OES Staff also reviewed whether Minnesota Municipal Power Agency s 2008 CIP report:

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1 April 3, 2009 Kim Lillyblad Minnesota Municipal Power Agency 200 South Sixth Street, Suite 300 Minneapolis, MN RE: Docket No. E,G999/CIP Dear Ms. Lillyblad: The Conservation Improvement Program (CIP) is an important component of Minnesota s focus on ensuring a reliable, low-cost, environmentally-superior source of energy for Minnesota consumers. Cooperative and municipal utilities play a significant role in this effort, investing over $35 million annually in CIP. The Next Generation Energy Act of 2007 implemented a number of changes to the CIP requirements. Most significant of these changes was the establishment of an annual energy savings goal of 1.5 percent of average retail sales for all utilities and associations that begins in Although the minimum spending obligations that existed prior to 2007 remain in place, the enactment of the savings goal provision effectively changed the focus of CIP from meeting a spending goal to meeting a savings goal. Staff of the Office of Energy Security (OES) reviewed Minnesota Municipal Power Agency s 2008 CIP report to assess whether it meets CIP statutory requirements and to offer suggestions for improving the utility s CIP. Central to their review was whether the utility is demonstrating a good faith effort to expand its program activities in anticipation of the 1.5 percent savings goal. OES Staff also reviewed whether Minnesota Municipal Power Agency s 2008 CIP report: Meets the CIP statutory requirements; Accurately records energy savings data for each direct savings project; Results in cost-effective energy savings for the customers; Contains projects that are available to all customer classes and reflect the customer mix of the individual utility; and Aggressively sets goals for increasing energy savings and overall cost-effectiveness. Based on Staff s review, it appears that Minnesota Municipal Power Agency (MMPA) is making significant progress towards achieving the 1.5 percent savings goal in 2010 and beyond. MMPA achieved savings of 0.13 percent in 2006, 0.32 percent in 2007, and plans to increase its energy savings to 1.56 percent of 2005 through 2007 average retail energy sales by In addition, MMPA will increase its CIP investments from $0.68 million in 2007 to over $1 million in 2010.

2 Kim Lillyblad April 3, 2009 Page 2 I am pleased to see MMPA s continued commitment to CIP, and I encourage MMPA to continue exploring additional ways to achieve energy savings and improve the overall cost-effectiveness of its CIP. OES is happy to work with you on identifying and evaluating new opportunities. Please contact Laura Silver at if you have any questions regarding the attached Comments. Sincerely, /s/ GLENN WILSON Commissioner Minnesota Department of Commerce WG/LS/jl Attachment

3 CONCLUSIONS AND RECOMMENDATIONS OF THE MINNESOTA DEPARTMENT OF COMMERCE REGARDING MINNESOTA MUNICIPAL POWER AGENCY S 2008 CIP REPORT DOCKET NO. E,G999/CIP Staff of the Office of Energy Security (Staff) present the following Conclusions and Recommendations regarding Minnesota Municipal Power Agency s (MMPA) 2008 Conservation Improvement Program (CIP) Report. Staff present these Conclusions and Recommendations in five sections: Introduction; Compliance with Minnesota Statutes; Programmatic Analysis; Project Review; and Conclusions and Recommendations. I. INTRODUCTION A. BACKGROUND The seven MMPA members, Brownton Municipal Light & Power, City of Arlington, City of Buffalo, City of Chaska, City of North St. Paul, City of Winthrop, and Le Sueur Municipal Utilities, collectively submitted their electric CIP pursuant to Minnesota Statutes 216B.241, subd. 1b(f). While approval of MMPA s CIP by the Office of Energy Security (OES) is not required, OES s review is offered to address compliance with section 216B.241 and provide suggestions for improving MMPA s overall CIP.

