Parties to Case No. U per Attachment 1 to Proof of Service

Transcription

1 A CMS Energy Company August 10, 2018 Ms. Kavita Kale Executive Secretary Michigan Public Service Commission 7109 West Saginaw Highway Post Office Box Lansing, MI General Offices: LEGAL DEPARTMENT One Energy Plaza Jackson, MI Tel: Fax: (517) (517) CATHERINE M REYNOLDS Senior Vice President and General Counsel *Washington Office: 1730 Rhode Island Ave. N.W. Tel: (202) MELISSA M GLEESPEN Suite 1007 Vice President, Corporate Washington, DC Fax: (202) Secretary and Chief Compliance Officer Writer s Direct Dial Number: (517) Writer s Address: michael.rampe@cmsenergy.com SHAUN M JOHNSON Vice President and Deputy General Counsel Bret A Totoraitis Kelly M Hall Eric V Luoma Assistant General Counsel Ashley L Bancroft Robert W Beach Don A D Amato Robert A. Farr Gary A Gensch, Jr. Gary L Kelterborn Chantez P Knowles Mary Jo Lawrie Jason M Milstone Rhonda M Morris Deborah A Moss* Mirče Michael Nestor Michael C. Rampe James D W Roush Scott J Sinkwitts Adam C Smith Theresa A G Staley Janae M Thayer Anne M Uitvlugt Aaron L Vorce Attorney RE: MPSC Case No. U In the matter of the application of Consumers Energy Company for an electric rate case self-implementation reconciliation for Case No. U Dear Ms. Kale: Enclosed for electronic filing in the above-captioned case, please find the Amended Application and Revised Direct Testimony and Revised Exhibits A-4 (SAS-4), A-5 (SAS-5), and A-7 (SAS-7) of Witness S. Austin Smith. Exhibits A-1 (SAS-1), A-2 (SAS-2), A-3 (SAS-3), and A-6 (SAS-6) are unchanged from the July 30, 2018 filing. This is a paperless filing and is therefore being filed only in PDF. Also included is a Proof of Service showing service upon the parties to Case No. U Sincerely, Michael C. Rampe cc: Parties to Case No. U per Attachment 1 to Proof of Service fl

2 S T A T E O F M I C H I G A N BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the matter of the application of ) CONSUMERS ENERGY COMPANY ) for an electric rate case self-implementation ) Case No. U reconciliation for Case No. U ) ) AMENDED APPLICATION OF CONSUMERS ENERGY COMPANY FOR RECONCILIATION OF ELECTRIC UTILITY REVENUES PURSUANT TO MCL 460.6a(2) ( Consumers Energy or the Company ) respectfully applies for authority to reconcile: (i) the total electric utility revenues collected during the period that self-implemented rates were in effect during Case No. U with the total revenues that would have been produced had the final rates authorized in that proceeding been in effect during that period; and (ii) a residual balance which occurred during the implementation of the reconciliation of self-implementation revenues in Case No. U In support of this Application, Consumers Energy states as follows: 1. Consumers Energy is, among other things, engaged as a public utility in the business of generating, purchasing, distributing, and selling electric energy to approximately 1.8 million retail customers in the State of Michigan. Consumers Energy operates its retail electric system as a single utility system. 2. Consumers Energy s retail electric business is subject to the jurisdiction of the Michigan Public Service Commission ( MPSC or the Commission ) pursuant to various provisions of 1909 Public Act ( PA ) 106, as amended, MCL et seq.; 1919 PA 419, as amended, MCL et seq.; and 1939 PA 3, as amended, MCL 460.1, et seq. Pursuant to ap

3 these statutory provisions, the Commission has the power and jurisdiction to regulate Consumers Energy s retail electric rates. 3. On March 1, 2017, Consumers Energy filed an Application in Case No. U seeking authority to increase its rates and charges for the generation and distribution of electricity in the annual amount of $173 million. On August 10, 2017, pursuant to the provisions of MCL 460.6a(1) 1 and consistent with the schedule established by the Administrative Law Judge in the case, Consumers Energy filed testimony indicating that the Company intended to self-implement a rate increase designed to increase revenues in the annual amount of $130 million on and after October 1, On March 29, 2018, the Commission issued its Order in Case No. U authorizing Consumers Energy to, among other things, increase its retail electric rates in the annual amount of $65,760,000. The rates designed to produce this increase went into effect for service rendered on and after April 1, Subsequently, on June 28, 2018, the Commission issued its Order on Rehearing in Case No. U-18322, in which it granted, in part, the Company s Petition for Rehearing, and which resulted in a final jurisdictional revenue deficiency of $72,269,000. The Commission ordered the Company to file revised tariff sheets, along with supporting workpapers, no later than July 13, Consumers Energy made the required filing on July 13, 2018, which the Commission approved with its Order Approving Revised Tariffs dated July 24, 2018 in Case No. U The final rates approved in the June 28, 2018 Rehearing Order were used to calculate the final revenues for purposes of this reconciliation. 5. MCL 460.6a(2) provides in relevant part as follows: If the commission has not issued an order within 180 days of the filing of a complete application, the utility may implement up to the amount of the proposed annual rate request through equal 1 Subsequently redesignated as MCL 460.6a(2) by 2016 PA 341. ap

