Miller, Canfield, Paddock and Stone, P.L.C. One Michigan Avenue, Suite 900 Lansing, Michigan TEL (517) FAX (517)

Transcription

1 Founded in 1852 by Sidney Davy Miller SHERRI A. WELLMAN TEL ( FAX ( Miller, Canfield, Paddock and Stone, P.L.C. One Michigan Avenue, Suite 900 Lansing, Michigan TEL ( FAX ( MICHIGAN: Ann Arbor Detroit Grand Rapids Kalamazoo Lansing Troy FLORIDA: Tampa ILLINOIS: Chicago NEW YORK: New York CANADA: Windsor CHINA: Shanghai MEXICO: Monterrey POLAND: Gdynia Warsaw Wrocław October 16, 2017 Ms. Kavita Kale Executive Secretary Michigan Public Service Commission 7109 West Saginaw Highway Lansing, MI Re: Upper Peninsula Power Company Case No. U Dear Ms. Kale: As directed by the Commission s September 28, 2017 Order In Case No. U-18094, enclosed for electronic filing is the Post-Order Testimony and Exhibit of Aaron L. Wallin. Also enclosed is the Proof of Service. Further, as directed, enclosed are the proposed tariff sheets revised to be reflective of the rulings made in the September 28 Order. Very truly yours, Miller, Canfield, Paddock and Stone, P.L.C. SAW/kld Enclosures cc w/enc: ALJ Suzanne D. Sonneborn Michael Orris Margrethe Kearney Gradon Haehnel Aaron Wallin By: Sherri A. Wellman \

2 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION * * * * In the matter, on the Commission s own motion, establishing the method and avoided cost calculation for UPPER PENINSULA POWER COMPANY to fully Case No. U comply with the Public Utilities Regulatory Policy Act of 1978, 16 USC 2601 et seq. POST-ORDER TESTIMONY AND EXHIBIT OF AARON L. WALLIN PART I QUALIFICATIONS 10/16/ Q. Please state your name and business address. My name is Aaron L. Wallin. My business address is Upper Peninsula Power Company, Inc. ( UPPCO or the Company, 1002 Harbor Hills, Marquette, MI I am the Manager of Power Supply and Resource Planning Q. Are you the same Aaron Wallin who caused direct testimony to be filed on October 28, 2016, and rebuttal testimony on February 17, 2017, in this matter on behalf of UPPCO? A. Yes. PART II Purpose and Exhibit Q. What is the purpose of your rebuttal testimony? A. The purpose of my testimony is to support UPPCO s forecast of Locational Marginal Prices ( LMPs as directed by the Commission in its September 28, 2017 order.

3 1 2 Q. As relevant to the specific purpose hearing to be held on November 9, 2017, in this matter, what did the Commission direct parties to address? 3 4 A. In its September 28, 2017 order, the Commission directed parties to Case No. U to file a proposed LMP 20-year forecast for UPPCO. 5 6 Q. Are you sponsoring an exhibit in connection with this post-order testimony? A. Yes, I am sponsoring Exhibit A-2 (ALW-2. This exhibit was prepared by me. 7 LMP Forecast 8 9 Q. Has UPPCO prepared an LMP forecast as directed by the Commission in its September 28, 2017 order? A. Yes, UPPCO has prepared a forecast of LMPs using a 20-year time horizon as directed by the Commission. 12 Q. Please describe how UPPCO completed its LMP forecast? A. UPPCO developed a regression analysis to forecast LMPs using the relationship between the historical Marginal Energy Component ( MEC of the LMP as the dependent variable. Based on the historical data, UPPCO determined that MISO load and natural gas prices were two variables that had a significant impact on the LMPs. Furthermore, heating and cooling degree days as well as whether the day was a weekday versus a weekend or holiday impacted the historical prices observed. Based on this information, UPPCO s regression model used forecasted MISO load, natural gas futures prices and natural gas price forecasts, as well as normal weather, month, day, and on or off-peak as independent variables to forecasted LMPs on a daily basis through Since LMPs 2

