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

Transcription

1 Penn Power Statement No. 3 BEFORE THE PENNSYLVANIA PUBLIC UTILITY COMMISSION PENNSYLVANIA POWER 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 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 800 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 1 provides regulatory support for the Pennsylvania electric utility subsidiaries 13 of FirstEnergy Corp. ( FirstEnergy ), which include Pennsylvania Power Company 14( Penn Power or the Company ). As a Consultant in the Rates and Regulatory Affairs 15 Department, my responsibilities with respect to Penn Power are to support the16 development, preparation, and presentation of the Company s retail electric rate design and 17 related rules and regulations, and ensure the uniform administration and interpretation 18 in all the Company s rate-related matters before the Pennsylvania Public 19Utility Commission ( Commission ). I also am responsible for, among other things, 0 default service plan development and implementation, recovery of non-utility generation 1 costs, regulatory program cost 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 frommoravian 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 Penn Power. 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; 1 (iv) a proof of revenue analysis; and (v) changes to Penn Power s Electric Service tariff 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: KMS-1 KMS- KMS-3 This exhibit consists of Attachments A, B and 18 C, reflecting normalized sales and revenues for the test years ending19december 31, 017, December 31, 016, and December 31, 015, respectively Summary of Present and Proposed Distribution 1 Revenues Customer Charge Analysis

5 1 4 6 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 5 Pa. Code 53.5 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 1 of energy sales, demand and base rate revenue for the twelve months ending December 13 31, 017. 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 0project the revenue to be billed under each rate schedule by month for the FPFTY. This 1detailed process assures that revenue under proposed rates can be directly tied in to thebilling determinants underlying the Company s revenues under existing rates that 3 are used to calculate its 4 revenue deficiency in this case. 3

6 1 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. Penn 4 Power 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 017 budget, 11 which formed the basis for the FPFTY level of energy sales, demand and base rate revenue, 1 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 017 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 0 use of LED street 1 lighting. 4

7 1 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, 017, December 31, 016, and December 31, 015, respectively. Summaries 15 of the Company s distribution revenues under existing and proposed rates are provided 16 in Exhibit KMS-. 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-approved0 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, 017 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 1 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 Q. Please describe the adjustments made to budget forecast data for the twelve months ending December 31, 017 to normalize and annualize revenues for conservation 1 66 Pa.C.S. 101, et seq. 6

9 1 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 3 reflect anticipated usage reductions from energy efficiency measures implemented 4 in accordance with the Company s Commission-approved Phase III EE&C Plan. The5forecasted reductions are reflected by month from January 1, 017 through December 31, The revenue reductions for the entire FPFTY were calculated by annualizing 7 the usage reduction targets that the Company must achieve by the end of its Phase 8III EE&C Plan (May 31, 01). The annualized amount was netted against the monthly9savings already included in the FPFTY sales forecast to derive the additional energy efficiency 10 normalization adjustment. The same approach was used to annualize and normalize 11 behind-the-meter generation to derive a total energy efficiency normalization adjustment. 1 The revenue effect of the annualization was calculated by multiplying the annualized 13 energy efficiency sales reductions by the average rate per customer by 14rate schedule. 15 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 designing18 the proposed rates: Rates must be designed to produce revenues equal to the 19 Company s revenue 0 requirement at the appropriate billing determinants. Rates should be designed to properly reflect cost causation 1 and, in that regard, the results of a cost of service study are used as a guide. 7

10 Rates generally should be designed, if practicable, to move 1 revenues for each rate schedule (or in some instances, customer classes consisting of aggregated rate schedules) toward that schedule s cost of service, giving 3 due regard to factors such as gradualism, economic efficiency, relative ease or 4 difficulty of 5 administration, and customer understandability. In addition to the general principles I just described, the Company 6 determined that in developing its proposed rates, it should strive to achieve the following 7 objectives: There should be a unified distribution rate design for all 8four of the FirstEnergy electric utilities that furnish service in Pennsylvania, given 9 that the Companies are managed on a consistent basis with a uniform set of business 10 processes. The rate design should give due consideration to the fact 11 that distribution service has now been fully unbundled for ratemaking purposes. 1 All else being equal, distribution rates should reflect customer 13 demand rather than energy usage. This is because distribution costs are driven 14 predominantly by investment in fixed assets, which does not vary with a15 customer s energy usage. With the implementation of the Company s Commission-approved 16 Smart Meter Deployment Plan and the significant investment in smart 17 meter technology that the Plan requires, the Company s rate design should incorporate 18 the functionality that smart meters provide to accurately measure demand. 19 Reconcilable adjustment clauses, set forth in riders to0 the Company s base rates, should be used to recover certain costs that are volatile1in nature and generally not 8