4 Page 2 B. SUMMARY OF CIP MMPA s actual and planned CIP budgets, energy savings, and participation figures for are listed below in Table 1. As indicated, MMPA plans to increase its energy savings from approximately 2,045,632 kwh in 2007 to 10,004,463 kwh in MMPA plans to increase its budget from $681,336 to $1,075,900 during this same period. Table 1: Summary of MMPA s Actual and Planned CIP for Program Name Actual Actual Planned Planned Planned Energy Star Rebate Program - Refrigerators Budget $9,123 $11,508 $15,332 $6,000 $0 Energy Savings (kwh) 10,624 12,035 14,193 5,893 0 Demand Savings (kw) Participation Energy Star Rebate Program - Dishwashers Budget $7,555 $10,397 $13,851 $6,000 $0 Energy Savings (kwh) 14,522 17,947 21,098 9,727 0 Demand Savings (kw) Participation Energy Star Rebate Program - Clothes Washers Budget $17,024 $25,837 $34,421 $12,000 $0 Energy Savings (kwh) 21,195 28,888 34,069 12,560 0 Demand Savings (kw) Participation Energy Star Rebate Program - Window A/Cs Budget $444 $604 $805 $0 $0 Energy Savings (kwh) Demand Savings (kw) Participation Energy Star Rebate Program - Commercial Motors Budget $995 $1,397 $1,860 $30,000 $55,000 Energy Savings (kwh) 10,000 20,000 20, , ,000 Demand Savings (kw) Participation Energy Star Rebate Program - Central A/Cs Budget $88,344 $83,885 $111,753 $30,000 $0 Energy Savings (kwh) 88,704 72,960 86,016 24,576 0 Demand Savings (kw) Participation Commercial & Industrial Lighting Program Budget $191,883 $160,488 $213,805 $360,000 $660,000 Energy Savings (kwh) 711,284 1,003,329 1,620,000 3,185,000 7,575,000 Demand Savings (kw) Participation Home Energy Audit Budget $0 $5,653 $7,532 $30,000 $55,000 Energy Savings (kwh) Demand Savings (kw) Participation CFL Bulb Purchase Program Budget $0 $12,903 $17,189 $30,000 $110,000 Energy Savings (kwh) 0 77,932 91, , ,463 Demand Savings (kw) Participation 0 2,007 2,364 4,387 18,271

5 Page 3 Table 1: Summary of MMPA s Actual and Proposed CIP for (cont'd) Program Name Actual Actual Planned Planned Planned Traffic and Outdoor Lighting Program Budget $0 $4,448 $5,926 $12,000 $30,900 Energy Savings (kwh) 0 102, , , ,000 Demand Savings (kw) Participation Other/Custom Programs Budget $2,632 $23,548 $31,371 $84,000 $165,000 Energy Savings (kwh) 0 710, , ,000 1,000,000 Demand Savings (kw) Participation Demand Curtailment Program* Budget $318,000 $340,668 $453,845 $400,000 $0 Energy Savings (kwh) Demand Savings (kw) Participation All Conservation Projects Budget $318,000 $340,668 $453,845 $600,000 $1,075,900 Energy Savings (kwh) 856,689 2,045,632 2,237,690 4,258,103 10,004,463 Demand Savings (kw) Participation 630 2,729 3,214 4,911 18,765 All Projects Budget $636,000 $681,336 $907,690 $1,000,000 $1,075,900 Energy Savings (kwh) 856,689 2,045,632 2,237,690 4,258,103 10,004,463 Demand Savings (kw) Participation 637 2,737 3,222 4,919 18,773 *Load management program II. COMPLIANCE WITH MINNESOTA STATUTES Staff reviewed MMPA s filing to assess compliance with Minnesota Statutes 216B.241 and 216B These statutes set forth the requirements for CIP compliance, including: A plan to achieve the 1.5 percent savings goal by 2010; Minimum spending level for the CIP; Maximum spending on load management projects; Minimum spending levels for projects focused on low-income customers; Investments in projects that encourage the use of fluorescent and high-intensity discharge lamps; A research and development spending cap; A requirement for projects that facilitate green building certifications; and A distributed and renewable generation spending cap.

6 Page 4 A. ENERGY SAVINGS GOAL Minnesota Statutes 216B.241, subd. 1c., establishes an annual energy savings goal of 1.5 percent of average retail sales for each utility or association beginning in The law allows the goal to be lowered based on certain factors, although 1.0 percent is the minimum level. The law also allows certain electric utility infrastructure and waste heat to electricity generation (EUI) projects to count towards the savings goal, though demand-side management (DSM) projects must account for at least 1.0 percent. Staff note that MMPA s CIP does not include any EUI projects. Average retail sales are to be calculated based on the most recent three-year period. For the 2008 CIP filings, the 2010 savings goal is therefore based on average retail sales 1. MMPA plans to meet the 2010, 1.5 percent energy savings goal. Table 2: MMPA's Energy Savings Goals Average Retail Sales 639,766, % Savings Goal 9,596,490 Year kwh % Avg Retail Sales 2010 Planned Total Savings 10,004, % 2010 EUI Savings % 2010 DSM Savings 10,004, % B. MINIMUM SPENDING REQUIREMENTS Minnesota Statutes 216B.241, subd. 1b(b)(2) requires cooperative electric associations to invest 1.5 percent of their gross operating revenues from service in Minnesota on energy conservation improvements. In light of the Legislature s emphasis on encouraging conservation to the maximum reasonable extent, 2 the OES interprets 1.5 percent to be a minimum spending level. In addition, Minnesota Statutes 216B.241 subd. 1b(f) allows: A municipal power agency or other not-for-profit entity that provides energy service to municipal utilities that provide electric service at retail may invest in energy conservation improvements on behalf of the municipal utilities it serves and may fulfill the conservation, spending, report, and energy-savings goals on an aggregate basis, under an agreement between the municipal power agency or not-for-profit entity and each municipal utility for funding the investments. 1 The original version of the 2008 CIP Report form had an error in cell F/G45 of the Overview page. The text should have said Estimated average sales (kwh) and not Estimated average sales (kwh). Utilities were sent a memo asking them to report the estimated average sales (kwh) in cell H45 but not to worry about changing the text in cell F/G45. Staff assume that MMPA reported energy sales in this filing. 2 See Minn. Stat. 216B.03.

