I. PROCEDURAL HISTORY

Transcription

1 DECISION BEFORE THE DEPUTY COMMISSIONER OF THE MINNESOTA DEPARTMENT OF COMMERCE WILLIAM GRANT, DEPUTY COMMISSIONER In the Matter of Otter Tail Power Issue Date: April 19, 2018 Company s Conservation Improvement Program Modification Request Docket No. E017/CIP I. PROCEDURAL HISTORY On November 17, 2017, Otter Tail Power Company (OTP or the Company) filed a program modification request to its Conservation Improvement Program Triennial plan regarding the moving of funds from the now ended Made in Minnesota (MiM) solar program to its Publicly-Owned Property (POP) Solar program, increasing the measure life of geothermal heat pumps, providing rebates and claiming the energy savings associated with customers who install a heat pump and have a heating system supplied by a delivered fuel or a CIP-exempt natural gas provider, and modifying the Commercial Design Assistance (CDA) program to an indirect program with the Minnesota Department of Commerce, Division of Energy Resources (Department) pursuant to Minnesota Rules On November 27, 2017, Staff of the Minnesota Department of Commerce, Division of Energy Resources (Staff) filed their Notification of Completion confirming that the Petition met the requirements of Minnesota Rules , subpart 2. On December 6, 2017, the Department issued a timeline modification. On January 16, 2018, Center for Energy and Environment (CEE), CenterPoint Energy (CPE), Citizens Utility Board (CUB), Fresh Energy, and Xcel Energy (Xcel) filed Comments. On January 31, 2018, CEE, CUB, Fresh Energy, and OTP filed Reply Comments. On February 6, 2018, the Department issued a timeline modification. On March 5, 2018, Department Staff issued their Analysis, Recommendations and Proposed Decision. On March 20, 2018, CEE, CPE, Fresh Energy, OTP, and Xcel filed Comments in response to Staff s Proposed Decision. 85 7th Place East - Suite Saint Paul, P: F: mn.gov/commerce An equal opportunity employer

2 Contents I. PROCEDURAL HISTORY... 1 II. ANALYSIS HEAT PUMPS... 3 a. Background... 3 b. Staff s Proposed Decision ASHP Rebates to Delivered Fuel or CIP-Exempt Natural Gas Customers ASHP Pilot Program Stakeholder Process... 4 c. Deputy Commissioner s Determinations ASHP Rebates to Delivered Fuel or CIP-Exempt Natural Gas Customers ASHP Pilot Program Stakeholder Process... 6 III. ANALYSIS POP SOLAR... 6 a. Background... 6 b. Staff s Proposed Decision... 6 c. Deputy Commissioner s Determinations... 7 IV. ANALYSIS GEOTHERMAL HEAT PUMP MEASURE LIVES... 7 a. Background... 7 b. Staff s Proposed Decision... 7 c. Deputy Commissioner s Determinations... 8 V. ANALYSIS COMMERCIAL DESIGN ASSISTANCE... 8 a. Background... 8 b. Staff s Proposed Decision... 8 c. Deputy Commissioner s Determinations... 8 VI. ANALYSIS DISCOUNT RATE... 8 a. Background... 8 b. Staff s Proposed Decision... 9 c. Deputy Commissioner s Determinations VII. DEPUTY COMMISSIONER S ORDER POINTS Heat Pumps POP Solar Geothermal Heat Pump Measure Lives Commercial Design Assistance Discount Rate th Place East - Suite Saint Paul, P: F: mn.gov/commerce An equal opportunity employer

