2 BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION. 8 Proceedings held in the above-entitled. 9 matter before Suzanne D. Sonneborn, Administrative

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1 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the matter, on the Commission's Own Motion, establishing the method and Case No. U- avoided cost calculation for Upper Peninsula Power Company to fully comply Volume with the Public Utilities Regulatory Policy Act of, USC 0 et seq. (Post Order) / CROSS-EXAMINATION Proceedings held in the above-entitled matter before Suzanne D. Sonneborn, Administrative Law Judge with MAHS, at the Michigan Public Service Commission, West Saginaw, Lake Superior Room, Lansing, Michigan, Thursday, November,, : a.m. APPEARANCES: SHERRI A. WELLMAN, ESQ. Miller Canfield Paddock & Stone One Michigan Avenue, Suite 00 Lansing, Michigan On behalf of Upper Peninsula Power Company MICHAEL J. ORRIS, Assistant Attorney General West Saginaw Highway, Floor Lansing, Michigan On behalf of Michigan Public Service Commission Staff REPORTED BY: Marie T. Schroeder, CSR-

2 I N D E X WITNESS PAGE AARON L. WALLIN Post-Order Testimony and Rebuttal Testimony bound in JULIE K. BALDWIN Direct Testimony bound in E X H I B I T S NUMBER DESCRIPTION MRKD OFRD RECD A- -year LMP Projection A- Tariff sheets S- REVISED Standard Offer Tariff

3 Lansing, Michigan Thursday, November, : a.m (Hearing resumed pursuant to Commission Order.) (Documents were marked for identification by the Court Reporter as Exhibits A-, A-, and Revised S-.) JUDGE SONNEBORN: Good morning. We are on the record. This is a continuation of a hearing in Case No. U- in which the Commission, in its September, Order, remanded this case and re-opened the record for the limited purpose of receiving additional evidence on the appropriate Locational Marginal Pricing forecast. May I have counsel present here please put your appearances on the record, beginning with Ms. Wellman. MS. WELLMAN: Sherri A. Wellman on behalf of Upper Peninsula Power Company. JUDGE SONNEBORN: Thank you. Good morning, Ms. Wellman. And Mr. Orris. MR. ORRIS: Good morning, your Honor. Michael Orris on behalf of the Public Service Commission

4 Staff. JUDGE SONNEBORN: Thank you. Good morning, Mr. Orris. And I did receive an yesterday from Margrethe Kearney on behalf of Environmental Law and Policy Center indicating that she would not be appearing today, and there was no objection by the parties. It is my understanding that by agreement of the parties all testimony will be bound into the record today without cross-examination of any witnesses. Ms. Wellman, you may proceed first. MS. WELLMAN: Thank you, your Honor. The Company would request that the post-order testimony and exhibit of Aaron L. Wallin, as well as the post-order rebuttal testimony and exhibit of Aaron L. Wallin be bound into the record. The post-order testimony consists of four pages, the rebuttal testimony consists of five pages. The exhibits have been marked by the Court Reporter as Exhibit A- and Exhibit A-. These exhibits the Company request be admitted into evidence. JUDGE SONNEBORN: Thank you, Ms. Wellman. Are there any objections to binding in Mr. Wallin's post-order direct and rebuttal testimony, and the admission of Exhibits A- and/or A-? MR. ORRIS: No, your Honor.

5 JUDGE SONNEBORN: All right. Hearing no objections, Mr. Wallin's prefiled post-order direct and rebuttal testimony are bound in the record, and his exhibits are admitted into evidence. (Testimony bound in.) - - -

6 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION * * * * In the matter, on the Commission s own motion, establishing the method and avoided cost calculation for ) ) UPPER PENINSULA POWER COMPANY to fully ) Case No. U- comply with the Public Utilities Regulatory Policy Act of, USC 0 et seq. ) ) POST-ORDER TESTIMONY AND EXHIBIT OF AARON L. WALLIN PART I QUALIFICATIONS // Q. Please state your name and business address. My name is Aaron L. Wallin. My business address is Upper Peninsula Power Company, Inc. ( UPPCO or the Company ), 0 Harbor Hills, Marquette, MI. I am the Manager of Power Supply and Resource Planning. Q. Are you the same Aaron Wallin who caused direct testimony to be filed on October,, and rebuttal testimony on February,, in this matter on behalf of UPPCO? A. Yes. PART II Purpose and Exhibit Q. What is the purpose of your rebuttal testimony? A. The purpose of my testimony is to support UPPCO s forecast of Locational Marginal Prices ( LMPs ) as directed by the Commission in its September, order.

