI/Exelo ad PSE&G. These developers are both party to the Lower Delaware Valley agreemet, while the other three (3) developers will eed to purchase all ew ROW. The estimated cost for proposed substatio expasios ad modificatios vary greatly because all five (5) developers have proposed sigificatly differet scopes of work. Domiio s ad PSE&G s proposed modificatios at Red Lio substatio are the most extesive ad costly, while LS Power s ad Trasource s proposed modificatios at Hope Creek/Salem are most impactful to the existig facilities. 8.0 Summary ad Closig Based o our costructability aalysis of the coceptual desigs proposed to PJM by five (5) developers, GAI has determied that costructio of a 500kV trasmissio adjacet to the existig Hope Creek-Red Lio 500kV lie is feasible, but will face cosiderable regulatory scrutiy ad sigificat costructio challeges. The total project duratio, from project kickoff to lie eergizatio, is estimated at approximately 66 moths, but could exted loger due to circumstaces outside the cotrol of the developers, such as regulatory approvals or outage availability. Sigificat risks that have bee idetified that may adversely affect the developer s ability to costruct the project withi the proposed schedule ad budget iclude possible difficulties i obtaiig the followig permits ad approvals: Permit to cross Supawa Natioal Wildlife Refuge; easemets o public lads; approvals required for placig structures i the Delaware River; ad obtaiig Certificates of Public Coveiece ad Necessity from NJ ad DE. Additioal risks that may affect the project iclude the challeges associated with costructio through evirometally sesitive areas ad across the Delaware River, availability of ay required trasmissio system outages, ad Edagered Species Act compliace.

21 Page 17 The above costructability aalysis is based o the curretly available documetatio. If additioal iformatio becomes available, ad as the project moves ito fial desig, modificatios to this documet may be ecessary. Respectfully submitted, GAI Cosultats, Ic. Michael T. Hor, P.E. Egieerig Maager Electrical Trasmissio Lie Egieerig

22 TABLES

23 Table 1 Evirometal Features Summary by State Evirometal Features Uit Total NJ DE Data Source Legth miles Earth Pro Adjacet to Existig ROW miles Earth Pro Federal Lads acres Uited States Departmet of Agriculture (USDA) State Lads acres USDA Local Govermet Lads acres USDA Total NWI-mapped Wetlads acres USFWS NWI NWI-Mapped Forested Wetlads 1 acres USFWS NWI NWI-Mapped Freshwater Wetlad 1 acres USFWS NWI NWI-Mapped Tidal Wetlads 1 acres USFWS NWI Blue Lie Streams 2 cout ESRI Uited States Waterbodies Natioal Wild ad Sceic Rivers cout ESRI Uited States Waterbodies Total Uplads acres USGS LULC Forest Lad acres USGS LULC Agricultural Lad acres USGS LULC Urba Lad acres USGS LULC Ragelad acres USGS LULC Barre Lad acres USGS LULC Residetial acres Earth Pro Commercial acres Earth Pro Other Lad acres USGS LULC Residetial cout Earth Pro Commercial cout Earth Pro Roads Crossed cout USGS LULC Notes: 1 2 NWI Forested Wetlads are a subset of NWI-mapped Wetlads. Icludes Waterbodies classified as Itermediate beig betwee 10 ad 100 feet i width ad Major.beig greater tha 100 feet i width.

