S T A T E OF M I C H I G A N BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION * * * *

Transcription

1 S T A T E OF M I C H I G A N BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION * * * * In the matter of the application of ) DTE Electric Company for ) Reconciliation of its Power Supply ) Case No. U-7680-R Cost Recovery Plan for the -month ) Period ending December 3, 05 ) ) QUALIFICATIONS AND DIRECT TESTIMONY OF GRETCHEN M. WAGNER MICHIGAN PUBLIC SERVICE COMMISSION October 7, 06

2 QUALIFICATIONS OF GRETCHEN M. WAGNER CASE NUMBER U-7680-R PART I Q. Please state your name and business address. A. My name is Gretchen M. Wagner. My business address is 709 West Saginaw Hwy., Lansing, Michigan Q. By whom are you employed and in what capacity? A. I am employed by the Michigan Public Service Commission (MPSC or Commission) as an Auditor in the Act 304 Reconciliations Section of the Financial Analysis and Audit Division. Q. Please outline your educational background. A. I earned a Master of Science Degree in Accounting, with a Concentration in Taxation, from Michigan State University. I also earned a Bachelor of Arts Degree in Accounting from Michigan State University. Q. Please describe your professional background. A. In February 009, I accepted my position with the MPSC. Prior to my employment with the Commission, I was employed by Oakland University as an Internal Auditor and by Iannuzzi and Darling, LLC as a Field Auditor. While in school, I was employed by Maner, Costerisan & Ellis, P.C. as a Tax Intern and also by Charles K. Poor, CPA, P.C. as an Accountant. I have attended the Institute of Public Utilities (IPU) two week Annual Regulatory Studies Program at Michigan State University and I have attended various IPU Advanced Studies Sessions. I have also attended MPSC training sessions regarding rate-making issues. Q. Have you obtained any certificates?

3 QUALIFICATIONS OF GRETCHEN M. WAGNER CASE NUMBER U-7680-R PART I A. Yes. I obtained a Tier I Certificate of Continuing Regulatory Education in December 04, from the Institute of Public Utilities Regulatory Research and Education. Q. Briefly discuss your experience with the MPSC. A. I have served as the lead auditor, case coordinator, and/or performed audit work on numerous cases including: Power Supply Cost Recovery (PSCR) reconciliations, Gas Cost Recovery (GCR) reconciliations, Times Interest Earned Ratio (TIER) reconciliations, Uncollectible Expense True-up Mechanism (UETM) reconciliations, Enhanced Infrastructure Replacement Program (EIRP) reconciliations, Self-implementation Refund (SIR), Choice Incentive Mechanism (CIM), and General Rate cases. Q. Have you previously filed testimony before the MPSC? A. Yes, I have filed testimony in the following cases: Case Number Company Subject U-545-R SEMCO Energy GCR (MPSC) U-570-R SEMCO Energy GCR (MPSC) U-598 Wisconsin Electric Rate Case (taxes) U-646-R MichCon GCR U-647-R SEMCO Energy GCR (MPSC) U-647-R Ontonagon PSCR & TIER U-6447 MichCon SIR U-648-R MichCon GCR U R SEMCO Energy GCR (MPSC)

4 QUALIFICATIONS OF GRETCHEN M. WAGNER CASE NUMBER U-7680-R PART I U R SEMCO Energy GCR (BC) U-6830 Wisconsin Electric Rate Case (taxes) U-69-R DTE Gas Company GCR U-695 Detroit Edison CIM (Choice Incentive Mechanism) U-6999 MichCon Rate Case (Uncollectible Exp.) U-7097-R Detroit Edison PSCR U-73-R DTE Gas Company GCR U-733-R DTE Gas Company GCR 3

