Miller, Canfield, Paddock and Stone, P.L.C. One Michigan Avenue, Suite 900 Lansing, Michigan TEL (517) FAX (517)

Transcription

1 Founded in 1852 by Sidney Davy Miller SHERRI A. WELLMAN TEL (517) FAX (517) Miller, Canfield, Paddock and Stone, P.L.C. One Michigan Avenue, Suite 900 Lansing, Michigan TEL (517) FAX (517) MICHIGAN: Ann Arbor Detroit Grand Rapids Kalamazoo Lansing Troy FLORIDA: Tampa ILLINOIS: Chicago NEW YORK: New York CANADA: Windsor CHINA: Shanghai MEXICO: Monterrey POLAND: Gdynia Warsaw Wrocław March 29, 2018 Ms. Kavita Kale Executive Secretary Michigan Public Service Commission 7109 W. Saginaw Hwy., 3rd Floor Lansing, MI Re: SEMCO Energy Gas Company Tax Reform Credit A Case No. U Dear Ms. Kale: Pursuant to the Commission s Order issued in Case No. U on February 22, 2018, SEMCO Energy Gas Company hereby files the enclosed Application, and Direct Testimony and Exhibits of Steven Q. McLean to prospectively reflect the effects of the federal Tax Cuts and Jobs Act of 2017 on its natural gas general base rates. Also enclosed are the Proof of Service and Appearances of Sherri A. Wellman and Paul M. Collins. Please be advised that a draft Notice of Hearing has been ed to Angela Sanderson at sandersona2@michigan.gov. Should you have any questions, please kindly advise. Very truly yours, Miller, Canfield, Paddock and Stone, P.L.C. Enclosures cc: Steve McLean Jennifer Dennis Intervenors in Case No. U By: Sherri A. Wellman

2 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION ***** In the matter on the Commission s own ) motion, to consider changes in the rates ) of all the Michigan rate-regulated ) electric, steam and natural gas utilities ) Case No. U to reflect the effects of the federal Tax ) Cuts and Jobs Act of 2017: ) SEMCO ENERGY GAS COMPANY ) files an application for determination of Credit A ) as described in order U ) APPLICATION SEMCO Energy Gas Company ( SEMCO Gas or the Company ), a division of SEMCO Energy, Inc. ( SEMCO Energy ), as directed in the February 22, 2018 Order of the Michigan Public Service Commission ( MPSC or the Commission ) issued in Case No. U ( February 22 Order ), hereby files its proposal for prospectively addressing the impacts of federal corporate tax reduction arising from the Tax Cuts and Jobs Act of 2017 ( TCJA ) on its natural gas general base rates (a/k/a Credit A ), with credits to be effective no later than July 1, In support of this Application, SEMCO Gas respectfully represents to the Commission as follows: 1. SEMCO Gas, with its principal office located at 1411 Third Street, Suite A, Port Huron, Michigan, is engaged as a public utility in the business of transporting, supplying and distributing natural gas to the public in its various service areas located in the Lower and Upper Peninsulas of Michigan. 2. SEMCO Gas s retail natural gas sales business and retail gas transportation business are subject to the jurisdiction of the Commission.

3 3. SEMCO Gas s last general rate case for retail gas service was in Case No. U , with a final order issued by the Commission in that case on January 6, In the Commission s February 22 Order, SEMCO Gas was directed to file this application to address going-forward adjustments to base rates to reflect the reduction in the federal corporate tax rate from 35% to 21%. Ordering paragraph D of the February 22 Order directed companies to file supporting testimony and base rate case exhibits similar to those included in the Case No. U filing requirements schedules A1 (revenue deficiency/sufficiency), B1 (rate base), C1 (operating income), C2 (revenue conversion factor), C8 (federal income tax), and D1 (cost of capital), and any other exhibits required to show the difference between the previously approved revenue requirement reflecting a 35% federal income tax expense and the new revenue requirement reflecting a 21% federal income tax expense. The companies were also directed to file cost of service studies similar to base rate case schedule F1, and proposed rate design and tariff sheets. 5. Consistent with the Commission s directives made in the February 22, Order, SEMCO Gas is filing herewith the supporting testimony and exhibits identified therein. 6. SEMCO Gas s proposed rate design and tariff sheet reflect credits to its base rates to be effective no later than July 1, SEMCO Gas represents that the proposed credits, as supported by its testimony and exhibits, are just, reasonable, in the public interest, and provide for its customers to enjoy the benefits of the tax reduction on a timely basis. 2