3 II. ANALYSIS HEAT PUMPS a. Background The Company requests a modification to its residential and commercial heat pump program contained in its triennial CIP plan. The request seeks to provide rebates and claim energy savings for customers that install air source heat pumps (ASHP) and have a heating system supplied by a delivered fuel or CIP-exempt natural gas utility. b. Staff s Proposed Decision In the Proposed Decision, Staff addressed the Company s proposal to provide ASHP rebates to delivered fuel or CIP-exempt natural gas customers, CEE s proposal for a limited pilot study, and the proposal supported by all those submitting comments for a stakeholder process to examine fuel switching issues more broadly. Staff s analysis contained in the Proposed Decision follows. 1. ASHP Rebates to Delivered Fuel or CIP-Exempt Natural Gas Customers The Company s proposed plan modification to provide rebates and claim energy savings for customers that install ASHP and have a heating system supplied by a delivered fuel or CIP-exempt natural gas utility raises a number of issues. Chief among these issues is that the proposal would amount to the use of CIP funding to incentivize switching from one fuel source to another, an action currently allowed only under very limited circumstances. In a March 7, 2005, order issued by the Department, following a long, multi-year stakeholder discussion on issues surrounding fuel-switching, the Department determined that targeted fuel-switching projects are not allowed in the Conservation Improvement Program. 1 As noted in CenterPoint Energy s comments in response to the Company s filing, fuel switching has been defined as a utility s promotion of a measure that will result in a greater increase in that utility s energy sales than if the measure had not been implemented. 2 The Company s proposed program expansion to include delivered fuel and non-cip natural gas customers conflicts with this guidance and would increase Company s energy sales. A very narrow exception to the CIP fuel-switching order was outlined through additional Department guidance issued on August 3, Consistent with recommendations from the 2011 Minnesota Environmental Initiative 1.5 percent Energy Efficiency Solution Project, 4 the Department determined that electric utilities may provide direct space heating and domestic hot water energy savings measures to low-income delivered fuel customers and low-income small natural gas municipal utility customers offered in conjunction with the Weatherization Assistance Program. The Department also stated that utilities may claim the energy savings from those measures towards their CIP energy savings goals. This exception does not apply to the Company s proposal, however, because the Company proposes targeting all delivered fuel or CIP-exempt natural gas customers, regardless of economic status. 1 In the Matter of Comments Concerning Btu Comparisons in Cost-Benefit Analysis for Conservation Improvement Programs, Docket No. G008/CIP , Ordering Point 1 (March 7, 2005). 2 Center Point Energy s Comments on Otter Tail Power Company s Minnesota Conservation Improvement Program Modification Request p. 2 (January 16, 2018). 3 CIP Policy Guidelines: Energy Savings from Delivered Fuels, Department of Commerce Policy Guidance (August 3, 2012). 4 Minnesota Environmental Initiative 1.5% Energy Efficiency Solutions Project, Final Report (March 2011).

4 In its Reply Comments, the Company also cited an order issued by the Department on November 22, In that order, the Department found that the Company was justified to offer an incentive for high efficiency air source and ground source heat pump installation to delivered fuel customers. Unlike the 2005 order and the 2012 guidance, this order was directed specifically toward the Company through the approval of its CIP plan and, as far as Staff were aware, was not approved or referenced in any subsequent CIP plans. While this order and the 2012 guidance appear to be at odds with each other, Staff contended that the more recently issued and more frequently referenced statewide guidance released in 2012 (and the original language contained in the 2005 order) currently governs CIP fuel switching matters. Staff also contends that until such time that the Department formally issues a decision directed at all CIP regulated utilities modifying or expanding the 2012 guidance, fuel switching in CIP is limited only to those electric customers identified in the 2012 guidance. Based on its analysis of the Company s proposal, comments submitted by interested parties, and a review of applicable statute, rules and previously issued Department policy guidance, Staff recommended that the Company s program modification request to provide rebates and claim energy savings for customers that install ASHP and have a heating system supplied by a delivered fuel or CIPexempt natural gas utility be denied. 2. ASHP Pilot Program In response to the Company s modification request, CEE submitted comments proposing a limited pilot study allow[ing] Otter Tail Power to provide rebates and claim the associated savings, using revised energy-savings calculations and assumptions, for customers who install an air source heat pump and have a heating system supplied by a delivered fuel or a CIP-exempt natural gas [utility]. 6 In its Reply Comments, Fresh Energy supported the concept of approving Company s modification request in the form of a limited pilot study, presumably, in a manner similar to that laid out by CEE. 7 Staff had several concerns about funding this type of pilot study through CIP. First, the basis of the study is contrary to current Department guidance prohibiting fuel switching within the CIP program. Second, approving a pilot study of this nature begins to pre-empt future, stakeholder-wide discussions around fuel switching and could mistakenly signal movement on behalf of the Department toward allowing certain instances of fuel switching. Third, approving this pilot study would set precedent for the approval of other pilot studies that involve fuel-switching scenarios. For these reasons, Staff recommended not approving the type of ASHP pilot study outlined in CEE s comments. 3. Stakeholder Process All stakeholders submitting comments in response to the proposed modification demonstrated support for a Department-led stakeholder process focusing on issues concerning fuel switching through CIP. Comments submitted in response to the Company s proposed modification highlighted the complexity of fuel switching, particularly with the increasing interest around the concept of beneficial electrification, where electrifying end-uses that have historically been powered by fossil fuel resources (e.g. space and water heating and vehicles) could result in significant emissions reductions, system efficiency gains, and additional flexibility in the grid. To begin exploring what this concept could mean 5 In the Matter of the Implementation of Otter Tail Power Company s Conservation Improvement Program, Docket No. E017/CIP (November 22, 2010). 6 Center for Energy and Environment Comments in the Matter of Otter Tail Power Company s Conservation Improvement Program: Modification Request p. 1 (January 16, 2018). 7 Fresh Energy Reply Comments in the Matter of Otter Tail Power Company s Conservation Improvement Program: Modification Request (January 31, 2018). 4

