June 12, Ms. Mary Jo Kunkle Executive Secretary Michigan Public Service Commission 4300 W. Saginaw Highway P.O. Box Lansing, MI 48909

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1 Founded in 182 by Sidney Davy Miller PUL MICHEL COLLINS TEL (17) FX (17) 7-60 E-MIL Miller, Canfield, Paddock and Stone, P.L.C. One Michigan venue, Suite 900 Lansing, Michigan 89 TEL (17) FX (17) June 12, 201 MICHIGN: nn rbor Detroit Grand Rapids Kalamazoo Lansing Saginaw Troy FLORID: Tampa ILLINOIS: Chicago NEW YORK: New York OHIO: Cincinnati CND: Toronto Windsor CHIN: Shanghai MEXICO: Monterrey POLND: Gdynia Warsaw Wrocław Ms. Mary Jo Kunkle Executive Secretary Michigan Public Service Commission 00 W. Saginaw Highway P.O. Box 0221 Lansing, MI 8909 Re: Michigan Gas Utilities Corporation GCR Plan and Factors MPSC Case No. U-1710 Dear Ms. Kunkle: Enclosed for electronic filing on behalf of Michigan Gas Utilities Corporation is Rebuttal Testimony and Exhibits of Sarah R. Mead, Rebuttal Testimony and Exhibits of Matthew M. Dirksen, and Rebuttal Testimony and Exhibits of David J. Tyler. lso is a Proof of Service for same Should you have any questions, please kindly advise. Very truly yours, Miller, Canfield, Paddock and Stone, P.L.C. PMC/jlc cc: LJ Mark Eyster David L. Shaltz Donald Erickson John Janiszewski Heather Durian Frank Hollewa Sebastian Coppola David J. Tyler By: Paul M. Collins \

2 STTE OF MICHIGN BEFORE THE MICHIGN PUBLIC SERVICE COMMISSION * * * * In the matter of the application of ) MICHIGN GS UTILITIES CORPORTION ) Case No. U-1710 for authority to implement a gas cost recovery plan and factors for the 12-month period from pril 201 through March 201, and for related approvals. ) ) ) STTE OF MICHIGN ) )ss COUNTY OF INGHM ) PROOF OF SERVICE Jeri L. Clevenger, being first duly sworn, deposes and says that on June 12, 201, she served a copy of Michigan Gas Utilities Corporation s Rebuttal Testimony and Exhibits of Sarah R. Mead, Rebuttal Testimony and Exhibits of Matthew M. Dirksen and Rebuttal Testimony and Exhibits of David J. Tyler on the parties listed below via electronic mail as follows: David L. Shaltz Donald Erickson John. Janiszewski Heather Durian Sebastian Coppola Frank Hollewa Subscribed and sworn before me on this 12th day of June, 201. Jeri L. Clevenger Theresa M. Briseno, Notary Public Eaton County, cting in Ingham My Commission Expires: 0/29/ \

3 S T T E O F M I C H I G N BEFORE THE MICHIGN PUBLIC SERVICE COMMISSION * * * * In the matter of the application of ) MICHIGN GS UTILITIES CORPORTION ) Case No. U-1710 for authority to implement a gas cost recovery plan and ) factors for the 12-month period from pril 201 through ) March 201, and for related approvals. ) ) REBUTTL TESTIMONY ND EXHIBITS OF SRH R. MED On Behalf of Michigan Gas Utilities Corporation Dated: June 12, 201

4 1 TESTIMONY 2 SECTION I BCKGROUND PLESE STTE YOUR NME, POSITION ND BUSINESS DDRESS. My name is Sarah R. Mead. My business address is Integrys Energy Group, Inc. ( Integrys ), 700 North dams Street, P.O. Box 19001, Green Bay, WI My position at Michigan Gas Utilities Corporation ( MGUC or the Company ) is Manager Gas Supply. RE YOU THE SME SRH R. MED WHO SUBMITTED DIRECT TESTIMONY IN THIS PRECEDING ON DECEMBER 21, 2012? Yes, I am. WHT IS THE PURPOSE OF YOUR REBUTTL? I am testifying regarding certain recommendations made by Sebastian 18 Coppola in his direct testimony filed on behalf of the ttorney General ( G ) 19 on May 1, 201. I am also testifying regarding certain recommendations made by Frank 20 Hollewa in his direct testimony filed on behalf of the Residential Ratepayer Consortium 21 ( RRC ) also on May 1,

5 The absence of rebuttal on other aspects of the Staff s, G s, and 1 RRC s direct cases should not be taken as an indication that the Company agrees with 2 the positions not addressed in my testimony RE YOU SPONSORING NY EXHIBITS IN CONNECTION WITH YOUR REBUTTL TESTIMONY? Yes, I am sponsoring the following exhibit, which was prepared 7 by me or under my direction and supervision: Revised Exhibit -7 (SRM-7) Price Contingency Matrix Exhibit -18 (SRM-8) ttorney General Discovery Request 101-G-2 Exhibit -19 (SRM-9) ttorney General Discovery Request 1101-G-21 PLESE EXPLIN WHT HS BEEN REVISED IN EXHIBIT 1-7 (SRM-7)? The exhibit has been revised to reflect corrections made in response 1 to an inquiry made by the ttorney General during discovery. The response to the 1 ttorney General s discovery request is included in Exhibit -18 (SRM-8). Revised 16 Exhibit -7(SRM-7) no longer reflects the quartile analysis percentages throughout the 17year and instead now utilizes the minimum hedge targets by month as filed. The revised 18 exhibit also reflects updated transportation fuel that was incorrect in the original filing 19 and a system-average heating value that is more representative of the planned purchases. 20 (These updated parameters can be found on the tab entitled Fractional Multipliers 21 in the Excel spreadsheet distributed to the parties during discovery.) 2

6 1 2 DO YOU GREE WITH MR. COPPOL S RECOMMENDTION ON PGE 8, LINES 7 10 OF HIS DIRECT TESTIMONY THT THE COMPNY NEEDS TO ENSURE THE MJORITY OF THE CLL/SWING SUPPLIES RE BCKED BY FIRM TRNSPORT? No, the Company believes that the obligation in the call/swing6contracts is equivalent to the obligation in a contract for firm transportation capacity. Exhibit 7-19 (SRM-9) contains MGUC s response to a discovery request by the ttorney 8 General describing the obligation in the call/swing contracts. s demonstrated by the9quoted portion of the representative call/swing supply contract shown on page 2 of10 Exhibit -19 (SRM-9), the supplier of a call/swing package is not excused from performance 11 unless firm transportation capacity has also failed. Thus the Company would 12 be in the same position regardless of whether it had relied on a call/swing package or1 a contract for firm 1 transportation capacity HOW DOES THE COMPNY RESPOND TO MR. COPPOL S RECOMMENDTION, ON PGE 10, LINES 9-12 OF HIS DIRECT TESTIMONY, THT THE COMPNY SHOULD MODIFY ITS GS SUPPLY STRTEGY FOR PERIODS OF LOWER THN NORML GS DEMND? MGUC does not agree that the purchases should be reduced in21 November/December; however, as I will discuss later, MGUC22 does agree that reducing purchases is a viable tool for the latter part of the GCR 2 period. During

