STATE OF INDIANA INDIANA UTILITY REGULATORY VERIFIED PETITION OF NORTHERN ) INDIANA PUBLIC SERVICE COMPANY ) CAUSE NO. 44 19 8 FOR APPROVAL OF A VOLUNTARY ) GREEN POWER RIDER PILOT PROGRAM. ) SUBMISSION OF DIRECT TESTIMONY AND EXHIBITS Northern Indiana Public Service Company, by counsel, hereby submits its Direct Testimony and Exhibits. Respectfully submitted, 101 W. Ohio Street, Suite 1707 Indianapolis, Indiana 46204 Phone: 317.684.4930 Fax: 317.684.4918 Email: [email protected]Attorney for Petitioner Northern Indiana Public Service Company
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STATE OF INDIANA INDIANA UTILITY REGULATORY · 07.05.2012 · STATE OF INDIANA INDIANA UTILITY ... as an offering to all NIPS CO ... recover ongoing certification costs incurred at
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STATE OF INDIANA
INDIANA UTILITY REGULATORY
VERIFIED PETITION OF NORTHERN ) INDIANA PUBLIC SERVICE COMPANY )
CAUSE NO. 44 19 8 FOR APPROVAL OF A VOLUNTARY ) GREEN POWER RIDER PILOT PROGRAM. )
SUBMISSION OF DIRECT TESTIMONY AND EXHIBITS
Northern Indiana Public Service Company, by counsel, hereby submits its
Direct Testimony and Exhibits.
Respectfully submitted,
101 W. Ohio Street, Suite 1707 Indianapolis, Indiana 46204 Phone: 317.684.4930 Fax: 317.684.4918 Email: [email protected]
Attorney for Petitioner Northern Indiana Public Service Company
CERTIFICATE OF SERVICE
The undersigned hereby certifies that the foregoing was served by email
transmission upon the following:
A. David Stippler Office of Utility Consumer Counselor 115 W. Washington Street Suite 1500 South Indianapolis, Indiana 46204 dstipp [email protected][email protected]
Dated this 7th day of May, 2012.
-2-
Petitioner's Exhibit No. TRC Northern Indiana Public Service Company
Page 1
VERIFIED DIRECT TESTIMONY OF TIMOTHY R. CAISTER
1 Q1. Please state your name, business address and title.
2 Al. My name is Timothy R. Caister. My business address is 101 W. Ohio Street, Suite
3 1707, Indianapolis, Indiana 46204. I am Director of Electric Regulatory Policy for
4 Northern Indiana Public Service Company ("NIPSCO" or IICompanyff).
5 Q2. Please briefly describe your educational and business experience.
6 A2. I am a graduate of Alma College in Alma, Michigan, with a Bachelor of Arts
7 degree. I received my Juris Doctor from Chicago-Kent College of Law at the
8 Illinois Institute of Technology in December 2004. I have also taken courses
9 towards a Masters of Business Administration at the Stuart Graduate School of
10 Business at the Illinois Institute of Technology. Upon my graduation from Alma
11 College, I was employed by NiSource Corporate Services Company (IINCSff ) in
12 various positions including Federal Regulatory Policy Specialist and Manager of
13 Regulatory Policy. After graduating from Chicago-Kent, I was employed by
14 NCS as an attorney providing regulatory legal support to NIPSCO's gas and
15 electric businesses, along with Northern Indiana Fuel & Light Company and
16 Kokomo Gas and Fuel Company, in proceedings before the Indiana Utility
17 Regulatory Commission (IICommissionff). In June 2007 I accepted a position as
Petitioner's Exhibit No. TRC Northern Indiana Public Service Company
Page 2
1 Associate General Counsel with Ameren Services Company (If Amerenlf) in St.
2 Louis as part of its Federal Regulatory Team. In that position, I handled a variety
3 of legal and regulatory issues including those associated with the Midwest
4 Independent Transmission System Operator, Inc. ("MISOIf), of which Ameren
5 Corp.' s utility subsidiaries are members. Specifically, during my tenure at
6 Ameren I was responsible for advising on matters in front of the Federal Energy
7 Regulatory Commission and associated wholesale power and transmission
8 contracts. I returned to NCS in November 2008 in my current position, and this
9 position was transitioned to NIPSCO in January of 2009.
10 Q3. Have you previously testified before this or any other regulatory commission?
11 A3. Yes. I have previously submitted testimony in requests for approval of new and
12 revised tariffs and riders in Cause Nos. 42348 and 42480. I also previously
13 submitted testimony in Cause No. 43566 regarding the Commission's demand
14 response generic investigation, and in Cause No. 43426-S1 regarding MISO. I
15 also submitted testimony in support of settlement agreements in Cause Nos.
16 38706-FAC80-S1 and 43674. I have submitted testimony regarding demand side
17 management in Cause No. 43912, testimony regarding feed-in tariffs and net
18 metering in Cause No. 43922 and testimony regarding an asset sale in Cause No.