5 for Minnesota, the Department has commissioned a white paper to better understand the possible metrics, end-uses, and policy considerations associated with electrification. The Department has also submitted a proposal to the U.S. Department of Energy to fund a two-year stakeholder process focused on electrification. Staff agreed with stakeholder comments, however, that a more immediate stakeholder process around fuel switching is needed that can, at the very least, provide some guidance to CIP stakeholders as planning for the triennial commences. To that end, Staff recommended that the Department convene a stakeholder meeting on or before May 1, 2018, to identify key issues and concerns around fuel switching and develop a process and timeline with which to address these issues. Staff asked that interested stakeholders include in their comments to the Proposed Decision: 1. Issues and concerns relating to fuel switching that they would like to see addressed as part of this stakeholder process. (For those stakeholders identifying multiple issues and concerns, please list them in order of priority.) 2. Preferences on whether this process should be facilitated by a third party. 3. Suggestions for how this process should be funded. c. Deputy Commissioner s Determinations 1. ASHP Rebates to Delivered Fuel or CIP-Exempt Natural Gas Customers The Deputy Commissioner appreciates the comments submitted by CEE, CenterPoint Energy, Fresh Energy, the Company, and Xcel in response to Staff s Proposed Decision. For the reasons stated above, the Deputy Commissioner agrees with Staff s analysis that the Company s proposal to provide ASHP rebates to delivered fuel or CIP-exempt natural gas customers and claim energy savings through CIP is currently prohibited by the 2005 order issued by the Department. Because of this, the Company s request is denied. In comments responding to Staff s Proposed Decision, the Company requested that in the alternative it be allowed to provide ASHP rebates to delivered fuel and CIP-exempt natural gas customers to replace standard cooling equipment. In its proposal, the Company would only claim energy and demand savings associated with space cooling for these customers, not heating. The Company provided the following information on the cost-effectiveness of this proposed modification: Table 1: Cost-Effectiveness of ASHP Program for Cooling Residential Cooling Savings Only Utility Test Ratepayer Test Societal Test Participant Test Commercial Cooling Savings Only Utility Test Ratepayer Test Societal Test Participant Test The Department requires that utility conservation programs be cost-effective at the market segment level (residential, commercial, etc.) Therefore, certain programs or measures that are not cost effective may be included in CIP portfolios provided that the overall market segment is cost effective. The Company s residential and commercial market segments will remain cost-effective with the inclusion of ASHP for cooling purposes. Therefore, the Deputy Commissioner approves the Company s request to provide rebates for ASHP and claim associated cooling energy savings. 5