7 the early portion of the winter (November/December), the Company 1 will maintain the limit of 10,000 Dth per day of additional withdrawals from2storage in response to periods of lower than normal gas demand. MGUC believes that this limit is necessary to prevent under purchasing for meeting normal demand, which could inhibit the Company s ability to cover a Peak Day during the early part of the winter season. This 10,000 Dth per day withdrawal is in addition 6 to the already planned storage withdrawals. For example, in a 0-day month7like November, the plan for responding to lower than normal gas demand would allow 8 for 00,000 Dth to be withdrawn in addition to the already planned withdrawal 9 -- an increase in storage withdrawals of nearly 0%. MGUC will not increase 10 the additional maximum daily withdrawal beyond the 10,000 Dth per day limit 11 because this could unnecessarily increase the risk of draining the storage accounts 12 prematurely during the winter, which could place the Company at risk of relying 1 on additional monthly or daily purchases during the latter part of the GCR period HOW DOES THE COMPNY PLN TO MNGE ITS STORGE DURING THE LTTER PRT OF THE WINTER SESON (JNURY MRCH) IN THE EVENT OF WRMER THN NORML WETHER? If warmer than normal weather is experienced during the latter part of the winter and gas is available in storage, MGUC will increase withdrawals starting in February. Higher withdrawals will be limited to 10,000 Dth per day. In conjunction with higher withdrawals, MGUC may also reduce its

8 first of the month purchases. The determination to reduce purchases from the Plan will occur prior to purchasing supply for the next month. MGUC will gather the data in the Plan, including current estimates and end of the month estimates related to the gas levels in the storage assets and will utilize this data to determine if any adjustments are needed to either planned storage or to monthly first of the month purchases. If an adjustment is needed, MGUC will take a phased approach to spread the long position over the remaining months in the Plan year HOW DOES THE COMPNY RESPOND TO MR. COPPOL S RECOMMENDTION ON PGE 1, LINES 1-2 OF HIS DIRECT TESTIMONY, THT MGUC SHOULD PERFORM GS SUPPLY NLYSIS? The Company is currently performing a gas supply analysis as 1part of the Company s consideration for renewal of the NR contracts that will expire 1in the spring of 201. fter the analysis is complete, the Company will engage in negotiations. 16 MGUC plans to describe the results of the analysis in the GCR Plan 17case. IS THE COMPNY PLNNING TO EXPLORE NY PEK SHVING STORGE SERVICES? Yes, as agreed to in discovery with Mr. Hollewa in Exhibit RRC-2 21 (FJH-2), MGUC will explore Bluewater for peak shaving and it will also contact NR 22 to explore similar 6

9 services. ON PGE 1, LINES 17 19, OF HIS DIRECT TESTIMONY, MR. COPPOL UESTIONS WHY THE COMPNY WOULD ENTER N SSET MNGEMENT GREEMENT IN THE MIDDLE OF THE GCR PLN YER. HOW DOES MGUC RESPOND? The planned sset Management greements ( M ), to which 6 Mr. Coppola refers, will assign MGUC s PEPL transportation capacity for the winter 7 season only. The PEPL transportation capacity contract has a larger Maximum Daily uantity 8 ( MD ) during the winter period. Given the short length of the M, MGUC9 does not believe it would be prudent to enter an agreement prior to filing the GCR Plan10 in December The economics could change, making the M less favorable and11 limiting the Company s ability to extract the maximum value from the M. MR. HOLLEW, ON PGE, LINES 18 20, OF HIS DIRECT TESTIMONY, RECOMMENDS THT THE COMPNY INCLUDE IN ITS REUEST FOR PROPOSL BIDS FOR FIVE, TEN ND TWENTY-DY CLLS T BENTON HRBOR ND CONSUMERS. DOES THE COMPNY GREE? MGUC does not object to including ten and twenty-day calls 19 in its Request for Proposal ( RFP ), which will be issued prior to the winter period for delivery 20 at the Benton Harbor and Consumers gate stations. MGUC does not agree that the RFP should request bids on five-day 22 call packages. The Company believes that five-day call packages create an unreasonable 2 risk of not having 7

10 secured enough supply to cover prolonged periods of colder than 1 normal weather days during the winter. If the Company exhausted the five-day call2package, MGUC could be forced into the day market to purchase daily supplies. If the Commission does order MGUC to rely upon five-day call packages, the Company would expect that costs associated with daily purchases after the five-day call has been exhausted would be 6 recoverable in the GCR reconciliation case LSO, MR. HOLLEW RECOMMENDS THT THE COMPNY INCLUDE IN ITS RFP BIDS FOR TEN ND TWENTY-DY CLLS FOR DTE. DOES THE COMPNY GREE? MGUC agrees to add to its RFP Firm DTE call/swing packages 11 of supply to be delivered at North Grand Haven City Gate. In the past few years, MGUC 12 has not requested proposals for DTE (previously known as MichCon) because DTE 1 only connects with the North Grand Haven portion of MGUC s service territory, which 1 limits this service s flexibility for use in meeting overall system demand. However, 1 MGUC will add the DTE call/swing packages to the RFP and evaluate any potential cost 16savings in relation to loss 17 of flexibility for meeting overall system demand DOES THE COMPNY CONCUR WITH MR. HOLLEW S SUGGESTION, ON PGE, LINE 22 ND PGE, LINES 1 OF HIS DIRECT TESTIMONY, THT THE COMPNY ISSUE SECOND RFP FOR 91-DY SWING SUPPLY? No, it does not. The Company does not believe there will be 2 a benefit in issuing two 8

11 RFP s for the same time period for similar products. The use of 1 two RFPs for similar products would unnecessarily increase the time and cost of the2rfp process both internally and externally for the bidders who would have to price out similar supply locations at two different times during a relatively short turn around period. The Company fears this could limit future bids and result in increased cost of supply. During discovery, Mr. Hollewa indicated his recommendation6for a second RFP for the swing packages is based upon the belief that enough call packages 7 will be available to make swing supply unnecessary for meeting peak day requirements. 8 The Company believes that one RFP is sufficient to obtain bids for a variety of 9 call and swing packages, as MGUC typically accepts the most favorable supply package 10and pricing offered from the bidders. s such, MGUC believes that a second RFP for11 swing supply is not 12 necessary DOES THE COMPNY ONLY SEND ONE RFP PER YER FOR FIRM BSE-LOD SUPPLY, CLL ND SWING PCKGES? Yes. The Company issues only one RFP per year for all firm16 base-load supply, call and swing packages. However, the Company will send an additional 17 RFP if it is seeking bids for a short-term M, like the one that has previously involved 18 PEPL. It has been MGUC s practice to send an M request individually, as it19 is more complex than a call, swing or base-load supply request. n M has unique aspects 20 associated with it that vary with each request, but call, swing and base-load follow similar 21 industry standards in what each entails; and, therefore, require less explanation to the 22 bidders. 9

