March31, 2016

BY ELECTRONIC M 1 L

Senior Corporate Counsel Monongahela Power Company & The Potomac Edison Company 5001 NASA Boulevard Fairmont, WV 26554 g)ack@firstenergycorp.com

Re: Case No. 15-2002-E-IRP, Aifonongahela Power Company and The Potomac Edison Company, Integrated Resource Plan

Dear Mr. Jack:

Enclosed please find WV SUN and West Virginia Citizen Action Group's First

Set of Discovery Requests to Monongahela Power Company and The Potomac Edison

Company in the above-referenced case. These discovery requests are being

contemporaneously filed with the Public Service Commission, and a copy is being served on

all parties of record.

Very Truly Yours,

(W.Va. State Bar #12051)

Enclosures cc: Ingrid Ferrell, Executive Secretary (filed by hand delivery)

Counsel of record (served via e-mail)

WEST VIRGINIA-CITIZEN ACTION GROUP 1500 DIXIE STREET * CHARLESTON, WEST VIRGINIA 2531 1 PHONE: 304-346-5891 - FAX 304-346-8981 - www.wvcag.org

6 printed on recycled paper

PUBLIC SERVICE COMMISSION OF WEST VIRGINIA

CHARLESTON

MONONGAHELA POWER COMPANY and ) THE POTOMAC EDISON COMPANY, ) Case No. 15-2002-E-IRP Integrated Resource Plan filed pursuant ) to the March 19,2015 Commission Order 1 in G.O. 184.35 )

WV SUN AND WEST VIRGINIA CITIZEN ACTION GROUP’S FIRST SET OF DISCOVERY REQUESTS TO MONONGAHELA POWER COMPANY AND THE POTOMAC EDISON COMPANY

Pursuant to Rule 13.6 of the Public Service Commission’s Rules of Practice and Procedure, Community Power NetworldWest Virginia Solar United Neighborhoods (“WV SUN”) and West Virginia Citizen Action Group (“CAW’) (collectively, “Citizen Intervenors”) propound the following discovery requests on Moiiongahela Power Company and The Potomac Edison Company (collectively, “FirstEnergy” or the “Companies”) in the above-captioned proceeding. FirstEnergy should respond to these discovery requests within 20 days of service, or sooner if practicable.

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Please produce the requested documents in elcctronic format to:

Emmett Pepper West Virginia Citizen Action Group 1500 Dixie Street Charleston, WV 253 11

emmett@eewv.org

Please respond to each discovery request by no later than April 20,2016. Rather than holding responses to individual items until all responses to the First Set of requests have been completed, the Companies should provide each response as completed. If there are any objectioiis to any request, please provide those objections within 14 days of service in accordance with Rule 13.6.

Wherever the response to a request consists of a statement that the requested information is already available to the Citizen Intervenors, provide a detailed citation to the document that contains the information. This citation shall include the title of the document, relevant page number(s), and to the extent possible paragraph iiumber(s) and/or cliartitablelfigure number(s).

If you claim a privilege including, but not limited to, the attorney-client privilege or the work product doctrine, as grounds for not fully and completely responding to any

304-346-5891

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discovery request, describe the basis for your claim of privilege in sufficient detail so as to permit the Citizen Intervenors or the Commission to evaluate the validity of the claim. With respect to documents for which a privilege is claimed, produce a “privilege log” that identifies the author, recipient, date and subject matter of the documents or interrogatory answers for which you are asserting a claim of privilege and any other information pertinent to the claim that would enable the Citizen Intervenors or the Commission to evaluate the validity of such claims.

To the extent that you can legitimately claim that any response or responsive document is entitled to confidentiality, the Citizen Intervenors are willing to enter into a confidentiality agreement that would protect such response or document from public disclosure.

In the event that any document referred to in response to any request for information has been destroyed, specify the date and the manner of such destruction, the reason for such destruction, the person authorizing the destruction and the custodian of the document at the time of its destruction.

The Citizen Intervenors reserve the right to serve supplemental, revised, or additional discovery requests as permitted in this proceeding.

DEFINITIONS

Unless otherwise specified in each individual interrogatory or request, the terms “you,” “your,” “FirstEnergy,” or “Companies” refer collectively to Monongahela Power Company and The Potomac Edison Company, including any affiliated companies, predecessors-in-interest, employees, authorized agents, or other representatives.

“And” and “or” shall be construed either conjunctively or disjunctively as required by the context to bring within the scope of these interrogatories and requests for production of documents any information which might be deemed outside their scope by another construction.