6 2. ASHP Pilot Program In response to the Company s modification request, CEE submitted comments proposing a limited pilot study as described above. In the Proposed Decision, Staff recommended not approving the study. The Deputy Commissioner agrees with staff s recommendation and reasoning. Therefore, approval for CEE s proposed pilot study is denied. 3. Stakeholder Process All stakeholders submitting comments in response to the proposed modification expressed support for a stakeholder process that can begin to address or at least prioritize issues around fuel switching. The Deputy Commissioner thanks stakeholders for the thoughtful responses to Staff s questions and agrees that an immediate stakeholder process to help inform IOU triennial planning and COU annual planning is needed. The Deputy Commission instructs staff to convene a stakeholder meeting on or before June 1, 2018 to develop a process and timeline with which to discuss and address issues concerning fuel switching within the CIP program. III. ANALYSIS POP SOLAR a. Background The 2017 Minnesota Energy Omnibus bill signed on May 30, 2017 included a provision to end the Made in Minnesota (MiM) solar program for the three Minnesota electric investor-owned utilities. The Company s CIP Plan included five percent of the minimum CIP spending requirement to the MiM solar program and an additional five percent to the Company s POP Solar program. The Company requests the movement of the MiM budget of $114,860 to the POP Solar program. Table 2 shows the approved budgets, savings, and participants for the two programs and the proposed values for the POP Solar program. Table 2. MiM and POP Solar Budget and Savings MiM Approved Budget $114,860 $114,860 $114,860 MiM Approved Savings 78,000 78,000 78,000 POP Solar Approved Budget $114,860 $114,860 $114,860 POP Solar Approved Savings 107, , ,250 POP Solar Approved Participation POP Solar Proposed Budget $229,720 $229,720 $229,720 POP Solar Proposed Savings 224, , ,250 POP Solar Proposed Participation b. Staff s Proposed Decision Staff recommended approval of the Company s proposal. The additional funds to the POP Solar program will slightly increase the B/C ratios for the program except for the Participant Test as shown in Table 5. 6

7 Table 3. POP Solar Program Benefit Cost Ratios Ratepayer Utility Test Impact Test Societal Test Participant Test Approved Proposed c. Deputy Commissioner s Determinations The Deputy Commissioner agrees with Staff s analysis and approves transfer of the MiM solar program funds to the Company s POP Solar Program. IV. ANALYSIS GEOTHERMAL HEAT PUMP MEASURE LIVES a. Background The Company requested an update to the measure lives of its geothermal heat pump measures from 18 years to 25 years. According to ASHRAE s Service Life Data Tool, the median age at time of removal for water-to-air geothermal heat pump installations is 25 years, and the average age at time of removal for the same system is 27.6 years. Table 4 details the changes in the benefit cost ratios due to this change. Residential Heat Pumps Approved Residential Heat Pumps Proposed Commercial Heat Pumps Approved Commercial Heat Pumps Proposed Table 4. Geothermal Heat Pump 2018 B/C Ratio Tests Societal Test Utility Test Participant Test Ratepayer Impact Test b. Staff s Proposed Decision The Department has previously ordered that the maximum measure life input into the BenCost model should be 20 years in most cases. 8 The Department s Order listed the following reasons for limiting measures to a 20-year life: a) benefits are more uncertain the further out in time the model is extended; b) benefit streams diminish further out in time and have lesser effects on cost-effectiveness than more current years; c) the further out in time the model is extended, the more uncertain it becomes that current ratepayers, who are funding CIP, receive the full benefits of CIP; and d) if a project cannot pay for itself within 20 years, ratepayers should instead be funding other, more cost-effective projects. 8 In the Matter of Inputs to Bencost for Natural Gas CIPs for the Conservation Improvement Program Triennium, DOC No. G999/CIP-16-36, Deputy Commissioner Decision (February 19, 2016). 7

8 Staff recommended that the Deputy Commissioner allow the Company to increase the ground source heat pump measure life to 20 years. c. Deputy Commissioner s Determinations The Deputy Commissioner agrees with Staff s analysis and approves an increase of the ground source heat pump measure life to 20 years. V. ANALYSIS COMMERCIAL DESIGN ASSISTANCE a. Background The Company requested that the existing Commercial Design Assistance (CDA) program be modified by classifying the program as a non-direct impact program and relaunching it as the Integrated Building Design Plus (IBD Plus) program in 2018 and The program will provide incentives for energy efficient lighting, motors, adjustable speed drives, air source heat pumps, geothermal heat pumps, and custom measures through the Company s existing prescriptive and custom efficiency programs. Table 3 details the transfer of budget and savings from the CDA program to new construction lighting, adjustable speed drives, motors, and custom efficiency grants. Table 3. Commercial Design Assistance Savings Transfer Approved Savings Proposed Savings Program Commercial Design Assistance 1,417,341 1,417, Adjustable Speed Drives 5,412,302 5,412,302 5,563,485 5,563,485 Custom Efficiency Grants 1,937,520 1,937,520 2,389,608 2,389,608 Lighting New Construction 2,834,125 2,834,125 3,625,635 3,625,635 Motors 731, , , ,519 b. Staff s Proposed Decision Staff recommended approving the change of CDA to a non-direct impact program. This change is accompanied by the Company increasing its training and outreach efforts with architectural and engineering professionals. c. Deputy Commissioner s Determinations The Deputy Commissioner agrees with Staff s analysis and approves the change of CDA to a non-direct impact program. VI. ANALYSIS DISCOUNT RATE a. Background Otter Tail has also updated its discount rate from 8.61 percent to 7.51 percent to reflect the retail rates and the cost of capital approved in its 2016 general rate case. 9 Table 4 shows the new B/C ratios for the Company s program offerings. 9 Docket No. E017/GR