11 under the Company s control, consistent with the criteria 1 for adjustment clauses established under Section 1307 of the Public Utility Code. 3 4 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 5 Dolezal and is described in Penn Power Statement No. 4. The results of the cost 6 of service study were the starting point for designing the proposed distribution rates. 7However, the final rate designs for the distribution rates that I am recommending also 8incorporate the rate design principles and objectives that I previously described, as well as9 my experience in 10 designing utility rates. 11 Q. How did you design the proposed distribution rates? A. I began by reviewing the rates of return produced by the various 1 rate schedules under current rates and the FPFTY level of revenue requirement. The 13 rate schedules exhibit a range of returns from positive to negative. The divergent class 14returns provide an indication, based on a snapshot at a specific moment in time, 15 of the general magnitude of interclass subsidies that exist among rate classes under current 16rates. Based upon the Company s overall retail rate of return, the cost of service study 17 shows that certain rate schedules are producing less than the Company s overall rate18 of return, while others are 19 producing rates of return in excess of it. Next, I reviewed the revenue that each rate schedule would have 0 to produce to achieve a rate of return equal to the Company s overall rate of return under 1 the proposed distribution rates. This level of revenue shows the magnitude of the rate changes 9

12 necessary to move each rate schedule to its cost of service as indicated 1 by the cost of service study. While movement toward cost of service is an important element 3 in designing rates, it is not the only factor that must be considered. For instance, the impact 4 on customers bills from implementing a range of potential rate increases must be 5carefully evaluated. Establishing rates for each rate schedule that produce a retail rate 6 of return equal to the Company s overall rate of return is the theoretical target of the7rate design process. However, the Company understands that bringing some of the 8rate schedules to their indicated cost of service would impose rate decreases for some9 and/or potentially disruptive rate increases for others. The proposed rate design, 10therefore, properly applies 11 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. 14 That table also shows the unitized rates of return ( UROR ) for each rate schedule. 15 The UROR of a rate class is the class rate of return divided by the Company s overall average 16 rate of return. A class UROR greater than 1.0 indicates that the class revenue exceeds 17 the class cost of service. A class UROR less than 1.0 indicates that the class revenue 18 is less than the class cost of service. URORs are used as a guide to measure the progress 19 that changes in rates will achieve in moving classes toward a UROR of 1.0 or unity, 0 which is generally accepted as a desirable goal in rate design, subject to those other 1 rate design factors that I previously discussed. 10

13 1 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 3 to the guidance provided by the results of the Company s cost of service study, 4two general criteria were developed. The first criterion was that no customer class would 5 experience, on average, an increase of more than 0% of total revenue assuming customers 6 were taking default service. The second criterion was a benchmark calculated by reference 7 to total distribution revenues. Specifically, for each rate schedule, the8company calculated two percentages, as follows: (1) revenue equal to the rate schedule s 9 cost of service divided by total-company distribution revenue under existing rates; and 10 () revenue under the rate schedule s existing rates divided by total-company distribution 11 revenue under existing rates. The average of those two percentages became1 a target, such that revenue produced by each rate schedule under the proposed rates, expressed 13 as a percentage of total-company distribution revenue under proposed rates, would 14 approximate the target 15 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 18 of revenues for that class. The Company proposes that the customer charge be increased 19 by a larger percentage than the overall revenue increase for the class to better 0 reflect actual customer-related costs. The amount of the increase is based on 1the analysis of customer- related costs that has been prepared and is provided as Penn Power Exhibit KMS-3. The Company s customer-related cost analysis was performed in the 3 same manner as the 11

