Buckeye Power

50
UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Buckeye Power, Inc. ) V. ) American Transmission Systems, Incorporated ) Docket No. EL I 1-54-002 EXHIBIT LIST OF COMMISSION TRIAL STAFF Exhibit Number S-l S-2 S-3 S-4 S-5 S-6 S-7 S-g Protected S-9 It'itness Description Antonio Maceo Antonio Maceo Antonio Maceo Antonio Maceo Antonio Maceo Antonio Maceo Antonio Maceo Antonio Maceo Antonio Maceo Direct and Answering Testimony Excerpt from PJM White Paper "A Survey of Cost Allocation Issues, Methods and Practices." PJM News Release, article announcing American Transmission Systems, Inc. (ATSI) joining PJM. Excerpt from NERC Balancing Authority/Transmission Operator Reliability Readiness Evaluation Report FirstEnergy Corporation (FE-West MISO Territory) Akron, Ohio, April 16-19, 2007. Midwest ISO Proposed Revisions to its Open Access Transmission Tariff (OATT) under ER05-285-000. Excerpt Irom First Energy Service Company (FirstEnergy's) 2/28/2011 filing with the Security and Exchange Commission (SEC). Excerpt from PJM "Manual 27: Open Access Transmission TarifF Accounting." ATSI's response to Staff discovery: Staff-l. I (PROTECTED), Staffl.3 (PROTECTED), Staff- 1.4 (PROTECTED), Staff-1.5 (PROTECTED), Staff-1.6 (PROTECTED), Staff-1.7, Staff-1.9, Staff-2.3. Excerpt from PJM Manual 14B: PJM Region Transmission Admitted into Evidence i n~~ nn alataiv Cammissia a D krtw Ef I I -5'e/ oa & HeariagFw Na. i9 - I patrie vtinM I/tf/t4 DateAdmitted I Ol I I l i~ I 20130116-0400 FERC PDF (Unofficial) 01/11/2013

Transcript of Buckeye Power

Page 1: Buckeye Power

UNITED STATES OF AMERICABEFORE THE

FEDERAL ENERGY REGULATORY COMMISSION

Buckeye Power, Inc. )V. )American Transmission Systems, Incorporated )

Docket No. ELI1-54-002

EXHIBIT LISTOF

COMMISSION TRIAL STAFF

ExhibitNumberS-l

S-2

S-3

S-4

S-5

S-6

S-7

S-gProtected

S-9

It'itness Description

AntonioMaceoAntonioMaceoAntonioMaceo

AntonioMaceo

AntonioMaceo

AntonioMaceo

AntonioMaceoAntonioMaceo

AntonioMaceo

Direct and Answering Testimony

Excerpt from PJM White Paper "A Survey ofCost Allocation Issues, Methods and Practices."PJM News Release, article announcingAmerican Transmission Systems, Inc. (ATSI)joining PJM.Excerpt from NERC BalancingAuthority/Transmission Operator ReliabilityReadiness Evaluation Report FirstEnergyCorporation (FE-West MISO Territory) Akron,Ohio, April 16-19,2007.Midwest ISO Proposed Revisions to its OpenAccess Transmission Tariff (OATT) underER05-285-000.Excerpt Irom First Energy Service Company(FirstEnergy's) 2/28/2011 filing with theSecurity and Exchange Commission (SEC).Excerpt from PJM "Manual 27: Open AccessTransmission TarifF Accounting."ATSI's response to Staff discovery: Staff-l. I(PROTECTED), Staffl.3 (PROTECTED), Staff-1.4(PROTECTED), Staff-1.5 (PROTECTED),Staff-1.6 (PROTECTED), Staff-1.7, Staff-1.9,Staff-2.3.Excerpt from PJM Manual 14B:PJM RegionTransmission

Admitted intoEvidence

i n~~ nn alataiv Cammissia a

D krtw Ef I I -5'e/ oa &HeariagFw Na. i9 - I

patrie vtinM I/tf/t4DateAdmitted I Ol I I li~

I

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 2: Buckeye Power

AntonioMaceo

ATSI's response to Staff Data Request 2.1

AntonioMaceo

ATSI's response to Staff Data Request 2.3

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 3: Buckeye Power

FEDERAL ENERGY REGULATORY COMMISSIONOFFICE OF ADMINISTRATIVE LITIGATION

BUCKEYE POWER, INC.V.

AMERICAN TRANSMISSION SYSTEM, INC.

DOCKET NO. EL11-54-002

DIRECT AND ANSWERING TESTIMONYOF

COMMISSION TRIAL STAFF WITNESS

ANTONIO MACEOU ~

August 09, 2012

WASHINGTON, D.C. 20426

PUBLIC VERSION

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 4: Buckeye Power

.'.01 '0809-5108 i ERC PDP (Unof ficial) 8/9/?012 8:54:25 PN

I EDERAL LNFRGY l&EGIJI ATORY COMMISSIONt)l'12ICE OF ADIV1IN ISTIC%'I'I VF. LI'I IGA'I'ION

WASH IN(l fON. D.C. 20426Via Electronic Filinn

August 9, 2012

Ms. Kimberly D. HoseSecretaryI'ederal Energy Regulatory Commission888 First Street, N.E.Washington, D.C. 20426

Re: Buckeye Power, Inc.V.

/Imerican Transmission Systems. Inc.

Docket No. EL I I -54-002

Dear Madam Secretary:

Enclosed for electronic tiling with the Commission are the Initial 'festimony and

Exhibits of Antonio Maceo on behalf of the Commission Trial Staff in the above-captionedproceeding. This testimony consists of Exhibit Nos. S-I through S-9.

The testimony and supporting exhibits contain Protected Material, including CriticalEnergy Infrastructure Information, as designated under the Protective Order in the proceedingand Section 3888.112of the Commission's rules governing information requests, 18 C.F.R. It

388.112(2011).Accordingly, the testimony and supporting exhibits are being submitted in

two versions, a Public Version, which contains text where the Protected Material has beenobscured, and a Protected Version, where the Protected Material is visible.

Trial Staff will be serving all parties on the Commission's service list with copies ofthis testimony and exhibits by e-mail as well as providing both hard copy and electronicservice to the Presiding Administrative Law Judge.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 5: Buckeye Power

201.:Ol)()0-0Ias FERC FDF (Unoiticial) 'I/O/00)" I:0 I: '"I IFM

I'lease contact me if you have any questions about this tiling. l'hank you l'or yourassistance with this matter.

Sincerely,

'.vl Lorna i HadlockLorna J. Hadlockl)redrick WilsonCommission Staff Counsel

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 6: Buckeye Power

'0 I:!0009-9108 I'EBC I'Df'Unof f icial i II/O/2012 4:94:25 PN

EXHIBIT iVO. S-I

FEDERAL ENERGY REGULATORY COMMISSIONOFFICE OF ADMINISTRATIVE LITIGATION

BUCKEYE POWER, INC.V.

AMERICAN TRANSMISSION SYSTEM, INC.

DOCKET NO. EL I 1-54-002

DIRECT AND ANSWERING TESTIMONYOF

COMMISSION TRIAL STAFF WITNESS

ANTONIO MACEO

lli8

4%5II'ugust

09, 2012

WASHINGTON, D.C. 20426

PUBLIC VERSION

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 7: Buckeye Power

. ) i 'i)HU')-su)8 I:iu)C PDF ir)notfici ii) Bls/2012 1:61:-'6,'u

Exhibit iVo. S-I

UViITED STATES OF AMERICABEFORE TIIE

FEDERAL ENERGY REGULATORY COMMISSION

Buckeye Power, Inc. l)ocket No. EL I I-54-002

American Transmission Systems, Incorporated

Direct and Answering Testimony ofAntonio Maceo

Witness for the Staff of theFederal Energy Regulatory Commission

Q. Please state your name and business address?

3 A. My name is Antonio Maceo. and my business address is 888 First Street, NE,

Washington, D.C. 20426.

5 Q. By whom are you employed and in what capacity?

6 A. I am employed by the Federal Energy Regulatory Commission (Commission) as

an Electrical Engineer in the Office of Administrative Litigation.

8 Q. Please state your educational background and work history.

9 A. I graduated from Morgan State University in l995 and 1996, earning Bachelor of

lo

l2

l3

Science degrees first in Physics and then Engineering Physics, with a

concentration in Nuclear Physics and Electrical Systems (Electro-physics).

Currently I am pursuing a Master of Science degree in Electrical Engineering

(MSEE) with a concentration in Control Systems from Capitol College in Laurel.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 8: Buckeye Power

iot.."nios-stoa I.:sac oDF (unofficial) 8/9/z012 i:54:z5 i'ls

ltuckcye Power, lac.l)ockct IVo. Kl. I I-54-002

I~:ah(bit iVo. 8-II'age 2 of 43

10

I2

l3

l4

I6

17

l8

l9

Maryland. In addition to my engineering education, I have completed two

depreciation seminars given by the Society of Depreciation Prolbssionals (SDP), a

commercial organization widely recognized for its expertise in depreciation-

related matters. I am also a member ol'he Society of Depreciation Professionals

(SDP), the Institute of Flectrical and Flectronic Engineers (IEEE), the Institute of

Public Utilities (IPU), the American Physical Society (APS), and the National

Society of Black Engineers (NSBE).