19 43989.
Petitioner's Exhibit No. TRC Northern Indiana Public Service Company
Page 3
1 Q4. What is the purpose of your direct testimony in this proceeding?
2 A4. The purpose of my testimony is to (1) provide an explanation of and support for
3 NIPSCO's proposed Green Power Rider ("GPR") pilot program and (2) provide
4 an introduction of the other witness in this proceeding.
5 Q5. What customer option or program is NIPSCO proposing in this proceeding?
6 A5. The GPR pilot program is proposed as an offering to all NIPS CO electric
7 customers in order to allow customers to designate all or some of their electricity
8 usage to be Green Power.
9 Q6. How is Green Power defined within the context of the GPR?
10 A6. Green Power is defined in the proposed GPR tariff sponsored by NIPS CO
11 witness Curt A. Westerhausen, and it includes energy generated from renewable
8 647,650, 655, 660 and Rider 676 are eligible to participate. No limit is being placed
9 on purchases from customers as it does not impact the integrity of the electric
10 distribution system because Renewable Energy Certificates ("RECs") purchasing
11 is purely an administrative function.
12 QI0. Will NIPSCO receive financial benefit from the GPR?
13 A10. No. The GPR program will be revenue neutral. The GPR rate is intended to
14 cover all costs associated with the program including the cost of RECs (which
15 includes all brokerage fees and trading commissions associated with purchasing
16 the RECs), marketing and all applicable taxes. The costs and revenues will be
17 subject to a "true up" in subsequent six-month filings via a reconciliation
Petitioner's Exhibit N o. CAW Northern Indiana Public Service Company
Page 5
1 mechanism (the "GPR Filing"). Mr. Caister provides additional details relating
2 to the GPR Filing.
3 Qll. Will the GPR economically benefit the state of Indiana?
4 A11. The proposed GPR may result in greater expansion of electricity generated from
5 wind, solar and biomass from Indiana facilities. Mr. Caister provides additional
6 details relating to the purchase of RECs from sources located in any particular
7 region.
8 Q12. Do the RECs purchased under NIPSCO's current wind power purchase
9 agreements affect the GPR?
10 A12. No. Although NIPSCO has a current REC inventory from wind power purchase
11 agreements, the total cost of generation is currently recoverable through the Fuel
12 Adjustment Clause proceedings. This would continue to be the case. All RECs
13 created from NIPSCO's wind purchases would be completely separate from the
14 GPR program.
15 Q13. Does this conclude your prefiled direct testimony?
16 A13. Yes.
VERIFICATION
If Curt A. Westerhausen, Director of Rates and Contracts in the Rates and
Regulatory Finance Department for Northern Indiana Public Service Company, affirm
tmder penalties of perjury that the foregoing representations are true and correct to the
best of my knowledge, information and belief.
&j)~ Curt A. vVesterhausen
Dated: May 4, 2012
NORTHERL'J INDIANA PUBLIC SERVICE COMPANY IURC Electric Service Tariff Original Volume No. 12 Cancelling All Previously Approved Tariffs
TO WHOM AVAILABLE
RIDER 686 GREEN POWER RIDER
Petitioner's Exhibit No. CAW-1 Page 1 of 7
Original Sheet No. 199.3
No.1 of2 Sheets
This Rider shall be applicable to the Rate Schedules as defined in Appendix A.
CHARACTER OF SERVICE
This Rider shall provide Customers with the option to designate a specific percentage of their energy consumption as associated with Green Power. Customers shall pay a surcharge for energy consumption associated with Green Power.
Green Power includes energy generated from renewable and/or environmentally friendly sources, including: solar; wind; geothermal; hydropower that is certified by the Low Impact Hydropower Institute; solid, liquid, and gaseous forms of biomass; and co-firing of biomass with nonrenewables.
Green Power includes the purchase of Renewable Energy Certificates from the sources described above.
All Customers selecting Green Power will be able to designate 25%, 50% or 100% of their energy consumption to be attributable to Green power. Commercial and Industrial Customers will also have the option of designating 5% or 10% of their energy consumption to be attributable to Green Power. The minimum purchase requirement for Residential Customers shall be 25%.
Customer participation is completely voluntary and Customers can sign up for Green Power at any point in time. Customers may withdraw from the program at any time. However, changes will take effect in the upcoming billing cycle after the request for withdrawal has been received by the Company.
