S T A T E OF M I C H I G A N BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION * * * *

S T A T E OF M I C H I G A N BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION * * * * In the matter of the application of Michigan Electric Transmission Company, LLC ) for a certificate of public convenience and ) Case No. U- 17041 necessity for the construction of a transmission ) line in Almena Township, Van Buren County, and ) Oshtemo Township, Kalamazoo County, Michigan ) ) QUALIFICATIONS AND DIRECT TESTIMONY OF LYNN M BECK MICHIGAN PUBLIC SERVICE COMMISSION November 30, 2012

QUALIFICATIONS OF LYNN M BECK CASE NUMBER U-17041 PART I 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Q. Please state your full name and business address for the record. A. My name is Lynn M. Beck, and my business address is the Michigan Public Service Commission s (Commission) temporary work site at 4300 West Saginaw Highway, Lansing, Michigan 48917. Q. By whom are you employed and what is your position? A. I am employed by the Commission as an Analyst for the Generation and Certificate of Need Section in the Electric Reliability Division. Q. Would you please outline your educational background? A. I obtained a Bachelor of Applied Science degree with a major in Environmental Technology from Sienna Heights University in 2009. Since joining the Commission, I have attended training programs sponsored by the National Association of Regulatory Utility Commissioners and Michigan State University including the Annual Regulatory Studies Program (August 2012) and the Advanced Regulatory Program: Ratemaking, Accounting, and Economics (October 2012). Q. Would you please outline your professional experience? A. From April 2005 to September 2007, I worked as a student assistant with the Michigan Department of Environmental Quality, Environmental Science and Services Division. My responsibilities included working with Section 313 (Title III) of the Superfund Amendments and Reauthorization Act, processing Toxic Chemical Release Inventory (TRI) reports, and processing 40 CFR 370 hazardous chemical inventory (Tier II) reports. I also assisted in reviewing and processing Annual Wastewater Reports for the Annual Wastewater Reporting Program. 1

QUALIFICATIONS OF LYNN M BECK CASE NUMBER U-17041 PART I 1 2 3 4 5 6 7 8 9 10 In January 2011, I began working full time for the Department of Energy, Labor and Economic Growth, Bureau of Energy Systems as a Grant Administrator for the Energy Efficiency and Conservation Block Grant Program (EECBG), funded by the American Recovery and Reinvestment Act of 2009 (ARRA). During my employment at the Bureau of Energy Systems, now called the Michigan Energy Office, I was responsible for the oversight of the EECBG grant recipients, which included local units of government in Michigan, to ensure that their grant and all grant requirements were carried out successfully. I was also responsible for the development of the management timeline for the closeout of the federal ARRA grant between the US Department of Energy and the Michigan Energy Office. 11 12 13 14 15 16 17 18 19 20 21 22 In March 2012, I began working for the Generation and Certificate of Need Section within the Electric Reliability Division of the Michigan Public Service Commission. This Section handles utility applications for Certificate of Necessity cases under 2008 Public Act 286, Expedited Siting Certificates for transmission lines under 2008 Public Act 295, and Certificates of Public Convenience and Necessity for transmission lines under 1995 Public Act 30. In addition to these responsibilities, we also participate in the Midwest Independent System Operator (MISO) Transmission Expansion Plan (MTEP). MTEP is an annual process involving stakeholder reviews of proposed transmission projects submitted by Transmission Owners (TO) and utilities to MISO. This Section also conducts special assignments as directed by the Commission. 23 2

QUALIFICATIONS OF LYNN M BECK CASE NUMBER U-17041 PART I 1 2 Q. Have you previously presented testimony? A. No. 3