4 WHEREFORE, SEMCO Energy Gas Company requests that the Commission: A. Approve this Application; B. Find and determine that SEMCO Gas s proposed credits as supported by its testimony and exhibits are reasonable and prudent; C. Authorize SEMCO Gas to file and make effective its proposed credits no later than July 1, 2018; and D. Grant SEMCO Gas such other and further relief and authorizations as shall be lawful and proper. Respectfully submitted, SEMCO ENERGY GAS COMPANY Dated: March 29, 2018 By: One of its Attorneys Sherri A. Wellman (P38989) Paul M. Collins (P69719) MILLER, CANFIELD, PADDOCK AND STONE, P.L.C. One Michigan Avenue, Suite 900 Lansing, MI (517) Attorneys for SEMCO Energy Gas Company 3

5 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION * * * * * In the matter on the Commission s own ) motion, to consider changes in the rates ) of all the Michigan rate-regulated ) electric, steam and natural gas utilities ) Case No. U to reflect the effects of the federal Tax ) Cuts and Jobs Act of 2017: ) SEMCO ENERGY GAS COMPANY ) files an application for determination of Credit A ) as described in order U ) DIRECT TESTIMONY AND EXHIBITS OF STEVEN Q. MCLEAN ON BEHALF OF SEMCO ENERGY GAS COMPANY March 29, 2018

6 Direct Testimony of Steven Q. McLean On Behalf of SEMCO Energy Gas Company Q. Please state your name and business address. A. My name is Steven Q. McLean. My business address is 1411 Third Street, Suite A, Port Huron, Michigan Q. By whom are you employed and what is your position? A. I am employed by SEMCO Energy Gas Company ( SEMCO Gas or the Company ), a division of SEMCO Energy, Inc. ( SEMCO ), as its Director of Regulatory Affairs. Q. What are your responsibilities as Director of Regulatory Affairs? A. I am responsible for all SEMCO Gas regulatory matters involving the Michigan Public Service Commission ( MPSC or the Commission ) and the Federal Energy Regulatory Commission. In addition, I am responsible for the Company s Energy Waste Reduction Program. Q. Would you briefly describe your educational background? A. I earned a Bachelor s of Science Degree in Political Science and Economics from Central Michigan University in May I earned a Master s of Arts Degree in Economics from Central Michigan University in December Q. Have you attended any seminars or other training courses? A. Yes. In May 2006, I attended the Association of Edison Illuminating Companies Fundamentals of Customer Load Analysis Seminar. In August 2006, I completed the National Regulatory Utilities Commissioners annual regulatory studies program held at Michigan State University. In October 2010, I attended the Association of Edison Illuminating Companies Advanced Course in Customer Load Research. 1

7 Direct Testimony of Steven Q. McLean On Behalf of SEMCO Energy Gas Company Q. Please summarize your employment and professional experience. A. In January 2006, I joined the MPSC where I held various positions of increasing responsibility. In 2011, I was promoted to the Manager of the Rates and Tariffs section. The responsibilities of that section included, but were not limited to, analyzing utility reports, financial records, and rate case filings to determine the appropriate level of rates for regulated energy utilities, utilizing laws, regulations, and Commission policies. In August of 2014, I was hired by SEMCO Gas as its Rates and Regulatory Affairs Manager. In December of 2016, I was promoted to my current position as Director of Regulatory Affairs. Q. Have you previously testified in any regulatory proceedings before the Commission? A. Yes. I have testified before the MPSC in numerous general rate cases and other miscellaneous proceedings on behalf of the MPSC Staff and SEMCO Gas. Q. Please identify the exhibits which you are sponsoring in this case. A. I am sponsoring: Exhibit A-1 (SQM-1) Adjusted Settlement Revenue Deficiency (U-16169) Exhibit A-2 (SQM-2) Settlement Rate Base (U-16169) Exhibit A-3 (SQM-3) Adjusted Settlement Operating Income (U-16169) Exhibit A-4 (SQM-4) Adjusted Settlement Revenue Conversion Factor (U-16169) Exhibit A-5 (SQM-5) Adjusted Settlement Agreement Federal Income Tax (U-16169) Exhibit A-6 (SQM-6) Settlement Cost of Capital (U-16169) Exhibit A-7 (SQM-7) Cost Allocation and Rate Design (U-16169) Exhibit A-8 (SQM-8) Tariff Sheets 2

