August 26, Ms. Mary Jo Kunkle Executive Secretary Michigan Public Service Commission 6545 Mercantile Way, Ste. 7 Lansing, Michigan 48911

Transcription

1 August 26, 2011 Ms. Mary Jo Kunkle Executive Secretary Michigan Public Service Commission 6545 Mercantile Way, Ste. 7 Lansing, Michigan Re: MPSC Case No. U Hospital Exceptions Dear Ms. Kunkle: Relative to the above-referenced matter, enclosed please find Detroit Medical Center, Henry Ford Health System, William Beaumont Hospital and Trinity Health-Michigan s Exceptions to Proposal for Decision, and Certificate of Service. Should you have any questions, please do not hesitate to contact the undersigned. Sincerely, Michael J. Watza Robert T. Kent (313) mike.watza@kitch.com RTK:rtk Encls. cc: All counsel of Record DET02\

2 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the matter of the application of THE DETROIT EDISON COMPANY for authority to increase its rates, amend its rate schedules and rules governing the the distribution and supply of electric energy, and for miscellaneous accounting authority. In the Matter of the Application of THE DETROIT EDISON COMPANY for Approval to defer certain pension and post-employment benefits expense for future Amortization and Recovery. Case No. U (Paperless e-file) Case No. U (Paperless e-file) DETROIT MEDICAL CENTER, HENRY FORD HEALTH SYSTEM, WILLIAM BEAUMONT HOSPITAL AND TRINITY HEALTH MICHIGAN S EXCEPTIONS TO PROPOSAL FOR DECISION I. Introduction The Intervenor Hospital LCC s, which face what is likely the largest 1 year increase of any rate payers in the State of Michigan since passage of the 2008 Energy Acts, 27-34% 1, will focus this exception brief on the 3 pages of the 138 page PFD, which are devoted to the Hospital issues (PFD , Doc. 348). Addressing points in the order set forth by Judge Cummins, the Hospitals do agree that with Judge Cummins that rates set forth in those LCCs were at least somewhat below the rates that the Hospitals would have paid had they taken service under Detroit Edison s otherwise applicable tariffs. PFD 117, Doc However the Hospitals do not agree - as has been suggested by the Company throughout the case - 1 Calculated increase based on comparison of Hospital 2010 Embedded billing determinates to; the Company s Original COSS filing at Exhibit A-14, and Staff witness Poornima Jayasheela s Exhibit S-6 Schedule F3, respectively.

3 that the Hospitals rates were ever below actual cost of service or otherwise subsidized. Id. The fact is that the Company s own records establish very clearly that for the years the LCC s were tracked by the Company, they were paying a rate at or above cost of service. See Cross-Exam Transcr (May 10, 2011), Doc. 318, Radigan Surrebuttal Testimony p It is also a fact that D-6, the otherwise applicable tariffs which the Company, Staff and now Judge Cummins suggest the Hospitals be shuffled off to where they will incur a massive rate increase from that which the Company voluntarily agreed to charge heretofore, was not and is not an appropriate rate class for the reasons further described in this brief. Had it been an appropriate rate class, the Hospitals would have been a part of it all along and never received the separate LCC agreements and treated separately from D-6 by the Company for the last 15 years. Further, the ALJ s criticism of Hospital Expert Frank Radigan s methodology for determining a just and reasonable rate at p 118 of the PFD is ironic since such criticism originates with the Company, the party charged with responsibility for tracking cost of service and who s records Mr. Radigan relied upon. The fact that the Company now, after 15 years of acquiescence, creates out of thin air, an entirely new set of numbers which they submit constitute the correct data, is absurd and instead of in turn being relied upon by Staff and the ALJ, should be flatly rejected. It is incumbent upon the Commission to establish rates that are just and reasonable. It is also incumbent upon the Commission to avoid rate shock as Staff recognized in its Initial Brief discussing the Company s proposed elimination of various 2

