January 12, Dear Ms. Kale:

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1 Clark Hill PLC S. Old Woodward Suite 00 Birmingham, MI 00 Robert. W. Strong T.. T.. F.. F.. clarkhill.com VI ELECTRONIC CSE FILING Ms. Kavita Kale Executive Secretary Michigan Public Service Commission 0 West Saginaw Highway Lansing, Michigan January, 0 Re: MPSC Case No. U-: In the matter of the application of DTE Electric Company for approval of Certificates of Necessity pursuant to MCL 0.s, as amended, in connection with the addition of a natural gas combined cycle generating facility to its generation fleet and for related accounting and ratemaking authorizations Dear Ms. Kale: Enclosed for filing are the Direct Testimony and Exhibits of on behalf of BTE, along with a Proof of Service in the case referenced above. Very truly yours, CLRK HILL PLC RWS:lllm Robert. W. Strong cc w/enc: Parties of Record. 0/

2 STTE OF MICHIGN BEFORE THE MICHIGN PUBLIC SERVICE COMMISSION In the matter of the pplication of DTE ELECTRIC COMPNY for approval of Certificates of Necessity pursuant to MCL 0.s, as amended, in connection with the addition of a natural gas combined cycle generating facility to its generation fleet and for related accounting and ratemaking authorizations. Case No. U- Direct Testimony and Exhibits of On behalf of ssociation of Businesses dvocating Tariff Equity January, 0 Project 0

3 Page STTE OF MICHIGN BEFORE THE MICHIGN PUBLIC SERVICE COMMISSION In the matter of the pplication of DTE ELECTRIC COMPNY for approval of Certificates of Necessity pursuant to MCL 0.s, as amended, in connection with the addition of a natural gas combined cycle generating facility to its generation fleet and for related accounting and ratemaking authorizations. Case No. U- Direct Testimony of PLESE STTE YOUR NME ND BUSINESS DDRESS.. My business address is 0 Swingley Ridge Road, Suite 0, Chesterfield, MO 0. WHT IS YOUR OCCUPTION? I am a consultant in the field of public utility regulation and an ssociate with the firm of Brubaker & ssociates, Inc. ( BI, energy, economic and regulatory consultants. 0 ON WHOSE BEHLF RE YOU PPERING IN THIS PROCEEDING? I am appearing on behalf of the ssociation of Businesses dvocating Tariff Equity ( BTE. BTE s members are customers of DTE Electric Company ( DTE or Company.

4 Page RE YOU FMILIR WITH THE FILING IN THIS DOCKET? Yes. I have reviewed the application, testimony and exhibits that have been filed. In addition, I have reviewed the responses to numerous data requests submitted by BTE, the Staff of the Michigan Public Service Commission ( MPSC or Commission, and numerous other intervenors. 0 WHT IS DTE REUESTING IN THIS DOCKET? DTE is seeking Certificates of Necessity ( CON in connection with the Company s proposal to build a nominal,00 MW natural gas combined cycle ( CCGT generating facility at the Company s Belle River Power Plant site ( Proposed Project or Belle River CCGT. WHT HVE YOU FOUND FROM YOUR NLYSIS OF DTE S REUEST? The foundation of DTE s request for a CON is predicated upon its proposal to retire the River Rouge, St. Clair, and the Trenton Channel coal-fired generating units before December 0. The retirement of this capacity creates the need for additional capacity resources which DTE proposes to meet by constructing and operating the Proposed Project. However, the retirement analysis itself was conducted in early 0 and contains assumptions which relate to federal environmental and tax policies that are no longer valid. 0 WHT RE YOUR RECOMMENDTIONS? For the reasons noted herein, I find that DTE has not conclusively established that the proposed coal retirements are in the public interest and, consequently, there is Direct Testimony of Kevin Chreston at Page. Exhibit B-, DTE s response to Staff s Data Request.a.

5 Page 0 not a clearly defined need for the Belle River CCGT in the 0/0 planning year. I recommend that the Commission deny DTE s request for a CON and direct the Company to revise its retirement analysis to incorporate the significant changes in federal environmental and tax policy to determine if the coal retirements proposed by DTE are in the public interest. Similarly, DTE should also revise its IRP based CON analysis for the same reasons. This is particularly important as one of the requests made by DTE in this Docket is for cost recovery of the Proposed Project. In addition to directing DTE to revise its coal retirement analysis ( Coal Retirement nalysis to incorporate significant known and measurable changes in federal policies, I also recommend the Commission set forth a more standardized process for DTE to follow when performing these analyses based upon the current IRP filing requirements being considered by this Commission in Docket Nos. U- and U-. Furthermore, the Commission should ensure that if/when DTE (or other Michigan utilities applies for another CON, there is a clear understanding of what information and models must be supplied with the filing in order to ensure the case can be efficiently processed. DO YOU HVE NY OTHER COMMENTS? Yes. The fact that I do not address a particular position or assumption made by DTE should not be construed as agreement with that position or assumption.