DIRECT TESTIMONY OF LYNN M BECK CASE NUMBER U-17041 PART II 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Q. What is the purpose of your testimony? A. The purpose of my testimony is to present the Michigan Public Service Commission Staff s (Staff) position in the matter of Michigan Electric Transmission Company s (METC) request for a Certificate of Public Convenience and Necessity (CPCN) pursuant to 1995 Public Act 30 (Act 30), MCL 460.561 et seq. Q. What specific guidance was available to Staff in its review of METC s application for a CPCN in connection with METC s proposed Weeds Lake substation and transmission line installation? A. Staff relied upon Act 30, specifically MCL 460.561 et seq. Q. What specific elements of METC s application will be covered by your testimony? A. My testimony will cover the application filing requirements outlined in MCL 460.566, MCL 460.567(2)(j), and MCL 460.568(1). Q. Are you sponsoring any exhibits in this proceeding? A. Yes. I am sponsoring Exhibits S-1 through S-3, and S-10. 17 18 19 20 21 22 23 Exhibit No. Exhibit S-1 Exhibit S-2 Exhibit S-3 Exhibit S-10 Description METC s response to question 41 of Staff s First Discovery Request The Kalamazoo Gazette distribution map The Courier-Leader distribution information METC s response to questions 1 through 3 of Staff s Fourth Discovery Request 4

DIRECT TESTIMONY OF LYNN M BECK CASE NUMBER U-17041 PART II 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Q. Did METC host a public meeting in each municipality through which the proposed transmission line passes, as outlined in MCL 460.566(1) of Act 30? A. Yes. According to testimony submitted by METC witness Mr. Gary R. Kirsh, METC held public meetings in both Almena and Oshtemo Townships on June 26 and 27, 2012, respectively. 1 Q. Did METC invite the chief elected official in each affected municipality to discuss the plans to construct the transmission line and potential routes prior to these public meetings, as outlined in MCL 460.566(2) of Act 30? A. Yes. On June 5, 2012, METC made two separate written offers to meet with the Almena Township Supervisor, Mr. Doug Stiles, and the Oshtemo Township Supervisor, Ms. Libby Heiny-Cogswell. 2 3 4 Q. What was the result of the written invitation to Almena Township Supervisor, Mr. Doug Stiles? A. According to METC witness Mr. Gary R. Kirsh s testimony, Almena Township declined to host such a meeting. 5 Q. What was the result of the written invitation to Oshtemo Township Supervisor, Ms. Libby Heiny-Cogswell? A. Oshtemo Township invited METC witness Mr. Gary R. Kirsh to attend the Oshtemo Township Board meeting on June 12, 2012. According to Mr. Kirsh s testimony, he did attend the meeting and presented the proposed and alternate 1 Prefiled Direct Testimony and Exhibits of Gary R. Kirsh, p 3. 2 Prefiled Direct Testimony and Exhibits of Gary R. Kirsh, p 5. 3 Prefiled Direct Testimony and Exhibits of Gary R. Kirsh, Exhibit A-13(GK-1). 4 Prefiled Direct Testimony and Exhibits of Gary R. Kirsh, Exhibit A-15(GK-3). 5 Prefiled Direct Testimony and Exhibits of Gary R. Kirsh, p 5. 5

DIRECT TESTIMONY OF LYNN M BECK CASE NUMBER U-17041 PART II 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 transmission line routes, the Act 30 process, and informed the township board of the open house event on June 27, 2012. 6 Q. Did METC include, in their application for a CPCN, a summary of all comments received at each public meeting, as outlined in MCL 460.567(2)(j)? A. Yes. The summaries are included in Exhibit A-18 (GK-6), attached to METC witness Mr. Gary R. Kirsh s testimony. 7 Q. Did METC include a summary of their responses to the comments mentioned above? A. Yes. The summaries of their responses are included in Exhibit A-18 (GK-6), attached to METC witness Mr. Gary R. Kirsh s testimony. 8 Q. Has METC submitted a full transcript from the aforementioned public meetings? A. Yes. In response to Staff s First Discovery Request, METC provided transcripts from both public meetings held on June 26 and June 27, 2012 in Almena and Oshtemo Townships respectively. The transcripts from both public meetings are included as Exhibit S-1. Q. Are you aware of any public outreach activities done by METC prior to the filing of the application? A. Yes. In addition to the aforementioned public meetings, METC held an open house at the Prairie Ridge Elementary School in Kalamazoo, MI on June 23, 2011. Maps and other relevant information were available for public review, and 6 Prefiled Direct Testimony and Exhibits of Gary R. Kirsh, p 5. 7 Prefiled Direct Testimony and Exhibits of Gary R. Kirsh, Exhibit A-18(GK-6). 8 Prefiled Direct Testimony and Exhibits of Gary R. Kirsh, Exhibit A-18(GK-6). 6

