PSC REF#:208210

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Intervenor Compensation Application

State of Wisconsin, Public Service Commission, PO Box 7854, Madison WI 53707-7854

Intervenor Compensation is governed under Wis. Stat. § 196.31 and Wis. Admin. Code ch. PSC 3.

Applicants must complete this form to be considered for compensation.

Check One: __X__ Original Request ____ Supplemental

General Applicant Information Required

Name of Applicant / Organization Citizens Energy Task Force

Street Address City State Zip Code P.O. Box 3571 La Crosse WI 54602-3571

Telephone Number (608) 790-7578 Email Address [email protected] Primary Contact Name George Nygaard Primary Contact Title

Case Number (Docket #) Are you a party in the case? Indicate one below.

Yes __X__ No _____ If no, have you applied for party status? Yes _____ date: __________ No _____

Information Required from Organizational Applicants

Description of Organization (General Purpose, Staff Size and Corporate Structure – use additional pages as needed)

CETF’s mission is to collaborate with individuals, organizations, and agencies with organizing, legal, and public education strategies to represent citizens who question the need for these particular high voltage power lines, and who support clean, sustainable, locally-generated power sources.

Number of Organization’s Members Residing in WI 200+ Total Number of Members in Organization 300+ Organization’s Federal Identification Number (FEIN) 30-0480091 (will forward new EIN for WI CETF ASAP)

Information on Organization’s Governing Body Members Name Title Address

Joseph M. Mores President Winona, MN Linda VanArt Treasurer La Crosse, WI George Nygaard Secretary Chaseburg, WI Irving Balto Chaseburg, WI Debra Severson Sparta, WI Guy Wolf Stoddard, WI Beverly Vaillancort LaValle, WI

PSC REF#:208210Public Service Commission of Wisconsin

RECEIVED: 06/27/14, 12:01:27 PM

Intervenor Compensation Application Page 2 of 5

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Information Required from All Applicants to Establish Eligibility for Compensation

Below, and on additional pages as needed, please address the following:

1. Please explain whether, and to what extent, you have a substantial interest in the case. a. Please select one or more categories below that best matches your interest in the case:

i. Are you a customer of a utility subject to the proceeding? _X__ Yes _____ No, If yes, which utility(ies)? All utilities charge ratepayers for MVP projects, directly Xcel, Dairyland, indirectly ATC

ii. Are members of your organization customers of a utility subject to the proceeding? _X__ Yes _____ No, If yes, which utility(ies)? All utilities charge ratepayers for MVP projects, directly Xcel, Dairyland, indirectly ATC

iii. Do you represent a customer of a utility subject to the proceeding? _X__ Yes _____ No, If yes, which utility(ies)? All utilities charge ratepayers for MVP projects, directly Xcel, Dairyland, indirectly ATC

iv. Are you or members of your organization materially affected by the outcome of the proceeding? _X__ Yes _____ No If yes, and you are an organization, please estimate, to the best of your ability, the number of your members materially affected by the proceeding: (or provide further detail under b. below).

b. Explain how the issues of the case specifically impact you or the individuals you represent. If you are an organizational applicant, please estimate, to the best of your ability, the number of your members affected by the case and the type of member you represent, for example neighborhood residents affected by proposed project, or residential rate payers, or industrial customers of a utility.

See IC Application narrative.

2. Please explain how your proposed participation in this case will adequately present a significant position for the proceeding’s record. In your answer, list the issues in the case (docket) that you plan to address; explain why your input, ideas and viewpoints on these issues are significant to this proceeding.

a. Also describe, to the best of your ability, how your position and information you will present may be different than positions or information that may be presented by Commission staff in the proceeding.



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3. Please describe specific educational and/or professional qualifications supporting your ability to represent your interest and position in the case.

a. If you are an organizational applicant, provide the educational and professional qualifications of your staff involved in the intervention.

b. If you plan to use an outside consultant or expert witness to address issues in the case, please describe why an outside consultant or expert witness is needed to address the proposed issues and why you, or your organization’s staff, are not able to adequately address these issues.

c. For each attorney you propose to use in your intervention, and who are not employed by your organization, please provide a resume. For all consultants, including but not limited to expert witnesses, provide resumes or Curriculum Vitae (CV).


4. Please explain why an adequate presentation of your position would not occur without a grant of compensation.

Describe why you would not be able to participate, or why presentation of your position would be inadequate, without compensation. Describe the specific financial barriers to participating, barriers to you or your staff’s participation, barriers to adequate legal representation, and barriers to obtaining expert testimony.



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5. Please explain how and why the compensation you are requesting for your participation is reasonable.

a. Describe how the specific costs of your request, such as travel costs, supply costs, per hour rates, and number of hours proposed for participation, are reasonable.

i. In support of the above, please provide a detailed budget for your request, with the cost of each service and expense itemized. For each itemized cost please be sure to include per hour rates, number of hours, and itemized travel costs and supply costs.

b. Address why your request is reasonable considering other potential sources of funding to support your participation. Explain why other funding sources; such as other grants, funding from members, or donations; cannot be used, or are not available, to cover the costs for which compensation is requested.

i. Please also describe any contribution to the intervention you or your organization is making. Please describe any in-kind, non-cash, contributions to the intervention and provide a cash-value estimate of the contributions.


6. Please explain whether, without compensation, the cost of intervention would cause significant financial hardship.

In your answer, please provide the following information if you are an organizational applicant: a. A detailed statement of revenues and expenses by program activity including fund-raising, education,

research, and lobbying for the previous and current fiscal years. b. A detailed list of current assets and liabilities (balance sheet) including all uncommitted funds. c. The organization’s official budget for the current fiscal year. Identify the parts of the budget that will be

used to contribute to the intervention (as detailed above in item number five). d. For organizations with gross annual revenues in excess of $30,000, a description of job duties of paid and

unpaid staff. Provide the following information if you are an individual applicant:

a. An annual, revenue (income) statement and statement of expenses for the current and prior calendar year. b. A budget for the current calendar year, showing any funding that will be used to support participation in the

proceeding. c. Total assets and liabilities, or a balance sheet, that includes liabilities such as loans and other debt; costs

such as food, taxes, utilities; assets such as house and/or car equity, savings bonds, investments and mortgages; and income.



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7. Please provide information on other formal Commission proceedings in the current state fiscal year (July – June) in which you plan to participate. For each proceeding, identify the expected source(s) of funding supporting your participation.


Certification Applicant by signature agrees to abide by the provisions of, and certifies to meeting the eligibility criteria in, PSC Ch. 3.

Signature

Date

June 27, 2014

Applicants must serve a copy of the completed application to each utility involved in the proceeding. Please

indicate below that you have served a copy of the completed application to each utility:

A copy of the above completed application has been served to each utility involved in the proceeding: Yes: __X__ No: If no, please state why a copy has not been provided.

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Citizens' Energy Task Force George R. Nygaard P.O. Box 3571 La Crosse , Wisconsin 54602-3571

June 27, 2014 Sandra Paske James Lepinski Secretary to the Commission Docket Coordinator Public Service Commission of Wisconsin Public Service Commission of WI 610 North Whitney Way 610 North Whitney Way P.O. Box 7854 P.O. Box 7854 Madison, WI 53707-7854 Madison, WI 54707-7854

RE: Application for Intervenor Compensation – Citizens' Energy Task Force (CETF) 1-IC-_____

Joint Application of American Transmission Company, LLC and Northern States Power Company - Wisconsin, for Authority to Construct and Place in Service 345 kV Electric Transmission Line from the La Crosse area, in La Crosse County, to the greater Madison area in Dane County, Wisconsin

Wisconsin PSC Docket 5-CE-142

Dear Ms. Paske: Enclosed and filed by ERF please find CETF Application for Intervenor Compensation to facilitate participation in the above-entitled docket. Thank you for your consideration. Sincerely,

George Nygaard cc: via email and hard copy: Lisa Agrimonti, Esq. Trevor Will, Esq. for Xcel Energy for ATC, LLC [email protected] [email protected] Briggs & Morgan Foley & Lardner 2200 IDS Center 777 E. Wisconsin Ave. 80 So. 8

th St. Milwaukee, WI 53202-5306

Mpls, MN 55402

mailto:[email protected]

mailto:[email protected]

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BEFORE THE PUBLIC SERVICE COMMISSION OF WISCONSIN

Joint Application of American Transmission Company, LLC and Northern States Power Company - Wisconsin, for Authority to Construct and Place in Service 345 kV Electric Transmission Line from the La Crosse area, in La Crosse County, to the greater Madison area in Dane County, Wisconsin

Wisconsin PSC Docket 5-CE-142

Application of CETF for

Intervenor Compensation Pursuant to Wis. Stat. 196.31 and Wis. Admin. Code, PSC Chapter 3

Application of CETF for Intervenor Compensation

Docket 5-CE-142

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Attachment A Case Related Information Attachment B Proposed Expenditures Attachment C Financial Information Appendix A Work Plan and Budget Appendix B CETF Work Plan and Budget Appendix C Not Applicable – No Income, No Audit Appendix D Not Applicable – Not Lobbyist Appendix E Not Applicable – No prior Intervenor Compensation Appendix F Not Applicable Appendix G CETF 2014 Budget Appendix H Not Applicable Appendix I CETF Board of Directors

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ATTACHMENT A: CASE-RELATED INFORMATION

1. Provide information about the purpose of the intervention, including a discussion of the issues the applicant plans to address and how they affect the applicant’s interest in the proceeding. An explanation is required of the ideas of viewpoints the applicant believes are substantive, novel or significant and why their presentation would contribute to a full and fair determination of the issues.

Citizens Energy Task Force (hereinafter “CETF”) is a Minnesota and Wisconsin-

based public interest and educational organization, operating in Wisconsin and

Minnesota, with Board, members and participants who live, work, and own property in

both states and beyond. CETF’s mission is to collaborate with individuals, organizations,

and agencies with organizing, legal, and public education strategies to represent citizens

who question the need for these particular high voltage power lines, and who support

clean, sustainable, locally-generated power sources. CETF participates in state and

regional planning and educational opportunities, such as those offered by the Wisconsin

Public Service Commission, RTO’s, utilities, etc.

For the purposes of this Application, CETF has been advised by staff that “less is

more” and will work towards brevity with staff’s assurance that if additional information is

wanted, requests shall be made.

On May 8, 2008 CETF was incorporated in Minnesota as a nonprofit corporation.

CETF’s focus of activities shifted from Minnesota’s southern metro area to Southeastern

and Southern Minnesota and Southwest Wisconsin with the CapX 2020 project, and while

continuing some work in Minnesota, CETF has been increasingly active in energy issues

in Wisconsin. The Minnesota founding board members of CETF are no longer active, and

a majority of board members are Wisconsin residents linked to the original Wisconsin

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Citizens Energy Task Force. Because of CETF’s increased focus on Wisconsin, CETF

has recently reestablished itself as a Wisconsin not-for-profit and dissolved its Minnesota

incorporation. In so doing, CETF learned that CETF was originally incorporated in

Wisconsin in 1981, and involuntarily dissolved in 1993. Current Wisconsin board

members were affiliated with this initiative. Furthermore, CETF has prepared and will

soon file its application to the IRS for 501(c)(3) status, and presuming CETF attains

501(c)(3) status, it does not anticipate having to use another organization as its fiscal

agent.

CETF has a seven member Board of Directors and over 300 members across

Minnesota and Wisconsin. Since the Minnesota CapX 2020 Certificate of Need was

granted, CETF has shifted its focus to Wisconsin, and the majority of the Board of

Directors and general members will be affected by the proposed routes for the Badger

Coulee transmission line. CETF has maintained a website since 2008, a list serve and a

Facebook page focused on these transmission projects.

Membership drives and fundraising, to date, have not been a primary focus for

CETF such that our reach and support are wider than membership numbers convey. A

recent petition initiated by CETF was signed by over 570 individuals, and CETF has

served as a resource for regional media, citizens and organizations including the Coulee

Region Sierra Club.

1. CETF has a substantial interest in this case.

All CETF member households are customers of one or of the utilities that are

Applicants in the CPCN application. The Badger Coulee project is part of MVP 5, an

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MISO MVP project, and the cost of an MVP project is apportioned to all Wisconsin utilities,

and an apportioned share of the cost of ALL of the MVP projects is apportioned to all

Wisconsin utilities. Many CETF members own property that may be directly affected by

the Badger Coulee project. During the past several months CETF members have

attended Applicant and Commission sponsored Badger Coulee meetings and noted

participants concerns about eminent domain issues and negative health effects of EMF,

as well as chemical exposure potential from ROW clearance and maintenance. CETF

members have deep concerns about depreciation in property values and aesthetic

degradation.

2. CETF’s proposed participation in this case will adequately present a significant position for the proceeding’s record.

In this proceeding, CETF’s intervention would focus on public interest and policy

issues incorporated in the Commission’s statutory review criteria for transmission projects

and general policy and planning issues controlled by the PSC that should also be

considered, including:

Review of need claim for this project, drivers of regional transmission expansion plans and transmission proposals, and associated policy issues such as:

o State authority, statutory and jurisdictional issues in light of regional

planning and wholesale electricity market and implication of “approval” of projects by MISO;

o Market transformation, centralization and wholesale energy market impacts related to project;

o Characterization of reliability, congestion, reliability benefits and regional

benefits; delineated by who pays and who benefits, and by how much;

o “Peak” as justification for transmission, with focus on coincident v. non-coincident, dedicated use of DSM as capacity v. demand response and peak reduction;

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o Security concerns inherent n an interconnected grid, and capturing the risks, costs, and alternatives in analysis of regional transmission;

o MVP 5 and MISO MVP Portfolio, consideration of all costs approved by

MISO and set by MISO/ FERC tariff; externalities, line loss; and

o CPCN as demonstration of “need” for eminent domain condemnation, where need largely driven by economic benefits to utilities and/or other regions, and where viable alternatives greatly reduce the taking of land;

Wisconsin’s Energy Hierarchy as set forth in Wis. Stat. § 1.12(4) and Wis. Stat. §196.025(1)(b)(1) and its role in planning at state and MISO;

o Consideration of statutory requirements to consider system and non-

transmission alternates, taking into account fuel mix relative to hierarchy and use of integrated resource planning versus single solution selection;

o How characterization of need claim affects alternatives under consideration; and

Environmental and health considerations:

o Climate change implications of project and compliance with Clean Air Act and evaluation of project against carbon reduction benefits of other solutions;

o Health and migratory impacts associated with transmission i.e., corona/ultra violet, routing both generally and near pollutants such as dust producing sand mines, avian and animal habitat, etc., and the application of the precautionary principle when scientific investigation proves there is a possible risk in these activities.

o Segmentation of MISO MVP and CapX 2020 projects.

The work of CETF will not be duplicative as CETF is strongly opposed to this

project, has committed to challenging need for this project, focused on policy based

issues. As with the CapX 2020 Hampton-La Crosse transmission project, many of the

organizational intervenors are intervening in support of this project and to the extent that

CETF’s work may have a similar subject matter, CETF’s is a critical perspective is, not

one of support. No other party is focused on the issues that CETF is raising, as detailed

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above.

3. CETF, its consultants, and its attorney have specific transmission and energy educational and professional qualifications that provide ability to well-represent our interest and positions in this case.

Consultants

CETF will utilize the services of Jerry Mendl and Geoffrey Crandall, principals of

MSB Energy Associates, to address need and lack thereof for this transmission project.

MSB Energy Associates of Middleton, Wisconsin, has extensive energy consulting

experiences and since 1988 has provided their services before the Commission and

elsewhere across the country to intervenors, businesses, state and federal government

agencies, consumer and environmental organizations and utilities.

MSB will analyze the need for the power line based on the proposed need

assessment and justification documentation relied on by the Applicants. This will include

consideration of need claim for this project and associated policy issues such as state

authority and jurisdiction; Wisconsin’s Energy Hierarchy, Wis. Stat. § 1.12(4);

consideration of system and non-transmission alternates; regional planning and electricity

market and implication of “approval” of projects by MISO; centralization and wholesale

energy market impacts related to project; characterization of reliability, congestion,

reliability benefits and regional benefits.

MSB’s work will also include a review and determination of the amounts of energy

efficiency, demand-response and alternative resources upon which ATC relied and

comparison of those values that are embedded in the forecast to the amount of these

resources built into neighboring states plans.

Additional information about MSB and the scope of its proposed work is detailed in

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Attachment A.