6 Page DTE S CLIMED ELECTRIC CPCITY NEED WHT IS THE BSIS OF NEED CLIMED BY DTE THT THE PROPOSED PROJECT IS EXPECTED TO FILL? Due to DTE s planned retirements of the River Rouge, St. Clair, and Trenton Channel Power Plants between 00 and 0, DTE is projecting a significant shortfall in capacity beginning in 0. DTE estimates the 0 shortfall, including a planning reserve margin, will be MW and expects the shortfall to increase to, MW in 0. 0 RE THE COL RETIREMENTS PLNNED BY DTE CONSISTENT WITH THE SERVICE LIVES FOR THE PLNTS ND THE CORRESPONDING DEPRECITION RTES PPROVED BY THE COMMISSION? No. The depreciation rates and expenses that are built-in to current rates are based on the depreciation rates and expenses that were approved in Docket No. U-. Those depreciation rates were based on the retirement dates that were proposed and approved in that Docket. In Case No. U-0, DTE has applied to change its depreciation rates based upon a Coal Retirement nalysis that according to DTE, demonstrates that retirement of St. Clair, River Rouge, and Trenton Channel, is more economic than their continued operation. 0 PLESE DESCRIBE THE COL RETIREMENT NLYSIS PERFORMED BY DTE. The Coal Retirement nalysis is an economic analysis conducted by DTE to evaluate the economics associated with the continued operation of its coal-fired units and the capital expenditures that would be required to bring the units into compliance with two environmental regulations. These two environmental regulations are the Steam

7 Page Electric Effluent Limitation Guidelines ( ELG and the Cooling Water Intake Regulations ( (b. This analysis was conducted by comparing the results of 0 individual retirement cases to a Base Retrofit Case using the production cost model PROMOD under four distinct scenarios. The Base Retrofit Case assumed the retirement of River Rouge in 00, St. Clair - and in 0, St. Clair and Trenton Channel in 0, Belle River in 0, Belle River in 00, and Monroe post 00. The replacement capacity in this scenario is a,00 MW CCGT in 0 and a,000 MW CCGT in 0. Because the retirements dates assumed in the Base Retrofit Case for Both Belle River and Monroe were post 0, the Base Retrofit Case assumed compliance and the corresponding capital investment necessary to bring Belle River and Monroe into compliance with ELG and (b. DTE performed six individual retirement cases to determine if a group of units should be retired. St. Clair - was considered as a single group. Belle River and were considered as a single group. The final four groups were St. Clair,, Trenton Channel, and River Rouge, all considered individually. In the St. Clair, Trenton 0 Channel, and River Rouge Case, the retirements were extended to 0 and the plants were retrofitted with the equipment required to comply with ELG and (b. In these cases, a,000 MW CCGT was installed in 0 and a,00 MW CCGT installed in 0. The Belle River retirement case assumed retirement of the Belle River coal plant in 0 with the,00 MW CCGT replacement installed in the same year. For each individual retirement case, a revenue requirement was computed and compared to the Base Retrofit Case. Figure below illustrates how the cases were compared to the Base Retrofit Case.

8 Page Figure If the revenue requirement in the individual retirement cases were less than the Base Retrofit Case, that would mean it makes more economic sense to retrofit the unit and continue operation past 0. DTE also performed three other sensitivities, which include High ELG Capital sensitivity where the ELG Capital was increased by 0%, a CO Price sensitivity where the CO price was increased from $0/ton to $/ton, and a Low Market Capacity Price where capacity prices were modeled at $0/kW-year; all other assumptions remained the same. 0 WHT DOES DTE CLIM RE THE RESULTS OF THE COL RETIREMENT NLYSIS? DTE claims the results of the Coal Retirement nalysis supports the retirements of St. Clair, Trenton Channel, and River Rouge in 0 or earlier, and replace of that

9 Page 0 capacity with a CCGT, rather than spending the capital necessary to makes these units comply with ELG and (b. The retirement of these three plants is what is driving the need for the,00 MW CCGT plant which is the subject of this Docket. Said another way, if the St. Clair, Trenton Channel, and River Rouge coal plants were to operate consistent with the lives that were used when determining their current depreciation rates, there would be no need for the Proposed Project in the 0/0 planning year. The analysis also purports to show it is economically beneficial to retrofit both Belle River and Monroe to make them compliant with the federal regulations and allow continued operations. With the proposed retrofits, Belle River would retire in 0, Belle River would retire in 00, and Monroe would retire in 00. WHT RE THE RETIREMENT DTES THT COINCIDE WITH DTE S DEPRECITION RTES? Table below shows the retirement dates that are used for the approved depreciation rates and the operation retirement dates used in the Coal Retirement nalysis as well the resultant retirement dates used in IRP modeling in this Docket and in the proposed depreciation rate calculations in U-0.

10 Page TBLE Comparison of Coal Plant Lives Plant Group Docket No. U- Retirement Dates Retirement Dates Used in Environmental Retrofit Case Retirement Dates Used in IRP Modeling Based on the Coal Retirement nalysis St. Clair - 0/ St. Clair St. Clair Trenton Channel River Rouge Belle River 00/0 0/00 0/00 DOES BTE HVE CONCERNS REGRDING THE COL RETIREMENT NLYSIS? Yes. I have a number of concerns about the validity of the Coal Retirement nalysis. First and foremost is the vintage of the analysis. The Coal Retirement nalysis was conducted in early 0. Since that time, a new administration controls the White 0 House and the federal environmental and tax policy has shifted. Similarly, the electric demand and commodity pricing data used in the analysis is now approaching two years old. Second, the approach used in the analysis is inconsistent with the method and risk analysis used to perform the IRP and CON replacement capacity analysis. Furthermore, the Coal Retirement nalysis neither used the retirement dates based on the currently approved depreciation rates as the baseline for comparison nor included increased depreciation expense in its Coal Retirement nalysis. Exhibit - in Case No. U-.