4 tariffs. Staff IB 72, Doc Here, because of the Company s failure to keep accurate records as it was obligated to, there is a lack of clarity in the record for several years and concern with respect to the accuracy of some of the numbers that were recorded. Accordingly, the Hospitals, blameless in all of this, should be afforded the benefit of the doubt and when the current LCC s expire, should be charged a rate consistent with the numbers and rates the Company kept during the life of the LCC s plus the amount of the overall increase granted by the MPSC in this case to industrial and commercial primary customers (which at this point based on the Judge s opinion may be 3.6%). 3 In addition, prospectively, to assure that such confusion as has occurred in this case not occur again, and so a true cost of service can be established, the Hospitals again submit that they should be placed in a separate rate class compelling the Company to conduct regular COSSs specific to and consistent with the Hospital s unique characteristics. Should a future COSS, properly performed and reviewed show a higher rate is necessary, then such can still be imposed by 2013 pursuant to the statutory requirement. This two step process thus ensures both accuracy and also avoids rate shock (if indeed a higher rate is proven) to the Hospitals in this year or 2012 as the LCC s expire. 2 Both Staff and the ALJ (in his PFD) agree that rate shock is a problem for other customers, but inexplicably they do not apply the same logic to the Hospitals. 3 This Commercial and Industrial primary customer increase was determined using Staff s Exhibit S-6, Schedule F2, p. 2 of 4, by excluding the LCCs present and proposed revenue from the remainder of the primary base. 3

5 II. Background The Hospitals were served by Detroit Edison Company (the Company ) under Large Customer Contracts ( LCCs ) which commenced in 1996, and will begin to expire in December In the current rate case, upon expiration of the LCCs, the Company proposes adding the LCC customers to Rate Schedule D-6, despite the fact that the electric usage profile of the current LCC customers, and specifically the Hospitals, is unique enough to warrant continuation of a separate rate class based on their actual cost of service. As addressed below, loss of the LCC rate class will cause immediate harm to the Hospitals by eliminating the embedded data necessary to determine the Hospital cost of service; but allowing the LCCs to remain as their own rate class, with a rate set at actual cost of service, will not harm non-lcc rate classes. III. The Recommendations Within the PFD Should Be Dismissed During the Rate Case, the Hospitals argued for the Commission to create a permanent LCC rate class with a rate based on LCC cost of service, or the alternative, create a Health Care rate class which includes the Hospitals and includes a rate based on cost of service to large health care providers, or in the alternative, extend the existing LCCs. DMC Initial Brief 26, Doc On August 18, 2011, administrative law judge Mark Cummins filed his PFD. In his PFD Judge Cummins summarily rejected the Hospitals requests because either: 1. The Hospitals have not demonstrated that their energy usage characteristics are different enough from the D-6 class to warrant creation of a separate class of rates for LCCs, or; 2. The Hospitals argument that current LCC rates are cost justified is based on an unsound premise. 4

6 PFD 118, Doc. 348 (in summary). As further discussed below, the problem with the ALJ following the logic of the Company and Staff, is that they rely on the results of a pro-forma cost of service study, a forecast cost of service study ( COSS ), to justify the elimination of the LCCs as a separate rate class. The pro-forma cost of service results purport to show that the LCCs are not providing revenues sufficient to cover the cost to serve them. The problem with the forecast cost of service study is four-fold; first, industry reference manuals distinctly state that historic or embedded cost of service studies are far superior to forecast cost of service studies; second, the results of the forecast cost of service are in direct contradiction to the results of every other cost of service study submitted by the Company; third it was not submitted with the original case which resulted in no time to adequately review it, and; fourth, when the LCCs submitted motions to compel discovery on this late filed study, the ALJ denied the motions which resulted in an inadequate review of the study. Any one of these facts would form a sufficient basis to seek relief from the recommendations from the PFD, but together they compel rejection of the recommendations in the PFD. Furthermore, not only did the Hospitals argue for the creation of a separate rate class for LCCs; the Hospitals also argued in the alternative for the creation of a separate Health Care rate class. For unknown reasons Judge Cummins failed to address the Hospitals argument for a separate Health Care rate class, but merely dismissed the Hospitals request without analysis. The Hospitals sustain their request for a separate Health Care rate class that will better reflect the cost to serve large health care providers. Lacking a reasoned rejection, the PFD on this point is unhelpful to the Commission and should not be relied upon by it. 5