“Any” means all or each and every example of the requested information

“CO2” means carbon dioxide

‘Commission” or “PSC” means the Public Service Commission of West Virginia, including its Commissioners, personnel, and offices.

“Communication” means any transmission or exchange of information between two or more persons, whether orally or in writing, and includes, without limitation, any conversation or discussion by means of letter, telephone, note, memorandum, telegraph, telex, telecopy, cable, email, or any other electronic or other medium.

“Document” refers to written matter of any kind, regardless of its form, and to information recorded on any storage medium, whether in electrical, optical or electromagnetic form, and capable of reduction to writing by the use of computer

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hardware and software, and includes all copies, drafts, proofs, both originals and copies either (1) in the possession, custody or control of the Companies regardless of where located, or (2) produced or generated by, known to or seen by the Companies, but now in their possession, custody or control, regardless of where located whether or still in existence. (a) Such “documents” shall include, but are not limited to, applications, permits,

monitoring reports, computer printouts, contracts, leases, agreements, papers, photographs, tape recordings, transcripts, letters or other forms of correspondence, folders or similar containers, programs, telex, TWX and other teletype communications, memoranda, reports, studies, summaries, minutes, minute books, circulars, notes (whether typewritten, handwritten or otherwise), agenda, bulletins, notices, announcements, instructions, charts, tables, manuals, brochures, magazines, pamphlets, lists, logs, telegrams, drawings, sketches, plans, specifications, diagrams, drafts, books and records, formal records, notebooks, diaries, registers, analyses, projections, email correspondence or communications and other data compilations froin which information can be obtained (including matter used in data processing) or translated, and any other printed, written, recorded, stenographic, computer-generated, computer-stored, or electronically stored matter, however and by whomever produced, prepared, reproduced, disseminated or made. Without limitation, the term “control” as used in the preceding paragraphs means that a document is deemed to be in your control if you have the right to secure the document or a copy thereof from another person or public or private entity having actual possession thereof. If a document is responsive to a request, but is not in your possession or custody, identify the person with possession or custody. If any document was in your possession or sub,ject to your control, and is no longer, state what disposition was made of it, by whom, the date on which such disposition was made, and why such disposition was made. For purposes of the production of “documents,” the term shall include copies of all documents being produced, to the extent the copies are not identical to the original, thus requiring the production of copies that contain any markings, additions or deletions that make thein different in any way from the original.

(b)

(c)

8 . “Identify” means:

(a) With respect to a person, to state the person’s name, address and business relationship

(b) With respect to a document, to state the nature of the document in sufficient detail for identification in a request for production, its date, its author, and to identify its custodian. If the information or document identified is recorded in electrical, optical or electromagnetic form, identification includes a description of the computer hardware or software required to reduce it to readable form.

(e.g., “employee”) to the Companies;

9. “IRP” means the 2015 Integrated Resource Plan, and all supporting exhibits and appendices, filed by the Companies in this proceeding.

“LCOE” means levelized cost of electricity. 10.

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“Mon Power” refers to the Monongahela Power Company, including any affiliated companies, predecessors-in-interest, employees, authorized agents, or other representatives.

“NOx” means nitrogen oxides.

“Relating to,” “concerning,” or “regarding,” means and includes pertaining to, referring to, or having as a subject matter, directly or indirectly, expressly or implied, the subject matter of the specific request.

“S02” means sulfur dioxide.

“Workpapers” are defined as original, electronic, machine-readable, unlocked, Excel format (where possible) with formulas intact.

DISCOVERY REQUESTS

1. Produce all discovery responses to any other party in this proceeding

2. Produce any workpaper, source document, and, in machine-readable format with formulas intact, input and output files, used in or developed in the evaluation of supply-side resources for the IRP.

3. Produce any workpaper, source document, and, in machine-readable format with formulas intact, input and output files, used in or developed in the evaluation of demand-side resources for the IRP.

4. Produce in machine-readable format with formulas intact the input and output files for each sensitivity analysis that you considered as part of this resource planning process.

5. Refer to the “MonPower Capacity Position” chart on page 6 of the IRP. a. Please produce, in machine-readable electronic format with formulas intact, all

modeling files, including input and output files, and workpapers created, used, or relied on in preparing this chart.

b. Please produce any studies or other documents that were reviewed, created, or relied on in preparing this chart.