11 Page 0 PLESE EXPND ON THIS LST POINT REGRDING THE RETIREMENT DTES ND DEPRECITION EXPENSE. s shown in Table, above, the Coal Retirement nalysis did not consider a case which aligned with the current retirement dates of the units. Some of the units, such as St Clair and Trenton Channel were assumed to retire six to seven years early, even in the case when they were brought into environmental compliance. This would have impacted the economics of the analysis and increased the cost of compliance on an NPV basis as the capital recovery would have occurred over a shorter time frame. In addition, in Docket No. U-0, DTE separately is requesting rates that would increase depreciation expense for the steam production plants, based on 0 plant levels, by $ million. The rates in that Docket would be applicable in DTE s next general rate case. That is, in DTE s next general rate case, it will be requesting approximately $ million in additional revenues solely due to the increased depreciation expense it claims it will need to retire the coal plants earlier than was approved in Docket No. U-. However, in response to BDE-., DTE states that increased depreciation expense is not an example of increased cost to customers. DTE s full response to BTE Date Request. is attached to my 0 testimony as Exhibit B-; however, the relevant portion of the response with respect to depreciation expense is as follows: Furthermore, the Company does not agree with the characterization of increased depreciation expenses as an example of increased cost to customers. The plant retirements do not result in increased revenue requirements to customers over the long-term. Recovery of the assets and the associated cost of removal is one of timing as it occurs via inclusion of depreciation expense in base rates. Exhibit B-, DTE s response to BTE s Data Request BDE-..

12 Page 0 Given that in Docket No. U-0 DTE is asking for an increase of $ million in its annual depreciation expense to be recovered from its customers, it is at the very least, disingenuous to state that this somehow is not an increased cost to customers. Furthermore, it is unclear whether DTE considered the change in depreciation revenue requirements in its economic modeling. failure to account for this change would result in underestimating the cost of the Proposed Project on a NPV basis. PLESE SUMMRIZE YOUR CONCLUSIONS REGRDING THE COL RETIREMENT NLYSIS. 0 I will discuss my concerns in detail throughout the next sections of my testimony. Due to these concerns, I find that DTE has not conclusively established that the proposed coal retirements are in the public interest and, consequently, there is not a clearly defined need for the Proposed Project. In particular, the Coal Retirement nalysis contained inputs and modeling assumptions that are no longer correct due to changes in environmental and tax policy by the current administration. Rather than ask the Commission to rule on information that is known to be incorrect, I recommend that the Commission deny DTE s request for a CON and direct the Company to revise its retirement analysis to incorporate the significant known and measurable changes in federal environmental and tax policy to determine if the coal retirements proposed by DTE are in the public interest. In doing so, DTE should also update its load 0 forecast, commodity inputs and other time sensitive data to reflect the most current information. Finally, DTE should be required to perform the base case analysis and risk assessment sensitivities consistently with the method and risk analysis it will perform when assessing replacement capacity if the results of its updated Coal Retirement nalysis demonstrate a need for additional capacity.

13 Page 0 0 CHNGES IN FEDERL POLICIES PLESE SUMMRIZE THE FEDERL POLICIES THT HVE CHNGED OR BECOME MORE UNCERTIN SINCE DTE BEGN ITS COL RETIREMENT, IRP ND CON NLYSIS. First, On December, 0, President Donald Trump signed into law the Tax Cuts and Jobs ct of 0 ( TCJ which contains provisions reducing the corporate tax rate and revising the federal tax structure. These new federal requirements affect the current tax expense and deferred tax accounting methods used by corporations, including utilities. Most of the provisions of the TCJ go into effect on January, 0. This Commission has recognized the magnitude of this change in policy and the potential for it to reduce costs to Michigan ratepayers. Consequently, the Commission recently ordered all Michigan utilities to apply regulatory accounting treatment, including regulatory assets and liabilities, for all impacts resulting from the TCJ. Second, the economic analysis DTE performed and relied upon to assess the future of its coal-fired generation was performed in the spring of 0 and incorporates assumptions related to the Clean Power Plan ( CPP even though this regulation has been stayed by the U.S. Supreme Court. similar circumstance is occurring with the ELG. The current administration has indicated its intent to review and potentially revise the ELG requirements and compliance dates. The EP has postponed certain compliance dates from 0-0 to Docket No. U-, Order, dated 0--.

14 Page WS DTE WRE OF THE CHNGES IN FEDERL ENVIRONMENTL POLICIES WHEN IT PERFORMED ITS COL RETIREMENT NLYSIS? 0 DTE was aware that the CPP had been stayed and that litigation was remanded back to the Circuit Court for review when it conducted its Coal Retirement nalysis. Since that time, additional uncertainties were added due to the outcome of the 0 U.S. Presidential election and corresponding change in direction undertaken by the new Trump administration. In particular, the new President recently issued an Executive Order titled Promoting Energy Independence and Economic Growth that instructed the EP to review the CPP and suspend, revise or rescind the rule if appropriate. In addition to the CPP, the EP also recently announced a stay of the ELG regulations for reconsideration. Prior to the stay, DTE estimated that it would take $0 million to bring its entire coal fleet into compliance with ELG; however, the outcome of the reconsideration and any potential changes in the regulations may greatly impact the investment necessary for operation of the existing facilities. HOW DO THESE POLICIES FFECT THE NLYSIS PERFORMED BY DTE? The environmental policies and the associated capital costs required to comply with the regulations are the driving factor behind DTE s proposal to retire the coal assets that then create the need for the Proposed Project. It is possible that some of these regulations may be delayed further or removed all together. However, even if the 0 regulations remain, due to the way a utility s revenue requirement is set, the change the federal corporate tax rate necessarily changes the costs to comply with the environmental regulations and, consequently, renders DTE s analysis incorrect regardless of the ultimate environmental compliance deadlines. Direct Testimony of Barry Marietta at page. Id.