8 Direct Testimony of Steven Q. McLean On Behalf of SEMCO Energy Gas Company As directed by the Commission in the February 22, 2018 Order in Case No. U ( February 22 Order ), these exhibits are similar to the base rate exhibits/schedules adopted in Case No. U Q. Were these exhibits prepared by you or under your direction and supervision? A. Yes. 6 Q. What is the purpose of your testimony in this proceeding? A. The purpose of my testimony is to provide the calculation for Credit A as required by the Commission s February 22 Order addressing prospectively the federal Tax Cuts and Jobs Act of 2017 ( TCJA ). Q. How were the Company s Credits A developed? A. The Company-proposed Credits A were developed by first calculating the reduction to the most recently approved revenue requirement reflecting lower federal taxes. The reduction was then allocated to customer classes based on cost of service study allocation factors. Finally, the Company created credits for each rate schedule based on forecasted sales. Q. In what case were the Company s current base rates approved by the Commission? A. The current base rates were approved in Case No. U by MPSC Order Approving Settlement Agreement, dated January 6, Q. What is the annual reduction to the revenue requirement associated with the lower tax rate? A. The annual reduction in the revenue requirement approved in U is $5,978,884 and is displayed in Exhibit A-1 (SQM-1). 3

9 Direct Testimony of Steven Q. McLean On Behalf of SEMCO Energy Gas Company Q. How was the annual reduction to the revenue requirement calculated? A. The reduction was calculated by first creating exhibits that replicated the revenue deficiency agreed to in the Settlement Agreement approved in Case No. U These exhibits were then adjusted to reflect the lower federal tax rate. Q. Why was it necessary to create exhibits that replicated the revenue deficiency in the settlement? A. The settlement in Case No. U was largely black box in nature, meaning that it did not explicitly state every component that is necessary to calculate the revenue deficiency or associated rates. Instead, the settlement included a limited amount of information such as revenue deficiency, overall rate of return, rate increase by rate schedule, and tariff sheets. Due to the limited information in the Settlement Agreement it was necessary to make certain assumptions to calculate the revenue requirement reduction associated with the lower federal tax rate. Q. How did the Company develop the assumptions necessary to create the exhibits replicating the revenue deficiency in the settlement? A. The Company reviewed the Settlement Agreement and the positions of the various parties to the case. It was determined that the revenue deficiency in the Settlement Agreement most closely matched the direct case of the Michigan Public Service Commission Staff ( Staff ). Using the Staff s direct case as a starting point the Company made changes to reflect the positions agreed to in the Settlement Agreement. Following these changes the Company then adjusted the Staff s filed net operating income so that the revenue deficiency matched the deficiency agreed to in the Settlement Agreement. These adjustments are reflected in Exhibit A-1 (SQM-1) and Exhibit A-3 (SQM-3). 4

10 Direct Testimony of Steven Q. McLean On Behalf of SEMCO Energy Gas Company Q. How were these exhibits adjusted to reflect the lower federal tax rate? A. Using the exhibits created to replicate the settlement outcome the Company adjusted the federal income tax from 35% to 21%. The impact of this adjustment resulted in a lower projected federal income tax as reflected in Exhibit A-5 (SQM-5). It also lowered the revenue multiplier as calculated in Exhibit A-4 (SQM-4). Q. How did the Company allocate the $5,978,884 revenue requirement reduction reflected in Exhibit A-1 (SQM-1) among its customers? A. SEMCO Gas reviewed the cost of service studies included in both the Company s and the Staff s direct cases filed in Case No. U to determine which allocation factors were used. Upon this review it was determined that both the Company and Staff used the total allocation of rate base as the allocation factor for federal taxes. To maintain consistency, SEMCO Gas used the Staff s allocation factors to allocate lower revenue requirement reductions resulting from the lower federal taxes to the various rate schedules as illustrated in Exhibit A-7 (SQM-7). Q. Why did the Company not create two separate cost of service studies as directed in the February 22 Order? A. Due to the black-box nature of the Settlement Agreement it was not possible to recreate an accurate cost of service study that would reflect the actual rates agreed to in the Settlement Agreement. Unlike the revenue deficiency there are simply too many variables involved. Furthermore, the methodology used by the Company is very similar to using a cost of service study, accurately reflects the allocation methodology supported by both the Staff and the Company, and creates a fair and equitable distribution of the rate reduction related to the lower federal tax rate. 5

