Rolf Nordstrom, CEO, GPI; Mike Bull, Director of Policy & External Affairs, CEE

Transcription

1 Page1 To: Fr: RE: Minnesota Public Utilities Coission Rolf Nordstro, CEO, GPI; Mike Bull, Director of Policy & External Affairs, CEE Notes fro Stakeholder Meetings in the Matter of Xcel s Residential Tie of Use Rate Design Pilot Docket No. E002/M , E002/M , and E002/CI Date: February 2nd, 2018 Dear Coissioners, Following a six-onth stakeholder engageent process in 2017, we are pleased to subit the following suary of notes fro eetings that drew on diverse perspectives to help infor Xcel Energy on the design of its Tie of Use Pilot Progra, for which the copany subitted its initial filing on Noveber 1 st, Key points about the process we facilitated: The stakeholder eetings that we convened garnered diverse representation and deep participation fro key actors in the regulatory process, including the Office of the Attorney General, the Departent of Coerce, and consuer and environental advocates. Xcel Energy not only actively participated in stakeholder eetings, but designed its Tie of Use Pilot Progra in direct response to the requests, goals, and objectives of the stakeholders involved. Where Xcel Energy was either not able to fully eet stakeholders requests or unable to provide requested inforation before its official filing, the participating stakeholders were able to identify key questions and concerns in order to prepare both advocates and the copany for an effective dialogue within the foral regulatory process. The table below lays out what stakeholders asked for or suggested in our May series of eetings, and what corresponding eleents were included in Xcel s initial pilot filing on Noveber 1 st :

2 Page2 PILOT OBJECTIVES May Stakeholder Suggestions Nov. 1 st Pilot Proposal 1 Identify what practices are effective at shifting custoer load, including the peak to off-peak ratios, duration of peaks, and tiing of peaks that will send an adequate price signal to custoers while accoplishing other states goals Goal 1 in Xcel Energy s filing is "Adequate price signaling to reduce deand," including learning "ore about the effectiveness of price signals at encouraging custoers to shift energy usage outside of designated periods of peak syste deand." 2 Identify what outreach and education ethods are ost effective for different custoer segents (including who is the best essenger) Goal 2 in Xcel Energy s filing is " Explore and identify effective custoer engageent strategies." This is to be further detailed in a custoer engageent plan. 3 Understand raifications for particular custoer segents, with particular attention to low-incoe custoers, including how uch oney custoer groups saved or lost, how specific practices increased or decreased custoer participation and satisfactions, and to what extent custoers had the ability to respond Goal 3 in Xcel Energy s filing is "Understand custoer ipacts by segent" including understanding "how custoers respond to inforation, tools, essages, and prive signals, and to gain insights into how these responses are distinguished by arket segent." 4 Understand how a TOU rate ight enable Deand Response (e.g., through Critical Peak Pricing or Critical Tie of Day pricing) Goal 4 in Xcel Energy s filing is "Support attainent of Deand Response goals," including the Coission's order to acquire an additional 400MW of Deand Response by Understand how this pilot will ipact selection and roll-out of AMI for Xcel Energy The pilot proposal discusses the costs and benefits of AMI eters and references additional inforation in the Copany's Grid Modernization Report 6 Identify what value is provided by different technology options (e.g., pre-prograed therostats) The pilot proposal states that the Copany is interested in exploring copleentary custoer options and progras, but focuses on options "without additional onsite hardware other than the eter." 7 Understand how other custoer interventions can be paired with TOU rates and how this affects cost-effectiveness (e.g., Hoe Energy Squad) The proposal discusses the potential addition of behavioral deand response progras 8 Understand how TOU ight enable energy conservation, cost-effective integration of renewables, and reduction of GHG eissions. Goal 5 in Xcel Energy s filing, "Understand integration of pilot eleents in our service territory," includes learning how to support energy conservation and efficiency. Additionally, TOU pricing is designed to incentivize energy usage when overnight wind generation is highest.

3 Page3 DESIGN SUGGESTIONS May Stakeholder Suggestions Nov. 1 st Pilot Proposal 1 Indenify low incoe custoers The proposed pilot offers full indenification for LIHEAP recipients in Year 1 and a bill protection schee for all other custoers 2 Use an opt-out approach Pilot uses an opt-out approach Provide rates that accurately reflect the costs of energy, both now and looking forward. Balance precision and practicality, both for the utility and for custoers Give custoers adequate tools to access and understand their usage data Pricing design is based on the Cost Duration Method and anticipates the growth of renewable generation. The proposed TOU pilot design takes into account a broad range of considerations, ultiately basing its design on both research and stakeholder suggestions to ake it operable for the copany and custoers. The pilot proposal states that "The Copany intends to continue to explore additional custoer insight tools and will likely issue an RFI or RFP to the arket to fully understand the latest in vendor capabilities and costs." This general alignent of the pilot design with stakeholders suggestions led us to focus on the following key discussions in our Septeber series of stakeholder eetings, which are described in ore detail in the notes suary following this letter: Defining low-incoe custoers: With Xcel Energy proposing full protection for LIHEAP custoers, the key concern raised was that only 27% of custoers eligible for LIHEAP are actually receiving assistance. Consuer advocates would prefer full bill protection for all LIHEAP-eligible custoers, rather than only those currently receiving assistance. In its initial filing, Xcel Energy proposes to address this by increasing LIHEAP outreach in the pilot areas and conducting robust surveys to identify this sector. Costs: Proving that pilot costs are balanced with benefits was a strong thee throughout our stakeholder conversations. However, Xcel Energy was not in a position to provide cost inforation for these eetings, so we have identified a set of key questions and concerns that ay be addressed in the foral regulatory process. Post-Pilot Planning: In our May series of eetings, stakeholders ade very clear that they wanted this pilot to serve as the initial learning phase. In the suary that follows, we have highlighted soe suggestions fro stakeholders for how to soothly navigate the transition fro pilot to full roll-out.