5 DIRECT TESTIMONY OF GRETCHEN M. WAGNER CASE NUMBER U-7680-R PART II Q. What is the purpose of your testimony? A. The purpose of my testimony is to present the MPSC Staff s (Staff) position on DTE Electric Company s (DTE Electric or the Company) cumulative Power Supply Cost Recovery (PSCR) reconciliation for the -month period ending December 05. Q. Are you sponsoring any exhibits in the proceeding? A. Yes, I am sponsoring the following exhibits: 8 Exhibit Title S- Power Supply Cost Recovery Calculation S- DTE Electric Answers in Case No. U-7663 S-3 Discovery Response STDE-3. S-4 Discovery Response STDE-3. Q. Were these exhibits prepared by you or under your direction? A. Yes. Q. Please explain Exhibit S-. A. Exhibit S- presents Staff s calculation of the total cumulative PSCR over recovery, with interest. The starting point for Staff s calculation was DTE Electric s Exhibit A-4. First, Staff verified the mathematical accuracy of the Company s exhibit. Staff made very minor layout changes to its Exhibit S- when compared to Exhibit A-4. Exhibit S- consists of two pages and incorporates Staff s adjustments to the PSCR calculation discussed below. Q. Did Staff make any adjustments to the Company s filed figures? A. Yes, Staff made one adjustment. 4

6 DIRECT TESTIMONY OF GRETCHEN M. WAGNER CASE NUMBER U-7680-R PART II Q. Please describe Staff s adjustment as shown on Exhibit S-. A. On July 4, 04, Severstal Dearborn, LLC (Severstal) filed a complaint against DTE Electric alleging that the utility overbilled it from February 008 to April 04. (See MPSC Case No. U-7663.) The Commission found in favor of Severstal and determined that it was entitled to a refund in the amount of $9,650,740, plus interest calculated at a 7% interest rate per annum, until the refund was paid in full. (MPSC Order Case No. U-7663, 7/9/5, p 0.) Staff removed this billing adjustment from its over/(under) recovery calculation on Exhibit S-, line 46, which resulted in an increase to the Company s filed over recovery. Q. If the Commission ordered a $9,650,740 refund (plus interest) in Case No. U- 7663, why did Staff only remove $3,450,30 from Exhibit S-, line 46? A. Staff only removed $3,450,30 from this case because that was the total amount included by the Company in its filing. The remainder of the $9,650,740 is due to other cases that were before the Commission during the period of the overbilling. Q. Why did Staff remove the Severstal adjustment? A. In Staff s opinion, the adjustment the Company is requesting in this case is the direct result of the Company s unreasonable and imprudent actions. The Commission has already reviewed and ruled on the Company s actions in Case No. U-7663, order dated July 9, 05. Q. What did the Commission order in Case No. U-7663? A. In its July 9, 05 order the Commission found that DTE Electric Company s billing statements to Severstal Dearborn, LLC, from February, 008 to March 5

7 DIRECT TESTIMONY OF GRETCHEN M. WAGNER CASE NUMBER U-7680-R PART II , 04, were calculated in error and that Severstal Dearborn, LLC. is entitled to a refund in the amount of $9.65 million plus interest calculated at a 7% interest per annum, until the refund is paid in full. Q. What additional information did Staff rely on to support its decision to remove the Severstal adjustment from this case? A Staff relied on Technical Standard for Electric Service Rule 603 (R Meters with transformers; post-installation inspection; exception) which states: meters with associated instrument transformers and phase shifting transformers shall be inspected to determine the proper operation and wiring connections. Inspections shall be made within 60 days after installation by a qualified person who, when possible, should be someone other than the original installer. All self-contained, socket-type meters are excluded from post-installation inspections, except that the original installation shall be inspected when the meter is installed. History: 983 AACS The Company in its Answer and Affirmative Defenses to the formal complaint of Severstal Dearborn, LLC. (Exhibit S-), in Case No. U-7663, stated on page 8: In further response to Paragraph 36, Respondent admits that DTE Electric s revenue meters at 400 Miller Road Substation 4A are subject to the inspection requirements of R , and that such inspection also requires inspection of associated instrument transformers including current transformers and potential transformers. However, DTE Electric admits that it did not make such inspections because Complainant refused 6

