BEFORE THE PENNSYLVANIA PUBLIC UTILITY COMMISSION PENNSYLVANIA ELECTRIC COMPANY DOCKET NO. R Direct Testimony of Kevin M.

Transcription

1 Penelec Statement No. 3 BEFORE THE PENNSYLVANIA PUBLIC UTILITY COMMISSION PENNSYLVANIA ELECTRIC COMPANY DOCKET NO. R Direct Testimony of Kevin M. Siedt List of Topics Addressed Sales and Revenue Normalization Rate Design Customer Impact Analysis Proof of Revenue Analysis and Bill Comparisons Tariff Revisions

2 TABLE OF CONTENTS Page I. INTRODUCTION AND BACKGROUND... 1 II. ENERGY SALES AND REVENUE NORMALIZATIONS... 3 III. RATE DESIGN... 7 IV. PROOF OF REVENUE ANALYSIS AND BILL COMPARISONS V. TARIFF REVISIONS VI. MISCELLANEOUS MATTERS VII. CONCLUSION APPENDIX A -i-

3 1 2 3 DIRECT TESTIMONY OF KEVIN M. SIEDT 4 5 I. INTRODUCTION AND BACKGROUND Q. Please state your name and business address. A. My name is Kevin M. Siedt. My business address is 2800 Pottsville 6 Pike, Reading, 7 Pennsylvania Q. By whom are you employed and in what capacity? A. I am employed by FirstEnergy Service Company as a Consultant 9 in the Rates and 10 Regulatory Affairs Department Pennsylvania. 11 Q. What are your responsibilities as a Consultant? A. Generally, the Rates and Regulatory Affairs Department - Pennsylvania 12 provides regulatory support for the Pennsylvania electric utility subsidiaries 13 of FirstEnergy Corp. ( FirstEnergy ), which include Pennsylvania Electric Company 14 ( Penelec or the Company ). As a Consultant in the Rates and Regulatory Affairs 15 Department, my responsibilities with respect to Penelec are to support the development, 16 preparation, and presentation of the Company s retail electric rate design and related 17 rules and regulations, and ensure the uniform administration and interpretation in all 18the Company s rate- related matters before the Pennsylvania Public Utility Commission 19 ( Commission ). I also am responsible for, among other things, default service plan 20 development and implementation, recovery of non-utility generation costs, regulatory 21 program cost 22 recovery and other financial matters.

4 1 Q. What is your educational background and work experience? A. I obtained a Master s Degree in Business Administration from2moravian College in I am also a graduate of Rowan University where I received a Bachelor 3 of Science Degree with a major in Accounting and Finance in My work experience 4 is more fully 5 described in Appendix A to this testimony. 6 7 Q. On whose behalf are you testifying in this proceeding? A. I am testifying on behalf of Penelec. 8 Q. What is the purpose of your direct testimony? A. My testimony addresses: (i) the annualization and normalization 9 of sales and revenues used in the Company s cost of service studies; (ii) the rate design 10 methodology used to develop the distribution rates proposed in this proceeding; (iii) 11a customer impact analysis, which compares bills at current and proposed rates; 12 (iv) a proof of revenue 13 analysis; and (v) changes to Penelec s Electric Service tariff. 14 Q. Have you prepared and are you sponsoring exhibits to accompany your testimony? A. Yes. As discussed in more detail later in my testimony, I am 15 sponsoring Exhibits KMS-1 through KMS-8 for the Company, which were prepared by me 16or under my supervision. The subjects addressed in each of these exhibits are summarized 17 below: 22 KMS-1 KMS-2 KMS-3 This exhibit consists of Attachments A, B and 18 C, reflecting normalized sales and revenues for the test years ending19december 31, 2017, December 31, 2016, and December 31, 2015, respectively Summary of Present and Proposed Distribution 21 Revenues Customer Charge Analysis 2