12 1 2 MR. HOLLEW, ON PGE, LINE 20 OF HIS DIRECT TESTIMONY, RECOMMENDS THT THE COMPNY S RFP EUL TOTL COMBINED DELIVERY OF 8,000 DTH/DY. DOES THE COMPNY HVE CONCERNS WITH THIS? Yes, the Company will accept bids for multiple products and assumes that the combination of accepted bids will exceed 8,000 Dth/day. The6 Company currently forecasts a shortfall on a peak day of 8,11 Dth/day that it needs 7 to cover, but it also utilizes these call/swing packages to cover non-peak days and colder 8 than normal days during the winter, in addition to storage, while taking into consideration 9 operational needs. The company plans for an average temperature and an10 average day for each month, but realizes that temperature fluctuates day to day and11 the day of week also has an effect. For example, the forecast for a Saturday at a certain temperature 12 may be less than the forecast for a Tuesday at the same temperature. To account 1 for this type of load variation and limit overrun charges on the days that deviate from 1 planned normal, MGUC 1 will sometimes utilize the call/swing packages HOW DOES THE COMPNY RESPOND TO MR. HOLLEW S RECOMMENDTION ON PGE 6, LINES 18-22, REGRDING THE UTILIZTION FOR PEK SUPPLY OF PRTELLO/NDERSON THT RE CURRENTLY SHUT IN? s responded to in discovery with Mr. Hollewa in Exhibit RRC-1 21 (FJH-1), the Company is taking a conservative approach to Partello/nderson and is22 therefore uncomfortable using this field for peak shaving at this time. However the Company 2 is willing to discuss 10

13 this recommendation with Mr. Hollewa and the other parties, and 1 accordingly, MGUC suggests a technical conference to be scheduled during the fall2of this year HOW DOES THE COMPNY RESPOND TO MR. HOLLEW S RECOMMENDTION, ON PGE 10, LINES 9, OF HIS DIRECT TESTIMONY, THT THE COMPNY SHOULD SSUME THT T LEST 0% OF SCHEDULED CHOICE CUSTOMER VOLUMES WOULD BE VILBLE TO MEET PEK DY REUIREMENTS ND THEREFORE REDUCE THE DILY MOUNT OF SWING SUPPLY? MGUC does not agree with Mr. Hollewa s recommendation because 10 relying on supply delivered by lternative Gas Suppliers ( GS ) for GCC customers 11 to meet peak day demand would be inconsistent with the Company s duty to serve 12 as the supplier of last resort for all GCC customers. The Company s tariffs require1 that it serve as supplier of last resort for all GCR and Gas Customer Choice ( GCC ) customers. 1 This means that MGUC must have the necessary assets in place to provide supply 1 to both GCR and GCC customers during peak cold weather conditions. This duty is 16 not excused if any or all of the GS fail to deliver supply MR. HOLLEW, ON PGE 1, LINES 1- OF HIS DIRECT TESTIMONY, RECOMMENDS THT THE COMPNY ISSUE N OPERTIONL FLOW ORDER ( OFO ) FOR NY WEEKEND ND/OR HOLIDY WHERE POTENTIL SUPPLY/DEMND IMBLNCE IS FORECSTED. HOW DOES THE COMPNY RESPOND? 11

14 . It is the Company s intent to implement an OFO in such circumstances 1 in accordance with tariff section C.2 Sheet No. C-9.00 C of the MGUC 2 Rate book DOES THIS COMPLETE YOUR DIRECT TESTIMONY T THIS TIME?. Yes it does \

15 MICHIGN PUBLIC SERVICE COMMISSION MICHIGN GS UTILITIES GCR CEILING PRICE CONTINGENCY MTRIX Case No Revised Exhibit -7 (SRM-7) Page 1 of 2 Witness: Sarah R. Mead pril-june July-Sept Oct-Dec Jan-Mar 1st tr 2nd tr rd tr th tr Summer Winter Summer Winter Summer Winter Summer Winter pril- Nov- pril- Nov- pril- Nov- pril- Nov- Oct Mar Oct Mar Oct Mar Oct Mar Fractional Multi Fm Plan NYMEX (Xplan) $.7278 $.1096 $.7278 $.1096 $.7278 $.1096 $.7278 $.178 Base GCR Factor $.0812 $.0812 $.0812 $.0812 NYMEX Increase Greater than But less or Equal to than Incremental Contingency GCR Factor ($/Mcf) $0.00 $0.0 $ $ $ $ $ $ $ $ $0.0 $0.10 $ $ $ $0.029 $0.017 $0.02 $0.017 $ $0.10 $0.1 $0.09 $0.07 $0.02 $0.018 $0.01 $0.006 $0.027 $0.078 $0.1 $0.20 $0.068 $0.068 $0.029 $ $0.070 $0.079 $0.012 $ $0.20 $0.2 $ $0.091 $0.070 $0.10 $ $ $0.09 $0.117 $0.2 $0.0 $ $0.112 $ $0.129 $0.078 $0.126 $ $0.16 $0.0 $0. $0.117 $0.170 $0.107 $0.1 $0.090 $0.117 $0.082 $0.17 $0. $0.0 $0.16 $0.198 $0.12 $ $ $ $ $0.202 $0.0 $0. $0.176 $ $0.110 $ $0.12 $0.202 $ $0.21 $0. $0.0 $0.197 $0.20 $0.186 $0.229 $0.109 $ $0.12 $0.260 $0.0 $0. $0.219 $0.228 $ $0.288 $0.166 $0.228 $0.172 $ $0. $0.60 $0.21 $0.211 $0.199 $0.287 $0.172 $ $0.109 $0.182 $0.60 $0.6 $0.26 $0.270 $0.211 $0.106 $ $0.0 $0.166 $0.71 $0.6 $0.70 $0.28 $ $ $0.6 $0.206 $0.287 $0.178 $0.760 $0.70 $0.7 $0.072 $0.196 $0.267 $0.62 $ $0.0 $ $0.09 $0.7 $0.80 $0.292 $0.2 $0.26 $0.882 $0.29 $0.79 $0.208 $0.9 $0.80 $0.8 $0.11 $0.6 $ $0.11 $0.206 $0.06 $0.219 $0.628 $0.8 $0.90 $0.71 $0.881 $ $0.00 $ $0.298 $0.22 $0.917 $0.90 $0.9 $0.90 $0.110 $0.172 $0.68 $ $0.1 $0.270 $0.206 $0.9 $1.00 $0.170 $0.8 $0.9 $0.917 $0.297 $0.80 $ $0.9 $1.00 $1.0 $0.89 $0.66 $0.2 $0.176 $0.12 $0.07 $0.27 $0.78 $1.0 $1.10 $0.609 $0.79 $0.701 $0. $0.289 $0.10 $ $0.607 $1.10 $1.1 $0.828 $0.02 $0.877 $0.69 $0. $0.6 $0.018 $0.66 $1.1 $1.20 $0.08 $0.21 $0.0 $0.92 $0.602 $0.81 $0.16 $0.662 $1.20 $1.2 $0.267 $0.79 $0.20 $ $0.78 $ $0.29 $0.692 $1.2 $1.0 $0.87 $0.708 $0.06 $0.670 $0.91 $0.621 $0.0 $0.721 $1.0 $1. $0.706 $0.96 $0.82 $ $0.072 $0.67 $0.67 $0.720 $1. $1.0 $0.926 $0.616 $0.79 $ $0.228 $ $0.70 $ $1.0 $1. $0.61 $0.69 $0.9 $0.726 $0.8 $ $0.82 $ $1. $1.0 $0.66 $ $0.111 $0.70 $0.1 $0.7 $0.979 $0.888

