The following is attached for paperless electronic filing: The Michigan Environmental Council Replacement/Corrected Exhibit MEC-4.

Transcription

1 June 5, 2018 Ms. Kavita Kale Michigan Public Service Commission 7109 W. Saginaw Hwy. P. O. Box Lansing, MI Via E-Filing RE: MPSC Case No. U Dear Ms. Kale: The following is attached for paperless electronic filing: The Michigan Environmental Council Replacement/Corrected Exhibit MEC-4 Proof of Service Sincerely, Christopher M. Bzdok xc: Parties to Case No. U James Clift, MEC

2 Page 1 of 60 [2017 MAP] DTE Energy Renewable Energy (RE) Strategies for Corporate Customers Matthew Bandyk, MBA 2018 James Kwon, MBA 2018 Daniel Partin, MBA/MS 2019 Sean Pavlik, MBA/MS 2018

3 Page 2 of 60 Who We Are Matt Bandyk James Kwon Dan Partin Sean Pavlik BA, Political Science, Davidson College Ross MBA, 2018 Journalism Background Reporter on Electric Utility News, Natural Gas, Nuclear and Renewable Market Developments for SNL Financial BS, Civil Engineering, Yonsei University, South Korea Ross MBA, 2018 Construction Background Developed New Civil Infrastructure through Public-Private Partnership Arrangement BA, Foreign Affairs & Psychology, University of Virginia UM MBA/MS 2019 Tauber Institute for Global Operations Background in Defense- Intelligence Analysis and Strategic Assessments BA, Environmental Sciences, Northwestern UM MBA/MS, 2018 International Political & Business Background Summer 2016 Intern with Rocky Mountain Institute s Business Renewable Center 2

4 Page 3 of Defining the Problem 2. Analyzing Product Offerings 3. Providing a Solution 4. Looking Ahead 3

5 Page 4 of 60 Why We Are Here: Problem Statement Corporate customers around the country are demanding renewable energy contracts, including customers already in DTE s service area (GM), and a number of regulated utilities are already working to accommodate them. DTE could miss out on revenue from both current and potential customers by not further exploring green tariffs as a way to meet corporate renewable demand. 4

6 Page 5 of 60 Corporate Customer Demand Is Increasingly Driving Renewable Energy (RE) Development Each bar represents a specific corporate deal by capacity at the date of project announcement. The width of the bar represents the product capacity (e.g. GM 50MW). 71 F100 companies have a RE goal 22 F100 companies have committed to 100% RE Source : Emerging Green Tariffs in U.S regulated Electricity Market 3. Rocky Mountain Institute, Business Renewables Center 5

7 Page 6 of 60 GM is a Key C&I Customer for DTE with Numerous Renewable Energy Investments GM s History of RE procurement Global 114MW, 193 GWh of contracted wind, including Texas and Mexico PPA deals 24 solar sites worldwide Michigan Source : 6

8 Page 7 of 60 Corporate Customers Present Unique Opportunities and Challenges for DTE Opportunities Existing C&I customers Possibility to capture add l revenue Strengthen partnerships Improve DTE s overall public image New customers Increase potential to attract new load (e.g. data center company Switch/Consumers) Challenges/ Threats Behind-the-meter corporate actions (solar panels, LFG) could decrease load and revenue Corporates could push for legislative/regulatory changes to allow them to buy RE Other states will attract C&I customers due to already established tariff plans DTE misses out on efficiency gains due to high load factor of these customers 7

9 Page 8 of 60 GM Seeks Three Main Criteria in Sourcing RE Limited or No Price Premium Longer Term Offerings Additionality Requirements Establishing a 100 percent renewable energy goal helps us better serve society by reducing environmental impact...this pursuit of renewable energy benefits our customers and communities through cleaner air while strengthening our business through lower and more stable energy costs. - GM Chairman and CEO Mary Barra Source: 8

10 Page 9 of 60 MIGreenPower Launched on April 3 rd as DTE s Pilot Green Tariff for Multiple Customer Segments Underlying assets and target customers Capacity 150,000 MWh (0.35% of Load) Underlying RE asset Solar 50% + Wind 50% Target customer Residential 33% 1 C&I 67% 1 1. Note: Customer caps expire on December 31, 2017; any customer may sign up for available MWh after this date. ` Fee Structure Subscription charge $0.072 / kwh Credit MIGreenPower Energy Capacity $0.026 / kwh $0.014 / kwh $0.032 / kwh 9