From May 1995 to July 1995, I was employed as a program instructor at Morgan

State Uniiversity in the Electrical Engineering department, where I taught basic and

introductory electronics (analog k digital), with the use of computer simulation of

«lectronic circuits. From 1995 to 2005, I performed various job functions as an

Electronic Engineering Technician, Metrology Engineer, Quality Control

Engineer, and tlnally as an Environmental Sanitarian and Radiation Safety OAicer

for the Baltimore City Department of Health. On September 29, 2005, I accepted

a position with the Pennsylvania Public Utility Commission (PAPUC) as a

Nuclear Engineer. My job duties with the PAPUC included. but were not limited

to, assisting in the performance of studies and analyses regarding engineering

issues and energy regulation. Specifically, those issues included valuation,

depreciation, cost of service, and quality and reliability of service as they apply to

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 9: Buckeye Power

.'r ) 'us))9 —0 u)a ) aRC por (Unotf ici &t) )3/') I "(1)s 4:ss: ss PM

Iluckcyc Paver, Inc.t)ockct Nn. KLI I-54«gt)2

Kshibit No..'l-l1'ge 3 of 43

«lcctric utilities. In August 2008 I joined the I'edcral Energy Regulatory

Commission (FFRC), Oil)ce ot'Administrative Litigation (OAI.).

Q. Please summarize your duties with the Federal Energy RegulatoryCommission.

A. My responsibilities include pert'orming Electrical Fngincering analyses in «lcctric

cases set for hearing by the Commission. Furthermore, I also determine the

appropriate depreciation rates in formal gas and electric mte case proceedings. and

provide support for such rates.

') Q. I lave you previously testified before the Commission?

10 A. Yes. While employed at FERC, I submitted testimony in: ( I) Mirl/Imerican

12

13

14

15

16

17

19

') 0

21

Energy Company, Docket No. ER09-823-000. My testimony in that proceeding

dealt with the examination of disputed facility upgrades of MidAmerican from the

perspective of the Commission's Seven Factor Test. The Seven Factor Test was

utilized in that proceeding to establish whether or not the disputed facility

upgrades conformed to the test for classifying them as local distribution facilities;

and (2) El Paso Natural Gas Company, Docket No. RP10-1398-000, in which I

examined and provided evidence supporting the view that contract life, should not

be the determining factor in establishing the depreciation service life of the

Willcox I.ateral (an extended natural gas pipeline). I further demonstrated that

contract life will understate the remaining life associated with this facility, thus

skewing the ability to have a properly assigned calculated depreciation rate.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 10: Buckeye Power

.«)!?I)rr))'3-s ')r) veac ace (unoiticial) s/9/so L2 ):s i r /5 au

Iluckeye Power, loe.l)neket No. KLI I-54-tl0Z

I'.shihit Nr&. 8-II'age 4 of 43

l (2. rllr. Maceo, have you previously testified before any State Commission?

Yes. While employed at the PAPUC, I tcstilied in: (1) Perrnsylvania Public Utilitv

3 Cr?rnnrission v. Valley Energy, Inc., Docket No. R-00072349. i&ly testimony in

4 that proceeding dealt with Late Payment Revenues as applied to natural gas

5 lacilities: (2) Pennsylvania Public Utility Commission v. Emporirrm )Voter

6 Crrmpany, Docket No. R-00061297, which dealt with Unaccounted t'or Water and

7 Line Breaks associated with the water system; (3) Pennsylvania Public Utility

10

12

l3

I5

l6

17

Commission v. /Iurbrbon Water Company, Docket No. R-000721000, which dealt

with Customer Service and its impact on the residential customerratepayers'verall

quality of service; (4) Pennsylvania Public Utility Commission v.

Cobrmbia Gas ofPennsylvania, Inc., Docket No. R-2008-2028039, which dealt

with the issue of Lost and Unaccounted for Gas, Retainage, and Unit)ed Sharing

Mechanisms within the context of natural gas facilities; and (5) Pennsylvania

Public Utility Commission v. Total Environmental Solutions, Inc., Docket No. R-

00072495, which dealt with the issue of Materials and Supply, Rate Design,

Customer Penalties, and the Water Allowance Minimum Charge within the

context of sewer facilities.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 11: Buckeye Power

:)&..f)etta-stoa t&I!ac t&DF Itlnorrici&i) 'ti')t.!ttu& t:&&a::!5 "ii

thickeye l&mver, lnc.t)acket No. I?I.l 1-54-0(12

Exhibit l&to. 5&-l

Page 5 of43

L INTRODUCTION

(P. What gave rise to this proceeding".

3 A. ()n July 1 tt. 2011, 13uckeye 1'ower, inc. (Buckeye) tiled a complaint alleging that

the American '1 ransmission Systems. Incorporated's (ATSI's) voltage

dit'I'ercntiated rates tor transmission service in the ATSI zone ot PJM

interconnection. L.L.C.(PJM) are unjust, unreasonable, unduly discriminatory,

and preferential, and should be replaced with a rolled-in rate rellecting the cost of

all ATSI transmission facilities. regardless of transmission voltage. By order

issued on October 20, 2011, the Commission set Buckeye's complaint for hearing

and established settlement judge proceedings. The settlement etforts were not

successful, and the case entered the trial phase.

12 Q. What is the purpose of your testimony?

13 A. The purpose of my testimony is (1) to address, from an engineering perspective.

15

16

whether the current voltage dilTerentiated rate structure is reasonable and whether

an alternative rate structure would be appropriate for ATSI's transmission

facilities: and (2) to respond to various comments raised in American Municipal

Power. Inc. and Cleveland Public Power (AMP/CPP's) witnesses'estimony.

18 Q. VVhat are your conclusions and recommendations?

19 A. Based on my analysis, I conclude that ATSI's existing voltage-differentiated rate

20 design is unreasonable and inappropriate. I recommend that ATSI's voltage

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 12: Buckeye Power

.'t)i,'.ORi)9 —RiOR FRRC FOF (Unof ficiel) R/9/soia i:54:25 iia

llackeye Power, Inc.l)oeket iso. FL I 1-54-0l)2

F,xhibit No. Si-I

Page 6 of 43

1 differentiated rate design be replaced with a single rolled-in rate which rccov«rs

7 the costs associated with all ot A CSI's integrated transmission lacilitics, regardless

ot'oltage, in a single rate.

4 (2. What information did you review in preparing your answering testimony7

A. I reviewed the t'ollowing materials in preparing my testimony:

6 ~ The complaint tiled in this docket on July 18, 2011 by Buckeye, including the

testimony and exhibits ot'Buckeye witnesses Denis W. Bethel and Manmohan

K. Sachdeva:

9 ~ The answers tiled in this docket in response to Buckeye's complaint by

10

l2

14

15

l6

17

l8

19

American Municipal Power. Inc. and Cleveland Public Power (AMP/CPP) and

ATSI;

~ Buckeye's case-in-chief, filed in this docket on April 18, 2012, including the

direct testimony of Buckeye witnesses Bethel and Sachdeva;

~ The prepared answering testimony of ATSI witnesses Richard A. Ziegler and

Donald Morrison, filed in this docket on June 27, 2012;

~ The prepared answering testimony of AMP/CPP witnesses Paul D. Reising, H.

Lee Willis, and David W. Hilt tiled in this docket on June 27, 2012;

~ The data requests and responses exchanged during the discovery process

among Buckeye, AMP/CPP, ATSI, PJM, and Staff; and

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 13: Buckeye Power

0) 1!0800-S100 L HRC L&or ))loof f iri LL ) S/0/!012 1:04:.!5 0!V)

llnckeye I'ower, Inc.l)oeket No. KI. I I-54-iltl2

Kxhihlt No. S-IPage 7 of 43

~ Various other documents, papers. and Commission Orders that dealt with

rolled-in methodology ol'ransmission cost allocation, as referenced below in

my testimony.

4 Q. WVhat exhibits are you sponsoring?

A. I am sponsoring Exhibit No. S-l, which is my direct and answering testimony, and

Exhibit Nos. S-2 through S-S, which include supporting documents and responses

to various data requests.

S Q. liow is your testimony organized?

9 A.

l2

l3

l4

IS

16

17

IS

l9

00

My testimony is organized into four sections: (I) Introduction; (II) Background;

(ill) Analysis of ATSI's Voltage-Differentiated Rates; and (IV) Comments

Regarding Other Witnesses'estimony.

In Section (I), I discuss Buckeye's complaint, the purpose of my testimony. and

how my testimony is organized.

in Section (II), I provide a description of ATSI's transmission system and describe

ATSI's Area Transmission System and Bulk Transmission System.

In Section (III), I provide an analysis of ATSI's voltage-diITerentiated rates, and

discuss tive factors that I believe should be addressed when addressing the issue of

rolled-in rates. In this section I also address problems with the existing cost

methodology and ATSI's justification for having a voltage-differentiated rate

treatment.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 14: Buckeye Power

10 1 /0) H I) ') -S 10a FFRC ROF ( l)no r f ic1a l ) 8 / 9 / 2 0 12 1:S 1:2 5 l ta

Buckeye Power, Inc.l)ncket No. KLI I-54-1)02

gshihit No. S-IPage 8 of 43

In Section (IV), I comment on AMP/CPP witnesses Willis'nd I lilt's testimonies.

