SMECO Files Complaint with FERC Against J.P. Morgan Ventures Energy Corp.

CALLAWAY, Md. (Feb. 8, 2016)—SMECO, the electric power co-op which serves the southern Maryland region, filed a formal complaint against J.P. Morgan Ventures Energy Corporation (JPMVEC) on Feb. 1 with the Federal Energy Regulatory Commission (FERC). In the complaint, SMECO states it believes that JPMVEC does not intend to transfer Capacity Performance (CP) credit to SMECO, starting with the 2016-2017 Delivery Year that begins June 1, 2016.

The dispute involves a "Capacity Purchase and Day Ahead Heat Rate Call Option on Physical Electricity" entered into by both parties on April 28, 2011. The option provides SMECO a 225 MW Reliability Pricing Model (RPM) capacity credit from the Brandywine Generation Facility at Brandywine in exchange for a monthly payment by SMECO to JPMVEC, according to the complaint.

In the complaint, SMECO estimates its financial impact from loss of CP credit as follows:

• Delivery Year 2016-17: $1,221,198.75

• Delivery Year 2017-18: $2,586,937.50

• Delivery Year 2018-19: $1,214,628.75

• Delivery Year 2019-20: $1,214,628.75

*Delivery Years after 2018-19 based on assumption that 2018-19 is indicative of later years.

SMECO is requesting that FERC render a decision on the complaint before June 1, 2016.

The Notice of Complaint and Complaint are included in their entirety.

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