DIRECT TESTIMONY OF LYNN M BECK CASE NUMBER U-17041 PART II 1 2 3 4 5 METC representatives were available to discuss issues and answer questions. Also, on November 7, 2011, METC held an informational meeting at the Kalamazoo Holiday Inn, in which all affected landowners along the potential routes were invited to attend. 9 10 Q. METC witness Mr. Gary R. Kirsh included the phrases open house and 6 7 informational meeting in his testimony. 11 two? Is there a difference between the 8 9 10 11 12 13 14 15 16 17 18 19 A. No. According to METC s response to Staff s fourth discovery request, the terms open house and informational meeting have the same meaning. 12 Q. Act 30, MCL 460.568(1) specifies the requirements for posting a public notice for the opportunity to comment on the application for the CPCN. What media outlet(s) did METC use to publish the notice? A. METC published the Notice of Hearing and Notice of Opportunity to Comment in both The Kalamazoo Gazette and The Courier-Leader, both local newspapers in the greater Kalamazoo area. 13 Q. What dates were the notices published? A. Notice was published in The Kalamazoo Gazette on August 28, 2012, and in The Courier-Leader on August 24, 2012. 14 Q. What is the distribution area of The Kalamazoo Gazette? 9 Prefiled Direct Testimony and Exhibits of Gary R. Kirsh, pp 4-5. 10 See Staff Exhibit S-10 11 Prefiled Direct Testimony and Exhibits of Gary R. Kirsh, pp 4-5. 12 See Staff Exhibit S-10 13 http://efile.mpsc.state.mi.us/efile/docs/17041/0021.pdf. 14 http://efile.mpsc.state.mi.us/efile/docs/17041/0021.pdf. 7

DIRECT TESTIMONY OF LYNN M BECK CASE NUMBER U-17041 PART II 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 A. The Kalamazoo Gazette covers all of Kalamazoo and St. Joseph counties, and parts of Van Buren, Allegan, and Barry counties in southwest Michigan. A map of the distribution area is included as Exhibit S-2. Q. What is the distribution area of The Courier-Leader? A. The Courier-Leader is distributed in parts of Van Buren and Kalamazoo counties, in southwest Michigan. Information regarding the distribution of the Courier- Leader is included as Exhibit S-3. Q. Does the distribution area of these publications include the entire geographic area of the proposed transmission project? A. Yes. Q. According to the guidance under Act 30, MCL 460.568(1), Notice shall be sent to each affected municipality and each affected landowner on whose property a portion of the proposed major transmission line will be constructed. Has METC provided a list of property owners which they sent the notice to? A. Yes. The list is included as MPSC Docket No. 0016 for Case No. U-17041, dated 09/06/2012. 15 Q. Has the Commission Staff validated the above list for accuracy? How was that validation performed? A. Yes. Staff submitted discovery to METC requesting a map identifying the proposed and alternate routes, all parcel lines, and any permanent structures located within either route s right-of-way. METC provided a map which included 15 http://efile.mpsc.state.mi.us/efile/docs/17041/0016.pdf. 8