Legal Services

CETF will be represented by Carol A. Overland, with Board Member Deb Severson

assisting through the technical hearing. Ms. Overland has 20 years of experience in utility

regulatory and rulemaking proceedings, from nuclear waste to transmission to natural gas

plants, coal gasification and everything in between, representing intervenors primarily in

Minnesota, and also consulting and/or representing Pro Hac Vice in the Midwest and also

New Jersey, Delaware, Maryland, Colorado, California, Montana, and Washington state.

Overland also has extensive knowledge and experience specific to the Applicant’s 345 kV

build-out projects gained over the last ten years, having been present at the planning

stages and unveiling of CapX 2020 at the NM-SPG MAPP meetings, intervening in the

2006 Minnesota Certificate of Need, and representing intervenors in the Brookings-

Hampton, Fargo-St. Cloud and the Minnesota and Wisconsin Hampton-Rochester-La

Crosse routes over the last four years, and currently in this and another MVP project

docket. Ms. Overland has represented parties in the USDA’s RUS scoping, DEIS and EIS

process. CETF can proceed immediately, more effectively and economically, by using

Ms. Overland’s prior data requests, filings and specific knowledge of this docket.

CETF board members, primarily Ms. Severson, will assist with those activities

necessary for participation in this docket, including review and cross-referencing of the

Minnesota Certificate of Need filings, the Wisconsin application and subsequent filings,

research transmission issues for this use in proceeding, conduct limited Discovery and

review the responses and that of others, review and Comment on the DEIS (with

assistance from consultants), work with witnesses preparing testimony and exhibits,

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review the testimony and exhibits of others, attend public hearings, participate in technical

hearings, file briefs, review and respond to staff memorandum and matrix, and consult

with other intervenors as necessary.

4. CETF does not have resources to make an adequate presentation of our position without intervenor compensation.

CETF has been an organization for over thirty years, inactive from 1993 until 2008.

We have consistently participated in energy related dockets as intervenors since 2008,

largely on a volunteer basis. Unlike several other organizations in this docket, CETF does

not receive an annual grant from the PSC. We have participated as fully as possible with

what funding we have, but at this time, our account contains approximately $300.00.

When we have received notification of 501(c)(3), we will commence intense fundraising

efforts and aggressively pursue grants. We are at this time, in this docket, dependent on

Intervenor Compensation for adequate presentation of our case.

In the CapX 2020 transmission docket, CETF was provided with minimum funding

for our attorney, without whom we would not have been able to navigate the

administrative review process. In this docket, we do not have a joint intervenor to share

costs in this case, and our need for Intervenor Compensation for legal services is greater.

Our attorney is making a 1/3 in-kind donation of services to CETF. We are requesting

funding for the other 2/3 of a conservative estimate of time required to adequately and

properly represent CETF and participate in this docket.

Without Intervenor Compensation, we are not able to present witnesses, and we

were severely hampered in our work in the CapX 2020 Hampton-La Crosse docket

without witness funding, and we were unable to file testimony, enter exhibits, and were

subject to costly changing requirements and directives regarding copying, paper and CDs,

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expending tremendous effort to enter exhibits which would have accompanied our witness

testimony. Without the testimony, the weight and value of these exhibits was diminished

and our case suffered. Sufficient Intervenor Compensation is the crucial factor in

presenting an adequate case.

5. CETF’s Intervenor Compensation request is reasonable.

CETF’s Intervenor Compensation is reasonable. On a dollar-to-dollar basis,

CETF’s cost estimate, alone and when compared with other Intervenor Compensation

requests, is reasonable. Further, CETF, its Board members, and its attorney have

extensive experience in participation in utility regulatory dockets, and are presently active

intervernors in another MISO MVP project docket in Minnesota, the ITC Midwest MN/IA

345 kV transmission project. This experience allows us to streamline efforts without

having to start from scratch. CETF would make efficient and effective use of a grant of

Intervenor Compensation.

6. CETF would suffer significant financial hardship without Intervenor Compensation to cover the costs of intervention.

Without the modest, narrow and specific Intervenor Compensation grant we are

requesting, we will not be able to participate in this docket.

CETF has been singularly focused on transmission policy, challenging the

assumption that regional transmission is the key to reliability and carbon reduction.

Decisions made in these individual Commission dockets form and direct policy directions

through significant investment in infrastructure lasting several decades, locking in our

range of energy options to those utilizing transmission. By not granting Intervenor

Compensation CETF efforts would be thwarted through minimized inclusion and the

effectiveness of one of the primary advocates challenging the line and regional

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transmission expansion as a public interest policy be minimized.

7. CETF plans to participate in select PSC dockets in the future.

CETF is “professionalizing” itself as an organization. We are formalizing our

demonstrated commitment to educate, advocate, and participate in Wisconsin energy

policy issues through incorporation in Wisconsin and application for IRS 501(c)(3) status.

CETF anticipates participation in energy efficiency dockets, planning dockets such

as the Strategic Energy Assessment, and project dockets such as this one, but at this time

CETF has not targeted any specific dockets for intervention or participation.

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ATTACHMENT B: PROPOSED EXPENDITURES

Expenditures proposed by CETF for intervention, detailed below in Appendix A and Appendix B, include: Consultants MSB Energy Assoc. 210 hours $37,500.00 Jerry Mendl and Geoff Crandall CETF Attorneys Fees – Carol Overland $34,780.00 Expenses (travel, lodging, per diem): $ 3,200.00 Deb Severson $ 4,464.00 Expenses (travel, lodging, per diem): $ 1,500.00 TOTAL IC REQUEST: $81,444.00

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ATTACHMENT C: FINANCIAL INFORMATION

1a. CETF 2013 Actual Revenues and Expenses

CETF revenue and expenses for the past four years are: Revenue Expenses

2011

2,209.58

1,338.58

2012

20,048.28

19,125.33

2013

1,835.00

2,691.70

2014

3.25

558.35

Total

24,096.11

23,713.96

In 2012, Intervenor Compensation for the CapX2020 docket accounted for a significant amount of CETF revenue. If this were removed, CETF total revenue for the above four years would be $ 9,621.78. Members routinely provide printed materials and cover the cost of attending seminars and meetings.

1b. CETF Current Assets and Liabilities

CETF has assets of $ 300.00. CETF had revenue of $3.25 thus far in 2014 and expenses of $170.00 thus far in 2014. CETF has no outstanding liabilities.

CETF will spend its assets, and any additional funds raised, on web service, mailings, copying costs, and materials in conjunction with the Badger Coulee intervention.

1c. Financial and Nonfinancial Contributions to this Intervention

CETF is requesting Intervenor Compensation for the cost of consultants, Director and staff time, and consulting and attorneys fees, and all expenses and other costs associated with intervention. CETF provides substantial non-cash contributions to the goals of the intervention. CETF provides to its members and the public current information on the status of the CapX2020 and Badger Coulee projects, related public meetings, PSC scoping meetings, and will participate in the public hearings and technical hearings in this docket..

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CETF has operated a website focused on the energy issues, and specifically the transmission projects, in which we are involved. Our work as intervenors includes Badger Coulee, CapX 2020 since its application in 2006, and our current intervention in the ITC Midwest MN/IA 345 kV transmission docket. Our website is used to present transmission issues as well as related energy articles and as a means to provide updates and notice of meetings. CETF has and will continue to participated in industry educational and planning opportunities, including Wisconsin Public Utilities Institute sessions, webinars hosted by RTO’s and media, ATC planning meetings, meetings requested of FERC and Wisconsin and Minnesota legislators, media and public energy forums, etc. CETF has participated in industry educational and planning opportunities, including Wisconsin Public Utilities Institute sessions, webinars hosted by RTO’s and media, ATC planning meetings, meetings requested of FERC and WI legislators, etc.

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APPENDIX A: CONSULTANTS’ WORK PLAN AND BUDGET

MSB Energy Associates – Need For The Line

This part of the overall review deals with the need for the line. We would conduct an assessment of ongoing EE and DR activities, related to strategies, programs and portfolios as well as MISO dispatch optimization methods which impacts resource selection within the geographic area. Alternative resources would also be included in the review. With customer utilization of new end-use technology and new developments in the industry related to automated metering infrastructure, smart meter and other end use technologies, an assessment would be conducted to analyze the current or anticipated impact that may emanate from existing and planned EE and DR portfolios. MSB Energy Associates is offering access to the expertise of two seasoned regulatory experts. Jerry Mendl and Geoffrey Crandall would be available to conduct this review and analysis. Between the two, they have over 80 years of combined experience related to the Commission’s consideration and potential approval of the need for this power line. Mr. Mendl was employed by the Public Service Commission of Wisconsin for over 14 years and was responsible for the development and evolution of Wisconsin’s long-range planning process for electric utilities. Mr. Mendl’s resume is attached as Appendix A Exhibit below for the detailed list of Mr. Mendl’s experience in preparing analyses and reviewing, testifying and participating in all aspects of regulatory proceedings in Wisconsin and throughout the United States. Geoffrey Crandall was employed by the Michigan Public Service Commission where he served as the supervisor of the energy conservation section and later as the Director of the Industrial, Commercial and Institutional Division. In this capacity he had responsibilities to develop and oversee energy efficiency and demand response programs impacting electric and gas customers throughout the State of Michigan. His job was to develop, implement, monitor and adjust, where necessary, numerous industrial, government and commercial (energy efficiency and demand-response) programs that were implemented by electric and gas utilities throughout the State of Michigan. Mr. Crandall’s resume is provided in Appendix A Exhibit below, which identifies his experience with energy efficiency and demand-response programs in Wisconsin, Iowa, Michigan, Ohio, Illinois and many other states. The relevant issues that MSB Energy Associates would focus on include: The need for the power line based on the proposed need assessment and justification documentation relied on by ATC in its application and filing. This will include consideration of need claim for this project and associated policy issues such as state authority and jurisdiction; Wisconsin’s Energy Hierarchy, Wis. Stat. § 1.12(4); consideration of system and non-transmission alternates; regional planning and electricity market and implication of “approval” of projects by MISO; centralization and wholesale energy market impacts related to project; characterization of reliability, congestion, reliability benefits and regional benefits. A review and determination of the amounts of energy efficiency, demand-response and alternative resources upon which ATC relied; Comparison of those values that are embedded in the forecast to the amount of these resources built into neighboring states plans.

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The reasonableness of the forecast relied on. This would include an overall review with particular attention paid to input assumptions related to end-use energy efficiency, demand response and renewable resources technologies. It would also include an assessment of the accuracy of past forecasts to examine whether they tend to systematically overestimate or underestimate demand. Compare the energy efficiency and demand response programs incorporated in the forecasts relied upon by ATC to the energy efficiency and demand response resource portfolios that are being implemented by electric investor owned electric utilities in the Midwest including Illinois and Iowa in particular due to their close proximity and recent activities in those states. Based on the comparative values, estimate how much potential exists to increase the energy efficiency and demand response resources to mitigate the need for the proposed project. Demand Response- Actual vs. Capability

The reasonableness of the Wisconsin electric investor-owned utilities Demand Response portfolio and its application will be the purpose of this portion of the review. We would review what has been used by dispatch optimization criteria has been used by MISO and how has that been applied in making dispatch decisions. We would assess the question of how the dispatch optimization criteria has been applied and if it resulted in benefitting MISO, ATC or local distribution utilities? We would review the existing DR options and strategies and determine the extent to which residential, commercial and industrial customers have experienced intentional appliance/power interruption events related to utility dispatchable demand-response tariffs/rates/services. We would address the following questions: Have investor owned utilities in Wisconsin been actively shedding load and applying demand-response options to mitigate peak, energy and system costs, in an effective manner? What has been the track record of electric investor-owned utilities in Wisconsin in recent years with respect dispatchable DR capability compared to actual calls for activation of available load management tools and options? What are the currently in-place demand response resources, strategies, tariffs, operational characteristics and data for the Wisconsin investor-owned electric utilities? What additional demand response technologies and strategies, options are the Wisconsin investor-owned planning to implement in the future? Has the use of load management and peak mitigation DR Tools been applied in a manner that has saved Wisconsin ratepayers higher energy, power, fuel and purchase power costs? If so, what has been the magnitude and impact of the savings? If DR options have not been activated, why not? Demand Response- WI Compared to Other States Reasonableness and comparison of the magnitude of DR Portfolio to other utilities - We would compare the magnitude, construct and reasonableness of the Wisconsin electric investor-owned utilities to other electric investor-owned utilities in the region. We would compare the DR resources achieved and system capability of other utilities DR portfolios in the Midwest to DR resources/system capability of Wisconsin investor-owned utilities. We would then assess the overall reasonableness of the Wisconsin electric investor-owned utilities Demand Response portfolio and its application given unique factors, system characteristics, or extenuating circumstances. This would include an overall review of existing DR options and strategies. We would review the extent to which other states in the Midwest have built greater DR capability or are planning to do so and also will compare the track record of actual load interruption events and

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the impact on peak and high energy cost mitigation and avoidance. If other Midwest states are pursuing a more aggressive DR portfolio in terms of capability and actual use we would point that out and provide an explanation of the reason for the differences. We would review the annual reports, EIA data, as well as the latest available evaluation, measurement and verification analyses for demand-response programs. EE – Planned vs. Potential & Impact on need for line

We would assess and analyze the extent to which energy efficiency resources were reflected in the forecasts and the basis of the need for the proposed line. The 2007 Energy Independence and Security Act and the U.S. Department of Energy have promulgated rules that impact the energy intensity of end-use by residential, commercial, institutional as well as industrial customers. With the passage of these Federal laws and implementation of rules the marketplace in Wisconsin has changed significantly. We would conduct a review and using the best available information would conduct a review of the reasonableness and comprehensiveness of these important changes on the forecast for which the need for the new line is based. Lighting technologies have been significantly impacted by these developments as have other technologies such as home appliances, commercial freezers and refrigeration, electric motors and many other end-use technologies and appliances. Energy Efficiency potential studies have been completed recently in the Midwest and we would determine if and how those values are integrated into the needs assessment and forecast. Alternative Resources Planned vs. Potential & Impact on need for line

Using the best available information we would assess the characterization of need for the line and the extent to which customer based renewable resources were reflected in the forecast that was relied upon in determining the need for the proposed line. Several organizations have quantified the available renewable energy potential in terms of potential peak and energy impact. For example, in Iowa an analysis of renewable potential found that up 30% or more of the electric needs in Iowa could be met with rooftop and ground mounted solar PV systems alone. We would review available information from Wisconsin sources, NREL and other sources to determine the reasonableness of the timing and amount of renewable resources that have been integrated into the forecast. MSB Energy Associates proposes to do the following:

1. Review and analyze the Draft Environmental Impact Statement

2. Identify issues and possible positions related to the need for this particular line

3. Prepare and review informal and formal data requests and discovery based on a close review of the filing and EIS.

4. Consider and develop various strategies and positions related to the review and analysis.

Share these positions and analysis with others on the intervener/review team to help formulate reasonable positions for use in testimony, exhibits or preparation of cross examination of the applicant witnesses.

19

5. Prepare written summaries and results of analyses for the intervener and review team assembled to handle this case.

6. As a result of the case review and analysis (working with others on the intervener team)

prepare formal testimony and exhibits to communicate the results of the analysis/review along with recommendations.

7. Prepare for and stand cross-examination of testimony and exhibits.

8. Provide assistance to intervener counsel related to cross-examination of applicant’s

witnesses, reviewing and editing briefs and other related documents. Jerry Mendl and Geoffrey Crandall – MSB Energy Associates Tasks and Budget

The MSB Energy Associates portion of the Citizens Energy Task Force team will have the following responsibilities and projected level of effort:

1. Review and analyze the Draft Environmental Impact Statement

2. Identify issues and possible positions related to the need for this particular line

3. Prepare and review informal and formal data requests and discovery based on a close review of the filing and EIS.

4. Consider and develop various strategies and positions related to the review and analysis.

Share these positions and analysis with others on the intervener/review team to help formulate positions for use in testimony, exhibits or preparation of cross examination of the applicant witnesses.

5. Prepare written summaries and results of analyses for the intervener and review team

assembled to handle this case.

6. As a result of the case review and analysis (working with others on the intervener team) prepare formal testimony and exhibits to communicate the results of the analysis and review along with recommendations, as appropriate.

7. The time and effort required for the MSB Energy Associates portion of the Citizens Energy

Task Force intervention team would be 250 hours. This would involve preparation of direct testimony and exhibits as well as stand cross-examination of the testimony and exhibits. In addition, assistance would be provided to intervener counsel related to cross-examination of applicant’s witnesses, reviewing and editing briefs and other related documents.