24 Table 2 Federally ad State Listed Threateed ad Edagered Species by State Species Name Status State (Couty) Federally-Listed Sesitive Joit-vetch (Aeschymoee virgiica) Threateed NJ (Salem Couty) Swamp Pik (Heloias bullata) Threateed NJ (Salem Couty) Bob Turtle (Clemmys muhlebergii) Threateed DE (New Castle) Atlatic Sturgeo (Acipeser oxyrhychus oxyrichus) 1 Edagered NJ/DE State-Listed Woolly Three-aw Grass (Aristida Iaosa) Edagered NJ (Salem Couty) Low Rough Aster (Aster radula) Edagered NJ (Salem Couty) Erect Bidweed (Calystegia spithamaea) Edagered NJ (Salem Couty) Chiquapi (Castaea pumila) Edagered NJ (Salem Couty) Coast Flat Sedge (Cyperus polystachyos) Edagered NJ (Salem Couty) Marsh Flat Sedge (Cyperus pseudovegetus) Edagered NJ (Salem Couty) Black-fruit Spike-rush (Elecocharis melaocarpa) Edagered NJ (Salem Couty) Carolia Elephat-foot (Elephatopus caroliiaus) Edagered NJ (Salem Couty) Darligto s Glade Spurge (Euphorbia purpurea) Edagered NJ (Salem Couty) Bouquet Mud-platai (Heterathera multiflora) Edagered NJ (Salem Couty) Floatig Marsh-peyworth (Hydrocotyle rauculoides) Edagered NJ (Salem Couty) Barto s St. Joh s-wort (Hypericum adpressum) Edagered NJ (Salem Couty) Miute Duckweed (Lema perpusilla) Edagered NJ (Salem Couty) Sadplai Flax (Lium itercursum) Edagered NJ (Salem Couty) Hairy Wood-rush (Luzula acumiata) Edagered NJ (Salem Couty) Virgiia Buchflower (Melathium virgiicum) Edagered NJ (Salem Couty) Cutleaf Water-milfoil (Myriophyllum piatum) Edagered NJ (Salem Couty) America Lotus (Nelumbo lutea) Edagered NJ (Salem Couty) Virgiia False-gromwell (Oosmodium virgiiaum) Edagered NJ (Salem Couty) Souther Adder s-togue (Ophioglossum vulgatum var. pycostichum) Edagered NJ (Salem Couty) Greek-valeria (Polemoium reptas) Edagered NJ (Salem Couty) Chickasaw Plum (Pruus agustifolia) Edagered NJ (Salem Couty) Overcup Oak (Quercus lyrata) Edagered NJ (Salem Couty) Dwarf Azalea (Rhododedro atlaticum) Edagered NJ (Salem Couty) Coarse Grass-like Beaked-rush (Rhychospora globularis) Edagered NJ (Salem Couty)

25 Table 2 (Cotiued) Species Name Status State (Couty) Small Skullcap (Scutellaria leoardii) Edagered NJ (Salem Couty) Two-flower Bladderwort (Utricularia biflora) Edagered NJ (Salem Couty) Broad-leaf Iroweed (Veroia glauca) Edagered NJ (Salem Couty) Squirrel-tail Six-weeks Grass (Vulpia elliotea) Edagered NJ (Salem Couty) Sword Bogmat (Wolffiella floridaa) Edagered NJ (Salem Couty) Note: 1 Listed by NMFS as a edagered species i the Delaware River.

26 Table 3 Prelimiary Permits, Authorizatios, ad Clearaces Permit/Approval Regulatory Agecy Agecy Review Timeframe Commets Federal Sectio 404 Idividual Permit Authorizatio Sectio 10, Rivers ad Harbors Act Authorizatio Killcohook Coordiatio Area (formerly Killcohook Migratory Bird Refuge) Public Utility Easemet USACE - Philadelphia District moths 4 6 moths A NWP-12 for Utility Lie Activities may be applicable if fill of wetlads is less tha 0.5-acre. USACE review of NWP-12 Applicatio is approximately 4 to 6 moths. O October 30, 1998, the USFWS Service jurisdictio over Killcohook Migratory Bird Refuge was revoked (Public Law , Sec. 203). Killcohook Coordiatio Area is used by the USACE to deposit dredged soil. Edagered Species Act of 1973 Cosultatio ROW permit for Crossig Supawa Meadows Natioal Wildlife Refuge USFWS Northeast Regio (5) moths moths Aids to Navigatio Private Permit USCG 2 3 moths Preparatio of a Evirometal Assessmet is likely to determie compatibility with the Refuge ad to assess evirometal impacts o ad off federal lad. Edagered Species Act of 1973, Marie Mammal Protectio Act, ad Maguso-Steves Fisheries Coservatio ad Maagemet Act Cosultatio NMFS moths The Atlatic sturgeo i the Delaware River is listed as a edagered species by NMFS. Regioal Approval for Costructio i Delaware River DRBC 9 12 moths Requires the submissio of a applicatio to the DRBC for review ad approval. Projects require approval at a commissio public meetig. There are four commissio meetigs each year. The project will also require a hearig which ca occur at the meetig or ca be scheduled separately. State of New Jersey Certificate of Public Coveiece ad Necessity NJBPU moths NJBPU reviews a project for eed ad lad use practices. Federal Coastal Zoe Approval NJDEP- Lad Use Regulatio Program (LURP) moths Coastal Area Facility Review Act Permit NJDEP-LURP 6-9 moths