9 Table 4. Program Benefit Cost Ratios Ratepayer Impact Test Societal Test Participant Test Utility Test Residential Air Conditioning Control inf. Appliance Recycling inf. Be Bright Electronically Commutated Motors Energy Feedback Program inf. Residential Heat Pumps Home Insulation Home Transformer School Kits Program inf. Smart Thermostats (Pilot) Water Heater Store & Save inf. Total Residential Low-Income House Therapy inf. Total Low-Income inf. Commercial Adjustable Speed Drives Commercial Cool Savings inf. Commercial Design Assistance Commercial Direct Install (Pilot) inf. Compressed Air Efficiency (Pilot) Custom Effiency Grants Commercial Heat Pumps Commercial & Industrial Process Efficiency Lighting Lighting - New Construction Midstream Commercial Kitchen Equipment Motors Recommissioning Refrigeration Roof Top Unit Efficiency (Pilot) Total Commercial Other Company-Owned Street & Area Lighting inf. Publicly-Owned Property Solar Total Other Total - All CIP b. Staff s Proposed Decision Staff recommended approval of the change of the discount rate to represent current market values and trends. 9

10 c. Deputy Commissioner s Determinations The Deputy Commissioner agrees with Staff s analysis and approves the change of the discount rate to represent current market trends. VII. DEPUTY COMMISSIONER S ORDER POINTS Heat Pumps The Company s proposal to provide ASHP rebates to delivered fuel or CIP-exempt natural gas customers and claim energy savings through CIP is denied. The Company s request to provide ASHP rebates to delivered fuel and CIP-exempt natural gas customers to replace standard cooling equipment is approved. CEE s proposal to conduct an ASHP pilot study to determine performance when combined with delivered fuels or natural gas as a secondary heating source is denied. Staff will convene a stakeholder meeting on or before June 1, 2018 to develop a process and timeline with which to discuss and address issues concerning fuel switching within the CIP program. POP Solar The Company s request to transfer MiM solar program funds to the Company s POP Solar Program is approved. Geothermal Heat Pump Measure Lives The ground source heat pump measure life will be increased to 20 years. Commercial Design Assistance The Company s request to change the Commercial Design Assistance to a non-direct impact program is approved. Discount Rate The Company s request to change the discount rate to represent current market trends is approved. The Deputy Commissioner thanks Staff and stakeholders for their analysis and comments concerning this important issue and looks forward to future discussions on this topic. BY ORDER OF THE DEPUTY COMMISSIONER William Grant Deputy Commissioner, Minnesota Department of Commerce, Division of Energy Resources 10

11 CERTIFICATE OF SERVICE I, Sharon Ferguson, hereby certify that I have this day, served copies of the following document on the attached list of persons by electronic filing, certified mail, , or by depositing a true and correct copy thereof properly enveloped with postage paid in the United States Mail at Minnesota. Minnesota Department of Commerce Decision Docket No. E017/CIP Dated this 19 th day of April 2018 /s/sharon Ferguson

12 Tom Balster om Interstate Power & Light Company PO Box st St SE Cedar Rapids, IA Lisa Beckner Minnesota Power 30 W Superior St Duluth, William Black bblack@mmua.org MMUA Suite Harbor Lane North Plymouth, Christina Brusven cbrusven@fredlaw.com Fredrikson Byron 200 S 6th St Ste Ray Choquette rchoquette@agp.com Ag Processing Inc West Dodge Road PO Box 2047 Omaha, NE Generic Notice Commerce Attorneys commerce.attorneys@ag.st ate.mn.us Office of the Attorney General-DOC 445 Minnesota Street Suite Electronic Service Yes OFF_SL_16- Gary Connett gconnett@grenergy.com Great River Energy Elm Creek Blvd N George Crocker gwillc@nawo.org North American Water Office Carl Cronin Regulatory.records@xcele nergy.com Maple Grove, PO Box 174 Lake Elmo, Xcel Energy 414 Nicollet Mall FL Jill Curran jcurran@mnchamber.com Minnesota Waste Wise 400 Robert Street North Suite 1500 Minnesota 55101