15 Page 0 PLESE EXPLIN HOW THE CPP IMPCTED THE COL RETIREMENT NLYSIS. The CPP was a proposed environmental regulation that would have severely limited the allowed CO emissions from power plants after 00. It is apparent that for coal plants that were expected to retire after 00, DTE arbitrarily moved the retirement dates to 00 or before without any analysis performed on the reasonableness of that decision. The lack of any supporting analysis or reasoning for the adjustment to 00 or before makes the choice appear arbitrary, since the dates could have equally been 0 or before, or 0 or before. Prior to this analysis being performed and the announcement of the CPP, Belle River and were expected to retire in 00 and 0, St. Clair was expected to retire in 0 and Trenton Channel was expected to retire in 0. DTE has produced no studies or justification of moving from these retirement dates to those utilized in the Base Retrofit Case, which assumed 0 and 00 for Belle River and, and 0 for St. Clair and Trenton Channel. PLESE EXPLIN HOW ELG IMPCTED THE COL RETIREMENT NLYSIS. Compliance with ELG and (b are the predominant factors driving the retirements resulting from the Coal Retirement nalysis that create the capacity shortfall and corresponding need for new capacity in the 0/0 planning year. Between the (b and ELG regulations, DTE expects compliance with ELG to be more costly. 0 The ELG regulations will impact DTE s coal-fired units. significant modifications at all existing power plants. Compliance would require Under the current ELG regulations, the required process and equipment modifications would necessitate extensive capital projects for any unit that would remain in service beyond the Direct Testimony of Kevin Chreston at page.

16 Page compliance deadline. DTE estimates that capital expenditures to comply with ELG are estimated at $0 million for all of DTE s existing coal plants; however, since performing the analysis, the EP announced a stay of the ELG regulations for reconsideration. The outcome of the reconsideration and any potential changes in the regulations may greatly impact the total investment and timing necessary for continued operation of existing facilities. In response to a Staff Data Request, DTE acknowledged that the economics for River Rouge, St. Clair and Trenton Channel would be improved if ELG continues to be stayed. DTE has not performed the full economic analysis to determine 0 whether the continued stay of ELG alone would change the outcome of the analysis for any of the plants. However, DTE also indicated that economics were not the only consideration for the decision to retire. In addition, DTE also considered the increased risk of failures, higher costs to operate and maintain the units, potential future regulations, as well as DTE s recently announced low carbon aspiration. 0 DO YOU GREE WITH DTE S RESPONSE TO THE STFF? No. In fact, I think that a properly updated analysis would address not only the question regarding the economics of a continued stay regarding ELG, but also the other considerations listed by DTE. It is obvious that performing an updated 0 economic analysis with the most current information available regarding DTE s load forecast, commodities and incorporating modeling assumptions that reflect the potential for a continued stay would answer the economic questions around that issue. Furthermore, DTE could address its concerns regarding increases in O&M costs or decreases in unit availability as these could be modeled and quantified. If Direct Testimony of Barry Marietta at page. 0 Exhibit B-, DTE s response to Staff s Data Request.b.

17 Page 0 DTE has not incorporated these assumptions into its exiting analysis, then this is yet another reason why the analysis cannot be relied upon. With respect to the future potential environmental regulations, this type of risk is fully considered, or should be fully considered by an IRP/CON resource planning analysis. s I will discuss later, ensuring that the Coal Retirement nalysis is performed consistently with the rest of the analyses, including a full set of scenarios and sensitivities, would provide the Commission the necessary information to assess whatever potential future environmental regulations the Company chose to model in its set of risk scenarios. Finally, DTE s low carbon aspiration should be considered within the confines of the Michigan RPS and DTE s obligation to provide reliable electric service at lowest reasonable cost. Ratepayers should not be forced to pay higher costs due to internal DTE policies. If DTE can conclusively demonstrate its proposal aligns with its obligation to provide reliable electric service at lowest reasonable cost, then the Commission should seriously consider that alternative. Once again, the solution is to update the analysis and provide those results to the Commission so it can make an informed decision with the best information possible. 0 HOW WOULD THE REFORMS CONTINED WITHIN THE TX CUTS ND JOBS CT SIGNED INTO LW ON DECEMBER, 0 IMPCT THE NLYSIS? The full effects of this law are unclear as much depends on how DTE intends to approach excess deferred income taxes and other tax nuances. BTE submitted discovery to DTE regarding the TCJ and its effects but did not have the responses prior to the filing of this testimony.

18 Page With that being said, the change in the federal corporate tax rate alone should be enough cause for the analyses to be revised. ny capital projects that are financed by DTE with equity resources are grossed up for taxes when determining the effective revenue requirement. The reduction in the federal corporate tax rate would then lower the revenue requirements of incremental capital expenditures paid for by customers. s a consequence, the revenue requirements considered in the Coal Retirement nalysis, as well as the resource planning analysis supporting the Proposed Project, are now incorrect and overstated. In addition to the direct effects of the change in the corporate tax rate there are also revenue requirement effects 0 associated with the flow back of excess accumulated deferred income taxes. The Commission should understand these revenue requirement implications, prior to making a decision in this Docket, including how they will affect the Coal Retirement nalysis and the Proposed Project. s I mentioned earlier, this Commission has recognized the magnitude of this change in tax policy and the potential for it to reduce costs to Michigan ratepayers. Consequently, the Commission recently ordered all Michigan utilities to apply regulatory accounting treatment, inclusive of regulatory assets and liabilities, for all impacts resulting from the TCJ. The Commission should be equally concerned 0 with understanding the effect in the instant Docket because it has the potential for a billion dollar impact to customers. Docket No. U-, Order, dated 0--.