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

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

9 A. The average annual LMPs, average annual on-peak LMPs, and annual average off-peak LMPs from through are presented in Exhibit A- (ALW-). The on-peak LMP for a - year contract term is estimated to be $./MWh while the off-peak LMP for a -year contract term is estimated to be $./MWh. For a -year contract term the onpeak LMP is estimated to be $./MWh while the off-peak LMP is estimated to be $./MWh. For a -year contract term, the on-peak LMP is estimated to be $./MWh while the off-peak LMP is estimated to be $./MWh. Finally, for a - year contract term, the on-peak LMP is estimated to be $0./MWh while the off-peak LMP is estimated to be $./MWh. Q. Does this complete your direct post-order testimony? A. Yes.

10 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION * * * * In the matter, on the Commission s own motion, establishing the method and avoided cost calculation for ) ) UPPER PENINSULA POWER COMPANY to fully ) Case No. U- comply with the Public Utilities Regulatory Policy Act of, USC 0 et seq. ) ) POST-ORDER REBUTTAL TESTIMONY OF AARON L. WALLIN PART I QUALIFICATIONS // Q. Please state your name and business address. My name is Aaron L. Wallin. My business address is Upper Peninsula Power Company ( UPPCO or the Company ), 0 Harbor Hills, Marquette, MI. I am UPPCO s Manager of Power Supply and Resource Planning. Q. Are you the same Aaron Wallin who caused direct testimony to be filed on October,, rebuttal testimony on February,, and post-order testimony on October, in this matter on behalf of UPPCO? A. Yes. PART II Purpose and Exhibit Q. What is the purpose of your post-order rebuttal testimony?

11 A. The purpose of my testimony is to respond to Staff s proposed standard offer tariff as sponsored by the direct testimony of Julie K. Baldwin in its post-order filing on October,. Q. As relevant to your testimony today, what did the Commission direct parties to do in its September, Order in this case? A. In its September, Order, the Commission directed parties to Case No. U- to file on or before October,, proposed locational marginal price ( LMP ) forecasts for UPPCO for years. The Commission also directed that parties shall at the same time file a proposed Standard Offer tariff that conforms to the findings in this order. Q. Did the Company comply with the Commission s September, Order directives? A. Yes. On October,, I caused to have filed post-order direct testimony regarding UPPCO s LMP -year forecast. UPPCO also filed tariff sheets reflective of the findings and rulings made by the Commission in its September, Order. I did not sponsor the tariff sheets in my testimony made on October,, as it was the Company s understanding that all contested issues regarding the contents of the tariff sheet had been decided in the September, Order. Q. Are you sponsoring an exhibit in connection with this post-order testimony? A. Yes, I am now sponsoring as Exhibit A- (ALW-) the Company s tariff sheets as filed on October,, which the Company believes conform to the findings of the September, Order.