DIRECT TESTIMONY OF LYNN M BECK CASE NUMBER U-17041 PART II 1 the proposed and alternate route, all affected parcels, and their respective 2 owners. 16 Staff then validated the list with the map which METC provided. 3 4 5 6 7 8 9 10 11 Q. What date did they send the notice? A. METC sent the notice to affected municipalities and landowners on August 22, 2012. However, one landowner was sent notice on August 23, 2012. 17 Q. What is Staff s conclusion? A. Staff concludes that METC has satisfied the requirements as outlined by Act 30, MCL 460.566, MCL 460.567(2)(j), and MCL 460.568(1) in their CPCN application filing. Q. Does this complete your testimony? A. Yes, it does. 16 See Staff Exhibit S-4 17 http://efile.mpsc.state.mi.us/efile/docs/17041/0016.pdf. 9

S T A T E OF M I C H I G A N BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION * * * * In the matter of the application of ) Michigan Electric Transmission Company, LLC ) for a certificate of public convenience and ) Case No. U- 17041 necessity for the construction of a transmission ) line in Almena Township, Van Buren County, and ) Oshtemo Township, Kalamazoo County, Michigan. ) ) EXHIBITS OF LYNN M. BECK MICHIGAN PUBLIC SERVICE COMMISSION November 30, 2012

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Exhibit No.: S-3 Page: 1 of 1 Vineyard Press, Inc. 32280 E. Red Arrow Hwy, Paw Paw MI 49079 COURIER LEADER CIRCULATION ALL 490 LABELS ONLY 1091 NON 490 LABELS 160 LOCAL DROPS 725 COMPLIMENTARY 100 TOTAL CIRCULATION 2076 *(includes store drops as shown below) ********************************************************** BREAKDOWN BY ZIP CODES FOR 490 LABELS: Decatur 49045 26 Gobles 49055 25 plus*(50 store drops) Kalamazoo 49001 09 58 Lawrence 49064 88 plus*(140 store drops) Lawton 49065 152 plus*(120 store drops) Mattawan 49071 98 plus*(100 store drops) Paw Paw 49079 599 plus*(315 store drops) MISC 490 s 45 Total 490 Labels 1091 October 4, 2012

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S T A T E OF M I C H I G A N BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION * * * * In the matter of the application of ) Michigan Electric Transmission Company, LLC ) for a certificate of public convenience and ) Case No. U-17041 necessity for the construction of a transmission ) line in Almena Township, Van Buren County, and ) Oshtemo Township, Kalamazoo County Michigan. ) ) QUALIFICATIONS AND DIRECT TESTIMONY OF NAOMI J. SIMPSON MICHIGAN PUBLIC SERVICE COMMISSION November 30, 2012

QUALIFICATIONS OF NAOMI J. SIMPSON CASE NUMBER U-17041 PART I 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Q. Please state your full name and business address for the record. A. My name is Naomi J. Simpson, and my business address is the Michigan Public Service Commission s (Commission) temporary work site at 4300 West Saginaw Highway, Lansing, Michigan 48917. Q. By whom are you employed and in what capacity? A. I am employed in the Electric Reliability Division (ERD) of the Michigan Public Service Commission. I am an engineer in the Generation and Certificate of Need Section which is responsible for evaluating generation and transmission expansion plans. Q. Would you please outline your educational background? A. I earned a Bachelor of Science degree in Engineering with a major in Industrial Design from Michigan State University in 1997 and a Master of Science in Education with a major in Secondary Education from the University of Phoenix in 2010. Since joining the Commission, I have also attended several training programs sponsored by the National Association of Regulatory Utility Commissioners and Michigan State University, including the Annual Regulatory Studies Program (August 2011, 2012), the Advanced Regulatory Studies Program (October 2011, 2012), and Introduction to Public Utility Regulation and Ratemaking (May 2012). I have also attended the Distribution Efficiency Planning and Voltage Optimization conference sponsored by Electric Utility Consultants, Inc. Q. Would you please outline your professional experience? 1

