The following is attached for paperless electronic filing: Sincerely,

Transcription

1 November, 0 Ms. Kavita Kale Michigan Public Service Commission 0 W. Saginaw Hwy. P. O. Box 0 Lansing, MI 0 Via E-filing RE: MPSC Case No. U-0 Dear Ms. Kale: The following is attached for paperless electronic filing: Rebuttal Testimony of Tyler Comings on behalf of Michigan Environmental Council, Natural Resources Defense Council and Sierra Club Exhibits MEC- through MEC- Proof of Service Sincerely, Lydia Barbash-Riley lydia@envlaw.com xc: Parties to Case No. U-0 James Clift, MEC Shannon Fisk, Earthjustice Michael Soules, Earthjustice riana Gonzalez, NRDC Elena Saxonhouse, Sierra Club

2 STTE OF MICHIGN BEFORE THE MICHIGN PUBLIC SERVICE COMMISSION In the matter of the application of Consumers Energy Company for pproval of an Integrated Resource Plan under MCL 0.t and for other relief. Case No. U-0 LJ Sharon L. Feldman Rebuttal Testimony of Tyler Comings On Behalf of Michigan Environmental Council, Natural Resources Defense Council, and Sierra Club November, 0

3 TBLE OF CONTENTS. INTRODUCTION, ULIFICTIONS, ND PURPOSE OF TESTIMONY.... RETIREMENT OF KRN & IN RECOMMENDTIONS... ii

4 U-0-November, 0 Page of. INTRODUCTION, ULIFICTIONS, ND PURPOSE OF TESTIMONY Please state your name, business address, and position. My name is Tyler Comings. I am a Senior Researcher at pplied Economics Clinic, located at Teele venue, Somerville, Massachusetts. re you the same Tyler Comings that filed direct testimony in this case on October, 0? Yes. 0 What is the purpose of your rebuttal testimony? My testimony rebuts portions of the direct testimony of MCV witness Emily Medine, BTE witness Jeffry Pollock, and ttorney General (G) witness Sebastian Coppola. I focus on these parties arguments with the Company s decision to retire Karn Units and in 0. 0 What specific points do you rebut for these witnesses? In my testimony, I show the following key points:. Ms. Medine, Mr. Pollock and Mr. Coppola rely on the Company s initial coal retirement analysis and related statements by the Company in concluding that 0 retirement of Karn Units and has not been supported. However, the Company s initial analysis contained a significant error, namely, not escalating coal prices after 0. s a result, the Company s initial analysis assumed coal prices that were too low. The Company s corrected analysis showed more savings from 0 retirement of the coal units. Direct Testimony of Sebastian Coppola, p., lines 0-; Direct Testimony of Jeffry Pollock, p., lines -; Direct Testimony of Emily Medine, p., lines -. Exhibit MEC- (Response to 0-MEC-CE- (Partial) (Revised), STRTEGIST NPV RESULTS 0 IRP CapPrice Sens_Coal_Reruns NPV Chart Data_coal_rerun tab only).

5 U-0-November, 0 Page of 0 0. Ms. Medine claims that the Company should have also considered the nnual Energy Outlook (EO) natural gas prices in its retirement analysis. However, the Company did just that and found more savings from 0 retirement of the units under these prices than under the Consumers (CE) gas prices.. Mr. Pollock focuses on the Company s uncorrected retirement analysis and mischaracterizes the results in his testimony.. Mr. Coppola s discussion of compliance costs for Clean Water ct Section (b) is misleading and his dollar figure is inaccurate. He claims that the Company could reduce spending on (b) but he cites a dollar figure from the Company that assumes no spending at all for compliance. lso, because he did not adjust for the spending in the units last year of operation properly, his dollar value is incorrect. Finally, his dollar value is in terms of nominal (i.e., undiscounted) dollars instead of the net present value. fter adjusting for the error in the last year of operation, his claim of $0 million in reduced costs is actually $. million in 0 net present value (or $. in terms of 0 NPV).. Ms. Medine mentions unrecovered plant balance of Karn Units and. The treatment of these costs is a separate issue from retirement as they are sunk costs assuming the Company gets full recovery of the book value regardless of the retirement year. re you sponsoring any exhibits in this proceeding? Yes, I am sponsoring the following exhibits: MEC- Response to U-0-MEC-CE- (Partial) (Revised), Strategist NPV RESULTS IRP Cap Price Sens_Coal_Reruns-Exhibits tab Medine Direct, p., lines -. Exhibit MEC- (Response to 0-MEC-CE- (Partial) (Revised), STRTEGIST NPV RESULTS 0 IRP CapPrice Sens_Coal_Reruns Exhibits tab only).