7 IV. The LCCs/Hospitals Remain a Unique and Separate Class of Customers LCC customers are a unique group of customers. This uniqueness is what drew the Company to offer the LCCs to select customers in 1996 and 1997, and extend the contracts for an additional 5 years in 2006 and DMC Initial Brief 6, Doc Within the LCC customers, the Hospitals are even more unique; both in the context of their energy use profile, as well as in the important social role the Hospitals play in the State of Michigan as they safeguard the health of our citizens and provide jobs for over 100 thousand people. See DMC Initial Brief 21, Doc The above common sense prevailed during years of Company reporting in embedded cost of service reports, within which LCC customers were acknowledged as having a cost of service that was at or below both the D-6 cost of service as well as the established rate of return. DMC Initial Brief 13, and Radigan Surrebuttal Testimony p. 6-7, Cross-Exam Transcr (May 10, 2011), Doc In an opportunistic move, the Company ignored the obvious, and prepared a pro-forma future COSS for this case which completely disregarded previous embedded COSSs; inexplicably putting the LCC customers cost of service above actual revenues. Using its newly minted numbers, the Company hypothecated that LCCs will be similar to the D-6 class, and therefore, LCCs should assume the D-6 rates upon expiration of the LCCs. This smoke and mirrors manufacture of data does not provide the preponderance of the evidence necessary to send the Hospitals on a 27-34% 4 rate increase leap-of-faith into the D-6 rate class. As previously noted by the Hospitals (DMC Initial Brief 16-18, Doc. 326), the national authority on electric utility cost allocation, the National 4 See footnote 1. 6

8 Association of Regulatory Utility Commissioners ( NARUC ), recognizes this problem head-on in its Electric Utility Cost Allocation Manual (the NARUC Manual ). a. The PFD Ignores NARUC Principals Necessary To Achieve Compliance with the 2008 Michigan Energy Act In their testimony, the Hospitals expert Frank Radigan demonstrates how embedded cost of service data from previous rate cases confirm that LCCs have historically been at or above the Indexed Rate of Return ( IROR ) for the LCC service class. Radigan Surrebuttal Testimony p. 6-7, Cross-Exam Transcr (May 10, 2011), Doc In his PFD, Judge Cummins without explanation instead adopts the testimony of Company witness Timothy Bloch, who uses a modified pro-forma COSS for this case to show that the Company forecasts (guesses) that the LCC class would create a revenue deficiency. PFD 119, Doc The precedent of the Company s previous embedded COSSs cannot simply be cast aside and replaced with the Company s inflated hypothetical wholly self serving forecast (guess). As stated in the Hospitals Initial Brief and the surrebuttal testimony of Hospital Witness Frank Radigan: As to usefulness of the historic COSS, Mr. Bloch is simply mistaken. Embedded cost of service studies are a vital tool in allocating revenues amongst service classes and for designing rates. Many Commissions across the country make historic COSS a requirement as part of the rate application and Michigan is one of them; an embedded COSS is a required part of the Standard Filing Requirements of the State of Michigan. 5 By order dated May 10, 1976 the Michigan Public Service Commission adopted standard rate application filing requirements wherein exhibits detailing a fully-distributed cost of service by rate schedule must be submitted with every rate case as part of the test year standardized data. The National Association of Regulatory Utility Commissions has also spoken to the issue in its electric Utility cost Allocation Manual: MPSC U-4771 (Opinion and Order, May 10, 1976, at 7). 7

9 Cost of Service studies are among the basic tools of ratemaking Utilities developed cost studies that were based on monies actually spent (embedded) for plant and operating expenses and divided those costs (fully allocated or distributed them) among the classes of customers according to principles of cost causation. In most cost studies submitted to regulatory commissions, the accounting costs in embedded cost studies reflect the cost incurred in providing a given level of service over some time period in the past. NARUC electric Utility Cost Allocation Manual, 1992, pages 12, 13, and 16 respectively. Not only has NARUC spoken on the usefulness of embedded cost of service studies for the test year, they have also weighed in on cost of service studies that rely on future costs: To the extent that the price of inputs, technology, and managerial and technical efficiency cause the cost of providing service in the past to differ from the cost of service in the future, rates based on historic test years will be over or under collecting during the years the rates are in effect. Within the context of embedded studies, solutions to the need to incorporate future costs include recognition of known and measurable changes to the test year costs, step increases between rate cases, fuel adjustment mechanisms to give immediate recognition to variations in fuel costs and the use of forward-looking test year for the cost study. This last is the most comprehensive response to the need to reflect future costs within an embedded study. However, it has the disadvantage of relying on estimated costs rather that costs that are subject to verification and audit (Id. at page 16). Historic accounting period cost of service studies are the normal method of preparing cost of service studies, as they use only historic numbers, and one can easily measure where each service class is relative to the overall Company. A review of several historic cost of service studies and indexed rates of return (IROR) allows the analyst to examine how adequate the rates being charged to a service class are over time. IRORs greater than one indicate that the rates to the service class should be reduced to bring the IROR in line with the overall utility IROR. On the other hand IRORs which are consistently below one indicate that the rates for the service class should be increased greater than average to bring the 8