6. Please provide the Companies’ monthly peak load (MW) for each month from January 201 5 through February 2016.

7. Please provide the Companies’ annual Obligation Peak Load for each year since 2008.

8. Provide the Companies’ Unforced Capacity Obligation for each year since 2008

9. Refer to page 15 of the IRP, which states: “The current peak forecast is predicting an annual growth rate of 2.2% for the years 2015 through 2020. The annnal growth rate continues to be driven by increased load in the natural gas sector. The natural gas sector is a newly emerging industry with future load needs dependent on many factors.”

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a. Please state whether the forecasted loads presented in Figure 5 on page 17 reflect an annual growth rate of 2.2% for the years 2015 through 2020.

i. If not, please explain why Figure 5 presents a different load forecast than described on page 15.

b. Please identify and produce any studies regarding the future electricity needs of the natural gas sector within the Companies’ service territory.

c. Please identify and produce, in machine-readable electronic format with formulas intact, all modeling files, including input and output files, and workpapers created, used, or relied on in projecting future electricity demand from the natural gas sector within the Companies’ service territory.

10. Referring to page 15 of the IRP, please provide the source of the “impacts of energy efficiency” input assumption included in the peak forecast, and state whether this assumption is implicit in the structure of the model or a direct input into the model.

11. Refer to the table immediately beneath Figure 4 on page 16 of the IRP. a. Please identify the date(s) of the forecast(s) that were used for the “Forecasted

Summer Peak (MW)” figures presented in this table. b. Please identify the date(s) of the forecast(s) that were used for the “Forecasted Winter

Peak (MW)” figures presented in this table. c. Refer to the table immediately beneath the “Historic Forecast and Actual Loads”

figure presented in your response to Staff Request 1.5(e). i. Please identify the date(s) of the forecast(s) that were used for the “Forecasted

Summer Peak (MW)” figures presented in this table. ii. Please identify the date(s) of the forecast(s) that were used for the “Forecasted

Winter Peak (MW)” figures presented in this table.

12. Refer to Figure 5 on page 17 of the IRP. a. Please explain why peak demand is expected to increase by approximately 300MW

from2016 to 2019. b. Are the load forecasts presented in Figure 5 unrestricted load forecasts?

i. If so, please provide the most recent load forecast conducted by or on behalf of the Companies that includes the impacts of energy efficiency and demand response programs.

c. Please produce, in machine-readable electronic format with formulas intact, all modeling files, including input and output files, and workpapers created, used, or relied on in preparing Figure 5 .

d. Please produce any studies or other documents that were reviewed, created, or relied on in preparing Figure 5.

13. Refer to page 18 of the IRP, which refers to “Establishing an Acceptable Asset Mix.” a. How do the Companies define an “acceptable” asset mix?

14. With regards to the future capacity shortfall referenced in the IRP:

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a. For each of the years 2016 through 2030, please identify the number of hours that the Companies project that customer load will exceed the Companies’ generation capacity.

b. Please produce the Companies’ load duration curve for each of the years 2012,2013, 2014, and 2015.

c. Please produce the Companies’ projected load duration curve for each of the years 2016 through 2030.

d. Please produce any studies or other documents that were reviewed, created, or relied on in projecting the Companies’ load duration curve for any of the years 2016 through 2030.

IS. Refer to the Figure 6 on page 19 of the IRP. a. Please explain why Mon Power’s generation capacity is projected to drop by 11 1

MW (from 3489 MWto 3378 MW) between 2015 and 2016. b. Please explain why the Companies’ capacity position is calculated with reference to

winter peak, rather than summer peak. c. Please produce, in machine-readable electronic format with formulas intact, all

modeling files, including input and output files, and workpapers created, used, or relied on in preparing Figure 6.

d. Please produce any studies or other documents that were reviewed, created, or relied on in preparing Figure 6.

16. Refer to page 21 of the IRP. a. Please provide the calculations that the Companies performed in estimating that the

capacity of the Bath County Pumped Storage units will be reduced by 253 MW starting in 2020.

17. Refer to page 25 of the IRF’. With regards to the Coal Combustion Residuals (“CCR”) Rule: a. Please identify any capital expenditure(s) or plant modification(s) that the Companies

anticipate will be needed at the Harrison or Fort Martin plants to comply with the CCR Rule.

b. For each capital expenditure or plant modification identified in your response to subpart (a), please identify:

i. The capital cost. ii. The annual O&M costs.

iii. The date by which such modification is anticipated to be needed. c. Please produce any studies regarding the potential impact of the CCR Rule on the

Harrison or Fort Martin plants.