8 DIRECT TESTIMONY OF GRETCHEN M. WAGNER CASE NUMBER U-7680-R PART II to shut-down its plant operations which are required to allow inspection of the instrument transformers. In Staff s opinion, had the Company followed Rule 603, the error in the meter installation that led to the billing error would almost certainly have been corrected once the post installation meter inspection was completed. Q. Are there any other Technical Standards for Electric Service that would apply to the Severstal error? A. Yes. Technical Standards for Electric Service Rule 305 (R Meter multiplier) requires that if it is necessary to apply a multiplier to the meter registration, then the multiplier shall be displayed on the face of the meter. In Staff s opinion, the fact that the multiplier, which was incorrect, was displayed on the meter from the installation of the meter on January 3, 008 until the inspection of the meter on April, 04 (Exhibit S-3), then the qualified person who should have performed the post meter installation inspection, should have easily caught the error. As the Primary Metering Visual Inspection Standard Work Instructions, attached as Exhibit S-4 requires said person to check [t]he site information is documented to make sure the billing is correct and the correct metering hardware was supplied to the customer. (Exhibit S-4, p. ) Q. Why is this relevant? A. The amount the Company is attempting to recover in this case is the result of the Company not following the rules under which it is required to provide service, rules which, had they been followed, would have resulted in the error being corrected. In Staff s opinion, there is no better example of imprudent and 7

9 DIRECT TESTIMONY OF GRETCHEN M. WAGNER CASE NUMBER U-7680-R PART II unreasonable action than this. Allowing the Company to recover this amount would be rewarding them for these unreasonable and imprudent actions. Q. What is Staff s recommended over recovery for DTE Electric s 05 PSCR period? A. Staff recommends the Commission approve an over recovery of $9,57,496, including interest, to be used as the Company s beginning balance in its 06 PSCR Reconciliation. Q. Does this conclude your testimony? A. Yes, it does. 8

10 S T A T E OF M I C H I G A N BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION * * * * In the matter of the application of ) DTE Electric Company for ) Reconciliation of its Power Supply ) Case No. U-7680-R Cost Recovery Plan for the -month ) Period ending December 3, 05 ) ) EXHIBITS OF GRETCHEN M. WAGNER MICHIGAN PUBLIC SERVICE COMMISSION October 7, 06

