Paul. June 28, Ms. Kavita Kale Executive Secretary Michigan Public Service Commission 7109 W. Saginaw Highway, 3 rd Floor Lansing, MI 48917

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1 Founded in 1852 by Sidney Davy Miller PUL MICHEL COLLINS TEL (517) FX (517) E-MIL Miller, Canfield, Paddock and Stone, P.L.C. One Michigan venue, Suite 900 Lansing, Michigan TEL (517) FX (517) June 28, 2018 MICHIGN: nn rbor Detroit Grand Rapids Kalamazoo Lansing Troy FLORID: Tampa ILLINOIS: Chicago NEW YORK: New York OHIO: Cincinnati CND: Toronto Windsor CHIN: Shanghai MEXICO: Monterrey POLND: Gdynia Warsaw Wrocław Ms. Kavita Kale Executive Secretary Michigan Public Service Commission 7109 W. Saginaw Highway, 3 rd Floor Lansing, MI Re: Michigan Gas Utilities Corporation GCR Reconciliation Case No. U Dear Ms. Kale: Enclosed for electronic filing are the following: (i) (ii) (iii) (iv) (v) (vi) (vii) Michigan Gas Utilities Corporation s pplication; Direct Testimony and Exhibits of Russell T. Laursen; Direct Testimony and Exhibits of Brian M. Marozas; Direct Testimony and Exhibits of David J. Tyler; Direct Testimony and Exhibit of Gary W. Simons; Direct Testimony and Exhibit of Nicholas J. Krzeminski; and ppearances of Sherri. Wellman and Paul M. Collins. Finally, a marked-up Notice of Hearing has been electronically sent to ngela Sanderson. If you should have any questions, please kindly advise. PMC/clc Enclosures cc: David Tyler Mary Wolter Ted Eidukas Koby Bailey Very truly yours, Miller, Canfield, Paddock and Stone, P.L.C. Digitally signed by: Paul Collins DN: CN = Paul Collins = Paul collinsp@millercanfield.com C = US By: Collins Date: :57:54-04'00' 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 for a gas cost recovery reconciliation proceeding ) for the 12-month period ending March 31, ) PPLICTION Michigan Gas Utilities Corporation, a Delaware corporation ( MGUC or the Company ) respectfully requests that the Michigan Public Service Commission ( Commission ) conduct a gas cost recovery ( GCR ) reconciliation proceeding and approve MGUC s reconciliation determinations relative to the 12-month period ended March 31, In support of its request, MGUC states as follows: 1. MGUC, with its principal Michigan office located at 899 South Telegraph Road, Monroe, Michigan, is a public utility engaged in purchasing, storing, transporting, distributing and selling natural gas to the public in the Southern and Western portions of Michigan s Lower Peninsula. s of pril 30, 2018, MGUC served approximately 176,200 customers, including about 140,500 residential customers, 11,100 commercial and small industrial customers, 47 large industrial customers and 24,600 transportation and CHOICE customers. Such customers are located in over 52 cities and villages and in 99 townships between Lake Erie on the east and Lake Michigan on the west MGUC s retail natural gas sales and transportation business is subject to the jurisdiction of the Commission. 1 Exhibit -1, page 1 of MGUC s filing in this docket includes a map depicting MGUC s gas service territories in Michigan.

3 3. Pursuant to 1982 P 304 ( ct 304 ), the Commission authorized MGUC to incorporate a GCR Clause in its rate schedules. Said Clause authorizes MGUC to include in its monthly rates a GCR factor. 4. Pursuant to the Commission s May 11, 2017 Order pproving Settlement greement in the Gas Cost Recovery Plan in Case No. U-18154, MGUC was authorized to charge a base 2017/2018 GCR factor of up to $ per thousand cubic feet ( Mcf ), consisting of a gas commodity charge of $ per Mcf and a Reservation charge of $ per Mcf. Prior to the Order, MGUC self-implemented its initially filed GCR factor as authorized by MCL 460.6h(9). The base GCR factor was subject to adjustment under an approved GCR factor contingency matrix. 5. Pursuant 6h(12) of ct 304, MGUC hereby files for, and requests approval of, a reconciliation of the revenues recorded pursuant to the authorized GCR factors with the cost of gas sold and reservation costs during the 12-month period beginning pril 1, 2017 and ending March 31, MGUC is filing, as part of this pplication, testimony and exhibits sufficient to allow reconciliation in accordance with 6h(12) through 6h(15) of ct Such testimony and exhibits indicate that MGUC has a cumulative over-recovered balance of $1,666,851 as of March 31, 2018 relative to gas costs. This cumulative overrecovered balance reflects the roll-in of the prior year s GCR under-recovered amount of ($2,169,957). s further described in the accompanying testimony and exhibits, the cumulative over-recovered gas cost balance when added to the interest expense, as calculated in accordance with ct 304, results in a total cumulative over-recovered gas cost balance of $1,668,515. 2

4 7. In accordance with its standard refund procedures, MGUC requests authorization to roll-in the total cumulative under-recovered gas cost balance amount of $1,668,515 into its current 2018/2019 GCR plan period. 8. In accordance with the Commission s January 26, 2012 order in Case Nos. U & U-16513, et al, MGUC committed to file a separate reconciliation of its Reservation costs. Such testimony and exhibits indicate that MGUC has a cumulative over-recovered balance, applicable to its Reservation costs, of $1,748,940 as of March 31, This cumulative over-recovered balance reflects the roll-in of the prior year s over-recovered amount of $1,270,581. s further described in the accompanying testimony and exhibits, the cumulative over-recovered balance added to the interest expense, as calculated in accordance with ct 304, results in a total cumulative over-recovered balance of $1,761,788 relative to Reservation charge costs. 9. In accordance with its standard refund procedures, MGUC requests authorization to roll-in the cumulative over-recovered Reservation Charge cost balance amount of $1,761,788 into its current 2018/2019 GCR plan period. 10. MGUC represents that the proposals contained in this pplication are just, reasonable and in the public interest. WHEREFORE, MGUC requests that the Commission:. Establish an early time and place for hearing and give notice thereof; B. pprove the reconciliation of the 12-month gas costs & revenues, as well as the reservation costs & revenues, for the period pril 1, 2017 through March 31, 2018, as presented by MGUC; 3

5 C. Find and determine that MGUC s gas costs and reservation costs incurred during the period pril 1, 2017 through March 31, 2018, were reasonably and prudently incurred; D. uthorize MGUC to roll-in the cumulative over-recovered balance of $1,668,515 into its 2018/2019 GCR plan period gas costs for GCR customers, roll-in the over-recovered balance of $1,761,788 into its 2018/2019 GCR plan period reservation costs; and E. Grant MGUC such other and further authority as may be lawful and proper. Dated: June 28, 2018 Respectfully submitted, MICHIGN GS UTILITIES CORPORTION Paul Collins Digitally signed by: Paul Collins DN: CN = Paul Collins = collinsp@millercanfield.com C = US Date: :58:23-04'00' By: One of its ttorneys Sherri. Wellman (P38989) Paul M. Collins (P69719) MILLER, CNFIELD, PDDOCK ND STONE, P.L.C. One Michigan venue, Suite 900 Lansing, Michigan (517)