27 Table 3 (Cotiued) Permit/Approval Regulatory Agecy Agecy Review Timeframe Commets State of New Jersey (Cotiued) Tidelads Licese NJDEP-LURP 3-6 moths Freshwater Wetlad Permit, Geeral Permit 21, Above Groud Utility Lie NJDEP-LURP moths Historic ad Archaeological Resources Cosultatio NJ Historic Trust 12 moths Fish ad Wildlife Review NJDEP-DFW moths Soil Erosio ad Sedimet Cotrol Pla - Costructio Permit Cumberlad- Salem Coservatio District 4 6 moths Road Crossig Permit NJ Departmet of Trasportatio N/A No state highways are crossed. State of Delaware Certificate of Public Coveiece ad Necessity DEPSC 6 moths The commissio may eter a order extedig this period for a additioal 3 moths Coastal Zoal Act Permit Subaqueous Lads ad Tidal Wetlads (wetlad ad permit ad subaqueous lads lease/easemet Federal Coastal Cosistecy Determiatio DNREC- Office of the Secretary DNREC, Divisio of Water Resources DNREC, Divisio of Soil ad Water Coservatio (DSWC) 6 moths Public has 14 days to appeal oce permit is issued 4 moths 6 9 moths Fish ad Wildlife Review DNREC-DFW moths Sedimet ad Storm water Maagemet Pla DNREC, DSWC 1 2 moths Cosultatio Regardig Historic or Archaeological Resources Departmet of State, Divisio of Historical ad Cultural Resources moths

28 Table 3 (Cotiued) Permit/Approval Regulatory Agecy Agecy Review Timeframe Commets Local Lad Use Approval Lad Use Approval Lad Use Approval Lad Use Approval Pesville Towship (NJ) Elsiboro Towship (NJ) Lower Alloways Creek Towship (NJ) New Castle Couty, DE 2 moths 2 moths 2 moths 1 moth

29 Table 4 Egieer s Estimate of Probable Costructio Costs Task Qty. Uit Uit Price Exteded Price Trasmissio Lie Routig ad Permittig 1 Lump Sum --- $3,000,000 Evirometal Remediatio (Wetlad Credits) a 350 Acre $20,000 $7,000,000 Trasmissio Lie Egieerig 1 Lump Sum --- $3,000,000 Substatio Egieerig 1 Lump Sum --- $500,000 Right-of-Way Acquisitio b 350 Acre $20,000 $7,000,000 Access (Road Costructio, Swamp Mats, Helicopter) ($1 millio per mile) 18 Mile $1,000 $18,000,000 Delaware River Crossig Material & Costructio c 2.5 Mile $22,000 $55,000,000 Trasmissio Lie Material & Costructio (Other tha river crossig) 15.5 Mile $4,000 $62,000,000 Trasmissio Lie Egieerig 1 Lump Sum --- $3,000,000 Red Lio/Hope Creek/Salem Substatio Expasios d 1 Lump Sum --- $10,000,000 Project Maagemet (Approx. 10 percet) 1 Lump Sum --- $16,500,000 Subtotal $185,000,000 Cotigecy (Approx. 25 percet) $45,000,000 Total $230,000,000 Notes: a. The probable cost for evirometal remediatio is based o the project crossig approximately 350 acres of forested wetlads that may require clearig, with compesatory mitigatio ivolvig the purchase of credits from a wetlads mitigatio bak at ratios as high as 4:1. b. The probable cost for right-of-way acquisitio is based o acquirig all ew right-of-way for the etire legth of the lie, at a average cost of $20,000 per acre. c. The probable cost for the Delaware River crossig was determied by takig the approximate actual cost of istallatio of the existig crossig i 1976 ($16,000,000) ad escalatig it to 2014 dollars (usig a average escalatio rate of 3 percet per year), plus a additioal 10 percet to cover improved protectio for structures istalled i the river. We also cosidered the relative differece i complexity betwee the river crossig costructio ad the costructio of the remaider of the lie. d. Sice the developers scopes of work ad cost estimates for substatio modificatios at Red Lio, Salem, ad Hope Creek substatios varied greatly, GAI used a approximate average cost i our opiio, solely for bechmarkig purposes.