19 Page WOULD IT BE IN THE PUBLIC INTEREST TO MOVE FORWRD IN THIS DOCKET WITHOUT UPDTING THE NLYSIS FOR THESE KNOWN ND MESURBLE CHNGES? No. While it is certainly possible that the outcome of a revised analysis will be the same, the fact of the matter is that the current analysis put forth by DTE is now known to be factually and materially incorrect due to the TCJ. Consequently, the Commission cannot maintain the public interest and simultaneously knowingly rely upon incorrect information. t the same time, it would be fundamentally unfair to 0 allow DTE to revise its analysis and then offer this new analysis in its rebuttal testimony, without allowing other parties to this Docket to conduct full discovery and then offer testimony responding to the new analysis. For these reasons, I recommend the Commission deny DTE s requested CON. lternatively, I recommend that the Commission vacate the current schedule, require DTE to address each of these issues in its rebuttal testimony and allow the Staff and Intervenors the opportunity to conduct discovery and file responsive testimony to the new analysis. This is particularly important as one of the requests made by DTE in this Docket is for cost recovery of the Proposed Project. 0 PLESE EXPND ON YOUR LST STTEMENT. In this filing, DTE is seeking three CONs. The first and second CONs deal with the need for the project and the reasonableness/prudency of the project in relation to the defined need. The third CON requests the estimated costs be recoverable in rates. In my opinion, the preapproval of costs necessitates that the Commission apply very strict scrutiny when examining the reasonableness of the Proposed Project. I would

20 Page recommend against preapproving any costs for recovery based upon an analysis that is known to be incorrect, which is a fact in this Docket due to the TCJ. RE OTHER COMMISSIONS REUIRING UTILITIES TO UPDTE OPEN DOCKETS TO UNDERSTND THE EFFECTS OF THE TCJ RTHER THN MKING DECISION BSED ON INCORRECT INFORMTION? Yes. Many Commissions are concerned with this issue and are taking action in different ways. One example involves a utility that operates in both Michigan and Indiana, Indiana Michigan Power Company ( I&M. The Indiana Utility Regulatory 0 Commission ( IURC issued a Docket Entry in Cause No. on January, 0 requiring I&M to update any schedules that are impacted by the TCJ by January 0, 0. I have attached a copy of this Docket Entry as Exhibit B-. In addition to I&M, the IURC also approved a schedule change in the Northern Indiana Public Service Company ( NIPSCO case based on all parties agreement to update for TCJ. Of particular note in this motion is Paragraph to which the utility, 0 NIPSCO, is a signatory. Paragraph states: Insofar as the changes in federal tax law have a material bearing on the merits of the rate proposals put forward by NIPSCO, the burden of moving forward with evidence in this regard properly falls on NIPSCO. NIPSCO prepared and submitted its case-in-chief evidence premised on tax assumptions that are no longer accurate. That case-in-chief evidence is deficient in light of the changed circumstances as to federal taxes. Joint Movants do not suggest there was any fault on the part of NIPSCO in failing to anticipate and address the changes in federal tax law that occurred three months after the initial submission occurred in this case. Indeed the statements contained within this motion are true of all utilities with active filings that contain analyses containing calculations that rely, in part, on the corporate tax rate. Similar to what is stated in the motion, I do not suggest that DTE is at fault Exhibit B-, Joint Motion Revise the Procedural Schedule to llow for the Submission of Evidence Regarding Material Changes in Federal Law. Cause No..

21 Page 0 for failing to address the changes in federal tax law that occurred almost six months after DTE s initial submission occurred in this Docket. However, the incontrovertible fact is that the submission originally made by DTE is now deficient in light of the changes to federal taxes. nother example, while not contained within a Commission order, but addressed by parties to a CON case in New Mexico via settlement agreement, is an agreement by the utility to provide a fully update economic analysis if the federal corporate tax rate changed. The hearing examiner asked many witnesses regarding this issue during the public hearings which occurred on December -0, 0. Other examples involve issuing orders that incorporate provisions for updates or special regulatory treatments to address changes in the tax law. Finally, some commissions, including this one, have issued orders asking for dockets to be opened to examine the effects on regulated utilities rates. 0 WHT RE YOUR CONCLUSIONS REGRDING THE CHNGE IN FEDERL ENVIRONMENTL ND TX POLICIES? Given the known changes resulting from the recently enacted TCJ, as well as the changes in the environmental policy related to the CPP and ELG, I recommend that either the Commission deny DTE s application or require DTE to update its Coal Retirement and CON analyses to incorporate the known and measurable changes and fully examine the risks and uncertainties created by the changes in federal policies. s I will discuss in the next section of this testimony, I further recommend the Commission require that regardless of whether the Commission denies the application or requires an update, these two analyses must both reflect the most New Mexico PRC Case No UT. New Mexico PRC Docket No. -00-UT & Nevada PUC Docket No lso Utah, Missouri, Idaho, North Carolina, and likely many others.