16 MICHIGN PUBLIC SERVICE COMMISSION MICHIGN GS UTILITIES GCR CEILING PRICE CONTINGENCY MTRIX Case No Revised Exhibit -7 (SRM-7) Page 2 of 2 Witness: Sarah R. Mead pril-june July-Sept Oct-Dec Jan-Mar 1st tr 2nd tr rd tr th tr Summer Winter Summer Winter Summer Winter Summer Winter pril- Nov- pril- Nov- pril- Nov- pril- Nov- Oct Mar Oct Mar Oct Mar Oct Mar Fractional Multi Fm Plan NYMEX (Xplan) $.7278 $.1096 $.7278 $.1096 $.7278 $.1096 $.7278 $.178 Base GCR Factor $.0812 $.0812 $.0812 $.0812 NYMEX Increase Greater than But less or Equal to than Incremental Contingency GCR Factor ($/Mcf) $1.0 $1. $0.68 $0.689 $0.287 $0.776 $0.698 $0.78 $0.116 $ $1. $1.60 $0.680 $ $0.6 $0.802 $0.8 $0.788 $0.2 $ $1.60 $1.6 $0.702 $0.706 $0.60 $ $0.011 $ $0.91 $0.926 $1.6 $1.70 $0.722 $0.7 $0.816 $0.80 $0.168 $0.8 $0.28 $0.9 $1.70 $1.7 $0.762 $0.776 $0.992 $ $0.2 $0.897 $0.66 $0.98 $1.7 $1.80 $ $ $ $0.908 $0.81 $0.880 $0.802 $1.012 $1.80 $1.8 $ $ $0.6 $0.917 $0.68 $ $0.99 $1.01 $1.8 $1.90 $ $0.87 $0.621 $0.976 $0.79 $0.9 $0.077 $ $1.90 $1.9 $0.80 $ $ $0.98 $0.91 $ $0.21 $ $1.9 $2.00 $0.89 $0.890 $0.687 $1.009 $ $ $0.1 $ $2.00 $2.0 $ $0.912 $0.700 $1.02 $0.626 $1.011 $0.88 $1.169 $2.0 $2.10 $ $0.961 $ $ $0.621 $1.067 $0.62 $1.189 $2.10 $2.1 $ $0.989 $0.702 $ $0.677 $ $0.76 $1.218 $2.1 $2.20 $0.97 $ $0.779 $ $0.67 $ $0.900 $1.27 $2.20 $2.2 $0.966 $1.006 $0.77 $1.187 $ $1.112 $0.607 $ $2.2 $2.0 $ $1.027 $0.791 $1.166 $0.707 $1.178 $0.617 $1.016 $2.0 $2. $1.009 $1.002 $ $1.190 $0.720 $1.161 $0.611 $1.0 $2. $2.0 $1.01 $1.071 $0.828 $1.216 $0.760 $1.188 $0.69 $1.9 $2.0 $2. $1.0 $1.099 $0.860 $1.222 $0.717 $1.217 $0.686 $1.88 $2. $2.0 $1.07 $ $0.866 $ $0.767 $1.290 $0.672 $1.17 $2.0 $2. $1.097 $1.11 $ $1.290 $0.780 $1.262 $ $1.62 $2. $2.60 $1.119 $1.16 $ $1.199 $ $1.289 $ $1.71 $2.60 $2.6 $1.112 $ $0.916 $1.7 $0.81 $1.18 $0.71 $1.00 $2.6 $2.70 $1.162 $ $0.91 $1.716 $0.800 $1.01 $ $1.0 $2.70 $2.7 $1.181 $1.229 $0.917 $1.97 $0.86 $1.6 $0.709 $1.619 $2.7 $2.80 $ $1.27 $0.969 $1.2 $0.861 $1.907 $0.76 $1.908 $2.80 $2.8 $ $1.278 $ $1.9 $ $1.19 $0.768 $ $2.8 $2.90 $1.209 $1.01 $1.006 $1.71 $ $1.12 $ $1.686 $2.90 $2.9 $ $1.22 $ $1.010 $0.908 $1.66 $0.798 $ $2.9 $.00 $1.298 $1.70 $1.099 $1.269 $0.929 $1.918 $0.809 $1.706

17 MICHIGN PUBLIC SERVICE COMMISSION Case No. U-1710 MICHIGN GS UTILITES CORPORTION Exhibit -18 (SRM-8) Witness: Sarah R. Mead Page 1 of 1 Michigan Gas Utilities Corporation Michigan Public Service Commission Case No. U-1710 ttorney General s First Discovery Request 01-G-2 Response With regard to Exhibit -7, please provide the Excel model that calculates the Fractional Multi Fm for each quarter and the assumptions underlying these calculations. The Excel spreadsheet for Exhibit -7, as originally filed, has been provided in response to 01-G-02. However, based upon the testimony of Robert G. Ozar, Lisa M. Kindschy and Nora B. uilico in Case Nos. U-100 and U-171, MGUC now plans to revise Exhibit -7 (SRM-7) because the underlying data for the exhibit, as filed, did not reflect the transition from the quartile analysis methodology to the current hedging methodology. ttachment 01-G-2 contains the Excel spreadsheet for a draft revised Exhibit -7. Exhibit -7 Price Contingency REDLINED.xlsx is also provided to assist in identifying the cells that have been revised or are no longer valid. The draft revised exhibit Exhibit -7 Price Contingency (REVISED on _26_201).xlsx now reflects the current hedging methodology. Specifically, the exhibit has been revised to no longer utilize the quartile analysis percentages throughout the year and now utilizes the minimum hedge targets by month as filed. The revised exhibit also reflects updated transportation fuel that was incorrect in the original filing and a system-average heating value that is more representative of the planned purchases as they were filed. (These updated parameters can be found on the tab entitled Fractional Multipliers.) nswered by: Sarah R. Mead Dated: pril 29, 201

18 MICHIGN PUBLIC SERVICE COMMISSION Case No. U-1710 MICHIGN GS UTILITIES CORPORTION Exhibit -19 (SRM-9) Witness: Sarah R. Mead Page 1 of Michigan Gas Utilities Corporation Michigan Public Service Commission Case No. U-1710 ttorney General s First Discovery Request 01-G-21 On line 1 of Exhibit -, the Company shows that 8,11 Dth or 27% of its peak day gas supply requirements will be sourced from gas call or swing supply packages. For the Western region the percent is even higher at 7%. Please answer the following questions: a. Explain what percent of the supply packages will be structures to provide firm delivery to the Company s gate stations or to the pipeline receipt point. If both, please provide the percentage to each. b. Explain what representations the Company will obtain from the supplier that a portion of the gas supply and transportation arrangements will be contracted on a firm basis along the supply chain from the gas field to the gate station. Response a. ll call/swing packages are bid on as firm. MGUC is unable to determine the mix of delivery to the gate stations or to the pipeline receipt point at this time, as the Request for Proposal ( RFP ) is not completed until fall. b. To date the Company has not experienced reliability problems with call/swing supplies. Properly contracting for these supplies should be roughly equivalent to firm transportation with regards to reliability. The call/swing supplies are secured using the RFP process. letter is sent inviting suppliers to bid for the sale of gas supplies. This letter is only sent to parties that have a signed and valid NESB agreement with MGUC. n example of a previous RFP letter follows:

19 MICHIGN PUBLIC SERVICE COMMISSION Case No. U-1710 MICHIGN GS UTILITIES CORPORTION Exhibit -19 (SRM-9) Witness: Sarah R. Mead Page 2 of The RFP letter specifically states in the request that the Michigan Gas Utilities Corporation is interested in acquiring Firm Supply during this RFP. Below is a copy of the cover letter that was sent for a previous GCR period. Firm is defined in the NESB, page of 1, section 2.19 as: Firm shall mean that either party may interrupt its performance without liability only to the extent that such performance is prevented for reason of Force Majeure; provided, however, that during Force Majeure interruption, the party invoking Force Majeure may be responsible for any Imbalance Charges as set forth. Force Majeure is defined on page 10 of 1, section 11.2 and 11.. Force Majeure shall include, but not be limited to, the following: (i) physical events such as acts of God, landslides, lightning,

20 MICHIGN PUBLIC SERVICE COMMISSION Case No. U-1710 MICHIGN GS UTILITIES CORPORTION Exhibit -19 (SRM-9) Witness: Sarah R. Mead Page of earthquakes, fires, storms or storm warnings, such as hurricanes, which result in evacuation of the affected area, floods, washouts, explosions, breakage or accident or necessity of repairs to machinery or equipment or lines of pipe; (ii) weather related events affecting an entire geographic region, such as low temperatures which cause freezing or failure of wells or lines of pipe; (iii) interruption and/or curtailment of Firm transportation and/or storage by Transporters; (iv) acts of others such as strikes, lockouts or other industrial disturbances, riots, sabotage, insurrections or wars, or acts of terror; and (v) governmental actions such as necessity for compliance with any court order, law, statute, ordinance, regulation, or policy having the effect of law promulgated by a governmental authority having jurisdiction. Seller and Buyer shall make reasonable efforts to avoid the adverse impacts of a Force Majeure and to resolve the event or occurrence once it has occurred in order to resume performance Neither party shall be entitled to the benefit of the provisions of Force Majeure to the extent performance is affected by any or all of the following circumstances: (i) the curtailment of interruptible or secondary Firm transportation unless primary, in-path, Firm transportation is also curtailed; (ii) the party claiming excuse failed to remedy the condition and to resume the performance of such covenants or obligations with reasonable dispatch; or (iii) economic hardship, to include, without limitation, Seller s ability to sell Gas at a higher or more advantageous price than the Contract Price, Buyer s ability to purchase Gas at a lower or more advantageous price than the Contract Price, or a regulatory agency disallowing, in whole or in part, the pass through of costs resulting from this Contract; (iv) the loss of Buyer s market(s) or Buyer s inability to use or resell Gas purchased hereunder, except, in either case, as provided in Section 11.2; or (v) the loss or failure of Seller s gas supply or depletion of reserves, except, in either case, as provided in Section The party claiming Force Majeure shall not be excused from its responsibility for Imbalance Charges. [Emphasis added.] nswered by: Sarah R. Mead Dated: pril 19, 201

21 S T T E OF M I C H I G N BEFORE THE MICHIGN PUBLIC SERVICE COMMISSION * * * * * In the matter of the application of ) MICHIGN GS UTILITIES CORPORTION ) for authority to implement a gas cost recovery plan ) and factors for the 12-month period from pril 201 ) Case No. U-1710 through March 201, and for related approvals. ) REBUTTL TESTIMONY ND EXHIBITS OF Matthew M. Dirksen ON BEHLF OF MICHIGN GS UTILITIES CORPORTION Dated: June 12, 201

22 PLESE STTE YOUR NME ND BUSINESS DDRESS. My name is Matthew M. Dirksen. My business address is Integrys Energy Group, Inc. ( Integrys ), 700 North dams Street, P.O. Box 19001, Green Bay, WI I am a Senior Sales and Revenue Forecaster in the Budget Planning and nalysis Department of Integrys. RE YOU THE SME MTTHEW M. DIRKSEN WHO CUSED TO HVE FILED DIRECT TESTIMONY IN THIS MTTER ON DECEMBER 21, 2012? Yes, I am. WHT IS THE PURPOSE OF YOUR REBUTTL TESTIMONY? The purpose of my rebuttal testimony is to respond to the direct testimony of: Frank J. Hollewa as filed on behalf of the Residential Ratepayer Consortium ( RRC ) on May 1, 201. Specifically, I will respond to Mr. Hollewa s recommendation regarding revised estimates for GCR/GCC. The absence of rebuttal on other positions taken by the Intervenors should not be interpreted as agreement with those positions RE YOU SPONSORING NY EXHIBITS IN CONNECTION WITH YOUR REBUTTL TESTIMONY? Yes, I am sponsoring the following exhibits: Exhibit Content Exhibit -20 (MMD-) Reflects 201 Weather normalized actuals compared to the forecast used for the GCR Plan Period. WERE THESE EXHIBITS PREPRED BY YOU OR UNDER YOUR DIRECTION ND 1 SUPERVISION? 1

23 Yes, they were. Sales estimates for GCC and GCR customers On PGE 10, LINES 10 THROUGH 1 OF HIS DIRECT TESTIMONY MR. HOLLEW RECOMMENDS THT THE COMPNY SHOULD MONITOR THE LEVEL OF GCR/GCC SLES ND MKE MONTHLY NORMLIZTIONS DURING THE WINTER PERIOD ND THT THE FORECST SHOULD BE UPDTED BSED UPON THE EXPERIENCE TO DTE RTHER THN RELYING ON REGRESSION NLYSIS PERFORMED BEFORE THE GCR PLN WS SUBMITTED. DOES THE COMPNY GREE? No, MGUC does not agree. s stated on page, lines 18-26, of my Direct Testimony, the forecast reflects up-to-date GCR and GCC customer counts prepared at the time that the GCR Plan is filed: In the fall before the GCR filing, the GCC customer count actuals to date were reviewed along with an assessment of expected activity of marketers and a new customer count forecast of GCC customers was prepared as derived in Exhibit -9 (MMD-2). new total sales forecast for GCC customers was then calculated taking the new GCC customer count times the originally forecasted use per customer for both GCC and GCR customers as derived in Exhibit -8 (MMD-1). Since the aggregate load forecast prepared in the spring does not change in total, any adjustment made to GCC customer counts or sales will have an opposite effect on GCR customer counts and sales. Furthermore, the updated actual normalized information thus far during calendar supports the sales forecast filed in the GCR Plan. The total weather normalized sales 1 2 for January 201-pril 201 compared to the what the total load forecast predicted for the same period of time is lower by only 0.% or 1,19 Mcf. Please see Exhibit -20 (MMD-). s can be seen from the exhibit, actual sales data through pril 201 does not support adjustments to the forecast. 2

24 1 2 DOES THIS CONCLUDE YOUR REBUTTL TESTIMONY T THIS TIME? Yes, it does \

25 Exhibit -20 (MMD-) Case No. U-1710 Page 1 0f 1 Witness: Matthew M. Dirksen MGU Forecast Performance 201 Weather Normalized ctuals to Forecast used for GCR Plan ctual WN Sales January February March pril Total Res 2,6,7.7 2,102, ,821, ,02, ,8,179.0 SC&I 988, , , ,61.6 2,97,8.2 LC&I,6. 7, , , ,7.29 Total,68, ,990,9.07 2,600, ,, ,68,788.6 Forecasted WN Sales January February March pril Total Res 2,1,009 2,128,626 1,80,621 1,108,67 7,601,91.00 SC&I 981,61 82, ,681 07,81 2,90,12.00 LC&I 9,809 1,688,709 26, 182,9.00 Total,,179,01,0 2,60,011 1,2,89 10,71, Difference in Sales January February March pril Total Res 121,66.7 (2,919.8) (28,796.82) (8,01.78) (18,71.97) SC&I 7, ,680.16, (1,89.7),.2 LC&I (26,2.67) (1,68.2) (8,0.98) (8,619.82) (7,78.71) Total 102,8.68 (22,807.9) (,28.1) (107,970.97) (1,19.6) Difference %'s January February March pril Total Res.8% -1.2% -1.6% -7.7% -0.2% SC&I 0.8% 2.1%.8% -.% 1.% LC&I -.9% -28.2% -18.7% -2.7% -1.7% Total 2.9% -0.8% -0.1% -7.0% -0.% Note: 1) Negative numbers mean that forecast is higher than actuals 2) Forecast is using a 1 year weather normalized period