Total – 250 hours at $150/hour $37,500

Mendl Resume Page 1

JERRY E. MENDL President MSB Energy Associates AREAS OF EXPERTISE + Analysis of energy resource adequacy, cost and availability + Evaluation of alternative energy resource options + Analysis of electric utility bulk power supplies + Analysis of electric utility projected merger savings and implications on system operations and

costs + Transmission system analysis + Service delivery and markets in a restructured electric utility industry EDUCATION 1973 B.S. Degree in Nuclear Engineering, With Very High Honors, from the University of Wisconsin,

Madison, Wisconsin 1974 M.S. Degree in Nuclear Engineering from the University of Wisconsin, Madison, Wisconsin. EXPERIENCE 1987-Present President MSB Energy Associates, Inc. Middleton, Wisconsin Since co-founding MSB Energy Associates in 1988, Mendl has served public-sector clients in Arizona, Kentucky, California, Utah, Nevada, Washington, Texas, Alaska, Iowa, Illinois, South Carolina, Connecticut, Massachusetts, Vermont, Maryland, Michigan, Missouri, Minnesota, Louisiana, Wisconsin, Pennsylvania, Georgia, Hawaii, Ohio, New Jersey, the District of Columbia and Ontario. Much of his recent work has involved electric utility restructuring, low-income consumer energy affordability and service issues, prudence of gas and electric utility planning and purchase practices, and analyzing need for transmission lines. He assesses “green pricing” tariffs for renewable electric resources and fuel/purchase power costs for electric and natural gas utility rate cases and renewable energy alternatives for utility construction cases. He evaluates electric utility restructuring alternatives and prepares restructuring policy recommendations and supporting technical information. He analyzes long-range plans and planning methods used by gas and electric utilities. He prepares and presents reports, recommendations and testimony. He conducted engineering, environmental, economic and life-cycle cost analyses of alternate energy resource options, including improved end-use energy efficiency and renewable resources. Mendl developed state regulatory commission codes for implementing integrated resource planning and evaluated the adequacy of existing and proposed codes. Mendl was both organizer and presenter for a series of five least-cost planning workshops across the U.S. sponsored by the National Association of Regulatory Utility Commissioners (NARUC). He also participated in five Conservation Law Foundation collaborative projects in the northeastern states.

Mendl Resume Page 2

1974-1988 Administrator, Division of Systems Planning, Environmental Review and Consumer Analysis (1979-1988) Director, Bureau of Environmental and Energy Systems (1976-1979) Public Service Engineer (1974-1976) State of Wisconsin, Public Service Commission Madison, Wisconsin Mendl was employed by the Wisconsin Public Service Commission for 14 years (1974-1988), and was responsible for the development and evolution of Wisconsin's long-range planning process for electric utilities. He had overall responsibility for directing the Commission's activities concerning utility long-range plans. In addition, Mendl had overall responsibility for and directed the preparation of environmental impact statements and environmental assessments, identifying expected impacts as well as evaluating alternatives, for five large power plants, numerous transmission lines, a major natural gas pipeline, and many policy issues including Electric Space Heat, Electric Utility Tariffs, Electric Sales Promotion, Small- Power Production and Cogeneration, and Extension of Service. Mendl was also responsible for directing the preparation of major studies, including The Alternative Electric Power Supply Study, Alternative Electric Power Supply - Update, and Utility SO2 Cleanup - Cost and Capability. (The Alternative Electric Power Supply Study and Update identified renewable energy, load management and energy efficiency resources that would economically meet Wisconsin’s long term electricity needs.) Mendl testified before the Wisconsin Commission in rate cases, planning cases, construction certificate cases and policy cases. He also appeared before other state Commissions and the Federal Energy Regulatory Commission. OTHER DISTINCTIONS Mendl staffed the NARUC Subcommittee on Energy Conservation for two and one-half years, and was closely involved with the preparation of the Least-Cost Planning Handbook for Public Utility Commissioners. Mendl also was appointed to serve a four-year term on the Research Advisory Committee of the National Regulatory Research Institute (NRRI). One of seven regulatory staff selected nationally, Mendl helped NRRI to shape its research agenda to be more useful and responsive to the regulatory community. TESTIMONY Mendl, since co-founding MSB Energy Associates in 1988, has testified in the following proceedings:

Submitted To: Subject Docket No. Date

Nevada Public Utilities Commission

Nevada Power and Sierra Power Annual Renewable Energy Plans for 2014-15 program year

14-02004 2014


Southwest Gas Annual Rate Adjustment 13-06006 2013


Nevada Power and Sierra Power Annual Renewable Energy Plans for 2013-14 program year

13-02003 2013


Sierra Power ESP Update for 2013, natural gas hedging

12-08010 2012

Wisconsin Public Service Commission

Route alternatives for Wauwatosa 138 kV transmission lines

05-CE-139 2012

Mendl Resume Page 3


NPC ESP, Phase 2 of IRP case and Sierra DSM Annual Update on DSM and Integration into integrated resource planning

12-06053, 12-06052

2012


NPC ESP, Phase 1 of IRP case, on gas hedging and ESP load forecast

12-06053 2012


Nevada Power and Sierra Power natural gas procurement and prudence (DEAAs)

12-03004, 12-03005, 12-03006

2012


Nevada Power and Sierra Power Solar, Wind and Waterpower Annual Plans PY 2012-13

12-02001 2012

Arizona Corporation Commission Mohave Electric Cooperative purchased power prudence review and setting base purchased power cost rate

E-01750A-11-0136

2012


Nevada Power and Sierra Power Energy Supply Plans

11-09003, 11-09004

2011


Nevada Power and Sierra Power electric fuel and power and Sierra LDC gas cost recovery practices (DEAAs)

11-03003, 11-03004, 11-03005

2011


Nevada Power Energy Supply Plan – gas hedging and electric power sales

10-09003 2010


Sierra Pacific Power Integrated Resource Plan/Energy Supply Plan

10-07003 2010


Nevada Power and Sierra power electric fuel and power cost recovery practices (DEAAs)

10-03003 & 10-03004

2010


Nevada Power and Sierra Pacific Power Energy Supply Plan Update

09-07003 & 09-09001

2010


Glacier Hills Wind Park application by WEPCo, analyze cost/benefits and RTO dispatch

6630-CE-302

2009


Nevada Power electric fuel and power cost recovery practices (DEAA)

09-02029 2009


Sierra Power gas and electric fuel and power cost recovery practices (DEAA)

09-02030 & 09-02031

2009


Need analysis for 345 kV transmission line proposed by American Transmission Company

137-CE-147

2009

Arizona Corporation Commission Sulphur Springs Valley Electric Cooperative power procurement review

E-01575A-08-0328

2009


Nevada Power Energy Supply Plan Update

08-08030 2008

Nevada Public Utilities Sierra Power Energy Supply Plan 08-08031 2008

Mendl Resume Page 4

Commission Update


Sierra Power gas and electric fuel and power cost recovery practices (DEAA)

08-02043 & 08-02044

2008


Nevada Power fuel gas and power cost recovery practices (DEAA)

08-02042 2008


Westpac Utilities fuel purchase practices and costs (including merging of utility LPG and natural gas rates)

07-05019 & 07-05020

2007


Nevada Power Amendment to 2006 IRP and Energy Supply Plan update forward sales proposal

07-07013 2007


Sierra Pacific Power approval of 2007 IRP forward sales proposal

07-06049 2007


Southwest Gas fuel procurement practices and setting DEAA rate

07-05015 2007

Georgia Public Service Commission

Georgia Power IRP 2007 demand side management plan, energy efficiency and cost tests

24505-U 2007


Nevada Power fuel gas and power purchase practices (BTER & DEAA)

07-01022 2007


Sierra Pacific Power fuel gas and power purchase practices (BTER & DEAA)

06-12001 2007

Arizona Corporation Commission UNS Gas prudence of gas procurement practices

G-04204A-05-0831

2007


Westpac Utilities fuel purchase practices and costs (BTER & DEAA)

06-05016 & 06-05017

2006


Nevada Power Integrated Resource Plan - gas purchase strategies

06-06051 2006


Sierra Pacific Power Energy Supply Plan - gas purchase strategies

06-07010 2006


Strategic Energy Assessment - electrical adequacy through 2012

5-ES-103 2006


Nevada Power fuel gas and power purchase practices (DEAA)

06-01016 2006


Sierra Pacific Power fuel gas and power purchase practices (DEAA)

05-12001 2006

Michigan Public Service Commission

MichCon gas cost recovery factor, contingent factor, and purchase acquisition strategy

U-14717 2006


Consumers gas cost recovery factor, contingent factor, and purchase acquisition strategy

U-14716 2006

Mendl Resume Page 5


Nevada Power fuel gas and power purchase practices (BTER)

06-01016 2006


Sierra Pacific Power fuel gas and power purchase practices (BTER)

05-12001 2006


Nevada Power gas purchase practices – Energy Supply Plan

05-9017 2005


Sierra Pacific Power gas purchase practices – Energy Supply Plan

05-9016 2005


Consumers gas cost recovery factor, contingent factor, and purchase acquisition strategy

U-14403 2005



U-14401 2005

Kentucky Public Service Commission

Analysis of need for and electrical alternatives to EKPC Cranston-Rowan County transmission line

2005-00089 2005


Nevada Power gas purchase practices 04-9004 2004


Sierra Pacific Power gas purchase practices

04-7004 2004


Prudence of Southwest Gas PGA costs, purchase practices

03-12012 2004



U-13902 2004


WPS rate case, low income programs, Weston 4 pre-certification expenses and capital

6690-UR-115

2003


Alliant rate case, RiverSide purchase power cost and incentive, Columbia maintenance and outages

6680-UR-113

2003


Alliant rate case, RockGen purchase power savings bonus, coal procurement

6680-UR-112

2002


Assess fuel and purchase power issues in WPS rate case

6690-UR-114

2002


Assess fuel and purchase power issues in MG&E rate case

3270-UR-111

2002


Assess renewable energy and other alternative resources in WE Power the Future –Port Washington case

05-CE-117 2002


Assess costs related to formation and operation of American Transmission Company

05-EI-129 2002

Mendl Resume Page 6


Filed comments in investigation of purchase power incentive mechanisms

05-EI-131 2002


Alliant rate case, adequacy of planning, purchase power contracts, coal contracts

6680-UR-111

2002


Analyze proposed gas cost recovery factor and plan, and gas procurement practices.

UR-13060 2002


WPS rate case, fuel costs, adequacy of planning, purchase power

6690-UR-113

2002


Alliant fuel cost rate case, adequacy of planning, purchase power contracts

6680-UR-110

2001


Wisconsin Electric fuel rate case, fuel costs, adequacy of planning, purchase power contracts

6630-UR-111

2001


Rulemaking regarding electric utility fuel and purchased power cost recovery

1-AC-197 2001


Nuclear spent fuel dry cask storage expansion at Point Beach

6630-CE-275

2000


WPS rate case, fuel costs, adequacy of planning, purchase power

6690-UR-112

2000


Alliant fuel cost rate case, adequacy of planning, prudence of plant maintenance practices, purchase power

6680-UR-110

2000


Rulemaking regarding environmental impact analysis and public input process

1-AC-185 1999


Over-recovery of revenues due to declining coal costs

U-11560 1999


Reasonableness of proposed settlement regarding recovery of nuclear plant replacement power costs through power cost recovery factor, suspension of factor

U-11181-R 1999


Fuel and purchase power surcharge, coal costs

U-11180-R 1998

Vermont Public Service Board Prudence of Green Mountain Power purchase and management of Hydro-Quebec power

5983 1997


Analysis of coal costs, purchase practices, spot market

U-10971-R 1997


Suspension of the fuel and purchase power factor and planning in the transition to restructured utilities

U-11453 1997

Wisconsin Public Service IEC merger (of WPL/IES/IPC), need and 6680-UM- 1997

Mendl Resume Page 7

Commission environmental issues regarding proposed Mississippi River transmission crossings

100

Pennsylvania Public Utility Commission

Restructuring, stranded cost, and securitization -- economic and environmental issues

R-00973877

1997


Fuel and purchase power surcharge, impact of sales promotion

U-11181 1997


Primergy merger (of WEPCO/NSP), impact on state regulatory authority

6630-UM-100/4220-UM-101

1996


Gas cost recovery adjustments U-10640-R

1996

Pennsylvania Public Utility Commission

Electric discounted rates, gas/electric competition

R-943280C0001

1996


Fuel and purchase power surcharge, impact of WEPCO/NSP merger

U-10966 1996


Fuel and purchase power surcharge, impact of energy efficiency

U-10971 1996

Minnesota House Committee on Taxes

Impact of cogeneration project on NSP ratepayers

HF637 1996

Minnesota Senate Committee on Jobs, Energy and Community Development

Impact of cogeneration project on NSP ratepayers

SF1147 1996


Role of DSM in Advance Plan-7 in light of potential restructuring

05-EP-7 1995

City Public Service Board of San Antonio

Integrated resource planning process (1992 EPAct hearings)

NA 1994

Maryland Public Service Commission

1992 EPAct rules 8630 1994


Commercial and Industrial DSM programs for Savannah Electric

4135-U 1993

Public Utilities Commission of Ohio

Analysis of forecasts and long range plans for Ohio Power and Columbus Southern (case settled)

90-659-EL-FOR and 90-660-EL-FOR

1990


Integrated resource plan analyses for Georgia Power and Savannah Electric

4131-U and 4134-U

1992

New Orleans City Council Least-cost planning rules 14629 MCS 1991

District of Columbia Public Service Commission

Potomac Electric least-cost plan analysis

834 Phase II

1990

Massachusetts Department of Boston Gas plan integrated resource 90-55 1990

Mendl Resume Page 8

Public Utilities plans

Massachusetts Department of Public Utilities

Boston Gas commercial and industrial DSM, cost recovery

90-320 1991

Hawaii Public Service Commission Least-cost resource planning 6617 1991


Least-cost planning and facility certification rules

4047-U 1991

New Jersey Board of Public Utilities Commissioners

Transmission line certificate (case settled)

NA 1990

South Carolina Public Service Commission

Transmission line certificate

88-519-E

1988

Vermont Public Service Board Least-cost planning 5270 1988

D.C. Public Service Commission Least-cost planning 834 1987

Mendl also assisted in preparing testimony and testified in numerous cases as a senior staff witness at the Wisconsin Public Service Commission. Dates are approximate.

Advance Plans 1 through 4 (Dockets 05-EP-1 through 05-EP-4 -- on various occasions between 1977 and 1988) before the Wisconsin Public Service Commission

A wide variety of planning issues including forecasts, nuclear vs coal power, alternative energy, renewable energy, load management, transmission planning, demand-side management resources, principles and methods of integrated resource planning

Rate Cases (various occasions between 1976 and 1988) including landmark time-of-use rate case (6630-ER-2) for Wisconsin Electric Power

Environmental and consumer impacts of rate levels and alternative rate designs before the Wisconsin Public Service Commission

Construction Cases before the Wisconsin Public Service Commission Pleasant Prairie Power Plant (1976-1978) Germantown Combustion Turbines (1976-1977) Weston 3 (1979) Edgewater 5 (1980) Apple River -- Crystal Cave Transmission Line (1980) Prairie Island -- Eau Claire Transmission Line (1981-1982) North Madison -- Huiskamp -- Sycamore Transmission Line (1982) Point Beach Nuclear Plant Steam Generator Replacement (1982) Wisconsin Natural Gas Pipeline (1986) Need for power, appropriateness of the utility proposals, and the comparative economics of

alternatives, environmental impacts

Other Appearances while employed at the Wisconsin Public Service Commission Planning investigation before the Connecticut Department of Public Utilities Control

Authority (1975); uranium availability and resource alternatives Rulemaking proceedings before Wisconsin Legislative Committees (1975-1982);

planning, siting, and environmental impact analysis rules Tyrone Nuclear Project Termination cost recovery hearing before the Federal Energy

Regulatory Commission (1980) Acid Rain legislation before Wisconsin Legislative Committees (1984-1985)

Mendl Resume Page 9

Selected Clients Mendl has served the following public sector clients since 1988.

Client Nature of Service

Alaska Housing Finance Corporation

Analysis of applicability of EPAct standards to Alaska resource selection process.

American Public Power Association

Prepared whitepaper on distributed resources, “Distributed Resources: Options for Public Power” and presented it to APPA National Meeting and distributed resources workshops.