22 Page 0 recent load forecast and commodity information available, as well as any other time sensitive cost (or other information and be performed using a consistent analytical method and consistent set of risk scenarios. CONSISTENCY IN CON FILING POLICIES PLESE DESCRIBE THE INCONSISTENCY BETWEEN THE COL RETIREMENT NLYSIS ND THE IRP ND CON NLYSES. The basis of DTE s IRP and CON filing is a Strategist analysis to select the most cost effective resource under a given set of scenarios and sensitivity assumptions to meet capacity and energy obligations. Indeed, this type of analysis is performed by 0 many utilities when assessing the economics of resource planning. Some utilities, DTE included, will then further refine the Strategist-based analysis by developing more detailed revenue requirement models for the resources selected by Strategist. Typically, a subset of scenarios and sensitivity assumptions believed to be the most influential will then be evaluated through the use of more rigorous variable cost models like PROMOD. The results of these computations are then used in 0 conjunction with spreadsheets and other tools used to more explicitly represent the fixed revenue requirements and regulatory accounting unique to the utility performing the analysis. However, when performing the Coal Retirement nalysis, DTE neither performed a Strategist analysis nor considered the same set of scenarios and sensitivity assumptions utilized in the CON and IRP analyses. The Coal Retirement nalysis and the CON analysis did not even use the same set of base inputs such as load forecasts and commodity prices. Given the dependence between the Coal Retirement nalysis and the need that the requested CON is based upon, using

23 Page consistent and timely assumptions is paramount. With consistency between the Coal Retirement nalysis and the CON analysis, DTE has yet to complete the analyses, scenarios, and sensitivities necessary to support its $ billion ask of ratepayers in this proceeding. 0 IS THE CIRCUMSTNCE OF POTENTIL ENVIRONMENTL COL RETIREMENTS ND THE CORRESPONDING NEED FOR REPLCEMENT CPCITY UNIUE TO DTE OR MICHIGN? No, though there are some nuances unique to Michigan. s environmental regulations have become more stringent in recent years, along with a significant decline in the cost for natural gas and increases in renewable energy standards, the U.S. has seen tens of thousands of megawatts of aging coal-fired capacity retired and it is unlikely that new coal plants will be built going forward. Indeed, this is 0 exemplified by historically coal-centric utilities such as merican Electric Power and PacifiCorp transitioning away from coal resources to natural gas-fired and renewable generation technologies. This fact, coupled with the increasing age of the U.S. coal generation fleet, foreshadows a nationwide trend for which Michigan is no exception. One distinction for Michigan, that is not shared by the U.S. as a whole, is the particular geography situation with respect to transmission limitations created by the current transmission system to Michigan s lower peninsula because of the situation of the Great Lakes on its borders. The effects of these limitations will necessitate that more replacement capacity will be built within Michigan near its loads, relative to other regions in the U.S. s a consequence, it is likely that Michigan will see more CON filings from its regulated utilities in the coming years. However, this does not mean that the Commission should jump to any conclusions in this case, especially

24 Page considering that the economic analysis filed by DTE is incomplete and incorrect. The current White House administration s shift in federal policies potentially offers a stay of execution for the plants at risk for immediate retirement. The additional time created by the shift in federal policies provides a chance for the Commission to require DTE to go back and revise its analysis to provide the Commission a complete and consistent analysis upon which to base a decision. 0 IS THERE DEDLINE TIME BY WHICH DTE MUST MKE DECISION OR COULD DELYING THIS DECISION LED TO RELIBILITY PROBLEMS IN THE FUTURE? In discovery, BTE asked DTE about the timing to comply with the regulations and when it must make a decision. DTE responded that currently there is not a specific date when a decision to retire the coal plants must be made to comply with ELG and (b. However, DTE went on to say, that given the age of the plants and the costs to comply with the regulations, DTE concluded, at this point in time, the most reasonable and prudent decision is to retire the plants. However, as I have discussed, this conclusion is based upon incorrect, inconsistent, and outdated information. Furthermore, it is exactly this decision to retire the coal plants that create the reliability concerns and need for new resources. Currently, these plants exist and 0 provide capacity to customers. DTE s proposal allows DTE to create a reliability problem of its own doing. The Commission should not allow DTE to create a reliability problem where one does not exist. Further, the Commission should not Exhibit B-, DTE s response to BTE s Data Request BDE.. Id.

25 Page approve retirement of these assets without first deciding, based on the best available information at the time, retiring the plants is in the public interest. GIVEN THE LIKELIHOOD OF DDITIONL CON FILINGS IN THE COMING YERS, WHT CN BE DONE TO IMPROVE THE PROCESS? There are a number of lessons that can be learned from this Docket as well as synchronization between the CON filings and the IRP filing requirements along with the associated IRP Strawman proposal under consideration by this Commission in Docket Nos. U- and U-. In fact, in its Opinion and Order in Docket No. U-, the Commission recognized that the risk assessment scenarios should be 0 consistent between a CON filing and an IRP filing. I would further this idea to fully encompass not just the CON filing and analysis used to select a new resource, but also in the context of an economic retirement analysis (or similarly, an analysis to determine the economics behind a Power Purchase greement such as the one considered for amendment recently by the Commission in Consumers Energy Company Docket No. U-0. 0 WHT OTHER LESSONS CN BE LERNED FROM THIS PROCEEDING? In addition to ensuring consistency going forward within all of the analyses relied upon to support the filing, there are other issues as well that the Commission should consider. t the top of the list is the amount of data and the overall size of the filing that must be reviewed. This filing was massive. DTE witness Chreston alone had almost 00 workpapers and relied upon multiple models/software. In order to facilitate an efficient process, I recommend that a technical conference for experts be Opinion and Order, Docket No. U-, dated 0--0 at page.