7 Page 5 Table 3 shows MMPA s minimum spending requirement and its aggregate actual and proposed CIP budgets. Staff conclude that MMPA met or plans to meet its minimum spending requirement for each year in the reporting period. Table 3: MMPA's Required CIP Spending 2005 GOR (basis fro 2006 and 2007 spending requirement) $35,302, GOR (basis fro 2008, 2009 and 2010 spending requirement) $56,636,211 Year 1.5% Spending Requirement CIP Budget % of GOR 2006 (actual) $529,530 $636, % 2007 (actual) $529,530 $681, % 2008 (planned) $849,543 $907, % 2009 (planned) $849,543 $1,000, % 2010 (planned) $849,543 $1,075, % C. MAXIMUM LOAD MANAGEMENT SPENDING Minnesota Statutes 216B.241, subd. 1b(e) sets the maximum expenditure levels for load management projects (those projects that are primarily intended to change the timing of energy use to reduce peak energy demand rather than conserve energy) at 50 percent of the conservation investment and spending requirements. This provision therefore effectively sets the minimum spending on conservation projects to 50 percent of the total CIP spending requirement. As indicated in Table 4, MMPA met or plans to meet this spending requirement in each year of the reporting period. Table 4: MMPA's Conservation Program Spending Year Min Conservation Spending Conservation Spending Load Mgmt Spending 2006 (actual) $264,765 $318,000 $318, (actual) $264,765 $340,668 $340, (planned) $424,772 $453,845 $453, (planned) $424,772 $600,000 $400, (planned) $424,772 $1,075,900 $0 D. LOW-INCOME AND RENTER SPENDING Minnesota Statutes 216B.241 subd. 1b(h) required that a portion of the money spent on residential conservation improvement programs is devoted to programs that directly address the needs of renters and low-income persons. The Next Generation Energy Act of 2007 removed this language and required that: A utility or association that furnishes electric service must spend at least 0.1 percent of its gross operating revenue from residential

8 Page 6 customers in the state on low-income programs. For a generation and transmission cooperative association, this requirement shall apply to each association's members' aggregate gross operating revenue from sale of electricity to residential customers in the state. Beginning in 2010, a utility or association that furnishes electric service must spend 0.2 percent of its gross operating revenue from residential customers in the state on low-income programs. 3 MMPA s CIP does not include a project exclusively dedicated to serving the needs of lowincome customers. Instead, MMPA estimates, using the method suggested by the Deputy Commissioner in a Letter to Municipal and Cooperative Utilities dated December 29, 2005 (Letter), that 10 percent of the participants of each residential CIP project in 2006 and 2007 are low-income. Staff note that in the Deputy Commissioner s Letter, the Deputy Commissioner approved use of the estimated method for small utilities that do not have budgets that allow the utility to offer more than one project or the administrative resources to oversee separate projects directed to low-income customers. MMPA offers a variety of projects and has combined budgets totaling more than $900,000 annually. Therefore, Staff recommend that MMPA develop a specific project dedicated to serving the needs of its low-income customers. Staff suggest that MMPA partner with the five local community action agencies in its members service areas to develop a weatherization program for low-income customers. A low-income project may include any or all of the following: audit and weatherization services; air conditioner tune-ups; installation of compact florescent and ENERGY STAR lighting; replacement and disposal of inefficient refrigerators; and/or other measures designed to improve energy efficiency and promote conservation in low-income households. Aggregating agencies or utilities often distribute funds proportionally to local community action program (CAP) agencies to support their weatherization programs. Staff understand that MMPA is planning such a program and are happy to assist MMPA in making contact with the appropriate agencies. 3 Minnesota Statutes 216B.241 subd. 7