13 Leigh Currie Minnesota Center for Environmental Advocacy 26 E. Exchange St., Suite 206 Minnesota Ian Dobson e.mn.us Office of the Attorney General-RUD 1400 BRM Tower 445 Minnesota St Steve Downer MMUA 3025 Harbor Ln N Ste 400 Charles Drayton charles.drayton@enbridge. com Enbridge Energy Company, Inc. Plymouth, France Ave S Ste 600 Electronic Service Yes OFF_SL_16- Edina, Jim Erchul jerchul@dbnhs.org Daytons Bluff Neighborhood Housing Sv. Greg Ernst gaernst@q.com G. A. Ernst & Associates, Inc. 823 E 7th St Union Lake Trl Northfield, Melissa S Feine melissa.feine@semcac.org SEMCAC PO Box S Elm St Rushford, Sharon Ferguson sharon.ferguson@state.mn.us Angela E. Gordon angela.e.gordon@lmco.co m Department of Commerce 85 7th Place E Ste 280 Lockheed Martin Saint Paul, Clark Ave. St. Louis, MO

14 Pat Green N/A N Energy Dev City Hall 401 E 21st St Hibbing, Jason Grenier jgrenier@otpco.com Otter Tail Power Company 215 South Cascade Street Stephan Gunn sgunn@appliedenergygrou p.com Tony Hainault anthony.hainault@co.henn epin.mn.us Applied Energy Group Tyler Hamman tylerh@bepc.com Basin Electric Power Cooperative Fergus Falls, Pike Ln De Pere, WI Hennepin County DES 701 4th Ave S Ste E Interstate Ave Bismarck, ND Patty Hanson phanson@rpu.org Rochester Public Utilities 4000 E River Rd NE Rochester, Norm Harold N/A NKS Consulting 5591 E 180th St Prior Lake, Scott Hautala scotth@hpuc.com Hibbing Public Utilities 1902 E 6th Ave Kimberly Hellwig kimberly.hellwig@stoel.co m Jared Hendricks hendricksj@owatonnautiliti es.com Stoel Rives LLP Hibbing, South Sixth Street Suite Owatonna Public Utilities PO Box S Walnut Ave Owatonna, Paper Service No OFF_SL_16- Paper Service No OFF_SL_16-3

15 Holly Hinman Xcel Energy Karolanne Hoffman Dairyland Power Cooperative Jim Horan Minnesota Rural Electric Association Dave Johnson Arrowhead Economic Opportunity Agency 414 Nicollet Mall, 7th Floor PO Box 817 La Crosse, WI rd Ave N Maple Grove, rd Ave S Virginia, Joel W. Kanvik joel.kanvik@enbridge.com Enbridge Energy LLC 4628 Mike Colalillo Dr Duluth, Deborah Knoll dknoll@mnpower.com Minnesota Power 30 W Superior St Duluth, Tina Koecher tkoecher@mnpower.com Minnesota Power 30 W Superior St Duluth, Kelly Lady kellyl@austinutilities.com Austin Utilities 400 4th St NE Martin Lepak Martin.Lepak@aeoa.org Arrowhead Economic Opportunity Nick Mark nick.mark@centerpointener gy.com CenterPoint Energy Austin, S 3rd Ave Virginia, Nicollet Mall

16 Pam Marshall Energy CENTS Coalition 823 7th St E Scot McClure scotmcclure@alliantenergy. com Interstate Power And Light Company John McWilliams jmm@dairynet.com Dairyland Power Cooperative N Biltmore Ln PO Box Madison, WI East Ave SPO Box 817 La Crosse, WI Brian Meloy brian.meloy@stinson.com Stinson,Leonard, Street LLP 50 S 6th St Ste David Moeller dmoeller@allete.com Minnesota Power 30 W Superior St Andrew Moratzka andrew.moratzka@stoel.co m Susan K Nathan snathan@appliedenergygro up.com Duluth, Stoel Rives LLP 33 South Sixth St Ste 4200 Applied Energy Group Carl Nelson cnelson@mncee.org Center for Energy and Environment Samantha Norris samanthanorris@alliantene rgy.com Interstate Power and Light Company NE 107th Ter Kansas City, MO rd Ave N Ste st Street SE PO Box 351 Cedar Rapids, IA

