Common use of THE WMPA APPLIES TO WHOLESALE Clause in Contracts

THE WMPA APPLIES TO WHOLESALE. SALES ONLY PJM submitted the WMPA for filing because the WMPA is a form of agreement not presently contained in either the PJM Open Access Transmission Tariff (“PJM Tariff”) or the PJM Operating Agreement. The WMPA applies only to wholesale transactions and is not intended to govern the actual physical interconnection of a generating facility to the distribution system. Therefore, it is immaterial whether the WMPA concerns a new interconnection to a distribution system or a pre-existing interconnection on a distribution system where the pre-existing generator subsequently elects to participate in the PJM markets. The WMPA will be initiated for the purpose of facilitating the wholesale sale and not the interconnection. To date, generator market participants connecting to the distribution system have been receptive to the use of the WMPA as a means to facilitate future sales into the PJM markets and to support the state interconnection processes as well. Further, the WMPA allows a vehicle for PJM to examine the potential reliability impacts the interconnection may have on the grid. As the GSG Order directs,14 interconnection to the distribution system is not FERC jurisdictional until wholesale sales begin on the system. Hence, the PJM Tariff would not apply to govern the terms and conditions of the physical interconnection, including the attachment of facilities and terms of use and charges for distribution service needed to afford the generator access to the PJM Transmission System. Again, PJM’s interest is to ensure sufficient visibility and, where necessary, control over generation that is participating as a Market Seller under the PJM Operating Agreement.15

THE WMPA APPLIES TO WHOLESALE. SALES ONLY PJM submitted the WMPA for filing because the WMPA is a form of agreement not presently contained in either the PJM Open Access Transmission Tariff (“PJM Tariff”) or the Amended and Restated Operating Agreement of PJM Interconnection, L.L.C. (“Operating Agreement”). The WMPA applies only to wholesale transactions and is not intended to govern the actual physical interconnection of a generating facility to the distribution system. Therefore, it is immaterial whether the WMPA concerns a new interconnection to a distribution system or a pre-existing interconnection on a distribution system where the pre-existing generator subsequently elects to participate in the PJM markets. The WMPA will be initiated for the purpose of facilitating the wholesale sale and not the interconnection. To date, generator market participants connecting to the distribution system have been receptive to the use of the WMPA as a means to facilitate future sales into the PJM markets and to support the state interconnection processes as well. Further, the WMPA allows a vehicle for PJM to examine the potential reliability impacts the interconnection may have on the grid. Xxxxxxxx X. Xxxx, Secretary May 25, 2021 As the GSG Order directs,14 directs, 14 interconnection to the distribution system is not FERC jurisdictional until wholesale sales begin on the system. Hence, the PJM Tariff would not apply to govern the terms and conditions of the physical interconnection, including the attachment of facilities and terms of use and charges for distribution service needed to afford the generator access to the PJM Transmission System. Again, PJM’s interest is to ensure sufficient visibility and, where necessary, control over generation that is participating as a Market Seller as defined under the Operating Agreement.15 IV. THE WMPA DIFFERS FROM THE ISA IN NUMEROUS IMPORTANT ASPECTS The WMPA is designed to have a similar format to the PJM Operating Agreement.15Interconnection Service Agreement (“ISA”) in order to provide a manageable and familiar document for the participants. Unlike the ISA, however, the WMPA does not address matters involving the actual physical interconnection of the generator to the distribution system or any terms, conditions or charges related to any service provided by the distribution system to the generator. The WMPA contains many provisions also typically found in an ISA that govern the relationship between the generator and PJM. These provisions establish reasonable and necessary standards and qualifications, such as revenue quality metering, both to enable the generator to participate as a Market Seller16 in PJM’s market and to allow PJM’s system operations the necessary visibility to the generator for reliability purposes. However, the WMPA is not an ISA and is not intended as a substitute for an interconnection agreement between the owners of the interconnecting physical facilities. More specifically, the WMPA differs from the ISA in several key respects. First, the 14 See GSG Order at P 14.

THE WMPA APPLIES TO WHOLESALE. SALES ONLY PJM submitted the WMPA for filing because the WMPA is a form of agreement not presently contained in either the PJM Open Access Transmission Tariff (“PJM Tariff”) or the Amended and Restated Operating Agreement of PJM Interconnection, L.L.C. (“Operating Agreement”). The WMPA applies only to wholesale transactions and is not intended to govern the actual physical interconnection of a generating facility to the distribution system. Therefore, it is immaterial whether the WMPA concerns a new interconnection to a distribution system or a pre-existing interconnection on a distribution system where the pre-existing generator subsequently elects to participate in the PJM markets. The WMPA will be initiated for the purpose of facilitating the wholesale sale and not the interconnection. To date, generator market participants connecting to the distribution system have been receptive to the use of the WMPA as a means to facilitate future sales into the PJM markets and to support the state interconnection processes as well. Further, the WMPA allows a vehicle for PJM to examine the potential reliability impacts the interconnection may have on the grid. As the GSG Order directs,14 directs, 14 interconnection to the distribution system is not FERC jurisdictional until wholesale sales begin on the system. Hence, the PJM Tariff would not apply to govern the terms and conditions of the physical interconnection, including the attachment of facilities and terms of use and charges for distribution service needed to afford the generator access to the PJM Transmission System. Again, PJM’s interest is to ensure sufficient visibility and, where necessary, control over generation that is participating as a Market Seller as defined under the Operating Agreement.15 IV. THE WMPA DIFFERS FROM THE ISA IN NUMEROUS IMPORTANT ASPECTS The WMPA is designed to have a similar format to the PJM Operating Agreement.15Interconnection Service Agreement (“ISA”) in order to provide a manageable and familiar document for the participants. Unlike the ISA, however, the WMPA does not address matters involving the actual physical interconnection of the generator to the distribution system or any terms, conditions or charges related to any service provided by the distribution system to the generator. The WMPA contains many provisions also typically found in an ISA that govern the relationship between the generator and PJM. These provisions establish reasonable and necessary standards and qualifications, such as revenue quality metering, both to enable the generator to participate as a Market Seller16 in PJM’s market and to allow PJM’s system operations the necessary visibility to the generator for reliability purposes. However, the WMPA is not an ISA and is not intended as a substitute for an interconnection agreement between the owners of the interconnecting physical facilities. More specifically, the WMPA differs from the ISA in several key respects. First, the 14 See GSG Order at P 14.