QUALIFICATIONS OF NAOMI J. SIMPSON CASE NUMBER U-17041 PART I 1 2 3 In September 1994, I began working at General Motors Corporation as a student engineer where I evaluated systems and components related to meeting vehicle EPA emissions standards and fuel efficiency. 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 In February 1998, I began working for Delphi Automotive Corporation as a Design and Release Engineer for vehicle platform exhaust systems. My duties included design team management, production approval, and lean manufacturing implementation. Lean manufacturing of production systems included creating an optimization plan for manufacturing while taking into account material conservation and energy efficiency throughout the manufacturing process. In August 2000, I became the Change Management Coordinator for the Delphi Lansing Cockpit Plant with responsibility for plant wide change management, plant-wide SAP system coordination and training, lean manufacturing, and cost reduction. In November 2004, I was assigned the duties of Quality Manager with responsibility for plant wide first-time-quality goals, root cause analysis, supplier quality standards, and statistical defect analysis. In addition, I organized cost saving and lean manufacturing workshops which included energy conservation, material conservation, and energy efficiency throughout the manufacturing process. 20 21 22 23 In March 2011, I began working as a Public Utilities Engineer in the Smart Grid Section of the ERD for the Michigan Public Service Commission Staff (Staff). I was a member of the Smart Grid Collaborative as the co-chair of the Customer 2

QUALIFICATIONS OF NAOMI J. SIMPSON CASE NUMBER U-17041 PART I 1 2 3 4 5 6 7 8 9 10 11 Programs and Communications workgroup. I was also a contributing member of the Regulatory Policy and Grid Applications workgroups. I have provided extensive assistance with the analysis of Consumers Energy Company s Advanced Metering Infrastructure/ Smart Grid proposal and request for recovery in Case No. U-16794. I have assisted in writing several portions of the U-17000 Staff report to the Commission. I have provided assistance to Staff witnesses in Case No. U-17026, Indiana Michigan Power Company s application for a certificate of necessity. Q. Have you previously presented testimony before the Commission? A. Yes. I prepared and filed testimony for Case No. U-16801, Indiana Michigan Power Company electric rate case. 3

DIRECT TESTIMONY OF NAOMI J. SIMPSON CASE NUMBER U-17041 PART II 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Q. What is the purpose of your testimony? A. The purpose of my testimony is to present Staff s position in the matter of Michigan Electric Transmission Company s (METC) application for a Certificate of Public Convenience and Necessity (CPCN) pursuant to 1995 PA 30 (Act 30), MCL 460.561 et seq. Q. What specific elements of METC s application will be covered in your testimony? A. My testimony will cover the application filing requirements outlined in MCL 460.564 and MCL 460.567. Q. What approach did Staff use in conducting its review of METC s application for a CPNC in this case? A. Staff conducted a review of the METC transmission project through the Midwest Independent System Operator (MISO) Transmission Expansion Plan (MTEP) process; conducted a detailed review of the application filing and related documents pursuant to the specific requirements in Act 30; issued discovery and follow-up discovery requests for supplemental information related to the application from all parties as needed. Q. Are you sponsoring any exhibits in this proceeding? A. Yes. I am sponsoring Staff Exhibits S-4 through S-9 and S-11. 20 Exhibit No. Description 21 22 23 Exhibit S-4 METC response to Staff s third discovery request, question 1 Exhibit S-5 METC response to Staff s first discovery request, question 19 Exhibit S-6 METC response to Staff s first discovery request, question 4 4