11 Michigan Public Service Commission DTE Electric Company Case No.: U-7680-R 04 Monthly PSCR Reconciliation Witness: G. M. Wagner Monthly Over (Under) Recovery Exhibit: S- Page: of Line No. January February March April May June July August Total System Sales kwh 3,658,89,876 3,48,08,58 3,4,006,99 3,3,09,76 3,46,454,86 3,6,584,690 4,3,057,555 4,004,89,483 Adjustment for LCC, R0 Estimates to Actual kwh,93,44 (3,064,306) 6,369,57 (0,476,79) 0,558,698 (5,05,848) 8,743,757 6,008,493 3 Adjusted Total System Sales kwh 3,660,03,00 3,467,964, 3,48,376,446 3,0,543,483 3,483,03,54 3,67,53,84 4,3,80,3 4,00,97,976 4 Less Non PSCR Sales: 5 Unmetered kwh 35,780,639 4,4,59 34,590,05 3,553,875 8,7,573 6,846,49 6,056,844 8,670,759 6 Resale kwh D8 in Buyout kwh , ,565, ,689 8 R0 kwh 39,43,99 6,34,5 3,70,855,3,735 4,793,006 37,74,46 46,449,446 6,44,696 9 PSCR Sales kwh 3,485,008,46 3,300,507,405 3,60,896,458,948,757,873 3,3,947,945 3,45,944,67 3,955,79,59 3,88,60,83 0 Adjusted Sales (from line 3 above) kwh 3,660,03,00 3,467,964, 3,48,376,446 3,0,543,483 3,483,03,54 3,67,53,84 4,3,80,3 4,00,97,976 Less: Total Sales of Direct Assignment Customers kwh 39,43,99 6,34,5 3,889,963,3,735 4,793,006 37,74,46 50,04,876 6,95, Adjusted Total System Sales w/o Direct Assignments kwh 3,50,789,0 3,34,6,997 3,95,486,483,980,3,748 3,340,0,58 3,479,790,696 3,98,786,436 3,857,7, PSCR Allocation Factor Fuel Costs for Electric Generation $ 70,403,959 $ 84,057,658 $ 77,588,334 $ 74,8,787 $ 73,58,497 $ 84,703,444 $ 88,964,838 $ 86,85,34 9 Purchased and Net Interchange Power $ 3,59, $ 5,8,9 $ 3,555,348 $ 0,90,964 $ 7,87,36 $ 7,89,909 $,039,069 $ 9,886,7 0 Total Power Supply Expenses $ 0,995,07 $ 99,85,877 $ 09,43,68 $ 84,309,75 $ 90,445,633 $ 0,993,353 $ 0,003,907 $ 06,738,06 Less: Total Expenses of Direct Assignment Customers (3) $ 4,580,684 $ 4,88,068 $ 4,78,05 $ 3,349,09 $ 4,600,44 $ 4,0,07 $ 4,8,63 $ 4,93,78 Net Power Supply Expense $ 97,44,387 $ 94,403,809 $ 04,865,657 $ 80,960,660 $ 85,845,09 $ 97,79,8 $ 05,8,83 $ 0,805, Applicable PSCR Energy Expense $ 96,40,760 $ 93,4,64 $ 03,764,568 $ 80,0,477 $ 85,5,55 $ 97,038,88 $ 04,497,605 $ 0,05, Transmission Expense $,336,.89 $9,76,95.8 $0,783,0.66 $9,43,90.63 $3,835,799. $5,99,44.7 $3,607,84.94 $9,395, PSCR Transmission Allocation Factor Applicable PSCR Transmission Expense $,66,.60 $8,774,5.30 $9,766, $8,460,476. $,665,46.38 $4,749,368. $30,6,33.60 $7,993, Total Applicable PSCR Expense $ 7,686,983 $,06,757 $ 3,53,47 $ 98,56,954 $ 07,780,986 $,787,656 $ 34,758,937 $ 9,044, Base Cost (U-544) Mills/kWh Loss Multiplier (U-544) Base Cost including Multiplier Mills/kWh PSCR Sales (from line 0 above) kwh 3,485,008,46 3,300,507,405 3,60,896,458,948,757,873 3,3,947,945 3,45,944,67 3,955,79,59 3,88,60,83 36 Base Power Supply Revenues $ 6,349,377 $ 0,89,684 $ 08,867,46 $ 98,446,87 $ 0,57,634 $ 5,78,89 $ 3,064,7 $ 7,80, PSCR Factor Mills/kWh PSCR Revenues $ 9,065,73 $ 8,55,309 $ 8,43,3 $ 7,607,795 $ 8,544,86 $ 8,908,596 $ 0,05,78 $ 9,877, Total Revenues $ 5,45,090 $ 8,704,993 $ 7,80,359 $ 06,054,08 $ 9,6,460 $ 4,87,489 $ 4,70,505 $ 37,698, Monthly Over (Under) Recovery $ 7,78,07 $ 6,688,36 $ (6,5,4) $ 7,49,8 $,335,474 $,399,833 $ 7,5,568 $ 8,653,38 44 Over (Under) Recovery Beginning Balance () $ (,89,34) $ (5,0,34) $,587,00 $ (4,664,) $,87,07 $ 4,6,49 $ 6,56,34 $ 4,073, Adjustment: Case No. U-7763 Severstal Complaint () $ - 47 Over (Under) Recovery Ending Balance $ (5,0,34) $,587,00 $ (4,664,) $,87,07 $ 4,6,49 $ 6,56,34 $ 4,073,89 $ 3,77, Over (Under) Recovery Average Balance $ (8,965,87) $ (,757,6) $ (,538,555) $ (98,547) $ 8,494,754 $ 5,36,407 $ 0,38,08 $ 8,400, Annual Interest Rate (3) 0.40% 0.367% % % % % % % 5 Monthly Interest Rate Interest $ (,994) $ (59) $ (495) $ (88) $ 74,39 $ 34,4 $ 77,783 $ 48, Cumulative Over (Under) Recovery $ (5,04,8) $,583,479 $ (4,668,30) $,8,70 $ 4,3,53 $ 6,766,767 $ 4,456,8 $ 33,358,006 () -The Company included the portion of its Severstal adjustment from complaint Case No. U-7763, dated July 9, 05. The Company indicated that the $3,450,30 is the PSCR portion of the billing error from the Severstal Case. Staff removed this adjustment from its calculation of the over/(under) recovery recovery above on line 46. () -The Company included a beginning balance amount of ($,89,34), which is the ordered amount from U-739-R and was also used by Staff. (3) - The Company had an average under recovery for the months of January thru April and the short term interest rate was correctly applied by the Company. The Company had an average over recovery of the months of May thru December and the Company's ROE was correctly applied by the Company. It should be noted that the Company received an order in Rate Case No. U-7767 on December, 03, for service rendered on and after December 7, 05. The order changed the ROE from 0.5% to 0.3%. The Company correctly prorated the ROE and applied it to the December average over recovery.