10 IROR up the overall utility average. Pro-forma COSSs are performed more rarely than historic cost of service studies for several reasons. First, proforma cost of service studies generally are done with the Company s as filed rate request. This poses many problems to the analyst as it involves many forecasts of changes in customer usage and revenues, allocation of forecast expenses, assumptions of growth in rate base, and requested rate of returns. Given that it is very rare that a utility rate case is approved as filed, the use of the pro-forma cost of service study brings very many challenges to its usefulness. DMC Initial Brief 16-18, Doc. 326, Radigan Surrebuttal Testimony p. 3-5, Cross-Exam Transcr (May 10, 2011), Doc Judge Cummins, by adoption of the Company s reasoning, provides no explanation why the Company s as-filed COSS should be adopted without some explanation why its COSS for the LCCs is so far off from the Company s historic embedded cost of service numbers. 6 Still worse, this type of rubber-stamp adoption of such disparate numbers shows zero deference to authoritative NARUC rate-making principles. Accordingly, using the Company s asfiled COSS as ammunition to demolish the LCC class is without merit, and dangerous to the Commission s statutory mandate to set customer rates at actual (not forecasted) cost of service. b. Keeping the LCC Class of Customers Cannot Harm Other Rate Payers; But Elimination of the Class Will Cause Irreparable Harm to LCC Customers Throughout this case the Hospitals have continuously run into the same problem; a lack of adequate data from the Company. Despite countless attempts, including a motion to compel (DMC Motion to Compel, April 29, 2011, Doc. 284), the Hospitals have been unable to get the Company to provide them with the data 6 It should be noted that in his PFD Judge Cummins was critical of other aspects of the Company s COSS which have much less of an impact. See Staff Initial Brief 72, Doc

11 necessary to ascertain an adequate rate for the LCC customers once their contracts expire. Failure to establish a separate rate class will abolish all hope for the LCC customers and/or the Hospitals to have the future embedded data necessary to determine an adequate cost of service rate. Once the LCC customers and/or the Hospitals are bundled into the D-6 rate class, the Company will no longer keep record for the LCC cost of service of the separate class; their unique profile will merely succumb to the dissimilar analysis of the rates of the D-6 class. This fate is unacceptable and inequitable. Upon creation of the LCC class in 1996 and 1997, the Company began collection of data that is specific to LCC customers. This data is essential to determination of actual cost of service for the LCC class. If the Company groups the LCC customers with the D-6 class, this data will no longer be available. As noted above, the Hospitals believe that future embedded COSS information will show that the LCC class will have a rate profile that is unique enough to justify a separate rate that reflects actual cost of service. Despite the fact the Company maintains existing procedures to separately monitor LCC customers, Staff currently opposes continuation of an LCC class. Staff argues that - based on the Company s as-filed COSS - establishing a new class for LCC customers is not warranted. Staff Initial Brief 63, Doc Staff argues that the NARUC Manual notes [t]he three principal rate classes are residential, commercial, and industrial and it may be reasonable to subdivide the three classes based on characteristics such as size of load, the voltage level at which the customer is served and other service characteristics, and therefore, utilities 10