9 Page 7 Table 5: CAP Agencies in MMPA Members Service Area Municipality County CAP Agency Brownton Municipal Light & Power McLeod Heartland Community Action Agency City of Arlington Sibley Minnesota Valley Action Council City of Buffalo Wright Wright County Community Action City of Chaska Carver Scott-Carver-Dakota CAP Agency City of North St Paul Ramsey Community Action Partnership of Ramsey and Washington Counties City of Olivia Renville Heartland Community Action Agency City of Winthrop Sibley Minnesota Valley Action Council Le Sueur Municipal Utilities Le Sueur Minnesota Valley Action Council E. EFFICIENT LIGHTING PROGRAM REQUIREMENTS Minnesota Statutes 216B.241, subd. 5, requires that the CIP of municipal utilities that provide electric service to retail customers strongly encourage the use of fluorescent and high-intensity discharge lamps. The program must include, at a minimum, a public information campaign to encourage use of the lamps and proper management of spent lamps by all customer classifications. MMPA s CIP includes the Commercial and Industrial Lighting Program, which fulfills part of this statutory requirement. Staff recommend that MMPA provide, if it is not already doing so, information about fluorescent bulb and lamp recycling to all of its lighting program participants. F. RESEARCH AND DEVELOPMENT SPENDING CAP Minnesota Statutes 216B.241, subd. 1b(d), states that no more than ten percent of a utility s minimum spending requirement may be spent on research and development (R&D) projects. MMPA s maximum allowable spending on electric R&D in 2008 through 2010 is $84,954. MMPA s CIP contains no allocation for R&D. Therefore, MMPA s CIP meets this requirement for all program years. G. ENERGY EFFICIENT BUILDING CERTIFICATION Minnesota Statutes 216B.241, subd. 1f(c) requires that utilities include in their CIPs projects that facilitate professional engineering verification to qualify buildings as ENERGY STARlabeled, Leadership in Energy and Environmental Design (LEED) certified, or Green Globescertified. The state goal is to achieve certification of 1,000 commercial buildings as ENERGY STAR -labeled, and 100 commercial buildings as LEED-certified or Green Globes-certified by December 31, 2010.

10 Page 8 MMPA s CIP does not contain a project that facilitates engineering verification for the building certifications listed above. Staff encourage East River to develop an ENERGY STAR-labeling program for existing buildings focused on low-cost/no-cost operations and maintenance (O&M) measures. Use of the ENERGY STAR Portfolio Manager and Minnesota B3 Database building benchmarking tools can help to identify high energy-using buildings that may be good candidates for O&M activities and verify reductions in energy use over time. H. RENEWABLE AND DISTRIBUTED GENERATION SPENDING CAP Minnesota Statutes 216B.2411 allows, but does not require, municipalities or rural electric cooperative associations to invest in renewable and distributed generation using a portion of their energy conservation improvement budgets. However, the amount that can be spent on these investments is limited to five percent of the total amount to be spent on energy conservation improvements. MMPA does not contain any expenses related to renewable generation. Therefore, MMPA s CIP meets this requirement for all program years. III. PROGRAMMATIC ANALYSIS A. OVERVIEW As shown in Table 1, MMPA s proposes to double energy savings in 2009 as compared to 2007 and then more than double energy savings between 2009 and MMPA proposes to increase its CIP budget by about $0.4 million between 2007 and B. CUSTOMER CLASS COVERAGE As part of their standard review of utility CIPs, Staff evaluate the proportion of CIP investment in each customer class (residential, commercial, industrial, farm, and other) relative to the utility s customer class make-up. Staff offer the following general commentary on the effectiveness of MMPA s CIP. As shown below in Table 6, MMPA s residential customers make up the largest share of its customer base while the commercial and industrial classes account for the majority of kwh sales. This is typical for many utilities.