4 Page4 We subit these notes as a copleent to the notes suary fro stakeholder eetings in May 2017, which we filed in Docket No. E002/M on Septeber 11 th, 2017 (Docuent ID ). We hope you ll find that this stakeholder engageent process provided a copleentary benefit to the foral regulatory process and look forward to continued discussions around Xcel Energy s proposed Tie of Use Pitot Progra in Minnesota. Thank you for your ongoing leadership and support of a ore consuer-centric electric syste in Minnesota, Rolf Nordstro, CEO Great Plains Institute Mike Bull, Director of Policy & Counications Center for Energy & Environent

5 Page5 Xcel Energy Alternative Rate Design Pilot Stakeholder Working Group Meeting Notes Suary Septeber 2017 Participants: Ryan Barlow, Office of the Attorney General; Sara Bergan, Stoel-Rives; Lizzie Brodeen-Kuo, Suburban Rate Authority; Mike Bull, Center for Energy and Environent; Joe Dael, Office of the Attorney General; Trevor Drake, Great Plains Institute; Holly Hinan, Xcel Energy; Lon Huber, Strategen Consulting; Steve Huso, Xcel Energy; Annie Levenson-Falk, Citizens Utility Board ; Ay Liberkowski, Xcel Energy; Pa Marshall, Energy CENTS Coalition; Ti Meernik, Office of the Attorney General; Ron Nelson, Office of the Attorney General; Will Nissen, Fresh Energy; Rolf Nordstro, Great Plains Institute; Sue Peirce, Departent of Coerce; Doug Scott, Great Plains Institute; Jaes Stroen, Suburban Rate Authority. This docuent provides a synthesis of rearks by presenters and attendees at three eetings in 2017 on Septeber 22 nd, Septeber 29 th, and October 6th. The notes do not indicate consensus aong the group, but rather are eant to capture the overall discussion. No view should be attributed to any specific individual or organization. Table of Contents I. Key Ters:... 6 II. Costs... 7 III. Low-Incoe Custoers... 7 IV. Post-Pilot Planning... 8 V. Custoer Education and Engageent... 9 VI. Pilot Design Features VII. Pilot Q&A... 11

6 Page6 I. Key Ters: The following ters cae up in the group s discussions and are defined here only to provide clarity to the notes. Advanced Metering Infrastructure (AMI): The cobination of sart eters, counication systes, syste control and data acquisition systes, and eter data anageent systes that together allow for etering of custoer energy usage with high teporal granularity, the counication of the inforation back to the utility and, optionally, to the custoer, and the potential for direct end-use control in response to real-tie cost variations and syste reliability conditions. 1 Behavioral Deand Response (BDR): A for of Deand Response in which custoers receive an alert asking the to reduce deand during critical periods, but for which they don t receive a onetary incentive. Critical Peak Pricing (CPP): A rate design in which the utility warns custoers and sends strong price signals to deter electric consuption during peak periods. Copared to a Peak Tie Rebate design, Critical Peak Pricing tends to achieve higher deand savings, but also results in custoer dissatisfaction, especially with an opt-out design. Deand Response (DR): Reduction in energy use in response to either syste reliability concerns or increased prices (where wholesale arkets are involved) or generation costs (in the case of vertically integrated utilities). Deand response ust generally be easurable and controllable to participate in wholesale arkets or be relied upon by syste operators. 1 LIHEAP: Low Incoe Hoe Energy Assistance Progra. Peak-Tie Rebate (PTR): A rate design in which custoers who choose to participate by lowering their usage during designated peak ties receive an incentive or bill credit. Peak Tie Rebate rate designs generally achieve lower deand savings when copared to Critical Peak Pricing, but are ore popular with custoers. Tie-of-Use (TOU): Rates that vary by tie of day and day of the week. TOU rates are intended to reflect differences in the underlying costs incurred to provide service at different ties of the day or week These definitions are fro the Second Edition of Electricity Regulation in the US: A Guide, by Ji Lazar and staff at the Regulatory Assistance Project (June 2016).

7 Page7 II. Costs Stakeholders were very interested in learning about and evaluating the costs and associated benefits of the proposed TOU pilot. However, estiated pilot costs were not available for these discussions. Therefore, the following coents were raised for consideration once pilot costs becoe available: Meters: Soe stakeholders would like Xcel Energy to present inforation explaining how the costs and benefits of eters being selected for the pilot would copare to the costs and benefits of other etering options that were not chosen. Soe stakeholders also felt that it would be valuable to have a broader (involving ultiple utilities) conversation about Advanced Metering Infrastructure (AMI) in Minnesota. Xcel Energy also raised the point that learnings about costs and value are generally the outcoe of a pilot, not the starting point. Cost-benefit analysis: There was a suggestion that even though the pilot need not be proven cost-effective, Xcel Energy should still subit a cost-benefit analysis so that stakeholders can weigh the expected benefits and costs of what s being proposed, especially in preparation for the possibility of a territory-wide rollout of TOU rates. Iportantly, it was noted that one outcoe of this pilot is to identify the benefits of a TOU rate design and associated etering infrastructure, so any upfront cost-benefit analysis will rely on findings fro pilots copleted elsewhere, to the extent such findings are applicable and appropriate for the Minnesota syste. III. Low-Incoe Custoers Several conversations in the May series of stakeholder eetings focused on the potential ipacts of a TOU rate on low-incoe custoers and strategies to itigate those ipacts, as well as the opportunity to generate learnings about the participation of this sector. That conversation continued throughout the Septeber eetings, including a focused conversation about low-incoe custoers on October 6 th. Extending bill protections to LIHEAP-eligible custoers: Xcel Energy s draft pilot design (presented by the copany s consultant at the Septeber 8 th, 2017 e21 Foru) included full indenification of bill ipacts on custoers receiving LIHEAP assistance. However, there was concern that liiting protections to only custoers currently receiving LIHEAP assistance would leave vulnerable the any custoers who are LIHEAPeligible, but not currently receiving assistance. To this point, it was noted that only 27% of LIHEAP-eligible custoers are receiving assistance. Stakeholders identified that the key challenge to extending bill protections to LIHEAP-eligible custoers would be having a reliable way to identify those custoers. Since custoer incoe inforation is likely to be collected (voluntarily) in pilot participant surveys, soe stakeholders suggested using that data to identify custoers eligible for LIHEAP assistance. However, it was pointed out that this ethod of identification could incent non-low-incoe custoers to falsely report their incoe in order to gain full bill protection and thereby skew the pilot results. To address this, stakeholders seeed to agree that pilot participants receiving LIHEAP assistance could be tracked separately in the pilot evaluation fro LIHEAP-eligible custoers who are not