DIRECT TESTIMONY OF NAOMI J. SIMPSON CASE NUMBER U-17041 PART II 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Exhibit S-7 METC response to Staff s first discovery request, question 21 Exhibit S-8 METC response to Staff s third discovery request, question 6 Exhibit S-9 METC response to Staff s first discovery request, question 39 Exhibit S-11 METC response to Staff s fourth discovery request, question 5 Q. Please generally describe the requirements outlined in Act 30, MCL 460.564. A. MCL 460.564 requires an applicant planning to construct a major transmission line in this state in the five (5) years after planning commences, the applicant shall submit a construction plan to the Commission. Further, MCL 460.564 identifies specific required information that shall be contained within the construction plan upon submittal. Q. Based upon Act 30 MCL 460.564, is METC required to include a construction plan with their application for the proposed transmission project? A. No. METC is not required to include a construction plan with their application. As indicated by Staff witness Steven Kulesia, METC is not proposing a major transmission line. MCL 460.569 establishes guidelines for a certificate other than a major transmission line. MCL 460.569 (3) specifically states that Section 4 does not apply to a transmission line for which a certificate is sought under this section. 1 Q. During the review of METC s application for the proposed transmission line project, did Staff do any computer modeling? 1 http://legislature.mi.gov/doc.aspx?mcl-460-569. 5

DIRECT TESTIMONY OF NAOMI J. SIMPSON CASE NUMBER U-17041 PART II 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 A. No. Staff does not have sufficient personnel and resources to perform transmission system computer modeling at the present time, however, MISO performs computer modeling studies and analysis for transmission projects approved through the MTEP process. Q. Does Act 30 describe specific information that is to be required in an application for a certificate? A. Yes. MCL 460.567 of Act 30 states the following: Sec. 7. (2) An application for a certificate shall contain all of the following: (a) The planned date for beginning construction. (b) A detailed description of the proposed major transmission line, its route, and its expected configuration and use. (c) A description and evaluation of 1 or more alternate major transmission line routes and a statement of why the proposed route was selected. (d) If a zoning ordinance prohibits or regulates the location or development of any portion of a proposed route, a description of the location and manner in which that zoning ordinance prohibits or regulates the location or construction of the proposed route. (e) The estimated overall cost of the proposed major transmission line. (f) Information supporting the need for the proposed major transmission line, including identification of known future wholesale users of the proposed major transmission line. 6

DIRECT TESTIMONY OF NAOMI J. SIMPSON CASE NUMBER U-17041 PART II 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 (g) Estimated quantifiable and nonquantifiable public benefits of the proposed major transmission line. (h) Estimated private benefits of the proposed major transmission line to the applicant or any legal entity that is affiliated with the applicant. (i) Information addressing potential effects of the proposed major transmission line on public health and safety. (j) A summary of all comments received at each public meeting and the applicant s response to those comments. (k) Information indicating that the proposed major transmission line will comply with all applicable state and federal environmental standards, laws, and rules. (l) Other information reasonably required by the commission pursuant to rule. Q. Can you explain the results of Staff s review of METC s compliance with each of these requirements outlined in MCL 460.567? A. Yes. Staff will explain the results of its review of each of the MCL 460.567 (2) requirements identified in Act 30 and their relationship to the specific elements of the application for certificate. Q. Did METC s application include a planned date for the beginning of construction? A. Yes. METC witness Jason Sutton states that construction will likely begin on or about April 1, 2014 pending the issuance of a certificate of public convenience and necessity from the Michigan Public Service Commission. 2 2 Prefiled Direct Testimony and Exhibits of Jason Sutton, p 7. 7

DIRECT TESTIMONY OF NAOMI J. SIMPSON CASE NUMBER U-17041 PART II 1 2 3 4 Q. Does Staff have a position with regards to METC s planned date for the beginning of construction as stated in its application? A. Yes. According to MCL 460.568 (4) [t]he commission shall grant or deny the application for a certificate not later than 1 year after the application s filing 5 date. 3 Therefore, Staff maintains that the April 1, 2014 date is a reasonable date 6 7 8 9 10 11 12 13 14 15 16 17 18 19 for the start of the proposed transmission project. Staff understands that there are project management activities such as planning, project design, and equipment procurement that precede the physical start of construction of the transmission project. Q. Has METC provided a detailed description of the proposed transmission line, its route, and its expected configuration and use? A. Yes. METC witness Carlo Capra describes the proposed transmission project as consisting of a new 345/138 kv substation and four 138 kv circuits on two double circuit transmission steel monopole lines. The new substation, identified as Weeds Lake Substation would be located on 41 acres in Almena Township. The substation will be designed to connect to the existing Argenta to Robinson Park 345 kv line. Power from the 345 kv line will flow down to the 138 kv system through one 345/138 kv transformer providing the Kalamazoo area a new power source from the south. 20 21 22 The two new double circuit pole lines will connect to the Weeds Lake substation and extend eastward in parallel approximately six miles. One double circuit pole 3 http://legislature.mi.gov/doc.aspx?mcl-act-30-of-1995. 8