4 percentage increases or decreases applied to all base rates. If the utility uses projected costs and revenues for a future period in developing its requested rates and charges, the utility may not implement the equal percentage increases or decreases before the calendar date corresponding to the start of the projected 12-month period. For good cause, the commission may issue a temporary order preventing or delaying a utility from implementing its proposed rates or charges. If a utility implements increased rates or charges under this subsection before the commission issues a final order, that utility shall refund to customers, with interest, any portion of the total revenues collected through application of the equal percentage increase that exceed the total that would have been produced by the rates or charges subsequently ordered by the commission in its final order. The commission shall allocate any refund required by this subsection among primary customers based upon their pro rata share of the total revenue collected through the applicable increase, and among secondary and residential customers in a manner to be determined by the commission. The rate of interest for refunds shall equal 5% plus the London interbank offered rate (LIBOR) for the appropriate time period. For any portion of the refund that, exclusive of interest, exceeds 25% of the annual revenue increase awarded by the commission in its final order, the rate of interest shall be the authorized rate of return on the common stock of the utility during the appropriate period. Any refund or interest awarded under this subsection shall not be included, in whole or in part, in any application for a rate increase by a utility. This subsection only applies to completed applications filed with the commission before the effective date of the amendatory act that added section 6t. Consumers Energy s Application in Case No. U was complete and filed before April 20, 2017 the effective date of the amendatory act that added Section 6t. The Commission s March 29, 2018 Order directed that [o]n or before July 30, 2018, shall file an application for authority to conduct a self-implementation reconciliation proceeding as required under MCL 460.6a. The instant Application is filed in conformance with this directive. 6. To accomplish the reconciliation required by statute and the March 29, 2018 Order in Case No. U-18322, Consumers Energy first compared the total revenues collected from ap

5 customers served on the various rate schedules pursuant to the interim rates implemented during the October 1, 2017 to March 31, 2018 period with the total revenues that would have been produced during that period by the final rates approved by the Commission s June 28, 2018 Rehearing Order and July 24, 2018 Order in Case No. U A description of that comparison is provided in the testimony and exhibits of Company witness S. Austin Smith filed in support of this Application. As described in Company witness Smith s testimony, the total revenues collected pursuant to the interim rates exceed the total revenues that would have been produced by the rates ordered in the June 28, 2018 Rehearing Order and July 24, 2018 Order by approximately $33.6 million. If the Commission adopts this reconciliation calculation, Consumers Energy proposes to refund the amount of approximately $33.6 million, which includes the over-recovery amount plus interest of approximately $3,074,000, in the February 2019 billing month. 7. Additionally, as more fully described in Mr. Smith s testimony and exhibits, a net residual balance over-collection of $52,444 remains in connection with the reconciliation of the self-implemented electric rate increase approved in Case No. U for the period September 1, 2016 to March 6, The Company is proposing to integrate the remaining residual balances greater than $50,000 into its refund calculations in the instant case. Interest would be calculated on residual balance amounts using the short-term borrowing rate. The Company s short-term interest rate was applied over a prospective 15-month period, to reflect the amount of interest due from the date of the original self-implementation refund through the proposed refund month of February The Company proposes to forgo interest from rate classes where there was a revenue shortfall. Pursuant to the residual balance methodology ap

6 approved in Case No. U-18381, the Company would write off any under or over-collections less than $50, Reference to written testimony and exhibits filed in support of this Application will provide additional details on the above-described reconciliation, and the relief being sought. The relief described in the testimony and exhibits should be considered as if specifically requested in this Application. WHEREFORE, respectfully requests that the Michigan Public Service Commission grant the following relief: A. Order that the refund required pursuant to MCL 460.6a(2) with respect to the provisional rates implemented by Consumers Energy in Case No. U for the period October 1, 2017 through March 31, 2018 is $33.6 million, plus interest; B. Approve the Company s proposed integration of the remaining residual balances greater than $50,000 in connection with the reconciliation of the self-implemented electric rate increase from September 1, 2016 to March 6, 2017 approved in Case No. U into its refund calculations in this instant case; C. Direct that the refunded amounts be returned to customers during the February 2019 billing month by means of a negative surcharge added to customers bills; D. Approve the negative surcharges included in the tariff sheet shown in Exhibit A-7 (SAS-7) for the February 2019 billing month; and ap

7 appropriate. E. Grant the Company such other and further relief as may be lawful and Respectfully submitted, Dated: August 10, 2018 CONSUMERS ENERGY COMPANY Michael C. Rampe (P58189) Bret A. Totoraitis (P72654) Robert W. Beach (P73112) One Energy Plaza Jackson, Michigan Attorneys for (517) By: Michael A. Torrey Vice President Rates and Regulation ap

8 S T A T E O F M I C H I G A N BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the matter of the application of ) CONSUMERS ENERGY COMPANY ) for an electric rate case self-implementation ) Case No. U reconciliation for Case No. U ) ) REVISED DIRECT TESTIMONY OF S. AUSTIN SMITH ON BEHALF OF CONSUMERS ENERGY COMPANY August 2018

9 S. AUSTIN SMITH REVISED DIRECT TESTIMONY Q. Please state your name and business address. A. My name is S. Austin Smith, and my business address is One Energy Plaza, Jackson, Michigan Q. By whom are you employed and in what capacity? A. I am employed by ( Consumers Energy or the Company ) as a Rate Analyst I in the Pricing Section of the Rates and Regulation Department. Q. Please describe your educational background and business experience. A. In 2014, I graduated from Alma College with a Bachelor of Business Administration degree with an emphasis in Accounting. From June 2014 to July 2016, I was employed by Alro Steel on the Sales team in Flint and Jackson, Michigan, and in Charlotte, North Carolina. My responsibilities included: (i) managing a portfolio of customer accounts; (ii) customer service and customer relations problem-solving; (iii) delivery scheduling; (iv) logistics planning; (v) inter-company communication; and (vi) face-to-face customer sales visits, tours, and events. In August 2016, I began employment as a Rate Analyst I in the Pricing Section of the Rates and Regulation Department at Consumers Energy. My current responsibilities include rate design, research and development of additional services, analyses for Senior Management, and customer-specific rate analyses. te0818-sas 1