11 Page 9 Table 6: MMPA's Customer Class Make-Up, 2007 (Based on Utility Reported Data) Customer Class # of Customers kwh sales Residential 22, ,817, % 31.29% Commercial 2, ,681, % 18.31% Industrial ,841, % 47.96% Farm 194 2,737, % 0.42% Other 98 13,063, % 2.02% Total 26, ,141,724 Table 7: MMPA's Actual and Proposed Spending by Customer Class, Year Residential Commercial/Industrial Other Total* 2006 (actual) $119, % $195, % $2, % $318, (actual) $148, % $164, % $27, % $340, (planned) $197, % $219, % $37, % $453, (planned) $113, % $390, % $96, % $600, (planned) $165, % $715, % $195, % $1,075,900 *Total does not include load management spending Tables 7 shows MMPA s spending by customer class throughout the reporting period. Staff are supportive of the proportion of programs that are targeted to commercial and industrial customers. Given the generally higher cost-effectiveness and savings potential of C/I projects, Staff recommend that MMPA continue to pursue these projects. C. ENERGY SAVINGS ASSUMPTIONS Based on the information provided, Staff believe that MMPA s savings estimates are generally reasonable. Staff appreciate the MMPA s use of established information sources. D. COST-EFFECTIVENESS One way Staff gauge the cost-effectiveness of a utility s CIP is to compare its spending per unit of energy saved to other utilities. The spending per kwh of electricity saved for conservation programs is shown in Table 8 below.

12 Page 10 Table 8: MMPA's spending per kwh Saved for Conservation Programs Year Residential C/I Other Total 2006 (actual) $0.90 $0.27 $0.00 $ (actual) $0.71 $0.16 $0.03 $ (planned) $0.81 $0.13 $0.11 $ (planned) $0.51 $0.12 $0.14 $ (planned) $0.23 $0.09 $0.14 $0.11 The overall spending per kwh saved reported in all Minnesota utility CIPs is shown in Table 9 at the end of this document. As can be seen, MMPA s overall CIP cost per kwh saved is high relative to other Minnesota utilities. Staff recommend that MMPA continue to evaluate the costeffectiveness of individual CIP programs, explore developing a set of cost-effective low-income weatherization programs, and continue to develop its commercial/industrial programs. IV. PROJECT REVIEW A. RESIDENTIAL REBATE PROGRAMS MMPA will provide rebates for residential customers purchasing ENERGY STAR refrigerators, dishwashers, clothes washers, and room and central air conditioners. While promotion of the ENERGY STAR label remains an important part of CIP, Staff note that many investor owned utilities are scaling back rebates for refrigerators and dishwashers because of their relative low energy savings and high market penetration compared to cost. In light of these facts, Staff suggest that MMPA modify its CIP for residential customers by scaling back rebates for refrigerators and dishwashers and adding one or more of the following: provide rebates for ENERGY STAR labeled CFLs and light fixtures; implement a central air conditioning quality installation project; partner with local gas utilities to provide rebates on electronically commutated motors for natural gas furnaces; and specifically target older working appliances, e.g. refrigerators and room and central air conditioners that are ten years or older. B. RESIDENTIAL AUDITS / DELIVERED FUELS / LOW INCOME WEATHERIZATION Electric utilities will be able to take credit for equivalent kwh savings from weatherization measures that result in delivered fuel savings in The weatherization activities must be delivered through a project serving low-income customers and the utility must have a residential energy audit program. The audit needs to be performed by an auditor that has demonstrated the qualifications established under docket The audit program should use a House as a

13 Page 11 System approach and incorporate an understanding of health and safety issues as they relate to combustion equipment. It is Staff s intention to develop deemed savings values for weatherization measures using established sources (e.g. Weatherization software developed as part of the Federal Weatherization Program). OES will be issuing guidance on such programs. C. COMMERCIAL/INDUSTRIAL PROGRAMS In an effort to increase MMPA s energy savings and improve the overall cost-effectiveness of its CIP, Staff recommend MMPA add additional end use technologies to the list of rebated measures available to commercial and industrial customers. Specifically, Staff encourage MMPA to consider rebates for the following: adjustable speed drives; compressed air; building recommissioning; energy management systems; and refrigeration. The U.S. Department of Energy (DOE) Industrial Technologies Program also offers several tools that can help utilities and energy efficiency program administrators in conducting more comprehensive building audits and finding more energy savings opportunities. The DOE s Save Energy Now program and the Best Practices assessment tools are resources that MMPA should explore in order to expand its industrial program offerings. D. FURNACE ELECTRONICALLY COMMUTATED MOTORS (ECMS) As MMPA continues to develop its CIP program, it should consider partnering with trade allies and gas utilities to offer rebates for the installation of ECMs on new furnaces and, as they become available, retrofit ECMs on existing furnaces. V. CONCLUSIONS AND RECOMMENDATIONS Based on a review of MMPA s 2008 CIP Report, Staff offer the following conclusions and recommendations: 1. MMPA provides a CIP plan that meets the 1.5% savings goal in 2010 as well as the 1.5% spending foal for each year. 2. MMPA must develop a program facilitating professional engineering verification of ENERGY STAR-labeling, or LEED or Green Globes certification of commercial buildings to comply with Minnesota Statutes. Staff suggest that MMPA develop a