Arizona Corporation Commission

Analyze UNS Gas fuel procurement practices, provide testimony regarding prudence, and develop auditor training manual. Analyzed Sempra request to be allowed to compete for selected retail loads. Analyzed Sulphur Springs Valley Electric Coop purchase power practices. Analyzed Mohave Electric Coop purchase power practices and recommended base purchased power cot rate for purchased power cost adjustor.

California Low Income Governing Board

Analysis of options to deliver energy efficiency and assistance programs to low-income households in a restructured utility environment. Assist Board to develop low-income programs and policies under interim utility administration.

City of Chicago Evaluate municipalization, especially regarding power availability and cost, transmission constraints, cogeneration potential.

Citizen's Utility Board of Wisconsin

Evaluate energy efficiency and load management programs in light of possible industry restructuring. Evaluate fuel rate cases and recommend revenue reductions in testimony for Alliant, Wisconsin Electric, Madison Gas & Electric and Wisconsin Public Service. Assess ATC formation and operation costs. Comment on and develop fuel rules, purchase power incentives. MISO collaborative

Center for Neighborhood Technologies

Analysis of value of avoiding generation, transmission and distribution through energy efficiency, load management and distributed generation.

Clean Wisconsin Review Strategic Energy Assessments, provide comments to Wisconsin PSC

Conservation Law Foundation of New England

Collaboratives with Boston Edison, United Illuminating, Eastern Utilities Association, and Nantucket Electric regarding system planning approaches, avoided costs, resource screening. Collaborative with Green Mountain Power regarding Vermont Yankee end-of-life planning.

Dane County Energy Collaborative

Technical contractor to collaborative analyzing 345 kV transmission proposal and alternatives to meet Dane County energy needs.

District of Columbia Energy Office

Analysis of DC Natural Gas' and PEPCo's integrated resource planning.


Testimony regarding least cost planning principles and rules.

Environmental Law and Policy Analyzed potential impacts of proposed merger of Wisconsin

Mendl Resume Page 10

Center Electric Power Company and Northern States Power Company on state regulatory authority in Wisconsin and Minnesota. Analyzed environmental impacts related to proposed merger of WPL and two Iowa utilities (IES and IPC), including the proposed transmission line crossings of Mississippi River and changes in air pollutant emissions. Analyzed electric and gas energy efficiency plans in Iowa, Illinois, Michigan and Ohio

Environmentalists/Penn. Energy Project

Analyzed PECO application to securitize stranded costs, especially on economic and environmental impacts that could result from authorizing overestimated stranded costs. Analyzed utility retail access pilot programs. Analyzed restructuring plans for PECO and PP&L.

Germantown Settlement, Philadelphia

Advise regarding business structure and market to aggregate load and/or provide energy efficiency and energy assistance services to low-income households.


Developed integrated resource planning and facility certification rules. Developed integrated resource plans and reviewed utility filings. Monitored utility DSM programs. Evaluated GP demand side plan for 2007 IRP. Analyzed DSM selection process in DSM Working Group setting on behalf of Commission Staff.

Hawaii Division of Consumer Advocacy

Developed integrated resource planning rules.

Illinois Citizens Utility Board Analyzed Illinois electric supply auction, suggested modifications to better incorporate energy efficiency and demand response resources.

Iowa Department of Natural Resources

Developed and implemented workshops to train building operators and architects in energy efficiency and renewable energy resource opportunities.

Kentucky Public Service Commission

Analyzed need and alternatives for an EKPC transmission line and a prepared report. Presented testimony defending and explaining report. Analyzed need and alternatives for an AEP transmission line and a prepared report.

Lake Michigan Coalition Analyzed nuclear spent fuel dry cask storage expansion proposal

Maryland Public Service Commission

Reviewed two utility long-range plans and suggested improvements.

Massachusetts Division of Energy Resources

Analysis of Boston Gas Co. integrated resource plans and residential energy efficiency programs. Analysis of Boston Gas's commercial and industrial energy efficiency programs.

Michigan Community Action Agency Association

Analysis of Michigan electric utility restructuring proposals and impacts on retail prices. Analysis of MichCon gas cost recovery case and factor. Analyses of Indiana-Michigan, Consumers Energy, Wisconsin Electric and Northern States Power-Wisconsin power supply cost recovery cases and factors, including analysis of coal and power purchase practices, demand-side management, and nuclear plant outage costs. Analysis of Northern States Power/Wisconsin Electric Power Co. proposed merger.

Missouri Public Service Developed rules for electric resource planning and gas resource planning. Evaluated three electric utility plans filed pursuant to


Commission rules.

National Association of Regulatory Utility Commissioners

Organized, prepared and presented at five workshops throughout the U.S. sponsored by NARUC/DOE.

Natural Resources Defense Council, Mid-Atlantic Energy Project Collaborative

Evaluated resource planning and selection processes used by PSE&G to prepare plan filings.

New Jersey Department of the Public Advocate

Analyzed a transmission line application.

City of New Orleans Developed least cost planning rules, guided a public working group to develop demand-side programs.

Nevada Office of Attorney General, Bureau of Consumer Protection

Sierra Pacific Power and Nevada Power Energy Supply Plans, Base Tariff Energy Rates and Deferred Energy Adjustment Accounts - gas purchase practices and prudence; Southwest Gas and Westpac PGA prudence analysis, gas purchase practices. Purchased power costs and power sales, energy efficiency programs and cost recovery.

Nevada Public Utilities Commission, Regulatory Operations Staff

Southwest Gas PGA prudence analysis, gas purchase practices

Northeast States for Coordinated Air Use Management

Electric vehicle analysis.

Ohio Office of Consumer Council

Analyzed two utilities' long-range plans and energy efficiency resource options.

Ontario Energy Board Evaluated need for natural gas integrated resource planning rules.

The Opportunity Council Evaluated gas DSM programs to be considered by Cascade Natural Gas in Washington.

Pennsylvania Office of Consumer Advocate

Evaluated demand-side management programs for several electric utilities. Investigated causes of Winter Emergency of 1994. Analyzed electric "flexible rates" and gas/electric competition issues. Analyzed electric reliability concerns in a restructured and competitive market. Evaluated electric energy efficiency plans..

Protect Our Rural Landscape Evaluated need for and alternatives to a 345kV transmission line in Dane County Wisconsin.

RENEW Wisconsin Analyzed MG&E’s green pricing tariff, compared costs of conventional resources to green resources to determine whether a green premium tariff was appropriate

Responsible Use of Rural and Agricultural Land (RURAL)

Evaluated air and licensing issues related to a proposed power plant. Evaluated Public Service Commission proposed environmental and siting rule changes. Analyzed rules governing environmental review and public comment process and provided testimony before PSCW.

South Carolina Office of Consumer Advocate

Analyzed a transmission line application.


Southeast Wisconsin Energy Initiative

Technical contractor to collaborative analyzing 345 kV transmission proposal and alternatives to meet energy needs in southeastern Wisconsin.

Texas ROSE Developed electric planning rules. Analyzed city of San Antonio resource plan.

U.S. Environmental Protection Agency

Developed handbook, "Energy Efficiency and Renewable Energy: Opportunities from Title IV of the Clean Air Act", which focuses on how energy efficiency and renewables relate to acid rain compliance strategies.

U.S. Environmental Protection Agency and U.S. Department of Energy

Analyzed and compared utility supply- and demand-side resource selection for Clean Air Act compliance on the Pennsylvania-New Jersey-Maryland (PJM) interconnection.

Utah Committee on Consumer Services

Analyzed DSM cost recovery mechanism, avoided cost methods, cost effectiveness tests, assisted in settlement discussions and would have prepared testimony if issues not settled.

Vermont Natural Resources Council and Vermont Public Interest Research Group

Testimony regarding least cost planning principles and rules.

Vermont Public Service Board Testimony regarding the prudence of Green Mountain Power's planning and management of the Hydro-Quebec power purchase.

Wisconsin Department of Administration

Analysis of new home characteristics built in northeastern Wisconsin, permit data, survey development and report

Wisconsin’s Environmental Decade

Review of Draft Environmental Impact Statement of major 345 kV transmission line in northwestern Wisconsin, develop comments.

Resume – Geoffrey C. Crandall 1

Geoffrey C. Crandall

Vice President and Principal of MSB Energy Associates, Inc.

EDUCATION B.S. in Business and Pre-Law, Western Michigan University, 1974. Mr. Crandall has also completed courses at Michigan State University Graduate School, the University of Wisconsin-Madison and Wayne State University, in areas of federal taxation, accounting, management and the economics of utility regulation. Mr. Crandall also completed the examination for the National Conference of States on Building Codes and Standards Energy Auditor. EXPERIENCE Mr. Crandall joined MSB in January 1990. Mr. Crandall has addressed issues related to fuel and purchase power, natural gas, re-regulation, planning, regulatory issues, residential and low-income issues, energy efficiency and impacts of utility restructuring on customers in California, New York, Colorado, Iowa, and Michigan. He has analyzed and/or designed energy efficiency programs for residential customers in Michigan, Georgia, Wisconsin, Arizona, and New Orleans, and has conducted workshops on system planning, energy efficiency, low-income restructuring and energy efficiency issues in over 20 states, including Washington, Hawaii, Nevada, Kansas, Michigan, Rhode Island, California, Virginia, and New Orleans. Mr. Crandall has analyzed integrated resource plan and or energy efficiency programs in the states of Arizona, Georgia, Hawaii, Illinois, Maine, Michigan, Minnesota, North Carolina, Ohio, Pennsylvania, Utah, Washington State, California, Iowa, Montana, Colorado, Missouri, Virginia, Wisconsin, and Washington D.C. Prior to joining MSB, Mr. Crandall was employed by the Michigan Public Service Commission from 1974 through 1989, where he served in several capacities including analyst in the rates and tariff section, Technical Assistant to the Chief of Staff, and as the Director of the Demand-Side Management Division. He had responsibilities that included rate and tariff review, rate cases, utilities uncollectible and bad debts, integrated resource planning, the development, implementation and monitoring of government- and utility-sponsored demand-side management, energy-efficiency and load response policies and programs. These activities involved customers in the residential, commercial, industrial and institutional sectors. Mr. Crandall has dealt with a wide variety of regulatory issues beyond energy efficiency, including utility diversification, incentive regulation, utility billing practices, utility power plant maintenance and management of plant outages. Mr. Crandall served as Chair of the NARUC Energy Conservation Staff Subcommittee from 1986-1989. He has lectured and made presentations to many groups on demand-side programs


and least-cost planning, including two NARUC-sponsored least-cost planning conferences; the 1990 NARUC Regional Workshops on Least-Cost Utility Planning in Newport, Rhode Island and Little Rock, Arkansas; the Wisconsin Public Service Commission's Integrated Resource Planning Workshop; the 1988, 1989, and 1990 Michigan State University Graduate School of Public Utilities and the U.S. Department of Energy. Mr. Crandall has testified before the: United States Congress, Michigan Legislature, Michigan Public Service Commission, North Carolina Utilities Commission, Public Service Commission of the District of Columbia, Illinois Commerce Commission, Maine Public Utilities Commission, Massachusetts Department of Public Utilities, Public Service Commission of Hawaii, Minnesota Public Service Commission, Iowa Public Service Commission, Georgia Public Service Commission, Public Utility Commission of Ohio, Virginia Public Service Commission, Wisconsin Public Service Commission, and the City Council of the City of New Orleans, Louisiana. Mr. Crandall has written several articles published in the Public Utilities Fortnightly and Electricity Journal, Natural Gas Magazine, and a number of proceedings for the Biennial Regulatory Information Conference and the American Council for an Energy-Efficient Economy.

TESTIMONY Case No. U-5531, (8/77), Consumers’ Power Company electric rate increase application. Mr. Crandall served as the Staff Witness and recommended that the Applicant initiate the Residential Electric Customers' Information program. Case No. U-6743, (3/81), Michigan Consolidated Gas Company. Mr. Crandall served as the Staff policy witness and recommended that the Commission approve a surcharge to cover all reasonable and prudent costs associated with Applicant's implementation of the Michigan Residential Conservation Services Program. Case No. U-6819, (6/81), Michigan Power Company-Gas. Mr. Crandall served as the Staff policy witness and described the basis for the program and the expected level of activity, recommending that the Commission approve a surcharge to cover all reasonable and prudent costs associated with Applicant's implementation of the Michigan Residential Conservation Service Program. Case No. U-6787, (6/81), Michigan Gas Utilities Company. Served as the Staff policy witness and described the basis for the program and the expected level of activity, recommending that the Commission approve a surcharge to cover all reasonable and prudent costs associated with the implementation of the Michigan Residential Conservation Service Program. Case No. U-6820, (6/81), Michigan Power Company-Electric. Served as the Staff policy witness and reviewed the Applicant's request to operate the Michigan Residential Conservation Service Program. Although not mandated by federal law, Applicant chose to operate the program in


conjunction with its other services offered to residential gas customers. Recommended the establishment of a surcharge to cover all reasonable and prudent costs associated with the operation of that program. Case No. U-5451-R, (10/82), Michigan Consolidated Gas Company. Served as the Staff policy witness and described the Staff's position regarding Applicant's proposed adjustment of surcharge level. Recommended that the eligibility criteria for customers be adjusted to more accurately reflect proper fuel consumption and to include customers who would be likely to realize a seven-year return on their investment by installing flue-modification devices in conjunction with Applicant's financing program. Case No. U-6743-R, (10/82), Michigan Consolidated Gas Company. Served as the Staff policy witness regarding the Applicant's proposed expenses and revenues, as well as the reasonableness of activity and expense levels in the company's projected period. Case No. U-7341, (12/84), Detroit Edison Company, Request for Authority for Certain Non-Utility Business Activities. Represented the Staff's position during settlement discussions and sponsored the settlement agreement. Case No. U-6787-R, (3/84), Michigan Gas Utilities Company. Served as the Staff witness regarding the Applicant's proposed expenses and revenues. This also included a review of the company's future expenses associated with the Energy Assurance Program, the Specialized Unemployed Energy Analyses, and the Michigan Business Energy Efficiency Program expenses. Case No. U-8528, (3/87), Commission's Own Motion on the Costs, Benefits, Goals and Objectives of Michigan's Utility Conservation Programs. Represented the Staff on the costs and savings of conservation programs and the other benefits of existing programs, and described alternative actions available to the Commission relative to future energy-conservation programs and services and other conservation policy matters. Case No. U-8871, et al., (4/88), Midland Cogeneration Venture Limited Partnership. For approval of capacity charges contained in a power-purchase agreement with Consumers' Power Company. Served as the Staff witness on Michigan conservation potential and reasonably achievable programs that could be operated by Consumers' Power Company, and testified to the potential impact of these conservation programs on the Company's request for use of its converted nuclear plant cogeneration project. Also recommended levels of demand-side management potential for the commercial, industrial and institutional sectors in Consumers' Power service territory. Case No. U-9172, (1/89), Consumers' Power Company, Power-Supply Cost-Recovery Plan and Authorization of Monthly Power-Supply Cost-Recovery Factors for 1989. Served as Staff witness on the conservation potential and reasonably achievable programs that could be operated by Consumers' Power Company. Testified to the potential impact of these conservation programs on the Company's fuel and purchase practices, its five-year forecast and the fuel factor. Recommended levels of demand-side management potential for the commercial, industrial and institutional sectors in Consumers' Power service territory as an offset to its more-expensive


outside and internally generated power. Suggested that CPCO vigorously pursue conservation, demand-side management research, and planning and program implementation. Case No. U-9263, (4/89), Consumers' Power Company Request to Amend its Gas Rate Schedule to Modify its Rule on Central Metering. Served as a Staff witness on the conservation effect of converting from individual metered apartments to a master meter. Suggested that the Commission continue its moratorium on the master meters, due to the adverse energy-conservation and efficiency impact. Case No. E-100, (1/90), North Carolina Public Service Commission proceeding on review of the Duke Power Company's least-cost utility plan. Testified on behalf of the North Carolina Consumers' Council regarding utility energy-efficiency and demand-side management programs and the concept of profitability and implementation of demand-side management programs. Case No. 889, (1/90), Public Service Commission of the District of Columbia. Testified on behalf of the Government of the District of Columbia in the Potomac Electric Power Company's application for an increase in its retail rates (general rate case). Sponsored testimony regarding the design and implementation and overall appropriateness of PEPCO's existing and proposed energy-efficiency and conservation programs. Case No. 889, (4/90), Public Service Commission of the District of Columbia. Provided supplemental direct testimony and testified on behalf of the Government of the District of Columbia in the Potomac Electric Power Company's application for an increase in its retail rates (general rate case). Offered supplemental testimony regarding a more detailed review of PEPCO's existing pilot and full-scale energy-efficiency and conservation programs. Offered suggestions and recommendations for a future direction for PEPCO to pursue in order to implement more cost-effective and higher-impact energy-efficiency and conservation programs. Case No. ICC Docket 90-004 and 90-0041, (6/90), Illinois Commerce Commission proceeding to adopt an electric-energy plan for Central Illinois Light Company (CILCO). Testified on behalf of the State of Illinois, Office of Public Counsel and the Small-Business Utility Advocate. Reviewed the CILCO electric least-cost plan filing and the conservation and load-management programs proposed in its filing. Sponsored testimony regarding my analysis of the proposed programs, and offered alternative programs for the Company's and the Commission's consideration. Case No. D.P.U. 90-55, (6/90), Commonwealth of Massachusetts Department of Public Utilities. Testified on behalf of the Commonwealth of Massachusetts, Division of Energy Resources. Reviewed and analyzed Boston Gas' proposed energy-conservation programs that were submitted for pre-approval in its main rate case. In addition, suggested that it might consider implementation of other natural-gas energy- efficiency programs, and not award an economic incentive for energy-efficiency and conservation programs until minimum program-implementation standards are satisfied. Case No. U-9346, (6/90), Michigan Public Service Commission. Testified on behalf of the Michigan Community Action Agency Association. Reviewed and analyzed the Consumers'