11 Direct Testimony of Steven Q. McLean On Behalf of SEMCO Energy Gas Company Q. How were the Credits A calculated? A. The Company divided the allocated rate reduction by rate schedule into the 2018 sales forecast by rate schedule, from the Company s currently filed GCR plan in Case No. U This created a volumetric credit by rate schedule as reflected on Exhibit A-7 (SQM-7) and the proposed tariffs in Exhibit A-8 (SQM-8). The Company believes that these credits are reasonable. Q. Does this conclude your testimony? 8 A. Yes. 6

12 SEMCO Energy Gas Company Case No.: U Adjusted Settlement Revenue Deficiency (U-16169) Witness: Steven Q. McLean Exhibit A-1 (SQM-1) Page 1 of 1 Staff Settlement Tax Settlement Description Direct Case Adjustments Amount Adjustment 2018 Tax Rate Rate Base 408,379, ,379, ,379,431 Rate of Return 7.12% 0.07% 7.19% 0.00% 7.19% Income Required 29,059, ,426 29,362,481-29,362,481 Adjusted Net Operating Income 24,286, ,957 24,400,219 3,382,932 27,783,151 Income Deficiency 4,772, ,469 4,962,262 (3,382,932) 1,579,330 Revenue Multiplier Revenue Deficiency 7,790, ,274 8,100,000 (5,978,884) 2,121,116

13 SEMCO Energy Gas Company Case No.: U Settlement Rate Base (U-16169) Witness: Steven Q. McLean Exhibit A-2 (SQM-2) Page 1 of 1 Line Staff No. Description Amount Amount 1 Plant in Service 624,366, ,209, Construction Work in Progress 6,098,068 6,098,068 4 Total Utility Plant 630,464, ,307,663 5 Accumulated Depreciation (277,427,882) (278,505,297) 6 Customer Advances and ARO Liability (3,923,209) (3,923,209) 7 Net Utility Plant 349,113, ,879,157 8 Working Capital 72,879,879 61,242,997 Unamortized MGP Balance - 3,257,277 9 Rate Base 421,993, ,379,431

14 SEMCO Energy Gas Company Case No.: U Adjusted Settlement Operating Income (U-16169) Witness: Steven Q. McLean Exhibit A-3 (SQM-3) Page 1 of Tax Staff Settlement Settlement Description Direct Case Adjustments Amount Adjustments Amount Operating Revenues: Sales Revenue 91,650,935 (618,521) 91,032,414-91,032,414 Transport Revenue 10,490,251 (641,987) 9,848,264-9,848,264 Cost of Gas Sold 187,965, ,965, ,965,549 Misc. Revenue 8,582,550-8,582,550-8,582,550 Total Operating Revnues 298,689,285 (1,260,508) 297,428, ,428,777 Operating Expenses: Cost of Gas Sold 187,965, ,965, ,965,594 LAUF & Company-Use Gas 1,908,688-1,908,688-1,908,688 Other Operation & Maintenance Expense 46,222,047 (1,435,826) 44,786,221-44,786,221 Depreciation, Depletion & Amoritization 19,449,428-19,449,428-19,449,428 Taxes Other than Income 8,500,093-8,500,093-8,500,093 Michigan Business Tax 1,961,204-1,961,204-1,961,204 Federal Income Tax 8,395,969 61,361 8,457,331 (3,382,932) 5,074,399 Total Operating Expenses 274,403, ,028,558 (3,382,932) 269,645,626 Net Operating Income 24,286,262 24,400,219 3,382,932 27,783,151 AFUDC Sub total 24,286, ,957 24,400,219 3,382,932 27,783,151 Income Tax Effect of Interest Synchronization Adjusted Net Operating Income 24,286, ,957 24,400,219 3,382,932 27,783,151

15 SEMCO Energy Gas Company Case No.: U Adjusted Settlement Revenue Conversion Factor (U-16169) Witness: Steven Q. McLean Exhibit A-4 (SQM-4) Page 1 of 1 Staff Settlement Settlement Description Rate Direct Case Adjustments Amount Adjustments 2018 Tax Rate Base Prior to Income Tax 100, , ,000 Michigan Business Income Tax 4.95% 4,950-4,950-4,950 Michigan Gross Receipts Tax 0.80% Federal Income Tax Base 94,250-94,250-94,250 Federal Income Tax@ (35% & 21%) 32,988-32,988 (13,195) 19,793 Income Base - After Taxes 61,263-61,263 13,195 74,458 Revenue Multiplier (0.29)