10 S. AUSTIN SMITH DIRECT TESTIMONY Q. Have you previously filed testimony with the Michigan Public Service Commission ( MPSC or the Commission )? A. Yes. I have filed direct testimony on behalf of the Company in the following MPSC Cases: Case No. U Case No. U Case No. U Case No. U (Amended) Energy Optimization Plan; Energy Waste Reduction ( EWR ) Plan; EWR Reconciliation; and EWR Reconciliation Q. What is the purpose of your direct testimony in this case? A. On October 1, 2017, pursuant to the provisions of MCL 460.6a(1), Consumers Energy self-implemented a retail electric rate increase of $130 million in Case No. U In its March 29, 2018 Order, the Commission authorized a rate increase of $66 million and directed Consumers Energy to file a reconciliation application as required under MCL 460.6a(1). I am sponsoring testimony and exhibits in support of the Company s Application filed in compliance with the Commission s Order. I am also sponsoring testimony and exhibits in support of the proposed reconciliation of a net residual balance over-collection of $52,444 which remains from the implementation of the reconciliation agreed to in a Settlement Agreement reached by the parties to Case No. U The settlement reached in Case No. U was ultimately approved by the Commission in its October 25, 2017 Order Approving Settlement Agreement in that matter. Case No. U addressed the reconciliation of the total electric utility revenues collected during the period self-implemented rates were in effect during Case No. U-17990, with te0818-sas 2

11 S. AUSTIN SMITH DIRECT TESTIMONY the total revenues that would have been produced had the final rates authorized in that proceeding been in effect during that period. Q. Please provide a brief description of the events that transpired in this case. A. On March 31, 2017, Consumers Energy filed an Application with the Commission seeking an annual rate increase in its electric generation and distribution rates of $173 million. On August 10, 2017, Consumers filed testimony proposing to self-implement a $130 million rate increase and implemented the $130 million increase on October 1, The Commission issued a March 29, 2018 Order which reflected an increase to the Company s electric rates of $66 million to be implemented on and after April 1, 2018 and directed the Company to file a reconciliation of the interim and final revenues. On June 28, 2018, the Commission issued an Order on Rehearing addressing the petition for rehearing filed by the Company. This Order provided increased final rate relief of $72 million. Final rates, including the rehearing amounts, were approved by the Commission in its July 24, 2018 Order Approving Revised Tariffs. These final rates were used calculating the final revenues for purposes of this reconciliation. Q. Please identify the exhibits you are sponsoring. A. I am sponsoring the following exhibits: 18 Exhibit Description A-1 (SAS-1) Summary of Interim and Final Revenue Increases by Rate Class; A-2 (SAS-2) Summary of Interim and Final Revenues by Rate Schedule; A-3 (SAS-3) Calculation of Interim and Final Revenues in Detail; te0818-sas 3

12 S. AUSTIN SMITH DIRECT TESTIMONY A-4 (SAS-4) (Revised) Calculation of Interest on the Self-Implemented Refund; A-5 (SAS-5) (Revised) Calculation of Refund Surcharge by Rate Schedule; A-6 (SAS-6) U Residual Balance Calculation of Case No. U Self-Implementation Reconciliation; and A-7 (SAS-7) (Revised) Proposed Tariff Sheet. Q. Were these exhibits prepared by you or under your supervision? A. Yes. Q. Please describe the content of these exhibits. A. Exhibit A-1 (SAS-1) provides a summary of the interim and final revenue increase by service type and rate class. The revenue difference between the interim and final increases is shown in column (d) of the exhibit. A negative difference indicates that total revenue collected from customers under the interim rates were greater than what would have been collected under final rates during the period in which self-implemented rates were in effect. A positive difference indicates that total revenue collected from customers under the interim rates were less than what would have been produced by the final rates during the period self-implemented rates were in effect. Exhibit A-2 (SAS-2) provides a summary of the interim and final revenues by rate schedule. The amount of revenue collected under the interim and final rates during the self-implementation period are shown in columns (d) and (f), respectively. The difference between the interim and final revenue is shown in column (g) of the exhibit and has the same meaning as the difference column shown in column (d) of Exhibit A-1 (SAS-1). te0818-sas 4

13 S. AUSTIN SMITH DIRECT TESTIMONY Exhibit A-3 (SAS-3) provides the detailed calculation of the interim and final revenue by rate schedule and service type. The product of the detailed billing determinants in column (a) and the interim and final rates is used to calculate the interim and final revenue shown in columns (d) and (f), respectively. The difference between the interim and final revenue is shown in column (g) of the exhibit and has the same meaning as the difference shown in column (d) of Exhibit A-1 (SAS-1). Revised Exhibit A-4 (SAS-4) provides the calculation of interest on the refund. According to the provisions of MCL 460.6a(2), the Company is required to include interest on any refund equal to 5% plus the London Interbank Offered Rate for the appropriate time period. For any portion of the refund that, exclusive of interest, exceeds 25% of the annual revenue increase awarded by the commission in its final order, the rate of interest shall be the authorized rate of return on the common stock of the utility during the appropriate period. The Company has determined the amount of applicable interest through the February 2019 bill month to be $3,074,000, as shown on Revised Exhibit A-4 (SAS-4), line 17, column (l). Revised Exhibit A-5 (SAS-5) shows the calculation of the refund by rate schedule. Column (c) shows the refund amount by rate schedule including interest. The Company is proposing a $5.2 million refund to the Residential Rate Class, a $5.3 million refund to the Secondary Rate Class, a $26.1 million refund to the Primary Rate Class $24.1 million to Full-Service customers plus $1.9 million to ROA Service customers), and a $14,000 refund to the Lighting and Unmetered Rate Class, for a total refund of $36.6 million including interest as shown on Revised Exhibit A-5 (SAS-5), column (c). te0818-sas 5

14 S. AUSTIN SMITH DIRECT TESTIMONY Q. What is the difference in total retail electric revenues produced under the interim and final approved rates? A. The total interim revenue collected from October 1, 2017 to March 31, 2018 is $65.3 million. Had final rates been in effect during this period, the Company would have collected total revenues of $31.7 million. Thus, the Company collected $33.6 million more during the interim period than it would have if final rates had been in effect. The summary of the interim and final revenue increases by rate class are provided in Exhibit A-1 (SAS-1). Q. Please explain how the interim and final revenue increases were determined. A. The interim revenue increase is the product of the self-implemented rates and the electric consumption for each service type and rate schedule. A summary of the interim increase and revenue by rate schedule is shown in column (c) and column (d) of Exhibit A-2 (SAS-2). The detailed calculation of the interim revenue by rate schedule is shown in column (d) of each page of Exhibit A-3 (SAS-3). The final revenue increase is the product of the change in rates and the billing determinants for each charge. The change in rates is based on the difference in final rates and the previously authorized rates in Case No. U A summary of the final increase and revenue by rate schedule is shown in column (e) and column (f) of Exhibit A-2 (SAS-2). The detailed calculation of the final revenue by rate schedule is shown in column (f) of each page of Exhibit A-3 (SAS-3). te0818-sas 6