THE WMPA APPLIES TO WHOLESALE. SALES ONLY PJM submitted the WMPA for filing because the WMPA is a form of agreement not presently contained in either the PJM Open Access Transmission Tariff (“PJM Tariff”) or the Amended and Restated Operating Agreement of PJM Interconnection, L.L.C. (“Operating Agreement”). The WMPA applies only to wholesale transactions and is not intended to govern the actual physical interconnection of a generating facility to the distribution system. Therefore, it is immaterial whether the WMPA concerns a new interconnection to a distribution system or a pre-existing interconnection on a distribution system where the pre-existing generator subsequently elects to participate in the PJM markets. The WMPA will be initiated for the purpose of facilitating the wholesale sale and not the interconnection. To date, generator market participants connecting to the distribution system have been receptive to the use of the WMPA as a means to facilitate future sales into the PJM markets and to support the state interconnection processes as well. Further, the WMPA allows a vehicle for PJM to examine the potential reliability impacts the interconnection may have on the grid. Xxxxxxxx X. Xxxx, Secretary February 11, 2021 As the GSG Order directs,14 directs, 14 interconnection to the distribution system is not FERC jurisdictional until wholesale sales begin on the system. Hence, the PJM Tariff would not apply to govern the terms and conditions of the physical interconnection, including the attachment of facilities and terms of use and charges for distribution service needed to afford the generator access to the PJM Transmission System. Again, PJM’s interest is to ensure sufficient visibility and, where necessary, control over generation that is participating as a Market Seller as defined under the Operating Agreement.15 IV. THE WMPA DIFFERS FROM THE ISA IN NUMEROUS IMPORTANT ASPECTS The WMPA is designed to have a similar format to the PJM Operating Agreement.15Interconnection Service Agreement (“ISA”) in order to provide a manageable and familiar document for the participants. Unlike the ISA, however, the WMPA does not address matters involving the actual physical interconnection of the generator to the distribution system or any terms, conditions or charges related to any service provided by the distribution system to the generator. The WMPA contains many provisions also typically found in an ISA that govern the relationship between the generator and PJM. These provisions establish reasonable and necessary standards and qualifications, such as revenue quality metering, both to enable the generator to participate as a Market Seller16 in PJM’s market and to allow PJM’s system operations the necessary visibility to the generator for reliability purposes. However, the WMPA is not an ISA and is not intended as a substitute for an interconnection agreement between the owners of the interconnecting physical facilities. More specifically, the WMPA differs from the ISA in several key respects. First, the 14 See GSG Order at P 14.

THE WMPA APPLIES TO WHOLESALE. SALES ONLY PJM submitted the WMPA for filing because the WMPA is a form of agreement not presently contained in either the PJM Open Access Transmission Tariff (“PJM Tariff”) or the Amended and Restated Operating Agreement of PJM Interconnection, L.L.C. (“Operating Agreement”). The WMPA applies only to wholesale transactions and is not intended to govern the actual physical interconnection of a generating facility to the distribution system. Therefore, it is immaterial whether the WMPA concerns a new interconnection to a distribution system or a pre-existing interconnection on a distribution system where the pre-existing generator subsequently elects to participate in the PJM markets. The WMPA will be initiated for the purpose of facilitating the wholesale sale and not the interconnection. To date, generator market participants connecting to the distribution system have been receptive to the use of the WMPA as a means to facilitate future sales into the PJM markets and to support the state interconnection processes as well. Further, the WMPA allows a vehicle for PJM to examine the potential reliability impacts the interconnection may have on the grid. Xxxxxxxx X. Xxxx, Secretary February 13, 2020 As the GSG Order directs,14 directs, 14 interconnection to the distribution system is not FERC jurisdictional until wholesale sales begin on the system. Hence, the PJM Tariff would not apply to govern the terms and conditions of the physical interconnection, including the attachment of facilities and terms of use and charges for distribution service needed to afford the generator access to the PJM Transmission System. Again, PJM’s interest is to ensure sufficient visibility and, where necessary, control over generation that is participating as a Market Seller as defined under the Operating Agreement.15 IV. THE WMPA DIFFERS FROM THE ISA IN NUMEROUS IMPORTANT ASPECTS The WMPA is designed to have a similar format to the PJM Operating Agreement.15Interconnection Service Agreement (“ISA”) in order to provide a manageable and familiar document for the participants. Unlike the ISA, however, the WMPA does not address matters involving the actual physical interconnection of the generator to the distribution system or any terms, conditions or charges related to any service provided by the distribution system to the generator. The WMPA contains many provisions also typically found in an ISA that govern the relationship between the generator and PJM. These provisions establish reasonable and necessary standards and qualifications, such as revenue quality metering, both to enable the generator to participate as a Market Seller16 in PJM’s market and to allow PJM’s system operations the necessary visibility to the generator for reliability purposes. However, the WMPA is not an ISA and is not intended as a substitute for an interconnection agreement between the owners of the interconnecting physical facilities. More specifically, the WMPA differs from the ISA in several key respects. First, the 14 See GSG Order at P 14.