5 KMS-4 KMS-5 KMS-6 KMS-7 KMS-8 Proof of Revenues Analyses Customer Impact Analyses Cost and Proposed Base Rate Revenue Curves 3 Matrix of Tariff changes Responses to the certain Commission filing5requirements as specified by 52 Pa. Code and In addition, I am sponsoring modifications to the rate schedules 7 and to certain of the riders in the Company s proposed tariff, which are discussed further 8 in this testimony. 9 II. ENERGY SALES AND REVENUE NORMALIZATIONS Q. What was the basis for developing the Company s claims for energy sales, demand and base rate revenue for the fully projected future test year ( FPFTY )? A. The starting point for the Company s claims was the budget forecast 12 of energy sales, demand and base rate revenue for the twelve months ending December 13 31, The budget forecast was developed by reviewing current customer14consumption data, conducting appliance saturation surveys and analyzing actual15 historical customer usage for the past several years to identify patterns and trends. That16 information was used to develop detailed projections of the actual billing determinants 17 (number of customers, demand (in kilowatts ( kw )) and energy (in kilowatt hours ( kwh )) 18 for each rate schedule. The actual charges for each component of each rate19schedule were applied to the applicable billing determinants (customers, kw or kwh) to 20project the revenue to be billed under each rate schedule by month for the FPFTY. This 21detailed process assures that revenue under proposed rates can be directly tied in to the22billing determinants underlying the Company s revenues under existing rates that 23 are used to calculate its 24 revenue deficiency in this case. 3

6 1 2 3 Q. In developing the Company s revenue claims in this case, were the budget projections and, specifically, the application of rates to the projected billing determinants reviewed for computational accuracy? A. Yes. The budget forecasts were found to be very accurate. Penelec 4 only made normalization adjustments that were consistent with the Commission s 5 filing 6 requirements. 7 Q. Did you make any other adjustment to reflect normalized sales? A. Yes, I made an adjustment to reflect the impact of the expanding 8 use of light-emitting diode ( LED ) street lighting. In its last base rate case, the Company 9 proposed and the Commission approved a new service offering and rate schedule 10for the installation of LED street lighting. As I previously explained, the 2017 budget, 11 which formed the basis for the FPFTY level of energy sales, demand and base rate revenue, 12 reflects the effects of the current level of LED street lighting installations. Nonetheless, 13 based on the current pace at which LED installations are taking place, it is anticipated 14 that there will be a materially larger number of LED fixtures installed by the end15 of the FPFTY than is reflected in the 2017 budget forecast. To a very large extent, 16 the LED fixtures are replacing existing sodium vapor and mercury vapor street lighting 17 fixtures. Because LED lighting distribution rates were set at a price lower than 18 the distribution rates for the lights that are being replaced, it is necessary to make a normalization 19 adjustment to reflect the lower level of revenue that will result from the expanded 20 use of LED street 21 lighting. 4

7 1 2 Q. Were any adjustments made to the budget forecast data to present energy sales, demand and base rate revenue on a ratemaking basis? A. Yes. Adjustments for ratemaking purposes were made to annualize 3 and normalize the budget data. Annualization is the process of adjusting budgeted 4 sales and revenues projected to be billed over a full test year to reflect the level of5sales and revenues as of the end of the test year. In that way, pro forma sales and revenues 6 are stated on a basis that properly reflects sales and revenues to be experienced going 7 forward. Normalization is the process of adjusting budgeted sales and revenues to remove 8 outliers and anomalies from the test year data. Thus, unusual events and one-time effects 9 are normalized to 10 reflect ongoing conditions Q. Have you prepared an exhibit setting forth annualized and normalized sales and revenues? A. Yes, I have. Annualized and normalized sales and revenues are 13 presented in Attachments A through C of Exhibit KMS-1 for the twelve months ending14 December 31, 2017, December 31, 2016, and December 31, 2015, respectively. Summaries 15 of the Company s distribution revenues under existing and proposed rates are provided 16 in Exhibit KMS-2. The principal adjustments to the budget forecast data were made 17 to annualize the sales and revenue effect of customers added during the test year and 18to normalize and annualize sales levels to reflect reductions attributable to measures 19 that have been or will be implemented under the Company s Commission-approved20 Phase III Energy 5