18. Refer to page 26 of the IRP, which discusses the final Effluent Limitation Guideline (“ELG”) rules.

a. Please explain how fly ash is currently handled (Le., wet or dry) at the Fort Martin plant.

i. If Fort Martin currently has a wet handling system for fly ash:

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(a) Please describe any plans for converting to dry handling. (b) Please identify the timeline for any planned conversion to dry

(c) Please identify the projected cost of any planned conversion to dry handling.

handling. b. Please explain how bottom ash is currently handled (Le,, wet or dry) at the Fort

Martin plant. i. If Fort Martin currently has a wet handling system for bottom ash:

(a) Please describe any plans for converting to dry handling. (b) Please identify the timeline for any planned conversion to dry

(c) Please identify the projected cost of any planned conversion to dry handling.

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handling. c. Please exolain how flv ash is curreiitlv handled (i.e.. wet or dry) at the Harrison plant ~, .,

i. If Harrison currently has a wet handling system for fly a sh (a) Please describe any plans for converting to dry handling. (b) Please identify the timeline for any planned conversion to dry

(c) Please identify the projected cost of any planned conversion to dry handling.

handling. d. Please explain how bottom ash is currently handled (is., wet or dry) at the Harrison

plant. i. If Harrison currently has a wet handling system for bottom ash:

(a) Please describe any plans for converting to dry handling. (b) Please identify the tiineline for any planned conversion to dry

(c) Please identify the projected cost of any plaimed conversion to dry

e. Identify any wastewater treatment project(s) that the Companies anticipate will be needed at the Harrison or Fort Martin plants to comply with the ELG rules.

f. For each wastewater treatment project identified in response to subpart (e), please identify:

i. The capital cost. ii. The projected annual O&M costs.

iii. The date by which such projects are anticipated to be needed.

handling.

handling.

g. Please produce any studies regarding the potential impact of the ELG rules on the Fort Martin or Harrison plauts.

19. For each of the years 2013, 2014, and 2015, and each unit of the units at the Harrison and Fort Martin plants, please identify the:

a. Availability b. Heat rate c. Forced or random outage rate d. Fixed 0 & M cost in dollars per MWh e. Variable O&M cost in dollars per MWh f. Fuel cost

g. Environmental capital cost h. Non-environmental capital cost i. SO2 emission rate j. NOx emission rate k. Mercury emission rate 1. Particulate matter emission rate in. Hydrochloric acid emission rate

20. Refer to page 12 of the IRF. a. Please identify the capacity factor for each of the units at the Fort Matin and

Harrison plants in 2015.

21. For each of the years 2016 through 2027, and each unit of the units at the Harrison and Fort Martin plants, identify the projected:

a. Capacity factor b. Availability c. Heat rate d. Forced or random outage rate e. Fixed O&M cost in dollars per MWh f. Variable O&M cost in dollars per MWh g. Fuel cost 11. Environmental capital cost i. Non-environmental capital cost j. SO2 emission rate k. NOx emission rate 1. Mercury emission rate m. Particulate matter emission rate n. Hydrochloric acid emission rate

22. Refer to pages 10 and 20 of the IRP. With regards to the capacity revenue that Moll Power receives for its generating units:

a. For each year of 2013,2014, and 2015, please identify: i. the capacity revenue for each unit of the units at the Harrison plant.

ii. the capacity revenue for each unit of the units at the Fort Martin plant.

i. the projected capacity revenue for each unit of the units at the Harrison plant. ii. the projected capacity revenue for each unit of the units at the Fort Martin

b. For each year of 2016 through 2027, please identify:

plant. c. Please produce the Companies’ most recent capacity price forecast.

i. Please identify the date and source of that forecast. 11. Please produce any studies or other documents supporting that forecast. ..

23. Refer to pages 5, 41, and 58 of the IRP, and specifically your statement that the “Mon Power generation fleet continues to produce low cost electricity.”

a. For each year of 2013,2014, and 2015, please identify: i. the annual costs of the Fort Martin plant (including the cost of any interest

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expenses, taxes, and equity return). ii. the annual costs of the Harrison plant (including the cost of any interest

expenses, taxes, and equity return). iii. the Fort Martin plant’s average variable cost of electricity, expressed in

$/MWh. iv. the Harrison plant’s average variable cost of electricity, expressed in $/MWh. v. the Fort Martin plant’s total cost of electricity, expressed in $/MWh.

vi. the Harrison plant’s total cost of electricity, expressed in $/MWh.

i. the projected annual costs of the Fort Martin plant (including the cost of any interest expenses, taxes, and equity return).

ii. the projected annual costs of the Harrison plant (including the cost of any interest expenses, taxes, and equity return).