6 MICHIGN GS UTILITIES CORPORTION TWELVE-MONTHS ENDED MRCH 31, 2018 GS COST RECOVERY RECONCILITION CSE CSE U INDEX OF EXHIBITS Exhibit No. Page No.(s) Description Witness -1 1 Map of MGUC s Service reas and Pipeline ccessibility R. T. Laursen -2 1 & /2018 Index and Daily Priced Purchase Listing R. T. Laursen /2018 Peak Day nalysis R. T. Laursen /2018 Storage Utilization R. T. Laursen -5 1 Capacity Utilization R. T. Laursen -6 1 Market Prices R. T. Laursen -7 1 to 7 Winter Firm Supply Bid nalysis R. T. Laursen -8 1 to 12 Volatility Calculation B. M. Marozas -9 1 to 18 Status Update on Hedging B. M. Marozas Legal and Regulatory ctions taken by MGUC at the Federal Level to Minimize the Cost of Purchased Gas to 13 Monthly Summary of Differences between Plan and ctual Supply GCR Reconciliation Report Monthly Over/(Under) Recovery 2 GCR Reconciliation Report Sources of Gas Supply psia Dry) D. J. Tyler D. J. Tyler D. J. Tyler D. J. Tyler 3 GCR Reconciliation Report - Cost of Purchased Gas D. J. Tyler 4 GCR Reconciliation Report - Monthly Sales and Number of Customers by Revenue Class 5 GCR Reconciliation Report Dekatherms / Volumes Reported By the Pipeline D. J. Tyler D. J. Tyler 1

7 MICHIGN GS UTILITIES CORPORTION TWELVE-MONTHS ENDED MRCH 31, 2018 GS COST RECOVERY RECONCILITION CSE CSE U INDEX OF EXHIBITS Exhibit No. Page No.(s) Description Witness GCR Reconciliation Report Computation of Lost and Unaccounted for Volumes 7 GCR Reconciliation Report - Monthly Reservation Charge Over/(Under) Recovery Reconciliation of Exhibit -11, Page 1 to Exhibit -12 Pages 2 and 6 D. J. Tyler D. J. Tyler D. J. Tyler Computation of Interest on Over/(Under)-Recoveries llocation of Reservation Charges and Revenues Between Choice & GCR Customers D. J. Tyler D.J. Tyler Detail of Cashouts D. J. Tyler 2 Detail of Overrun Charges D. J. Tyler 3 Detail of Scheduling Fees D. J. Tyler 4 Detail of Capacity Release Credits D. J. Tyler Impact of Unbilled Sales djustment G. W. Simons to 5 Performance of the PEGsys system N. J. Krzeminski 2

8 STTE OF MICHIGN BEFORE THE MICHIGN PUBLIC SERVICE COMMISSION * * * * * In the matter of the application of MICHIGN ) GS UTILITIES CORPORTION for a gas cost ) Case No. U recovery reconciliation proceeding for the ) 12-month period ended March 31, ) DIRECT TESTIMONY ND EXHIBITS OF RUSSELL T. LURSEN ON BEHLF OF MICHIGN GS UTILITIES CORPORTION Date: June 28, 2018

9 1 PLESE STTE YOUR NME, POSITION ND BUSINESS DDRESS My name is Russell T. Laursen. My business address is WEC Energy Group, Inc., 700 North dams Street, P.O. Box 19001, Green Bay, Wisconsin My position at Michigan Gas Utilities Corporation ( MGUC or the Company ), a subsidiary of WEC Energy Group, Inc. ( WEC ), is Manager-Gas Supply WHT RE YOUR PRIMRY DUTIES ND RESPONSIBILITIES S MNGER GS SUPPLY FOR MGUC? s Manager-Gas Supply, I am responsible for the daily supply and balancing of MGUC s distribution system. I am also responsible for the following: (i) developing gas supply and storage capacity strategies to provide reliable and cost-effective natural gas service; (ii) developing and implementing short- and long-term gas supply and capacity release strategies including gas purchase and hedging strategies; (iii) administering gas supply, transportation and storage contracts in accordance with prescribed legal policies, procedures, and approved plans; and (iv) acquiring daily, monthly, and annual supplies to meet system requirements. dditionally, I review and approve invoices for supply, storage, and transportation costs PLESE SUMMRIZE YOUR EDUCTION, EMPLOYMENT ND PROFESSIONL EXPERIENCE I received a Bachelor of Science degree in Mechanical Engineering from the Milwaukee School of Engineering in 2004, and a Master of Business dministration degree from the University of Wisconsin La Crosse in I have been employed by WEC or its predecessors since In addition to my current role, I have held positions as a Gas 1

10 Trader ( ), Manager of Upper Peninsula Power Company ( UPPCO ) Power Supply ( ), Manager of Retail Electric Rates ( ), and Manager of Resource Planning and Policy ( ). In my role from , and beginning again in September 2015, I worked as a Gas Trader for WEC subsidiaries (including MGUC). In this position, I planned and executed monthly purchases, released capacity, planned and executed storage activity, and generally had a significant role in ensuring the daily operations of MGUC fit within the structure of the GCR plan. In ugust 2016, I assumed my current role as Gas Supply Manager HVE YOU PREVIOUSLY TESTIFIED IN NY REGULTORY PROCEEDINGS? Yes. I have testified before the Michigan Public Service Commission ( MPSC or Commission ) and the Public Service Commission of Wisconsin ( PSCW ) in various Gas Cost Recovery ( GCR ), Power Supply Cost Recovery ( PSCR ), and rate case dockets on behalf of MGU, UPPCO and Wisconsin Public Service Corporation ( WPS Corp ), including: MPSC Case No. U-18414: MGU s GCR Plan; MPSC Case No. U R: MGU s GCR Plan Reconciliation; MPSC Case No. U-18154: MGU s GCR Plan; MPSC Case No. U-18224: Upper Michigan Energy Resources Corp s filing for a Certificate of Need to build generation; MPSC Case No. U-17091: UPPCO s 2013 PSCR Plan; MPSC Case No. U R: UPPCO s 2012 PSCR Plan Reconciliation; MPSC Case No. U-16881: UPPCO s 2012 PSCR Plan; 2