8 Efficiency and Conservation ( EE&C ) Plans, which were adopted 1 pursuant to Section of the Pennsylvania Public Utility Code Q. Please describe the adjustment made to budget forecast data for the twelve months ending December 31, 2017 to annualize revenues for changes in the number of customers. A. In accordance with the Commission s filing requirements, an adjustment 6 was made to annualize energy usage and demand for the difference between7 the monthly average number of customers forecasted for the FPFTY and the number 8 of customers forecasted for the end of the FPFTY. Usage (kwh) and demand (kw) forecasted 9 for the FPFTY were divided by the monthly average number of customers at10 mid-month (for each month) to calculate the average usage and average billed demand 11 per customer. The average usage (in kwh) and average demand (in kw) per customer 12 were multiplied by the difference between the monthly average number of customers 13 and the number of customers forecasted for the end of the test year to determine14 the additional kwh and kw to be added to the budget forecast to annualize sales and revenue. 15 The additional revenues attributable to the customer annualization 16 were calculated by multiplying the additional billing determinants (customers, kw17or kwh) derived from the customer annualization by the applicable customer, demand or 18energy charges. This calculation is shown in Exhibit KMS-1, Attachment A, page 3, 19column Pa.C.S. 101, et seq. 6

9 Q. Please describe the adjustments made to budget forecast data for the twelve months ending December 31, 2017 to normalize and annualize revenues for conservation measures implemented or to be implemented pursuant to the Company s EE&C Phase III Plan. A. The energy sales that were forecasted by rate schedule for the FPFTY 5 reflect anticipated usage reductions from energy efficiency measures implemented 6 in accordance with the Company s Commission-approved Phase III EE&C Plan. The7forecasted reductions are reflected by month from January 1, 2017 through December 31, The revenue reductions for the entire FPFTY were calculated by annualizing 9 the usage reduction targets that the Company must achieve by the end of its Phase10III EE&C Plan (May 31, 2021). The annualized amount was netted against the monthly 11savings already included in the FPFTY sales forecast to derive the additional energy efficiency 12 normalization adjustment. The same approach was used to annualize and normalize 13 behind-the-meter generation to derive a total energy efficiency normalization adjustment. 14 The revenue effect of the annualization was calculated by multiplying the annualized 15 energy efficiency sales reductions by the average rate per customer by 16rate schedule. 17 III. RATE DESIGN Q. What considerations, concepts and objectives underlie the rate designs proposed by the Company? A. The following general principles were employed in designing20 the proposed rates: Rates must be designed to produce revenues equal to the 21 Company s revenue 22 requirement at the appropriate billing determinants. 7

10 Rates should be designed to properly reflect cost causation 1 and, in that regard, the 2 results of a cost of service study are used as a guide. Rates generally should be designed, if practicable, to move 3 revenues for each rate schedule (or in some instances, customer classes consisting 4 of aggregated rate schedules) toward that schedule s cost of service, giving 5 due regard to factors such as gradualism, economic efficiency, relative ease or 6 difficulty of 7 administration, and customer understandability. In addition to the general principles I just described, the Company 8 determined that in developing its proposed rates, it should strive to achieve the following 9 objectives: There should be a unified distribution rate design for all 10four of the FirstEnergy electric utilities that furnish service in Pennsylvania, given 11 that the Companies are managed on a consistent basis with a uniform set of business 12 processes. The rate design should give due consideration to the fact 13 that distribution service has now been fully unbundled for ratemaking purposes. 14 All else being equal, distribution rates should reflect customer 15 demand rather than energy usage. This is because distribution costs are driven 16 predominantly by investment in fixed assets, which does not vary with a17 customer s energy usage. With the implementation of the Company s Commission-approved 18 Smart Meter Deployment Plan and the significant investment in smart 19 meter technology that the Plan requires, the Company s rate design should incorporate 20 the functionality that smart meters provide to accurately measure demand. 21 8