15 S. AUSTIN SMITH DIRECT TESTIMONY Q. Please explain any assumptions or adjustments made in determining the interim or final revenue increases. A. The billing determinants were prorated for the months of October through May to align the final revenue that would have been collected with the interim revenue that was collected based on the dates when self-implemented rates were actually in effect. The approach to prorating the billing determinants is consistent with the method approved by the Commission in the Company s previous refund reconciliation filings in Case Nos. U-16191, U-16794, U-17087, U-17735, and U Q. Is a refund required based on the total revenue differences between interim and final rates? A. Yes, a refund to customers is required. Consistent with MCL 460.6a(1) and the Commission s August 10, 2010 Order in Case No. U-15645, the amount of any potential refund is based on the excess of total revenue produced by the interim rates as compared to final rates. Had the final rates authorized by the Commission in its July 24, 2018 Order Approving Revised Tariffs been in effect from October 1, 2017 to March 31, 2018, the Company would have collected $33.6 million less in total revenue than it did by using the self-implemented rates for this period. Since there was an over-collection by the Company during the time period that interim rates were in effect, a refund to customers is required. Therefore, the Company is proposing to refund $33.6 million plus interest in this case. te0818-sas 7

16 S. AUSTIN SMITH DIRECT TESTIMONY Q. How was interest calculated on the amount of the over-collected revenues proposed to be refunded to customers? A. Pursuant to the statute MCL 460.6a(2), the Company is required to pay interest to customers on the amount of the over-collection. The statute states: The rate of interest for refunds shall equal 5% plus the London interbank offered rate (LIBOR) for the appropriate time period. For any portion of the refund that, exclusive of interest, exceeds 25% of the annual revenue increase awarded by the commission in its final order, the rate of interest shall be the authorized rate of return on the common stock of the utility during the appropriate period. Q. Did any portion of the refund, exclusive of interest, exceed 25% of the annual revenue increase awarded by the Commission in its final order? A. Yes. Twenty-five percent of the Commission s July 24, 2018 approved rate increase of $72 million is approximately $18 million. Therefore, the Company is required to pay interest on $15 million ($33 million less the $18 million threshold) at the rate of return on the Company s common stock that was applicable during the self-implementation period, which was 10.1%. A detailed calculation of interest calculation is shown in Revised Exhibit A-4 (SAS-4). Q. Is the Company proposing any additional customer refunds or collections in this case? A. Yes. A net residual balance (over refunded) amount of $52,444 remains in Case No. U-18381, the reconciliation of the self-implemented rate increase in Case No. U from September 1, 2016 to March 6, The Company is proposing to integrate the remaining residual balances (for any single rate class) greater than $50,000 into its refund calculations in this instant case, as shown in Revised Exhibit A-5 (SAS-5), te0818-sas 8

17 S. AUSTIN SMITH DIRECT TESTIMONY column (d). Integrating these amounts will expedite the reconciliation of the residual balances for the final two electric rate cases where self-implemented rates were permitted and will provide administrative efficiency in rate changes and rate configuration. The detailed calculation of the over-collection from Case No. U is shown on Exhibit A-6 (SAS-6). Consistent with previously Commission-approved residual balance cases, interest for the remaining refund in U was calculated on residual balance amounts using the short-term borrowing rate. The Company s short-term interest rate was applied over a prospective fifteen-month period, to reflect the amount of interest due from the date of the original self-implementation refund through the proposed refund month of February Consistent with past practice, the Company proposes to forgo interest on any balance from rate classes where there was a revenue shortfall. The result of applying interest to the Case No. U residual balance is shown on Exhibit A-6 (SAS-6), column (e). Pursuant to the residual balance methodology approved in Case No. U-18381, any under or over-collections less than $50,000 for any single rate class will be written off by the Company. Q. How is the Company proposing to distribute the amount of the refund? A. The Company proposes to refund the $33.6 million plus interest to customers for rate classes where an over-collection occurred during the self-implementation period. The Company is proposing to implement the refund during the February 2019 bill month based on forecasted sales and forecasted customers as shown on Revised Exhibit A-5 (SAS-5) columns (f) and (g). Columns (h) and (i) of Revised Exhibit A-5 (SAS-5) show the refund surcharge amounts. Column (h) calculates a refund per customer, which is calculated by dividing the total refund amount in column (e) by the forecasted customers te0818-sas 9

18 S. AUSTIN SMITH DIRECT TESTIMONY in column (g). Column (i) is a refund per kwh which is calculated by dividing the total refund amount in column (e) by the forecasted sales in column (f). The proposed refund surcharge for each rate schedule is provided on the proposed tariff sheet found in Revised Exhibit A-7 (SAS-7). Q. Is the Company proposing any changes to the forecasted sales for purposes of this reconciliation? A. Yes, for Rate EIP only. The Company believes the current February 2019 sales forecast for Rate EIP is understated. Rate EIP has limited participation and the usage has fluctuated considerably. However, the Company s current February forecasted EIP usage is lower than the actual sales for the most recent months, and a new forecast is not expected to be final until October Therefore, the Company believes it is more appropriate to use EIP actual historic sales figures as a basis for calculating the refund surcharge to Rate EIP customers, which will help prevent an over-refund situation that would result in a later collection when reconciling any remaining residual balance. The Company proposes to use the EIP average monthly sales amount from the most recent eight months since self-implemented rates went into effect. For all other rate schedules, Company is proposing to use the current forecast. Q. How does the Company propose to address any remaining residual balances that result from the application of the surcharges as shown on Revised Exhibit A-5 (SAS-5) if approved by the Commission? A. If a residual balance exists that is less than $50,000, the amount shall be given to a charity chosen by the Company. If an under-collection occurred that is less than $50,000, the under-collection will be written off by the Company. If a residual balance exists te0818-sas 10