6 U-0-November, 0 Page of MEC-0 Response to U-0-MCV-CE- MEC- Response to U-0-G-CE-, G-CE- avoided (b) capital expenditure. RETIREMENT OF KRN & IN 0 0 Do other parties claim that the Company has not justified its decision to retire Karn Units and in 0? Yes. MCV witness Emily Medine, BTE witness Jeffry Pollock, and G witness Sebastian Coppola all question the Company s decision to retire these units in 0. They all claim that the Company s analysis does not justify this decision: Ms. Medine states that: The Company has not demonstrated that early retirement of Karn & is justified. She also cites the Company s statement that the results of its modeling do not clearly favor early retirement. Mr. Pollock cites the same statement made by the Company as cited by Ms. Medine. He states that: There are no compelling reasons to retire Karn Units and prior to their design lives. Mr. Coppola cites the Company s statements of 0 retirement being nearly break-even and echoes this conclusion throughout. Medine Direct, p., lines -. Medine Direct, p., lines - (quoting page of Consumers pplication). Pollock Direct, p., lines -. Pollock Direct, p., lines -. Coppola Direct, p., line.

7 U-0-November, 0 Page of 0 Do these witnesses rely on the Company s initial analysis which contained a key error? Yes. These witnesses rely on the Company s initial analysis and its conclusions from that analysis such as the statement that this analysis did not clearly favor... early retirement. 0 However, in that initial analysis, the Company failed to escalate coal prices after 0. That error led this analysis and the Company s conclusions to be biased towards the 0 retirement scenario in comparison to the 0 scenario. The witnesses addressed the coal price error in the following ways: Ms. Medine never mentions the error. Mr. Pollock never mentions the error and presents figures in his testimony that include the error. Mr. Coppola mentions the error, but still presents the initial results in this testimony, which contain that error. These three witnesses either ignored the error completely or failed to present corrected results. In either case, they rely on an analysis with a critical error in making their assessments of the retirement decision. 0 Did the correction of that error lead to a more compelling argument for retiring the units? Yes. In my direct testimony, I showed that the Company s correction increased savings for 0 or 0 retirement of Karn Units and by $ million. The total (corrected) savings from 0 and 0 retirement of these units was $ million and $ million, respectively. Under a more reasonable capacity price, these savings increased even further to $0 million and $0 million, 0 Consumers pplication, p.. Comings Direct, p., Table. These results are under the Company s BU, including its own gas price and a % CONE capacity price.

8 U-0-November, 0 Page of respectively. These results more clearly favor retirement and should not be considered break-even. Were the savings stated above using the Company s natural gas price forecast? Yes. 0 Does Ms. Medine claim that the Company s coal retirement analysis was incomplete because it did not use the EO natural gas price forecast as well? Yes. In discussing the Company s analysis, Ms. Medine states that: this analysis cannot be deemed complete as presented. Use of the Consumers forecast as a sensitivity would have been appropriate. However, this was not done. The use of the EO price forecast would most certainly have produced different conclusions. Is Ms. Medine mistaken on this point? Yes. The Company did, in fact, provide results of 0 retirement using the EO gas price in its initial filing and later in a corrected workpaper to address the coal price error. 0 Were the savings of 0 retirement higher using the EO natural gas price? Yes. The Company s estimate of savings under both natural gas prices are presented in Figure, below. Under the EO natural gas prices and Business as Usual (BU) technology costs, the Company projects savings of $ million almost $00 million more savings than when using its own natural gas price. The Comings Direct, p., Table. On pages - of my direct testimony, I explained that the 0% CONE price is more reasonable than the Company s BU price of % CONE. Medine Direct, p., lines -. Exhibit - (STW-0). Exhibit MEC- (Response to 0-MEC-CE- (Partial) (Revised), STRTEGIST NPV RESULTS 0 IRP CapPrice Sens_Coal_Reruns Exhibits tab only). The savings are calculated by taking the difference in the base portfolio compared to the Karn & 0 portfolio in line of each table, which represents supply and demand-side optimization in the Strategist model. Note: the values in the Company s workpaper are incorrectly labeled as thousands whereas they are actually in millions.