12 Standard Offer Tariff Q. As part of her post-order filing, Ms. Baldwin sponsors Revised Exhibit S-. On page of her post-order direct testimony, Ms. Baldwin lists Staff s proposed revisions to the Standard Offer tariff as reflected in Revised Exhibit S-. UPPCO agree with these proposed changes? Does A. No, not all of them. UPPCO takes issue with the changes Ms. Baldwin identifies as numbers,, and. Q. Please explain? A. Per the Commission order on September,, parties were instructed to file a proposed standard offer tariff that conforms to the findings in the order. Ms. Baldwin states on page of her direct testimony that Item numbers,,, and were added as clarification based on my experience working on other avoided cost cases. UPPCO does not agree that these are simply clarification and is of the opinion that such revisions do not conform to, and go beyond, the findings in the Order as such issues were not previously addressed in this case. Q. Please specifically describe the issue with item. A. Ms. Baldwin asserts at page of her prefiled testimony that the addition of item will provide the QF an option to lock in the MISO method to calculate the Effective Load Carrying Capability and ZRCs in effect at the time the Standard Contract is executed for the term of the contract. UPPCO believes that this has the potential to unfairly compensate a QF at the expense of UPPCO s customers. For example, if a QF installs a MW solar facility, the first year of operations using MISO solar capacity credit of 0%,

13 0 UPPCO would receive. ZRCs that it could use to fulfill its planning reserve margin requirement ( PRMR ). In subsequent years, UPPCO only receives ZRCs equivalent to the year historical average output of the resource for hours ending,, and EST for the most recent June, July, and August. If the QF chooses to receive payment each year for the. ZRC but the output from the facility using the MISO -year average methodology does not at least equal. MWs then UPPCO s customers are paying for something that is not received. Q. Does MISO allow UPPCO to lock-in a methodology for determining the capacity credit it will receive for QF? A. No. UPPCO will receive ZRCs to fulfill its PRMR in accordance with the methodology in the Resource Adequacy Business Practice Manual. Q. How does UPPCO propose to compensate a QF for capacity? A. Contrary to Ms. Baldwin s proposal, UPPCO is proposing to only compensate a QF for the ZRCs that it is able to obtain using the MISO methodology applicable to the QF for the planning year. This is no different than how UPPCO would receive ZRCs if UPPCO installed the same technology as the QF. Q. Please describe the issue with items and. A. Ms. Baldwin asserts that Item has been added to establish a -day response time for the Company to provide a draft Standard Contract to the QF, and Item adds an early termination provision. UPPCO asserts that as these provisions/requirements were not addressed in the September, Order such are not in conformance with the Order and there is nothing in the record regarding the reasonableness of these provisions as

14 relating to UPPCO. Specifically, because UPPCO is a small operation with limited staff, establishing a day response deadline is not reasonable. Additionally, UPPCO believes that the early termination provision is too vague and may lead to increased time and costs associated with negotiations. It is UPPCO s opinion that it would be best to address any additional requirements two years from now in the next PURPA proceeding. It is at that time, that such proposed requirements could be assessed and based on UPPCO s actual experience. Q. Does this conclude your post-hearing rebuttal testimony? A. Yes. 0.\00-000

15 JUDGE SONNEBORN: And Mr. Orris, you may proceed on behalf of Staff. MR. ORRIS: Thank you, your Honor. At this time Staff would move to have admitted into evidence the qualifications and direct testimony of Julie K. Baldwin, dated October,, consisting of a cover sheet and six pages of qualifications, questions, and answers, plus a revised Exhibit S- consisting of five pages. JUDGE SONNEBORN: All right. Are there any objections to binding in Ms. Baldwin's post-order direct testimony and to the admission into the record of Revised Exhibit S-? Hearing none, Ms. Baldwin's prefiled post-order direct testimony is bound into the record, and Revised Exhibit S- is admitted into evidence. (Testimony bound in.) - - -

16 S T A T E OF M I C H I G A N BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION * * * * In the matter, on the Commission's own ) motion, establishing the method and ) avoided cost calculation for ) UPPER PENINSULA POWER COMPANY ) Case No. U- to fully comply with the Public Utility ) Regulatory Policies Act of, ) USC 0 et seq. ) ) QUALIFICATIONS AND DIRECT TESTIMONY OF JULIE K. BALDWIN MICHIGAN PUBLIC SERVICE COMMISSION October,