19 S. AUSTIN SMITH DIRECT TESTIMONY resulting from an under-collection that is greater than $50,000, surcharges will be calculated on a per customer basis and applied during a subsequent month until the residual balance is less than $50,000. If an over-collection occurred that is greater than $50,000, credits will be calculated on a per customer basis and applied during a subsequent month until the over-collection is less than $50,000. However, if the residual balance is less than $50,000, and any one rate schedule is over or under-collected by greater than $50,000, then additional surcharging or credits will be implemented for that particular rate schedule on a per customer basis, until the balance is less than $50,000 for that rate schedule. Q. Does this conclude your direct testimony? A. Yes. te0818-sas 11

20 S T A T E O F M I C H I G A N BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the matter of the application of ) CONSUMERS ENERGY COMPANY ) for an electric rate case self-implementation ) Case No. U reconciliation for Case No. U ) ) REVISED EXHIBITS OF S. AUSTIN SMITH ON BEHALF OF CONSUMERS ENERGY COMPANY August 2018

21 Exhibit No.: A-1 (SAS-1) U Reconciliation of Electric Interim Rate Increase Page: 1 of 1 Interim October 1, March 31, 2018 Summary of Interim and Final Revenue Increases by Rate Class (a) (b) (c) (d) Interim Final Difference Line No. Description Sales Increase Increase (c - b) (MWh) ($000) ($000) ($000) BUNDLED SERVICE 1 Residential Class 6,309,378 31,055 25,788 (5,267) 2 Secondary Class 3,558,871 15,716 14,436 (1,280) 3 Primary Class 6,338,180 17,347 (9,074) (26,421) 4 Lighting & Unmetered Class 118, ,893 1,236 5 GSG-2 35, (36) (107) 6 Total Bundled Service 16,360,425 64,846 33,007 (31,839) ROA SERVICE 7 Residential Class Secondary Class 107, Primary Class 1,717, (1,772) (2,129) 10 Total ROA Service 1,824, (1,267) (1,740) 11 Total Jurisdictional Service 18,185,396 65,319 31,740 (33,579)

22 Exhibit No.: A-2 (SAS-2) U Reconciliation of Electric Interim Rate Increase Page: 1 of 1 Interim October 1, March 31, 2018 Summary of Interim and Final Revenues by Rate Schedule (a) (b) (c) (d) (e) (f) (g) Interim Final Prior Rate Revenues Revenues Difference Line No. Description Sales Revenues Increase (b + c) Increase (b + e) (f - d) (MWh) ($000) ($000) ($000) ($000) ($000) ($000) BUNDLED SERVICE Residential Class 1 Standard Service RS 6,205, ,510 30, ,077 24, ,387 (5,690) 2 Time-of-Day Service RT 33,176 4, , , Residential Dynamic Pricing RDP 37,905 5, , , Residential Dynamic Pricing Rewards RDPR 28,411 3, , , Electric Vehicles REV 4, (15) 6 Class Subtotal 6,309, ,540 31, ,595 25, ,328 (5,267) Secondary Class 7 Energy-only Service GS 1,880, ,992 8, ,862 3, ,048 (5,814) 8 Demand Service GSD 1,678, ,691 6, ,537 11, ,071 4,534 9 Class Subtotal 3,558, ,683 15, ,399 14, ,119 (1,280) Primary Class 10 Energy-only Service GP VL 1 3, (28) 303 (40) 11 Energy-only Service GP VL 2 36,074 3, ,994 (334) 3,529 (465) 12 Energy-only Service GP VL 3 545,649 61,811 1,976 63,787 1,783 63,594 (193) 13 Demand Service GPD VL 1 1,760, ,039 4, ,652 (4,091) 116,948 (8,704) 14 Demand Service GPD VL 2 1,008,020 83,283 2,641 85,924 (5,513) 77,770 (8,154) 15 Demand Service GPD VL 3 2,141, ,264 5, ,875 1, ,655 (4,220) 16 Time of Use GPTU VL (11) 53 (13) 17 Time of Use GPTU VL 2 77,321 6, ,845 (1,056) 5,554 (1,291) 18 Time of Use GPTU VL 3 568,126 52,520 1,728 54,248 (1,108) 51,412 (2,836) 19 Energy Intensive Rate EIP VL 1 152,250 8, ,996 (136) 8,552 (444) 20 Energy Intensive Rate EIP VL 2 37,343 2, , ,380 (67) 21 Energy Intensive Rate EIP VL 3 7, Class Subtotal 6,338, ,318 17, ,665 (9,074) 535,244 (26,421) Lighting & Unmetered Class 23 Metered Lighting GML 3, Unmetered Lighting GUL 65,976 12, ,187 1,732 14,415 1, Unmetered Service GU 47,452 4, , , Unmetered Service GU-XL 1, (12) 357 (18) 27 Class Subtotal 118,442 17, ,344 1,893 19,580 1, GSG-2 35, (36) 244 (107) 29 Total Bundled Service 16,360,425 1,988,508 64,846 2,053,354 33,007 2,021,515 (31,839) ROA SERVICE Residential Class 30 Standard Service RS Time-of-Day Service RT Class Subtotal Secondary Class 33 Energy-only Service GS 11, (4) 34 Demand Service GSD 95,991 2, , , Class Subtotal 107,533 3, , , Primary Class 36 Energy-only Service GP 36, (76) 641 (83) 37 Demand Service GPD 1,680,895 13, ,548 (1,696) 11,502 (2,046) 38 Class Subtotal 1,717,438 13, ,272 (1,772) 12,143 (2,129) 39 Total ROA Service 1,824,971 17, ,852 (1,267) 16,112 (1,740) 40 Total Jurisdictional Service 18,185,396 2,005,887 65,319 2,071,206 31,740 2,037,627 (33,579)