14 Page 12 program focused on ENERGY STAR labeling of existing commercial buildings incorporating low-cost O&M activities. 3. Staff recommend MMPA partner with local weatherization providers to develop a specific project dedicated to serving the needs of its low-income customers. A lowincome project may include any or all of the following: audit and weatherization services; air conditioner tune-ups; installation of compact florescent and ENERGY STAR lighting; replacement and disposal of inefficient refrigerators; and/or other measures designed to improve energy efficiency and promote conservation in low-income households. 4. Staff recommend that MMPA provide, if it is already not doing so, information about fluorescent bulb and lamp recycling to all of its lighting program participants. 5. Staff suggest that MMPA modify its CIP for residential customers by scaling back rebates for refrigerators and dishwashers and adding one or more of the following: provide rebates for ENERGY STAR labeled CFLs and light fixtures; implement a central air conditioning quality installation project; partner with local gas utilities to provide rebates on electronically commutated motors for natural gas furnaces; and specifically target older working appliances, e.g. refrigerators and room and central air conditioners that are ten years or older. 6. Staff recommend MMPA add additional end use technologies to the list of rebated measures available to commercial and industrial customers. Specifically, Staff encourage MMPA to consider rebates for the following: adjustable speed drives; compressed air; building recommissioning; energy management systems; and refrigeration.

15 /jl Table 9: REPORTED CIP SPENDING PER KWH SAVED, ELECTRIC UTILITIES Utility kwh Savings Spending $/kwh kwh Savings Spending $/kwh Investor-Owned Utilities Alliant Energy 13,636,911 $1,967, ,990,441 $2,562, Minnesota Power 45,940,938 $3,794, ,168,014 $3,908, Otter Tail Power 14,027,710 $1,936, ,617,820 $1,862, Xcel Energy 256,386,037 $42,880, ,207,821 $47,382, Cooperatives Dairyland Power Coop 2,482,889 $1,966, ,318,591 $2,053, East River Electric Power Coop, Inc. 383,959 $285, ,529 $284, Great River Energy 32,076,202 $18,194, ,060,845 $20,872, Minnesota Valley Coop L&P 469,500 $190, ,550 $246, Minnkota Power Coop 4,634,379 $2,290, ,061,664 $2,284, Sioux Valley Southwestern Electric 1,989,511 $73, ,164,796 $73, Municipals Alexandria Light & Power 933,739 $229, ,266,653 $280, Hutchinson Utilities Commission 1,425,198 $308, ,650 $350, Benson Municipal Utilities 100,633 $108, ,042 $128, Brainerd Public Utilities 2,314,037 $144, ,956,427 $199, Detroit Lakes Public Utility 373,863 $139, ,008 $127, East Grand Forks Water & Light Dept. 162,414 $368, ,362 $342, Glencoe Light & Power Commission 317,264 $71, ,549 $93, Grand Rapids Public Utilities Commission 1,853,086 $103, ,683,822 $110, Hibbing Public Utilities Commission 11,655 $73, ,637 $99, Hutchinson Utilities Commission 1,264,611 $166, ,124,104 $430, Jackson Municipal Utilities 160,278 $42, ,172 $57, Luverne Municipal Utilities 721,622 $177, ,482 $114, Marshall Municipal Utilities 1,793,001 $326, ,628,227 $343, Melrose Public Utilities 1,094,520 $88, ,599 $37, Minnesota Municipal Power Agency 856,689 $636, ,045,632 $681, Moorhead Public Service 1,282,024 $381, ,257,909 $407, New Ulm Public Utilities 1,889,810 $400, ,129,389 $335, Shakopee Public Utilities 4,462,076 $623, ,653,643 $727, Southern MN Municipal Power Agency 4,125,429 $1,404, ,112,231 $1,629, St. James Municipal Light & Power 73,708 $49, ,668 $49, Thief River Falls Municipal Utility 791,592 $205, ,322 $223, Triad (Austin, Owatonna, Rochester) 12,399,386 $2,196, ,895,990 $2,864, Wadena Light & Water 28,599 $48, ,532 $54, Willmar Municipal Utilities 775,110 $287, ,186,110 $305, Windom Municipal Utilities 83,415 $74, ,480,922 $74, Worthington Public Utilities 676,758 $176, ,545 $165,