111. the Fort Martin plant’s projected average variable cost of electricity, expressed in $/MWh.

iv. the Harrison plant’s projected average variable cost of electricity, expressed in $/MWh.

v. the Fort Martin plant’s projected total cost of electricity, expressed in $/MWh. vi. the Harrison plant’s projected total cost of electricity, expressed in $/MWh.

b. For each year of 2016 through 2027, please identify:

...

24. Refer to Figure 7 on page 22 of the IW. a. Please provide the actual load, generation output, and net Mon Power energy position

for the years 2013,2014, and 2015. b. With regards to the projected generation output for the years 2016 through 2030:

i. Does that projection assume that Mon Power’s generation fleet will include resources other than the resources identified in Figure 1 on page lo?

included in Mon Power’s generation fleet for purposes of this projection.

(b) If not, please explain how adding capacity would “mitigate market price risk,” given that the Companies are already long on energy through 2030.

c. Please produce, in machine-readable electronic format with formulas intact, all modeling files, including input and output files, and workpapers created, used, or relied on in the preparing Figure 7.

d. Please produce any studies or other documents that were reviewed, created, or relied on in preparing Figure 7.

e. Please identify the modeling software, and any other programs, that were used in developing the generation output forecast reflected in Figure 7.

f. Please produce any forecast of market energy prices that was used in developing the generation output forecast reflected in Figure 7.

(a) If so, please identify each additional resource that was assumed to be

25. Refer to page 22 of the IW, which states: “Mon Power currently generates more energy than its customers consume, creating a long energy position as shown in Figure 7.” With respect to the excess generation from Moil Power’s generating units:

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a. Please identify the net revenue from excess generation that each of Mon Power’s generating units produced in each ofthe years 2013,2014, and 2015.

b. Please identify the net revenue from excess generation that each of Mon Power’s generating units is projected to produce in each of the years 2016 through 2030.

c. Do the Companies’ customers receive any of the net revenue from such excess generation?

i. If so, explain how net revenues from excess generation are divided between the Companies and their customers.

ii. If not, explain why not.

26. Refer to page 22 of the IRP, which states: “Projected market prices for energy indicate that in the near-term pricing is relatively stable. In the long-term, as load increases over time and future EPA mandates go into effect, energy prices may be more volatile.”

a. Please identify and produce any energy price forecasts that you relied on in making the statements quoted above.

i. For each energy price forecast identified in response to subpart (a), please identify the date and source of the forecast.

b. Please identify and produce any studies or other documents that you reviewed, created, or relied on in concluding that long-term “energy prices may be more volatile.”

27. Refer to page 27 of the IRP, which states: “Mon Power’s planning position has been to use existing generation until it becomes uneconomical from a market perspective or impractical from a capital cost or operations perspective.”

a. Please provide the Companies’ definition of when generation becomes “uneconomical from a market perspective.”

28. Refer to Figure 9 on page 29 of the IW. a. Please provide this Figure in native file format. b. During the polar vortex price spike (which is shown in Figure 9), was Mon Power a

net seller of energy into the PJM market?

29. Have all of Mon Power’s generation resources (except Bath County) cleared the Capacity Performance transition auctions?

a. If not, please identify which resources have not cleared the Capacity Performance transition auctions.

30. Did all of Moil Power’s generation resources (except Bath County) clear the 2018/2019 base residual auction as Capacity Performance resources?

a. If not, please identify which resources did not clear the 2018/2019 base residual action as Capacity Performance resources.

3 1. Refer to Figure 14 on page 37 of the IRP. a. Are the prices in Figure 14 in nominal or real dollars? If the latter, please identify

which year’s dollars those prices are expressed in. b. Please identify the date on which you pulled the forward prices reflected in Figure 14

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C. Please explain why you used natural gas forward prices through 2026 in this IRP. d. Do you consider natural gas forward prices to be a reliable source for purposes of

integrated resource planning? i. If so, please explain why.

ii. If not, please explain why you used natural gas forward prices in Figure 14. e. State whether the Companies have created, obtained, or reviewed any natural gas

price forecasts since January 1,2015. i. If so, please identify and produce each such forecast.