Power Company rate-case filing related to energy-efficiency and demand-side management programs. Proposed alternative energy-efficiency programs and recommended program budgets and a cost-recovery mechanism. Case No. 89-193; 89-194; 89-195; and 90-001, (6/90), Maine Public Utilities Commission. Testified on behalf of the Maine Public Advocate's Office. Reviewed the appropriateness of Bangor Hydro-Electric Company's existing energy-efficiency and demand-side management programs in the context of BHE's main rate case and request for approval to construct the Basin Mills Hydro-Electric dam. Reviewed the overall resource plan and suggested alternative programs to strengthen the energy-efficiency and demand-side management resource efforts. Case No. 6617, (4/91), Hawaii Public Utility Commission. Testified on behalf of the Hawaii Division of Consumer Advocacy. Described what demand-side management resources are, why they should be included in the integrated resource planning process, and proposed the implementation of several pilot projects in Hawaii along with guidelines for the pilot programs. Case No. E002/GR-91-001, (5/91), Minnesota Public Utilities Commission. Testified on behalf of Minnesotans for an Energy Efficient Economy. Assessed the DSM programs being operated or proposed by Northern States Power Company and made recommendations as to ways in which NSP could improve its DSM efforts. Case No. 905, (6/91), Public Service Commission of the District of Columbia. Testified on behalf of the District of Columbia Energy Office. Responded to the energy-efficiency and load management aspects of Potomac Electric Company's filing and made several recommendations for DC-PSC action. Case No. 6690-UR-106, (9/91), Public Service Commission of Wisconsin. Testified on behalf of The Citizens' Utility Board of Wisconsin. Assessed the DSM programs being operated or proposed by the Wisconsin Public Service Corporation, made recommendations as to the WPSCO energy efficiency programs, and suggested ways the company could improve its DSM efforts. Case No. E002/CN-91-19, (12/91), Minnesota Public Utilities Commission. Testified on behalf of Minnesota Department of Public Service. Assessed the DSM potential and programs being operated or proposed by Northern States Power Company and made recommendations as to the potential for energy efficiency in the NSP service territory and ways in which NSP could improve its DSM efforts. Case No. 912, (4/92), Public Service Commission of the District of Columbia. Testified on behalf of the Government of the District of Columbia in the Potomac Electric Power Company's application for an increase in its retail rates for the sale of electric energy. Testified regarding the reasonableness of DSM and EUM policy changes, the cost allocation of the DSM and EUM expenses, an examination of the prudence of management regarding the energy-efficiency programs, and an examination of the appropriateness of the costs associated with energy-efficiency programs.


Case No. PUE 910050, (5/92), Virginia State Corporation Commission. Testified on behalf of the Citizens for the Preservation of Craig County regarding the need for the Wyoming-Cloverdale 765 kV transmission line. Specifically, addressed the adequacy of the DSM planning of Appalachian Power Company and Virginia Power/North Carolina Power. Made recommendations as to APCO and VEPCO's energy efficiency programs, and suggested ways the company could improve its DSM efforts. Case No. EEP-91-8, (5/92), Iowa Utilities Board. Testified on behalf of the Izaak Walton League concerning the adequacy of Iowa Public Service Company's Energy Efficiency Plan. Reviewed the plan and suggested modifications to it. Case No. 4131-U and 4134-U, (5/92), Georgia Public Service Commission. Testified on behalf of the Georgia Public Service Commission staff regarding the demand-side management portions of Georgia Power Company's and Savannah Electric and Power Company's Integrated Resource Plans. Testimony demonstrated that it is reasonable for the Commission to expect that the utilities can successfully secure substantial amounts of demand-side management resources by working effectively with customers. Case No. 917, (8/92), Public Service Commission of the District of Columbia. Testified on behalf of the District of Columbia Energy Office in hearings on Potomac Electric Power Company's Integrated Resource Planning process. Addressed a number of program-specific issues related to PEPCO's demand-side management efforts. Case No. 4132-U, 4133-U, 4135-U, 4136-U, (10/92), Georgia Public Service Commission. Testified on behalf of the Staff Adversary IRP Team of the Georgia PSC. Provided a critique of Georgia Power Company's and Savannah Electric and Power Company's proposed residential and small commercial DSM programs. Case No. 4135-U, (3/93), Georgia Public Service Commission. Testified on behalf of the Staff Adversary IRP Team of the Georgia PSC. Provided a critique of Savannah Electric and Power Company's proposed Commercial and Industrial DSM programs. Case No. R-0000-93-052, (12/93), Arizona Corporation Commission. Testified on behalf of the Arizona Community Action Association. Critiqued and made recommendations regarding the integrated resource plans and demand-side management programs of Arizona Public Service Company and Tucson Electric Power Company. Case No. 934, (4/94), Public Service Commission of the District of Columbia. Filed testimony on behalf of the District of Columbia Energy Office in hearings concerning the Washington Gas Light Company (WGL) general rate case application to increase existing rates and charges for gas service. Testimony involved critiquing and reviewing WGL's least cost planning efforts and integration of DSM, marketing and gas supply efforts. Case No. U-10640, (10/94), Michigan Public Service Commission. Testified on behalf of the Michigan Community Action Agency Association concerning the need to integrate DSM and load promotion analysis into MichCon's GCR planning process.


Case No. 05-EP-7, (3/95), Wisconsin Public Service Commission. Testified on behalf of the Citizens' Utility Board on level of utility DSM and program designs and strategies. Case No. 05-EP-7, (3/95), Wisconsin Public Service Commission. Testified on behalf of the Wisconsin Community Action Program Association on low-income customers and utility DSM programs. Case No. TVA 2020-IRP, (9/95), Tennessee Valley Authority. Testified on behalf of the Tennessee Valley Energy Reform Coalition. Assessed, critiqued and made recommendations regarding the integrated resource plans and demand-side management programs proposed by the Tennessee Valley Authority. Case No. R-96-1, (10/95), Alaska Public Utilities Commission. Testified on behalf of the Alaska Weatherization Directors Association regarding the proposed standards and guidelines for integrated resource planning and energy efficiency initiatives under consideration in Alaska. Case No. D95.9.128, (2/96), Montana Public Service Commission. Testified on behalf of the District XI Human Resources Council concerning the low-income energy efficiency programs offered by the Montana Power Company. Case No. DPSC Docket No. 95-172, (5/96), Delaware Public Service Commission. Prepared draft testimony on behalf of the Low-Income Energy Consumer Interest Group regarding Delmarva Power & Light Company's application to revise its demand-side programs. The case was settled, with LIECIG obtaining funding for low-income energy efficiency programs, prior to testimony. Case No. U-11076, (8/96), Michigan Public Service Commission. Testified on behalf of the Michigan Community Action Agency regarding the Michigan Jobs Commission's recommendations regarding electric and gas reform. Discussed the implications of utility restructuring and the needs of residential and low-income households, and proposed regulatory and industry solutions. Case No. 96-E-0897, (3/97), New York Public Service Commission. Prepared draft testimony for New York's Association for Energy Affordability regarding the impact of proposed utility restructuring plans on low-income customers. The case was settled in spring 1997. Case No. R-00973954, (7/97), Pennsylvania Public Utilities Commission. Testified on behalf of the Commission on Economic Opportunity regarding the economics of demand-side measures and programs proposed for implementation by Pennsylvania Power & Light Company. Case No. 98-07-037, (7/98), California Public Utilities Commission. Testified on the California Alternative Rates for Energy and the Low Income Energy Efficiency programs regarding the implementation and adoption of revisions to these programs necessitated by the AB 1890 and the Low Income Governing Board.


Case No. U-12613, (3/01), Michigan Public Service Commission. Testified on behalf of the Michigan Community Action Agency regarding the Wisconsin Public Service Corporation application to implement PA 141 the electricity deregulation law. I reviewed the portions of the filing related to their provision of electric energy efficiency and load management. Case No. U-12649, (3/01), Michigan Public Service Commission. Testified on behalf of the Michigan Community Action Agency regarding the Wisconsin Electric Power Company and the Edison Sault Electric Company application to implement PA 141 Michigan’s electricity deregulation law. I reviewed the portions of the filing related to their provision of electric energy efficiency and load management. Case No. U-12651, (3/01), Michigan Public Service Commission. Testified on behalf of the Michigan Community Action Agency regarding the Northern States Power Company – Wisconsin application to implement PA 141 the electricity deregulation law. I reviewed the portions of the filing related to their provision of electric energy efficiency and load management. Case No. U-12652. (3/01), Michigan Public Service Commission. Testified on behalf of the Michigan Community Action Agency regarding the Indiana Michigan Power Company d/b/a American Electric Power application to implement PA 141 the electricity deregulation law. I reviewed the portions of the filing related to their provision of electric energy efficiency and load management. Case No. U-12725, (4/01), Michigan Public Service Commission. Testified on behalf of the Michigan Community Action Agency regarding the Wisconsin Electric Power Company and the Edison Sault Electric Company application to increase its residential rates. I reviewed the portions of the filing related to their provision of electric energy efficiency and load management and recommended a significant increase in these activities. Case No. U-13060, (12/01), Michigan Public Service Commission. Testified on behalf of the Michigan Community Action Agency regarding the Michigan Consolidated Gas Company application for Approval of their Gas Cost Recovery Plan and Five-Year gas Forecast. I reviewed the filing and recommended the Commission reject the proposed GCR factor and suggested continuation of the existing GCR factor or adopt an adjusted MCAAA sponsored GCR factor. I also suggested a set-aside allocation be designated for low-income customers to ensure access to alternative gas providers under the applicant’s customer choice program. Case No. 6690-UR-114, (9/02), Wisconsin Public Service Commission. Testified on behalf of the Citizens Utility Board regarding the Wisconsin Public Service Corporation application to increase its electric and natural gas rates. I reviewed the portions of the filing related to their low-income assistance/weatherization and the proposed executive compensation incentive plan. Case No. U-14401, (04/05), Michigan Public Service Commission. Testified on behalf of the Michigan Community Action Agency regarding the Michigan Consolidated Gas Company application for Approval of their Gas Cost Recovery Plan and Five-Year gas Forecast. I


reviewed the filing and recommended the Commission reject the proposed plan and suggested initiation of strategies that would lower the need to acquire expensive and unnecessary gas supplies. Case No. U-14401-R, (10/05), Michigan Public Service Commission. Testified on behalf of the Michigan Community Action Agency regarding the Michigan Consolidated Gas Company application re-opener Approval of their Gas Cost Recovery Plan and Five-Year gas Forecast. I reviewed the filing and recommended the Commission reject the proposed plan and suggested initiation of strategies that would lower the need to acquire expensive and unnecessary gas supplies. Case No. U-14701, (02/06), Michigan Public Service Commission. Testified on behalf of the Michigan Environmental Council and The Public Interest Group In Michigan regarding the Consumers Energy Company application for Approval of a Power Supply Cost Recovery Plan and for Authorization of Monthly Power Supply Cost Recovery Factors for Calendar Year 2006. I reviewed the filing including the application, testimony, exhibits, discovery responses and submitted testimony recommending that the Commission not approve the five-year PSCR plan as filed due to the impacts related to the Palisades sale and the absence of alternative resources in the projected five-year resource portfolio. Case No. U-14702, (02/06), Michigan Public Service Commission. Testified on behalf of the Michigan Environmental Council and The Public Interest Group In Michigan regarding The Detroit Edison Company application for authority to implement a Power Supply Cost Recovery Plan in its rate schedules for 2006-metered jurisdictional sales of electricity. I reviewed the application, testimony, exhibits and submitted testimony that recommended that the Commission not approve the proposed five-year PSCR plan as filed due because it was deficient in its selection of alternative resources in the projected five-year resource portfolio. Case No. U-14992, (12/06), Michigan Public Service Commission. Testified on behalf of the Michigan Environmental Council and The Public Interest Group In Michigan regarding The Consumers Energy Company application for approval of the proposed Power Purchase Agreement in connection with the sale of the Palisades Nuclear Power Plant and other assets. The purpose of my testimony was to address the overall soundness of this application and proposal. I reviewed the application, testimony, exhibits and submitted testimony that recommended that the Commission not approve the proposed purchase power agreement and transfer the ownership of the nuclear plant and other assets. Case No. 06-0800, (3/07), Illinois Commerce Commission. Provided testimony on behalf of the Illinois Citizens Utility Board regarding the Illinois electricity resource auction process. I assessed the existing resource/power supply auction based bidding process and recommended modifications and improvements to the Illinois resource acquisition mechanism. Case No. 24505-U, (5/07), Georgia Public Service Commission. Testified on behalf of the Georgia Public Service Commission Advocacy staff regarding the demand-side management portions of Georgia Power Company's Integrated Resource Plans. Testimony demonstrated that it is reasonable for the Commission to approve the five proposed DSM programs and expect that