8 Page8 receiving assistance. The Copany also intends to develop intelligent survey questions around household incoe inforation to buttress against gaing. Xcel Energy staff agreed to consider this set of options for inclusion in the pilot design. Additional coents related to low-incoe custoers: Soe stakeholders were interested in specifically easuring the ipacts of the super off-peak period on low incoe custoers, to know whether inclusion of such a period causes ore adverse bill ipacts than a rate design with only a regular off-peak period. Stakeholders asked if there are other pilots or studies that have already proven the ipact of TOU rates on low-incoe custoers. However, it was noted that it s difficult to draw conclusions fro existing pilots and studies because they tend to define low incoe differently. It was pointed out that in addition to the bill protection schee, another way to protect low-incoe custoers fro adverse bill ipacts would be to conduct targeted outreach in the pilot areas to enroll custoers in LIHEAP and energy efficiency assistance progras. IV. Post-Pilot Planning One of the key outcoes fro stakeholder discussions in May was a desire fro any stakeholders that this pilot should be designed to test and deonstrate the application of TOU rates so that, without pre-judging the outcoe of the pilot, they can be eventually expanded to the full Xcel Energy service territory (in other words, if the pilot doesn t achieve its desired results, the intention is to learn fro the experience and ake changes for a broader roll-out, not to eliinate the option of extending TOU rates to all custoers). As a continuation of this discussion, stakeholders provided the following suggestions for a sooth transition at the conclusion of this pilot: Initial filing: Stakeholders felt it was iportant for Xcel Energy to include in its initial pilot design soething about how the TOU rate will be handled when the pilot ends. It was suggested that this could be as siple as stating that the copany will subit another filing before the pilot ends, providing an update on initial findings and proposing a continuation plan, perhaps with additional stakeholder input. Interi reporting: Stakeholders saw value in Xcel Energy subitting evaluation filings -- updates on interi results while the pilot is in process. For exaple, Xcel Energy could share suarized results of surveys adinistered to participants throughout the pilot ipleentation period. Xcel staff also offered to provide a id-pilot report, which stakeholders thought was a useful idea. If such a report was produced, stakeholders suggested that Xcel could use the goals and objectives set forth by this group as criteria for evaluation. It was noted that this report need not be a coplete evaluation, but rather provide a rough sense of how the pilot is going to enable effective planning of a broader TOU rollout. Bill protection: Xcel Energy s draft pilot design, as presented at the e21 Foru on Septeber 8 th, included bill protection in the first year of the pilot for all participants if the

9 Page9 su of their annual electric bills increased by ore than 10% due to the TOU rate. Stakeholders suggested that the pilot should evaluate the costs and benefits of this firstyear 10% bill protection schee to identify whether it would akes sense to apply it when TOU rates are extended to the full service territory. Custoer continuation: Many stakeholders felt that, barring significant failures, custoers who participated in the pilot should be allowed to stay on the TOU rate after the pilot ends and until the details of a broader rollout of TOU rates are deterined. Soe stakeholders would like to see a coitent to this in Xcel Energy s initial filing. Metering costs: Soe stakeholders wanted to understand the characteristics of the current arket for TOU rates and the associated etering and IT infrastructure, especially in relation to costs and the tiing of ipleentation. In response, it was noted that the costs of AMI eters are coing down and there are now over 90 Million AMI eters deployed in the United States; however, the other key cost of AMI is labor for IT integration, and labor costs are not going down. These two drivers ay have an overall balancing effect on the cost of eter upgrades. It was also noted that current etering technology is becoing obsolete, so there will likely be a need to transition to AMI even without a TOU rate. Iportantly, a TOU rate (and other advanced rate options like CPP and PTR) can help to fully leverage the benefits that can outweigh the costs of AMI. V. Custoer Education and Engageent Xcel Energy staff presented to stakeholders the likely strategies they ll use to engage and educate pilot participants, which will build on their experience with the Colorado TOU pilot, but will also be custoized for unique features of the Minnesota pilot, including the opt-out approach and local custoer deographics. Stakeholders raised the following questions and suggestions during this conversation: Costs: o o o Soe stakeholders would like the opportunity to understand the balance of costs and benefits of various custoer engageent and education approaches. Additionally, it was suggested that rather than seeking prescriptive input fro stakeholders on custoer arketing strategies, Xcel should propose whatever it dees to be a sart and cost-effective pathway to deliver results. Lastly, it was noted that investing significant resources on creating a positive initial experience for custoers during the pilot would be beneficial in advance of a broader roll-out of TOU rates (in other words, ake a positive first ipression aong custoers). Energy use feedback: o Soe stakeholders questioned whether investing in technology to provide custoers the ability to view electricity usage on an hourly basis (for exaple, via an online portal) would be worth the cost. At iniu, stakeholders thought it was iportant to provide custoers soe general rules-of-thub on which specific appliances ight provide the best opportunities for shifting their deand.