32. State whether you modeled or evaluated any scenarios for this IRP in which the Companies sell or divest any portion of the Harrison plant.

a. If so, please produce and explain the results of such modeling or evaluation. b. If not, explain why not.

33. State whether you modeled or evaluated any scenarios for this IRP in which the Companies sell or divest any portion of the Fort Martin plant.

a. If so, please produce and explain the results of such modeling or evaluation. b. If not, explain why not.

34. Re€er to page 42 of the IRP, which states that “many sources, like solar. . . are not economic options for Mon Power with the Companies’ service territories based 011 the current state of development for those technologies or for meteorological or geographical reasons.”

a. Please describe the “current state of development” for solar and explain whether the current state, in the Companies’ view, renders solar an uneconomic resource option. Please produce all supporting documentation.

b. Please explain all “meteorological or geographical reasons’’ why the Companies believe that solar is an uneconomic resource option. Please produce all supporting documentation,

c. Please explain the “significant leaps in [solar] technology” that the Companies believe would need to occur to make solar a viable renewable option.

d. Please produce any study or other document - not produced in response to subparts (a)-(c) - that you reviewed, created, or relied on for your conclusion that solar is not an ecoiioinic option within the Companies’ service territories.

35. Please produce all studies conducted by or for the Companies regarding the wind potential in the Companies’ service territories.

36. Please produce all studies conducted by or for the Companies regarding the solar potential in the Companies’ service territories.

37. Refer page 44 of the IRP, which states that “the Moil Power service area is still not

a. Please produce all studies conducted by or for the Companies, and all other documents (other than the NREL graph provided), that support this conclusion.

b. Does this statement refer to utility-scale solar, distributed solar generation, or both?

particularly conducive to wide scale economical photovoltaic development.”

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38. Refer to the NREL graph shown on page 44 of the IRP. a. Please provide this NREL graph in native file form. b. Please provide the NREL reportistudy from which this graph originates c. Please provide the date of the data underlying this graph.

39. Please provide the Companies’ understanding of the relationship between peak times and solar energy production.

40. Referring to the Companies’ Phase I EEC Plan (referenced on page 46 of the IW): a. Please confirm that the 0.5% reduction in energy from 2009 levels through 20 16 is a

cumulative target. b. Please provide the incremental energy savings the Companies have achieved each

year from 2012 through 2015, expressed in both MWh terms and as a percentage of retail sales.

c. Please provide the incremental demand savings the Companies have achieved each year from 2012 through 2015, expressed in both MWh terms and as a percentage of retail sales.

41. Refer to sectioii 6.3.5 of the IRP. a. Please provide the incremental energy savings the Companies expect to achieve each

year from 2016 through 2029, expressed in both MWh terms and as a percentage of retail sales.

b. Please provide the incremental demand savings the Companies expect to achieve each year from 2016 through 2029, expressed in both MWh terms and as a percentage of retail sales.

c. Please provide the cumulative energy savings the Companies expect to achieve during the IRP planning horizon, expressed in both MWh terms and as a percentage of retail sales.

d. Please provide the cumulative demand savings the Companies expect to achieve during the IRP planning horizon, expressed in both MWh terms and as a percentage of retail sales.

42. Please explain in detail how demand-side resources are modeled in the IRP. If such resources were not modeled, explain why.

43. Refer to page 49 of the IRP, which states: “There are also performance risks associated with DR resources. If DR resources fail to perform, . . . .”

a. Please describe all instances in which “DR resources fail[ed] to perform” in the Companies’ service territory.

b. Produce all documentation supporting the instances described in response to subpart (4.

44. Refer to the discussion of the EPSA demand response lawsuit on page 5 1 of the IRP. a. Please explain how the Supreme Court’s decision, which was issued roughly four

weeks after the Companies filed the IRP, impacts the Companies’ consideration of demand response resources.

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b. Page 5 1 of the IRP states that the Supreme Court’s decision affects “investment decisions on whether to retire generating units.” Please explain how the decision impacts decisions concerning generating unit retirements.

45. Refer lo page 52 of the IRP, which states: “The Companies compared the continued reliance oil the market against the levelized costs of procuring other alternative sources of generation, resulting in a levelized cost range of $72-76/MWh, shown in Figure 16.”

a. Please explain how you developed this $72-76/MWh estimate. b. Please produce any forecasts of energy, capacity, or natural gas prices that were

reviewed, created, or relied on in preparing this $72-76/MWh estimate. c. Please produce any studies or other documents that were reviewed, created, or relied

on in preparing this $72-76/MWh estimate. d. Please provide any studies prepared by or on behalf of the Companies of the LCOE of

continued reliance on PJM energy and capacity market purchases through 2030, instead of acquiring additional geiieration resources.