Georgia Power can successfully secure considerably more demand-side management resources by working effectively with its customers. Case No. U-14992, (11/07), Michigan Public Service Commission. Testified on behalf of the Michigan Environmental Council and The Public Interest Group In Michigan regarding The Consumers Energy Company rate application for approval of a rate increase and the recovery of energy efficiency programs and certain costs in connection with the sale of the Palisades Nuclear Power Plant and other assets. I reviewed the application, testimony, exhibits and submitted testimony that recommended that the Commission not approve the recovery of transaction costs involving the transfer the ownership of the nuclear plant and other assets and on various aspects of its proposed energy efficiency programs and proposed incentives. Case No. 07-0540, (12/07), Illinois Commerce Commission. Provided testimony on behalf of the Environmental Law and Policy Center regarding the Commonwealth Edison Company application for approval of its proposed Energy Efficiency and Demand Response Plan. I assessed the proposed energy efficiency and demand response plan and recommended modifications and improvements to the proposed plan filing. Case No. 07-0539, (12/07), Illinois Commerce Commission. Provided testimony on behalf of the Environmental Law and Policy Center regarding the Central Illinois Light Company d/b/a and Ameren CIPS CENTRAL ILLINOIS PUBLIC SERVICE COMPANY and Ameren CIPS ILLINOIS POWER COMPANY d/b/a Ameren IP application for approval of its proposed Energy Efficiency and Demand Response Plan. I assessed the proposed energy efficiency and demand response plan and recommended modifications and improvements to the proposed plan filing. Case No. U-15415, (2/08), Michigan Public Service Commission. Testified on behalf of the American Association of Retired People regarding The Consumers Power Company application for approval for authority to implement a Purchase Power recovery plan, 5-year forecast, and monthly PSCR factors for the 12-month period calendar year 2008. I reviewed the application, testimony, exhibits and submitted testimony that recommended that the Commission adopt a more effective and less expensive resource acquisition procedure to help keep the cost of energy down in Michigan. Case No. U-15417, (4/08), Michigan Public Service Commission. Provided testimony on behalf of the American Association of Retired People regarding The Detroit Edison Company for Authority to Implement a Power Supply Cost Recovery Plan in its Rate Schedule for 2008 Metered Jurisdictional Sales of Electricity. I reviewed the application, testimony, exhibits and submitted testimony that recommended that the Commission adopt a more effective and less expensive resource acquisition procedure to help keep the cost of energy down in Michigan. Case No. U-15244, (7/08), Michigan Public Service Commission. Provided testimony on behalf of the Michigan Environmental Council and The Public Interest Group In Michigan regarding The Detroit Edison Company request for Authority to increase rates, amend its rate schedules and rules governing the distribution and supply of electric energy, and for miscellaneous accounting authority. I reviewed the application, testimony, and exhibits and submitted


testimony that recommended that the Commission direct DECO to make modifications to its Integrate Resource Planning analysis. Case No. EEP-08-2, (7-08), Iowa Public Utilities Board. Provided testimony on behalf of the environmental interveners regarding the request of the Mid American Energy Company for approval of an Energy Efficiency Plan. I made an assessment of the proposed energy efficiency and demand response plan and recommended modifications and improvements to the implementation strategy and proposed programs. Case No. EEP-08-1, (8-08), Iowa Public Utilities Board. Provided testimony on behalf of the environmental interveners regarding the Interstate Power and Light Company request for approval of an Energy Efficiency Plan. I made an assessment of the proposed energy efficiency and demand response plan and recommended modifications and improvements to the proposed programs and implementation strategy. Case No. 137-CE-147, (2-09), Public Service Commission of Wisconsin. Provided testimony on behalf of PRESERVE OUR RURAL LANDS regarding the Application of American Transmission Company, as an Electric Public Utility, to Construct a new 345 kV Line from the Rockdale Substation to the West Middleton Substation, Dane County, Wisconsin. I suggested modifications of the proposal and rejection of the approval of the line. Case No. M2009-2093218, (8-09), Pennsylvania Public Utility Commission. Provided testimony on behalf of The Office Of Consumer Advocate regarding the West Penn Power Company d/b/a Allegheny Power Energy Efficiency and Conservation Plan request for plan approval. I analyzed the proposed plan and made an assessment of the proposed energy efficiency and demand response and cost recovery plan. I suggested modifications and improvements to the proposed programs as well as the proposed implementation strategy. Case No. 09-1947-EL-POR, 09-1948-EL-POR, 09-1949-EL-POR, 09-1942-EL-EEC, 09-1943-EL-EEC, 09-1944-EL-EEC, POR, 09-580-EL-EEC, 09-580-EL-EEC, 09-580-EL-EEC, Public Utilities Commission of Ohio. Provided testimony on behalf of The Office Of The Environmental Law and Policy Center regarding the Ohio Edison Company, The Cleveland Electric Illuminating Company and the Toledo Edison Company for approval of their energy efficiency and peak demand reduction program portfolio and associated cost recovery mechanism and approval of their initial benchmark reports and in the matter of the energy efficiency and peak demand reduction programs. I reviewed, analyzed and assessed the appropriateness of the proposed plans, benchmark reports and proposed peak reduction program portfolio. I suggested modifications and improvements to the proposed programs. I also made recommendations regarding the proposed implementation strategy as well as accounting and program cost tracking. Case No. U-16412, (10/10), Michigan Public Service Commission. Provided testimony on behalf of the Natural Resources Defense Council, Michigan Environmental Council and The Environmental Law and Policy Center regarding the Consumers Energy Company request to


amend its natural gas & energy efficiency Energy Optimization Plan. I reviewed the application, testimony, exhibits, discovery responses and submitted testimony that recommended modifications to the proposed Energy Optimization Plan. Case No. 10-0570, (11/10), Illinois Commerce Commission. Provided testimony on behalf of the Environmental Law and Policy Center regarding the Commonwealth Edison Company application for approval of its proposed Energy Efficiency and Demand Response Plan. Assessed the proposed energy efficiency and demand response plan and recommended modifications and improvements to the proposed plan filing. Case No. 10-0568, (11/10), Illinois Commerce Commission. Provided testimony on behalf of the Environmental Law and Policy Center regarding the Central Illinois Light Company d/b/a and Ameren CIPS CENTRAL ILLINOIS PUBLIC SERVICE COMPANY and Ameren CIPS ILLINOIS POWER COMPANY d/b/a Ameren IP application for approval of its proposed Energy Efficiency and Demand Response Plan. Assessed the proposed energy efficiency and demand response plan and recommended modifications and improvements to the proposed plan filing. Case No. 10-0564, (11/10), Illinois Commerce Commission. Provided testimony on behalf of the Environmental Law and Policy Center regarding the People’s Gas Light and Coke Company and North Shore Gas Company request for approval of its proposed Energy Efficiency Plan. Assessed the proposed energy efficiency and demand response plan and recommended modifications and improvements to the proposed plan filing. Case No. 10-0567, (11/10), Illinois Commerce Commission. Provided testimony on behalf of the Environmental Law and Policy Center regarding the Northern Illinois Gas Company application for approval of its proposed Energy Efficiency Plan and approval of Rider 30, Energy Efficiency Plan Cost recovery and related changes to Nicor tariffs. Assessed the proposed energy efficiency and demand response plan and recommended modifications and improvements to the proposed plan filing. Case No. M-2010-2210316, (3/11), Pennsylvania Public Utility Commission. I provided testimony on behalf of The Office Of Consumer Advocate regarding the UGI Utilities, Inc. Electric Division (UGI-Electric) request for Efficiency and Conservation Plan approval. I analyzed the proposed plan and made an assessment of the proposed energy efficiency and demand response and cost recovery plan. I suggested modifications and improvements to the proposed programs and implementation strategy. Case No. 11-07026 and 11-07027, (11/11), Public Utilities Commission of Nevada. I provided testimony on behalf of the Bureau of Consumer Protection regarding both the Sierra Pacific Power Company and Nevada Power Company 2011 Annual Demand Side Management Update reports. I reviewed the filings and made recommendations regarding various aspects of demand response resources and demand side management portfolios.


Case No., U-16671 (01/12), Michigan Public Service Commission. I provided testimony on behalf of the Environmental Law and Policy Center regarding the reasonableness of the Detroit Edison Company’s filing and assertions made by a witness regarding a net-to-gross factor relative to the 2010 and 2011 energy efficiency programs implemented in response to Public Act 295 of 2008. Case Nos. P-2012-2320468, P-2012-2320480, P-2012-2320484, P-2012-2320450, (10/12), Pennsylvania Public Utility Commission. I provided testimony on behalf of The Office Of the Consumer Advocate regarding the application of Metropolitan Edison Company, Pennsylvania Electric Company, West Penn Power, Pennsylvania Power Company on the Energy Efficiency regarding the benchmarks established for the period June 1, 2013 through May 31, 2016. I analyzed the proposed adjustments of Phase II Energy Efficiency and Conservation target levels and energy efficiency acquisition costs. Case No. Case Nos. 12-2190-EL-POR, 12-2191-EL-POR, 12-2192-EL-POR, (10/12) Application of Ohio Edison Company, The Cleveland Electric Illuminating Company and the Toledo Edison Company for Approval of their energy efficiency and peak demand reduction program portfolio plan for 2013-2015. I provided testimony on behalf of Ohio Environmental Council and The Environmental Law and Policy Center regarding the Ohio Edison Company, The Cleveland Electric Illuminating Company and the Toledo Edison Company for approval of their 2013-2015 energy efficiency and peak demand reduction program portfolio. I reviewed, analyzed and assessed the appropriateness of the proposed plans, benchmark reports and proposed peak reduction program portfolio. I suggested modifications and improvements to the proposed programs and made recommendations and proposed new approaches to the proposed implementation strategy. Case No., 12-06052 and 12-06053 (10/12), Public Utilities Commission of Nevada, I provided testimony on behalf of the Attorney General of the State of Nevada, Bureau of Consumer Protection regarding both the Sierra Pacific Power Company and Nevada Power Company 2013-2015 Triennial Integrated Resource Plan covering the period 2013-2032 and Approval of its Energy Supply Plan for the period 2013-2015. I reviewed, analyzed and assessed the appropriateness of the proposed plans and proposed peak reduction portfolio. I suggested modifications and improvements to the proposed programs and made recommendations and proposed new approaches to the implementation strategy. Case No. U-16434-R, (10/12), Michigan Public Service Commission. Provided testimony on behalf of the Michigan Community Action Agency Association regarding The Detroit Edison Company for Reconciliation of its Power Supply Cost Recovery Plan for 12-month Period Ending December 31, 2011. I reviewed the application, testimony, exhibits and submitted testimony that recommended that the Commission adopt a remedy in regards to several aspects of the Reduced Emission Fuels projects that Detroit Edison was involved in.


Case No. Docket No. M-2012-2334388 (12/12), Pennsylvania Public Utility Commission. I provided testimony on behalf of The Office of the Consumer Advocate regarding the Petition of PPL Electric Utilities Corporation for Approval of an Energy Efficiency and Conservation Plan. I analyzed the proposed plan and made an assessment of the proposed energy efficiency and demand response and cost recovery plan. I suggested modifications to the proposed programs and implementation strategy to enhance its effectiveness. Case No. U-17097, (03/13) Michigan Public Service Commission. Provided testimony on behalf of the Michigan Community Action Agency Association regarding The Detroit Edison Company filing for Reconciliation of its Power Supply Cost Recovery Plan for 12-month Period Ending December 31, 2013. I reviewed the application, testimony, exhibits and submitted testimony recommending that the Commission adopt a remedy regarding the Reduced Emission Fuels projects that Detroit Edison was participating in. Case No. U-17095, (04/13) Michigan Public Service Commission. Provided testimony on behalf of the Michigan Community Action Agency Association regarding The Consumers Electric Company Application for Approval of A Power Supply Cost Recovery Plan and for Authorization of Monthly Power Supply Cost Recovery Factors for 2013. I reviewed the application, testimony, and exhibits and submitted testimony recommending that the Commission reject the proposed five-year resource plan. I also recommend that the Commission prohibit CECO from collecting capital related investments for a pipeline in Zeeland, Michigan. I also recommended that CECO demonstrate to the Commission that the Palisades and MCV generation plants purchase power agreements are cost-effective, being complied with and are in the public interest. Case No. EEP-2012-0001, (4-13), Iowa Public Utilities Board. Provided testimony on behalf of the environmental interveners regarding the Interstate Power and Light Company 2014-2018 Energy Efficiency Plan. I made an assessment of IPL’s proposed resource planning as well their energy efficiency, renewable energy and demand response resources. I recommended modifications and improvements to the proposed programs, implementation and resource measurement strategy. Case No. U-17131, (04/13), Michigan Public Service Commission. Testified on behalf of the Michigan Community Action Agency regarding the Michigan Consolidated Gas Company application for Approval of their Gas Cost Recovery Plan and Five-Year gas Forecast and approval to implement a reservation charge. I reviewed the filing and recommended the Commission require MichCon to initiate procurement strategies that would reduce the heavy reliance that is being placed on the 75% VCA gas procurement strategy. Case No. U-17133, (04/13), Michigan Public Service Commission. Testified on behalf of the Michigan Community Action Agency regarding the Consumers Energy Company application for approval of its gas cost recovery plan and authorization of a gas cost recovery factor from April 2013- March 2014. I reviewed the filing and made recommendations regarding the Quartile Fixed Price Purchases Gas purchasing strategy used by CECO.


Case No. EEP-2012-0002, (6/13), Iowa Public Utilities Board. Provided testimony on behalf of the environmental interveners regarding the Mid American Energy Company 2014-2018 Energy Efficiency Plan. I made an assessment of MidAm’s proposed resource planning as well their energy efficiency, renewable energy and demand response resources. I recommended modifications and improvements to the proposed programs, implementation and resource measurement strategy. Case No. 13-0431-EL-POR (08/13) regarding the Application of Duke Energy Ohio, Inc. for Approval of its Energy Efficiency and Peak Demand Reduction Portfolio of Programs. I provided testimony on behalf of Ohio Environmental Council and The Environmental Law and Policy Center regarding Duke Energy Ohio, Inc. for approval of their revised energy efficiency and peak demand reduction program portfolio. I analyzed and reviewed the appropriateness of the revised plan and proposed peak reduction program portfolio. I suggested that significant additions and modifications be made before the proposed programs were approved. I offered specific program recommendations and new elements be added to their programs and implementation strategy. Case No. 13-0498, (10/13), Illinois Commerce Commission. Provided testimony on behalf of the Environmental Law and Policy Center regarding the request by Ameren Illinois for approval of its proposed Energy Efficiency and Demand Response Plan 3. Assessed the proposed energy efficiency and demand response plan and recommended modifications and improvements to the proposed plan filing. Case No. 13-0499 (10/13), Illinois Commerce Commission. Provided testimony on behalf of the Environmental Law and Policy Center regarding the request by The Illinois Department of Commerce and Economic Opportunity for approval of its proposed Energy Efficiency Plan 3. Assessed the proposed energy efficiency plan and recommended modifications and improvements to the proposed plan filing. Case No. 13-0495 (11/13), Illinois Commerce Commission. Provided testimony on behalf of the Environmental Law and Policy Center regarding the request by Commonwealth Edison application for approval of its proposed third Energy Efficiency Plan. I assessed the proposed energy efficiency plan and recommended modifications and enhancements to the proposed plan. Case No. 13-0550 (12/13), Illinois Commerce Commission. Provided testimony on behalf of the Environmental Law and Policy Center regarding the request by North Shore Gas Company and The Peoples Gas Light and Coke Company for approval of its proposed second Energy Efficiency Plan. I assessed the proposed energy efficiency plan and recommended modifications and enhancements to the proposed plan. Case No. 13-0549, (01/14), Illinois Commerce Commission. Provided testimony on behalf of the Environmental Law and Policy Center regarding the Northern Illinois Gas Company d/b/a/ Nicor for approval of its proposed second Energy Efficiency Plan, Cost recovery and related changes to Nicor tariffs. I assessed the proposed energy efficiency plan and recommended modifications and improvements to the proposed plan filing.


Case No. U-17319, (06/14), Michigan Public Service Commission. Testified on behalf of the Great Lakes Renewable Energy Association regarding the DTE Electric Company application for authority to implement a Power Supply Cost Recovery Plan in its Rate Schedules for 2014 Metered Jurisdictional Sales. I reviewed the five-year plan filing and made recommendations regarding the integrated resource planning process and resources selected and planned to be used in the five year planning period. In addition, I have served the following public sector clients since 1990.

Client Nature of Service

Alaska Housing Finance Corporation

Analysis of energy efficiency, system planning and applicability of Energy Policy Act standards to Alaska resource selection process.

California Low Income Governing Board

In conjunction with AB 1890 the state’s restructuring statute provided analyses of options to deliver energy efficiency and assistance programs to low-income households in a restructured utility environment. Assisted the CPUC and Low Income Governing Board in developing low-income energy assistance and energy efficiency programs, implementation methods and procedures under interim utility administration.

Conservation Law Foundation of New England

Provided technical support to the collaborative working groups with Boston Edison, United Illuminating, Eastern Utilities Association, and Nantucket Electric regarding system planning approaches, energy efficiency programs and resource screening.


Testimony regarding demand-side management, least cost planning principles.

Germantown Settlement, Philadelphia

Analysis and technical support regarding business structure and market to aggregate load and/or provide energy efficiency and energy assistance services to low-income households.

City of New Orleans Developed least cost planning rules, guided a public working group to develop demand-side programs, and developed a low income, senior citizens energy efficiency program.

Oak Ridge National Laboratory

Prepared an economic analysis of the customer impact from various electricity restructuring configurations for the State of Ohio


Ohio Office of Consumer Council

Analyzed two utilities' long-range plans and energy efficiency resource options. Analyzed the Dominion East Gas Company application to be relieved of the merchant function.

Ontario Energy Board Developed demand-side management programs and evaluated need for natural gas integrated resource planning rules.

U.S. Environmental Protection Agency

Developed handbook, "Energy Efficiency and Renewable Energy: Opportunities from Title IV of the Clean Air Act",

which focuses on how energy efficiency and renewables relate to acid rain compliance strategies.

U.S. Environmental Protection Agency and U.S. Department of Energy

Analyzed and compared utility supply- and demand-side resource selection for Clean Air Act compliance on the Pennsylvania-New Jersey-Maryland (PJM) interconnection.