II.BACKGROUND

3 (2. IVhat is your understanding of the term "transmission system"?

4 A. A transmission system rel'ers to the physical assets or equipment (lines, towers,

12

13

14

15

16

17

transformers, etc.) that facilitate the movement of electric energy from one

location to another. All physical assets that comprise the transmission system are

interconnected and operated in a synchronized manner.

'fhe movement of electricity over distances results in losses. Electric utilities use

higher transmission voltages for transmission lines to improve transmission

efftciency. Basically, for a given power transfer, transmission losses are reduced

exponentially with higher voltages. Therefore, electric utilities generally use

higher voltage facilities to move large amounts of power over long distances, as

transfers over higher voltages result in reduced power losses. According to PJM

White Paper, "A Survey of Transmission Cost Allocation Issues, Methods and

Practices," dated March 10, 2010, the function of the 345 kV, 500 kV. and 765 kV

transmission system is primarily to move large amounts of power over long

distances, whereas the function of facilities that operate at 230 kV and below is to

serve zonal, or localized needs.'

Ex. S-2, Excerpts from PJM White Paper 'A Survey of Cost Allocation Issues, Methods andPractices." The full paper can be found online at:htto://fto. oim.corn/-/media/documents/reoorts/20100310-transmission-allocation-cost-web.ash x.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 15: Buckeye Power

.''! l 'Usus-alon !:!Rc !'DF &Unotficiul) s/9/snt/ t:5t:ss !'N

Buckeye Power. lac.l)acket No. KLI I-54-titi2

Kxhihit iVo. S-lI'age 9 of 43

I I lcctricity flows on the physical transmission system over paths in inverse

2 proportion to their impedances. I'he implication ol'this physical property is that

3 the llows of power from a generator to a load will not necessarily follow its

4 scheduled or contracted path, but rather, will l'ollow on paths based on the paths

5 relative impedances.

6 Q. Briefly describe ATSI's transmission system.

7 A. The ATSI transmission system consists ol'over 7,500 circuit miles of transmission

lines operated at 69 kV, l38 kV, and 345 kV voltages. The ATSI transmission

svstem is used to serve over 2.2 million customers in northern and central Ohio

10 and western Pennsylvania. The system has 38 interconnections with six

l2

l3

l4

15

neighboring control areas at voltages of 69 kV or higher. According to the North

American Electric Reliability Corporation (NERC) 2007 Balancing Authority/

fransmission Operator Reliability Readiness Evaluation Report, ATSI has four tie

lines that interconnect with neighboring control areas at 69 kV. On October 1.

2003, ATSI transferred functional control of its transmission facilities to Midwest

Ex. ATS-5 at 3.

Ex. S-4, Excerpt from NERC 2007 Balancing Authority/ Transmission Operator Reliability

Readiness Report. The full report is available online at htto:/Avww.nerc.corn/docs/rao/audits/FE BA-TOP Final Reoort.odf.~ ")

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 16: Buckeye Power

!I) l.!0))0')-5)UH r Iiac I'OP (U0OE t') 0 l. 1l ) rl/') /2012 I:54:25 I'

lluekeye Power, Iac.Docket No. KLII-54-1)112

Exhibit )Vo. 8-IPage 10 of 43

Independent 'I ransmission System Operator. Inc. (Midwest ISO), and on June I.

'0 I I, A I'SI exited Midwest ISO and became a member ot'JM.

.3 Q. I)Vhitt is "PJM"?

A. PJM is a l&cgional Transmission Organization (I&TO) which ensures the reliability

12

of the high-voltage electric power system serving 58 million people in all or parts

of Delaware, Illinois, Indiana, Kentucky, Maryland, Michigan, New Jersey, North

Carolina, Ohio, Pennsylvania, 'I'ennessee, Virginia, West Virginia and the District

ot Columbia. PJM coordinates and directs the operation of the transmission grid,

which includes 6,038 substations and 61,000 miles ot'ransmission lines;

administers a competitive wholesale electricity market; and plans regional

transmission expansion improvements to maintain grid reliability and relieve

congestion.'3

Q. How does ATSI currently classify its transmission system'?

14 A.

15

16

17

18

While PJM coordinates and directs the operation of several regions'ransmission

grid, ATSI does the actual operation and planning of its own transmission system.

Even prior to transfer of its transmission facilities to ATSI, FirstEnergy (ATSI's

parent company) classified its transmission facilities into two categories: the Bulk

Transmission System (BTS), which was comprised of transmission facilities that

Ex. S-4 at 2, aod Ex. S-3, PJM News Release

Ex. S-3 at 2.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 17: Buckeye Power

.'U120009-5tna FERC PDF u/notficiai) 0/9/2012 t:54:25 RN

Buckeye Power, Inc.l)ucket No. EL I I-54-UU2

I&'.xhihtt iVn.!I-IPage II of43

I operated at 345 kV and l38 kV, and the Area 'I'ransmission System (ATS), which

was comprised of transmission t'acilities that operated at 69 kV, 36 kV, 34.5 kV.

3 33 kV, nnd 23 kV.e

4 When FirstEnergy transferred its transmission t'neil ities to ATSI, it only

transferred its transmission facilities that were integrated and operated in a parallel

6 manner.'hose facilities were determined to be of 345 kV, l38 kV, and 69 kV

7 voltages. Although those facilities were integrated and operated in parallel, ATSI

8 continued to use the FirstEnergy classitication of BTS and ATS, with the only

9 difference being that the ATS is now comprised of 69 kV facilities only."

10 Thus, ATSI's transmission system is currently made up of BTS (138 and 345 kV)

facilities. and ATS (69 kV) facilities.

l2 Q.l3

What are the main similarities between the I38/345 kV BTS and the 69 kVATS?

l4 A. The main similarities between the 138/345 kV BTS and the 69 kV ATS are: (I)

I5

l6

both are used for the transfer of power from generation (500 MW of generation is

connected to the 69 kV ATS) to load centers or wholesale customers'elivery

000.Ex. BPI-3, Testimony of Carl Bridenbaugh —FERC Docket Nos. EC99-53-000 and ELUI-69-

Id. at 4: I I -I4.

/d. at 4:I I-I9.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 18: Buckeye Power

:!OL:!OR00-5!OR YRRC I'OF (I)ootficial) a/0220!2 4:54:25 PM

Buckeye Power, Inc.llocket No. KL I I-54-llll2

I".xhibit No. 8-IPage l2 of43

points and (2) they are both operated in a network manner with one another, and

are therefore responsive to facility outages in each other system.'"

Q.

5

6 A.

What is the main difference between the l38/345 kV BTS and the 69 kVATS?

'fhe main difference between the l38/345 kV BTS and the Ci9 kV A'I'S is that the

7 BTS is more responsive to the transfer of power between interconnected

transmission systems across ATSI's territory, than the ATS. 'owever, I note

that, as also indicated in the PJM White Paper, higher-voltage transmission is

10 usually more responsive to transfers of power between transmission regions, as

ll

12

"transmission at 345 kV and above is generally used to move large amounts of

power over long distances," while transmission at 230 kV and below "is intended

13 to serve localized needs." Thus, not only the 69 kV ATS, but also the 138 kV

14 portion of the 138/345 kV BTS have little network response to large transfers of

15 power across ATSI'sregion.'6

Q. Are ATSPs 69 kV ATS and I38/345 kV BTS integrated, and operated17 parallel to each other?

18 A. Yes. All parties in this proceeding agree that the 69 kV ATS and the 138/345 kV

Ex. BPI-3 at 5:5-17.

I 0(d

12Ex. S-2 at 2.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 19: Buckeye Power

.!012I)si)5-5108 i E)3C PDP )Unofficial) 3)/')i 2012 ii54:25 vtt

Buckeye Power, Ine.Iyocket No. KLI I-54-002

Kxhihit No. 8-II'age l3 of 43

I3TS are integrated. For example, Buckeye's witness Bethel states in his

testimony that: "'ATSI's transmission system consists of more than 7.000 circuit

miles of 345 kV, 138 kV, and 69 kV transmission lines that are operated as a

single network."''fSI's witness Morrison, acknowledges that the 69 kV ATS is

integrated with the higher voltage facilities." Similarly AMP/CPP witness

lieising does not challenge the proposition that ATSI's 69 kV facilities are

integrated with the rest of the ATSl transmissionsystem.'O

According to FirstEnergy's description ol'ts transmission system in its 2001 tiling

with the Securities and Exchange Commission (SEC), the 69 kV ATS and the

138/345 kV BTS are integrated and operate in parallel to each other:

lll2l314I5

The primary function ot'he Transmission System is to integrate thegeneration resources of the FirstEnergy Companies with their nativeretail and wholesale loads. To perform this network function, theBulk Transmission System and the Area Transmission System areintegrated and operate in a parallel manner to each

other.'6

Ex. BPI-I at IO:20 —I I:I-3.