46. Refer to the Figure 16 on page 53 of the IRP, and to footnote 9 on page 52 of the IRP.. a Please confirm that you assumed a 20-year cost recovery period for your LCOE

analysis. b. Please explain why you did not use a 30-year cost recovery period, as the Energy

Information Administration did for the LCOE values presented in the 2015 Annual Energy Outlook. See EIA, Levelized Cost and Levelized Avoided Cost of New Generation Resources in the Amiual Energy Outlook 2015, at p.2 (June 2015), available at https://www.eia.gov/forecasts/aeo/pdf/eleclricity eeneration.odf.

47 Refer to the Figure 16 on page 53 of the IRP. a. Please produce, in machine-readable electronic format with formulas intact, all

modeling files, including input and output files, and workpapers created, used, or relied on in preparing Figure 16.

b. Please produce any studies or other documents that were reviewed, created, or relied on in preparing Figure 16.

c. For each of the generation resources identified in Figure 16, or in your responses lo Staff Requests 1.10 and 1 . I 1, please identify each of the following values that you used in calculating the LCOE for that resource:

i. the projected annual capital cost assumed for each year of the 20-year analysis.

ii. the projected annual fuel cost assumed for each year of the 20-year analysis. iii. the projected aimual fixed O&M cost assumed for each year of the 20-year

analysis. iv. the projected capacity factor assumed for each year of the 20-year analysis. v. the projected annual variable O&M cost assumed for each year of the 20-year

analysis. vi. the projected annual emission allowance cost (including C02 emission costs,

if any) assumed for each year of the 20-year analysis. vii. the projected annual depreciation, debt interest, and tax costs assumed for

each year of the 20-year aiialysis.

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viii. the generation resource’s weighted average cost of capital assumed for each year of the 20-year analysis.

ix. the assumed life expectancy of the generation resource.

48. Refer to pages 52-58 ofthe IRP. a. Please state whether you consider an LCOE analysis to be a sufficiently robust type

of analysis upon which to base the Companies’ long-term resource planning.

b. Please confirm that you did not perform any dispatch modeling for purposes of this IRP.

i. If so, please explain why.

i. If confirmed, please explain why you did not perform any dispatch modeling. ii. If not confirmed, please identify and produce the results of any dispatch

modeling performed for purposes of this IRP. (a) For any dispatch modeling results identified in response to subpart

(b)(ii), please produce, in machine-readable electronic format with forinulas intact, all modeling files, including input and output files, and workpapers created, used, or relied on.

49. Refer to page 54 of the IRP, which references “a levelized Henry hub price of $3.36/mmBtu.”

a. Please state whether the $3.36 figure is in nominal dollars or real dollars, and which year’s dollars that figure is expressed in.

50. Refer to page 55 of the IRP, which states: “There are a limited number of existing facilities

a. Please identify each of “the limited number of existing facilities within the region” referenced in this portion of the IRP.

b. In developing this IRP, did the Companies consider the acquisition of an existing natural gas combined cycle (“CC”) plant?

i. If so, please identify the LCOE for the acquisition of an existing CC plant. Please produce all supporting documentation.

ii. If not, please explain why not.

within the region capable of economically serving Mon Power’s and PE’s WV load.”

c. In developing this IRP, did the Companies consider the acquisition of an existing natural gas combustion turbine (“CT”) system?

i. If so, please identify the LCOE for the acquisition of an existing CT system. Please produce all supporting documentation.

ii. If not, please explain why not. d. In developing this IRP, did the Companies consider the acquisition of any existing

generation resource other than a coal-fired generating unit(s)? i. If so, please identify and produce all studies conducted by or on behalf of the

Companies of the LCOE of acquiring an existing non-coal generation resource. Please produce any supporting documentation.

ii. If not, please explain why not.

51. Refer to Section 7.4 of the IRP on page 56.

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a. Please produce all modeling and/or studies conducted by or for the Companies that support the conclusion that “demand side resource options will not meet Mon Power’s obligations.”

b. Did the Companies evaluate demand-side resource options as a ineans to meet part of Mon Power’s obligations?

i. If so, please provide all supporting documents. ii. If not, why not.