17 Audrey Partridge Center for Energy and Environment Lisa Pickard Minnkota Power Cooperative 212 3rd Ave. N. Suite 560 Minnesota Mill Rd PO Box Grand Forks, ND Bill Poppert Technology North 2433 Highwood Ave Dave Reinke m Christopher Schoenherr g Cindy Schweitzer Rott lt.com Ken Smith om Russ Stark s Dakota Electric Association SMMPA CLEAResult's th St W Farmington, First Ave SW Rochester, S12637A Merrilee Rd. Spring Green, WI District Energy St. Paul Inc. 76 W Kellogg Blvd City of St. Paul City Hall 15 West Kellogg Boulevard Saint Paul, Richard Szydlowski N/A Center for Energy & Environment Michael Volker mvolker@eastriver.coop East River Electric Power Coop 212 3rd Ave N Ste S. Harth Ave Madison, SD Paper Service No OFF_SL_16-6

18 Sharon N. Walsh om Robyn Woeste y.com Shakopee Public Utilties Interstate Power and Light Company 255 Sarazin St Shakopee, First St SE Cedar Rapids, IA Daniel P Wolf dan.wolf@state.mn.us Public Utilities Commission 121 7th Place East Suite Electronic Service Yes OFF_SL_16-7

19 Tom Balster om Interstate Power & Light Company PO Box st St SE Cedar Rapids, IA Lisa Beckner Minnesota Power 30 W Superior St Duluth, William Black bblack@mmua.org MMUA Suite Harbor Lane North Plymouth, Christina Brusven cbrusven@fredlaw.com Fredrikson Byron 200 S 6th St Ste Charlie Buck charlie.buck@oracle.com Oracle 760 Market St FL 4 San Francisco, CA Ray Choquette rchoquette@agp.com Ag Processing Inc West Dodge Road PO Box 2047 Omaha, NE Generic Notice Commerce Attorneys commerce.attorneys@ag.st ate.mn.us Office of the Attorney General-DOC 445 Minnesota Street Suite Gary Connett gconnett@grenergy.com Great River Energy Elm Creek Blvd N George Crocker gwillc@nawo.org North American Water Office Carl Cronin Regulatory.records@xcele nergy.com Maple Grove, PO Box 174 Lake Elmo, Xcel Energy 414 Nicollet Mall FL

20 Jill Curran Minnesota Waste Wise 400 Robert Street North Suite 1500 Minnesota Leigh Currie Minnesota Center for Environmental Advocacy 26 E. Exchange St., Suite 206 Minnesota Ian Dobson e.mn.us Office of the Attorney General-RUD 1400 BRM Tower 445 Minnesota St Steve Downer MMUA 3025 Harbor Ln N Ste 400 Charles Drayton charles.drayton@enbridge. com Enbridge Energy Company, Inc. Plymouth, France Ave S Ste 600 Edina, Jim Erchul jerchul@dbnhs.org Daytons Bluff Neighborhood Housing Sv. Greg Ernst gaernst@q.com G. A. Ernst & Associates, Inc. 823 E 7th St Union Lake Trl Northfield, Melissa S Feine melissa.feine@semcac.org SEMCAC PO Box S Elm St Rushford, Sharon Ferguson sharon.ferguson@state.mn.us Department of Commerce 85 7th Place E Ste 280 Saint Paul,

21 Angela E. Gordon m Lockheed Martin 1000 Clark Ave. St. Louis, MO Pat Green N/A N Energy Dev City Hall 401 E 21st St Hibbing, Jason Grenier jgrenier@otpco.com Otter Tail Power Company 215 South Cascade Street Stephan Gunn sgunn@appliedenergygrou p.com Tony Hainault anthony.hainault@co.henn epin.mn.us Applied Energy Group Tyler Hamman tylerh@bepc.com Basin Electric Power Cooperative Fergus Falls, Pike Ln De Pere, WI Hennepin County DES 701 4th Ave S Ste E Interstate Ave Bismarck, ND Patty Hanson phanson@rpu.org Rochester Public Utilities 4000 E River Rd NE Rochester, Norm Harold N/A NKS Consulting 5591 E 180th St Prior Lake, Scott Hautala scotth@hpuc.com Hibbing Public Utilities 1902 E 6th Ave Kimberly Hellwig kimberly.hellwig@stoel.co m Stoel Rives LLP Hibbing, South Sixth Street Suite Paper Service No SPL_SL CIP SPECIAL Paper Service No SPL_SL CIP SPECIAL 3