9 U-0-November, 0 Page of 0 0 savings, under both gas prices, are higher when assuming reduced costs for renewable and demand-side resources (shown in the Emerging Technology (ET) and Environmental Policy (EP) cases). Figure : Company s Corrected Estimate of Savings from Karn & 0 Retirement ($0 mil NPV) Gas Price Technology Costs BU ET EP CE $ $0 $ EO $ $ $,0 In asserting that a coal plant retirement decision should be founded on a strong basis, Ms. Medine recommended that the retirement analysis focus on the EO natural gas prices and treat the CE natural gas prices as a sensitivity. s the results above demonstrate, focusing on the EO prices provides an even stronger basis for 0 retirement. These results strongly contradict her claims, and those of witnesses Pollock and Coppola, that the Company s decision to retire Karn Units and in 0 was not justified. It is also worth noting that the Company previously stated that it: considers there to be more upside risk than downside risk to natural gas prices and more downside risk than upside risk to renewable resource capital costs. If one agrees with this statement, as I do, the results shown above further buttress the Company s decision to retire the units. Does Ms. Medine question the Company s coal prices for a different reason? Yes. Ms. Medine claims that [t]he delivered coal price assumptions were not adjusted to reflect the rail discounts that had been offered to Consumers. 0 Id. Medine Direct, p., lines -0. Medine Direct, p., lines -. Direct Testimony of Thomas P. Clark, p., lines -. 0 Medine Direct, p., lines -.

10 U-0-November, 0 Page of How do you respond to this concern? First, the Company has not asserted that these offers will amount to an actual discount in coal prices. Second, the Company has not quantified what such a discount would look like. If the Company quantified this, it could model a sensitivity with discounted coal prices. Finally, we have modeling with a discounted coal price already in the form of Company s initial, modeling which contained an erroneously low coal price. 0 0 What were the savings of 0 retirement under the erroneously low coal price? The initial, uncorrected savings are presented in Figure. This shows the initial estimate of $ million in savings and the nearly $00 million in incremental savings under the EO natural gas price under the BU. Figure : Company s Estimate of Savings from Karn & 0 Retirement with Incorrect Coal Prices ($0 mil NPV) Gas Price Technology Costs BU ET EP CE $ $ $ EO $ $ $,0 Thus, even under extremely low coal prices, retiring the units in 0 was found to be favorable. Correcting for the coal price error produced more than $0 million in additional savings under both gas prices in the BU scenario (see Figure ). Because the Company s uncorrected coal prices were unrealistically low, the discounted coal prices that Ms. Medine is discussing would likely be higher than those which already showed substantial savings under her preferred natural gas price. Moreover, as noted above, the Company has not stated that Exhibit MEC- 0 (Response to 0-MCV-CE-). Exhibit - (STW-0). The savings are calculated by taking the difference in the base portfolio compared to the Karn & 0 portfolio in line of each table, which represents supply and demandside optimization in the Strategist model.