11 1 2 3 MPSC Case No. U R: UPPCO s 2011 PSCR Plan Reconciliation; PSCW Docket No UR-123: WPS Corp s 2015 test year rate case; and PSCW Docket No UR-122: WPS Corp s 2014 test year rate case WHT IS THE PURPOSE OF YOUR TESTIMONY IN THIS PROCEEDING? The purpose of my testimony is to demonstrate that MGUC s GCR expenditures were incurred in a reasonable and prudent manner. My testimony will discuss the consistency of MGUC s actual results in as compared to the GCR Plan. I will focus on significant events and purchasing activity for the period pril 1, 2017, through March 31, I will also testify in support of the reasonableness and prudence of MGUC s actual gas supply costs. PLESE IDENTIFY ND BRIEFLY DESCRIBE THE EXHIBITS THT YOU RE SPONSORING. Exhibit -1 (RTL-1) is a map of MGUC s service territory. The map shows the general location of MGUC s three service areas and of the Company s twelve groups within those service areas. Exhibit -2 (RTL-2) is a summary of term and spot purchases for the GCR period. Exhibit -3 (RTL-3) displays the five peak-days for total sendout and the corresponding sales volume. Exhibit -4 (RTL-4) is a table reflecting the actual monthly storage balances compared to the GCR Plan. 3

12 Exhibit -5 (RTL-5) displays the Company s utilization of long haul interstate transportation capacity on a monthly basis, as well as capacity release volumes. Exhibit -6 (RTL-6) compares the price forecast in the GCR Plan utilizing the December 2016 NYMEX with actual index prices for the Plan year. Exhibit -7 (RTL-7) is a summary of the bids received during the Request for Proposal ( RFP ) for the firm winter supply PLESE DEFINE SOME OF THE UNIUE TERMS IN THE TESTIMONY OR EXHIBITS YOU RE SPONSORING. Some key terms commonly used in my testimony and exhibits include the following: sset Management greement ( M ) n agreement where a counterparty provides gas supply and manages transportation assets. The utility agrees to receive and pay for the gas delivered and release all applicable transportation assets to the sset Manager for some level of compensation. Baseload Supply that is the same volume every day for a given period. Call Option lso known as a 10-day or 20-day call, where supply is available to be called upon during a certain period for the number of days in the option and not to exceed the daily volume multiplied by the number of days. For example: a 10-day call of 2,000 Dth can be called upon for a total of 20,000 Dth for the winter period, but cannot exceed 2,000 Dth per day. Forward Start Option lso known as a swing deal, where supply is available to be called upon during a certain period, typically for one or more months up to the volume agreed upon. 4

13 Gas Customer Choice ( GCC or Choice ) Service Under this service, customers separately contract with an lternative Gas Supplier ( GS also called a Choice Marketer ) to obtain gas supply, and MGUC distributes the gas received from the Choice Marketer. MGUC also acts as the Supplier of Last Resort, so that service to GCC customers will not be interrupted in the event that the Choice customers consume more gas than was delivered by Choice Marketers. Gas Cost Recovery ( GCR ) Service Under this service MGUC procures and distributes gas to customers. Peaking Services contracted service which gives MGUC the right to call upon gas supply for a certain number of days for a predetermined period at a certain location. lso known as calls, swings, and forward start options. Request for Proposal ( RFP ) formal process for inviting counterparties to provide offers for a product or services. Total Sendout - The total amount of gas that flowed through the pipeline meters into MGUC s distribution system, including all supplies purchased for GCR customers and delivered by Transportation customers and Choice Marketers. Transportation Service Under this service, a customer procures its own gas supply and delivers it to MGUC s distribution system. MGUC does not serve as the Supplier of Last Resort for Transportation customers, so Transportation customers may use only as much gas as they have delivered to MGUC s system. 5

14 SUMMRY OF SUPPLY PORTFOLIO ND PURCHSES PLESE SUMMRIZE THE COMPNY S GS SUPPLY PORTFOLIO ND PURCHSING METHODOLOGY DURING THE GCR PERIOD. The goal for the MGUC gas supply portfolio is to provide reliable and reasonably priced natural gas for its GCR customers. Reliability is accomplished through utilizing diverse purchase locations and counterparties. HOW DID PRICES FORECSTED IN THE GCR PLN COMPRE TO THE CTUL PRICES IN THE MRKET PLCE? ctual gas prices were 15.4% lower than the forecast in the Plan. The average of the various pricing points in the Plan was $3.31 and actual index pricing at these points was $2.81 over the GCR period. Exhibit -6 (RTL-6) provides monthly prices at each location. PLESE DESCRIBE THE COMPNY S METHODOLOGY FOR SECURING INDEX-PRICED SUPPLY. The majority of the Company s index-priced purchases are made on a monthly basis through the request for proposal ( RFP ) process. Winter (November through March) supplies are purchased on a term basis as well. The results of the winter RFP are available in Exhibit -7 (RTL-7). Purchase volumes are determined by the GCR Plan and adjusted for the current storage positions relative to Plan storage levels. The Company may make a multi-month index-priced purchase if a base level requirement for a period can be determined. Multi-month index-priced purchases provide security in ensuring that supply is contracted for and will be available, especially during the 6

15 1 2 winter period. Exhibit -2 (RTL-2) provides specific information as to the term, volumes, prices and supply location of gas purchased DID THE COMPNY ENGGE IN NY NON-CORE SLES DURING THE PLN YER? No, the Company did not engage in non-core sales. 8 9 DID THE COMPNY CONTRCT FOR PEKING SERVICES FOR THE PLN YER? Yes. The Company contracted for peaking services during the Plan year through the winter RFP process. The results of the winter RFP are available in Exhibit - 7 (RTL-7). These peaking services give MGUC the right to call upon gas supply for a certain number of days for a predetermined period at a certain location. Multiple bids were received from multiple parties. The bids were assessed for reliability, flexibility and price. The packages that were selected are displayed in Exhibit -7 (RTL-7). DID THE COMPNY CONTRCT FOR NY MULTI-MONTH PURCHSES THT WERE NOT INCLUDED IN N SSET MNGEMENT GREEMENT? Yes. Through the winter RFP process, the Company sought and received bids for base load packages of index-priced gas for PEPL (Supplier 5), NR SW (Supplier 8), NR SE (Supplier 5), and Benton Harbor (Supplier 17). Please see Exhibit -2 (RTL-2) where these purchases are labeled as Term in the Type column. The results of the winter RFP are available in Exhibit -7 (RTL-7). 7

16 DID THE COMPNY PURCHSE NY INTR-MONTH SUPPLIES DURING THE PLN YER? Yes, the Company purchased intra-month supplies on PEPL due to colder than normal weather on pril 6, 2017 and October 31, Colder than normal weather during the winter resulted in purchases of infield NR Storage gas on December 15 and 18, This cold weather also necessitated purchases on Consumers December 27-31, 2017 and January 1-5, 2018 along with Benton Harbor NR citygate purchases on December 29-31, 2017 and January 1-2 and 4-5, DISCUSS THE COLD WETHER IN LTE DECEMBER 2017 ND ERLY JNURY MGUC s service territory experienced sustained cold weather with temperatures degrees (F) below normal. Daily average temperatures were in the low single digits with lows below zero degrees Fahrenheit. Low pressures on NR resulted in the Company purchasing gas on Consumers to maintain reliability in the Western region. Further, citygate purchases were made at Benton Harbor to ensure the Company had sufficient supply during this high-demand period DID NY OF THE COMPNY S PURCHSES DEVITE BY MORE THN 20% FROM THE PLN? Yes. The weather during the GCR period was volatile with periods of extreme cold, but as shown on Mr. Tyler s Exhibit -11 (DJT-2), page 1, line 33, the Degree Day Deficiency for the 12-month GCR period was only 1.9% colder than normal. NR (line10) and PEPL purchases (line 16) were 18% less and 9% more than plan 8