16 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, , or by depositing a true and correct copy thereof properly enveloped with postage paid in the United States Mail at St. Paul, Minnesota. Minnesota Office of Energy Security Conclusions and Recommendations Minnesota Municipal Power Agency (MMPA) Docket No. E,G999/CIP Dated this 8 th day of April, 2009 /s/sharon Ferguson

17 CIP General List (updated 4/09) Burl W Haar Exec Sec MN Public Utilities Commission 350 Metro Square Bldg 121 7th Place E St Paul MN MN Dept of Commerce Docketing 85 7 th Place E Ste 500 St Paul MN Tom Holt East River Electric Power Cooperative Inc 121 SE 1 St PO Drawer E Madison SD Jerry Irsfeld Minnesota Senior Federation 1885 University Ave Ste 190 St Paul MN Chris Cloutier D&R International 1684 Selby Ave St Paul MN Dave Johnson Manager Community & Conservation Services Community Action of Minneapolis 2104 Park Ave S Minneapolis MN Tom Sagstetter DSM/Member Services Manager Great River Energy U S Hwy 10 Elk River MN Jeff A Daugherty CenterPoint Energy 800 LaSalle Ave FL 14 Minneapolis MN Julia Anderson Attorney General s Office 1400 Bremer Tower 445 Minnesota St St Paul MN John Lindell Attorney General s Office-RUD 900 Bremer Tower 445 Minnesota St St Paul MN Julie Coopet 1636 Chatham Ave Arden Hills MN Tony Hainault Hennepin County Environmental Svcs 417 N. 5 th St, Ste 200 Minneapolis, MN Don Stauty 7606 Rice River Road Virginia, MN Jim Erchul Dayton s Bluff Neighborhood Housing Svc 823 E 7 th St St Paul MN George Agriesti CIP Administrator Minnesota Power 30 W Superior St Duluth MN Bob Ambrose Great River Energy 1745 E Hwy 10 PO Box 800 Elk River MN Anne Hunt Office of the Mayor 390 City Hall St Paul MN Ron Elwood Legal Services Advocacy Project 2324 University Ave Ste 101 St Paul MN Greg Ernst G A Ernst & Associates Inc 2377 Union Lake Trail Northfield MN Pam Marshall Energy CENTS Coalition th St E St Paul MN Bill Grant Izaak Walton League 1619 Dayton Ave Ste 202 St Paul MN Nick Mark Energy Program Administrator CenterPoint Energy 800 LaSalle Ave FL 14 Minneapolis MN Larry Johnston Southern MN Municipal Pwr Agency 500 1st Ave SW Rochester MN Kyle MacLaury Center for Energy and Environment rd Ave N Ste 560 Minneapolis MN Jennifer Moore Alliant Energy Corporation PO Box First St SE Cedar Rapids IA Tom Smilanich Passive Concepts th Ave N South St Paul MN 55075

18 Tina Koecher CIP Administrator Minnesota Power Company 30 W Superior St Duluth MN SaGonna Thompson Xcel Energy 414 Nicollet Mall FL 7 Minneapolis MN Ken Smith District Energy St Paul Inc 76 W Kellogg Blvd St Paul MN Joseph Hallberg President NICE/EnerActNow PO Box 752 Wayzata MN Kim Pederson Manager Market Planning Otter Tail Power 215 S Cascade St Fergus Falls MN Bill Poppert Technology North 2433 Highwood Ave St Paul MN Allen Carlson Dept. of Planning & Econ Dev. City of St. Paul 25 West 4th Street St. Paul, MN Jim Walters CEM Mgr of Marketing & Ext Services Rochester Public Utilities 4000 E River Rd NE Rochester MN Christopher Clark Xcel Energy Law Dept 414 Nicollet Mall, 5 th Floor Minneapolis MN Scott McClure Alliant Energy Corporation 4902 N Biltmore Ln Madison WI Mary Morse St Paul Neighborhood Consortium 624 Selby Ave St Paul MN Alan Lian Marketing Sales Supervisor Minnesota Power Company 30 W Superior St Duluth MN Andrew Lambert PCEC Program Manager Phillips Community Energy Coop st Ave, Ste 110 Minneapolis MN Christy Brusven Attorney at Law Fredrikson & Byron, P.A. 200 S 6 th St, Ste 4000 Minneapolis, MN S Mark Curwin Enbridge Energy Co Inc 119 N 25 th St E Superior WI Lisa Pickard Communications/Member Services Specialist Minnkota Power Cooperative Inc PO Box Grand Forks ND John Steinhoff Resource Solutions Inc 318 Kensington Dr Madison W Richard Szydlowski, Dir/Research & Engr Center for Energy and Environment (CEE) Colonial Warehouse rd Ave N Ste 560 Minneapolis MN Greg Groenje CIP Chair Healthy Buildings committee MN Multi Housing Assn 1650 W 82 nd St #250 Bloomington MN Narv Somdahl 5100 W 102 ND ST APT 209 Bloomington MN Keith Butcher Center for Energy & Environment rd Ave N Ste 560 Minneapolis MN Steve Grohn Standard Heating & Air Conditioning 410 W Lake St Minneapolis MN David R Moeller Attorney Minnesota Power 30 W Superior St Duluth MN Jason Willett Metropolitan Council 390 N. Robert Street St. Paul, MN Mike Sarafolean Gerdau Ameristeel US Inc 4221 Boy Scout Blvd Ste 600 Tampa FL Martin Lepak Manager AEOA AEOA Duluth Weatherization & Energy Assistance 6526 Grand Ave Duluth MN Brian Peterson City of Red Wing P.O. Box West 4th Street Red Wing, MN 55066