23 Exhibit No.: A-3 (SAS-3) U Reconciliation of Electric Interim Rate Increase Page: 1 of 25 Calculation of Interim and Final Revenues in Detail Residential Class : Standard Service RS (a) (b) (c) (d) (e) (f) (g) Interim Rates Final Rates Difference Line No. Description Billing Determinants Rates Revenue Rates Revenue (f - d) (Quantity) (Units) ($/Unit) ($000) ($/Unit) ($000) ($000) BUNDLED SERVICE Power Supply Summer (June - Sept.) 1 First 600 kwh/mth MWh Excess kwh/mth MWh Peak Saver kwh/mth Mth (7.84) - (7.84) - - Winter (Oct. - May) 4 All kwh/mth 6,205,241 MWh , ,034 4,461 5 PSCR Factor 6,205,241 MWh Total Power Supply 582, ,034 4,461 7 Distribution kwh/mth 6,205,241 MWh , ,427 20,416 8 System Access 9,319,157 Mth , ,234-9 Total 358, ,661 20,416 Provisions 10 Senior Citizen RSC 2,037,289 Mth (3.50) (7,131) (3.50) (7,131) - 11 Income Assistance RIA 311,008 Mth (7.00) (2,177) (7.00) (2,177) - 12 Total Provisions (9,308) (9,308) - 13 Interim Surcharge 6,205,241 MWh , (30,567) 14 Total Bundled Service 962, ,387 (5,690) ROA SERVICE 15 Distribution kwh/mth - MWh System Access - Mth Total Provisions 18 Senior Citizen RSC - Mth (3.50) - (3.50) Income Assistance RIA - Mth (7.00) - (7.00) Life Support RLS - Mth Small Farm RSF - Mth Total Provisions Interim Surcharge - MWh Total ROA Service Total Bundled & ROA Service 962, ,387 (5,690)

24 Exhibit No.: A-3 (SAS-3) U Reconciliation of Electric Interim Rate Increase Page: 2 of 25 Calculation of Interim and Final Revenues in Detail Residential Class : Time-of-Day Service RT (a) (b) (c) (d) (e) (f) (g) Interim Rates Final Rates Difference Line No. Description Billing Determinants Rates Revenue Rates Revenue (f - d) (Quantity) (Units) ($/Unit) ($000) ($/Unit) ($000) ($000) BUNDLED SERVICE Power Supply Summer (June - Sept.) 1 On-peak kwh/mth MWh Off-peak kwh/mth MWh Winter (Oct. - May) 3 On-peak kwh/mth 7,289 MWh (3) 4 Off-peak kwh/mth 25,887 MWh , , PSCR Factor 33,176 MWh Total Power Supply 2,723 2, Distribution kwh/mth 33,176 MWh , , System Access 13,590 Mth Total 1,662 1, Provisions 10 Senior Citizen RSC 3,039 Mth (3.50) (11) (3.50) (11) - 11 Income Assistance RIA 396 Mth (7.00) (3) (7.00) (3) - 12 Total Provisions (14) (14) - 13 Interim Surcharge 33,176 MWh (140) 14 Total Bundled Service 4,511 4, ROA SERVICE 15 Distribution kwh/mth - MWh System Access - Mth Total Provisions 18 Senior Citizen RSC - Mth (3.50) - (3.50) Income Assistance RIA - Mth (7.00) - (7.00) Life Support RLS - Mth Small Farm RSF - Mth Total Provisions Interim Surcharge - MWh Total ROA Service Total Bundled & ROA Service 4,511 4,522 11

25 Exhibit No.: A-3 (SAS-3) U Reconciliation of Electric Interim Rate Increase Page: 3 of 25 Calculation of Interim and Final Revenues in Detail Residential Class : Electric Vehicle REV-1 (a) (b) (c) (d) (e) (f) (g) Interim Rates Final Rates Difference Line No. Description Billing Determinants Rates Revenue Rates Revenue (f - d) (Quantity) (Units) ($/Unit) ($000) ($/Unit) ($000) ($000) BUNDLED SERVICE Power Supply Summer (June - Sept.) 1 On-peak kwh/mth MWh Mid-peak kwh/mth MWh Off-peak kwh/mth MWh Winter (Oct. - May) 4 On-peak kwh/mth 2,071 MWh (12) 5 Off-peak kwh/mth 2,540 MWh PSCR Factor 4,611 MWh Total Power Supply (9) 8 Distribution kwh/mth 4,611 MWh System Access 4,218 Mth Total Interim Surcharge 4,611 MWh (21) 12 Total Bundled Service (15)

26 Exhibit No.: A-3 (SAS-3) U Reconciliation of Electric Interim Rate Increase Page: 4 of 25 Calculation of Interim and Final Revenues in Detail Residential Class : Electric Vehicle REV-2 (a) (b) (c) (d) (e) (f) (g) Interim Rates Final Rates Difference Line No. Description Billing Determinants Rates Revenue Rates Revenue (f - d) (Quantity) (Units) ($/Unit) ($000) ($/Unit) ($000) ($000) BUNDLED SERVICE Power Supply Summer (June - Sept.) 1 On-peak kwh/mth MWh Mid-peak kwh/mth MWh Off-peak kwh/mth MWh Winter (Oct. - May) 4 On-peak kwh/mth 10 MWh Off-peak kwh/mth 24 MWh PSCR Factor 34 MWh Total Power Supply Distribution kwh/mth 34 MWh Total Interim Surcharge 34 MWh Total Bundled Service 5 5 -

27 Exhibit No.: A-3 (SAS-3) U Reconciliation of Electric Interim Rate Increase Page: 5 of 25 Calculation of Interim and Final Revenues in Detail Residential Class: Residential Dynamic Pricing RDP (a) (b) (c) (d) (e) (f) (g) Line Billing Determinants Interim Proposed Difference No. Description Quantity Units Rates Revenue Rates Revenue Revenue $/unit $000 $/unit $000 $000 Bundled Service Power Supply Summer (June - Sept.) 1 Off-peak kwh/mth MWh $ $ - $ - 2 Mid-peak kwh/mth MWh On-peak kwh/mth MWh Critical-peak kwh/mth MWh Total Summer Power Supply Winter (Oct. - May) 6 Off-peak kwh/mth 37,851 MWh , , On-peak kwh/mth 54 MWh Total Winter Power Supply 37,905 2,944 3, Annual PSCR Factor kwh/mth 37,905 MWh Total Power Supply 2,944 3, Distribution kwh/mth 37,905 MWh , , System Access 49,908 Bills Provisions 12 Senior Citizen RSC 6,939 Bills (3.50) (24) (3.50) (24) - 13 Income Assistance RIA 1,309 Bills (7.00) (9) (7.00) (9) - 14 Total 2,106 2, Interim Surcharge 37,905 MWh (187) 15 Total Residential RDP $ 5,237 $ 5,565 $ 328