CALCULA nON OF GREEN POWER RIDER RATE
Energy Charges in the Rate Schedules included in this Tariff are subject to charges approved by the Commission to reflect Green Power consumption. Such charges shall be increased or decreased to the nearest 0.001 mill ($.000001) per kilowatt-hour ("kWh") in accordance with the following:
Green Power Rider ("GPR") = [(ES x REC) + M]/ES
Issued Date Effective Date
Petitioner's Exhibit No. CAW-1 Page 2 of 7
NORTHERl~ INDIANA PUBLIC SERVICE COMPANY IURC Electric Service Tariff
Original Sheet No. 199.4
Original Volume No. 12 Cancelling All Previously Approved Tariffs
Where:
"GPR"
"ES"
"REC"
"NI"
RIDER 686 GREEN POWER RIDER
No.2 of 2 Sheets
is the rate adjustment for each Rate Schedule representing the premium for Green Power consumption.
is the estimated annual sales of Green Power based on estimate of the number of participants and usage level.
is the estimated cost of purchasing Renewable Energy Certificates.
is the marketing costs of the Green Power program.
GREEN POWER RIDER RATE
The rates defmed in Appendix A are subject to a Green Power Rider rate. The Green Power Rider rate stated in Appendix H is applicable hereto and is issued and effective at the dates shown on Appendix H.
The Green Power Rider rate as computed above shall be further modified to allow the recovery of gross receipts taxes and other similar revenue based tax charges occasioned by the Green Power Rider revenues and later reconciled with actual sales and costs.
See Appendix H for the Green Power Rider charge per kWh for each Rate Schedule.
Issued Date Effective Date
NIPSCO'
NORTHERl'l" INDIANA PUBLIC SERVICE COMPANY IURC Electric Service Tariff Original Volume No. 12 Cancelling All Previously Approved Tariffs
APPENDIXH
Petitioner's Exhibit No. CAW-1 Page 3 of 7
Original Sheet No. 208
GREEN POWER RIDER RATE
No.1 of 1 Sheet
The Green Power Rider Rate in Rates 611, 612, 613, 620, 621, 622, 623, 624, 625, 626, 632, 633, 634, 641, 642, 644, 650, 655 and 660, Rate Code 647 and Rider 676, shall be computed in accordance with Rider 686.
Effective for all bills rendered during the through , 2012 billing months, the Green Power Rider Rate shall be a charge of $0.002163 per kilowatt hour.
Issued Date Effective Date
NIPSCO'
I
I
Petitioner's Exhibit No. CAW-1 Page 4 of7
NORTHERN INDIANA PUBLIC SERVICE COMPANY IURC Electric Service Tariff
Second Hrs-t-Revised Sheet No.3 Superseding
First Revised Original Sheet No.3 Original Volume No. 12 Cancelling All Previously Approved Tariffs
Rider 678 COG Purchases from Cogeneration and Small Power Production 127, 128, 129, 130 Facilities
Rider 683 DSMA Demand Side Management Adjustment Factors 198 Rider 684 DLC Credits for Direct Load Control Progran1 199 Rider 685 PEV Plug-In Electric Vehicle Off-Peak Charging Rider (Pilot 199.1,199.2
Program) Rider 686 GPR Green Power Rider 199.'\.199.4 Appendix A Applicable Riders 200-201 AJ2P~ndixB FAC Fuel Cost Charge 202 AJ2Pendix C RTO Regional Transmission Organization Factor 203 AQpendix D ECRM Environmental Cost Recovery Mechanism Factor 204 Appendix E EERM Environmental Expense Recovery Mechanism Factor 205 AppendixF RA Resource Adeguacy Adjustment Factor 206 AppendL,( G DSMA Demand Side Management Adjustment Mechanism Factor 207 ADuendixH GPR Green Power Rider Rate 708
Issued Date Effective Date
NIPSCO'
Petitioner's Exhibit No. CAW-1 Page 5 of 7
NORTHER1~ INDIANA PUBLIC SERVICE COMPANY IURC Electric Service Tariff
Second Revised Sheet No.3 Superseding
First Revised Sheet No.3 Original Volume No. 12 Cancelling All Previously Approved Tariffs
Rider 678 COG
Rider 679 IS
Rider 680 NM Rider 681 DRR-1
Rider 682 EDRR
Rider 683 DSMA Rider 684 DLC Rider 685 PEV
Rider 686 GPR Appendi'\.A Appendix B FAC Appendix C RTO Appendi'\.D ECRM Appendix E EERM Appendix F RA Appendix G DSMA AppendixH GPR
Issued Date Pending, 2012
Purchases from Cogeneration and Small Power Production Facilities Interconnection Standards
Net Meterina Demand Response Resource Type 1 (DRR 1) - Energy Only
Emergency Demand Response Resource (EDR) - Energy Only
Demand Side Management Adjustment Factors Credits for Direct Load Control Program Plug-In Electric Vehicle Off-Peak Charging Rider (Pilot Program) Green Power Rider Applicable Riders Fuel Cost Charge Regional Transmission Organization Factor Environmental Cost Recovery Mechanism Factor Environmental Expense Recovery Mechanism Factor Resource Adequacy Adjustment Factor Demand Side Manaaement Adjustment Mechanism Factor Green Power Rider Rate