16 SEMCO Energy Gas Company Case No.: U Adjusted Settlement Agreement Federal Income Tax (U-16169) Witness: Steven Q. McLean Exhibit A-5 (SQM-5) Page 1 of 1 Staff Settlement Settlement Description Direct Case Adjustments Amount Adjustments 2018 Tax Rate Total Operating Revnues 298,689,285 (1,260,508) 297,428, ,428,777 Cost of Gas Sold (187,965,594) - (187,965,594) - (187,965,594) LAUF & Company-Use Gas (1,908,688) - (1,908,688) - (1,908,688) Other Operation & Maintenance Expense (46,222,047) (1,435,826) (44,786,221) - (44,786,221) Depreciation, Depletion & Amoritization (19,449,428) - (19,449,428) - (19,449,428) Taxes Other than Income (8,500,093) - (8,500,093) - (8,500,093) Michigan Business Tax (1,961,204) - (1,961,204) - (1,961,204) Allowable Interest Expense (8,414,998) - (8,414,998) - (8,414,998) Operating Income Before Fed. Income Tax 24,267, ,318 24,442,551-24,442,551 Schedule M Permanent Differences (278,749) - (278,749) - (278,749) Taxable Income 23,988, ,318 24,163,802-24,163,802 Federal Income Tax Rate 35.00% 0.00% 35.00% -14% 21.00% Projected Federal Income Tax 8,395,969 61,361 8,457,331 (3,382,932) 5,074,399

17 SEMCO Energy Gas Company Case No.: U Settlement Cost of Capital (U-16169) Witness: Steven Q. McLean Exhibit A-6 (SQM-6) Page 1 of 1 % of % of Weighted Cost Weighted Line 13 Month Permanent Total Cost Permanent Total Cost of No. Description Average Capital Capital Rate (1) Capital Capital Debt (Col. 1) (Col. 3) (Col. 4) (Col. 5) (Col. 6) (Col. 7) (Col. 8) (Col. 9) 1 Long Term Debt 168,293, % 39.88% 5.17% 2.32% 2.06% 2.06% 2 Short Term Debt % 0.00% 0.00% 0.00% 0.00% 0.00% 3 Common Equity 206,925, % 49.04% 10.35% 5.71% 5.08% 4 Subtotal 375,219, % 8.03% 2.06% 5 Customer Deposits 3,229, % 7.00% 0.05% 0.05% 6 Other Interest Bearing Obligations % 0.00% 0.00% 7 Deferred FIT 43,544, % 0.00% 0.00% 8 JDITC % 8.03% 0.00% 0.00% 9 Total 421,993, % 7.19% 2.11%

18 SEMCO Energy Gas Company Case No.: U Cost Allocation and Rate Design (U-16169) Witness: Steven Q. McLean Exhibit A-7 (SQM-7) Page 1 of Tax Credit Estimate Total Company Residential GS-1 GS-2 GS-3 TR-1 TR-2 TR-3 1 Tax Allocator (Ratebase U-16169) % Tax Rate Savings $ (5,978,884) $ (4,016,091) $ (568,153) $ (391,828) $ (401,854) $ (123,833) $ (258,935) $ (83,355) GCR Forecast Dth 63,190,447 26,610,936 4,943,089 4,308,771 6,229,177 3,246,977 9,113,898 4,552,074 4 Proposed Rate Reduction $/Dth $ (0.1509) $ (0.1149) $ (0.0909) $ (0.0645) $ (0.0381) $ (0.0284) $ (0.0183)

19 M.P.S.C. - No. 1 Gas SEMCO ENERGY GAS COMPANY (T.C.J.A. Credit A Case No. U-20115) Continued From Sheet No. D-2.00 Case No.: U Witness: Steven McLean Exhibit: A-8 (SQM-8) Page 1 of 2 Original Sheet No. D-2.01 Tax Cuts and Jobs Act Credit A This credit is pursuant to the adjustment of the federal corporate tax rate on a going forward basis. This credit is to be on a volumetric basis. Tax Cuts and Jobs Act Credit A (Surcharge) Rate Class Amount/Dth Order No. Residential ($0.1509) per Dth U GS-1 ($0.1149) per Dth U GS-2 ($0.0909) per Dth U GS-2 ($0.0645) per Dth U Issued June 29, 2018 Colleen Starring President Port Huron, MI Effective for bills rendered on and after July 1, Issued under authority of the Michigan Public Service Commission dated June 28, 2018 in Case No. U