17 QUALIFICATIONS OF JULIE K. BALDWIN CASE NUMBER U- PART I Q. Please state your full name, business address and occupation. A. My name is Julie K. Baldwin, and my business address is West Saginaw Highway, Lansing, Michigan. I am employed by the Michigan Public Service Commission (MPSC) as the Manager of the Renewable Energy Section (Section) of the Electric Reliability Division. Q. Please describe your current responsibilities. A. I became Manager of the Renewable Energy Section in December. In addition to myself, the Section presently includes a staff of four professionals: two departmental analysts, an engineer and auditor. This Section was established in direct response to passage of Michigan s Clean, Renewable and Efficient Energy Act of 0 (0 PA ). In general, the Section provides Staff oversight and input to the Commission regarding all of the Commission s regulatory responsibilities for renewable energy. Q. Describe your educational and professional background. A. I graduated from Michigan State University in June with a Bachelor of Science Degree in Chemical Engineering. I was employed by TRC Environmental Consultants in Los Angeles, California from February to June and was involved in various air quality consulting projects. In July, I began my employment with the Michigan Public Service Commission as a Public Utilities Engineer working in the areas of Act natural gas contract pricing issues, natural gas and petroleum products pipeline certificates of public convenience and necessity, and monthly natural gas production reporting. I began working on electric and natural gas tariff

18 QUALIFICATIONS OF JULIE K. BALDWIN CASE NUMBER U- PART I administration in December 0 and in October 0 was transferred to the Rates and Tariff Section. My tariff administration responsibilities included reviewing all electric and natural gas tariff filings, reviewing Commission Orders to determine whether tariff filings were necessary, reviewing rate books to see if they met the requirements of U-00 (Administrative Regulations Prescribing the Filing Procedures for Rate Schedules, Rules and Regulations, Standard Forms and Contracts by Electric, Water, Steam and Gas Utilities), and serving as case coordinator for various ex parte electric and natural gas tariff-related cases filed with the Commission. In June 0, I attended an Electric Utility Consultants, Inc. (EUCI) course titled Introduction to Cost of Service Concepts and Techniques for Electric Utilities in Denver, Colorado. Shortly after the course, I was temporarily assigned as Executive Assistant to former Commission Chairman J. Peter Lark. I remained in that position until May 0. Next, I was assigned to what is now the Renewable Energy Section of the Electric Reliability Division. I was the lead engineer for matters pertaining to electric interconnections and net metering. My work responsibilities included developing and assisting in implementing rules for the 0 PA net metering program and electric utility interconnection, serving as case coordinator for net metering and electric utility interconnection formal complaint cases, resolving informal net metering and electric utility interconnection complaints and inquiries, and public education and outreach. Additional responsibilities included reviewing rates impacting distributed generation in utility rate cases, green pricing programs, and renewable energy

19 QUALIFICATIONS OF JULIE K. BALDWIN CASE NUMBER U- PART I contracts filed for approval with the Commission. During 0 and 0, I served as the Commission s representative and Secretary on the Wind Energy Resource Zone Board established by the Commission pursuant to 0 PA. Q. Have you previously filed testimony in proceedings before the Commission? A. Yes. During my work at the MPSC, I have filed testimony in the following cases: Case No. U- (Act natural gas contract pricing case) Various Act natural gas pipeline cases Case No. U- (Consumers Energy Electric Rate Case) Case No. U- (Detroit Edison Rate Case) Case No. U- (Consumers Energy Electric Rate Case) Case No. U- (Indiana Michigan Power Rate Case) Case No. U- (Detroit Edison Renewable Energy Reconciliation Case) Case No. U- (Consumers Energy Amended Renewable Energy Plan Case) Case No. U- (Detroit Edison Amended Renewable Energy Plan Case) Case No. U--R (Wisconsin Electric PSCR-R) Case No. U--R (Detroit Edison PSCR-R) Case No. U-0 (WEPCo Renewable Energy Plan Case) Case No. U- (WEPCo Renewable Energy Plan Case) Case No. U- (Consumers Energy Rate Case) Case No. U- (DTE Electric Rate Case) Case No. U- (UMERC Merger & Acquisition Case) Case No. U-0 (Consumers Energy Avoided Cost Case) Case No. U- (DTE Electric Avoided Cost Case)