E». ATS-5 at 6:I-2.

E». AC-I at I I:S-IS.

16 Ex. S-6, Excerpts from FirstEnergy's filing with the Security and Exchange Commission. Thefull report can be found online at: htto://www.secinfo.corn/dvf4f.sig9a.htm.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 20: Buckeye Power

xu (2(la()3-51((R l ERC poF (((not Eicial ) S/3/ l012 4:5'l: 25 Ptt

Buckeye Power, Inc.l)ocket No. FLI I-54-I)I)2

Fxbibit No. S-IPage 14 of 43

I Q. Is there any generation interconnected at the 69 kV ATS?

2 A. Ycs. As I previously indicated, thcrc is more than 500 MW of generation

interconnected to ATSI's 69 kV ATS.'

Q. Please describe Buckeye.

5 A. Buckeye is a generation and transmission cooperative that produces, procures, and

6 provides the electric capacity and energy required by its 25 member electric

7 distribution cooperatives operating in Ohio. Buckeye and all of its member

8 distribution cooperatives are transmission dependent electric utilities. Buckeye is

9 a Network Integration Transmission Service (NITS) customer in the ATSI zone of

IO PJM, and purchases transmission service from PJM to deliver electricity to its

II members in the ATSI zone at delivery points operating at voltages of 138 kV or

12 lower. According to Buckeye's witness Sachdeva, Buckeye has six delivery points

13 connected to ATSI's 138 kV transmission facilities, and 36 delivery points

14 connected to ATSI's 69 kV transmission facilities. Buckeye and its members that

15 take delivery at 69 kV delivery points and pay two transmission rates: (I) the tirst

16 rate reflects the roiled-in cost of ATSI 138/345 kV BTS facilities; and (2) the

17 second rate retlects the rolled-in cost of ATSI's 69 kV ATS facilities.

18 Q. Mr. Maceo, please discuss your understanding of ATSI's voltage19 differentiated rates.

(7See ATSI circuit diagrams included as attachment to Buckeye's witness Sachdeva testimony as

Exhibit No. BPI-20 (PROTECTED).

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 21: Buckeye Power

20120S09-5108 i ERC PDP (Unofficial) «/9/2012 4:54:25 Pia

I

llockeye Power, Inc.l)ocket No. KL I I-54-IIIIZ

Kxhil&it No. S-IPage IS of 43

I A. ATSI employs a dual voltage rolled-in rate design for its transmission customers.

IO

12

l3

l4

l6

l7

IJnder this rate structure. two rolled in rates are established. One rate, the 138 kV

and above rate, recovers costs associated with ATSI's 138/345 kV BTS and is

charged to all transmission customers in the A fSI zone. 'fhe second rate, the 69

kV rate, recovers costs associated with ATSI's 69 kV ATS. Transmission

customers with delivery points at 69 kV pay this rate, in addition to the rate for the

138/345 kv BTS.

Pursuant to ATSI's voltage differentiated rate design, PJM currently charges

$9,906.26/MW-year to every transmission customer (connected at all voltage

levels, i.e., 69 kV, 138 kV, and 345 kV) for its total load on the BTS at the time of

the ATSI annual Network Service Peak Load (NSPL), and an additional

$13,177.10/MW-year for load identified by ATSI as being served on the ATS for

connections to or through 69 kV facilities at the time of the annual NSPL. For

example, a customer that takes service at 138 kV would pay $9,906.26/MW-year

for its annual NSPL total load, whereas a customer that takes service at 69 kV

would pay $23,083.36/MW-year ($9,906.26 + $ 13,177.10)for its annual NSPL

total load, which is more than twice what the 138 kV customer would pay."

Ex. BPI-I at 5-6.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 22: Buckeye Power

'Ill 'OHOO-5l08 FFRC ROF (Unof f icinl 1 a/0/!0 !2 I:54 I.!5 Rtt

Ihtckeye Power, Ine.l)ocket No. EL I I-54-002

I".shibit No.!I-IPage 16 of 43

I About 90% of Buckeye's load is charged both ot'TSI's transmission rates, and,

as a result. ATSI's charges to 13uckeye for the year ended May 31, 2012 will

3 average $21,793/MW- Year.'

Q. When were the dual voltage rates established?

5 A. 'I'he dual voltage rates were established for ATSI's transmission system in 1997

6 Iollowing approval of the FirstEnergy Merger. With the approval of the

7 FirstFnergy Merger, a dual voltage design was integrated into the FirstEnergy

8 OA'IT. This rate structure was later transferred over to ATSI's OATT and to the

9 iVIidwest ISO Tarily when ATSI became a member of Midwest ISO. The current

IO dual voltage rate structure was established in Docket No. ER 05-285-000, which

was the proceeding that established the initial formula rate for ATSI under the

12 Midwest ISO tariff. By order issued on May 31, 2005, the Commission approved

13 a settlement that provided, among other things, for the continued use of dual

14 voltage rolled in rate design for customers taking transmission service to serve

15 loads in the ATSI zone.'"

16 Q. Has the transmission system changed from an operational and functional17 standpoint since the dual-voltage rate was introduced in l997?18

19 Es. BPW at 6-7.

20Midwest Independent Transmission System Operator, Inc. and FirstEnergy Service Company,

I I I FERC ti 61,30I (2005).

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 23: Buckeye Power

?01 20000-5108 Faac FOF (rtaof floiol 1 0/0/201 ':54:25 Ftt

Ih&ckcyc Power, inc.l)acket No. KL l l-54-002

Kxhihit No. S-IPage l7 of 43

I A. Ycs. In l997, FirstEncrgy's A'I'S included, in addition to the 69 kV facilities,

lower voltage lacilities of 36 kV, 34.5 kV, 33 kV, and 23 k V facilities (which are

3 generally isolated, and in a radial conltguration). FirstEnergy tound that these

4 lower voltage l'acilities -do not play a signiltcant role in the transt'cr of power on

the system." 'herefore, it is likely that in 1997, when the dual-voltage rates

6 were first introduced, the 23/33/34.5/36 /69 kV ATS was not fully integrated with

7 the l38/345 kV BTS (because it included the 36 kV, 34.5 kV, 33 kV, and 23 k V

8 lower-voltage facilities).

l2

l3

l4

I6

Subsequently, in l999, FirstEnergy updated its lunctional classification of its

transmission system, when it performed several analyses to identify which

facilities were in fact serving a transmission function, in order to transfer those to

ATSL lt appears that in I 999, FirstEnergy analyzed for the first time its

transmission facilities based on the Commission's Seven Factor Test for

distinguishing transmission from local distribution. Based on that analysis,

FirstEnergy identified and transferred to ATSI all transmission facilities that

served a transmission function. All facilities that served a distribution function

Ex. BPI-3 at 4:l7-lg.

22Protnoting IVholesale Competition through Open Access Non-Discriminatory Transmission

Services by Pnhiic Utiiities, Order No. 888.

Ex. BPI-3 at 10:IU-I2.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 24: Buckeye Power

..'0l20809-8108 PFRC PDP (Unoeficiai) 8/9/20i2 i:54:25 Pa

t)nckeye Power, Inc.Docket No. EL1 1-54-lN)2

Exhibit No. S-tPage 18 of 43

which were classitied as local distribution remained with First Energy Operating

Company (FEOC).

'fhcrefore, in 1999, FirstEnergy changed the tunctional classification of its ATS

and determined that the transmission system transferred to ATSI was comprised of

69 kV ATS and l38/345 kV BTS facilities which were integrated and operated in

a parallel manner. However, despite the fact that ATSI's transmission system is

now fully integrated, ATSI has continued to use the pre-1999 dual-voltage rate

design.

9 Q.10

lr A.

13

14

IS

16

17

18

19

20

Did ATSI propose the elimination of the dual voltage rate in its formula ratefiling in Docket No. ER05-285-000?

Yes. Contrary to their current testimony, in 2004, ATSI proposed to adopt a

single, 100% rolled-in transmission rate that makes no "distinction between

service provided over different transmission voltage facilities." As shown in its

EROS-285-000 filing, where the Midwest ISO and FirstEnergy jointly filed for a

formula rate for ATSI under the Midwest ISO Tariff, ATSI proposed to eliminate

its voltage differentiated rates from its transmission rates and to replace it with a

single, uniform transmission rate across the entire ATSI zone. In its transmittal

!etter, ATSI stated that by adopting a single, rolled-in rate, ATSI's customers "will

benefit from a more transparent and uniform rate design than is currently in

Ex. BPt-3 at 11:14-16.