52. Refer to page 57 of the IW, which states: ‘‘[Tllie issue of whether DR is a retail or a wholesale product is currently before the U. S. Supreme Court for a decision this term ending July 2016. Ifthe DC Court’s decision is upheld by the US Supreme Court, the result will be that DR will be regulated by the state public service commissions rather than by FERC. Due to this uncertainty, it is difficult and impractical for the Companies to rely on DR as either a capacity or energy resource.”

a. Please explain how, if at all, the Companies expect their reliance on DR as a resource to change in light of the Supreme Court’s decision, issued January 25,2016.

b. Please explain how the Supreme Court’s decision affects the Companies’ decision not to consider demand-side resources “a viable, long-term solution to meet Mon Power’s need for an additional 850 MW.”

53. Refer to page 4 of the IRP, which states: “Moil Power examined several alternatives to address its capacity shortfall, including purchasing power from the PJM market, building new capacity, purchasing power from other parties, co-firing existing coal fired generation using natural gas, and acquiring existing generating facilities.”

e. Please confirm that the Companies did not examine increasing its investment in demand-side resources, including energy efficiency and demand response, to address their projected capacity shortfall.

i. If you confirm, please explain why the Companies failed to consider this alternative.

ii. If you do not confirm, please describe your evaluation and produce all documents that were created, reviewed, or relied on in performing this evaluation.

54. Refer to page 5 of the IRP, which recommends, inter alia, “the acquisition of additional resources,” and states that the Companies “expect to seek the Commission’s approval in a separate docket for any future specific proposed transaction(s) which are selected.”

a. When do the Companies expect to file a proposal with the Commission for the acquisition of additional resources?

b. Please produce all requests for proposal (“RFPs”) issued by the Companies since October 1,2013, for the addition of new gemration capacity.

c. Please produce any studies or other documents that the Companies have reviewed, created, or relied on to date in their “continuing . . . review” of potential resource options.

d. Refer to the IW’s statement that “the specific asset or assets cannot be determined at this time.”

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i. Have the Companies, at present ( i . e . , as of the date you respond to this request), identified any specific asset or assets that might be the subject of a future acquisition proposal?

(a) If so, please identify each such asset that the Companies may propose

(b) If not, please explain why not, and please state when the Companies to acquire.

plan to identify specific asset(s) that might be the subject of an acquisition proposal.

55. Refer to page 5 of the IRP, which discusses “Retrofit[ting] some or all of Mon Power’s existing coal-fired units to implement co-firing with up to 30% natural gas burn.” Please also refer to pages 38-41 and 58 of the IRP, which also discuss co-firing with natural gas.

a. Please produce any studies conducted by or on behalf of the Companies of the cost of converting the Fort Martin or Harrison units to dual-fire units.

b. Please produce any studies or other documents you created, reviewed, or relied on for your estimate that the cost to add co-firing capabilities “is expected to be between $55430 million for each unit.”

c. Please produce any studies or other documents you created, reviewed, or relied on for your estimate that the cost to add co-firing capabilities “is expected to be . . . about $85 per MW for Harrison.”

d. Please produce any studies or other documents you created, reviewed, or relied on for your estimate that the cost to add co-firing capabilities “is expected to be . . . about . . . $140 per MW for Fort Martin.”

56. Please explain why the IRF’ fails to discuss distributed generation, including distributed solar generation.

Emmett P‘epper W. Va. Bar No. 12051 West Virginia Citizen Action Group 1500 Dixie Street Charleston, WV 253 1 1

emrnett@eewv.org 304-346-5891

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CERTIFICATE OF SERVICE

I hereby certify that on this date I served a copy of the foregoing First Set ofDiscovery

Requests to Monongahela Power Company and The Potomac Edison Company upon the parties

listed below via e-mail. I also sent a courtesy copy of the foregoing document to the parties

listed below via U.S. Mail, first class, postage prepaid.

Gary A. Jack, Esq. Senior Corporate Counsel Moiioiigahela Power Company & The Potomac Edison Company 5001 NASA Boulevard Fainnont, WV 26554 giaclc@firsteiiergycorp.coin

John R. Auville, Esq. Staff Attorney Public Service Commission of West Virginia PO Box 812 Charleston, WV 25323 jauville@psc.state.wv.us

Jacqueline Roberts, Esq. David A. Sade, Esq. Consumer Advocate Division 700 Union Building 723 Kanawha Boulevard, East Charleston, WV 25301 jroberts@cad.state.w.us tsade@cad.state,wv.us

Date: March 31, 2016 qe Emme Pepper

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