Washington State Weatherization Directors

Natural Gas energy conservation program design involving Cascade Natural Gas Company

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APPENDIX B: CETF PROPOSED WORK PLAN AND BUDGET CETF is in need of funding for this intervention. Unlike many of the other organizational intervenors, CETF is not receiving compensation under the PSC’s general Inervenor Compensation program. What funds that CETF has, at $300, will be utilized in support of this intervention. CETF is investing in filing of an application for IRS 501(c)(3) status to build its capacity for public education and participation in energy policy issues before the Commission and other relevant policy organizations and venues. The work of CETF will not be duplicative as CETF is strongly opposed to this project, has committed to challenging need for this project, focused on policy based issues. As with the CapX 2020 Hampton-La Crosse transmission project, many of the organizational intervenors are intervening in support of this project and to the extent that CETF’s work may have a similar subject matter, CETF’s is a critical perspective is, not one of support. No other party is focused on the issues that CETF is raising, as detailed above. In this proceeding, CETF’s intervention would focus on public interest and policy issues incorporated in the Commission’s statutory review criteria for transmission projects, including:

Review of need claim for this project, drivers of regional transmission expansion plans and transmission proposals, and associated policy issues such as:

o State authority, statutory and jurisdictional issues in light of regional

planning and wholesale electricity market and implication of “approval” of projects by MISO;

o Market transformation, centralization and wholesale energy market impacts related to project;

o Characterization of reliability, congestion, reliability benefits and regional

benefits; delineated by who pays and who benefits, and by how much;

o “Peak” as justification for transmission, with focus on coincident v. non-coincident, dedicated use of DSM as capacity v. demand response and peak reduction;

o Security concerns inherent n an interconnected grid, and capturing the

risks, costs, and alternatives in analysis of regional transmission;

o MVP 5 and MISO MVP Portfolio, consideration of all costs approved by MISO and set by MISO/ FERC tariff; externalities, line loss; and

o CPCN as demonstration of “need” for eminent domain condemnation,

where need largely driven by economic benefits to utilities and/or other regions, and where viable alternatives greatly reduce the taking of land;

21

Wisconsin’s Energy Hierarchy as set forth in Wis. Stat. § 1.12(4) and Wis. Stat. §196.025(1)(b)(1) and its role in planning at state and MISO;

o Consideration of statutory requirements to consider system and non-

transmission alternates, taking into account fuel mix relative to hierarchy and use of integrated resource planning versus single solution selection;

o How characterization of need claim affects alternatives under consideration; and

Environmental and health considerations:

o Climate change implications of project and compliance with Clean Air Act and evaluation of project against carbon reduction benefits of other solutions;

o Health and migratory impacts associated with transmission i.e., corona/ultra violet, routing both generally and near pollutants such as dust producing sand mines, avian and animal habitat, etc., and the application of the precautionary principle when scientific investigation proves there is a possible risk in these activities.

o Segmentation of MISO MVP and CapX 2020 projects.

CETF is seeking intervenor compensation for the expenses of intervention, consultants, and the cost of discounted attorneys fees, as itemized below. CETF will benefit from an in-kind donation of legal services, representing 1/3 of the conservative estimate, below, of expected cost in this Intervenor Compensation request. Time allotted for tasks reflects that we expect to utilize some information and materials from our intervention files.

Budget for Attorney Fees - Carol A. Overland, Attorney for CETF at $185/hr:

Task Hours Dollars

Review Application & docket filings, issue identification, and monitoring docket throughout

20 3,700

Research WI statute & rules; transmission issues for this proceeding, MISO reports and dockets, utility studies, FERC cost allocation dockets.

15 2,775

Discovery – Prepare Discovery and review those of others, review answers

18 3,330

Review DEIS & Draft Comments 10 1,850

Draft Testimony – Work with witnesses on Direct, Rebuttal, Surrebuttal & prepare exhibits

35 6,475

Testimony of Applicants and Intervenors – review testimony & exhibits

18 3,330

Cross-Examination – Prep and prefile per Order 15 2,775

22

Public Hearings 5.5hr/6days 16 2,960

Technical Hearing in Madison - 11hr/5 days (hearing and daily prep)

55 10,175

Initial & Reply Briefs, review record & transcript 44 8,140

Review & respond to staff Memorandum/Matrix 12 2,220

Consultation with other parties 10 1,850

Prehearing Conferences – 2? & travel 6 1,110

Motion practice, i.e. Discovery (if necessary) 8 1,480

Total: 282 52,170

CETF Intervenor Compensation Request (2/3): 34,780

Copies: $1,500 Copies (lower if paper copies of exhibits to PSC not required) Travel: $1,700 Mileage, lodging, per diem for PHC, Public and Tech. Hrgs $3,200

Expenses: $ 3,200.00 Attorneys fees: $34,780.00 TOTAL: $37,980.00 CETF Board member Deb Severson, with assistance of George Nygaard, will serve as staff and participate in the proceeding on behalf of CETF. Duties include DEIS review and comments, review of application and testimony, preparation for the technical hearings, participation in technical hearings and public hearings.

Budget for CETF’sDeb Severson and George Nygaard (unpaid) as staff:

Task Time Rate Total

Review Application & docket filings, Commission discovery, issue identification, and monitoring docket throughout 110 8 880

Discovery – Prepare Discovery and review those of others, review answers 35 15 525

Review DEIS & Draft Comments 35 8 280

Testimony – Work on selection and preparation of exhibits 10 15 150

Review All Testimony 25 8 200

Cross-Examination – Prep for technical hearing 10 15 150

Public Hearings 5.5 hr/6 days 33 8 264

Technical Hearing in Madison – 11hr/5 days (hearing and daily prep) 55 8 440

Initial & Reply Briefs, review record & transcript 40 15 600

Review & respond to staff Memorandum 25 15 375

Consultation with attorney (if necessary) 40 15 600

Totals: 418 4464

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Materials/Supplies Expenses

Expenses related to supplies and materials, content placement, technology and printing for displays and other activities related to intervention. Travel, Lodging, per diem: $1,500.00

Total: $1,500.00

CETF RELATED TOTAL:

CETF Attorneys Fees – Carol Overland $34,780.00 Expenses (travel, lodging, per diem): $ 3,200.00 Deb Severson $ 4,464.00 Expenses (travel, lodging, per diem): $ 1,500.00 $43,944.00

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Legalectric, Inc. Carol Overland, Attorney at Law MN #254617 Energy Consultant—Transmission, Power Plants, Nuclear Waste [email protected]

1110 West Avenue P.O. Box 69 Red Wing, Minnesota 55066 Port Penn, Delaware 19731 612.227.8638 302.834.3466

FEDERAL PROCEEDINGS

Nuclear Regulatory Commission

2008 Prairie Island Nuclear Plant relicensing – EIS Scoping Comments

2005 Monticello Part 72 license for dry cask storage for high level nuclear waste. Docket No. 72- Comments on scope of EIS

2000 Intervention in NSP’s transfer of operating licenses to Nuclear Management Company, LLC. Intervention and solicited interventions from others.- Docket Nos. 50-263, 50-282, 50-306, 72-10

1/97-present Participation regarding PFS (NSP/Xcel driven LLC) application for spent fuel storage facility in Skull Valley, UT. Assist Utah’s EQC & A.G. in strategy, information and document exchange, §2.206 petition re: Emergency Plan, & Minn. PUC IRP. Individual submission of comments on record, organization comments, and Commentary pieces in Deseret News (SLC paper). Coordinate campaign with allies including Downwinders. Docket 72-22.

2000 Yucca Mountain DEIS Comments

2000 Comments and Meetings regarding NRC plant safety rule revisions. Independent participation.

1998 Comments on Financial Qualifications & Assurance Rulemaking

1998 §2.206 Petition – Nuclear Waste Dry Cask Unloading

1996-1998 Intervention at NRC, representation of Florence Township regarding NSP’s application for dry cask storage in Florence Township, from Petition to Withdrawal of application, including 2 §2.206 Petitions re: Emergency Plan and Permanency. Docket 72-12. Federal Energy Regulatory Commission

2012 – 2013 Citizens Energy Task Force and No CapX 2020 Complaint against CapX 2020 utilities regarding system instability; FERC Docket EL13-49

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Department of Energy

2005 Excelsior Energy – FOIA and Comment for EIS for $1.97 billion in guaranteed loans for project deemed too risky for private investment

Rural Utilities Service 2009 – 2012 CapX 2020 transmission – Hampton to LaCrosse EIS

National Park Service 2009 – 2012 Susquehanna-Roseland transmission EIS – Delaware Water Gap U.S. Forest Service, U.S. Army Corps of Engineers, MN DNR 2013 & 2014 PolyMet – Comments on Draft and Supplemental EIS

STATE OF MINNESOTA PROCEEDINGS Minnesota District and Appellate Courts (utility, land use and public interest) 2012 – 2013 Representing St. Paul’s Lutheran School and Church in Appeal of CapX

Hampton-LaCrosse Segment 1 Appellate Case No:A12-1607 2012 – 2013 Representing Laymen for Christ in Appeal of CapX Hampton-LaCrosse

Segment 3 transmission siting Appellate Case No.: A12-1632 2012 – 2013 Amicus brief – Transmission “Buy the Farm” Minn. Stat. §216F.12, Subd. 4

Appellate Case No. A11-1116 2010 – 2011 Amicus brief in appeal of AWA Goodhue Wind Project Permit – A11-2229 2009 – 2010 CapX 2020 Transmission Project – Certificate of Need

Appellate Court File: A09-1646 – New Information, Offer of Proof and EIS inadequacy

2009 Great River Energy Transmission Line – for private client Cass County Court File: CV-08-223 2007 Rice County Land Use Accountability v. Rice County Rice Co. District Court File: C7-05-2141 MERA claim - land use issues 2006 Deschamp v. ABC Housing C1-05-692 Mold house jury verdict against major developer in Faribault 2005 Rice County Land Use Accountability v. Rice County District Court File: C7-05-2141 MERA claim - land use issues 2001 Appeal of Permit Approval of Duluth City Council, Appellate Court Appellate

Court File: C1-01-1933

Appeal of Permit Approval of Duluth City Council, St. Louis County

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District Court (served, but not filed – no funding)

Appeal – In the Matter of the Exemption Application by Minnesota Power for a 345/230kV High Voltage Transmission Line Known as the Arrowhead Project Appellate Court File: C4-01-1022 Supreme Court: Petition for Writ of Certiorari In the Matter of:

Petition of Power Line Task Force, Docket No. E002/C-99-902, Supreme Court File: C8-00-1143 2000 Power Line Task Force v. MEQB, Motion to Reopen based on newly discovered information. Ramsey County: C3-99-010952 2000 Appeal of In the Matter of: Petition of Power Line Task Force PUC Docket No. E002/C-99-902; Appellate Court File C8-00-1143 1999 In the Matter of the Application of Northern States Power Company for Approval of its 1998 Resource Plan Amicus for C.U.R.E. Appellate Court File: C0-99-917

Summa v. City of Northfield, Appointment of Council member without election Rice County Court File: 99- 1998 Matson v. City of Northfield, Rice Co., Court File: 98- Grant Park disappearing parkland, settled prior to trial in favor of client, City bought and dedicated parkland as ordinance required Rice County Court File: 98- 1997 State by Florence Township v. NSP, MEQB, PUC & Goodhue County Challenge NSP’s siting of nuclear waste in Florence Twp. Ramsey County Court File: C1-96-180

Minnesota Public Utilities Commission

2014 – present ITC Midwest MN/IA 345 kV line, Intervention (limited) representing Citizens Energy Task Force and No CapX2020

2013 – present PUC Rulemaking Advisory Committee – Ch. 7849 CoN and 7850 Route 2013 – present Great Northern Transmission Line – Certificate of Need open houses,

Notice Plan Comments, Intervention representing Residents and Ratepayers Against Not-so-great-Northern Transmission

PUC Dockets 12-1163 and 14-21 2013 – present Hollydale Transmission Line representing the Barry Family – Xcel Energy

has withdrawn the application PUC Dockets 11-152 and 12-113 2011 – present PUC Rulemaking – Petition for Rulemaking for amendment of Certificate of

Need and Siting/Routing rules

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2011 Petition for Rulemaking for amendment of wind siting rules, Minn. R. Ch. 7854

2011 – present Consultation on project before PUC on transmission issue (confidential

client) and drafting of filings, obtained mandated Certificate of Need filing 2011 – present Hollydale Transmission Line – Comments as individual in CoN and Routing PUC Dockets 11-152 and 12-113 2011 Pleasant Valley-Byron transmission line – Exceptions to Recommendation

of ALJ for “Route 3 Landowners” PUC Docket s 09-1315 and 08-992. 2010 – 2012 CapX 2020 Fargo-St. Cloud docket, representing NoCapX 2020, United

Citizen Action Network and North Route Citizens Alliance. PUC Docket 09-1056.

2009 – 2010 CapX 2020 St. Cloud-Monticello – assist private client with Comments PUC Docket 09-246 2009 -- 2012 CapX 2020 Hampton-Alma/LaCrosse – Intervene in Routing Docket –

NoCapX, U-CAN and North Route Group - PUC Docket 09-1448 2008 – 2011 CapX 2020 Brookings-Hampton – Intervene in Routing Docket – NoCapX &

United Citizens Action Network (U-CAN) PUC Docket 08-1474 2008 – 2013 Goodhue Wind – Intervene in Certificate of Need, Siting and two Power

Purchase Agreement dockets (08-1233; 09-1186; 09-1349;09-1350). Permit revoked 2013.

2008 – 2011 Xcel’s Hiawatha Project – Certificate of Need (09-38) and Routing (10-694)

dockets, independent Comments 2008 -- 2012 Prairie Island Nuclear Plant – Uprate & Dry Cask – Scoping Comments and

limited assistance to members of Citizens Advisory Task Force, Comments on “Changed Circumstances” petition

2007-2009 Bent Tree Wind – Intervene in Certificate of Need and Siting Docket representing Safe Wind in Freeborn County, Dockets 07-1425 & 08-573 2007-2009 In the matter of the Application of Northern States Power Company for a

Transmission Line in Chisago County MPUC Docket 04-1176, representing first Concerned River Valley Citizens and then City of Lindstrom

2007 Transmission - Excelsior Energy Mesaba Project, MPCU 07-1640 limited representation of landowner

2007-2010 Kenyon Wind – MPUC Docket 06-1445 for Citizens for Energy Responsibility and Safety – permit extension denied December 2010.

2006 -- 2009 In the matter of the Application of Great River Energy, Xcel Energy etc., for Certificates of Need for CapX 2020, MPCU Docket 06-1115 – Intervenor, multiple series of meetings and scoping hearings statewide over two years

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2006 In the matter of the Application for Big Stone Transmission PUC Dockets: CN-05-619;TR-05-1275 – Comments & limited Intervention

2006 Big Stone II – South Dakota – consult with and assist Intervenor

2006 In the matter of the Application of Northern States Power Company for a Certification of Need to Establish an Independent Spent-Fuel Storage Installation at the Monticello Generating Plant

PUC Docket No. E-002/CN-05-123 –Completeness & General Comments

2005 – 2011 In the matter of a Power Purchase Agreement between Excelsior Energy (Mesaba) and Xcel. Phase I and II, MPUC Docket 05-1993

2005 – 2010 Biennial Transmission Plan – Comments & public meetings

2005 Certificate of Need – First draft of application for wind project (confidential)

2004 Solar interconnection v. rural utility issue for private client

2003 In the matter of the Application of Faribault Energy Park Testimony at technical hearing on need, transmission access & renewables PUC Docket No.: IP6202/CN-02-2006; EQB Docket No.: 02-48-PPS-FEP

2002 In the Matter of Application to the Minnesota Public Utilities Commission for Certificates of Need for Four High Voltage Transmission Line Projects in Southwestern Minnesota, Hearings 5/6/02-7/3/02 Docket No. E-002/CN-01-1958.

2001-2002 Biennial Transmission Plan Rulemaking Advisory Committee

Transmission Plan, Docket E-999/TL-01-961, Comments on record

Transmission Plan, Docket E-999/TL-01-961, Public Energy, Inc. filing of Buffalo Ridge Transmission Plan for Category I project certification In the Matter of Application to the Minnesota Public Utilities Commission for Certificates of Need for Four High Voltage Transmission Line Projects in Southwestern Minnesota Docket No. E-002/CN-01-1958, Comments on record

2001 In the Matter of the Application of Rapids Power LLC for a Certificate of Need for its Grand Rapids Project, Docket No. IP-4/CN-01/1306. Comments on Record for W.O.L.F.