17 respectively. Michigan Consolidated purchased volumes on line 17 were 100% less than plan due to the cost of this supply relative to others. The volatile weather resulted in a small volume of Consumers purchases, while none were planned as shown on line 18. Local Production on line 19 varied from forecast and is not controllable by the Company. Pipeline fuel on line 20 was 33% less due to significant NR and PEPL citygate purchases WHT LEVEL OF PEK DY PROTECTION DID MGUC INCLUDE IN ITS GCR PLN? The GCR Plan projected a GCC and GCR combined customer peak load of 234,279 Dth. Exhibit -3 (RTL-3) shows the greatest five days for send-out for the winter months of November 2017 through March 2018 and the sources of supply for those days. The supply for this load was met through a combination of term, city-gate, peaking, and storage supplies. PLESE EXPLIN WHY THERE IS DIFFERENCE BETWEEN THE COLUMN LBELED GCR SUPPLY ND THE COLUMN LBELED TOTL MGUC SUPPLY IN EXHIBIT -3 (RTL-3)? The Total Sendout column and the MGU Storage column are only available in Mcf -- all other columns are in Dth; therefore MGUC has to convert Mcf to Dth using a monthly pipeline average BTU factor. MGUC does not have BTU data for individual days for this conversion and, therefore, utilizes monthly data. In addition, MGUC cannot determine if distribution line pack was increased or decreased on any given day. (Line pack is the amount of supply that has flowed through the pipeline meters that is in the distribution 9

18 1 2 system but has not flowed through the customer meters yet.) The variances between the columns range from 5,592 to 11,261 or from 2.4% to 4.8% of Total Sendout DID THE COMPNY INCUR NY OVERRUN CHRGES FROM THE PIPELINES? No, as shown on Exhibit -15 (DJT-6), page 2, MGUC did not pay any overrun charges during the 12-month period ended March 31, DID THE COMPNY INCUR NY CSH-OUTS OR NY SCHEDULING FEES FROM THE PIPELINES? s shown on Exhibit -15 (DTJ-6) page 1, MGUC did not incur any cash-outs during the Plan year. s shown on Exhibit -15 (DJT-6) page 3, MGUC incurred $ in daily scheduling fees during the 12 month period ended March 31, Scheduling fees were incurred on Panhandle Eastern Pipeline ( PEPL ). MGUC receives scheduling fees when the actual deliveries exceed 10% or 100 Dth (whichever is greater) of the scheduled quantity. Scheduling fees on PEPL are common, minimal, and expected. STORGE UTILIZTION PLESE DESCRIBE THE STORGE UTILIZTION FOR THE PLN YER. The Company started and ended the Plan year with actual natural gas inventories greater than that set forth in the Plan for both NR storage and the MGUC storage fields. s delineated in the Plan, the Company adjusted monthly index purchases throughout the summer and winter to compensate for initial and subsequent storage inventory levels. 10

19 1 2 Exhibit -4 (RTL-4) compares the planned storage balances to the actual storage balances throughout the Plan year TRNSPORTTION MNGEMENT BRIEFLY EXPLIN MGUC S CPCITY UTILIZTION FOR THE PLN YER Exhibit -5 (RTL-5) shows the capacity utilization for the Company s transportation contracts. This exhibit shows capacity utilization, capacity release volumes, capacity that was part of the sset Management greement (M), capacity needed for Swing/Call/Peaking deals, and the combination of the four elements. Through capacity segmentation and capacity release the Company was able to achieve utilization rates in excess of 100% periodically throughout the year. The Company is required to meet its Peak Day load obligation, and the contracts for primary in-path firm transportation capacity help satisfy this requirement. Because the Company contracts for pipeline capacity with terms generally longer than one year, contract capacity may not match with the Plan period s Peak Day requirement. The Company releases transportation capacity to mitigate reservation costs when circumstances permit. While the Company may not experience a Peak Day during a 12- month GCR period, it is still necessary to plan for a Peak Day. Failing to have adequate supply, capacity, storage, and/or swing/call packages on a Peak Day would place the Company s customers at risk of curtailment and financial harm. 11

20 The Company s current portfolio of transportation capacity is contracted through the GCR year with (a majority of) NR and for the GCR year with PEPL. The Company continually assesses current and future capacity needs in the context of safety, reliability, operational requirements, cost, availability, supply basin diversity, and delivery point requirements. The Company s use of capacity segmentation, coupled with the releases referred to above, enhanced the Company s capacity utilization rate WHT WS THE COMPNY S EXPERIENCE WITH CPCITY RELESE DURING THE PLN YER? The Company released Bcf of capacity outright and Bcf associated with Ms for the Plan year Bcf of capacity was reserved for use with Call/Swing/Peaking deals. Exhibit -5 (RTL-5) contains the Company s capacity utilization for the Plan year. HOW RE CPCITY RELESE OFFER VOLUMES DETERMINED BY THE COMPNY (SPECIFICLLY NR ML7 STORGE CPCITY)? NR-ML7 capacity is short-haul capacity from NR storage or Joliet to MGUC city gates. Its usage mostly depends on the need for storage, Joliet baseload, balancing the system, and intraday nominations. MGUC does not typically release the NR-ML7 storage capacity during the winter because such release could render the Company unable to fully use its NR storage services, including the NR No-Notice service, which is critical for balancing MGUC s system on a daily basis. Storage injections 12

21 1 2 are typically facilitated using long haul or Joliet capacity, but withdrawal capacity can be used to inject if necessary during warmer than normal winter weather IS THE COMPNY UNDER-UTILIZING ITS NR ML7 STORGE WITHDRWL CPCITY? No. s shown Exhibit -5 (RTL-5), line 7, the Company has 12,690,235 Dth of ML7 storage withdrawal capacity annually. The Company utilized 5,138,942 Dth of this capacity directly, as shown on line 41, and prudently holds much of the capacity for storage withdrawals during the November through March period. DOES THE COMPNY EVER RELESE ML7 STORGE CPCITY DURING THE WINTER? Yes. There are times in early or later winter when warm weather persists and, at the Company s judgement, it may pursue release opportunities. However, these are exceptions to the general policy of the Company that it holds storage withdrawal capacity during the winter season. PLESE EXPLIN THE PEPL M THT MGUC ENTERED INTO FOR NOVEMBER 1, 2017 THROUGH MRCH 31, The Company entered into an M through the RFP process using PEPL capacity of 42,219 Dth/day and a primary path of PEPL Field Zone to MGUC. MGUC only accepted bids for this full quantity in conjunction with delivered firm baseload and swing supplies. MGUC released the capacity to the sset Manager on a recallable basis with baseload 13