30 Table 5 Costructability Review Summary Domiio LS Power PHI/Exelo PSE&G Trasource ROW Acquisitio Domiio proposes istallatio of the ew 500kV lie i a 150' wide right-of-way (ROW) o the west side of the existig 5015 lie ROW. Domiio would eed to acquire ROW for the etire legth of the lie, ad estimates a 81 moth time frame. LS Power will eed to procure all ew ROW for the trasmissio lie, ad estimates a 18 moth time frame. PHI/Exelo has owership, easemet rights, or joit owership rights to all plaed ROW for the project. PHI is part of the Lower Delaware Valley (LDV) Trasmissio Service Agreemet. PSE&G ows or has property rights i some of the proposed ROW s. They estimate a time frame of 18 moths will be required to obtai all required ROW. PSE&G is part of the LDV Trasmissio Service Agreemet. Trasource will eed to procure all ew ROW for the trasmissio lie. They estimate that 15 moths will be required to procure all required ROW. Lad Acquisitio Sitig/Permittig Project Complexity Domiio would eed to work with the existig owers of Red Lio ad Salem Substatios to execute ay ecessary agreemets for property rights. LS Power would eed to work with the existig owers of Red Lio ad Salem Substatios to execute ay ecessary agreemets for property rights. PHI/Exelo ows all property required for the proposed expasio of Red Lio Substatio. Expasio of Salem Substatio would require the cooperatio of the icumbet ower. PSE&G ows all property required for the proposed modificatios to Hope Creek ad Salem Substatios. Expasio of Red Lio SS would require the cooperatio of the icumbet ower. Trasource would eed to work with the existig owers of Red Lio ad Salem Substatios to execute ay ecessary agreemets for property rights. The projects proposed by all five (5) developers will have similar sitig ad permittig risks sice they all follow similar routes. The permits that are most complex ad require the logest lead times are the Supawa Natioal Wildlife Refuge crossig permit, the Delaware River crossig permit, ad CPCNs i Delaware ad New Jersey. Domiio's desig requires a crossig of the existig Red Lio-Hope Creek Lie 5015 ear Red Lio SS. Proposed 500kV lie will swap termials with Lie Salem Substatio will be expaded, ad the proposed 500kV lie will swap termials with the Hope Creek tie lie; Proposed lie will cross Lies 5015 ad At Salem SS, the existig Hope Creek tie lie would be moved to a ew termial positio; the proposed lie would tie ito the vacated positio at Salem, ad would have to cross Lies 5015, 5021, 5023 ad Proposed lie would tie ito Red Lio SS at ew termial locatio o orth side of substatio; this will require the ew lie to cross Lie The proposed 500kV lie will cross Lie 5015 ear Red Lio Substatio. At Salem Substatio, the New Freedom ad Orchard lies would be moved to ew positios; the proposed lie would use the curret Orchard positio, ad would the eed to cross Lies 5015 ad Project Schedule 111 moths 66 moths 60 moths 51 moths 48 moths Estimated Project Cost $199 millio $171 millio $157 millio $297 millio $123 - $156 millio

31 FIGURES

32 ³ Red Lio Substatio Leged Proposed Trasmissio Lie Road Estuarie ad Marie Deepwater Estuarie ad Marie Wetlad Freshwater Wetlad Artificial Isad Freshwater Forested/Shrub Wetlad Freshwater Pod Lake Other 0 6,000 Riverie 12,000 24,000 Feet Copyright: 2013 Esri, DeLorme, NAVTEQ FIGURE 1 ENVIRONMENTAL FEATURES MAP ARTIFICIAL ISLAND RED LION 500kV TRANSMISSION LINE

33 EGlebe ") ³ Cemetery Meadowwood Behavioral Health v ) " Ommelade Ommelade Rage Rage Delaware State Hospital v Fis Poit Natioal Cemetery E Red Lio Substatio Gree Hill Cemetery E Goveror Baco Health Ceter v E Evergree Cemetery E Hickory Grove Cemetery E Asbury Cemetery E Vadegrift Vadegrift Golf Golf Club Club Artificial Islad 0 6,000 12,000 24,000 Feet Leged Corbit Cemetery E Educatioal Istitutio Federal Lad Golf Course State Lad Cemetery Native America Lad v Hospital Military Istallatio Local Lad Church Stadium or Area Private Coservatio Lad Federal or State Priso Joit Owership; Ukow Amusemet Ceter Historic Properties Govermet Ceter ) " School Public Buildig Proposed Trasmissio Lie Copyright: 2013 Esri, DeLorme, NAVTEQ FIGURE 2 LAND USE MAP ARTIFICIAL ISLAND RED LION 500kV TRANSMISSION LINE

34 ³ Red Lio Substatio Leged Area With A High/Medium Probabiltiy of Archaeological Sites NRHP Property Proposed Trasmissio Lie Artificial Islad 0 4,650 9,300 18,600 Feet Source: Esri, DigitalGlobe, GeoEye, icubed, USDA, USGS, AEX, Getmappig, Aerogrid, IGN, IGP, swisstopo, ad the GIS User Commuity FIGURE 3 NHRP PROPERTIES AND ARCHAEOLOGICAL SITES ARTIFICIAL ISLANDRED LION 500kV TRANSMISSION LINE