11 U-0-November, 0 Page of these rail transport offers would actually result in a discount and was unable to provide a reliable estimate of the discount due to insufficient information. 0 Does BTE Witness Pollock also criticize the Company s decision to retire Karn Units and? Yes. However, he mistakenly identifies these results as a comparison between Karn Units and and replacement supply and demand-side resources. Mr. Pollock instead presents the Company s comparison of replacing the Karn units with all market capacity and energy not new supply or demand-side resources. He also compounds this error by presenting results that include the Company s coal price error. 0 Does Mr. Pollock accurately describe the analysis he was presenting? No. Mr. Pollock, in referring to his chart showing the all-market replacement comparison, states that: with respect to retiring Karn Units and in 0 and replacing this capacity with various renewable and other soft resources, the economics are clearly unfavorable as shown in Table. He incorrectly states that the data shows new supply and demand-side replacement, but it clearly does not; indeed, the name of his chart is BU CE Retirement nalysis vs. Market. The comparison he is describing would show savings (see Figure ) but he instead focuses on the less-relevant and uncorrected comparison which makes 0 retirement appear unfavorable. Is an all-market replacement consistent with the Company s PC? No. The Company is not planning to procure market capacity or energy in replacing Karn Units and. Therefore, the coal retirement analysis with new Exhibit MEC- 0 (Response to 0-MCV-CE-). Pollock Direct, p., Table. Pollock Direct, p., lines -. Pollock Direct, p., Table.

12 U-0-November, 0 Page of supply and demand-side replacement should be the focus as presented elsewhere in this testimony. Does Mr. Pollock s figure include the Company s initial coal price error? Yes. The results shown by Mr. Pollock contain the coal price error and, therefore, underestimate savings from early retirement. The Company later provided updated modeling to address that error. 0 Does Mr. Coppola claim that the Company should consider delaying retirement because environmental compliance costs could be lower? Yes. In referring to Clean Water ct Section (b) costs, Mr. Coppola states that [t]he Company believes that there are alternatives that can be used under the rules which can reduce the O&M and capital expenditures by approximately $0 million from the amounts included in some of the scenarios modeled. In support of this statement, Mr. Coppola cites a Consumers data response. Does the data response provided by the Company include a scenario with reduced costs for (b)? Technically, yes. The Company presents a scenario with zero costs for (b). However, it does not present a scenario with reduced, but still positive, costs required for compliance. Mr. Coppola only refers to potential cost reductions. He does not clarify that these cost savings assume zero compliance costs. 0 Was Mr. Coppola s $0 million figure correct? No. The data response provided by the Company includes a full year s capital and O&M costs in the final year of operation. However, the Company assumes that units retire on May st of their final year of operation. To account for this, the Strategist model applies a factor of / to the final year s costs provided in the Exhibit MEC- (Response to 0-MEC-CE- (Partial) (Revised), STRTEGIST NPV RESULTS 0 IRP CapPrice Sens_Coal_Reruns Exhibits tab only. Coppola Direct, p., line -p., line. Exhibit MEC- (Response to 0-G-CE-, G-CE- avoided (b) capital expenditure).

13 U-0-November, 0 Page 0 of input workbook. Mr. Coppola did not make this adjustment, which would have lowered his estimate to $. million. re the $0 million and $. million figures you cite above in terms of net present value (NPV)? No. These figures are total nominal (i.e., undiscounted) dollars which should not be mistaken for NPV. In terms of 0 NPV, the (b) compliance costs assumed by the Company for Karn Units and are $. million (or $. million in 0 NPV). 0 re you claiming that the Company will likely avoid $. million NPV in compliance costs? No. In fact the Company claimed that it would be imprudent to assume no compliance costs at this time. 0 If one believes that the Company will completely avoid these costs, then this would be the savings. Even under this scenario, however, the savings from 0 retirement are still substantial in most scenarios (see Figure ). 0 Does Ms. Medine take issue with the Company s treatment of unrecovered plant balance of Karn Units and? Yes. Ms. Medine is concerned with the treatment of the remaining book value of the units. She states that this balance would decrease if they were allowed to continue operation. Does unrecovered plant balance need to be considered in the Company s resource decisions? No. The plant balance will likely be recovered whether the units retire in 0, 0, or any other year. ssuming the Company will get recovery, these are sunk costs which should not influence a forward-looking decision. I am more concerned with the Company incurring new capital expenditures through a 0 Direct Testimony of Heather. Breining, p., line - p., line. 0