20 QUALIFICATIONS OF JULIE K. BALDWIN CASE NUMBER U- PART I Case No. U- (Alpena Avoided Cost Case) Case No. U- (Indiana Michigan Power Avoided Cost Case) Case No. U- (Northern States Power Avoided Cost Case) Case No. U- (UPPCo Avoided Cost Case) Case No. U- & U- (WEPCo and UMERC Avoided Cost Case) Case No. U- (Consumers Energy Rate Case) Case No. U- (DTE Electric Rate Case)

21 DIRECT TESTIMONY OF JULIE K. BALDWIN CASE NUMBER U- PART II Q. What is the purpose of your testimony? A. The purpose of my testimony is to propose a revised Standard Offer tariff in accordance with the Commission s September, order in this case. Q. Are you filing any exhibits? A. Yes. I am filing the following exhibit: Revised Staff Exhibit S- Revised MPSC Staff Proposed Standard Offer Tariff STANDARD OFFER TARIFF Q. Please describe the changes to the Revised Standard Offer tariff filed as Revised Staff Exhibit S-. A. The following changes were made to the Revised Standard Offer tariff:. Clarified that the MW size cap for the Standard Offer is based on the AC rating of the project.. The qualifying facility (QF) now has two Rate Options for the Energy Rate: As Available Rate and LMP Energy Rate Forecast.. Added a reference to the line loss adjustment in the Energy Rate description.. The Fixed ICE element has been removed from the Energy Rate calculations.. The Contract Term section has been updated to reflect that the QF has a choice between a,,, and year contract.. The Capacity Payment has been updated to reflect the contract rates approved by the Commission and the application of Zonal Resource Credits (ZRCs).. A provision is added to provide the QF an option to lock in the MISO method to calculate Effective Load Carrying Capability and ZRCs in effect at the time the Standard Contract is executed for the term of the contract.. An Execution of Standard Contract provision has been added to provide for a -day response time for the Company to provide a draft Standard Contract to the QF.. A provision clarifying that the avoided cost rates will be reviewed by the Commission every two years was added.

22 DIRECT TESTIMONY OF JULIE K. BALDWIN CASE NUMBER U- PART II. An early termination provision was added.. Updated the reference to liability insurance and the Wisconsin Administrative Code to reflect Michigan s Electric Interconnection and Net Metering Standards. Q. Please explain the reason for the revisions on Revised Staff Exhibit S-. A. The changes numbered through and were made based on the Commission s order issued in this case on September,. Item numbers,, and were added as clarification based on my experience working on other avoided cost cases. Item was added to update a tariff reference from Wisconsin to Michigan. Q. Does this conclude your testimony? A. Yes.

23 0 JUDGE SONNEBORN: Pursuant to the Commission's September Order, a briefing schedule is to be set so briefs in this re-opened case are submitted to the Commission by December st. To this end, I propose that initial briefs be filed by November and reply briefs be filed by November 0. Ms. Wellman, is that an acceptable timeline for briefs? MS. WELLMAN: Yes, your Honor. JUDGE SONNEBORN: And you as well, Mr. Orris? Is that acceptable to you? MR. ORRIS: Yes, your Honor. JUDGE SONNEBORN: All right. Thank you. Is there anything further from anyone for the record? MR. ORRIS: No, your Honor. MS. WELLMAN: No, your Honor. JUDGE SONNEBORN: All right. I wish you both a warm Thanksgiving season, and we are adjourned. Thank you. (At :00 a.m., the record was closed.) - - -

24 C E R T I F I C A T E I, Marie T. Schroeder (CSR-), do hereby certify that I reported in stenotype the proceedings had in the within-entitled matter, that being Case No. U-, before Suzanne D. Sonneborn, Administrative Law Judge with MAHS, at the Michigan Public Service Commission, Lansing, Michigan, on Thursday, November, ; and do further certify that the foregoing transcript, consisting of Volume, Pages -, is a true and correct transcript of my stenotype notes. A Marie T. Schroeder, CSR- Notary Public, Oakland County Grand River Avenue Farmington, Michigan Dated: November,

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