See Ex. S-S, Excerpt from ATS1's December 2, 2004 filing in Docket No. ER05-285-000.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 25: Buckeye Power

!&)i"0809-'&Los !)sac aur (unoffici~l) sl')I'.&012 4:s)&25 t&t&

Ilackeye Power, Inc.l)acket Nn. KL I I-54-IIII2

I?xhlhlt Nn. S-IPage I9 of 43

&0

place." ATSI asserted that the existing dual-voltage rate design "made sense in

the cra when transmission customers contended with balkanized transmission

systems. I-lowever, today, all transmission customers receive the same quality of

service ...regardless of whether the load is situated on a 69 kV, 138 kV, or 345

kV facility." ATSI also noted that another benettt to adopting a rolled-in rate

was "reduction in the cost and complexity of administering ATSI's rate that is

unique within the Midwest ISO. A'CSI is the only transmission asset owner in the

Midwest ISO that has a voltage differentiated rate in effect, and the instant hling

will eliminate the need to maintain special billing and settlements processes to

accommodate this feature." ATSI further stated that:

Il121314

151617IS

19

[T]he change to Attachment 0 will increase transparency in the costof transmission service, align the derivation of transmission chargeswithin the ATSI zone more closely with the other Midwest ISOzones, and simplify billing and settlement processes. For theforegoing reasons, FirstEnergy and the Midwest ISO propose toeliminate the voltage-differentiated charges in the Tariff.

Ultimately, however, that proceeding was resolved by a settlement that retained

the current dual voltage rate design.

Ex. S-5 at 4.

21 Ex. S-5 at 5.

sgEx. S-5 at 5.

29 Ex. S-5 at 5.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 26: Buckeye Power

la I .'Once-Sins &2HRC FDF ii/nof f iciol) u19/2&)12 2&: S4 225 i'lt

Iiuckeye P&&ver, Ine.Docket &s(o. KL I 1-54-002

Exhil&it No. S-lPnge 20 ol'43

I As discussed above, at this time, ATSI was the only transmission owner in the

ibtidwest ISO's tootprint that used a voltage-differentiated mte design. Similarly

3 in PJM, Al SI again appears to be the only transmission owner that uses a dual-

voltage rate design.'"

5 (2. lies Buckeye been paying voltage-differentiated rates for its wholesale6 transmission service since the l997 approval of the FirstEnergy Merger'7

8 A. No. According to Buckeye's response to AMP/CPP discovery, from January I,

9 l 968 through June 30, 2003, Buckeye received transmission service I'rom six

10 interconnected transmission-owning utilities pursuant to a Power Delivery

II

21 12

Agreement (PDA). 'uring the 35 year term of the PDA, Buckeye paid a single

contract rate administered by Ohio Power. Starting July I, 2003, Buckeye entered

13 separate transmission contracts with its providers of transmission service (ATSI

14 being one of them), their holding companies, or their RTO/ISO operators. Thus,

15 Buckeye started paying voltage differentiated rates under ATSI's transmission

16

17 Q.Ig

service contract starting July I, 2003,

Did Buckeye participate in Docket No. ER05-285-000?

30See Ex. S-7, Excerpt from PJM OATT.

3& Ex. AC-18, AMP/CPP-BP1-1.4 at 1-4. The six utilities were: The Cincinnati Gas & ElectricCompany (CG&E); Columbus and Southern Ohio Electric Company (CSO); The Dayton Power andLight Company (DP&L); Monongahela Power Company (Monongahela); Ohio Power Company (OhioPower); and The Toledo Edison Company (TEC).

Ex. AC-18, AlvlP/CPP-BPI-I.4 at 1-4.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 27: Buckeye Power

'. ) i Xiaua —Slaa FSRC PDF (Unof ficta i) 4/niaala i:54:38 ai'i

l)uckeye Power, Iuc.l)ocket No. EL I I-54-l)02

I?shihit No. S-IPage 21 of 43

l A. No. Buckeye states that although it was concerned about ATSI's voltage

differentiated rate design, 13uckeye expressed that concern only informally on a

number of occasions afier July I. 2003.'uckeye states that at the time of the

4 proceeding in Docket No. ER05-285-000, it was 'was preoccupied with other

matters," and therefore did not submit an intervention."

6 However, Buckeye submitted a protest in Docket No. ER11-2814-000, et al.,

7 where PJM and ATSI jointly proposed to modify the PJM OATT to integrate

8 ATSI into PJM. In that proceeding, Buckeye protested ATSI's proposal to retain

9 the dual-voltage rate design. In its order on the proposed modifications. the

10

12

l3

Commission found that the issue of voltage differentiated rates was beyond the

scope of that proceeding and indicated to Buckeye that, should they wish to pursue

the matter further, they should do so by filing a complaint." On July 18, 2011,

Buckeye tiled a complaint alleging that ATSI's voltage diITerentiated rates were

14 unjust, unreasonable and unduly discriminatory which began the instant

15 proceeding.

Ex. AC-)8, AMP/CPP-BPI-1.4 at 3-4.ie

id.

PJMInierconnection, LLC., 135 FERC I 6),l98 (20) 1)

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 28: Buckeye Power

u) L'! t)sn9-'& u)s vaar voF ulnot ticioil s/9/ 'ots 4:54:ss oiti

llockeye Power, loc.l)ockot No. KL1 1-54-llll2

Exhibit Nn. 8-IPage 22 of 43

I IIL ANALYSIS OF ATSI'S VOLTAC E-DIFFERENTIATED RATES

Q3

4 A.

WVhat is your opinion of ATSI's existing rate design?

Based on my analysis, I believe A'1'Sl's existing voltage-differentiated rate design

5 is unreasonable.

6 Q. liow did you form that opinion'&

7 A. 1 considered the following factors:

IO

12

13

14

15

16

~ Whether ATSI's 69 kV ATS is integrated and operates in parallel with its

138/345 kv BTS.

~ Whether the 69 kV ATS provides, or has the capacity to provide benefits

and support to the 138/345 kV BTS.

~ Whether the difference in rates paid by customers served from the 69 kV

ATS and 138/345 kV BTS is justified.

~ Whether transmission customers taking service at 69 kV are similarly

situated to customers taking service at 138 kV.

~ Whether Commission policy supports the roll-in of transmission costs for

ATSI's ATS and BTS facilities.

18

70

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 29: Buckeye Power

201 'US09-5108 FRRC UDF (Uoofficiol) S/9/2012 4:94:25 Ftt

lluckeye I'ower, Iue.l)oeket No. EL I I-54-002

Kshihit No. S-IPage 23 of43

FIVE FACTORS FOR ROLLED-IN RATES

Whether ATSI's 69 kV ATS is intearated and onerated in narallel with its13II/345 kV BTS.

Q. Is ATSI's 69 kV ATS integrated and operated in parallel with its BTS?

6 A. Yes. As I noted earlier in my testimony, all parties in this proceeding agree that

ATSI's 69 kV ATS is integrated with the 138/345 kV BTS. My own examination

of the ATSI's One Line Diagrams, provided as Exhibit Nos. ATS-6, ATS-7, BPI-

19 (PROTECTED), and BPI-20 (PROTECTED),

10

13

15

16

17

18

19

20

22 Q. Does the 69 kV ATS satisfy the AIansfield Integration Test?

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 30: Buckeye Power

Cii icosi)9-5108 I&RRC PDP (UooEEicial 1 8/9/2012 1:'54 &25 PM

Itackcyc Pov/cr, Inc.I)ockct No. EEI I-54-002

Exhibit No. S-IPage 24 of 43

I A. Yes. I'e 69 kV ATS meets all ot the Manstield integration t'actors set forth in

Mansfield Municipal Electric Department, et aL v. /Yew England Power Company,

3 ')4 FERC $ 63,023 (200 l ).

4 Q. Please discuss the iVlansficld integration factors.

5 A. ln Mansfield, the Presiding Judge agreed, and the Commission oflirmed, a tive-

factor test to determine whether a facility is integrated with the rest of the

transmission system. That test has since been known as the "Manstield Test."

The Manstield Test looks at the following five factors:

0)

10

II

I2

I3

I4

15

l6

17

IS

l. Whether the facilities are radial, or whether they loop back into the

transmission system;

2. Whether power tlows only in one direction, from the transmission system

to the customer over the facilities, or in both directions, from the

transmission system to the customer, and from the customer to the

transmission system;

3. Whether the transmission provider is able to provide transmission service to

itself or other transmission customers over the facilities in question;

4. Whether the facilities provide benefits to the transmission grid in terms of

capability or reliability, and whether the facilities can be relied on for

Op. No. 454, 97 FERC $ 6(, (34 (200 I ), reh'g denied, Op. No. 454A, 98 FERC $ 6I,I I5 (2002).

.it//nsfietd, 94 FERC $ 63,023 (200 I), at p. 65, I 70.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 31: Buckeye Power

'!))12VVV')-5)08 i'SRO PDF (unoiticial) ')/')/2012 4:54:25 PM

Iluckeye Power, Iac.l)ocket No. F.L1 I-54-tl()2

Fxhibit iVo. S-IPage 25 of 43

coordinated operation of the grid; and

5. Whether an outage on the Iacilities would at'I'ect the transmission system.

3 g. Under the Mansfield Test, is the 69 kV ATS integrated with the 138/345 kV4 BTS2

5 A. Ycs, the 69 kV ATS is integrated with the 138/345 kV BTS for the following

reasons:

l. As I explained above, the vast majority of the ATSI's 69 kV, 138 kV, and 345

kV transmission lines are looped facilities, not radial lines. Thus, the 69 kV ATS

satistles this tirst factor.

ID

Il

2. Power tlows in two directions, from the 138 kV BTS to the 69 kV ATS and

from the 69 kV ATS to the 138 kV BTS.

l2

13

14

15

16

17

18 Thus, the 69 kV

Ex. BPI-3 at I I:17-19.