19 East River Electric Power Coop 121 SE 1 st St PO Drawer E Madison SD Gary S Olson CPA CMA Product Recovery 2605 E Cliff Rd Burnsville MN Gary Chestnut AG Processing Inc W Dodge Rd PO Box 2047 Omaha NE Steve Downer MN Municipal Utilities Assn 3025 Harbor Ln N Ste 400 Plymouth MN Michael Hoy Dakota Electric Association th St W Farmington, MN Rebecca Wentler Otter Tail Power Company 215 S Cascade St Fergus Falls MN Angela Kline CenterPoint Energy Minnegasco 800 LaSalle Ave Fl 14 Minneapolis MN George Crocker North American Water Office PO Box 174 Lake Elmo, MN Rick Lancaster Great River Energy E Hwy 10 PO Box 800 Elk River MN Larry Oswald Great Plains Natural Gas Co 105 W Lincoln Ave PO Box 176 Fergus Falls MN Stephen A. Gunn Program Manager MERC PO Box Green Bay, WI Patty Hanson, BEP Manager of Marketing and External Affairs 4000 East River Road Rochester, MN John Bailey Inst. For Local Self-Reliance th St SE Ste 306 Minneapolis MN Suzanne Glaster-Doyle Xcel Energy 414 Nicollet Mall FL 6 Minneapolis MN Tom Balster Alliant Energy st St SE PO Box 351 Cedar Rapids IA Sheldon Strom Center of Energy & Environment rd Ave N Ste 560 Minneapolis MN Susan Thompson Director Customer Service Minnesota Power 30 W Superior St Duluth MN Arshia Javaherian Regulatory Attorney Interstate Power & Light Company 200 First St SE Cedar Rapids IA Howard Ankrum Weatherization Director Arrowhead Economic Opportunity rd Ave S Virginia MN Mark Glaess General Manager Minnesota Rural Electric Assn rd Ave Maple Grove MN Dahlen Berg & Co 200 S 6 th St Ste 300 Minneapolis MN Ann Tessier Greater Minnesota Gas, Inc. 315 ½ S Minnesota St, Ste 201 St. Peter, MN Leo Steidel Tom McDougall The Weidt Group Inc 5800 Baker Rd Minnetonka MN Donna Walkup Great Plains Natural Gas Company 105 W Lincoln Ave, PO Box 176 Fergus Falls, MN Dale Niezwaag Basin Electric Power Cooperative 1717 E Interstate Ave Bismarck ND Melissa S Feine Weatherization Program Coordinator SEMCAC PO Box S Elm St Rushford MN Pat Green City of Hibbing Clerk's Office City Hall Hibbing, MN 55746

20 Jean Kuehn Energy Coordinator City Hall st Ave NE Spring Lake Park, MN Brian Meloy Leonard Street & Deinard 150 S 5 th St Ste 2300 Minneapolis MN Roger Warehein Marketing/Conservation Specialist Owatonna Public Utilities 208 S Walnut PO Box 800 Owatonna MN Norm Harold 5591 East 180th Street Prior Lake, MN John McWilliams Dairyland Power Cooperative 3200 E Avenue S PO Box 817 LaCrosse WI Robyn Woeste Interstate Power and Light Company 200 First St SE PO Box 351 Cedar Rapids IA Dale Sullivan Ramsey Action Programs, Inc Labore Road Vadnais Heights, MN 55110