11 Reconcilable adjustment clauses, set forth in riders to the 1 Company s base rates, should be used to recover certain costs that are volatile2in nature and generally not under the Company s control, consistent with the criteria 3 for adjustment clauses established under Section 1307 of the Public Utility Code Q. What role did the results of the cost of service study play in designing the proposed distribution rates? A. The cost of service study for the Company was prepared by Thomas 7 Dolezal and is described in Penelec Statement No. 4. The results of the cost of 8 service study were the starting point for designing the proposed distribution rates. However, 9 the final rate designs for the distribution rates that I am recommending also10incorporate the rate design principles and objectives that I previously described, as well as 11my experience in 12 designing utility rates. 13 Q. How did you design the proposed distribution rates? A. I began by reviewing the rates of return produced by the various 14 rate schedules under current rates and the FPFTY level of revenue requirement. The 15 rate schedules exhibit a range of returns from positive to negative. The divergent class 16returns provide an indication, based on a snapshot at a specific moment in time, 17 of the general magnitude of interclass subsidies that exist among rate classes under current 18rates. Based upon the Company s overall retail rate of return, the cost of service study 19 shows that certain rate schedules are producing less than the Company s overall rate20 of return, while others are 21 producing rates of return in excess of it. 9

12 Next, I reviewed the revenue that each rate schedule would have 1 to produce to achieve a rate of return equal to the Company s overall rate of return under 2 the proposed distribution rates. This level of revenue shows the magnitude of 3 the rate changes necessary to move each rate schedule to its cost of service as indicated 4 by the cost of 5 service study. While movement toward cost of service is an important element 6 in designing rates, it is not the only factor that must be considered. For instance, the impact 7 on customers bills from implementing a range of potential rate increases must be 8carefully evaluated. Establishing rates for each rate schedule that produce a retail rate 9 of return equal to the Company s overall rate of return is the theoretical target of the 10rate design process. However, the Company understands that bringing some of the11rate schedules to their indicated cost of service would impose rate decreases for some 12and/or potentially disruptive rate increases for others. The proposed rate design, 13therefore, properly applies 14 the principle of gradualism to mitigate customer impact Q. Has a table been prepared that shows the rates of return under existing and proposed rates by rate schedule for the Company? A. Yes. Such tables are set forth in Mr. Dolezal s direct testimony. 17 That table also shows the unitized rates of return ( UROR ) for each rate schedule. 18 The UROR of a rate class is the class rate of return divided by the Company s overall average 19 rate of return. A class UROR greater than 1.0 indicates that the class revenue exceeds 20 the class cost of service. A class UROR less than 1.0 indicates that the class revenue 21 is less than the class cost of service. URORs are used as a guide to measure the progress 22 that changes in rates 10

13 will achieve in moving classes toward a UROR of 1.0 or unity, 1 which is generally accepted as a desirable goal in rate design, subject to those other 2 rate design factors that I 3 previously discussed. 4 5 Q. Were any specific criteria used in determining how much progress should be made in moving specific rate schedules toward unity, or cost of service? A. Yes. In order to implement the concept of gradualism as applied 6 to the guidance provided by the results of the Company s cost of service study, 7two general criteria were developed. The first criterion was that no customer class would 8 experience, on average, an increase of more than 20% of total revenue assuming customers 9 were taking default service. The second criterion was a benchmark calculated by10 reference to total distribution revenues. Specifically, for each rate schedule, the11company calculated two percentages, as follows: (1) revenue equal to the rate schedule s 12 cost of service divided by total-company distribution revenue under existing rates; and 13 (2) revenue under the rate schedule s existing rates divided by total-company distribution 14 revenue under existing rates. The average of those two percentages became15 a target, such that revenue produced by each rate schedule under the proposed rates, expressed 16 as a percentage of total-company distribution revenue under proposed rates, would 17 approximate the target 18 percentage Q. Turning to the design of specific rates, please describe, in general, the changes the Company proposes to its existing Residential rate schedules. A. The Residential rates were designed to recover the targeted level 21 of revenues for that class. The Company proposes that the customer charge be increased 22 by a larger 11