12 Michigan Public Service Commission DTE Electric Company 04 Monthly PSCR Reconciliation Monthly Over (Under) Recovery Line No. Case No.: U-7680-R Witness: G. M. Wagner Exhibit: S- Page: of September October November December Total Input source Total System Sales kwh Adjustment for LCC, R0 Estimates to Actual kwh 3 Adjusted Total System Sales kwh 4 Less Non PSCR Sales: 5 Unmetered kwh 6 Resale kwh 7 D8 in Buyout kwh 8 R0 kwh 9 PSCR Sales kwh 0 Adjusted Sales (from line 3 above) kwh Less: Total Sales of Direct Assignment Customers kwh 3 4 Adjusted Total System Sales w/o Direct Assignments kwh 5 6 PSCR Allocation Factor 7 8 Fuel Costs for Electric Generation 9 Purchased and Net Interchange Power 0 Total Power Supply Expenses Less: Total Expenses of Direct Assignment Customers (3) Net Power Supply Expense 3 4 Applicable PSCR Energy Expense 5 6 Transmission Expense 7 PSCR Transmission Allocation Factor 8 Applicable PSCR Transmission Expense 9 30 Total Applicable PSCR Expense 3 3 Base Cost (U-544) Mills/kWh 33 Loss Multiplier (U-544) 34 Base Cost including Multiplier Mills/kWh 35 PSCR Sales (from line 0 above) kwh 36 Base Power Supply Revenues PSCR Factor Mills/kWh 39 PSCR Revenues 40 4 Total Revenues 4 43 Monthly Over (Under) Recovery 44 Over (Under) Recovery Beginning Balance () Adjustment: Case No. U-7763 Severstal Complaint () 47 Over (Under) Recovery Ending Balance Over (Under) Recovery Average Balance 50 Annual Interest Rate (3) 5 Monthly Interest Rate 5 Interest Cumulative Over (Under) Recovery 3,744,477,364 3,60,963,400 3,3,3,4 3,44,700,70 4,530,005,074 Exhibit A-4 (5,74,46) (9,837,054) (7,344,06) (574,87) (7,99,7) Exhibit A-4 3,79,30,948 3,5,6,346 3,95,888,395 3,44,5,443 4,5,075,947 Sum Lines - 3,9,84 34,767,455 35,57,767 38,587,48 393,30,560 Exhibit A Exhibit A-4 4,348, ,576,855 Exhibit A-4 47,68,377 37,430,78 0,034,95 9,378,75,634,37,033 Exhibit A-4 3,545,773,759 3,078,98,63 3,040,696,433 3,66,59,30 40,475,95,499 = Line 3 - Sum Lines 5-8 3,79,30,948 3,5,6,346 3,95,888,395 3,44,5,443 4,5,075,947 = Line 3 5,67,005 37,430,78 0,034,95 9,378,75,64,83,888 = Line 7 + Line 8 3,577,685,943 3,3,695,68 3,075,854,00 3,304,746,78 40,869,6,059 = Line - Line = Line 9 / Line 4 $ 69,489,476 $ 63,08,90 $ 6,608,584 $ 63,340,667 $ 897,468,479 Exhibit A-4 $ 40,34,559 $ 43,8,986 $ 33,370,004 $ 7,497,99 $ 308,79,948 Exhibit A-4 $ 09,64,035 $ 06,904,906 $ 94,978,588 $ 90,838,596 $,06,6,47 Sum Lines 8 & 9 $ 5,4,779 $ 3,93,465 $ 3,96,539 $,9,794 $ 50,83,346 Exhibit A-4 $ 04,499,56 $ 0,97,44 $ 9,78,050 $ 87,96,80 $,55,448,08 = Line 0 - Line $ 03,569,3 $ 0,89,50 $ 90,735,734 $ 86,898,059 $,44,55,907 = Line * Line 6 $8,74, $8,64,0.0 $9,067,64.39 $0,78, $ 79,765,55 Exhibit A = Line 9 / Line 3, rounded to 4 digits $7,30, $7,0,56.53 $8,40, $9,83, $ 66,404,7 = Line 6 * Line 7 $ 30,87,308 $ 9,00,666 $ 08,876,330 $ 06,7,45 $,40,660,079 = Line 4 + Line Exhibit A Exhibit A =Line 3 * Line 33 3,545,773,759 3,078,98,63 3,040,696,433 3,66,59,30 40,475,95,499 = Line 9 $ 8,378,068 $ 0,79,0 $ 0,55,78 $ 09,04,950 $,35,37,64 = Line 34 * Line 35 / Exhibit A-4 $ 9,48,096 $ 7,943,635 $ 7,844,997 $ 4,099,47 $ 00,74,80 Exhibit A-4 $ 7,56,64 $ 0,735,745 $ 09,360,75 $ 3,4,097 $,45,49,967 = Line 36 + Line 39 $ (3,345,44) $ (8,84,9) $ 484,385 $ 6,40,95 $ 40,83,888 = Line 4 - Line 30 $ 3,77,74 $ 9,38,3 $,097,0 $,58,595 = Prior month ending balance (Ln 47) $ 9,38,3 $,097,0 $,58,595 8,00,547 $ - Exhibit A-4, Page, line 45 $ = Lines $ 3,054,70 $ 5,39,670 $,339,40 $ 4,79,07 = (Line 44 + Line 47) / % % % 0.403% Exhibit A = Line 50 / $ 7,79 $ 0,847 $ 86,70 $ 4,9 $,54,950 = Line 49 * Line 5 $ 30,84,59 $,0,57 $,89,6 $ 9,57,496.8 $ 9,57,496 = Prior Mnt Cum Recovery + Ln 43 + Ln 5 + adj (if any)