14 U-0-November, 0 Page of delayed retirement decision. This would only increase the plant balance and, once spent, would become additional sunk costs that would be recovered from ratepayers. Thus, a forward-looking retirement would allow for avoiding future capital investment that would otherwise become sunk later. 0 Has the Company already delayed the retirement decision on Karn Units and in the past? Yes. Mr. Coppola suggests delaying retirement of these units, claiming that there is nothing in these analyses that poses an obstacle to deferring the retirement of Karn and past 0. However, this is not the first time the Company assessed the economics of retiring these two units. s I discussed previously in my testimony on the Company s 0 rate case, Consumers has continually found that retiring these units in the short term would provide savings. Delaying even further, as Mr. Coppola suggests, would just cost ratepayers more. 0 Is retirement of Karn Units and in 0 premature or rushed in any way? No. First, by 0 both Karn Units and will be more than 0 years old, making them among the oldest coal units in the U.S. Second, the Company has conducted an analysis showing that 0 retirement would save ratepayers more than 0 retirement. The Company has decided to delay retirement by two years, in part due to logistics and economic development. However, the 0 retirement date is already a suboptimal delay from the ratepayers perspective, as they will ultimately pay more for keeping the units operating for two more years. Coppola Direct, p., lines -. U-0 PUBLIC Direct Testimony of Tyler Comings on behalf of MEC-NRDC-SC, p., line through p., line.

15 U-0-November, 0 Page of. RECOMMENDTIONS What do you recommend? I recommend that the Commission accept the Company s decision to retire Karn Units and in 0. Despite the claims of several other parties, there is a compelling case for retiring these units no later than 0. Does this conclude your testimony? Yes.