26 STTE OF MICHIGN BEFORE THE MICHIGN PUBLIC SERVICE COMMISSION * * * * * In the matter of the application of MICHIGN GS ) UTILITIES CORPORTION for authority to implement ) Case No. U-1710 a gas cost recovery plan and factors for the period ) from pril 201 through March 201, and for related ) approvals. ) REBUTTL TESTIMONY ND EXHIBITS OF DVID J. TYLER ON BEHLF OF MICHIGN GS UTILITIES CORPORTION Dated: June 12, 201

27 PLESE STTE YOUR NME ND BUSINESS DDRESS. My name is David J. Tyler. My business address is 899 S. Telegraph, Monroe, Michigan RE YOU THE SME DVID J. TYLER WHO CUSED TO HVE FILED DIRECT TESTIMONY IN THIS MTTER ON DECEMBER 21, 2012? Yes, I am. WHT IS THE PURPOSE OF YOUR REBUTTL TESTIMONY? I am proposing to update the Company s filed GCR factor based upon the settlement agreement in Case No. U-1681-R and to respond to the Direct testimony of Dolores. Midkiff-Powell filed on behalf of the MPSC Staff, Sebastian Coppola filed on behalf of the ttorney General, and Frank J. Hollewa filed on behalf of the Residential Ratepayer Consortium, on May 1, 201. In particular I am responding to Staff s recommendation for separate reconciliations of GCR costs & recoveries from Reservation costs & recoveries. I will also respond to the Intervenor s objections to the Company s proposal to change its GCR period. RE YOU SPONSORING NY EXHIBITS WITH YOUR REBUTTL TESTIMONY? Yes, I am sponsoring the following exhibits, which were prepared by me or under my direct supervision: Exhibit Content Revised Exhibit -1 (DJT-1) nnual Base Gas Cost Recovery ( GCR ) Factor and Reservation 1

28 Revised Exhibit -16 (DJT-) Revised Exhibit -17 (DJT-) Charge for the 12-Month Period Ending March 1, 201; Calculation of the (Under)-Recovery Balance for 2012/201; Derivation of the Base GCR Factor and Reservation Charge for the GCR Plan Period Ending March 1, PLESE BRIEFLY DESCRIBE THE EXHIBITS THT YOU RE SPONSORING On May 1, 201, the Commission issued its Order pproving Settlement greement in Case No. U-1681-R. The Settlement greement authorized the rolling in of a $,268,981 under recovery into the GCR period, which in turn, affected the over/under recovery for the GCR period ending March 1, 201. Each of the three revised exhibits that I am sponsoring has been revised to reflect the impact of the beginning underrecovered balance for the GCR period from the Settlement greement in Case No. U-1681-R. Response to Staff s Recommended Format for Upcoming Reconciliation DID THE COMPNY REVIEW STFF S RECOMMENDTION, ON PGES -, LINES 1- OF ITS REBUTTL TESTIMONY, TO PERFORM SEPRTE RECONCILITIONS OF ITS GCR ND RESERVTION COSTS & RECOVERIES? 2

29 Yes, it did, and the Company has no objection to Staff s recommendation. It was the Company s intent to perform separate reconciliations of its GCR and Reservation Charge costs & recoveries when it submitted its 2012/201 reconciliation in Case No. U R at the end of June 201. The format that the Company intends to utilize will be consistent with Staff s recommendation. RE THERE NY OTHER ITEMS RELTED TO THE SEPRTION OF THE RESERVTION CHRGE REVENUES THT NEED TO BE MENTIONED? Yes, Revised Exhibit -16 has been updated to specifically exclude the Reservation Charge costs & revenues from the gas costs. In response to a question from the G, the Company provided attachment 01-G-0 which reflected a total under-recovered figure of ($1,0,1) for the period. The figure reported on Revised Exhibit -16 is ($1,066,080). The difference between the two figures of $20,96 reflects the Reservation Charge costs and recoveries which were excluded from the revised exhibit Response to Objections to Shifting the GCR Period HOW DOES THE COMPNY RESPOND TO MR. COPPOL S COMMENTS OPPOSING THE CHNGE TO THE GCR YER ENDING IN OCTOBER INSTED OF MRCH?

30 t page 19, line 9 of his testimony Mr. Coppola states that he does not believe that changing the GCR period will make much difference in reducing the Company s large ending over/(under)-recovery balances. Mr. Coppola then goes on to state that October or any other month can still be a volatile month for weather. By focusing on the single month of October he is overlooking the effect of having the three largest months of sales volumes, i.e. January, February and March, at the end of the GCR period. These three months account for more than 1 percent of the Company s annual throughput. Shifting the GCR period to end with October, the final quarter of the GCR period being comprised of ugust, September and October, would instead place the lowest level of sales volumes during the year, i.e. less than 1 percent, at the end of the period. This change would place the most volatile weather closer to the beginning of the GCR period and allow more time to adjust the GCR factors in order to recover weather anomalies and forecasting inaccuracies that may occur during the highly volatile winter months DOES MGUC GREE WITH THE SSERTION THT LL OF THE MICHIGN GS UTILITIES SHRE THE SME GCR PERIOD? MGUC disagrees. t page 20, lines 1 through 10, of his direct testimony, Mr. Coppola asserts that all of the Michigan gas utilities share the same GCR Period and characterizes Wisconsin Public Service ( WPS ) as being a utility that operates in Wisconsin, which should have no bearing on a utility 2 operating in Michigan. In addition to operating in Wisconsin, WPS also

31 1 serves customers in Michigan s Upper Peninsula under the jurisdiction of the 2 MPSC. WPS operates under a November to October GCR time frame Furthermore, MGUC previously operated under a calendar GCR period, as did a number of other LDC s in the state. DOES MGUC GREE WITH THE SSERTION THT SHIFTING THE COMPNY S GCR PERIOD WOULD REUIRE THE COMMISSION TO SHIFT THE GCR PERIODS FOR LL OTHER MICHIGN GS UTILITIES? No, it does not. Mr. Coppola goes on further to state that if the Commission grants MGUC s request to change its GCR period then it would need to do 12 the same for the other gas utilities. There is no statutory requirement 1 setting forth the months to be included in a GCR Period. lso, the existence of the alternate GCR period for WPS demonstrates that there is no requirement that all Michigan gas utilities share the same GCR period. HVE YOU LSO REVIEWED MR. HOLLEW S OBJECTION TO THE COMPNY S PROPOSL TO CHNGE THE GCR PERIOD? 19 Yes, I have. Mr. Hollewa raises some of the same objections as Mr. 20 Coppola. MGUC s responses to Mr. Coppola are equally applicable as responses to Mr. Hollewa on these same issues. dditionally, at pages 11-12, lines 22-12, of his direct testimony, Mr. Hollewa questions whether the Company s proposal to shift the GCR period is an overreaction to 2011/ GCR period, and particularly March That is not the case; the