14 percentage than the overall revenue increase for the class to better 1 reflect actual customer-related costs. The amount of the increase is based on2 the analysis of customer- related costs that has been prepared and is provided as Penelec3Exhibit KMS-3. The Company s customer-related cost analysis was performed in the 4 same manner as the comparable customer-cost analysis presented by PPL Electric Company 5 in its 2012 electric base rate case, where that analysis was approved and used 6 as the basis for the increase in customer charges that the Administrative Law Judge 7 and the Commission 8 adopted. 2 Once the customer charge was established, customer charge revenue 9 was deducted from the total revenue target for the class to determine the revenues10to be recovered in the variable charge. The variable charge was then increased to recover 11 the non-customer 12 charge revenue for the class Q. Was the same general approach to rate design that you explained above for the Residential class employed for the other rate classes? A. Yes, it was. Customer charges were increased to better reflect 15customer-related costs and the non-customer charges of each rate schedule were increased 16to recover the remaining revenue in order to reach the class revenue target. The non-residential 17 customer charges were increased by approximately the same percentage as the distribution 18 percentage 19 increase for each non-residential rate. 2 Pa. P.U.C. v. PPL Elec. Util. Corp., Docket No. R , Recommended Decision (Oct. 19, 2012), pp , and Final Order (Dec. 28, 2012), p

15 1 2 Q. What impact, if any, will this base rate case have on riders that are in place, or are expected to be in place shortly, for the Company? A. There is a relationship between this case and the Company s existing 3 riders (the Smart Meter Technology Charge ( SMT-C ) Rider, the Universal Service 4 Cost ( USC ) Rider, the Default Service Support ( DSS ) Rider and Hourly Pricing5 Default Service ( HP ) Rider) as well as the Distribution System Improvement Charge 6( DSIC ) that is currently pending approval from the Commission. 3 I will discuss the DSIC 7 first. On February 16, 2016, the Company filed a Petition requesting8 Commission approval to implement a DSIC rider and to begin to charge an initial DSIC9rate effective July 1, Pursuant to the applicable provisions of the Public Utility Code, 10 the DSIC will recover the fixed costs of eligible property (as defined in the Code) placed 11 in service since the end of the FPFTY in the Company s last base rate case. The 12 eligible property that will form the basis for the Company s DSIC rates in effect from July 13 1, 2016 through the end of the future test year ( FTY ) in this case (the twelve months14ending December 31, 2016) are part of the plant in service that is included in the proposed 15 rate base in this case. Therefore, the fixed costs of that plant will be recovered16in the new base rates when they become effective. Accordingly, the C-Factor of the DSIC 17 will be reset to zero on the effective date of new base rates, and the E-Factor will remain 18 only to true-up prior 19 period DSIC costs and revenues. Additionally, Penelec has a SMT-C. While the SMT-C currently 20 has a charge of zero, the Company expects that the SMT-C will be updated to a positive 21 charge during the 3 I would note that the Company s State Tax Adjustment Charge is zero and is expected to remain at zero through to the effective date of the new base rates established in this case. 13

16 suspension period of this case to reflect smart meter expenditures 1 that exceed the level included in the Company s existing base rates. The costs to be2 recovered under the SMT- C have been included in developing the FPFTY revenue requirement 3 in this case and, therefore, would be recovered in the new base rates when they4become effective. Accordingly, the C-Factor of the SMT-C will be reset to zero5 on the effective date of new base rates, and the E-Factor will remain only to true-up6prior period DSIC costs 7 and revenues. In addition to the impacts on the Riders explained above, the Company 8 is proposing in this case to update the charges imposed under its DSS and HP 9Riders to reflect an increase in uncollectible accounts expense, as explained by Laura 10 W. Gifford in Penelec 11 Statement No IV. PROOF OF REVENUE ANALYSIS AND BILL COMPARISONS 13 Q. What is a proof of revenue analysis? A. A proof of revenue analysis provides the total billing units for14a specified period (January 1, 2017 through December 31, 2017, for the FPFTY), including 15 pro forma ratemaking adjustments, summarized by rate components for each rate schedule 16 and multiplied by the applicable unit rates to derive the base rate revenues that proposed 17 rates will produce. Exhibit KMS-4 contains the Company s proof of revenue analysis Q. Have you prepared an analysis of the rates in the Company s proposed tariff supplements showing their impact upon various customer classes? A. Yes. Exhibit KMS-5 sets forth the Company s comparison of21bills at current and proposed rates for the Company s residential, commercial and22industrial customers at 14