12 should create as few customer classes as necessary. Staff Initial Brief 63, Doc Staff s interpretation of this section is diametrically opposed to a common sense reading of the text. All the while, Staff argues to maintain certain rate classes that the Company proposed to eliminate; D1.4 Optional Residential Service Rate (Time of Day and Space Heating Rate), and Option II of D5 Water Heating Service Rate. The reason cited by Staff, and agreed with by the ALJ, was that the rate increase imposed on these customers would be too great. Staff Initial Brief 72, Doc Staff s contradictory position related to the correct number of necessary classes is indicative of a fundamental flaw in their reasoning as it relates to LCC customers; that is, to accomplish the mandates of the 2008 Michigan Energy Act, the Commission must authorize as many classes as are necessary to reflect different load and service characteristics of each customer class. MCL p (10). There is no precedent in Michigan establishing a restrained approach to class creation. In fact, the various rate classes in the State of Michigan are too numerous to list on a single page (see DMC Reply Brief 3-4, Doc. 340). The Company, Staff, and Judge Cummins have failed to identify any parameters which the Commission should use to determine whether to create/maintain a service class. Accordingly there is no reason to deny the LCC customers the opportunity to continue their existence as a separate class and allow the LCC customers to prove to the Commission that their cost of service is lower than that of the D-6 class the Company proposes to put them in. Most importantly, there will be no harm to other rate classes by keeping the Hospitals in a separate LCC rate class; the Hospitals are merely requesting the continuance of a separate class with rates set at cost of service. 11

13 V. The Hospitals Merely Request a Rate Based On Their Cost of Service The Hospitals readily admit that due in part to the Company s failure to provide adequate reporting and discovery, the record of this case does not provide a definitive rate for the proposed LCC class continuation. In this regard the Hospitals propose the Commission establish a rate that reflects cost of service, to be used until such time as a rate may be created which reflects a reasonable compromise between future embedded cost of service and the Company s next as-filed COSS. Accordingly, the Hospitals propose they should be charged a rate consistent with the numbers and rates the Company kept during the life of the LCC s, plus the amount of the overall increase granted by the Commission to industrial and commercial primary customers (which at this point based on the Judge s opinion appears to be 3.6%). 7 VI. Amelioration of Hospital Rate Shock The overall proposed rate increase in this case pursuant to the ALJ s opinion is 3.6%. With the Company s and Staff s proposed increases, the Hospitals will experience a rate increase of about 34% or 27% respectively. 8 The Hospitals recognize they will likely experience an increase when their LCCs expire. That said, the immediate increases forecasted are unprecedented. For this reason, should the Commission determine the Hospitals must experience rate increase above 3.6%, the Hospitals request an incremented approach to raising their rates so as to prevent the 7 This number was determined using excluding the LCCs present and proposed revenue from the remainder of the primary base within Staff s Exhibit S-6, Schedule F2, p. 2 of 4. 8 See footnote 1. 12

14 resultant business and economic consequence of multi-million dollar reductions in operating capital. VII. Conclusion As stated above: The Commission should establish an LCC or Hospital rate class; creation of which will not harm other rate classes; The Hospitals LCC rates were never below cost of service; The Hospitals do not belong in the D-6 rate class; The Company s pro-forma COSS is contrary to embedded costs, and must be rejected, and; The Hospitals should not be required to endure rate shock due to the Company s failure to keep adequate records. For the above reasons, the Hospitals request continuation of the LCC customer designation in the form of a separate LCC class, or in the alternative, creation of a separate Health Care rate class. The rate for this class should be based on the actual LCC or Hospital cost of service (respectively), and should include an initial increase that is similar to the overall increase granted by the Commission in this case to industrial and commercial primary customers, with the expectation that future embedded COSSs will validate the Hospitals existence as a unique class. 13

15 Respectfully submitted, WAGNER VALITUTTI & Attorneys for the Hospitals Dated: August 26, 2011 By: Michael J. Watza (P38726) Robert T. Kent (P71897) One Woodward Ave., 24th Floor Detroit, MI Telephone: (313)

16 CERTIFICATE OF SERVICE Robert T. Kent certifies that on the 26th day of August, 2011, he served a copy of the Detroit Medical Center, Henry Ford Health System, William Beaumont Hospital and Trinity Health-Michigan s Exceptions to Proposal for Decision, in relation to MPSC Case No , upon the parties listed on the attached Service List by electronic mail.