22 and swing option purchases delivered to MGUC s PEPL delivery point at the volumes outlined below: NOV 2017 Baseload (15,000 Dth/day) Swing (0-27,219 Dth/day) DEC 2017 Baseload (24,000 Dth/day) Swing (0-18,219 Dth/day) JN 2018 Baseload (32,000 Dth/day) Swing (0-10,219 Dth/day) FEB 2018 Baseload (31,000 Dth/day) Swing (0-11,219 Dth/day) MR 2018 Baseload (25,000 Dth/day) Swing (0-17,219 Dth/day) WHT RE THE BENEFITS OF THE PEPL M TO MGUC? MGUC was able to not only streamline the process of releasing excess capacity into one process, but was also able to secure baseload and swing volumes for the winter period as listed above. Supplier 7 PEPL M in Exhibit -2 (RTL-2) signifies the gas purchases made through the M. HOW DID MGUC CLCULTE THE INTRINSIC VLUE OF THE PEPL CPCITY? This was calculated using the forward curve on the day that the bids were due and factoring in variable charges to transport gas to MGUC. The steps included: 1. Obtaining November 2017 March 2018 forward curve for : a. Panhandle (receipt point for released capacity). b. MichCon (delivery point for released capacity). 2. Determining the basis spread between Panhandle and MichCon. 3. Calculating variable charges to move gas from Panhandle to MichCon. 14

23 Determining the intrinsic value per Dth of the PEPL capacity by subtracting the variable charges from the basis spread. 5. Determining the total intrinsic value of the released capacity by multiplying the intrinsic value per Dth of the PEPL capacity times the estimated quantity of capacity to be released. Since MGUC had the contractual right to call on the swing option supply at any time, it was expected that suppliers would plan to have less than the total capacity available. The capacity release credits, therefore, were expected to be less than the total intrinsic value due to volume uncertainty. Based on historical experience with PEPL capacity that MGUC had released over the last few years, and the current intrinsic value per Dth, MGUC estimated that the current value of the released capacity was approximately $130,000. This value was determined by projecting the volume that a supplier may assume to be available after meeting MGUC s needs (i.e. full pipeline capacity, minus baseload, minus potential swing option supply, minus an uncertainty holdback amount). The reasonableness of the M credit offered by suppliers was determined by a judgment comparison to the calculated intrinsic value DID MGUC RECEIVE BIDS BOVE $130,000 FOR THE PEPL M? Yes, MGUC received seven bids in excess of $130,000 and two that were below this amount. The Company accepted the largest conforming bid of $801,000. HOW WERE THE BSELOD ND SWING SUPPLIES PRICED FOR THE PEPL M? 15

24 The Baseload commodity charge for delivered and sold quantities was the price per MMBtu first published each month in Inside FERC s Gas Market Report under the headings Daily Prices of Spot Gas Delivered to Pipelines, Panhandle Eastern Pipe Line Co., Texas, Oklahoma (mainline) plus PEPL transportation fuel, commodity charges, and nnual Charge djustment ( C ) charges to deliver to the MGU point. Daily Swing Supply commodity charges for the delivered and sold quantity were the price per MMBtu set forth in Platts Gas Daily under the headings Daily Price Survey, Oklahoma, Panhandle, TX.-Okla., Midpoint plus PEPL transportation fuel, commodity charges, and C charges to deliver to the MGUC point. Intra-Day Supply commodity charge was a negotiated fixed price at time of purchase. The availability of Intra-Day Supplies were satisfied on a best efforts basis by the sset Manager. DID MGUC ENGGE IN NY OTHER Ms DURING THE GCR PERIOD? No, MGUC issued an RFP for an NR SW summer M, but the value offered did not justify giving up rights to the Company s pipeline capacity. WHT VLUE WS OFFERED FOR THE NR SW M ND WHY WS THIS INSUFFICIENT? The highest bid on the NR SW M would have resulted in a value of approximately $7,600 for the seven month summer period. When capacity is released in an M, 16

25 MGUC loses its ability to move gas to a different point (Storage or citygate) on an intraday basis. Further, the Company loses the ability to segment the capacity and takes on the risk of being unable to purchase in a different location should there be a basis blowout at NR SW. MGUC determined that the $7,600 credit was not worth these risks and losses in flexibility WHY HS THE VLUE OF MGUC S NR SW CPCITY CHNGED IN THE MRKETPLCE? MGUC extended its NR portfolio beginning pril 1, The Company was able to negotiate significant discounts on its long haul NR SW and SE capacity as part of this extension. When NR discounts capacity, it adds language to the contract that specifies the points at which the capacity discounts apply. If the capacity is used at points other than those in the contract, a surcharge of the difference between tariff rates and the discount is applied. The result of this is that MGUC s NR SW capacity incurs an $0.11/dth surcharge when it is used at non-contract points. This surcharge, combined with lower price spreads between NR SW and ML7 has eroded the value of the NR SW capacity on the release market. CUSTOMER CHOICE WHT WERE MGUC S GCC PRTICIPTION LEVELS DURING THE PLN YER? MGUC experienced a slight increase in GCC participation this Plan year. s shown in Mr. Tyler s Exhibit -12 (DJT-3) page 4, the GCC customer count increased from 23,649 in pril 2017 to 24,520 in March

26 DID MGUC SSESS NY FILURE FEES UNDER THE GCC PROGRM? Yes. Each day, an GS is responsible for delivering its Daily Delivery Obligation ( DDO ) to the Company s designated Point of Receipt. When an GS does not deliver the correct DDO during any given day, MGUC will implement a Failure Fee for failing to deliver the correct volume to the correct location. Mr. Tyler s Exhibit -12, page 3 of 7, details the Failure Fees assessed and collected over the Plan year. DO YOU BELIEVE THT MGUC S GS PURCHSE, TRNSPORTTION ND STORGE DECISIONS WERE RESONBLE ND PRUDENT DURING THE PLN PERIOD? Yes, I do. 13 DOES THIS CONCLUDE YOUR TESTIMONY T THIS TIME? 14 Yes, it does. 18

27 Case No: U Exhibit: -1 (RTL-1) Witness: Russell T. Laursen Page 1 of 1 Service reas and Pipeline ccessibility Western rea Coldwater rea Monroe rea Benton Harbor (NR) Coldwater (NR, CP, PEPL, MGU Storage) Monroe (NR, PEPL) Berrien Springs (NR) Coldwater Lake (NR) Fennville (NR) Morenci City (NR) South Haven (NR) Grand Haven (NR, DTE) Coopersville (NR) Otsego North (NR, CP) Otsego South (NR,CP)