10 Page10 o o Soe stakeholders inquired about how custoers will receive inforation about their electricity usage if they won t be able to do so in real-tie. Suggestions to accoplish this included a break-down of electric usage within the daily TOU periods on custoer onthly bills and providing onthly reports that copare a custoer s usage in one onth to that of the previous onth (to identify whether they re iproving at deand shifting). Stakeholders asked if Xcel Energy s existing obile app could be used as an education and engageent channel for pilot custoers. However, it was noted that this would likely be cost-prohibitive, because it would require Xcel to invest in additional functionality and features that would only be applicable to a sall percentage of the custoer base. This ight ake sense though if and when TOU rates are rolled out ore broadly. VI. Pilot Design Features On-Peak Duration o There was interest fro the group in exploring whether the peak period could be shortened, but Xcel s syste data showed that if anything, the peak period should be longer. Snap-back (where deand spikes iediately after the peak period ends) was a concern raised and will be studied through the pilot. Integration of Renewable Energy o During this group s initial eetings in Spring 2017, identifying how a TOU rate could support the integration of ore renewables on Xcel s syste was a key interest fro soe stakeholders. In this Fall 2017 series of eetings, Xcel s consultant presented inforation to show how the TOU rate was designed to support the integration of additional renewables, taking into account projections for increased wind and solar generation through 2024 and 2030 based on Xcel Energy s resource plan. Overall, stakeholders seeed satisfied that this request had been et. Weekend Rate Design o o Suary: Stakeholders were asked by Xcel to give input on two weekend rate designs: 1) a weekend TOU rate that includes the sae three pricing levels (peak, off-peak, and super off-peak) as weekdays, 2) a weekend TOU rate that only includes off-peak and super off-peak pricing levels (i.e., the peak period becoes part of the off-peak period). After stakeholder discussion and additional evaluation fro Xcel Energy, it becae clear that there was not a strong reason to have three pricing levels on the weekend. Additional info that eerged fro Q&A on this topic: Custoers ay use slightly ore kwh on the weekend than a weekday, but not substantially ore. In ters of custoer bill ipacts, there ight be greater deviation in ipacts on individual custoers with the three-tier weekend option.

11 Page11 Beyond TOU o Conceivably the fuel ix would have higher penetration of renewables on the weekend, but that would vary seasonally. Suary: Stakeholders discussed the following three different design features that could reduce peak load in addition to the Tie of Use rate: Behavioral Deand Response, Peak Tie Rebate, and Critical Peak Pricing (see definitions of key ters above). Overall, stakeholders saw value in these options but were also concerned about the increased cost of ipleenting the. The group did not reach a recoendation on these beyond TOU options, though one stakeholder declared that he or she would oppose an opt-out CPP design. Deand Response o There was significant interest fro stakeholder in understanding how Xcel Energy is currently using and developing Deand Response technologies, with an eye towards how Deand Response could integrate with a Tie of Use rate. At stakeholders request, Xcel Energy brought in an expert to describe the current status of these technologies and to respond to questions about potential future integrations. Ultiately, however, the topic seeed a better fit for the upcoing Deand Response stakeholder working group eetings. VII. Pilot Q&A Stakeholders had several questions about the pilot that were raised throughout the three eetings. While Xcel Energy s filing addresses any of these ites (and since these were asked while the pilot design was in developent, soe responses ay have changed), we thought it ay still be helpful to capture the questions considered by stakeholders. Overall, these questions and answers reflect the need to balance precision and practicality, both for the utility and for custoers, which was a key design suggestion raised by this group. These have been categorized for ease of viewing, but otherwise are not presented in any specific order: Custoer Inforation: 1. Do we know if custoers are willing and able to take advantage of a TOU rate? a. Yes, surveying indicates that a significant portion of custoers willing to take advantage of TOU pricing. 2. What do we know about housing stock and age of appliances in the service areas being looked at for the pilot? a. Xcel Energy doesn t have reliable inforation on this now, but could get it through surveys during the study. 3. Does Xcel have data on whether custoers have central A/C? This is a controllable load that ay be less coon aong low-incoe custoers. a. No, but this could be included in a pre-enrollent survey.

12 Page12 Bill Ipacts: 4. What are the expected opportunities for savings and bill ipacts? a. In general, it s expected that custoers will have the opportunity to save, but not have significant bill ipacts if they don t change their behavior. 5. When would non-low-incoe custoers get refunded if their bill goes up by ore than 10%? b. On an annual basis. 6. If a custoer participating in the pilot falls behind on their electric bill, possibly enough to get disconnected, how will they be treated? c. Soe stakeholders felt it would be iportant to not kick people out of the pilot in this case, as learning about how and why the pilot affected the so drastically is iportant. Syste Ipacts: 7. What happens to syste load as a result of the TOU rate does it shift, and if so, to when? d. This will be studied as part of this pilot. Snap-back (in which deand spikes iediately after the end of the peak tie period) is a concern. 8. How does this rate design interact with renewables on the syste? e. The rate is designed to support the integration of additional renewables. Rules for Opt-in, Opt-out, Exclusions, and Mobility: 9. Why is Xcel Energy exploring only two locations for the pilot? a. To reduce the study costs. A broader pilot would be ore expensive, both for custoer engageent and for etering infrastructure. 10. Will custoers who are not opted into the pilot, but in one of the selected pilot counities and interested in being on the TOU rate, be able to sign up (opt-in) for the TOU rate? f. No, for two ain reasons: 1) custoers that are part of the pilot will need new eters, so allowing this would add to the cost of the pilot; 2) custoers selfselecting into the pilot could skew the pilot results and ay be difficult and costly to separate out. 11. What sort of opt-out rate do you expect to see? g. In SMUD s pilot, 5% dropped out during the study period and 15-20% oved out of the service territory. 12. How will the opt-out process work? For exaple, can a custoer opt-out before the advanced eter is even installed? h. Custoers ay opt-out at any tie.