17 selected ranges of usage. The exhibit shows, among other things, 1 the percentage impact on a customer s total electric service bill based on the proposed2 rates. For example, as shown on page 1 of Penelec Exhibit KMS-5, a residential customer 3 of Penelec that receives service under Rate Schedule RS and uses 1000 kwh per 4 month would pay $ under the proposed rates, which represents an increase5 of 16.19% in the 6 customer s total bill. 7 Q. Please explain what is shown in Exhibit KMS-6. A. Filing Requirement IV-E-2 requires that the Company provide8a comparison showing costs, as defined by the cost of service study, and the proposed9base rate revenues and usage for all rate schedules. Exhibit KMS-6 depicts that comparison 10 graphically for 11 representative rate schedules V. TARIFF REVISIONS Q. Is the Company proposing any changes to its existing tariff in addition to changing the rates for service in the manner you previously described? A. Yes. The Company is proposing certain technical, non-substantive 15 revisions that are shown in the matrix of changes set forth in Exhibit KMS-7. Those 16 changes are also 17 summarized below: 1) Description of Service Territory The description of the 18 Company s service territory has been revised to conform to the Company s 19actual service territory. 15

18 2) Modification of the Definitions of Applicant and Customer(s) 1 The definitions were modified to state that an Applicant or Customer must 2 be at least 18 years 3 old, consistent with 52 Pa. Code ) Rule 2 The phrase in the amount that is equal to one-sixth 4 (1/6) of the Applicant s/customer s estimated annual bill is being5replaced with in an 6 amount that conforms to the requirements of 52 Pa. Code ) Rule 7 Currently, Rule 7 establishes standard wiring, 7apparatus, and installation obligations for the Company and the customer. This rule 8 is being modified to adopt power factor requirements that are consistent with 9 the Company s resource 10 planning documents. 11 5) Rule 10 Kilovar is being changed to kilovar. 6) Rule 11.b. Rule 11.b. deals with late payment charges. 12 The rule is being modified to reflect charges of 1.5% for residential and13 2.0% for non-residential customers pursuant to 52 Pa. Code The incremental 14 impact of this 15 change has been reflected in Exhibit KMS-2. 7) Rule 22 Rule 22 deals with the transfer of customers16between electric generation suppliers ( EGSs ). The rule is being updated 17 to conform to new 18 regulations Pa. Code Chapter 57, Subchapter M, Standards for Changing a Customer s Electricity Generation Supplier. 16

19 8) LED Street Lighting The existing tariff requires a minimum 1 installation of twelve LED lights per customer. A modification is proposed 2 so that this 3 requirement will not apply to new installations. 9) Street Lighting Schedules The rate schedules are being 4 revised to establish a 5 replacement/removal fee. 10) Outdoor Area Lighting Service Add a rate for High Pressure 6 Sodium Vapor lamps with a Nominal Lamp Rating of 150 watts to conform 7 to 112 SV150W 8 outdoor area lights that are being billed at the SV100W rate. 11) Rate Schedule Availability A number of rate schedules 9 currently require that a customer be transferred to another rate schedule if the10 customer exceeds a specified usage or demand threshold in two consecutive 11months. The availability section of the applicable rate schedules is being revised 12to provide that a review for compliance will be performed once per year, and a13 customer will be deemed out of compliance if it exceeded the specified threshold 14in two consecutive 15 months during the preceding twelve-month review period. 12) Determination of Billing Demand, Rate Schedules GS-Medium, 16 GS-Large, GP and LP Eliminate non-interval from the sentence that 17 designates the 18 customers to whom the on-peak and off-peak provisions apply. 13) Rider L Rider L is the Partial Service Rider. Language 19 was added to expressly state that the General Monthly charges listed in Rider20 L are in addition to the 17