28 MICHIGN PUBLIC SERVICE COMMISSION MICHIGN GS UTILITIES CORPORTION Case No: U Exhibit: -2 (RTL-2) Witness: Russell T. Laursen Page 1 of 2 Line # Start End Supplier Pipeline Volume Price Value Index Prices Type pril /01/17 04/30/17 Supplier 5 NR-Fayetteville Exp 11, ,000 IF NR L USD/MMBtu $1,023, $ Spot 2 04/01/17 04/30/17 Supplier 5 NR-lliance/NR Int 5, ,600 NGI FOM Chicago CG USD/MMBtu $449, $ Spot 3 04/01/17 04/30/17 Supplier 14 PEPL-Field 14, ,100 IF Panhandle TX-OK USD/MMBtu $1,188, $ Spot 4 04/01/17 04/30/17 Supplier 14 NR-S W Headstation 4, ,120 IF NR OK USD/MMBtu $333, $ Spot 5 04/01/17 04/30/17 Local Production 1 MGUP-Otsego 75 2,253 IF Mich Con CG USD/MMBtu $6, $ Spot 6 04/01/17 04/30/17 Local Production 2 MGUP-Otsego IF Mich Con CG USD/MMBtu $1, $ Spot 7 04/06/17 04/06/17 Supplier 5 PEPL-MGU 8,000 8,000 GDD Mich Con CG USD/MMBtu $26, $ Spot May /01/17 05/31/17 Supplier 5 NR-Fayetteville Exp 15, ,681 IF NR L USD/MMBtu $1,436, $ Spot 9 05/01/17 05/31/17 Supplier 4 PEPL-Field 4, ,770 IF Panhandle TX-OK USD/MMBtu $384, $ Spot 10 05/01/17 05/31/17 Supplier 6 NR-lliance/NR Int 5, ,620 NGI FOM Chicago CG USD/MMBtu $449, $ Spot 11 05/01/17 05/31/17 Supplier 5 PEPL-Field 10, ,000 IF Panhandle TX-OK USD/MMBtu $823, $ Spot 12 05/01/17 05/31/17 Supplier 14 NR-S W Headstation 4, ,224 IF NR OK USD/MMBtu $337, $ Spot 13 05/01/17 05/31/17 Supplier 11 NR-Benton Harbor 8, ,000 IF Mich Con CG USD/MMBtu $770, $ Spot 14 05/01/17 05/31/17 Local Production 1 MGUP-Otsego 80 2,482 IF Mich Con CG USD/MMBtu $7, $ Spot June /01/17 06/30/17 Supplier 8 NR-S W Headstation 104 3,120 IF NR OK USD/MMBtu $8, $ Spot 16 06/01/17 06/30/17 Supplier 6 NR-lliance/NR Int 5, ,600 NGI FOM Chicago CG USD/MMBtu $465, $ Spot 17 06/01/17 06/30/17 Supplier 5 NR-Fayetteville Exp 8, ,000 IF NR L USD/MMBtu $756, $ Spot 18 06/01/17 06/30/17 Supplier 15 PEPL-Field 10, ,000 IF Panhandle TX-OK USD/MMBtu $842, $ Spot 19 06/01/17 06/30/17 Supplier 4 PEPL-Field 3,000 90,000 IF Panhandle TX-OK USD/MMBtu $252, $ Spot 20 06/01/17 06/30/17 Supplier 10 NR-S W Headstation 4, ,000 IF NR OK USD/MMBtu $344, $ Spot 21 06/01/17 06/30/17 Local Production 1 MGUP-Otsego 129 3,860 IF Mich Con CG USD/MMBtu $11, $ Spot July /01/17 07/31/17 Supplier 6 NR-lliance/NR Int 5, ,620 NGI FOM Chicago CG USD/MMBtu $448, $ Spot 23 07/01/17 07/31/17 Supplier 15 PEPL-Field 14, ,770 IF Panhandle TX-OK USD/MMBtu $1,214, $ Spot 24 07/01/17 07/31/17 Supplier 5 NR-Fayetteville Exp 15, ,681 IF NR L USD/MMBtu $1,390, $ Spot 25 07/01/17 07/31/17 Supplier 5 NR-S W Headstation 4, ,224 IF NR OK USD/MMBtu $346, $ Spot 26 07/01/17 07/31/17 Supplier 1 NR-PL StoFacilities 6, ,000 IF Mich Con CG USD/MMBtu $552, $ Spot 27 07/01/17 07/31/17 Local Production 1 MGUP-Otsego 136 4,216 IF Mich Con CG USD/MMBtu $11, $ Spot ugust /01/17 08/31/17 Supplier 5 NR-Fayetteville Exp 15, ,681 IF NR L USD/MMBtu $1,352, $ Spot 29 08/01/17 08/31/17 Supplier 1 NR-PL StoFacilities 6, ,000 IF Mich Con CG USD/MMBtu $537, $ Spot 30 08/01/17 08/31/17 Supplier 3 NR-S W Headstation 4, ,224 IF NR OK USD/MMBtu $333, $ Spot 31 08/01/17 08/31/17 Supplier 4 PEPL-Field 14, ,770 IF Panhandle TX-OK USD/MMBtu $1,163, $ Spot 32 08/01/17 08/31/17 Supplier 6 NR-lliance/NR Int 5, ,620 NGI FOM Chicago CG USD/MMBtu $441, $ Spot 33 08/01/17 08/31/17 Local Production 1 MGUP-Otsego 127 3,925 IF Mich Con CG USD/MMBtu $10, $ Spot September /01/17 09/30/17 Supplier 15 PEPL-Field 14, ,100 IF Panhandle TX-OK USD/MMBtu $1,123, $ Spot 35 09/01/17 09/30/17 Supplier 17 NR ML7 rea 9,000 0 IF Mich Con CG USD/MMBtu $5, $ Spot 36 09/01/17 09/30/17 Supplier 5 NR-Fayetteville Exp 15, ,530 IF NR L USD/MMBtu $1,304, $ Spot 37 09/01/17 09/30/17 Supplier 8 NR-S W Headstation 4, ,120 IF NR OK USD/MMBtu $323, $ Spot 38 09/01/17 09/30/17 Supplier 17 NR-PL StoFacilities 9, ,090 IF Mich Con CG USD/MMBtu $374, $ Spot 39 09/01/17 09/30/17 Supplier 17 NR-Benton Harbor 9, ,130 IF Mich Con CG USD/MMBtu $406, $ Spot 40 09/01/17 09/30/17 Supplier 8 NR-lliance/NR Int 5, ,600 NGI FOM Chicago CG USD/MMBtu $420, $ Spot 41 09/01/17 09/30/17 Local Production 1 MGUP-Otsego 93 2,788 IF Mich Con CG USD/MMBtu $7, $ Spot October /01/17 10/31/17 Supplier 10 NR-Fayetteville Exp 15, ,681 IF NR L USD/MMBtu $1,333, $ Spot 43 10/01/17 10/31/17 Supplier 8 PEPL-Field 10, ,000 IF Panhandle TX-OK USD/MMBtu $774, $ Spot 44 10/01/17 10/31/17 Supplier 4 PEPL-Field 4, ,770 IF Panhandle TX-OK USD/MMBtu $360, $ Spot 45 10/01/17 10/31/17 Supplier 11 NR-lliance/NR Int 5, ,620 NGI FOM Chicago CG USD/MMBtu $438, $ Spot 46 10/01/17 10/31/17 Supplier 8 NR-S W Headstation 1,104 34,005 IF NR OK USD/MMBtu $87, $ Spot 47 10/01/17 10/31/17 Supplier 10 NR-S W Headstation 3,000 92,405 IF NR OK USD/MMBtu $238, $ Spot 48 10/01/17 10/31/17 Local Production 1 MGUP-Otsego 92 2,841 IF Mich Con CG USD/MMBtu $7, $ Spot 49 10/31/17 10/31/17 Supplier 8 PEPL-MGU 5,000 5,000 GDD Panhandle TX-OK USD/MMBtu $14, $ Spot November /01/17 11/30/17 Supplier 5 PEPL-Field 5, ,000 NYMEX HH NG LD USD/MMBtu $367, $ Term 51 11/01/17 11/30/17 Supplier 8 NR-S W Headstation 4, ,520 IF NR OK USD/MMBtu $339, $ Term 52 11/01/17 11/30/17 Supplier 7 - PEPL M PEPL-MGU 25, ,000 IFSP Panhandle + Variables USD/MMBtu $1,135, $ Term 53 11/01/17 11/30/17 Supplier 8 NR-S W Headstation 2,500 75,000 NYMEX HH NG LD USD/MMBtu $188, $ Term 54 11/01/17 11/30/17 Local Production 1 MGUP-Otsego 106 3,175 IF Mich Con CG USD/MMBtu $7, $ Spot 55 11/09/17 11/09/17 Supplier 7 - PEPL M PEPL-MGU 5,000 5,000 GDDSP Panhandle + Variables $15, $ Spot 56 11/10/17 11/10/17 Supplier 7 - PEPL M PEPL-MGU 10,000 10,000 GDDSP Panhandle + Variables $31, $ Spot December /01/17 12/31/17 Supplier 7 - PEPL M PEPL-MGU 25, ,999 IFSP Panhandle + Variables USD/MMBtu $2,111, $ Term 58 12/01/17 12/31/17 Supplier 5 PEPL-Field 5, ,000 NYMEX HH NG LD USD/MMBtu $429, $ Term 59 12/01/17 12/31/17 Supplier 8 NR-S W Headstation 2,500 77,500 NYMEX HH NG LD USD/MMBtu $219, $ Term 60 12/01/17 12/31/17 Supplier 8 NR-S W Headstation 4, ,204 IF NR OK USD/MMBtu $398, $ Term 61 12/01/17 12/31/17 Supplier 17 NR-Benton Harbor 2,620 81,220 IF Mich Con CG USD/MMBtu $250, $ Term 62 12/01/17 12/31/17 Supplier 5 NR-Fayetteville Exp 5, ,681 IF NR L USD/MMBtu $477, $ Spot 63 12/01/17 12/31/17 Supplier 5 NR-Fayetteville Exp 10, ,000 IF NR L USD/MMBtu $926, $ Term 64 12/01/17 12/31/17 Supplier 12 NR-Benton Harbor 0 180,000 GDD Mich Con CG $493, $ Term 65 12/01/17 12/31/17 Local Production 2 MGUP-Otsego IF Mich Con CG USD/MMBtu $ $ Spot 66 12/01/17 12/31/17 Local Production 1 MGUP-Otsego 127 3,922 IF Mich Con CG USD/MMBtu $11, $ Spot 67 12/09/17 12/09/17 Supplier 7 - PEPL M PEPL-MGU 5,000 5,000 GDDSP Panhandle + Variables $12, $ Spot 68 12/10/17 12/10/17 Supplier 7 - PEPL M PEPL-MGU 5,000 5,000 GDDSP Panhandle + Variables $12, $ Spot 69 12/11/17 12/11/17 Supplier 7 - PEPL M PEPL-MGU 5,000 5,000 GDDSP Panhandle + Variables $12, $ Spot 70 12/12/17 12/12/17 Supplier 7 - PEPL M PEPL-MGU 18,219 18,219 GDDSP Panhandle + Variables $46, $ Spot 71 12/13/17 12/13/17 Supplier 7 - PEPL M PEPL-MGU 18,219 18,219 GDDSP Panhandle + Variables $46, $ Spot 72 12/14/17 12/14/17 Supplier 7 - PEPL M PEPL-MGU 18,219 18,219 GDDSP Panhandle + Variables $44, $ Spot 73 12/15/17 12/15/17 Supplier 7 - PEPL M PEPL-MGU 5,000 5,000 GDDSP Panhandle + Variables $12, $ Spot 74 12/15/17 12/15/17 Supplier 12 NR-PL StoFacilities 50,000 50, USD/MMBtu $133, $ Fixed 75 12/18/17 12/18/17 Supplier 12 NR-PL StoFacilities 50,000 50, USD/MMBtu $137, $ Fixed 76 12/23/17 12/23/17 Supplier 7 - PEPL M PEPL-MGU 18,219 18,219 GDDSP Panhandle + Variables $45, $ Spot 77 12/24/17 12/24/17 Supplier 7 - PEPL M PEPL-MGU 18,219 18,219 GDDSP Panhandle + Variables $45, $ Spot 78 12/25/17 12/25/17 Supplier 7 - PEPL M PEPL-MGU 18,219 18,219 GDDSP Panhandle + Variables $45, $ Spot 79 12/26/17 12/26/17 Supplier 7 - PEPL M PEPL-MGU 18,219 18,219 GDDSP Panhandle + Variables $45, $ Spot 80 12/27/17 12/27/17 Supplier 7 - PEPL M PEPL-MGU 18,219 18,219 GDDSP Panhandle + Variables $49, $ Spot 81 12/27/17 12/31/17 Supplier 1 CONS-MGU Pool 6,000 30, USD/MMBtu $90, $ Fixed 82 12/28/17 12/28/17 Supplier 7 - PEPL M PEPL-MGU 18,219 18,219 GDDSP Panhandle + Variables $51, $ Spot 83 12/29/17 12/29/17 Supplier 7 - PEPL M PEPL-MGU 18,219 18,219 GDDSP Panhandle + Variables $65, $ Spot 84 12/29/17 12/29/17 Supplier 6 NR-Benton Harbor 10,000 10,000 GDD Mich Con CG USD/MMBtu $29, $ Spot 85 12/30/17 12/30/17 Supplier 7 - PEPL M PEPL-MGU 18,219 18,219 GDDSP Panhandle + Variables $65, $ Spot 86 12/30/17 12/30/17 Supplier 6 NR-Benton Harbor 10,000 10,000 GDD Mich Con CG USD/MMBtu $29, $ Spot 87 12/31/17 12/31/17 Supplier 7 - PEPL M PEPL-MGU 18,219 18,219 GDDSP Panhandle + Variables $65, $ Spot 88 12/31/17 12/31/17 Supplier 6 NR-Benton Harbor 10,000 10,000 GDD Mich Con CG USD/MMBtu $29, $ Spot January /01/18 01/01/18 Supplier 7 - PEPL M PEPL-MGU 10,219 10,219 GDDSP Panhandle + Variables $46, $ Spot 90 01/01/18 01/31/18 Supplier 17 NR-Benton Harbor 2,620 81,220 IF Mich Con CG USD/MMBtu $223, $ Term 91 01/01/18 01/31/18 Supplier 5 NR-Fayetteville Exp 10, ,000 IF NR L USD/MMBtu $824, $ Term 92 01/01/18 01/31/18 Supplier 7 - PEPL M PEPL-MGU 25, ,000 IFSP Panhandle + Variables USD/MMBtu $2,534, $ Term 93 01/01/18 01/31/18 Supplier 8 NR-S W Headstation 4, ,204 IF NR OK USD/MMBtu $375, $ Term 94 01/01/18 01/31/18 Supplier 8 NR-S W Headstation 2,500 77,500 NYMEX HH NG LD USD/MMBtu $193, $ Term