14 comparable customer-cost analysis presented by PPL Electric Company 1 in its 01 electric base rate case, where that analysis was approved and used as the basis for the increase in customer charges that the Administrative Law Judge 3 and the Commission 4 adopted. Once the customer charge was established, customer charge revenue 5 was deducted from the total revenue target for the class to determine the revenues 6to be recovered in the variable charge. The variable charge was then increased to recover 7 the non-customer 8 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 11customer-related costs and the non-customer charges of each rate schedule were increased 1to recover the remaining revenue in order to reach the class revenue target. The non-residential 13 customer charges were increased by approximately the same percentage as the distribution 14 percentage 15 increase for each non-residential rate 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 18 Default Service Support ( DSS ) Rider and Hourly Pricing Default Service ( HP ) 19 Rider and its Pa. P.U.C. v. PPL Elec. Util. Corp., Docket No. R , Recommended Decision (Oct. 19, 01), pp , and Final Order (Dec. 8, 01), p

15 proposed Distribution System Improvement Charge ( DSIC ), 1which is currently pending approval from the Commission. 3 I will discuss the DSIC first. On February 16, 016, the Company filed a Petition requesting3 Commission approval to implement a DSIC rider and to begin to charge an initial DSIC4rate effective July 1, 016. Pursuant to the applicable provisions of the Public Utility Code, 5 the DSIC will recover the fixed costs of eligible property (as defined in the Code) placed 6 in service since the end of the FPFTY in the Company s last base rate case. The eligible 7 property that will form the basis for the Company s DSIC rates in effect from July 8 1, 016 through the end of the future test year ( FTY ) in this case (the twelve months 9ending December 31, 016) are part of the plant in service that is included in the proposed 10 rate base in this case. Therefore, the fixed costs of that plant will be recovered11in the new base rates when they become effective. Accordingly, the C-Factor of the DSIC 1 will be reset to zero on the effective date of new base rates, and the E-Factor will remain 13 only to true-up prior 14 period DSIC costs and revenues. In addition, to the impact of the DSIC, discussed above, the Company 15 is proposing in this case to update the charges imposed under its DSS and HP Riders 16 to reflect an increase in uncollectible accounts expense, as explained by Laura W. Gifford 17 in Penn Power 18 Statement No 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 1 IV. PROOF OF REVENUE ANALYSIS AND BILL COMPARISONS Q. What is a proof of revenue analysis? A. A proof of revenue analysis provides the total billing units for 3a specified period (January 1, 017 through December 31, 017, for the FPFTY), including4 pro forma ratemaking adjustments, summarized by rate components for each rate schedule 5 and multiplied by the applicable unit rates to derive the base rate revenues that proposed 6 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 of10bills at current and proposed rates for the Company s residential, commercial and11industrial customers at 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 proposed 13 rates. For example, as shown on page 1 of Penn Power Exhibit KMS-5, a residential14 customer of Penn Power that receives service under Rate Schedule RS and uses 1000 kwh 15 per month would pay $ under the proposed rates, which represents an increase 16of 13.08% in the 17 customer s total bill. 18 Q. Please explain what is shown in Exhibit KMS-6. A. Filing Requirement IV-E- requires that the Company provide 19a comparison showing costs, as defined by the cost of service study, and the proposed 0base rate revenues and usage for all rate schedules. Exhibit KMS-6 depicts that comparison 1 graphically for representative rate schedules. 14

17 1 3 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 4 revisions that are shown in the matrix of changes set forth in Exhibit KMS-7. Those 5 changes are also 6 summarized below: 1) Description of Service Territory The description of the 7 Company s service territory has been revised to conform to the Company s8 actual service territory. ) Modification of the Definitions of Applicant and Customer(s) 9 The definitions were modified to state that an Applicant or Customer 10 must be at least 18 years 11 old, consistent with 5 Pa. Code ) Rule The phrase in the amount that is equal to one-sixth 1 (1/6) of the Applicant s/customer s estimated annual bill is being13replaced with in an amount that conforms to the requirements of 5 Pa. Code ) Rule 7 Currently, Rule 7 establishes standard wiring, 15apparatus, and installation obligations for the Company and the customer. This rule 16 is being modified to adopt power factor requirements that are consistent with 17 the Company s resource 18 planning documents. 19 5) Rule 10 Kilovar is being changed to kilovar. 6) Rule 11.b. Rule 11.b. deals with late payment charges. 0 The rule is being modified to reflect charges of 1.5% for residential and1.0% for non-residential 15