20 M.P.S.C. - No. 1 Gas SEMCO ENERGY GAS COMPANY (T.C.J.A. Credit A Case No. U-20115) Continued From Sheet No. E-1.00 Case No.: U Witness: Steven McLean Exhibit: A-8 (SQM-8) Page 2 of 2 Original Sheet No. E-1.01 Tax Cuts and Jobs Act Credit A This credit is pursuant to the adjustment of the federal corporate tax rate on a going forward basis. This credit is to be on a volumetric basis. Tax Cuts and Jobs Act Credit A (Surcharge) Rate Class Amount/Dth Order No. TR-1 ($0.0381) per Dth U TR-2 ($0.0284) per Dth U TR-3 ($0.0183) per Dth U Issued June 29, 2018 Colleen Starring President Port Huron, MI Effective for bills rendered on and after July 1, Issued under authority of the Michigan Public Service Commission dated June 28, 2018 in Case No. U

21 MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS PUBLIC SERVICE COMMISSION ENTRY OF APPEARANCE IN AN ADMINISTRATIVE HEARING This form is issued as provided for by 1939 PA 3, as amended, and by 1933 PA 254, as amended. The filing of this form, or an acceptable alternative, is necessary to ensure subsequent service of any hearing notices, Commission orders, and related hearing documents. General Instructions: Type or print legibly in ink. For assistance or clarification, please contact the Public Service Commission at (517) 2)'")$*0. $)'%-' #+.'" The #ommission will provide ')'&.,+*(& service of documents.* $(( +$,.'&- in this proceeding" THIS APPEARANCE TO BE ENTERED IN ASSOCIATION WITH THE ADMINISTRATIVE HEARING: Case / Company Name: SEMCO Energy Gas Company U Please enter my appearance in the above-entitled matter on behalf of: 1. (Name) SEMCO Energy Gas Company 2. (Name) 3. (Name) 4. (Name) 5. (Name) 6. (Name) 7. (Name) Docket No. Sherri A. Wellman Name One Michigan Avenue, Ste. 900 Address Lansing MI City State Zip Phone ( ) wellmans@millercanfield.com March 29, 2018 Date " I am not an attorney " I am an attorney whose: Michigan Bar # is P- Bar # is: ( state ) Signature: EAHR1 - $*#&*#&$%(

22 MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS PUBLIC SERVICE COMMISSION ENTRY OF APPEARANCE IN AN ADMINISTRATIVE HEARING This form is issued as provided for by 1939 PA 3, as amended, and by 1933 PA 254, as amended. The filing of this form, or an acceptable alternative, is necessary to ensure subsequent service of any hearing notices, Commission orders, and related hearing documents. General Instructions: Type or print legibly in ink. For assistance or clarification, please contact the Public Service Commission at (517) 2)'")$*0. $)'%-' #+.'" The #ommission will provide ')'&.,+*(& service of documents.* $(( +$,.'&- in this proceeding" THIS APPEARANCE TO BE ENTERED IN ASSOCIATION WITH THE ADMINISTRATIVE HEARING: Case / Company Name: SEMCO Energy Gas Company U Please enter my appearance in the above-entitled matter on behalf of: Docket No. 1. (Name) 2. (Name) SEMCO Energy Gas Company 3. (Name) 4. (Name) 5. (Name) 6. (Name) 7. (Name) Paul M. Collins Name One Michigan Avenue, Ste. 900 Address Lansing MI City State Zip Phone ( ) collinsp@millercanfield.com March 29, 2018 Date " I am not an attorney " I am an attorney whose: Michigan Bar # is P- Bar # is: ( state ) Signature: EAHR1 - $*#&*#&$%(

23 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION * * * * * In the matter on the Commission s own ) motion, to consider changes in the rates ) of all the Michigan rate-regulated ) electric, steam and natural gas utilities ) Case No. U to reflect the effects of the federal Tax ) Cuts and Jobs Act of 2017: ) SEMCO ENERGY GAS COMPANY ) files an application for determination of Credit A ) as described in order U ) STATE OF MICHIGAN ) ) ss COUNTY OF INGHAM ) PROOF OF SERVICE Crystal L. Chacon, being first duly sworn, deposes and says that on March 29, 2018 she served a copy of the direct case on the persons listed below via electronic mail: Michael E. Moody Eric J. Schneidewind Michael J. Brown moodym2@michigan.gov ejschneidewind@varnumlaw.com mbrown@cebhlaw.com Crystal L. Chacon Subscribed and sworn before me on this 29 th day of March, Kim L. Delinescheff, Notary Public State of Michigan, Ingham County My Commission Expires: October 12, 2018