22 Jared Hendricks es.com Karolanne Hoffman Dairyland Power Cooperative Jim Horan Minnesota Rural Electric Association Dave Johnson Arrowhead Economic Opportunity Agency Owatonna Public Utilities PO Box S Walnut Ave Owatonna, PO Box 817 La Crosse, WI rd Ave N Maple Grove, rd Ave S Virginia, Joel W. Kanvik joel.kanvik@enbridge.com Enbridge Energy LLC 4628 Mike Colalillo Dr Duluth, Deborah Knoll dknoll@mnpower.com Minnesota Power 30 W Superior St Duluth, Tina Koecher tkoecher@mnpower.com Minnesota Power 30 W Superior St Duluth, Kelly Lady kellyl@austinutilities.com Austin Utilities 400 4th St NE Erica Larson erica.larson@centerpointen ergy.com CenterPoint Energy Martin Lepak Martin.Lepak@aeoa.org Arrowhead Economic Opportunity Austin, Nicollet Avenue P.O. Box Minnesota S 3rd Ave Virginia,

23 Nick Mark gy.com CenterPoint Energy 505 Nicollet Mall Pam Marshall Energy CENTS Coalition 823 7th St E Scot McClure scotmcclure@alliantenergy. com Interstate Power And Light Company John McWilliams jmm@dairynet.com Dairyland Power Cooperative N Biltmore Ln PO Box Madison, WI East Ave SPO Box 817 La Crosse, WI Brian Meloy brian.meloy@stinson.com Stinson,Leonard, Street LLP 50 S 6th St Ste David Moeller dmoeller@allete.com Minnesota Power 30 W Superior St Andrew Moratzka andrew.moratzka@stoel.co m Susan K Nathan snathan@appliedenergygro up.com Duluth, Stoel Rives LLP 33 South Sixth St Ste 4200 Applied Energy Group Carl Nelson cnelson@mncee.org Center for Energy and Environment NE 107th Ter Kansas City, MO rd Ave N Ste

24 Samantha Norris rgy.com Interstate Power and Light Company 200 1st Street SE PO Box 351 Cedar Rapids, IA Matt Okeefe Oracle 760 Market St FL 4 Audrey Partridge apartridge@mncee.org Center for Energy and Environment Lisa Pickard lpickard@minnkota.com Minnkota Power Cooperative San Francisco, CA rd Ave. N. Suite 560 Minnesota Mill Rd PO Box Grand Forks, ND Bill Poppert info@technologycos.com Technology North 2433 Highwood Ave Kathleen A Prestidge Kathy.Prestidge@stoel.co m Dave Reinke dreinke@dakotaelectric.co m Christopher Schoenherr cp.schoenherr@smmpa.or g Cindy Schweitzer Rott cindy.schweitzer@clearesu lt.com Ken Smith ken.smith@districtenergy.c om Stoel Rives LLP 33 S 6th St Ste 4200 Dakota Electric Association SMMPA CLEAResult's th St W Farmington, First Ave SW Rochester, S12637A Merrilee Rd. Spring Green, WI District Energy St. Paul Inc. 76 W Kellogg Blvd

25 Anna Sommer Sommer Energy LLC PO Box 766 Russ Stark s City of St. Paul Richard Szydlowski N/A Center for Energy & Environment Grand Canyon, AZ City Hall 15 West Kellogg Boulevard Saint Paul, rd Ave N Ste Kodi Verhalen kverhalen@briggs.com Briggs & Morgan 2200 IDS Center Michael Volker mvolker@eastriver.coop East River Electric Power Coop Sharon N. Walsh swalsh@shakopeeutilities.c om Ethan Warner ethan.warner@centerpoint energy.com Robyn Woeste robynwoeste@alliantenerg y.com Shakopee Public Utilties CenterPoint Energy Interstate Power and Light Company 80 South Eighth Street Minnesota S. Harth Ave Madison, SD Sarazin St Shakopee, Nicollet Mall Minnesota First St SE Cedar Rapids, IA Daniel P Wolf dan.wolf@state.mn.us Public Utilities Commission 121 7th Place East Suite Paper Service No SPL_SL CIP SPECIAL 7