4 fluctuate during the day depending on changes in system characteristics, UPPCO adapted the daily price forecast based on the ratio of the 8-year historical average hourly price to the average daily price. This results in prices that are higher than the average during onpeak hours and lower that the daily average during off-peak hours. Lastly, since UPPCO is forecasting only the MEC component of the LMP, the Marginal Congestion Component ( MCC and Marginal Loss Component ( MLC need to be added to the MEC resulting in the LMP. UPPCO used the historical hourly 5-year average MCC and MLC and added the hourly 5-year averages to the hourly MEC forecast. 9 Q. What is the basis for the natural gas price forecast? A. UPPCO used the final monthly settled futures price at the Henry Hub on October 9, 2017 from the CME Group for January 2018 through December From January 2025 through December 2037, UPPCO used the delivered natural gas price for electric power without the Clean Power Plan as published by the U.S. Energy Information Administration. 15 Q. What is the basis for the MISO load forecast? 16 A. UPPCO determined that historically, weather and price were the most significant 17 variables affecting MISO load. Therefore, to forecast MISO load, UPPCO performed 18 regression analysis using actual heating degree days and cooling degree days and the 19 MEC as the main independent variables. UPPCO also included variables for month and 20 day and whether the day was a weekday, weekend, or holiday. 21 Q. What are the LMPs UPPCO has forecasted using regression analysis? 3

5 A. The average annual LMPs, average annual on-peak LMPs, and annual average off-peak LMPs from 2018 through 2037 are presented in Exhibit A-2 (ALW-2. The on-peak LMP for a 5- year contract term is estimated to be $44.22/MWh while the off-peak LMP for a 5-year contract term is estimated to be $31.27/MWh. For a 10-year contract term the onpeak LMP is estimated to be $47.29/MWh while the off-peak LMP is estimated to be 6 $33.74/MWh. For a 15-year contract term, the on-peak LMP is estimated to be $49.48/MWh while the off-peak LMP is estimated to be $35.49/MWh. Finally, for a 20- year contract term, the on-peak LMP is estimated to be $50.57/MWh while the off-peak LMP is estimated to be $36.36/MWh. 10 Q. Does this complete your direct post-order testimony? 11 A. Yes. 12 4

6 20-yearL M P P rojection Case No: U Exhibit A-2 (ALW-2 Date: October 16, Year 5-Year 10-Year 10-Year 15-Year 15-Year 20-Year 20-Year Average Average ContractO n- ContractO ff- ContractO n- ContractO ff- ContractO n- ContractO ff- ContractO n- ContractO ff- P eriod Year Average Annual L M P Annual O n- L M P Annual O ff- L M P $/M W h $/M W h $/M W h $/M W h $/M W h $/M W h $/M W h $/M W h $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $44.22 $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $47.29 $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $49.48 $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $50.57 $36.36 Discount R ate 9% P ers taffexhibits -5 (JJH-4

7 R ateo ption 1.AsAvailable R ate 2.L M P Energy R ateforecast ContractT erm Energy R ate $/kw h M IS O R ealt im el ocationalm arginalp rice(l M P atthecom pany'su P P C.IN T EGR AT D load node lesstheadm inistrativefeeof$0.001/kw h. M IS O R ealt im el ocationalm arginalp rice(l M P atthecom pany'su P P C.IN T EGR AT D load node lesstheadm inistrativefeeof$0.001/kw h. 5 Years 10 Years 15 Years 20 Years O n- O ff- O n- O ff- O n- O ff- O n- O ff- $44.22 $31.27 $47.29 $33.74 $49.48 $35.49 $50.57 $36.36 Capacity R ate$/kw -m onth Yearof Contract Execution $/kw -m onth 2018 $ $ $ 3.00

8 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION * * * * In the matter, on the Commission s own motion, establishing the method and avoided cost calculation for UPPER PENINSULA POWER COMPANY to fully Case No. U comply with the Public Utilities Regulatory Policy Act of 1978, 16 USC 2601 et seq. STATE OF MICHIGAN ss COUNTY OF INGHAM PROOF OF SERVICE Kim L. Delinescheff, being first duly sworn, deposes and says that on October 16, 2017, she served a copy of the Post-Order Testimony and Exhibit of Aaron L. Wallin on the parties below via electronic mail as follows: Suzanne D. Sonneborn Administrative Law Judge Michigan Public Service Commission 7109 W. Saginaw Highway Lansing, MI sonneborns@michigan.gov Michael J. Orris Assistant Attorney General Public Service Division 7109 W. Saginaw Highway, 3rd Floor Lansing, MI orrism@michigan.gov Margrethe Kearney Environmental Law & Policy Center 1514 Wealthy Street SE, Suite 256 Grand Rapids, MI mkearney@elpc.org Kim L. Delinescheff Subscribed and sworn before me on this 16 th day of October, Crystal L. Abbott, Notary Public State of Michigan, County of Eaton My Commission Expires: May 25, 2018 Acting in Ingham County \