29 MICHIGN PUBLIC SERVICE COMMISSION MICHIGN GS UTILITIES CORPORTION Case No: U Exhibit: -2 (RTL-2) Witness: Russell T. Laursen Page 2 of 2 Line # Start End Supplier Pipeline Volume Price Value Index Prices Type 95 01/01/18 01/31/18 Supplier 5 PEPL-Field 5, ,000 NYMEX HH NG LD USD/MMBtu $377, $ Term 96 01/01/18 01/31/18 Supplier 12 NR-Benton Harbor 0 44,092 GDD Mich Con CG $134, $ Term 97 01/01/18 01/31/18 Supplier 7 - PEPL M NR-Benton Harbor 5, ,000 IF Mich Con CG USD/MMBtu $419, $ Spot 98 01/01/18 01/31/18 Supplier 16 NR-PL StoFacilities 5, ,000 IF Mich Con CG USD/MMBtu $416, $ Spot 99 01/01/18 01/02/18 Supplier 1 CONS-MGU Pool 3,500 7,000 GDD Consumers CG USD/MMBtu $28, $ Spot /01/18 01/01/18 Supplier 6 NR-Benton Harbor 5,000 5,000 GDD Mich Con CG USD/MMBtu $15, $ Spot /01/18 01/01/18 Supplier 9 NR-S E Headstation 5,179 4,979 GDD NR L USD/MMBtu $17, $ Spot /01/18 01/31/18 Local Production 2 MGUP-Otsego IF Mich Con CG USD/MMBtu $1, $ Spot /01/18 01/31/18 Local Production 1 MGUP-Otsego 121 3,754 IF Mich Con CG USD/MMBtu $9, $ Spot /02/18 01/02/18 Supplier 7 - PEPL M PEPL-MGU 10,219 10,165 GDDSP Panhandle + Variables $45, $ Spot /02/18 01/02/18 Supplier 6 NR-Benton Harbor 5,000 5,000 GDD Mich Con CG USD/MMBtu $15, $ Spot /02/18 01/02/18 Supplier 9 NR-S E Headstation 5,179 5,179 GDD NR L USD/MMBtu $18, $ Spot /03/18 01/03/18 Supplier 7 - PEPL M PEPL-MGU 10,219 10,219 GDDSP Panhandle + Variables $77, $ Spot /03/18 01/03/18 Supplier 13 CONS-MGU Pool 3,500 3,500 GDD Consumers CG USD/MMBtu $31, $ Spot /04/18 01/04/18 Supplier 7 - PEPL M PEPL-MGU 10,219 10,219 GDDSP Panhandle + Variables $63, $ Spot /04/18 01/04/18 Supplier 9 NR-S E Headstation 5,179 5,179 GDD NR L USD/MMBtu $35, $ Spot /04/18 01/04/18 Supplier 12 CONS-MGU Pool 3,500 3,500 GDD Consumers CG USD/MMBtu $23, $ Spot /04/18 01/04/18 Supplier 6 NR-Benton Harbor 10,000 10,000 GDD Mich Con CG USD/MMBtu $30, $ Spot /05/18 01/05/18 Supplier 7 - PEPL M PEPL-MGU 10,219 10,219 GDDSP Panhandle + Variables $36, $ Spot /05/18 01/05/18 Supplier 6 NR-Benton Harbor 10,000 10,000 GDD Mich Con CG USD/MMBtu $30, $ Spot /05/18 01/05/18 Supplier 1 CONS-MGU Pool 3,500 3,500 GDD Consumers CG USD/MMBtu $20, $ Spot /12/18 01/12/18 Supplier 7 - PEPL M PEPL-MGU 10,219 10,219 GDDSP Panhandle + Variables $30, $ Spot /13/18 01/13/18 Supplier 7 - PEPL M PEPL-MGU 10,219 10,219 GDDSP Panhandle + Variables $35, $ Spot /14/18 01/14/18 Supplier 7 - PEPL M PEPL-MGU 10,219 10,219 GDDSP Panhandle + Variables $35, $ Spot /15/18 01/15/18 Supplier 7 - PEPL M PEPL-MGU 10,219 10,215 GDDSP Panhandle + Variables $35, $ Spot /16/18 01/16/18 Supplier 7 - PEPL M PEPL-MGU 10,219 10,205 GDDSP Panhandle + Variables $35, $ Spot /17/18 01/17/18 Supplier 7 - PEPL M PEPL-MGU 10,219 10,219 GDDSP Panhandle + Variables $42, $ Spot February /01/18 02/28/18 Supplier 8 NR-S W Headstation 4, ,152 IF NR OK USD/MMBtu $374, $ Term /01/18 02/28/18 Supplier 8 NR-S W Headstation 2,500 70,000 NYMEX HH NG LD USD/MMBtu $237, $ Term /01/18 02/28/18 Supplier 17 NR-Benton Harbor 2,620 73,360 IF Mich Con CG USD/MMBtu $255, $ Term /01/18 02/28/18 Supplier 7 - PEPL M PEPL-MGU 25, ,000 IFSP Panhandle + Variables USD/MMBtu $2,589, $ Term /01/18 02/28/18 Supplier 5 PEPL-Field 5, ,000 NYMEX HH NG LD USD/MMBtu $466, $ Term /01/18 02/28/18 Supplier 5 NR-Fayetteville Exp 10, ,000 IF NR L USD/MMBtu $988, $ Term /01/18 02/28/18 Supplier 12 NR-lliance/NR Int 5, ,560 NGI FOM Chicago CG USD/MMBtu $601, $ Spot /01/18 02/01/18 Supplier 7 - PEPL M PEPL-MGU 11,219 11,219 GDDSP Panhandle + Variables $29, $ Spot /01/18 02/28/18 Local Production 1 MGUP-Otsego 122 3,415 IF Mich Con CG USD/MMBtu $10, $ Spot /01/18 02/28/18 Local Production 2 MGUP-Otsego IF Mich Con CG USD/MMBtu $1, $ Spot

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