17 Service List U & U ADMINISTRATIVE JUDGE Hon. Mark E. Cummins Administrative Law Judge Michigan Public Service Comm Mercantile Way, Ste. 7 P.O. Box Lansing, MI cumminsm1@michigan.gov COUNSEL FOR MPSC STAFF Anne M. Uitvlugt Robert W. Beach Brian W. Farkas Spencer A. Sattler Public Service Division 6545 Mercantile Way, Suite 15 Lansing, MI uitvlugta@michigan.gov beachr1@michigan.gov farkasb@michigan.gov mpscredratecase@michigan.gov sattlers@michigan.gov DETROIT EDISON COMPANY Bruce R. Maters Jon P. Christinidis Michael J. Solo Richard P. Middleton David S. Maquera One Energy Plaza, 688 WCB Detroit, MI christinidisj@dteenergy.com matersb@dteenergy.com christinidisj@dteenergy.com solom@dteenergy.com mpscfilings@dteenergy.com middletonr@dteenergy.com maquerad@dteenergy.com THE DETROIT WATER AND SEWERAGE DEPARTMENT Robert Walter Senior Assistant Corporation Counsel City of Detroit Law Department 660 Woodward Suite 1650 Detroit MI waltr@detroitmi.gov MICHIGAN ENVIRONMENTAL COUNCIL Mr. Christopher M. Bzdok James Clift Rebecca Stanfield Bradley Klein Olson, Bzdok & Howard 420 East Front Street Traverse City, MI chris@envlaw.com james@environmentalcouncil.org rstanfield@nrdc.org bkelin@elpc.org ENERGY MICHIGAN, INC. Eric J. Schneidewind 201 N. Washington Square, Suite 810 Lansing, MI ejschneidewin@varnumlaw.com

18 Michigan ATTORNEY GENERAL Donald E. Erickson Environmental Natural Resources & Agriculture Division 525 W. Ottawa St., 6th Floor Lansing, MI Michael J. McGarry Dan Salter Blue Ridge Consulting Services, Inc Woodruff Rd. Suite 2100 PMB309 Greenville, SC Sebastin Coppola Corporate Analystics 1359 Springwood Lane Rochester Hills, MI John W. Hutts GDS Associates, Inc Parkway Place, Suite 800 Marietta, GA THE KROGER COMPANY Kurt J. Boehm Boehm, Kurtz & Lowry 36 East Seventh Street, Suite 150 Cincinnati, OH Anthony J. Szilagyi, Esq. Law Offices of Anthony J. Szilagyi, Esq. 110 South Clemens Avenue Lansing, MI Kevin Higgins Energy Strategies, LLC Parkside Towers 215 South State Street, Suite 200 Salt Lake City, Utah CITY OF DETROIT Robert C. Walter Law Department 660 Woodward, Suite 1650 Detroit, MI DEAR - THE DETROIT EDISON ALLIANCE OF RETIREES Raymond O. Sturdy, Jr Thornridge Drive Plymouth, MI rstrudy@comcast.net ABATE Robert A. Strong Leland R. Rosier Clark Hill PLC 151 S. Old Woodward Ave., Ste. 200 Birmingham, MI rstrong@clarkhill.com lrrosier@clarkhill.com James T. Selecky Brubaker & Associates, Inc Swingley Ridge Road, Suite 140 Chesterfield, MO jtselecky@consultbai.com

19 LOCAL 223, UTILITY WORKERS UNION OF AMERICA John R. Canzano Meagan B. Dolleris 400 Galleria Officentre Suite 117 Southfield, MI MICHIGAN COMMUNITY ACTION AGENCY ASSOCIATION Don L. Keskey 505 North Capitol Avenue Lansing, MI m MICHIGAN CABLE TELECOMMUNICATIONS ASSOCIATION David E. S. Marvin Jennifer Utter Heston 124 W. Allegan, Suite 1000 Lansing, MI lheston@fraserlawfirm.com ENVIRONMENTAL AND POLICY CENTER Christopher M. BzDok 420 East Front Street Traverse City, MI WAL-MART STORES EAST, LP, SAM S EAST, INC. Edward C. Dawada Tyler D. Tennant Dwada, Mann, Mulcahy & Sadler, PLC Woodward Avenue, Suite 200 Bloomfield Hills, MI edawada@dmms.com ttennant@dmms.com Rick D. Chamberlain Behrens, Wheeler & Chamberlain 6 N.E. 63rd Street, Suite 400 Oklahoma City, OK rdc_law@swbell.net DET02\ MICHIGAN ENVIRONMENTAL COUNCIL Christopher M. BzDok 420 East Front Street Traverse City, MI chris@envlaw.com NATURAL RESOURCES DEFENSE COUNCIL Christopher M. BzDok 420 East Front Street Traverse City, MI chris@envlaw.com