26 Page scheduled to understand the workflow, location of data, development of model inputs, and other technical considerations. This technical conference proposal is not 0 suggested as a forum to argue over methods, but a forum to understand the data and processes used by the utility in its IRP and CON analyses to evaluate and prepare a CON application. long a similar line, I would also note that this is the second CON filing where the LJ ordered that the pplicant make certain modeling software available to intervenors (Strategist and PROMOD. If proprietary software and modeling results access barriers are going to become a regular part of the CON process, the Commission should make that known and ensure that there is a reasonable time and process to obtain the software to ensure maximum value to the regulatory process. 0 REFERENCING YOUR STTEMENT REGRDING THE MODELS, CN YOU DISCUSS WHY BTE DID NOT PRESENT MODELING RESULTS EVEN THOUGH IT HD CCESS TO THE MODELS? Yes. There are two primary reasons. s I have discussed at length in this testimony, the inputs and analysis used by the Company are outdated and inconsistent with current federal policies. Had BTE used DTE s models as the starting point for any analysis, BTE would be supporting the use of incorrect information to form conclusions regarding the reasonableness of DTE s request for a CON. The second reason is the consistency of methods used between the Coal Retirement nalysis and the resource planning analysis used to support the Proposed Project. One of BTE s strongest concerns is the Coal Retirement nalysis, and specifically, the lack of a Strategist based analysis as the starting point for the Coal Retirement nalysis. Strategist can be used to assess the

27 Page economics of retirement versus retrofit alternatives simultaneously with replacement capacity options. But DTE failed to do that in this case. s I discussed earlier, this should have been modeled by DTE with assumptions reflecting that those plants that are retrofitted and are currently expected to remain in service beyond 0, are modeled to remain in service through their expected useful lives. In other jurisdictions, I have reviewed retirement analyses performed using Strategist in which the replacement alternatives were considered simultaneously, or co-optimized, with the potential retirement alternatives. This makes perfect sense because these decisions are mutually dependent. Indeed, this was one of the types of analysis 0 considered by BTE; however, because there was no Strategist case built to consider the retirements as alternatives, it would have been nearly impossible to convert the existing Coal Retirement nalysis into a Strategist model, ensure data integrity and prepare testimony within the time frame BTE had access to the model. WHT DO YOU CONCLUDE REGRDING THE CONSISTENCY OF THE NLYSES RELIED UPON IN THIS FILING? 0 There are a number of inconsistencies contained within the analyses DTE conducted and relied upon in support of its request for a CON. In order to assure that the public interest is preserved, consistency must be maintained across the inputs, and in the instance of similar problems, similar methods and models should be employed. This starts with having a well understood process and ensuring a relevant, status quo case for a baseline from which to compare each alternative.

28 Page 0 WHT DO YOU RECOMMEND WITH RESPECT TO THE CONSISTENCY ISSUES? My recommendation with respect to these issues is in accord with my recommendations throughout this testimony; the Commission should deny DTE s request for a CON in this Docket. lternatively, the Commission should direct DTE to revise its coal retirement and replacement capacity analyses used to support this filing to reflect a consistent set of updated inputs and assumptions, as well as a consistent set of alternative scenarios and sensitivities to assess the risks faced by this decision. In doing so, I recommend the Commission require that any updated analysis filed in this Docket or analyses supporting future CON filings maintain consistency internally and, where possible, align with or stem from the recent IRP filing requirements and Strawman proposals considered by this Commission. Furthermore, I recommend the Commission consider the lessons learned from this Docket and ensure that in the future the process is clear with respect to the models/software, sharing of data, setting of technical conferences, etc. to ensure the CON process is efficient and in the best interest of the ratepayers. 0 PESE SUMMRIZE YOUR CONCLUSIONS ND RECOMMENDTIONS. For the reasons noted herein, I find that DTE has not conclusively established that the proposed coal retirements are in the public interest and, consequently, there is not a clearly defined need for the Belle River CCGT in the 0/0 planning year. I recommend that the Commission deny DTE s request for a CON, or in the alternative, direct the Company to revise its retirement analysis to incorporate the significant changes in federal environmental and tax policy to determine if the coal retirements

29 Page 0 proposed by DTE are in the public interest. Similarly, DTE should also revise its IRP based CON analysis for the same reasons. This is particularly important as one of the requests made by DTE in this Docket is for cost recovery of the Proposed Project. In addition to directing DTE to revise its Coal Retirement nalysis, I also recommend the Commission set forth a more standardized process for DTE to follow when performing these analyses based upon the current IRP filing requirements being considered by this Commission in Docket Nos. U- and U-. Furthermore, the Commission should ensure that if/when DTE (or other Michigan utilities applies for another CON, there is a clear understanding of what information and models must be supplied with the filing in order to ensure the case can be efficiently processed. DOES THIS CONCLUDE YOUR DIRECT TESTIMONY? Yes, it does.