Ex. S-8 at 2-7.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 32: Buckeye Power

!0120805-5108 eeec DDP (Unofficial) 8/5/2012 1:54:25 PM

13uckeye Power, Inc.I)acket No. EL11-54-i)II2

I?xhihit No. S-lPage 26 of 43

ATS satislies this second factor.

3. ATSl can, and does provide transmission service to itselt and also to other

transmission customers, such as AMP. and other customers serving retail load in

Ohio Edison, Penn Power. and Toledo Edison over the 69 kV ATS. Therefore, the

69 kV ATS satisfy this third factor as well.

12

13

4. The 69 kV ATS facilities provide clear benelits to the 138/345 kU BTS, as they

and therefore can serve as a

back-up to that system. Also, the 69 kV ATS facilities are included in PJM's

Regional Transmission Expansion Planning (RTEP), and Energy Management

System (EMS) Model which is used for reliability evaluations and for congestion

management analysis." Thus, the 69 kV facilities are being relied upon for

reliability and, to a certain extent, for coordinated operation of the grid.

Consequently, the 69 kV ATS satisfies this fourth factor.

l4

15

l6

5. An outage on the 69 kV ATS would definitely alfect the 138/345 kV BTS, as

the 69 kV facilities are operated in a network, or looped fashion, with the 138 kV

and 345 kV facilities. An outage on one of the looped 69 kV facilities would

create a change in power flow over the networked 138 kV or 345 kV facilities.

iaSee Ex. S-9 for an excernt from PJM Manual 148: PJM Region Transmission Planning

Process, and Ex. AC-23 and AC-24 for a list of ATSI 69 kV facilities modeled by PJM in its RTEP and

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 33: Buckeye Power

'Oicusuo-51iis RERC RDI: (Uuofficiali S/9/2012 I:54i25 PM

Iluckeye Power, inc.l)acket iXu. F L I I-64-Ot)2

gxhihit No. 8-IPape 27 uf 43

Accordingly, this BIIh and linal I'actor is also satisfied by the 69 kV A' S.

2 Q. lies ATSI performed any power tlow studies that demonstrate the integrationand the parallel nature of its 69 kV ATS with its l38/345 kV BTS?

45 A. Yes. 'fhe testimony of lvir. Bridcnbaugh, FirstEnergy director ol transmission

6 planning and protection which was submitted to the Public Utilities Commission

7 ot'Ohio in 2000, provided by Buckeye witness Bethel in Exhibit BPI-4, includes a

II power liow analysis that "demonstrates the network or parallel nature of the 69 kV

system across the entire FirstEnergy fransmission System." 'hat analysis uses

IO power tlow models ol the ATSI system tor the 2000 summer peak load conditions,

and shows the extent to which ATSI facilities support deliveries to loads

connected at different voltages."

l3 This study is signilicant as both ATSI and Buckeye agree that ATSI's

l4 transmission system has not significantly changed since the 2000 analysis, and

IS hence the results of that analysis remain valid."

l6 Q. Please explain your understanding of how Mr. Bridenbaugh's analysis was

l7 performed and the conclusions of that analysis.

Fx. BPI-4 at 23:4-5.

Ex. ATS-5 at 7:12-22.

Ex. ATS-5 at I I:IO-I4.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 34: Buckeye Power

00!.0)007—5108 FERO FDF (!)nof ficin)) R/0/.?0 Ls 0:54: '5 !')t

llaekeye Power, lac.13oeket No. EL 1 1-84-1102

Exhibit )Vn. S-lI'age 28 of 43

I A. Ivfr. 13ridenbaugh's analysis is based on his Transmission Participation Factor

ITPF), which determines the extent to which particular transmission facilitics

support a given power transfer. 'I he analysis comprises two studies; the l)rst study

measured the impact of power transt'ers between each ot'he six control areas

directly interconnected to FirstEnergy on its 34S kV, 138 kV. 69 kV. 33-36 kV,

and 23 kV facilities, as illustrated in fable I, which is shown below:

'fable 1:Transmission Participation Factor (TPF)

for power transfers between control areas bordering ATSI

FirstEnergy Voltage Class Net Area to Area Absolute Value of lns andOuts

345 kv138 kv69 kv33-36 kv73 kv

36.00%6.64%0.24%0.00%0.01%

46.95%12.20%1.76%0.14%0 13%

10II12

13

14

The second study was performed to determine the impact of power transfers from

generation internal to the FirstEnergy system or imported from neighboring

systems to load within the FirstEnergy control area at different voltage levels.

Table 2, shown below, illustrates the results of the second study.

16

17

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 35: Buckeye Power

cu 1 'OSLL9-'i LOB raao PDF (Unct E Lci i1) S/SE2012 L: 'i 1: ."i L'a

1)uckeye Puwcr, lac.l)ocket No. EL l l-54-002

Kidiihit No. 8-IPage 29 uf 43

Table 2:Transmission Participation Factor (TPF)

for power transfers from generation to loads within ATSl

345 kvI38 kv69 kV33-36 kv23 kv

76 38%76.55%

'8%

0 00ut

0.03%

FirstEnergy Voltage Class Net Area to Area Absolute Value ol lns andOuts89.78%85 97%6.52%0.38%0.25%

5 Q. What is your interpretation of the results of the first study performed by Mr.Ci Bridenbaugh as illustrated in Table l?78 A. Table I shows each voltage level power )low participation for transfer of power

9 through the FirstEnergy transmission system. fn other words, Table I illustrates

10 the question: "For a power transfer between two control areas bordering ATSI,

12

13

15

16

17

18

how much power tlows through each of ATSI's voltage classes?" For example,

looking at the "Absolute Value of lns and Outs" column, for a transfer of power

between two control areas interconnected to FirstEnergy, the 345 kV transmission

system demonstrates a significant TPF of 46.95%, the l38 kV transmission system

demonstrates a lower TPF of 12.20%, and the 69 kV transmission system

demonstrates a TPF of 1.76%.

The significant TPF of the 345 kV transmission facilities validates its high

participation in movement of bulk power across control areas, in comparison to a

lower participation in movement of large amounts of power with the decrease in

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 36: Buckeye Power

!'l l 'aaus-StUR rERC por (Unor Etc tall H/9/2012 4:54:25 au

Iksckeye Power, Inc.l)ockct i%n. KLI I-54-IIIIZ

Exhibit iso. S-II'age 30 of 43

voltage. The main reason for this result is that a 345 kV line has more than twice

lhe capacity of a 138 kV line, and therefore it can carry more than twice the

amount of power that a 138 kV line can carry, and a 138 kV line has more than

twice the capacity of a 69 kV line, and therefore it can carry more than twice the

amount of power that a 69 kV line can carry.

6 Q.7

What is your interpretation of the results of the second study performed byMr. Bridenbaugh as illustrated in Table 2?

8 A. The results in Table 2 illustrate the question: -For deliveries to loads connected to

10

12

13

14

a voltage class, what portion of that energy is carried by parallel lines. on facilities

in another voltage class?" For example, using again the absolute value method,

(he 345 kV facilities provide 89.78%of the flows to loads connected at 138 kV

and 69 kV, the 138 kV facilities provide 85.97%of the flows to loads connected at

69 kV, and the 69 kV facilities provide 6.52% of the flows to loads connected at

138 kV. According to Mr. Bridenbaugh, the response of the targeted voltage was

15 excluded from the average response calculation. For example, the response of the

16

17

l8

138 kV system was not considered for transfer of load directly connected at 138

kV, as that response would necessarily be high and not an indication of general

network response."

19 Q.20

Do the power flow results presented in Table I support ATSI's use of its dual-voltage transmission rate?

Ex. BPI-4 at 24:2-6.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 37: Buckeye Power

20i20809-510ii rERC pDF (Unofficinll 0/9/2012 4:54:25 0N

tluckeye Power, Inc.l)ocket No. EL I 1-54-1102

Exhibit No. S-IPage 3I of 43

I

A.

10

No. The TFP results presented in Table 1 simply illustrate the law of physics that

transfer of power follows the path of least impedance, and since higher-voltage

lacilities are of lower impedance than lower-voltage facilities, the higher-voltage

1'acilities would have a signilicantly higher TPF. Also, the 'I'PF results in Table I

show that the demarcation between voitages could very reasonably be set between

the 345 kV and 138 kV, as the TPF of the 345 kV facilities (46.95 percent) is

almost four times larger than that of the 138 kV lacilities (12.20 percent).

I also note that the results for the 69 kV facilities did not show zero participation

in movement of bulk power across control areas, but 1.76 percent, which shows

some support, in the movement of buik power (which according to the PIM White

12

13

14

15

16

17

18

Paper is typical of mainly 345 kV and above facilities). The fact that the 69 kV

ATS exhibits 1.76percent support confirms that the 69 kV ATS contributes in the

movement of bulk power across ATSI's transmission system.

Mr. Bridenbaugh confirms this in his testimony stating: "However, while the

participation of the 69 kY facilities is less than for the Bulk facilities, it is still

significant and demonstrates the network or parallel nature of the 69 kV system

across the entire FirstEnergy Transmission System.""