13 Page Who will be excluded fro the pilot and what reasoning guides the exclusion rules? i. In general, custoers that are already on coplex rate designs will be excluded as cobining two advanced rate designs would be difficult and expensive. Additionally, custoers that have invested their own capital in distributed energy technologies are excluded to avoid affecting the expected payback of their investent. Following these criteria, the following groups will not be opted into the pilot, even if they are in the pilot territory: i. Net etering custoers, including those with rooftop solar ii. Custoers on the electric space heating TOU rate iii. Dual fuel custoers iv. Custoers on the existing electric vehicle charging TOU rate 14. What happens if a pilot participant oves? j. If a custoer oves fro one residence in the pilot to another residence in the pilot, they ll reain in the pilot. But if a custoer oves fro a pilot residence to a non-pilot residence, they ll go back to the noral rate.

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15 First Nae Last Nae Eail Copany Nae Address Delivery Method View Trade Secret Service List Nae David Aafedt Winthrop & Weinstine, P.A. Suite 3500, 225 South Sixth Street 4629 Christopher Anderson Minnesota Power 30 W Superior St Duluth, Alison C Archer aarcher@isoenergy.org MISO 2985 Aes Crossing Rd Eagan, Mara Aschean ara.k.aschean@xcelen ergy.co Xcel Energy 414 Nicollet Mall Fl Andrew Bahn Andrew.Bahn@state.n.us Public Utilities Coission 121 7th Place E., Suite 350 Ryan Barlow Ryan.Barlow@ag.state.n. us Jaes J. Bertrand jaes.bertrand@stinson.co Brenda A. Bjorklund brenda.bjorklund@centerp ointenergy.co General-RUD Stinson Leonard Street LLP 50 S 6th St Ste 2600 CenterPoint Energy Willia A. Blazar bblazar@nchaber.co Minnesota Chaber Of Coerce Jaes Canaday jaes.canaday@ag.state. n.us General-RUD 445 Minnesota Street Breer Tower, Suite 1400 Minnesota 505 Nicollet Mall Suite Robert Street North Suite Minnesota St.

16 First Nae Last Nae Eail Copany Nae Address Delivery Method View Trade Secret Service List Nae Jeanne Cochran Office of Adinistrative Hearings P.O. Box John Coffan AARP 871 Tuxedo Blvd. Generic Notice Coerce Attorneys ate.n.us General-DOC St, Louis, MO Minnesota Street Suite 1800 Electronic Service Yes OFF_SL_17-775_M Corey Conover sn.gov Carl Cronin nergy.co Joseph Dael n.us Jaes Denniston ergy.co Minneapolis City Attorney 350 S. Fifth Street City Hall, Roo Xcel Energy 414 Nicollet Mall FL 7 General-RUD Xcel Energy Services, Inc Breer Tower, Suite Minnesota Street Nicollet Mall, Fifth Floor Ian Dobson residential.utilities@ag.stat e.n.us General-RUD John Farrell jfarrell@ilsr.org Institute for Local Self- Reliance BRM Tower 445 Minnesota St th St SE # Electronic Service Yes OFF_SL_17-775_M

17 First Nae Last Nae Eail Copany Nae Address Delivery Method View Trade Secret Service List Nae Sharon Ferguson Stephen Fogel rgy.co Departent of Coerce 85 7th Place E Ste 280 Xcel Energy Services, Inc. Saint Paul, Congress Ave, Suite 1650 Austin, TX Edward Garvey edward.garvey@aeslcons ulting.co Janet Gonzalez Janet.gonzalez@state.n. us Kiberly Hellwig kiberly.hellwig@stoel.co AESL Consulting 32 Lawton St Saint Paul, Public Utilities Coission Suite th Place East Stoel Rives LLP 33 South Sixth Street Suite 4200 Michael Hoppe il23@tn.org Local Union 23, I.B.E.W. 932 Payne Avenue Julia Jazynka jjazynka@energyfreedoc oalition.co Energy Freedo Coalition of Aerica 101 Constitution Ave NW Ste 525 East Washington, DC Alan Jenkins aj@jenkinsatlaw.co Jenkins at Law 2265 Roswell Road Suite 100 Marietta, GA Linda Jensen linda.s.jensen@ag.state. n.us General-DOC 1800 BRM Tower 445 Minnesota Street

18 First Nae Last Nae Eail Copany Nae Address Delivery Method View Trade Secret Service List Nae Richard Johnson Moss & Barnett 150 S. 5th Street Suite 1200 Sarah Johnson Phillips Stoel Rives LLP 33 South Sixth Street Suite 4200 Dan Juhl Juhl Energy Inc th St SE Pipestone, Mark J. Kaufan rg IBEW Local Union Nicollet Avenue South Burnsville, Thoas Koehler Local Union #160, IBEW 2909 Anthony Ln St Anthony Village, Michael Krikava Briggs And Morgan, P.A IDS Center 80 S 8th St Douglas Larson dlarson@dakotaelectric.co Peder Larson plarson@larkinhoffan.co Paula Maccabee Paccabee@justchangela w.co Peter Madsen peter.adsen@ag.state. n.us Dakota Electric Association Larkin Hoffan Daly & Lindgren, Ltd. Just Change Law Offices General-DOC th St W Farington, Noran Center Drive Suite 1000 Blooington, Selby Ave Saint Paul, Breer Tower, Suite Minnesota Street Minnesota 4