11 Page 10 of 60 Such a premium will limit participation only to those few that are willing to pay an artificially high cost for resources that are now the cheapest generation options available. We would also like to see multiple offerings made available, including some that offer long-term fixed price schedules. Source: Corporate Purchasers Roundtable Comments, MIGreenPower MPSC Docket 10

12 Page 11 of 60 MIGreenPower s High Premium Likely Prevents Industrial Customers to Sign Up for the Program Premium per Subscribed kwh 2017 Tariff Rate 2017 Premium 1 Subscribed kwh Rate Premium per subscribed kwh 1 Limited or No Price Premium Residential % Commercial % Industrial % 2 3 Longer Term Offerings Additionality Requirements 11

13 Page 12 of Defining the Problem 2. Analyzing Product Offerings 3. Providing a Solution 4. Looking Ahead 12

14 Page 13 of 60 First, We Conducted Research and Interviews To Understand the Problem Customers and industry players Global Environmental Compliance & Sustainability Regulatory bodies Renewable Energy (Biz. Development, Wind PJT development, Finance control) Major Account Managers (GM, Quicken Loans) Electric Marketing (Strategy & Planning, Economic Development) Generation and Optimization Corporate Energy Forecasting Corporate Strategy Regulatory Compliance Subject matter experts 13

15 Page 14 of 60 There Has Been Significant Growth of Green Tariff Deployment in Recent Years Subscriber / Tariff WA MN Subscriber / Tariff Subscriber / Rider Subscriber / Rider NV UT CO Contract for Difference / Tariff Sleeved PPA / Tariff x 2 Subscriber / Rider NM Sleeved PPA / Rider VA NC Sleeved PPA / Rider Sleeved PPA / Rider : Green Tariff Deregulated Partial regulated Regulated Source : World Resources Institute 14

16 Page 15 of 60 Subscriber products (tariffs and riders) Users subscribe to a portion of RE capacity provided by a utility The utility locks in fixed subscriber rate for part or all of a corporate customer s RE needs, customers charged a rate that reflects wholesale pricing Sleeved PPA Output from long-term PPA with specific renewable energy generator is sleeved into utility s supply to customer Utility provides balancing services Contract for difference Customer pays difference between market-based rate and actual marginal costs of serving that customer 15

17 Page 16 of 60 We Compared the Three Tariff Types With DTE Internal Requirements & Preferences Asset Ownership Revenue Neutral/Positive No Cross-Subsidies Attractive to Customers Regulatory Ease 16

18 Page 17 of 60 Based on DTE Criteria, Subscriber Products (Tariff and Riders) Are Most Applicable Contract for Difference Sleeved PPA Subscriber Products 17

19 Page 18 of 60 Two Recent Subscriber Product Examples are Most Promising to DTE Puget Sound Energy (Wash.) Schedule 139 (Rider) Voluntary long-term RE purchase rider (10, 15, or 20-year schedule) 75 MW of wind sourced via a third-party PPA 10GWh minimum annual customer load or must be a government institution Similar to MIGreenPower structurally. However, escalating (not set) fixed charge Xcel Energy (Minn.) Renewable*Connect (Tariff) Tariff program replaces the current bill structure Three options: month-to-month, 5-year, and 10-year contracts RE offerings (50MW wind and 25MW solar) earmarked for and paid for by subscribers Costs include the LCOE, a capacity credit, administrative cost, and a neutrality adjustment to ensure non-subscribing customers are not impacted by the program 18

20 Page 19 of Defining the Problem 2. Analyzing Product Offerings 3. Providing a Solution A. MIGreenPower C&I B. Ross Tariff 4. Looking Ahead 19

21 Page 20 of 60 We Recommend Adjusting MIGreenPower Pilot to Better Suit C&I Customer Needs Option A: Rider - MIGreenPower C&I (Non-escalator and escalator) Structurally similar to current MIGreenPower: premium rate comprised of subscription fees partially offset by energy and capacity credits However, uses 100% wind generation to reduce premiums through lower LCOE costs Non-escalator (Non-ESC) More expensive upfront premium offset by the potential for long-term savings Benefits customers seeking a hedge against fuel price volatility Escalator (ESC) Maintains nearly flat revenue for DTE over the lifetime of the subscription Appealing to customers who value upfront savings and fixed costs 20 20

