Allegheny Power System Benefit Fund

“The bank of new york mellon serves as the sole directed trustee of this trust. The plan sponsor is firstenergy corp. The trust is administered by the plan sponsor in accordance with the terms of the trust agreement. As such the veba does not have a governing body that exercises discretion.”

“A complete electronic copy of the organization's Form 990 was provided to the Trustee for review prior to filing with the IRS.”

“SUBJECT TO FIRSTENERGY CORP's OVERALL POLICY. FIRSTENERGY CORP DOES MONITOR AND ENFORCE COMPLIANCE WITH ITS CONFLICTS OF INTEREST POLICY.”

“SUBJECT TO FIRSTENERGY CORP's OVERALL POLICY.”

“ALL SUBSIDIARIES ARE SUBJECT TO FIRSTENERGY CORP's OVERALL POLICY.”

“To applicable to this organization, as it is a 501(c)(9) trust (voluntary employee benefits assocation). Additionally, it does not have any employees therefore no processes related to employee compensation.”

“As a 501(c)(9) organization the trust is not required to make the documents referenced in question 19 available to the general public.”

“AVERAGE HOURS PER WEEK DEVOTED TO POSITION: AS TRUSTEE, THE BANK OF NEW YORK MELLON PROVIDES ADMINISTRATIVE SERVICES SUCH AS ACTING AS INVESTMENT MANAGER FOR Allegheny Power Benefit Fund 170-742. THESE SERVICES REQUIRE NUMEROUS INDIVIDUAL BANK EMPLOYEES' INVOLVEMENT IN THE ACTIVITIES OF THE ORGANIZATION AND THUS CANNOT BE QUANTIFIED ON AN HOURLY BASIS. THEREFORE, THE TRUSTEE FEES ARE NOT BASED UPON AN HOURLY BASIS, BUT ARE CALCULATED BASED UPON FACTORS SUCH AS THE MARKET VALUE OF THE ACCOUNT AND IN ACCORDANCE WITH THE BANK OF NEW YORK MELLON'S AGREEMENT WITH FIRSTENERGY CORP.”

“MODIFIED CASH BASIS”

“Election under IRC 419A(h)(1)(B) to aggregate welfare benefit funds for non-bargaining post-retirement medical benefits and non-bargaining post retirement life benefits FirstEnergy Corp. (EIN 34-1843785) sponsors several voluntary employee's beneficiary associations (VEBAs) as defined in IRC 501(c)(9) of the Internal Revenue Code. These VEBAs were formed to finance life, medical and certain other welfare benefits for nonunion employees and retirees. IRC 419A(h)(1)(B) permits an employer to elect to permissively aggregate two or more of its welfare benefit funds as one fund for the purpose of computing unrelated business taxable income determined under 512(a)(3). FirstEnergy Corp. is making the voluntary election for the 2013 tax year to aggregate the VEBAs which fund non-bargaining post-retirement medical benefits and non-bargaining post-retirement life benefits which are listed below and which file Form 990: - Ohio Edison Postretirement Health Benefits Trust- Nonunion (EIN 34-1814802) - GPU Companies Health Care Plan For Nonbargaining Retirees Trust (EIN 22-3323698) - GPU Companies Long Term Disability Income Plan For Nonbargaining Employees Trust (EIN 22-3096742) - GPU Companies Basic Life And Accident Insurance Plan For Non Bargaining Retirees Trust (EIN 23-3062202) - Allegheny Power Benefit Fund 170-742 (13-3419121)”