19 First Nae Last Nae Eail Copany Nae Address Delivery Method View Trade Secret Service List Nae Kavita Maini KM Energy Consulting LLC 961 N Lost Woods Rd Oconoowoc, WI Pa Marshall pa@energycents.org Energy CENTS Coalition 823 7th St E Mary Martinka ary.a.artinka@xcelener gy.co Xcel Energy Inc Brian Meloy brian.eloy@stinson.co Stinson,Leonard, Street LLP Joseph Meyer joseph.eyer@ag.state.n.us General-RUD 414 Nicollet Mall 7th Floor S 6th St Ste 2600 Breer Tower, Suite Minnesota Street St Paul, David Moeller doeller@allete.co Minnesota Power 30 W Superior St Electronic Service Yes OFF_SL_17-775_M Duluth, Andrew Moratzka andrew.oratzka@stoel.co David Niles david.niles@avantenergy.c o Stoel Rives LLP 33 South Sixth St Ste 4200 Minnesota Municipal Power Agency 220 South Sixth Street Suite 1300 Minnesota Will Nissen nissen@fresh-energy.org Fresh Energy 408 St. Peter Street Ste 220 Carol A. Overland overland@legalectric.org Legalectric - Overland Law Office Saint Paul, West Avenue Red Wing,

20 First Nae Last Nae Eail Copany Nae Address Delivery Method View Trade Secret Service List Nae Jeff Oxley Office of Adinistrative Hearings Kevin Reuther Center for Environental Advocacy Richard Savelkoul o Martin & Squires, P.A. 600 North Robert Street 26 E Exchange St, Ste Minnesota Street Ste W2750 Inga Schuchard ischuchard@larkinhoffan. co Larkin Hoffan 8300 Noran Center Drive Suite Janet Shaddix Elling jshaddix@janetshaddix.co Shaddix And Associates 7400 Lyndale Ave S Ste 190 Electronic Service Yes OFF_SL_17-775_M Richfield, Zeviel Sipser zsipser@briggs.co Briggs and Morgan PA 2200 IDS Center80 South Eighth Street 2157 Ken Sith ken.sith@districtenergy.c o Peggy Soru peggy.soru@centerpointe nergy.co District Energy St. Paul Inc. 76 W Kellogg Blvd CenterPoint Energy Nicollet Mall Byron E. Starns byron.starns@stinson.co Stinson Leonard Street LLP 50 S 6th St Ste

21 First Nae Last Nae Eail Copany Nae Address Delivery Method View Trade Secret Service List Nae Jaes M. Stroen Kennedy & Graven, Chartered Eric Swanson Winthrop & Weinstine 225 S 6th St Ste 3500 Capella Tower U.S. Bank Plaza 200 South Sixth Street Lisa Veith lisa.veith@ci.stpaul.n.us City of St. Paul 400 City Hall and Courthouse 15 West Kellogg Blvd Saantha Willias swillias@nrdc.org Natural Resources Defense Council 20 N. Wacker Drive Ste 1600 Chicago, IL Joseph Windler jwindler@winthrop.co Winthrop & Weinstine 225 South Sixth Street, Suite 3500 Ca Winton cwinton@nchaber.co Minnesota Chaber of Coerce 400 Robert Street North Suite 1500 Minnesota Daniel P Wolf dan.wolf@state.n.us Public Utilities Coission 121 7th Place East Suite Jeff Zethayr jzethayr@citizensutilitybo ard.org Citizens Utility Board 309 W. Washington, Ste 800 Electronic Service Yes OFF_SL_17-775_M Chicago, IL Patrick Zoer Patrick.Zoer@lawoss.c o Moss & Barnett a Professional Association 150 S. 5th Street, #1200 7

22 First Nae Last Nae Eail Copany Nae Address Delivery Method View Trade Secret Service List Nae David Aafedt Winthrop & Weinstine, P.A. Suite 3500, 225 South Sixth Street 4629 Christopher Anderson Minnesota Power 30 W Superior St Duluth, Alison C Archer aarcher@isoenergy.org MISO 2985 Aes Crossing Rd Ryan Barlow Ryan.Barlow@ag.state.n. us Jaes J. Bertrand jaes.bertrand@stinson.co General-RUD Willia A. Blazar bblazar@nchaber.co Minnesota Chaber Of Coerce Jaes Canaday jaes.canaday@ag.state. n.us Jeanne Cochran Jeanne.Cochran@state.n.us Eagan, Stinson Leonard Street LLP 50 S 6th St Ste 2600 General-RUD Office of Adinistrative Hearings 445 Minnesota Street Breer Tower, Suite 1400 Minnesota Suite Robert Street North Suite Minnesota St. P.O. Box John Coffan john@johncoffan.net AARP 871 Tuxedo Blvd. St, Louis, MO Generic Notice Coerce Attorneys coerce.attorneys@ag.st ate.n.us General-DOC 445 Minnesota Street Suite 1800 Electronic Service Yes OFF_SL_17-776_M

23 First Nae Last Nae Eail Copany Nae Address Delivery Method View Trade Secret Service List Nae Corey Conover sn.gov Carl Cronin nergy.co Joseph Dael n.us Ian Dobson e.n.us Minneapolis City Attorney 350 S. Fifth Street City Hall, Roo Xcel Energy 414 Nicollet Mall FL 7 General-RUD General-RUD John Farrell jfarrell@ilsr.org Institute for Local Self- Reliance Sharon Ferguson sharon.ferguson@state.n.us Edward Garvey edward.garvey@aeslcons ulting.co Janet Gonzalez Janet.gonzalez@state.n. us Kiberly Hellwig kiberly.hellwig@stoel.co Breer Tower, Suite Minnesota Street BRM Tower 445 Minnesota St th St SE # Departent of Coerce 85 7th Place E Ste 280 AESL Consulting Saint Paul, Lawton St Saint Paul, Public Utilities Coission Suite th Place East Stoel Rives LLP 33 South Sixth Street Suite 4200 Michael Hoppe il23@tn.org Local Union 23, I.B.E.W. 932 Payne Avenue Electronic Service Yes OFF_SL_17-776_M