22 Page 21 of 60 We Identified Two Levers to Reduce the Rider Premium Charged to Corporate Customers MIGreenPower structure Levers for price adjustment Rider Subscription Charge LCOE Marketing & Administration 1 Underlying RE Asset Cost of generation (i.e. LCOE) MISO capacity credit Credit Energy Capacity 2 Targeting Customer Segments Subscription certainty (Attrition) Necessary additional effort (marketing and admin. cost) 21

23 Page 22 of 60 Lever 1 Alter the Underlying RE Asset Mix Using more wind generation will provide a net cost benefit, despite customers losing some capacity credit Positive for cost reduction Negative for cost reduction Solar Wind Result Installation Cost $1,470 / kw $1,537 / kw MISO Capacity Credit (% of Nameplate Capacity) Capacity Factor (Generation / Capacity) 52.6% 16.4% 14.5% 40.2% Capacity Credit LCOE $0.09 / kwh $0.05 / kwh Generation Profile (Avg. Day) Internal expertise of DTE (MW Deployed) Winter Summer Winter Summer 66 MW 490 MW Subscription Charge portion of LCOE 22

24 Page 23 of 60 Lever 2 Lower Cost to Acquire & Retain Customers Corporate customers typically have greater contract certainty, allowing for lower acquisition and retention costs MIGreenPower Target customer segment is mix of residential, commercial and industrial with a large number of subscribers Change Attrition Result MIGreenPower C&I Specific and predetermined corporate customers (i.e. GM) Marketing & administrative cost Subscription charge 23

25 Page 24 of 60 We Designed MIGreenPower C&I with These Two Levers in Mind, Resulting in Lower Premiums Assumptions Result in Year 1 MIGreenPower $0.032 MIGreenPower C&I $0.022 C&I - Original Impact Total Sub. Charge $0.072 $ $0.022 Positive Subscription Charge $0.070 $ $0.020 Positive Marketing & Admin $0.002 $ $0.002 Positive Credit $0.040 $ $0.012 Negative Energy $0.026 $0.026 $0.000 Neutral Capacity $0.014 $ $0.012 Negative Impact on Bill Standard Tariff Standard Tariff Rider Rider Total Charge per kwh $0.103 $0.093 Premium 45.07% 30.47% Premium rate over standard tariff 45% 30% MIGreenPower MIGreenPower C&I MIGreenPower C&I w/esc Ross Tariff 24

26 Page 25 of 60 We Can Lower Initial Premiums Even Further Through MIGreenPower C&I with Escalator Assumptions We set a 0% attrition rate We applied 30% of current marketing and administrative costs from MIGreenPower Adjustments We applied escalating charge in order to lower initial premium Rider rate 2.0% vs. Energy credit 3.2% Result in Year 1 MIGreenPower $0.032 MIGreenPower C&I $0.022 C&I with ESC $0.015 Total Sub. Charge $0.072 $0.050 $0.043 Subscription Charge $0.070 $0.050 Marketing & Admin $0.002 $0.000 Credit $0.040 $0.028 $0.028 Energy $0.026 $0.026 $0.026 Capacity $0.014 $0.003 $0.003 Impact on Bill Standard Tariff Standard Tariff Standard Tariff Rider Rider Rider Total Charge per kwh $0.103 $0.093 $0.086 Premium 45.07% 30.47% 20.52% 3.2 MIGreenPower 2.2 MIGreenPower C&I MIGreenPower C&I w/esc Premium rate 30% 20% Ross Tariff 25

27 Page 26 of 60 While Ensuring Same Present Value, the Initial Rider Premium Can Be Lowered Through Escalation DTE can avoid energy credits overtaking premium rates during the lifetime of an RE asset Original MIGreenPower imposes fixed subscription charge Subscription charge will increase by 2% ESC Rate ($/kwh) Energy credit portion will increase by 3.2% for both programs Year 26

28 Page 27 of 60 The Premium Over the Lifespan of MIGreenPower C&I with Escalator is Virtually Flat The smaller initial premium can attract customers, while DTE earns the same amount of revenue through the program s 20 year life Rate ($/kwh) Initial premium lowered from 30% to 20% Premium for customers is nearly flat Year 27

29 Page 28 of Defining the Problem 2. Analyzing Product Offerings 3. Providing a Solution A. MIGreenPower C&I B. Ross Tariff 4. Looking Ahead 28

30 Page 29 of 60 Ross Tariff is a Possible Long-Term Solution for C&I Customer Needs While Maintaining DTE Revenue Option B: Ross Tariff Tariff structure would replace the current contract of a corporate customer A tariff that matches a specific customer s load profile to a specific RE asset increases the efficiency of tariff charges and credits Rider (MIGreenPower C&I) Standard Tariff New Green Tariff (Ross Tariff) 29