In the Matter of Transmission Projects Reports and Development of Certified List of Transmission Line Projects, Docket No. E-999/TL-01-961. Comments on Record and

2000 -- 2002 Representation of Power Line Task Force re: NSP’s City Requested Facilities Surcharge Rider and Miscellaneous Tariff Change, Comments on record, participation at table as party in Technical Meeting, interim rulemaking, and rulemaking. Later Comments regarding Chisago

Transmission Project. Docket No. E002/M-99-799

2000-present Appeal of Petition of Power Line Task Force (as above)

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1999 - 2004 In the matter of Exemption Application by Minnesota Power for a 345/230kV High Voltage Transmission Line known as the Arrowhead Project – representing WOLF regarding NAWO & SOUL Motion re: American Transmission Company. EQB Docket: MP-HVTL-EA-1-99

1999-2001 Comments and Intervention in NSP’s Integrated Resource Plan. Solicit participation from others who due to burden of intervention would not ordinarily participate. Focus on Utah Skull Valley nuclear waste storage facility, transmission and generation issues, and need and reliability. Office of Administrative Hearings 2012 – present OAH Rulemaking – Petition for Rulemaking and Comments on informal

rules draft – Ch. 1400 and 1405

Minnesota Pollution Control Agency

2012 – present MPCA Streamlining Environmental Review – Comments and Testimony 2012 – present MPCA Greenhouse Gas for Range emitters – Comments and Testimony 2008 – 2009 MPCA Streamlining Environmental Review docket - Comments 2007 Kandiyohi Development – Midtown Eco-Energy – Comments, EAW Petition

and Petition for Contested Case for Neighbors Against the Burner

Environmental Quality Board then shifted to Dept. of Commerce (see also Public Utilities Commission)

2007 – 2008 Chisago County-Apple River HVTL, representing City of Lindstrom MPUC Docket 04-1176 and 06-1667 2006 – 2009 Chisago County-Apple River HVTL, representing Concerned River Valley Citizens, MPUC Docket 05-1176 and 06-1667

2006 – 2010 Mesaba Energy Project representing mncoalgasplant.com – GS06-668

2005 Renewable Energy Forums - Attend with clients, provide handouts, and comment at meetings across state to raise awareness of clients’ interests

2002 Distributed Generation Interconnection Rules Work Group - Member. 2002 – 2003 Transmission Plan Rulemaking, Minn. R. 7848 – Committee member 2001 Energy Plan – Comments on Record and public meetings across state,

present and advocate client positions

2000 Keeping the Lights On – Participation shadowing agency meetings, seven presentations across state, promotion and generation of clients’ interests, public interest and comments, and submission of individual and organization comments.

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Environmental Quality Board

2012 – present Silica Sand Mining Standards and Criteria Comments representing Citizens Against Silica Sand Mining (CASM) and independent Rulemaking Comments (ongoing)

2007 EAW Petition – Neighbors Against the Burner – Kandiyohi’s Midtown Eco-

Energy

EAW – against Waseca tank track & bazooka/machine gun shooting range

2004 In the matter of Xcel Energy’s Application to the Environmental Quality Board for Route Permits, Split Rock Substation to Nobles County Substation to Lakefield Junction Substation 345kV Transmission Line and the Nobles County Substation to Chanarambie Substation 115kV Transmission Line and the Nobles County Substation. EQB Docket 03-73-TR-XCEL. Testimony, participation in hearings in Lakefield and Luverne, MN.

Mesaba Power Plant –legislative and administrative venues to challenge legitimacy of project, meet with project promoters Dec. 2004.

2002 Minn. R. 4410 Rulemaking Task Force

2001 Power Plant Siting Act Rule Changes – Comment on Record

2000-2001 In the matter of Arrowhead-Weston Powerline, Hearings before Environmental Quality Board (8/28-9/9/00)

2000 MPCA Environmental Review - Comments on record and participation in public forums

1999 EAW – Citizens for Responsible Development - Target – Northfield EAW – Matsons - Presidential Commons/Grant Park - Northfield EAW - Transport Designs Truck Terminal, Hwy. 35 & 19 (#!)

1998-2013 Power Plant Siting Act annual hearing - Comments and participation x 12

1995-2000 Representation of Florence Township regarding NSP’s application for dry cask storage in the township. Review application, comments on record, organizing and coalition building, media work, lawsuit

Local Governments

2012 – 2013 Goodhue County frac sand mining ordinance – Comments to subcommittee and consultation with County Attorney

2012 Principal in successful campaign to eject Red Wing Mayor Dennis Egan

from office for failure to disclose conflict of interest as Exec. Dir. of frac sand mining industry group

2011 – present Investigation of gun range permit compliance in Aitkin County 2010 – present Rice County – local landowner concerns regarding Gro Wind project.

Mower County – local landowner concerns regarding transmission for Pleasant Valley wind project.

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2009 – present Chisago County – representing Concerned River Valley Citizens regarding LS Power gas plant, including Development Agreement, Host Fee Agreement & Utility Personal Property Tax Exemption legislation.

2008 -- present Goodhue County – Goodhue Wind Truth concerns regarding the AWA

Goodhue Wind project and establishment of County Wind Ordinance, and separate background work for private client regarding certification of wind projects

2007 -- 2008 Freeborn County –Bent Tree Wind environmental review for Safe Wind 2007 Chisago Transmission Line – representing City of Lindstrom PUC Docket: 04-1176; 06-1667

Waseca County - Private client – against Waseca tank track, shooting range

2006 Private client – Distribution line in Northfield/Greenvale Township Private client – small transmission line in Ely

City of Red Wing – presentation of information re: nuclear waste, PFS City of Red Wing – successful challenge practice of wide ranging background checks of city candidates

Itasca County – for local landowner clients -- inform about utility personal property tax, draft and promote legislative language to protect local governments with Host Fee Agreement, legislation was amended to provide Host Fee Agmt (revenue) for local govts, monitor $55 million Mesaba bonding bill, result was far less

2005 Lake County - Private client – small transmission line in Grand Marais

Rice County Planning Commission & Board – Comments on AUAR

Waseca County & Blooming Grove Township – Resolution to require Host Fee Agreement regarding personal property tax exemption – Simon Industries 325 MW gas plant

2004 City of Northfield – Comments and community organizing on Hospital restructuring

2004 Rice County – Opposition to county rezoning of I-35 & Co. Rd. 46

City of St. Croix Falls – private client – consult on denial of wind permit

2003-2004 Rice County representing Land Rights Action in opposition Transport Designs truck Terminal and land use changes

2001 City of Duluth, Representing W.O.L.F., Special Use Permit request by Minnesota Power to relocate, upgrade and construct a 115/345kV transmission line, known as Arrowhead Project, FN 01073

Chisago County – Advocacy and defense of recommendation of Essential Services Task Force for Need Determination requirement in ordinance through passage of county ordinance.

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City of Northfield, Representing WeCAN, Comprehensive Plan and Zoning Change, Annexation, regarding Allina Hospital.

1998-99 City of Northfield, Representing Citizens for Responsible Development, Comprehensive Plan and Zoning Change, Annexation, Referendum

regarding Target Mall.

STATE OF WISCONSIN PROCEEDINGS

District Court

2012 Citizens Energy Task Force v. Public Service Commission 12-CV-3328 Appeal of PSC Docket 05-CE-136 Dismissed

1997 State v. 29 Defendants, Disorderly Conduct, Crandon Mine Demonstration Represented 2 defendants for Wisconsin ACLU

Attorney General - Wisconsin

2001 Open Meeting and Data Practices Complaint to WI A.G. and ACLU regarding violations of City of St. Croix Falls & Mayor Lundgren

Public Service Commission of Wisconsin

2013 – present Badger Coulee Transmission Line representing Citizens Energy Task Force PSC Docket 05-CE-142

2012 – 2013 Badger Coulee Transmission Line PSC Docket 137-CE-160 Comments 2011 – 2013 CapX 2020 Hampton-Rochester-LaCrosse Docket 05-CE-136 representing

NoCapX and Citizens Energy Task Force 2004 Chisago Transmission Project – Reopening, representing CRVC

2002-2004 In the Matter of Arrowhead-Weston Powerline – representation of Intervenor W.O.L.F. in original and reopening of docket # 2. PSC Docket No. 05-CE-113 and reopening on Petition of Co-Applicant American Transmission Company on Cost Increase and on rerouting around Douglas County.

2001 In the Matter of Joint Application of NSP-WI, NSP-MN and Dairyland Power Cooperate known as Chisago Transmission Project – represented

Concerned River Valley Citizens (CRVC), PSC Docket No. 1515-CE-102; 4220-CE-155

2000-2001 In the Matter of Arrowhead-Weston Transmission Project - representation of Intervenor W.O.L.F. PSC Docket No. 05-CE-113

STATE OF IOWA PROCEEDINGS

Polk County District Court

2005-2006 In re: Cedar Falls Utilities (transmission franchise appeal) Docket No. E-21647 – franchise granted

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STATE OF NEW JERSEY PROCEEDINGS

2010 Consulting with private land-use client regarding 600+ acre solar development in rural NJ

2009 – 2010 Susquehanna-Roseland transmission line – representing Stop the Lines!

Board of Public Utilities Docket: EM09010035; coordinating with Eastern Environmental Law Center and Sierra Club in appeal

2008 Transmission line consulting on technical/electrical issues - Stop the Poles

STATE OF DELAWARE PROCEEDINGS

2007 – present Delmarva Power IRP – Comments regarding coal gasification proposal

2007 – present Delmarva Power RFP – individual Comments & with Green Delaware

PUBLIC POSITIONS - BOARDS OF DIRECTORS (selected)

2009 – present Humane Society of Goodhue County – President, Board of Directors 2007 – present Green Delaware – Steering Committee 2005 – 2007 Red Wing Charter Commission

2004 – 2006 Girl Scout Council of Cannon Valley

1998 – 2004 Clean Water Action Alliance, Vice Chair from 2000 – 2004 Committees: Development, Energy.

2001-2003 Eagle Watch, operator of National Eagle Center, Wabasha. Vice President 2001-2003. Committees: Fundraising, Bylaws.

2002 – 2004 RENew Northfield. Included full responsibility for programming of Community Wind Conference, April 2002.

1980-1984 KFAI – Fresh Air Radio Board of Directors, Secretary 1981-1984. Programmer of weekly shows including We Want You to Know, Friday Morning Jazz, sound tech for live on air mix for 9-Oscar Show and special broadcasts including 7th International Treaty Conference on White Earth Reservation.

PRESENTATIONS (selected)

Rochester, MN, and Eau Claire and La Crosse, Wisconsin 2013 Ethical Issues in Frac Sand Mining (CLE) Public Interest and Environmental Law Conference, Eugene, Oregon - Transmission panel 2012 Transmission panel (organize & present) March 2-4, 2012 (CLE)

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San Luis Valley, CO citizens groups 2011 Transmission presentations, LeVeta and Alamosa, Colorado Stop TANC Rally – Redding, CA 2009 It’s All Connected – Transmission in US and CA specific LaCrosse Community Energy Coalition – LaCrosse, WI 2008 “Debate” with Xcel Energy representatives regarding CapX 2020 transmission No New Coal Plants – Houston, Texas 2008 Presentation and Panel Discussion with Alan Muller & Nancy LaPlaca IGCC: Pipedreams of Green and Clean (revised) Midwest Sierra Club Environmental Committee – Indianapolis, IN

2007 IGCC: Pipedreams of Green and Clean Ratepayers United of Colorado – Denver, CO

2007 IGCC: Pipedreams of Green and Clean (shadow industry conference) MREA – Midwest Renewable Energy Fair – Custer, WI

2006 No New Coal Plants – Booth on coal and incineration 2003 Lobbyists ‘R Us – Co-Presented by Carol A. Overland, Clean Water Action Alliance and Tom Dunnwald, Board Members, Clean Water Action Alliance.

Community Wind – Co-Presented by Carol A. Overland, RENew Northfield and David Bly, Co-Chair, Northfield Wind Energy Task Force

2002 Lobbyists ‘R Us – Co-Presented by Carol A. Overland and David Blecker, Seventh

Generation Energy & MREA. 2001 Strategies for Grassroots Energy Policy Intervention, Co-Presented by Carol A.

Overland, Overland Law Office; David Blecker, Earth Energy Systems; Tom Kreager, Save Our Unique Lands (S.O.U.L.) and Katy Nekola, RURAL.

Windy River Energy Fair – Little Falls, MN 2005 Xmsn 1001: It’s all connected 2001-2002 Lobbyists ‘R Us – Co-Presented by Carol A. Overland and Tom Dunnwald, Board

Members, Clean Water Action Alliance.

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William Mitchell College of Law 1998-2001 From Here to Attorney – large group panel discussion of lawyering and Utility

Regulatory and Environmental breakout session. 2003 The Other Half: What else can you do with a J.D.? Panel discussion Lawyers Guild - Midwest 1997 Annual Regional Convention, Iowa City, IA

Presentation on Federal and State Law of Nuclear Waste Siting (CLE) Women’s Political Alliance 1996-2001 Presentations on:

Status of Nuclear Waste Storage in Minnesota

Dry Cask Unloading Issues and NRC §2.206 Petition

Transfer of NSP’s Nuclear Licenses to NMC (shell corporation)

MPCA’s Rulemaking on Environmental Review League of Women Voters 2005 Cannon Valley LWV – panel on Invenergy 325 mW gas plant 2002 Northfield LWV – Nuclear Waste Forum 1998 Cannon Valley LWV -- Citizen of Year Award

MEDIA APPEARANCES (selected)

KTCA Newsnight

Selection of Florence Twp. for High Level Nuclear Waste, with Jim Alders, Northern States Power

Nuclear Waste Policy in Minnesota, with David Morris, Institute for Local Self Reliance; Senator Paul Wellstone and Senator David Durenburger

KFAI Hiawatha Transmission Project – Truth to Tell Arrowhead Transmission Project – Northern Sun News

Florence Township nuclear waste siting – Northern Sun News

KUED Skull Valley – Feature length documentary on siting of nuclear waste on Goshute reservation, Skull Valley, Utah. Produced by Ken Verdoia, Salt Lake City, Utah (filmed in Madison, WI)

KARE-11 Xtra – “Breaking the Mold” profile feature

Duluth Ch. 11 Two part news story on Excelsior Energy/Mesaba

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FEATURE ARTICLES (selected)

2009 GRIST – Transmission Lies - author

Climate Hope: On the Front Lines of the Fight Against Coal – Ted Nace (profiled) 2008 Orion – Stopping coal in its tracks (No New Coal Plants) (profiled)

2005 A small quote in Time Magazine!!! War of the Winds – October 9, 2005

1999 “Up Against the Mall” Hope Magazine, Summer issue

1995 Women’s Press – Profile feature

GRANTWRITING

2003 $150,000 – MN Dept. of Commerce “Community Wind” grant for Carleton College and Northfield School District wind project

2001 $35,000 - McKnight Foundation for Public Intervenors Network’s intervention

in Xcel’s SW Minnesota 345kV Certificate of Need proceeding at PUC

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APPENDIX C: CETF AUDIT REPORT

Not Applicable – Due to small budget, CETF does not perform an audit.

APPENDIX D: CETF LOBBY REPORT

Not Applicable – CETF has no lobbying expenses.

APPENDIX E: CETF 12 MONTH IC SUMMARY

Not Applicable – CETF has received no Intervenor Compensation over the last 12 months, is not participating in other PSC dockets, and does not anticipate any other applications for Intervenor Compensation in 2014. APPENDIX F: CETF ASSET AND LIABILITY STATEMENT

Not Applicable – CETF has less than $ 500.00 in its checking account.

APPENDIX G: CETF 2011 BUDGET

The 2013 Budget of CETF is as outlined in detail in Appendix A and Appendix B. There are no other anticipated expenses other than the Wisconsin incorporation fee and the IRS Form 1023 Application fee. Revenue anticipated is limited to Intervenor Compensation and whatever funds are raised by CETF, historically just over $2,000.00 annually. When our non-profit is formalized, we will advance on fundraising and grant writing work. APPENDIX H: CETF STAFF

CETF has no staff. Board members will serve as staff, in this case Deb Severson will represent CETF at the technical hearings, and George Nygaard will do staff work and research with assistance of other Board members as needed. APPENDIX I: CETF Board of Directors

Joseph M. Morse – President Winona, MN Linda Van Art – Treasurer La Crosse, WI Irving Balto Chaseburg, WI George R. Nygaard -- Secretary Chaseburg, WI Debra Severson Sparta, WI Guy Wolf Stoddard, WI Beverly Vaillancort LaValle, WI

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