19 Q.2021

Do the power flow results presented in Table 2 support ATSI's use of its dual-voltage transmission rate?

Ex. BPI-4 at 23:2-5.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 38: Buckeye Power

Ct)120800-5108 I ERC PDP IUnoificiat) 8/9/2012 4:54:25 PM

llackcye Power, lnc.1)ockct No. KLI I-54-lit)2

Fxhihit No. S-lPage32 of 43

1 A. No. Dhe FFP results presented in'I'able 2 illustrate that 6.52 percent of the power

that tlows to the 138 kV loads, llows through the 69 kV system during normal

power system operation (and that percentage could be even higher during

emergency conditions, as the 69 k V can be used as a back-up to the 138 kV

system). I consider this to be an important amount of power tlowing through the

6)9 kV system, not from a magnitude perspective, but from the fact that the 6.52

percent power tlow benetits strictly loads served at 138 kV. Nonetheless, under

the dual-voltage rate design, customers served over the 138 kV lines pay nothing

towards the recovery of costs for 69 kV tacilities.

1 p Q. What is your conclusion regarding this ilrst factor?

11 A. Based on the fact that ATSI's 69 kV ATS is integrated and operates in parallel

12

13

14

with its 138/345 kV BTS, a single rolled-in transmission rate covering all ATSI's

integrated transmission facilities would be more appropriate to use than the

existing dual-voltage transmission rate.

15

16

1718 Q.19')p

2I A.

73

Whether the 69 kV ATS orovides. or has the canacitv to nrovide benefits andsunnort to the 138/345 kV BTS.

Does the 69 kV ATS provide, or has the capacity to provide benefits andsupport to the I38/345 kV BTS?

Yes. As I mentioned earlier in my testimony, the 69 kV ATS operates in parallel

with the 138/345 kV BTS. This means that during emergency conditions on the

138/345 kV BTS, the 69 kV ATS can operate as a back-up, or can be relied upon

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 39: Buckeye Power

.'vl:!Oa(3'i-Sids MERC (0DF (Unoiticial) a!s!'012 S:54125 i'M

iiackeye Power, Ioc.Docket No. KL I 1-54-01)2

Fxhihit No. S0-1

Page 33 of 43

to relieve overloads on the higher-voltage system.

10

which constitutes a major benetit to the BTS

and demonstrates that the 69 kV A fS supports the 138/345 kV BTS.""

Furthermore, ATSI witness Morrison agrees that the 69 kV facilities support the

138/345 kV BTS.Mr. Morrison states:

li12

13

1415

161718

192O

21

72

I lowever, ATSI agrees that the 69 kV Area Transmission System isintegrated with the higher voltage facilities. This is one of theconclusions of an analysis that is discussed in the testimony of Mr.Bridenbaugh, which Buckeye has submitted as Exhibit No. BPI-4.This analysis demonstrates that the 69 kV Area TransmissionSystem otTered a degree of support for power llows on the highervoltage system sufficient to show that the 69 kV facilities wereintegrated with the Bulk Transmission System."

Mr. Bridenbaugh further states that, "This additional power flow analysis also

demonstrates the signilicant network response of the Area Transmission System to

supply of load in the FirstEnergy transmission system.""

See ATSi's response to Staff discovery, Ex. S-8 at 2-7.

Ex. ATS-5 at fn1-7

Ex. BPI-4 at 24:9-10.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 40: Buckeye Power

.")) 0809-9 )os FERC PDF (()noir ioiol) 0/9/?012 i: 9 i:25 PM

Ilackcye Power, Inc.l)ockct No. FLI I-54-1)02

Kshihlt No. S-lPage 34 of 43

l.astly. the bcnelits provided by the 69 kY ATS may also be detined more broadly.

I'or example, if the 6.52 percent ot power tlow on the 69 kY ATS that is

attributable to loads served at I 38 kV were eliminated, then the l38/345 kY BTS

would have to accommodate this additional power tlow by constructing new high-

voltage facilities, which all transmission customers would have to pay for.

6 Q. What is your conclusion regarding this second factor?

7 A. Based on the lhct that ATSI's 69 kV A'I'S provides benefits and support to its

10

l2

l3

l38/345 kY BTS, it is unreasonable tbr ATSI to use a ditferentiated transmission

rate treatment in which its wholesale customers receiving transmission service at

the I 38/345 kV BTS level pay nothing for this additional service/benefit. The

appropriate and equitable rate treatment would be to use a single rolled-in

transmission rate recovering all ATSI's integrated transmission facilities, as these

facilities benefit to some degree all ATSI's transmission customers.

I4I5l6I7ISI920

21

22

23

)

Whether the difference in rates naid bv customers served from the 69 kVATS and 138/345 kV BTS is iustifiied.

Q. Is there justification for the difference in transmission rates paid bycustomers served from the 69 kV ATS and the 138/345 kV BTS?

A. No. In my opinion, there is no justification for the difference in rates paid by

customers served from the 69 kV ATS and the 138/345 kV BTS. The network

transmission rate paid by the BTS customers is twice the NITS transmission rate

paid by the ATS customers. There is simply no justification for this significant

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 41: Buckeye Power

"oi"osas-s&ias aFRC l&ot& ulnotficioi) a/9/zoi2 4:s4:ss au

Buckeye Power, Inc.l)ocket No. FL I I-54-ill)2

Fxhihlt Nro 8-II'age 35 of 43

dill'crcnce, as all ATSI's transmission customers receive the same quality

ot'ervice.

regardless of whether their load is situated on a 69 kV, I 38 kV, or 345 k V

lhcility. My opinion is shared by the hfidwest ISO and FirstEnergy in their tiling

in Docket No. ER05-285-000 with the Commission, where they jointly recognized

the lack of justilication I'or the continuing ATSI's voltage dilTerentiated rates,

stating:

789

lolll2l3

Under the existing voltage differentiated rates, suppliers in the ATSIzone pay different transmission charges to serve the same amount ofload based on the voltage of facilities utilized. This distinction madesense in the era when transmission customers contended withbalkanized transmission systems. However, today, all transmissioncustomers receive the same quality of service from the Midwest ISO,across the entire Midwest ISO footprint, regardless of whether theload is situated on a 69 kV, 138 kV or 345 kV facility.

I 5 Q.l6l718 A.

19

2l

22

23

24

What is ATS1's main argument now in this proceeding for changing itsposition and supporting the existing dual-voltage rate treatment?

In this proceeding, ATSI's main argument for supporting the dual-voltage rate

treatment is that transmission customers derive different levels of benefits from

ATSI's 69 kV ATS, and 138 kV BTS. For example, ATSI's witness Ziegler

argues that "certain transmission customers (such as Cleveland Public Power)

serve their load entirely through voltages of 138 kV and above; others (including

Buckeye) serve their load predominantly using the 69 kV system...while all of

these customers are receiving network transmission service from PJM for

49 Ex. S-Sat4.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 42: Buckeye Power

00100809-5108 l ERC PDR (Unof f icia1 1 8/0/ "0la /1: 54:25 RM

Buckeye Power, Ioc.l)ocket No. EL I I-54-tlt)2

Exhibit No. 8-1I'age 36 of 43

10

deliveries to load in the ATSI's pricing zone, they are using and benetiting from

ATSI's transmission t'acilitics in different voltage classes in very different

ways...ihe 69 kV transmission facilities provide only limited support for power

transfers to loads connected at higher voltages."'r. Ziegler t'urther concludes

that -some wholesale customers rely signilicantly on the 69 kV transmission

I'acilities to serve loads from those I'acilities, while other customers place much

less reliance on those facilities""

I disagree with Mr. Ziegler. First, as I mentioned earlier in my testimony,

transmission lines can carry different amounts of power liow, based on their

voltage. A 138 kV line can carry at least twice as much power as a 69 kV line.

For example, Exhibit No. BPI-I9, shows

12

13

15

16

17

18

Ex. ATS-1 at 11:10-20.

Ex. ATS-1 at 12:1-3.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 43: Buckeye Power

20120800-5 108 FFRC FDF (Unofficial) 8/9/2012 4:54:25 FN

lluckcyc Power, lac.1)ockct No. KL I I-54-lll)2

Exhibit No. S-IPage 37 of 43

In my

10

II

12

13

14

opinion, the customers served in the Cleveland area by the l38 kY 13TS derive the

same degree of benetit from ATSI's transmission system as customers located in

more rural areas of ATSI's territory with lesser load density, which ATSI can

serve more economically by a 69 kV transmission line.'n other words, ATSI has

chosen routes for its l38 kV and 69 kV so as to minimize its overall costs to

provide firm power and energy to all of its customers.'" More densely-situated

customers, such those trom urban areas, would be served more economically by

higher-voltage, 138 kV transmission lines. Customers situated in less-dense rural

areas would be more economically served by lower voltage, 69 kV transmission

lines, which are less expensive to construct and maintain than the higher-voltage

transmission networks. In my opinion, both the urban and the rural customers

derive the same benefit from the integrated transmission system, and there is no

justification to charge those customers voltage differentiated transmission rates.