32 1 2 Company examined what occurred during the 2011/2012 GCR period and has corrected a deficiency that it found in its forecasting model, so MGUC believes that the circumstances at issue in March 2012 will not recur in the future. Nevertheless, for many years the parties to MGUC s GCR reconciliation proceedings have criticized the magnitude of the respective 6 over or under-recovery. MGUC s proposal is simply an effort to bring the 7 timing of its GCR Plan forecast more closely aligned with its annual 8 budgeting process. The Company believes that aligning the forecast and budget processes will improve the accuracy of the forecast and reduce over/under recovery fluctuations from year-to-year. HS STFF RISED NY OTHER ISSUES WITH THE PROPOSED CHNGE TO THE GCR SCHEDULE? Yes, both Staff and the G have stated that the Company has not presented enough evidence to show that a change is warranted. The Company constantly utilizes its best efforts to match GCR costs and revenues throughout the GCR period, so the Company cannot guarantee that shifting 18 the GCR period will improve the result in this regard. However, the Company suggests that a one year pilot period could serve as a test of this premise. IN HER TESTIMONY T PGE, LINES 1 THROUGH 17, MS. MIDKIFF- POWELL STTES THT THE RESON THT THE COMPNY CHNGED ITS PRIOR GCR PERIOD FROM CLENDR-YER TO 6

33 THE PRIL TO MRCH PERIOD WS T STFF S REUEST IN ORDER TO HELP WITH ITS CLCULTION OF OVER/(UNDER)- COLLECTIONS. DOES THE COMPNY GREE WITH THIS STTEMENT? Not entirely. While the Company did believe that a shift from a calendaryear to the pril to March period would improve its over/(under)-collections, it was not the sole reason. The Company also saw a benefit of aligning its GCR period with the operation of its storage fields which cycle from pril through March and agreed to make the change. Further in recognition of Staff s annual requirements, when the gas and electric divisions were combined, a change in the GCR period would assist Staff in the management of its workload. The Company was willing to assist Staff in this regard. lthough Staff has suggested that the change of the GCR period from a calendar-year to the pril to March period did not seem to improve the Company s ability to forecast its over/(under)-recovery projections, this is not 17 an appropriate conclusion. Since the time that MGUC changed its GCR period, the Company s ownership and related forecasting functions have changed. The Company was acquired by WPS Resources in pril of Since that time MGUC has revised and made improvements in its forecasting 22 procedures, although not to the satisfaction of all parties. The Company 7

34 continues to review its processes and make modifications as necessary. The proposal to change the GCR period is another step in that ongoing process. STFF OPPOSES THE PROPOSL TO SHIFT THE GCR PERIOD BSED ON CONCERNS WITH SCHEDULING ND WORKLOD. HOW DOES THE COMPNY RESPOND? With the exception of a single transitional plan case, Staff will be reviewing one MGUC GCR Plan per 12-month period, regardless of the month in which the plan is submitted. While MGUC understands the Staff s concerns with varying from the established schedule to accommodate a modified GCR period, the Company believes that all parties will quickly adjust to the new schedule just as they did when the GCR periods were first shifted to run from pril through March. MR. TYLER, DOES THIS COMPLETE YOUR REBUTTL TESTIMONY? Yes, it does \

35 MICHIGN PUBLIC SERVICE COMMISSION Case No. U MICHIGN GS UTILITIES CORPORTION CLCULTION OF THE GCR OVER/UNDER RECOVERIES FOR 2012/201 UTILIZING CTUL GS COSTS Revised Exhibit -16 (DJT-) Witness David J. Tyler ctual/projected Projected ctual / Cost ctual/projected ctual/projected GCR Factor Commodity Projected Cost Difference Current Month Change Total Cost GCR Sales Billed Cost ($/Mcf) ($/Mcf) Unbilled Sales In GCR Difference Line # Month Volumes ($/Mcf) ($/Mcf) (i) / (a) (b)-(d) GCR Volumes Rate Billed [(a)*(e)]+[(f)*(g)] (a) (b) (c) (d) (e) (f) (g) (h) Over/(Under) Recovery Carry-Over s of March 1, 2012 $ (,268,981) 1 pril ,929 $.97 $ $ ,11 $ - 2,12,116 2 May 6, ,29-98,01 June 261, ,0-22,298 July 2, ,899 (0.7122) 12,01 ugust 28, , - 121,91 6 September 28, ,16-17,17 7 October 86, ,98-1,61 8 November 1,11, (0.20) 1,18, (21,089) 9 December 1,819, (0.0) 1,9,91 - (,19) 10 January 201 2,06, (0.1) 1,72,027 - (2,1) 11 February 2,21, (0.19) 1,0,297 - (19,111) 12 March 2,166, (0.) 1,, 0.0 1,908 1,09, ,202, /201 OVER/(UNDER)-RECOVERY (excluding interest ) $ (1,066,080)

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37 MICHIGN PUBLIC SERVICE COMMISSION Case No.: U-1710 MICHIGN GS UTILITIES CORPORTION Revised Exhibit: -17 (DJT-) Page 2 of Witness: David J. Tyler Derivation of the Base Gas Cost Recovery Factor for the GCR Plan Period Ending March 1, 201 Line Description nnual Cost (a) (b) Cost of Gas Sold 1 Total Supplier Commodity Costs (1) $ 8,6, 2 Pipeline Demand/Supply Reservation Costs (2) 12,166,790 Total Net Cost of Storage (Injections) / Withdrawals () 16,292 Hedging Costs () 20,20 Less: Company Use Gas () 12,91 6 Lost and Unaccounted For () 127,12 Plus: 7 Gas-In-kind () 26,201 8 Total GCR Cost of Gas Sold 70,61, /201 Under-Recovery (6) 1,070, Total Projected 2012/201 GCR Costs $ 71,701,891 Derivation of Charges 11 Demand/Supply Reservation Costs (from line 2) $ 12,166, Total Sales and GCC Volumes - Mcf (7) 18,871,2 1 Proposed Reservation Charge - Per Mcf (line11 / 12) $ Reservation Revenues (line 12 X 1) 12,168,677 1 Total Cost of Gas Sold (from line 10) $ 71,701, Less: Reservation Revenues (from line 1) (12,168,677) 17 Commodity Cost of Gas Sold 9,,21 18 Total Calendar Month Sales (8) 1,87,60 19 Proposed Gas Commodity Cost - Per Mcf (line17 / 18) $ Gas Commodity Cost Revenues (line18 X 19) 9,,67 21 Total Cost of Gas Revenues recovered (line 1 +20) $ 71,70, /201 Base GCR Factor - Per Mcf (line ) $.7260 per Mcf Sources : (1) Exhibit -6, Page 2, Line 1, less Hedging Costs. (2) Exhibit -6, Page 2, Line 22 () Exhibit -6, Page 2, Line 2 () Exhibit -6, Page, Line 10 () Exhibit -17, Page 1, columns (c), (d) & (e) mulitipled by the Base GCR Factor. (6) Exhibit -16, Line 1 plus applicable interest. (7) Worpaper WP -1-1, page 1 of 20, line 20 plus line 22. (8) Exhibit -17, Page 1, column (f)