31 Page 30 of 60 A Tariff Structure Allowed Us to Adjust a Third Lever: Operational Efficiency MIGreenPower structure Levers for price adjustment Rider Credit New Green Tariff (Ross Tariff) Subscription Charge LCOE Standard Tariff Marketing & Administration Energy Capacity Underlying RE Asset Target Customer Segment Operational Efficiency Cost of generation (i.e. LCOE) MISO capacity credit Subscription certainty (Attrition) Necessary additional effort (marketing and admin. cost) RE asset to serve a specific facility Maximize operational efficiency to provide greatest benefit to subscribers 30

32 Page 31 of 60 Operational Efficiency Addresses Mismatch Between Load and Generation During Peak and Non-Peak Times Simplified generation & demand profile for modeling Generation Demand 31

33 Page 32 of 60 Generation and Load Differential Drives the Calculation of Charges and Credits Under Ross Tariff Attribute DTE action Cost for DTE Charge to customers (1) RE Generation Consumed by GM (2) Excess RE generation over GM demand Sell to MISO LCOE + Transmission + Distribution LCOE + Transmission Cost for DTE Cost - Energy Credit Peak : Energy credit incentive (120% energy credit) Margin (Addition to ROE in LCOE) Minus Capacity Credit (3) Generation shortage Buy from MISO MISO price + Transmission + Distribution Standard tariff Peak : Peak Charge (120% standard tariff) 32

34 Page 33 of 60 Ross Tariff Provides The Greatest Opportunity for Premium Reduction Assumptions We used 100% wind to meet GM s annual load We ignored precise matching between wind generation & GM load We set a 0% attrition rate We applied 30% of current marketing and administrative costs from MIGreenPower Tariff Assumption Result in Year 1 MIGreenPower C&I $0.022 C&I with ESC $0.015 Ross Tariff $0.084 Total Sub. Charge $0.050 $0.043 $0.100 Subscription Charge $0.050 Marketing & Admin $0.000 Credit $0.028 $0.028 $0.015 Energy $0.026 $0.026 $0.013 Capacity $0.003 $0.003 $0.003 Impact on Bill Standard Tariff Standard Tariff Ross Tariff $0.084 Rider Rider Total Charge per kwh $0.093 $0.086 $0.084 Premium 30.47% 20.52% 18.63% Transmission cost 0.74/kWh Distribution cost 0.68/kWh Peak Charge 20% of standard tariff Premium rate 18% * Peak Incentive 20% of energy credit DTE margin 10% + ROE in LCOE MIGreenPower 33 MIGreenPower C&I MIGreenPower C&I w/esc Ross Tariff *Over Standard Tariff

35 Page 34 of 60 Ross Tariff Provides Lowest Premium to Customers While Providing DTE Increased Revenue Ross Tariff provides customers with a better hedge against fuel cost variability 34

36 Page 35 of 60 Overall Evaluation of Tariff Proposals MIGreenPower C&I MIGreenPower C&I with ESC Ross Tariff Pros Builds off existing pilot rider structure (easy to adopt) More competitive premium compared with existing pilot More competitive initial premium compared with C&I without ESC Prevents credits from crossing over charges Allows for more flexible term options Most competitive premium More cost effective for C&I customers over time Easier additionality claim for C&I customers Cons May not reduce premium enough to be attractive Does not incorporate solar No long-term savings for C&I customers Escalation is new consideration for MPSC Lower DTE revenue generation than rider options New structure to DTE/Michigan Involves more data analysis to construct 35 35

37 Page 36 of Defining the Problem 2. Analyzing Product Offerings 3. Providing a Solution 4. Looking Ahead 36

38 Page 37 of 60 How to expand to other customers beyond GM? Customers could subscribe to varying amounts of capacity of a wind farm, based on the amount of average load expected for each customer DTE planning 675 MW of wind power already could pursue subscriber projects on top of this capacity Already planned projects meet RPS, while subscriber projects satisfy corporate additionality goals DTE could set floors or ceilings on subscription size Xcel Renewable*Connect said no more than 10% of available MWh can be subscribed Available only to those who want to purchase 1 million or more kwh of green energy 37

39 Page 38 of 60 Additionally, It's Important to Consider Challenges to Green Tariff Implementation Convincing customers to subscribe to program (in case of Dominion VA green tariff, corporates found it too expensive) If green tariffs become industry standard, then there could be little competitive advantage for attracting new customers 38 Source:

40 Page 39 of 60 After careful thought and analysis over many months, [MGM has] concluded our objectives are best met by purchasing the energy required to operate our resorts, and serve our customers and guests, from a source other than NV Energy. Las Vegas Review-Journal, May 19, 2016 How to avoid this fate? Offer premium low enough to make it worth sticking with utility Offer long-term, fixed-price contracts to allow for hedging certainty Customer choice of assets Source: 39

41 Page 40 of 60 or DTE Can Work Together with Its C&I Customers to Find the Viable Path Forward We also expect to meet the goal through green tariffs working with our utility partners to allow customers greater access to source electricity from renewable sources. Director of Sustainability David Tulauskas Source: 40

42 41 U June 5, 2018 Page 41 of 60

43 Page 42 of 60 Appendix 42

44 Page 43 of 60 How Do Green Tariffs Deal with Cross-Subsidization? Different utilities have taken different measures to show to regulators that non-tariff customers will not be charged more as a result of the green tariff New Mexico: Utility buys RECs at customer expense to cover excess usage and also customer pays a fixed charge for times when it is served by traditional utility supply North Carolina: PPA considered to displace other energy, lowering fuel and fuel-related costs. Duke allocates those cost-savings to customers not on the green tariff through a bill adjustment. Also, rider bills customer for total cost of renewable energy procured Virginia: Two-month true-up period for renewable supply to cover deficiencies Subscription lengths vary, but typically long-term contracts with early termination fees 43

45 Page 44 of 60 How Do Utilities Deal with Generation/Load Mismatch? Minnesota Xcel Energy said there will never be an exact match but that it will track production, and on a monthly basis balance any surplus/shortfall from the target 50 MW wind/25 MW solar with output from two new wind and solar projects otherwise not part of the subscriber product New Mexico To greatest extent possible the customer s power comes from new renewable resources, but tariff allows for traditional supply to fill gaps when necessary 44

46 Page 45 of 60 Avoiding Subsidization Rider structured the same as MIGreenPower, so avoids subsidization in the same way Tariff Our peak charge bills the customer for times when renewable energy does not cover facility load 45

47 Page 46 of 60 There are Two Distinct Corporate Customer Groups for DTE to Evaluate Existing C&I customers New customers Other Mfg 11% Steel 8% Auto 17% Industry 9,918 GWh Commercial 17,262 GWh Comm Secondary 38% Data centers Comm Primary 26% Source : Sales Forecast data (2016) Greenhouses 46

48 Page 47 of 60 June 2016 PwC Survey on Corporate RE Procurement Drivers of intent to purchase RE Drivers for lack of intent Source : Corporate Renewable Energy Survey (PwC, June 2016) 47

49 Page 48 of 60 Recent Green Tariffs Exhibit a Variety of Possible Structures and Active Utilities Green Tariffs in regulated markets (10 tariffs in 8 states excluding MI) State Electric Market Utility Type 1 Type 2 Colorado Regulated Xcel Energy Rider Subscriber Product Minnesota Regulated Xcel Energy Pilot Tariff Subscriber Product Nevada Deregulated for some commercial & industrial consumers NV Energy Rider Subscriber Product New Mexico Regulated PNM Rider Sleeved PPA North Carolina Regulated Duke Energy Rider Sleeved PPA Utah Regulated RMP Tariff (2) Sleeved PPA Virginia Virginia Deregulated for some commercial & industrial consumers Deregulated for some commercial & industrial consumers Dominion Virginia Power Tariff Contract for Difference Dominion Virginia Power Rider Sleeved PPA Washington Regulated Puget Sound Energy Tariff Subscriber Product 48

50 Page 49 of 60 Green Tariff #1: Subscriber Output Key Characteristics Users subscribe to a portion of RE capacity provided by a utility - Utilities can either directly own RE production (XCEL s Renewable*Connect in Minnesota) or contract RE from third party producers (PSE Voluntary Renewable Energy Tariff in Washington) The utility locks in fixed subscriber rate for part or all of a corporate customer s RE needs, provided within the allowable subscription limit Fixed rate typically replaces existing subscription rates (tariff version) - Often rate is at least partially offset by credits for avoided costs associated with RE Subscription lengths vary, but typically long-term contracts with early termination fees 49