20 charges included in the applicable rate schedule, which1makes the tariff language 2 clearly reflect the existing manner in which those charges have been applied. 3 4 Q. Please explain the proposed changes to eliminate certain options under existing street lighting and outdoor lighting rate schedules. A. The Company proposes to eliminate certain street lighting sizes 5 and general provisions within the lighting schedules that have become obsolete through 6 restrictions (grandfathering) to existing customers on certain lighting schedules 7 and a result of migration to newer technology. The Company proposes to eliminate 8 those options that are part of the rate schedules that are grandfathered for continued 9 use only by existing customers in the existing tariff; have been replaced by newer 10 technologies (such as replacing mercury vapor with high pressure sodium vapor lamps); 11 and have no customers currently on the specific option. A listing of all of the sizes and 12 provisions proposed to 13 be eliminated is set forth on the last page Exhibit KMS VI. MISCELLANEOUS MATTERS 15 Q. Please describe the provisions of 52 Pa. Code A. This section of the Commission s regulations is a Statement of 16Policy expressing the Commission s intent to examine in electric and gas rate proceedings 17 actions taken by utilities to encourage the development of cost effective energy18supply alternatives. I am responding only to 52 Pa. Code 69.36(5), which requires utilities 19 to demonstrate progressive work regarding the development of a reliable customer 20 data base. 18

21 1 2 Q. Please address the Company s efforts to develop a reliable customer data base in accordance with 52 Pa. Code 69.36(5). A. The Company has completed substantial work in this area. The 3 Company s Customer Care System currently contains data for each customer regarding 4 billing, usage and usage-related revenue, demand and demand-related revenue, rate 5 categories and a premises code. The premises code keeps track of all data associated 6 with a location, even if the customer at that location changes its name, moves, 7etc. More recently, the Company has developed a business warehouse data base that8 allows the Company to query customer-specific data. In addition to this data base, the9company routinely completes residential customer surveys, which produce additional 10 information concerning customers characteristics, such as appliance usage 11and air conditioning saturation. Also, each year the Company conducts a Large Power 12 Customer contact survey. Throughout the year, Company representatives routinely 13 meet with large customers to discuss their current and long-term needs and other 14 factors related to their electric service. These contacts provide information regarding15programs, services, rates 16 and other information which might affect their businesses. From these data bases, surveys and other contacts with customers, 17 the Company has amassed a substantial amount of information about customers 18end-use applications and their behavior and decision-making processes. This information 19 is routinely factored into 20 the Company s planning for furnishing service and conducting their operations. 19

22 1 VII. CONCLUSION 2 3 Q. Does this complete your direct testimony? A. Yes, it does. DB1/

23 APPENDIX A

24 Resume: Education and Experience of Kevin M. Siedt Penelec Statement No. 3 Witness: K. M. Siedt Appendix A Page 1 of 3 Education: 1984 Bachelor of Science Degree- Accounting/Finance, Rowan University, Glassboro, New Jersey 1994 Masters of Business Administration Degree, Moravian College, Bethlehem, PA Experience: Commercial Credit Analyst First Fidelity Bank Financial Analyst, Corporate Finance Department Foster Wheeler Corporation Senior Financial Analyst, Corporate and Project Finance Foster Wheeler Corporation Manager of Financial Analysis, Corporate and Project Finance - Foster Wheeler Corporation Director of Financial Analysis, Corporate and Project Finance Foster Wheeler Corporation Financial Consultant, Treasury Department GPU Corporation Consultant, Market Economics GPU Corporation Staff Business Analyst, Rates and Regulatory Affairs FirstEnergy Service Company Rate Analyst V, Rates and Regulatory Affairs FirstEnergy Service Company 2014 Present Consultant, Rates and Regulatory Affairs FirstEnergy Corporation Prepared and presented testimony in the following rate-related cases: Pa. P.U.C. Cases: Docket Nos. P P M M M P C C M M M M

25 Penelec Statement No. 3 Witness: K. M. Siedt Appendix A Page 2 of 3 M M M M M M P P P P R R R R M NJ BPU Cases: Docket Nos. ER EM EM EM EM EM Assisted in development and preparation of the following rate cases: Pa. P.U.C. Cases: Docket Nos. R R P M P P P R R M M M P P M-A

26 A P P P P M Penelec Statement No. 3 Witness: K. M. Siedt Appendix A Page 3 of 3