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39 Michigan Public Service Commission Case No.: U-1710 MICHIGN GS UTILITIES CORPORTION Revised Exhibit: -17 (DJT-) Page of Calculation of the nnual Base GCR Factor DERIVTION OF THE RESERVTION SURCHRGE ND GS COMMODITY CHRGE Witness: David J. Tyler pril May June July ugust September October November December January February March 12 Months Ended Line Total 1 Total GCR Supply - Mcf 1,209,00 69,72 6,79 26,886 2,80 6,98 812,76 1,98,17 2,27,82 2,70,07 2,19,8 2,002,91 1,91,0 2 Less Volumes for - Company Use,600 1,800,00, ,000 2,100,700,200,100 0,900 Lost and Unaccounted For 2,600 1,700 1,200 1,100 1,100 1,200 2,000,200,00,100,00,800 1,700 Plus - Gas In Kind,000,100,800,800,800,700,00 6,00,800 6,00 6,00,00 8,900 6 Total GCR Sales - Mcf 1,207,80 60,2,89 26,186 27,280 9,8 81,76 1,99,17 2,27,22 2,78,007 2,17,28 2,000,1 1,87, Sales Mcf 9 Rate Schedule Sales (Billed and Unbilled) 1,207,80 60,2,89 26,186 27,280 9,8 81,76 1,99,17 2,27,22 2,78,007 2,17,28 2,000,1 1,87,60 10 GCC Volumes,80 178,91 92,89 7,917 7, ,99 26,28 19, , 80,877 68,0 91,7,28,68 11 Total Sales and GCC Volumes - Mcf 1,2,6 829,28 27,698 9,10 20,7 0,79 1,060,62 1,818,79 2,9,779,,88,002,62 2,92,17 18,871, Cost of Gas Sold ($) 1 Purchased and Produced - Demand Costs $ 802,87 $ 68,708 $ 68,708 $ 68,708 $ 68,708 $ 68,708 $ 68,708 $ 1,,2 $ 1,0,86 $ 1,0,86 $ 1,22,28 $ 1,,2 $ 12,166,790 1 Capacity Release Credits Pipeline Demand/Supply Reservation Costs 802,87 68,708 68,708 68,708 68,708 68,708 68,708 1,,2 1,0,86 1,0,86 1,22,28 1,,2 12,166, Purchased and Produced - Volumetric Costs,9,8,980,89,71,61,96,88 2,91,608,77,296,076,66,12,0,76,10 7,22,819,917,266,8,986 8,6, 19 Net (To) / From Storage - Volumetric Costs (7,211) (,06,968) (,19,17) (,67,90) (1,96,1) (,2,896) 77,66 2,88,19,02,9,100,9,67,6 2,77,127 16, Hedging Costs - Losses 10,0 6,712, ,20 21 Total Cost Of Gas,19,668,129,6 1,96,69 1,677,66 1,98,77 1,96,108,802,90 6,96,0 10,789,129 12,86,7 11,086,90 9,67,6 70,666, Cost Of Gas For - 2 Company Use (17,01) (8,07) (21,267) (20,79) - (7) (1,890) (9,2) (9,92) (17,86) (19,89) (19,77) (16,0) 2 Lost and Unaccounted For (12,288) (8,0) (,671) (,199) (,199) (,671) (9,2) (1,12) (20,22) (2,10) (20,79) (17,99) (19,81) 2 Gas In Kind 2,60 19,77 17,99 17,99 17,99 17,86 20,79 29,77 27,11 0,719 29,77 2,20 278,61 26 Total Cost of Gas Sold $,188,997 $,12,182 $ 1,97,90 $ 1,669,629 $ 1,611, $ 1,97,0 $,812,82 $ 6,961,79 $ 10,786,29 $ 12,82,87 $ 11,076,080 $ 9,6,621 70,69, GCR Revenues ($) 29 Net Demand/Supply Reservation costs $ 802,87 $ 68,708 $ 68,708 $ 68,708 $ 68,708 $ 68,708 $ 68,708 $ 1,,2 $ 1,0,86 $ 1,0,86 $ 1,22,28 $ 1,,2 $ 12,166,789 0 Total Sales and GCC Volumes - Mcf 1,2,6 829,28 27,698 9,10 20,7 0,79 1,060,62 1,818,79 2,9,779,,88,002,62 2,92,17 18,871,2 1 2 Proposed Reservation Charge - per Mcf $ 0.68 $ 0.68 $ 0.68 $ 0.68 $ 0.68 $ 0.68 $ 0.68 $ 0.68 $ 0.68 $ 0.68 $ 0.68 $ 0.68 Reservation Revenues $ 99,727 $,712 $ 27,790 $ 218,662 $ 206,68 $ 28,967 $ 68,91 $ 1,172,766 $ 1,90,667 $ 2,28,180 $ 1,96,17 $ 1,671,78 12,168,676 Total Cost of Gas Sold $,188,997 $,12,182 $ 1,97,90 $ 1,669,629 $ 1,611, $ 1,97,0 $,812,82 $ 6,961,79 $ 10,786,29 $ 12,82,87 $ 11,076,080 $ 9,6,621 70,69,282 6 Less: Reservation Revenues (99,727) (,712) (27,790) (218,662) (206,68) (28,967) (68,91) (1,172,766) (1,90,667) (2,28,180) (1,96,17) (1,671,78) (12,168,676) 7 Commodity Cost of Gas Sold,19,270 2,97,69 1,661,700 1,0,967 1,0,897 1,690,8,128,67,788,98 8,881,627 10,67,69 9,19,906 7,97,1 8,80, /201 Under-Recovery (including interest) $ 1,070, ,070,192 9 Total 201/201 Projected Gas Costs $ 71,719,7 0 1 Proposed Gas Commodity Cost - per Mcf $.0812 $.0812 $.0812 $.0812 $.0812 $.0812 $.0812 $.0812 $.0812 $.0812 $.0812 $ Gas Commodity Cost Revenues $,929,62 $ 2,6,08 $ 1,66,617 $ 1,07,107 $ 1,009,192 $ 1,8,089 $,2,609 $,711,670 $ 9,28,8 $ 11,17,278 $ 9,7,08 $ 8,16,00 $ 9,,67 Total GCR Factor Billed $.7260 $.7260 $.7260 $.7260 $.7260 $.7260 $.7260 $.7260 $.7260 $.7260 $.7260 $ Total Cost of Gas Revenues $,92,089 $,188,797 $ 1,62,07 $ 1,292,769 $ 1,21,81 $ 1,669,0 $,007,2 $ 6,88,6 $ 11,190,22 $ 1,9,9 $ 11,9,222 $ 9,8,08 $ 71,70,9 7 8 Over / (Under) Recovery $ (,100) $ 6,61 $ (29,08) $ (76,860) $ (9,70) $ (0,9) $ 19,12 $ (77,1) $ 0,99 $ 606,8 $ 17,12 $ 189,887 $ (16,12) 9 Cumulative Over / (Under) Recovery $ (,100) $ (278,8) $ (7,67) $ (90,27) $ (1,6,11) $ (1,61,26) $ (1,6,8) $ (1,,697) $ (1,129,78) $ (2,1) $ (206,012) $ (16,12)

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