51 Page 50 of 60 Green Tariff #1: Subscriber Output Pros & Cons Aggregation of subscribers allows for participation by smaller companies Pros Long-term contracts allow for sustained and predictable revenue Attractive to companies seeking stable/predictable energy costs Examples to date have been limited in capacity (75MW max) Cons Long-term cost effectiveness for corporate customers dependent on fuel cost variability When formatted as a rider, adds premium cost for RE (MIGreenPower) 50

52 Page 51 of 60 Green Tariff #2: Sleeved PPAs Key Characteristics Utility acts as sleeve between customers and renewable energy generator. Output from long-term PPA is sleeved into utility s supply to customer. Not necessarily RE from an outside party: New Mexico PPA with non-regulated PNM affiliate In some cases gives customer choice of source Often includes provision that renewable energy source must be new and not already part of utility s supply, thus helping customers meet additionality requirements 51

53 Page 52 of 60 Green Tariff #2: Sleeved PPAs Pros & Cons Load factor improvements if data center subscribes Pros Deals with problem of intermittency and costs being passed to other customers Clear additionality: utility contracts with new renewable resources Cons Unclear if can be offered as a non-premium product 52

54 Page 53 of 60 Green Tariff #3: Contract for Difference Key characteristics 53

55 Page 54 of 60 Green Tariff #3: Contract for Difference Pros & Cons Enhances ability to attract high-value customers Pros Load factor improvements if data center subscribes Can dissuade customers from looking at third party energy Novel for regulated states Cons Limited appeal for many customers they must be risk-taking May encourage some customers to self-generate more 54

56 Page 55 of 60 The Renewable Energy Buyers Principles Indicate Corporate Preferences for RE Deals Greater choice in procurement options More access to cost competitive options Longer and variable-term contracts Access to new projects Standardized and simplified financial vehicles Cooperation with utilities and regulators Source : Creating Renewable Energy Opportunities (June 2016) 55

57 Page 56 of 60 Corporate Customers May View Various Green Tariff Options Based on the Buyers Principles Sleeved PPA Positive Negative Positive Positive Neutral Positive Subscriber Tariff Negative Neutral Positive Negative Positive Negative Contract for Difference Neutral Positive* Negative Neutral Negative Neutral *Most competitive in deregulated states 56

58 Page 57 of 60 Green Tariff Options Have Varying Implications for DTE s Operations System-wide impact Potential customer view (Based on Buyers Principles) Sleeved PPA Negative Neutral? Positive? Subscriber Tariff Positive Positive? Neutral? Contract for Difference Neutral Negative Positive Negative? 57

59 Page 58 of 60 New Tariff Incorporates DTE s Operational Characteristics Current operation characteristics Renewable Energy Asset DTE Own Asset Sell all the energy generated by DTE s own assets and provided from contractors Third Party Developer Customers 58

60 Page 59 of 60

61 Page 60 of 60 Effect of Solar Energy Total Load 60

62 STATE OF MICHIGAN MICHIGAN PUBLIC SERVICE COMMISSION In the matter on the Commission s own motion, regarding the regulatory reviews, revisions, determinations and/or approvals necessary for DTE ELECTRIC COMPANY to comply with Section 61 of 2016 PA 342 Case N o. U ALJ Martin D. Snider PROOF OF SERVICE On the date below, an electronic copy of the Michigan Environmental Council s REPLACEMENT/CORRECTED Exhibit MEC-4 was served on the following: Name/Party Administrative Law Judge Martin D. Snider Counsel for DTE Electric Company Andrea Hayden Counsel for Michigan Energy Innovation Business Council, Institute for Energy Innovation, Advanced Energy Economy, and Energy Michigan, Inc. Timothy J. Lundgren Laura A. Chappelle Toni L. Newell Counsel for MPSC Staff Amit T. Singh Counsel for Environmental Law & Policy Center Margrethe Kearney Rachel Granneman Address sniderm@michigan.gov mpscfilings@dteenergy.com andrea.hayden@dteenergy.com tjlundgren@varnumlaw.com lachappelle@varnumlaw.com tlnewell@varnumlaw.com singha9@michigan.gov mkearney@elpc.org rgranneman@elpc.org The statements above are true to the best of my knowledge, information and belief. OLSON, BZDOK & HOWARD, P.C. Counsel for MEC Date: June 5, 2018 By: Kimberly Flynn, Legal Assistant Karla Gerds, Legal Assistant 420 E. Front St. Traverse City, MI Phone: 231/ kimberly@envlaw.com and karla@envlaw.com