18 customers pursuant to 5 Pa. Code 56.. The incremental 1 impact of this change has been reflected in Exhibit KMS-. 7) Rule Rule deals with the transfer of customers 3between electric generation suppliers ( EGSs ). The rule is being updated 4 to conform to new 5 regulations 4. 8) LED Street Lighting The existing tariff requires a minimum 6 installation of twelve LED lights per customer. A modification is proposed 7 so that this 8 requirement will not apply to new installations. 9) Street Lighting Schedules The rate schedules are being 9 revised to establish a 10 replacement/removal fee. 10) Rate Schedule Availability Rate schedules GS-Medium 11 and GS Large currently require that a customer be transferred to another rate schedule 1 if the customer exceeds a specified usage or demand threshold in two13 consecutive months. The availability section of the applicable rate schedules is 14 being revised to provide that a review for compliance will be performed once per year, 15 and a customer will be deemed out of compliance if it exceeded the specified16 threshold in two consecutive months during the preceding twelve-month 17review period. 11) Determination of Billing Demand, Rate Schedule GS-Medium, 18 GS Large, GP, GT Eliminate non-interval from the sentence that designates 19 which customers the 0 on-peak and off-peak provisions apply. 4 5 Pa. Code Chapter 57, Subchapter M, Standards for Changing a Customer s Electricity Generation Supplier. 16

19 1) Change GS Large to be part of the commercial class for1 the Default Service Support Rider, to be billed on a kwh basis. 13) Rider L Rider L is the Partial Service Rider. Language 3 was added to expressly state that the General Monthly charges listed in Rider L4 are in addition to the charges included in the applicable rate schedule, which5makes the tariff language clearly reflect the existing manner in which those charges 6 have been applied. 14) Definition of Primary Voltage The definition is being7 revised to state that 8 Primary Voltage cannot exceed 3,000 volts. 15) Definition of Sub-Transmission Voltage The definition 9 is being revised to by adding the following: Sub-transmission Voltage Voltage 10 at 3,000 volts 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 13 and general provisions within the lighting schedules that have become obsolete through 14 restrictions (grandfathering) to existing customers on certain lighting schedules 15 and a result of migration to newer technology. The Company proposes to eliminate 16 those options that are part of the rate schedules that are grandfathered for continued 17 use only by existing customers in the existing tariff; have been replaced by newer 18 technologies (such as replacing mercury vapor with high pressure sodium vapor lamps); 19 and have no customers currently on the specific option. A listing of all of the sizes and 0 provisions proposed to 1 be eliminated is set forth on the last page Exhibit KMS-6. 17

20 1 VI. MISCELLANEOUS MATTERS Q. Please describe the provisions of 5 Pa. Code A. This section of the Commission s regulations is a Statement of3policy expressing the Commission s intent to examine in electric and gas rate proceedings 4 actions taken by utilities to encourage the development of cost effective energy5supply alternatives. I am responding only to 5 Pa. Code 69.36(5), which requires utilities 6 to demonstrate progressive work regarding the development of a reliable customer 7 data base. 8 9 Q. Please address the Company s efforts to develop a reliable customer data base in accordance with 5 Pa. Code 69.36(5). A. The Company has completed substantial work in this area. The 10 Company s Customer Care System currently contains data for each customer regarding 11 billing, usage and usage-related revenue, demand and demand-related revenue, rate 1 categories and a premises code. The premises code keeps track of all data associated 13 with a location, even if the customer at that location changes its name, moves, 14etc. More recently, the Company has developed a business warehouse data base that 15allows the Company to query customer-specific data. In addition to this data base, the 16Company routinely completes residential customer surveys, which produce additional 17 information concerning customers characteristics, such as appliance usage 18and air conditioning saturation. Also, each year the Company conducts a Large Power 19 Customer contact survey. Throughout the year, Company representatives routinely 0 meet with large customers to discuss their current and long-term needs and other 1 factors related to their electric service. These contacts provide information regardingprograms, services, rates 3 and other information which might affect their businesses. 18

21 From these data bases, surveys and other contacts with customers, 1 the Company has amassed a substantial amount of information about customers end-use applications and their behavior and decision-making processes. This information 3 is routinely factored into the Company s planning for furnishing service and conducting4their operations. 5 VII. CONCLUSION 6 7 Q. Does this complete your direct testimony? A. Yes, it does. DB1/

22 APPENDIX A

23 Resume: Education and Experience of Kevin M. Siedt Penn Power 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 014 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

24 Penn Power Statement No. 3 Witness: K. M. Siedt Appendix A Page 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

25 A P P P P M Penn Power Statement No. 3 Witness: K. M. Siedt Appendix A Page 3 of 3