30 ppendix Page ualifications of PLESE STTE YOUR NME ND BUSINESS DDRESS.. My business address is 0 Swingley Ridge Road, Suite 0, Chesterfield, MO 0. PLESE STTE YOUR OCCUPTION. I am a consultant in the field of public utility regulation and an ssociate with the firm of Brubaker & ssociates, Inc. ( BI, energy, economic and regulatory consultants. 0 PLESE STTE YOUR EDUCTIONL BCKGROUND ND PROFESSIONL EMPLOYMENT EXPERIENCE. I graduated from the Washington University in St. Louis/University of Missouri-St. Louis joint engineering program in 00 where I received a Bachelor of Science degree in Electrical Engineering. In 0 I received the degree of Master of Engineering in Electrical Engineering with a concentration in Electric Power and Energy Systems from Iowa State University of Science and Technology. In 0 I received a Master of Science Degree in Computational Finance and Risk Management from the University of Washington Seattle. I am a member of the Power and Energy Society of the Institute of Electrical and Electronics Engineers. I joined BI as an intern in 00 and upon graduation, I accepted a position with BI as an ssociate Engineer. In January of 0, I was promoted to the 0 position of ssociate Consultant, in January of 0 I was promoted to the position of Consultant at BI, in January of 0 I was promoted to my the position of Senior Consultant at BI, and in January of 0 I was promoted to my current position of ssociate at BI. While at BI, I have been involved with numerous regulated and BRUBKER & SSOCITES, INC.

31 ppendix Page competitive electric service issues. These have included transmission planning, 0 0 resource planning, electric price forecasting, load forecasting, cost of service, combined heat and power steam costs and power procurement. This has involved the performance of power flow, production cost, transmission line routing, cost of service and other analysis to address these issues. Prior to joining BI, through the department of Electrical and Computer Engineering and the Medical School at Washington University in St. Louis, I aided in preliminary research focusing on the use of ultrasound as a mechanism for in vitro localized thermometry. BI and its predecessor firm have participated in more than 00 regulatory proceedings in 0 states and Canada. BI provides consulting services in the economic, technical, accounting, and financial aspects of public utility rates and in the acquisition of utility and energy services through RFPs and negotiations, in both regulated and unregulated markets. Our clients include large industrial and institutional customers, some utilities and, on occasion, state regulatory agencies. We also prepare special studies and reports, forecasts, surveys and siting studies, and present seminars on utility-related issues. In general, we are engaged in energy and regulatory consulting, economic analysis and contract negotiation. In addition to our main office in St. Louis, the firm also has branch offices in Phoenix, rizona and Corpus Christi, Texas. \\Doc\Shares\ProlawDocs\MED\0\.docx BRUBKER & SSOCITES, INC.

32 Case No.: U- Exhibit: B- Witness: Date: January, 0 Page of MPSC Case No.: U- Respondent: K. J. Chreston/B.J. Marietta Requestor: STFF uestion No.: STDE-.a Page: of uestion: Please reference page of Mr. Chreston s testimony. a. The Company mentions ELG and (b regulations, were other emerging environmental regulations assumed in the company s analysis resulting in the River Rouge, St. Clair and Trenton Channel facilities being uneconomical? nswer: The Retirement nalysis was run in spring of 0, and other environmental regulations were considered. The National mbient ir uality Standards (NS were considered. The Cross-State ir Pollution Rule (CSPR with stricter NOX and SO budgets was also considered along with forecasted ozone season reductions beginning in May 0. The underlying environmental basis in the analysis assumed the Clean Power Plan to be in effect, even though it had been stayed by the US Supreme Court at the time of the study. It was assumed that the court action would keep the CO regulations uncertain for some time. To account for some of the CO uncertainty, a CO price sensitivity was run.

33 Case No.: U- Exhibit: B- Witness: Date: January, 0 Page of MPSC Case No.: U- Respondent: I. M. Dimitry/T.M. Uzenski Requestor: BTE uestion No.: BDE-. Page: of uestion: nswer: Please explain if the Company has performed any analysis that captures the increased cost to customers associated with the early retirement of the coal plants. n example of increased costs is the estimated $. million in additional steam production depreciation expense that DTE has proposed in Docket No. U-0. If this type of analysis has been performed, please provide in its complete format, with all formulas and links intact, as well as all supporting workpapers. If this analysis has not been performed, please provide a detailed narrative explaining why such an analysis has not been performed. It is unclear what is meant by the early retirement of the coal plants. The Company does not consider the planned retirement dates for the Tier plants as discussed in this case to be early. s part of its long-term resource planning, the Company has determined that a number of coal plants will be retired between now and 0 due to age, environmental requirements, and the Company s commitment toward building a cleaner, sustainable generation fleet. Furthermore, the Company does not agree with the characterization of increased depreciation expenses as an example of increased cost to customers. The plant retirements do not result in increased revenue requirements to customers over the long-term. Recovery of the assets and the associated cost of removal is one of timing as it occurs via inclusion of depreciation expense in base rates. The Company uses the Group Method of depreciation and generally does not track depreciation reserves within each utility account down to the individual plant level. (n exception is the Belle River plant, where the Company is required to separately account for depreciation. t the time an individual plant retires, any undepreciated plant balances will be recovered through the process of redistributing reserve balances and resetting depreciation rates for the remaining plants in the group. n economic analysis was conducted that led to a conclusion that retirement of River Rouge, St. Clair Units, St. Clair Unit, and Trenton Channel Unit was favorable for customers compared to the capital investment and expenses required to safely operate and maintain these units with the revised environmental regulations. The resource planning process and the economic analysis associated with the planned retirements of the Tier coal plants is described the testimony of witnesses

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