9 UPPER PENINSULA POWER COMPANY MPSC Vol No 8-ELECTRIC xth Revised Sheet No. D-xx.xx Replaces xth Revised Sheet No. D-xx.xx Dx. Standard Rates for Purchases from Qualifying Facilities xx-x EFFECTIVE IN All territory served. AVAILABILITY To customers contracting for electric service who satisfy the requirements of "qualifying facility" status under Part 292 of the Federal Energy Regulatory Commission's regulations under the Public Utility Regulatory Policies Act of 1978, generating electrical energy with total customer owned generating capacity of 1 MW or less, and desiring to sell electrical energy to the Company. To qualify for this service, a seller shall execute a standard Power Purchase Agreement with the Company. Customers with generation capacity greater than 1 MW may negotiate with the Company for rates other than specified in this rate schedule. Customers with generation capacity of 150 KW or less have the option of selling energy to the Company under the Pg-2 tariff or the Pg-1M tariff for customers with generator ratings that do not exceed 20 KW. Customers may take service under PG-3 if the requirements are met for methane digesters. Service hereunder shall be restricted to the Company s purchase of energy or energy and capacity from the seller s generating facilities up to the Contract Capacity specified in the Power Purchase Agreement which may be operated in parallel with the Company s system. Power delivered to the Company shall not offset or be substituted for power contracted for, or which may be contracted for, under any other schedule of the Company. If a seller requires supplemental, back-up, or standby services, the seller shall enter into a separate service agreement with the Company in accordance with the Company's applicable electric rates and Service Regulations approved by the Michigan Public Service Commission. MONTHLY RATES Customer Charge: For total customer owned generating capacity of under 200 KW: Standard applicable rate schedule Customer Charge. For total customer owned generating capacity of 200 KW and greater: Secondary Primary Transmission Monthly: $ $ $ Daily: $ $ $ Charges for Deliveries from Company Deliveries from the Company to the customer shall be billed in accordance with the standard applicable rate schedules of the Company. Continued to Sheet No. D-xx.xx

10 Continued from Sheet No. D-xx.xx Energy and Capacity Rate Energy For all energy supplied by the customer, the customer shall receive an energy payment equal to one of the rate options below, as selected by the customer and applicable for the term of the special offer contract: Rate Option 1. As Available Rate 2. LMP Energy Rate Forecast Contract Term Energy Rate $/kwh MISO Real Time Locational Marginal Price (LMP at the Company's UPPC.INTEGRATD load node less the Administrative Fee of $0.001/kWh. MISO Real Time Locational Marginal Price (LMP at the Company's UPPC.INTEGRATD load node less the Administrative Fee of $0.001/kWh. 5 Years 10 Years 15 Years 20 Years On- On- On- On- Peak Off-Peak Peak Off-Peak Peak Off-Peak Peak Off-Peak $44.22 $31.27 $47.29 $33.74 $49.48 $35.49 $50.57 $36.36 The seller shall receive a monthly capacity payment based on the units of capacity that the MISO determines the seller s Qualifying Facility can supply for the applicable MISO established resource planning period multiplied by the applicable capacity rate obtained under Capacity above as expressed in such units of capacity. The current resource planning period is the planning year which runs from June 1st of each year through May 31st of the following year. Payments shall be reduced by any applicable monthly Interconnection Cost. Capacity Rate $/kw-month Year of Contract Execution $/kw-month 2018 $ $ $ 3.00 Renewable Premium: At the Company s sole discretion, a premium to be paid on a per Kwh basis may be applied to generators that generate a renewable credit that is transferred to the Company. Customers retain the right to refuse a renewable premium and keep the renewable credits or tags. Premiums are to be set when the contract is signed and will not change during the contract period. Distribution Loss Factors: The following factors shall be applied to the onpeak and off-peak energy factors and capacity payments to reflect system losses: Customers metered at a transmission voltage of 50,000 volts or higher: Customers metered at a primary voltage of 4,160 volts - 50,000 volts: l.0550 Customers metered at a secondary voltage of less than 4,160 volts: Continued to Sheet No. D-xx.xx Issued: xx-xx-xx By G R Haehnel Director - Regulatory Affairs Marquette, Michigan Effective for Service On and After: xx-xx-xx Issued Under Auth. of Mich Public Serv Comm Dated: xx-xx-xx In Case No: U-18094