13 Case No.: U-7680-R Witness: G.M. Wagner Exhibit: S-

14 Case No.: U-7680-R Witness: G.M. Wagner Exhibit: S-3 MPSC Case No.: U-7680-R Respondent: K. Tolios Requestor: Staff-3 Question No.: STDE-3. Page: of Question: In January 008, three revenue meters where installed in substation 4A. Did the Company display the multiplier on the face of the meter, as required by Rule 305 (R )? If so, what was the multiplier displayed? Answer: Yes. The multiplier on the face of the meters for sub 4A ( , & ) on February 9, 04, the initial investigation date, was PT=0: CT=400:; 0 x 400 = 48,000. This was the same multiplier that was on the face of the meter in January 008. Further, as detailed in the Company s briefs in Case No. U-7663, in essence the only matter in dispute in the Severstal (subsequently sold to AK Steel) case is the period of time during which DTE Electric calculated its bills for the energy used by AK Steel using a current transformer ( CT ) ratio of 400: when it should have been using a CT ratio of 300:. There was no dispute among the parties to this case that in February 04 the correct CT ratio to be used in the billing calculation for AK Steel was 300:. It is important to understand that the CTs that are connected to DTE Electric meters serving AK Steel are not owned or operated by DTE Electric. They are separate pieces of equipment owned, operated and therefore controlled by Severstal; AK Steel s predecessor in interest. When the DTE meters were connected to Severstal s CTs in 008, DTE Electric had to rely on the representations of the customer as to what the proper CT ratio was for the Severstal-owned equipment. Moreover, as admitted by AK Steel, the CT units now owned and operated by AK Steel are dual winding units that contain one set of windings with a CT ratio of 400: and one set of windings with a CT ratio of 300:. (Exhibit DE-3)

15 Case No.: U-7680-R Witness: G.M. Wagner Exhibit: S-4 Page of MPSC Case No.: U-7680-R Respondent: H. M. Zaidi Requestor: Staff-3 Question No.: STDE-3. Page: of Question: Answer: Rule 603 (R ) requires that meters with associated instrument transformers and phase shifting transformers shall be inspected to determine the proper operation and wiring connections. Please explain, in detail, what these post- installation inspections entail. DTE Electric follows the post-installations inspections set forth in the attached files. The file labeled U-7680-R, STDE-3.a Primary Metering Visual Inspection SWI is the current Electric Field Operations (EFO) SWI that explains the post-installation inspections by the EFO Primary Group to satisfy the requirements stated in MPSC Technical Standards for Electric Service Rule R Additionally, the file labeled U R, STDE-3.b Primary Group Checklist is the associated checklist used in the field by EFO.

16 Case No.: U-7680-R Witness: G.M. Wagner Exhibit: S-4 Page of Attachment U-7680-R STDE-3.a Primary Metering Visual Inspection SWI

17 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the matter of the application of DTE ELECTRIC COMPANY for reconciliation of its power supply cost recovery plan for the -month period ending December 3, 05. / Case No. U-7680-R (e-file paperless) STATE OF MICHIGAN ) ) ss COUNTY OF EATON ) PROOF OF SERVICE JENNIFER M. BROOKS, being first duly sworn, deposes and says that on October 7, 06, she served a true copy of the Testimony and Exhibits on behalf of the MPSC Staff upon the following parties via only: DTE Electric Company David S. Maquera Jon P. Christinidis DTE Energy One Energy Plaza, 688 WCB Detroit, MI 486 maquerad@dteenergy.com christinidisj@dteenergy.com mpscfilings@dteenergy.com Michigan Environmental Council Christopher M. Bzdok Olson, Bzdok & Howard 40 E. Front St. Traverse City, MI chris@envlaw.com karla@envlaw.com kimberly@envlaw.com

18 Attorney General Bill Schuette Celeste R. Gill Assistant Attorney General Environment, Natural Resources and Agriculture Div. G. Mennen Williams Bldg., 6 th Floor 545 W. Ottawa St.; P.O. Box Lansing, MI gillc@michigan.gov novakr@michigan.gov Administrative Law Judge Hon. Dennis W. Mack Administrative Law Judge Michigan Public Service Comm. 709 W. Saginaw Hwy., 3 rd Floor Lansing, MI 4897 mackd@michigan.gov Donna Mullinax Michael McGarry Dan Salter Tracy Klaes Blue Ridge Consulting Services 33 Wesley Way Hendersonville, NC 879 dmullinax@blueridgecs.com mmcgarry@blueridgecs.com dsalter@blueridgecs.com tklaes@blueridgecs.com Jennifer M. Brooks Subscribed and sworn to before me this 7th day of October, 06. Corinna C. Swafford, Notary Public State of Michigan, County of Ionia Acting in the County of Eaton My Commission Expires: -3-09