28 Exhibit No.: A-3 (SAS-3) U Reconciliation of Electric Interim Rate Increase Page: 6 of 25 Calculation of Interim and Final Revenues in Detail Residential Class: Residential Dynamic Pricing Rewards RDPR (a) (b) (c) (d) (e) (f) (g) Line Billing Determinants Interim Proposed Difference No. Description Quantity Units Rates Revenue Rates Revenue Revenue $/unit $000 $/unit $000 $000 Bundled Service Power Supply Summer (June - Sept.) 1 Off-peak kwh/mth MWh $ $ - $ - 2 Mid-peak kwh/mth MWh On-peak kwh/mth MWh Critical-peak kwh/mth MWh ( ) - ( ) Total Summer Power Supply Winter (Oct. - May) 6 Off-peak kwh/mth 28,391 MWh , , On-peak kwh/mth 20 MWh Total Winter Power Supply 28,411 2,353 2, Annual PSCR Factor kwh/mth 28,411 MWh Total Power Supply 2,353 2, Distribution kwh/mth 28,411 MWh , , System Access 38,175 Bills Provisions 13 Senior Citizen RSC 5,314 Bills (3.50) (19) (3.50) (19) - 14 Income Assistance RIA 1,495 Bills (7.00) (10) (7.00) (10) - 15 Total 1,580 1, Interim Surcharge 28,411 MWh (140) 17 Total Residential RDPR $ 4,073 $ 4,172 $ 99

29 Exhibit No.: A-3 (SAS-3) U Reconciliation of Electric Interim Rate Increase Page: 7 of 25 Calculation of Interim and Final Revenues in Detail Secondary Class : Energy-only Service GS (a) (b) (c) (d) (e) (f) (g) Interim Rates Final Rates Difference Line No. Description Billing Determinants Rates Revenue Rates Revenue (f - d) (Quantity) (Units) ($/Unit) ($000) ($/Unit) ($000) ($000) BUNDLED SERVICE Power Supply Summer (June - Sept.) 1 All kwh/mth MWh Winter (Oct. - May) 2 All kwh/mth 1,880,453 MWh , ,803 1,905 3 PSCR Factor 1,880,453 MWh Total Power Supply 172, ,803 1,905 5 Distribution kwh/mth 1,880,453 MWh , ,418 1,149 6 System Access 1,143,069 Mth , ,861-7 Total 102, ,279 1,149 Provisions Education GEI 8 Summer kwh/mth MWh ( ) - ( ) Winter kwh/mth 48,567 MWh ( ) (36) ( ) (34) 2 10 Total Provisions (36) (34) 2 11 Interim Surcharge 1,880,453 MWh , (8,870) 12 Total Bundled Service 283, ,048 (5,814) ROA SERVICE 13 Distribution kwh/mth 11,542 MWh System Access 628 Mth Total Provisions Education GEI 16 All kwh/mth 7,562 MWh ( ) (6) ( ) (5) 1 17 Total Provisions (6) (5) 1 18 Interim Surcharge 11,542 MWh (12) 19 Total ROA Service (4) 20 Total Bundled & ROA Service 284, ,550 (5,818)

30 Exhibit No.: A-3 (SAS-3) U Reconciliation of Electric Interim Rate Increase Page: 8 of 25 Calculation of Interim and Final Revenues in Detail Secondary Class : Demand Service GSD (a) (b) (c) (d) (e) (f) (g) Interim Rates Final Rates Difference Line No. Description Billing Determinants Rates Revenue Rates Revenue (f - d) (Quantity) (Units) ($/Unit) ($000) ($/Unit) ($000) ($000) BUNDLED SERVICE Power Supply Summer (June - Sept.) 1 Peak kw/mth MW All kwh/mth MWh Winter (Oct. - May) 3 Peak kw/mth 4,528 MW , ,638 10,414 4 All kwh/mth 1,678,418 MWh , ,622 (7,722) 5 PSCR Factor 1,678,418 MWh Total Power Supply 146, ,260 2,692 7 Peak kw/mth 4,528 MW , ,207-8 Distribution kwh/mth 1,678,418 MWh , ,112 8,689 9 System Access 118,421 Mth , , Total 59,183 67,872 8,689 Provisions Education GEI 11 Summer kwh/mth MWh ( ) - ( ) Winter kwh/mth 98,317 MWh ( ) (60) ( ) (61) (1) 13 Total Provisions (60) (61) (1) 14 Interim Surcharge 1,678,418 MWh , (6,846) 15 Total Bundled Service 212, ,071 4,534 ROA SERVICE 16 Peak kw/mth 256 MW Distribution kwh/mth 95,991 MWh , , System Access 2,912 Mth Total 2,971 3, Provisions Education GEI 20 All kwh/mth 1,815 MWh ( ) (1) ( ) (1) - 21 Total Provisions (1) (1) - 22 Interim Surcharge 95,991 MWh (104) 23 Total ROA Service 3,074 3, Total Bundled & ROA Service 215, ,538 4,927