16 MICHIGN PUBLIC SERVICE COMMISSION CONSUMERS ENERGY COMPNY U-0-November, 0 Rebuttal Testimony of Tyler Comings on behalf of MEC-NRDC-SC Exhibit:MEC-; Source: Response to 0-MEC-CE- (Partial) (Revised), STRTEGIST NPV RESULTS 0 IRP CapPrice Sens_Coal_Reruns Exhibits tab only Page of CSE NO.: U-XXXXX EXHIBIT: - (STW- ) WITNESS: STWLZ DTE: JUNE, 0 PGE: OF () (B) (C) (D) (E) (F) (G) IRP PORTFOLIO ECONOMICS BY SENSITIVITY MEDIUM NLYSIS Net Present Value (K$) Strategist Modeling Results Business s Usual Consumers Energy Gas Price No Line No Description Base K& 0 K& 0 C 0 C 0 C 0 C 0 Reference case (Do nothing, short term market purchases all years) 0,0 0, 0, 0, 0, 0, 0, New Build, gas, wind, solar, storage 0,,,,,0,,0 New Build, gas, wind, solar, storage, CVR, DR, EE 0, 0, 0, 0, 0,0 0, 0, Preferred Plan, 0 lternative Plan, MICHIGN PUBLIC SERVICE COMMISSION CONSUMERS ENERGY COMPNY CSE NO.: U-XXXXX EXHIBIT: - (STW- ) WITNESS: STWLZ DTE: JUNE, 0 PGE: OF () (B) (C) (D) (E) (F) (G) IRP PORTFOLIO ECONOMICS BY SENSITIVITY MEDIUM NLYSIS Net Present Value (K$) Strategist Modeling Results Environmental Policy Consumers Energy Gas Price No Description Base K& 0 K& 0 C 0 C 0 C 0 C 0 Deltas to Base Reference Case Reference case (Do nothing, short term market purchases all years) 0, 0,0 0,0 0, 0, 0, 0, New Build, gas, wind, solar, storage 0, 0,, 0, 0, 0, 0,0 New Build, gas, wind, solar, storage, CVR, DR, EE 0, 0,0, 0, 0, 0, 0, Preferred Plan 0, 0 lternative Plan 0,0 MICHIGN PUBLIC SERVICE COMMISSION CONSUMERS ENERGY COMPNY CSE NO.: U-XXXXX EXHIBIT: - (STW- ) WITNESS: STWLZ DTE: JUNE, 0 PGE: OF () (B) (C) (D) (E) (F) (G) IRP PORTFOLIO ECONOMICS BY SENSITIVITY MEDIUM NLYSIS Net Present Value (K$) Strategist Modeling Results Emerging Technologies Consumers Energy Gas Price No Description Base K& 0 K& 0 C 0 C 0 C 0 C 0 Reference case (Do nothing, short term market purchases all years) 0, 0, 0, 0, 0, 0, 0, New Build, gas, wind, solar, storage 0, 0, 0, 0, 0, 0, 0, New Build, gas, wind, solar, storage, CVR, DR, EE 0, 0,0 0,0 0, 0, 0, 0, Preferred Plan 0,0 0 lternative Plan 0, MICHIGN PUBLIC SERVICE COMMISSION CONSUMERS ENERGY COMPNY CSE NO.: U-XXXXX EXHIBIT: - (STW- ) WITNESS: STWLZ DTE: JUNE, 0 PGE: OF () (B) (C) (D) (E) (F) IRP PORTFOLIO ECONOMICS BY SENSITIVITY MEDIUM NLYSIS Net Present Value (K$) Strategist Modeling Results Business s Usual EI 0 nnual Energy Outlook Gas Price Description Base K& 0.% Load Growth K& 0.% EE Growth K& 0 00% Gas K& 0 0% RO Return K& 0 CT Only K& 0 Sensitivity Number Reference case (Do nothing, short term market purchases all years),,,,0 0,, New Build, gas, wind, solar, storage,,,,,,0, New Build, gas, wind, solar, storage, CVR, DR, EE,,,,,, Preferred Plan,,,, 0 lternative Plan, MICHIGN PUBLIC SERVICE COMMISSION CONSUMERS ENERGY COMPNY CSE NO.: U-XXXXX EXHIBIT: - (STW- ) WITNESS: STWLZ DTE: JUNE, 0 PGE: OF () (B) (C) (D) (E) (F) IRP PORTFOLIO ECONOMICS BY SENSITIVITY MEDIUM NLYSIS Net Present Value (K$) Strategist Modeling Results Environmental Policy EI 0 nnual Energy Outlook Gas Price Description Base K& 0.% Load Growth K& 0.% EE Growth K& 0 00% Gas K& 0 0% CO Reference case (Do nothing, short term market purchases all years),,,, 0,00, New Build, gas, wind, solar, storage,,0, 0,,,0 New Build, gas, wind, solar, storage, CVR, DR, EE,,,00 0,,, Preferred Plan,0,0,,0 0 lternative Plan, MICHIGN PUBLIC SERVICE COMMISSION CONSUMERS ENERGY COMPNY CSE NO.: U-XXXXX EXHIBIT: - (STW- ) WITNESS: STWLZ DTE: JUNE, 0 PGE: OF () (B) (C) (D) (E) (F) IRP PORTFOLIO ECONOMICS BY SENSITIVITY MEDIUM NLYSIS Net Present Value (K$) Strategist Modeling Results Emerging Techonologies EI 0 nnual Energy Outlook Gas Price Description Base K& 0.% Load Growth K& 0.% EE Growth K& 0 00% Gas K& 0 % Renewable Reference case (Do nothing, short term market purchases all years),,0,0,,,0 New Build, gas, wind, solar, storage,,,,,, New Build, gas, wind, solar, storage, CVR, DR, EE,,,0,0,, Preferred Plan,,,, 0 lternative Plan,0 Page

17 U-0-November, 0 Rebuttal Testimony of Tyler Comings on behalf of MEC-NRDC-SC Exhibit:MEC-0; Source: Response to 0-MCV- CE- Page of 0-MCV-CE- uestion:. Refer to Mr. Gallaway s direct testimony on page, lines -. Provide an estimate of the rail rate reductions that could be realized. Response: There is insufficient information available to provide a reliable estimate. Brian Gallaway October, 0 Fossil Fuel Supply Department 00