24 First Nae Last Nae Eail Copany Nae Address Delivery Method View Trade Secret Service List Nae Julia Jazynka oalition.co Energy Freedo Coalition of Aerica 101 Constitution Ave NW Ste 525 East Washington, DC Alan Jenkins Jenkins at Law 2265 Roswell Road Suite 100 Marietta, GA Linda Jensen n.us General-DOC 1800 BRM Tower 445 Minnesota Street 2134 Richard Johnson Moss & Barnett 150 S. 5th Street Suite 1200 Sarah Johnson Phillips Stoel Rives LLP 33 South Sixth Street Suite 4200 Mark J. Kaufan rg IBEW Local Union Nicollet Avenue South Burnsville, Thoas Koehler Local Union #160, IBEW 2909 Anthony Ln St Anthony Village, Michael Krikava Briggs And Morgan, P.A IDS Center 80 S 8th St Douglas Larson dlarson@dakotaelectric.co Dakota Electric Association th St W Farington,

25 First Nae Last Nae Eail Copany Nae Address Delivery Method View Trade Secret Service List Nae Peder Larson Paula Maccabee w.co Peter Madsen n.us Larkin Hoffan Daly & Lindgren, Ltd. Just Change Law Offices General-DOC 8300 Noran Center Drive Suite 1000 Blooington, Selby Ave Saint Paul, Breer Tower, Suite Minnesota Street Minnesota Kavita Maini KM Energy Consulting LLC 961 N Lost Woods Rd Oconoowoc, WI Pa Marshall pa@energycents.org Energy CENTS Coalition 823 7th St E Joseph Meyer joseph.eyer@ag.state.n.us General-RUD Breer Tower, Suite Minnesota Street St Paul, David Moeller doeller@allete.co Minnesota Power 30 W Superior St Duluth, Andrew Moratzka andrew.oratzka@stoel.co David Niles david.niles@avantenergy.c o Stoel Rives LLP 33 South Sixth St Ste 4200 Minnesota Municipal Power Agency Carol A. Overland overland@legalectric.org Legalectric - Overland Law Office 220 South Sixth Street Suite 1300 Minnesota 1110 West Avenue Red Wing,

26 First Nae Last Nae Eail Copany Nae Address Delivery Method View Trade Secret Service List Nae Jeff Oxley Office of Adinistrative Hearings Kevin Reuther Center for Environental Advocacy Richard Savelkoul o Martin & Squires, P.A. 600 North Robert Street 26 E Exchange St, Ste Minnesota Street Ste W2750 Inga Schuchard ischuchard@larkinhoffan. co Larkin Hoffan 8300 Noran Center Drive Suite Zeviel Sipser zsipser@briggs.co Briggs and Morgan PA 2200 IDS Center80 South Eighth Street 2157 Ken Sith ken.sith@districtenergy.c o District Energy St. Paul Inc. 76 W Kellogg Blvd Byron E. Starns byron.starns@stinson.co Stinson Leonard Street LLP 50 S 6th St Ste 2600 Jaes M. Stroen jstroen@kennedygraven.co Kennedy & Graven, Chartered Eric Swanson eswanson@winthrop.co Winthrop & Weinstine 225 S 6th St Ste 3500 Capella Tower U.S. Bank Plaza 200 South Sixth Street 5

27 First Nae Last Nae Eail Copany Nae Address Delivery Method View Trade Secret Service List Nae Lisa Veith City of St. Paul 400 City Hall and Courthouse 15 West Kellogg Blvd Joseph Windler Winthrop & Weinstine 225 South Sixth Street, Suite 3500 Ca Winton Minnesota Chaber of Coerce 400 Robert Street North Suite 1500 Minnesota Daniel P Wolf dan.wolf@state.n.us Public Utilities Coission 121 7th Place East Suite Patrick Zoer Patrick.Zoer@lawoss.c o Moss & Barnett a Professional Association 150 S. 5th Street, #1200 Electronic Service Yes OFF_SL_17-776_M

28 First Nae Last Nae Eail Copany Nae Address Delivery Method View Trade Secret Service List Nae Christopher Anderson Minnesota Power 30 W Superior St Duluth, Alison C Archer aarcher@isoenergy.org MISO 2985 Aes Crossing Rd Eagan, Mara Aschean ara.k.aschean@xcelen ergy.co Xcel Energy 414 Nicollet Mall Fl Andrew Bahn Andrew.Bahn@state.n.us Public Utilities Coission 121 7th Place E., Suite 350 Ryan Barlow Ryan.Barlow@ag.state.n. us Jaes J. Bertrand jaes.bertrand@stinson.co Brenda A. Bjorklund brenda.bjorklund@centerp ointenergy.co General-RUD Stinson Leonard Street LLP 50 S 6th St Ste 2600 CenterPoint Energy Willia A. Blazar bblazar@nchaber.co Minnesota Chaber Of Coerce Jaes Canaday jaes.canaday@ag.state. n.us Jeanne Cochran Jeanne.Cochran@state.n.us General-RUD Office of Adinistrative Hearings 445 Minnesota Street Electronic Service Yes OFF_SL_15-662_Official Breer Tower, Suite 1400 Minnesota 505 Nicollet Mall Suite Robert Street North Suite Minnesota St. P.O. Box Electronic Service Yes OFF_SL_15-662_Official Electronic Service Yes OFF_SL_15-662_Official