11 UPPER PENINSULA POWER COMPANY MPSC Vol No 8-ELECTRIC Original Sheet No. D D2. Parallel Generation Purchase by UPPCO PG-4 Continued from Sheet No. D-xx.xx ON-PEAK HOURS Winter (calendar months of October through May: through Friday (except holidays. 7:00 AM to 10:00 PM; Monday Summer (calendar months of June through September: 7:00 AM to 11:00 PM; Monday through Friday (except holidays. OFF-PEAK HOURS All hours not listed as on-peak hours. HOLIDAYS The days of the year which are considered holidays are: New Year's Day, Memorial Day, Fourth of July, Labor Day, Thanksgiving Day, Christmas Day. MINIMUM CHARGE The monthly minimum charge shall be the customer charge. SERVICE COMPATIBILITY The customer must generate electric power at the same characteristics, voltage, current and frequency, and number of phases as the customer receives service from the Company and will be subject to the same electric service rules as are the general service customers of the Company. CONTRACT The Company will require a contract specifying technical and operating aspects of parallel generation. Customers have the right to appeal to the Michigan Public Service Commission if they believe the contract required by the Company is unreasonable. PRO-RATION OF DEMAND COST FOR AUTHORIZED MAINTENANCE For customers billed on rates with demand charges, the demand charges other than "Customer Demand" shall be prorated if the maintenance schedule of the customer owned generation facility has been approved in advance in writing by the Company. Said pro-ration shall be based on the number of authorized days of scheduled maintenance. The customer shall pay the demand rate for the higher than normal demands due to the generation outage only for the days of authorized maintenance. Continued to Sheet No. D-xx.xx Issued: xx-xx-xx By G R Haehnel Director - Regulatory Affairs Marquette, Michigan Effective for Service On and After: xx-xx-xx Issued Under Auth. of Mich Public Serv Comm Dated: xx-xx-xx In Case No: U-18094

12 UPPER PENINSULA POWER COMPANY MPSC Vol No 8-ELECTRIC Original Sheet No. D D2. Parallel Generation Purchase by UPPCO PG-4 Continued from Sheet No. D-xx.xx SPECIAL RULES 1. The Company shall install appropriate metering facilities to record all flows of energy necessary to bill the customer in accordance with the charges and credits of this rate schedule. 2. The customer shall furnish, install, and wire the necessary service entrance equipment, meter sockets, meter enclosure cabinets, or meter connection cabinets that may be required by the Company to properly meter usage and sales to the Company. 3. The requirements for interconnecting a generator with the Company s facilities are contained in the Michigan Public Service Commission s Electric Interconnection Standards Rules R and the Company s Michigan Utility Generator Interconnection Requirements, copies of which will be provided to customers upon request. All requirements must be met prior to commencing service. 4. Customer will secure and maintain liability insurance that provides protection against claims for damages resulting from (1 bodily injury, including wrongful death, and (2 property damage arising out of the customer's ownership and/or operation of the facility. The limits of the policy will be at least one million dollars (or the level shown in Wis. Admin. Code per occurrence or prove financial responsibility by another method acceptable to and approved in writing by the Company. The failure of the customer or the Company to enforce the minimum levels of insurance does not relieve the customer from maintaining such levels of insurance or relieve the customer of any liability. The customer will provide the Company with a certificate of insurance containing a minimum 30-day notice of cancellation prior to execution of this agreement. Each of the parties will indemnify and save harmless the other party against any and all damages to persons or property occasioned, without the negligence of such other party, by the maintenance and operation by such parties of their respective lines and other electrical equipment. Issued: xx-xx-xx By G R Haehnel Director - Regulatory Affairs Marquette, Michigan Effective for Service On and After: xx-xx-xx Issued Under Auth. of Mich Public Serv Comm Dated: xx-xx-xx In Case No: U-18094