18 U-0-November, 0 Rebuttal Testimony of Tyler Comings on behalf of MEC-NRDC-SC Exhibit:MEC-; Source: Response to 0-G-CE- Page of 0-G-CE- uestion:. Refer to page 0, lines -, of Mr. Clark s direct testimony. Response: a. Does the Base Case with Karn Unit and operating until 0 have the (b) capital expenditures included? If no, why not and how can the plant be compliant with environmental regulations? b. What flexibility does the Company have with spending on environmental upgrades for (b) compliance and what reductions in capital expenditures were made in the sensitivity analysis for operation through 0? c. Provide the changes in the NPV for each scenario shown in Figure and as a result of avoiding the (b) capital expenditures. a. Yes. The base case includes (b) capital expenditure. b. Refer direct testimony of Heather. Breining page, line through page, line. Reductions in capital expenditures for the (b) sensitivity at Karn Units & resulted in removal of costs shown in Exhibit -, (HB-), column (d), lines -. c. Please see attachment 0-G-CE- avoided (b) capital expenditure. This analysis calculates the economic carrying charge impact associated with removal of (b)-associated costs at Karn Units & (Excel columns -J). Columns M-Y show the increases in capital expenditures if (b) investments were required at Campbell Units &. Thomas P. Clark October, 0 Merchant Operations and Resource Planning 00

19 ttachment 0 G CE Economic Carrying Charge Net Present Value Impact (b) sensitivities Karn Evaluation of Costs if b investments WERE NOT required Campbell Evaluation of Costs if b investments WERE required U-0-November, 0 Rebuttal Testimony of Tyler Comings on behalf of MEC-NRDC-SC Exhibit:MEC-; Source: Response to 0-G-CE- Page of Base Case b investments required Sensitivity no b inv reqd Delta Base Case no b investments required Sensitivity b inv reqd Delta Capital ECC + O&M Capital ECC + O&M Capital ECC + O&M Capital ECC + O&M Capital ECC + O&M Capital ECC + O&M K K K C C C C C C ($K) ($K) ($K) ($K) ($K) ($K) ($K) ($K) ($K) Total 0 Total 0 Total 00 Total 0 0 Total 00 Total 0 00 NPV 0 NPV 0 NPV 0 0 NPV 0 NPV 0 0 NPV 0

20 STTE OF MICHIGN BEFORE THE MICHIGN PUBLIC SERVICE COMMISSION In the matter of the pplication of CONSUMERS ENERGY COMPNY for approval of its integrated resource plan pursuant to MCL 0.t and for other relief U-0 LJ Sharon L. Feldman PROOF OF SERVICE On the date below, an electronic copy of Rebuttal Testimony of Tyler Comings on behalf of Michigan Environmental Council, Natural Resources Defense Council and Sierra Club along with Exhibits MEC- through MEC- were served on the following: Name/Party dministrative Law Judge Sharon L. Feldman Counsel for Consumers Energy Co. Bret. Totoraitis Robert W. Beach Michael C. Rampe Theresa.G. Staley nne M. Uitvlugt Counsel for Michigan Public Service Commission Spencer. Sattler Daniel Sonneveldt Counsel for BTE Bryan. Brandenburg Michael J. Pattwell Counsel for Environmental Law & Policy Center Margrethe Kearney Counsel for Cypress Creek Renewables, LLC and Solar Energy Industries ssociation, Jennifer Utter Heston Counsel for ttorney General Special Litigation Division Celeste R. Gill mit Singh ddress

21 Counsel for Michigan Chemistry Council, Energy Michigan Timothy Lundgren Justin Ooms Counsel for Michigan Energy Innovation Business Council, Independent Power Producers Coalition of Michigan and Institute for Energy Innovation Laura. Chappelle Toni L. Newell Counsel for Midland Cogeneration Venture Jason T. Henselman John. Janiszewski Counsel for Michigan Electric Transmission Company (METC) Richard J. aron Courtney Kissel Counsel for Cadillac Renewable Energy, Genesee Power Station, Grayling Generating Station, Hillman Power Company, TES Filer City Station, Viking Energy of Lincoln, Viking Energy of McBain, Inc. Thomas J. Waters nita G. Fox The statements above are true to the best of my knowledge, information and belief. OLSON, BZDOK & HOWRD, P.C. Counsel for MEC-NRDC-SC Date: November, 0 By: Kimberly Flynn, Legal ssistant Karla L. Gerds, Legal ssistant Breanna Thomas, Legal ssistant 0 E. Front St. Traverse City, MI Phone: /-00 kimberly@envlaw.com, karla@envlaw.com and breanna@envlaw.com