15

16Whether transmission customers takina service at 69 kV are similarlvsituated to customers takina service at 138 kV and above.

17 Q. Are the transmission customers taking service at 69 kV similarly-situated tocustomers taking service at 138 kV and above?

Ex. BPI-18 at 13-14.

See Ex. BPI-S.

See Ex. ATS-I at 21:21-23.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 44: Buckeye Power

! 2') 1"l)809-5108 PERC PDF (Unoif icial) 8/9/2012 1:54:25 Ple

l3ockeye Power, lnc.Docket No. KL l I-54-1102

Kzhlhit No. 8-IPage 38 of 43

I A. Ycs, I believe they are. Customers situated in highly-dense urban areas who toke

2 service t'rom l38 k V Iacilities receive the same quality of transmission service that

3 customers situated in less-dense, rural areas receive Irom 69 k V facilities. In other

4 words, both types of customers are similarly situated, although they receive

5 transmission service at diITcrent voltages. At one point in time, both urban and

6 rural loads were adequately served by 69 kY facilities. However, because of the

7 high load increase in urban areas, it became more economical. and also made

8 engineering sense tor ATSI to replace the 69 kV facilities with l38 kV facilities,

12

l3

l4

l5

l6

which can carry more load. Could ATSI continue to serve its urban customers

trom 69 kV lines'? Certainly. However, it would have to use two or more 69 kV

lines to serve the same load served by a single l38 kV line. In an urban setting,

this may not be achievable, due to land constraints. Mr. Sachdeva's testimony

confirms this fact, pointing out that the Cleveland area has underground 69 kV

facilities that are no longer in service." ATSI's customers served from the 69 kV

facilities pay more than twice for network transmission service than their urban

counterpart, at 138 kV, even though they are similarly situated.

l7

Ex. BPl-la at 14.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 45: Buckeye Power

20)zt)ROS-5108 FERC PDF (unottininl) Si')/2012 ):64:25 PM

Ilockeye Power, Inc.Docket No. KLI I-54-002

Exhibit I))n. S-IPage 40 of43

I

7

3

4

5

67

8()

10II17

13

1415161718102071

2273

74

25

26

'I'wo other factors weighing in favor of rolled-in costing are theundisputed nature of the transmission system. and the fact that thelower voltage facilities appear to meet the technical delmition ofIacilities which serve a -transmission" Iunction. Where power linesoperate in an integrated manner to perform a transmission I'unction,

we think it unnecessary and inappropriate to try to segregate selectedlines and claim they do not benet)t the entire network of lines. Withan integrated transmission system such as hJtah's, it would almost beimpossible to trace individual lines and show that some of thoselines do not benetit others by providing general back up, maximizingcNciency and minimizing costs of the entire transmission network.

In cases where an integrated transmission system is involved, weadhered to the rolled in costing methodology absent specialcircumstances. The judge provides a well-reasoned analysis ofCommission precedent and the evidence in this particular case. Weagree with him that no special circumstances have been shown. Theinitial decision is aIT)rmed and adopted on the merits of the

issue.'ow

does the Commission policy favoring roll-in of integratedtransmission facilities affect your analysis in this case?

A. My engineering analysis is independent of my review of the Commission's

policy. However, it is my understanding that the Commission as a matter of

policy supports the roll-in of integrated transmission facility costs,

Accordingly, the Commission's policy corroborates my analysis.

2728')9

30

31

What are the conclusions and recommendations of your analysis?

Based on the tive factors discussed above, I conclude that ATSI's existing voltage

differentiated rate design methodology is unreasonable and unfair toward ATSI's

wholesale transmission customers served from delivery points at 69 kV.

Utah, 27 FERC at 61,258.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 46: Buckeye Power

in'nttnv-5108 FERC t'OF (Unof ficiott 8/9/?nis t:54:.!5 t'tt

Ituckeye Power, Inc.l)ocket Nn. EL I l-54-002

Exhibit Nta 8-IPage 4l of 43

I I'herefore, I recommend that the dual-voltage rate be replaced by a single rolled-in

transmission rate which covers all of A'I'SI's integrated transmission facilities.

AMP/CPP witness Willis asserts in his testimony that "the 69 kV facilitiesoperated by ATSI are sub-transmission lines, which makes them an adjunctto equipment that performs the local power distribution function..." Do youagree with Mr. Willis'ssertion'!

3 IV. COMMENTS REGARDINGOTHER WITNESSES'ESTIMONY

5

6 Q.28

IO

I I A. iVo. As I explained throughout my testimony, ATSI's 69 kV ATS facilities have

l2 always been classified as transmission. These facilities perform a transmission

l3 lunction, and are integrated and operate in parallel with the 138/345 kV BTS.

l4

I5

l6

Therefore, they are transmission, and not sub-transmission. and do not perform a

local power distribution function. This opinion is also shared by ATSI, as

contirmed by their response to Statt's discovery request.

AMP/CMP witness Hilt contends in his testimony that ATSI's 69 kV ATSdoes not provide support to the 13S/345 kV BTS because the 69 kV ATS didnot/could not support the 138/345 kV during the August 2003 Blackout. Doyou have comments regarding Mr. Hilt's contention'7

l7 Q.l8l9o02122 A. Yes. Mr. I-lilt discusses in his testimony some of the events that occurred during

23

24

25

the August 2003 Blackout that involved the West Akron substation. "During the

progression of the blackout, numerous l38 kV lines in Ohio had tripped out of

service due generally to overloads caused by the tripping of higher-voltage

rs Ex. 8-8 at 8.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 47: Buckeye Power

2O L,u)RO9-5 LOR YERC PDP (()narriciai) R/9/2012 4:54:25 PM

I

IIuckcye Power, Inc.l)ockct No. KLI I-54-II02

Fxhlhit No. S-IPage 42 uf 43

IO

12

l3

l4

l5

lines.-'r. I-lilt further notes that because nt'he numerous I 38 kV circuits that

had been lost, the 69 kV facilities, which were still energized, became a path for

power to liow toward the l38 kV loads."" Due to the excessive amount ot'current

llowing from the 69 kV system into the 138 kV system, the relays protecting the

ti9/138 kV Transformer No. I at West Akron interrupted the tlow into the l38 kV

system from the 69 KV system "to prevent an excessive amount of current from

being pulled through the 69 kV facilities into the l38 kU system. l3ecause the

protective relaying operated as expected, the 69 kV facilities did not support the

l38 kV system during this instance of network stress.""

While I agree that during the 2003 blackout the relays protecting Transformer No.

I at West Akron intenupted the Ilaw into the l38 kV system from the 69 kV

system to prevent an excessive amount of current flowing through the transformer,

I disagree that this relay operation is indicative of the lack of support the 69 kV

system provided to the 138 kV system. First, as discussed in ATSI's response to

StaQ'discovery, the protective relays at West Akron "do not react to balanced

power flow through the transformer." In other words, the extreme, unbalanced

Ex. AC-2& at 5:16-IS.

Ex. AC-2S at 5:16-6:2.

6) Ex. AC-2S at 6:4-IS.

Ex. S-S at 2.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 48: Buckeye Power

")i.!0000-6100 FERC Por (Unorficiai) 0/0/2012 4ia4:;!5 DN

l3ucktpe Power, Inc.l)ocket )No. KLI 1-54-tttl2

ltxhihit No. 8-IPage 43 of 43

I power tlow conditions during the 3003 blackout were the reasons lor the relay

operations at West Akron, and not the lack of support received from the 6)9 kV

.3 system. Moreover, in its response to Staff discovery ATSI admits that that "the

4 West Akron Substation could be energized from the 69 kV system through the

5 138/69 kV Transformer // l. There are no protection schemes that would prevent

this from occurring."" ATSl explains that 139/69 kV transtormers at Star,

7 Chamberlain, Darrow, and Midway substations can all be energized from the 69

8 k V system and there are no protection schemes that would prevent this from

10

Il

happening.6'hus, ATSI's response conlirms that the 69 kV ATS can support

and serve as a back-up for the 138/345 kV BTS.Therefore, the 69 kV ATS is

designed to support, and can support the 138/345 kV BTS.

l2 Q. Doesthisconcludeyourtestimony?

13 A. Yes, it does.

Ex. S-8 at 2.

64Ex S-8 at 3-6.

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 49: Buckeye Power

001'&0809-5108 RRRC RDF (Unorticivl) a/0/0012 t:51:"5 Rn

UNITED STA'I'ES OF AMERICABEFORE TIIK

FEDERAL ENERGY REGULATORY COMMISSION

Buckeye Power,! nc. ) Docket No. KLI I-54-002

CERTIFICATE of Antonio Maceo

l, Antonio Maceo, declare under penalty ot'erjury that I am the author of the foregoingtestimony„ that the facts set forth herein are true and correct to the best of my knowledge,and that if asked the same questions contained in the text, I would give the answerscontained in the testimony.

Is/Antonio Maceo

Antonio Maceo

Auaust 9. 2012

Date

20130116-0400 FERC PDF (Unofficial) 01/11/2013

Page 50: Buckeye Power

Document Content(s)

13154720.tif..........................................................1-49

20130116-0400 FERC PDF (Unofficial) 01/11/2013