31 Exhibit No.: A-3 (SAS-3) U Reconciliation of Electric Interim Rate Increase Page No.: 9 of 25 Calculation of Interim and Final Revenues in Detail Primary Class : Energy-only Service GP (Voltage Level 1) (a) (b) (c) (d) (e) (f) (g) Interim Rates Final Rates Difference Line No. Description Billing Determinants Rates Revenue Rates Revenue (f - d) (Quantity) (Units) ($/Unit) ($000) ($/Unit) ($000) ($000) BUNDLED SERVICE Power Supply Summer (June - Sept.) 1 All kwh/mth MWh Winter (Oct. - May) 2 All kwh/mth 3,291 MWh (23) 3 PSCR Factor 3,291 MWh Total Power Supply (23) 5 Distribution kwh/mth 3,291 MWh (5) 6 System Access 72 Mth Total (5) Provisions Education GEI 8 Summer kwh/mth - MWh ( ) - ( ) Winter kwh/mth MWh ( ) - ( ) Total Provisions Interim Surcharge 3,291 MWh (12) 12 Total Bundled Service (40) ROA SERVICE 13 Distribution kwh/mth - MWh System Access - Mth Total Provisions Education GEI 16 All kwh/mth - MWh ( ) - ( ) Total Provisions Interim Surcharge - MWh Total ROA Service Total Bundled & ROA Service (40)

32 Exhibit No.: A-3 (SAS-3) U Reconciliation of Electric Interim Rate Increase Page: 10 of 25 Calculation of Interim and Final Revenues in Detail Primary Class : Energy-only Service GP (Voltage Level 2) (a) (b) (c) (d) (e) (f) (g) Interim Rates Final Rates Difference Line No. Description Billing Determinants Rates Revenue Rates Revenue (f - d) (Quantity) (Units) ($/Unit) ($000) ($/Unit) ($000) ($000) BUNDLED SERVICE Power Supply Summer (June - Sept.) 1 All kwh/mth MWh Winter (Oct. - May) 2 All kwh/mth 36,074 MWh , ,109 (282) 3 PSCR Factor 36,074 MWh Total Power Supply 3,391 3,109 (282) 5 Distribution kwh/mth 36,074 MWh (52) 6 System Access 309 Mth Total (52) Provisions Education GEI 8 Summer kwh/mth - MWh ( ) - ( ) Winter kwh/mth - MWh ( ) - ( ) Total Provisions Interim Surcharge 36,074 MWh (131) 12 Total Bundled Service 3,994 3,529 (465) ROA SERVICE 13 Distribution kwh/mth 1,403 MWh (2) 14 System Access 12 Mth Total (2) Provisions Education GEI 16 All kwh/mth - MWh ( ) - ( ) Total Provisions Interim Surcharge 1,403 MWh Total ROA Service (2) 20 Total Bundled & ROA Service 4,012 3,545 (467)

33 Exhibit No.: A-3 (SAS-3) U Reconciliation of Electric Interim Rate Increase Page: 11 of 25 Calculation of Interim and Final Revenues in Detail Primary Class : Energy-only Service GP (Voltage Level 3) (a) (b) (c) (d) (e) (f) (g) Interim Rates Final Rates Difference Line No. Description Billing Determinants Rates Revenue Rates Revenue (f - d) (Quantity) (Units) ($/Unit) ($000) ($/Unit) ($000) ($000) BUNDLED SERVICE Power Supply Summer (June - Sept.) 1 All kwh/mth MWh Winter (Oct. - May) 2 All kwh/mth 545,649 MWh , ,244 2,929 3 PSCR Factor 545,649 MWh Total Power Supply 50,315 53,244 2,929 5 Distribution kwh/mth 545,649 MWh , ,411 (1,149) 6 System Access 9,814 Mth Total 11,541 10,392 (1,149) Provisions Education GEI 8 Summer kwh/mth MWh ( ) - ( ) Winter kwh/mth 80,021 MWh ( ) (45) ( ) (42) 3 10 Total Provisions (45) (42) 3 11 Interim Surcharge 545,649 MWh , (1,976) 12 Total Bundled Service 63,787 63,594 (193) ROA SERVICE 13 Distribution kwh/mth 35,140 MWh (74) 14 System Access 270 Mth Total (74) Provisions Education GEI 16 All kwh/mth 14,421 MWh ( ) (8) ( ) (8) - 17 Total Provisions (8) (8) - 18 Interim Surcharge 35,140 MWh (7) 19 Total ROA Service (81) 20 Total Bundled & ROA Service 64,493 64,219 (274)

34 Exhibit No.: A-3 (SAS-3) U Reconciliation of Electric Interim Rate Increase Page: 12 of 25 Calculation of Interim and Final Revenues in Detail Primary Class : Demand Service GPD (voltage level 1) (a) (b) (c) (d) (e) (f) (g) Interim Rates Final Rates Difference Line No. Description Billing Determinants Rates Revenue Rates Revenue (f - d) (Quantity) (Units) ($/Unit) ($000) ($/Unit) ($000) ($000) BUNDLED SERVICE Power Supply Summer (June - Sept.) 1 On-peak kw/mth MW On-peak kwh/mth MWh Off-peak kwh/mth MWh Winter (Oct. - May) - 4 On-peak kw/mth 2,852 MW , ,872-5 On-peak kwh/mth 408,036 MWh , ,819 (1,179) 6 Off-peak kwh/mth 1,352,547 MWh , ,652 (2,247) 7 PSCR Factor 1,760,583 MWh Total Power Supply 116, ,343 (3,426) 9 Maximum kw/mth 3,702 MW , ,554 (666) 10 System Access 267 Mth Total 4,273 3,607 (666) Provisions Education GEI 12 Summer kwh/mth MWh ( ) - ( ) Winter kwh/mth 7,687 MWh ( ) (3) ( ) (2) 1 Interruptible GI 14 Summer kw/mth MW (7.00) - (7.00) Winter kw/mth MW (6.00) - (6.00) Total Provisions (3) (2) 1 17 Interim Surcharge 1,760,583 MWh , (4,613) 18 Total Bundled Service 125, ,948 (8,704) ROA SERVICE 19 Maximum kw/mth 1,028 MW , (185) 20 System Access 77 Mth Total 1,187 1,002 (185) Provisions Education GEI 22 All kwh/mth 35,775 MWh ( ) (12) ( ) (11) 1 23 Total Provisions (12) (11) 1 24 Interim Surcharge 504,358 MWh (105) 25 Total ROA Service 1, (289) 26 Total Bundled & ROA Service 126, ,939 (8,993)