29 First Nae Last Nae Eail Copany Nae Address Delivery Method View Trade Secret Service List Nae John Coffan AARP 871 Tuxedo Blvd. Generic Notice Coerce Attorneys ate.n.us General-DOC St, Louis, MO Minnesota Street Suite 1800 Electronic Service Yes OFF_SL_15-662_Official Carl Cronin nergy.co Jaes Denniston ergy.co Xcel Energy 414 Nicollet Mall FL 7 Xcel Energy Services, Inc Nicollet Mall, Fifth Floor Electronic Service Yes OFF_SL_15-662_Official Electronic Service Yes OFF_SL_15-662_Official Ian Dobson residential.utilities@ag.stat e.n.us Sharon Ferguson sharon.ferguson@state.n.us Stephen Fogel Stephen.E.Fogel@XcelEne rgy.co General-RUD 1400 BRM Tower 445 Minnesota St 2130 Departent of Coerce 85 7th Place E Ste 280 Xcel Energy Services, Inc. Saint Paul, Congress Ave, Suite 1650 Electronic Service Yes OFF_SL_15-662_Official Electronic Service Yes OFF_SL_15-662_Official Austin, TX Kiberly Hellwig kiberly.hellwig@stoel.co Stoel Rives LLP 33 South Sixth Street Suite 4200 Michael Hoppe il23@tn.org Local Union 23, I.B.E.W. 932 Payne Avenue

30 First Nae Last Nae Eail Copany Nae Address Delivery Method View Trade Secret Service List Nae Alan Jenkins Jenkins at Law 2265 Roswell Road Suite 100 Marietta, GA Linda Jensen n.us General-DOC 1800 BRM Tower 445 Minnesota Street Electronic Service Yes OFF_SL_15-662_Official 2134 Richard Johnson Moss & Barnett 150 S. 5th Street Suite 1200 Sarah Johnson Phillips Stoel Rives LLP 33 South Sixth Street Suite 4200 Dan Juhl Juhl Energy Inc th St SE Pipestone, Mark J. Kaufan rg IBEW Local Union Nicollet Avenue South Burnsville, Thoas Koehler Local Union #160, IBEW 2909 Anthony Ln St Anthony Village, Michael Krikava Briggs And Morgan, P.A IDS Center 80 S 8th St Peder Larson plarson@larkinhoffan.co Larkin Hoffan Daly & Lindgren, Ltd Noran Center Drive Suite 1000 Blooington,

31 First Nae Last Nae Eail Copany Nae Address Delivery Method View Trade Secret Service List Nae Douglas Larson Paula Maccabee w.co Peter Madsen n.us Dakota Electric Association Just Change Law Offices General-DOC th St W Farington, Selby Ave Saint Paul, Pa Marshall pa@energycents.org Energy CENTS Coalition 823 7th St E Breer Tower, Suite Minnesota Street Minnesota Electronic Service Yes OFF_SL_15-662_Official Mary Martinka ary.a.artinka@xcelener gy.co Xcel Energy Inc Brian Meloy brian.eloy@stinson.co Stinson,Leonard, Street LLP 414 Nicollet Mall 7th Floor S 6th St Ste 2600 David Moeller doeller@allete.co Minnesota Power 30 W Superior St Electronic Service Yes OFF_SL_15-662_Official Duluth, Andrew Moratzka andrew.oratzka@stoel.co David Niles david.niles@avantenergy.c o Stoel Rives LLP 33 South Sixth St Ste 4200 Minnesota Municipal Power Agency 220 South Sixth Street Suite 1300 Minnesota Will Nissen nissen@fresh-energy.org Fresh Energy 408 St. Peter Street Ste 220 Saint Paul,

32 First Nae Last Nae Eail Copany Nae Address Delivery Method View Trade Secret Service List Nae Carol A. Overland Legalectric - Overland Law Office Kevin Reuther kreuther@ncenter.org Center for Environental Advocacy Richard Savelkoul rsavelkoul@artinsquires.c o Martin & Squires, P.A West Avenue Red Wing, E Exchange St, Ste Minnesota Street Ste W2750 Inga Schuchard ischuchard@larkinhoffan. co Larkin Hoffan 8300 Noran Center Drive Suite Janet Shaddix Elling jshaddix@janetshaddix.co Shaddix And Associates 7400 Lyndale Ave S Ste 190 Electronic Service Yes OFF_SL_15-662_Official Richfield, Ken Sith ken.sith@districtenergy.c o Peggy Soru peggy.soru@centerpointe nergy.co District Energy St. Paul Inc. 76 W Kellogg Blvd CenterPoint Energy Nicollet Mall Byron E. Starns byron.starns@stinson.co Stinson Leonard Street LLP 50 S 6th St Ste 2600 Jaes M. Stroen jstroen@kennedygraven.co Kennedy & Graven, Chartered 470 U.S. Bank Plaza 200 South Sixth Street 5

33 First Nae Last Nae Eail Copany Nae Address Delivery Method View Trade Secret Service List Nae Eric Swanson Winthrop & Weinstine 225 S 6th St Ste 3500 Capella Tower 4629 Lisa Veith lisa.veith@ci.stpaul.n.us City of St. Paul 400 City Hall and Courthouse 15 West Kellogg Blvd Saantha Willias swillias@nrdc.org Natural Resources Defense Council Ca Winton cwinton@nchaber.co Minnesota Chaber of Coerce 20 N. Wacker Drive Ste 1600 Chicago, IL Robert Street North Suite 1500 Minnesota Daniel P Wolf dan.wolf@state.n.us Public Utilities Coission 121 7th Place East Suite Jeff Zethayr jzethayr@citizensutilitybo ard.org Citizens Utility Board 309 W. Washington, Ste 800 Electronic Service Yes OFF_SL_15-662_Official Chicago, IL Patrick Zoer Patrick.Zoer@lawoss.c o Moss & Barnett a Professional Association 150 S. 5th Street, #1200 6