DIRECT TESTIMONY OF NAOMI J. SIMPSON CASE NUMBER U-17041 PART II 1 2 3 4 5 6 7 8 9 10 11 line will connect to an existing 138 kv circuit between Bronco and 12 th Street substation creating two new 138 kv circuits. The other double circuit pole line will connect to an existing 138 kv circuit between Drake Road and Milham substations creating another two new 138 kv circuits. Further description can be found in METC witness Carlo Capra s testimony 4 and METC witness Jason Sutton s testimony. 5 Q. Did METC provide a detailed description of the purpose for the proposed transmission project and why it is needed? A. Yes. METC has provided testimony and exhibits supporting the project based upon system reliability. As stated in Mr. Capra s testimony, this project addresses NERC criteria TPL-002a 6 for the shutdown of one transformer plus the 12 contingent loss of a second. 7 [T]he proposed transmission line was identified as 13 14 15 16 17 18 19 20 the best solution to this planning criteria violation and submitted to the MISO for further evaluation in its 2009 MISO Transmission Expansion Plan (MTEP). 8 Q. Did METC consider other alternative transmission projects to address the above mentioned planning criteria violation? A. Yes. METC identified several other alternative solutions which were considered. Alternatives included different combinations of new substations, new transmission lines, and additional transformers. METC and MISO used transmission system data to evaluation alternatives. The proposed project was 4 Prefiled Direct Testimony and Exhibits of Carlo Capra, pp 4-5. 5 Prefiled Direct Testimony and Exhibits of Jason Sutton, pp 4-5. 6 http://www.nerc.com/files/tpl-002-0b.pdf. 7 Prefiled Direct Testimony and Exhibits of Carlo Capra, p 7. 8 Prefiled Direct Testimony and Exhibits of Carlo Capra, p 8. 9

DIRECT TESTIMONY OF NAOMI J. SIMPSON CASE NUMBER U-17041 PART II 1 2 3 4 5 6 7 8 found to be the most satisfactory solution to the planning criteria violation by providing for a balanced and reliable transmission system throughout the Kalamazoo area. The project was subsequently approved in MISO s MTEP 2009 process. Q. Has METC provided a detailed description of the preferred route? A. Yes. METC witness Stephen Thornhill describes the preferred route in detail. The routes are identified in Mr. Thornhill s testimony as R2 and R38. 9 Additionally, METC Exhibit A-11 (ST-2), Figure 4-2 contains an aerial map of 9 the preferred route. 10 METC also provided a more comprehensive aerial map in 10 11 12 13 14 response to a Staff discovery request. This aerial map is included as Exhibit S- 4. 11 This map illustrates the discrete parcels located along the proposed route. Q. Has METC provided a detailed description of at least one alternative route, and a statement of why the preferred route was selected? A. Yes, METC provided a detailed description of an alternative route in METC 15 witness Stephen Thornhill s testimony. 12 The alternative route is further 16 illustrated in Exhibit A-11 (ST-2), Figure 4-3 as an aerial map. 13 METC also 17 provided a more comprehensive aerial map in response to a Staff discovery 18 19 20 request. Staff has included this aerial map as Exhibit S-4. 14 the discrete parcels located along the proposed route. This map illustrates 9 Prefiled Direct Testimony and Exhibits of Stephen G. Thornhill, pp 15-18. 10 Prefiled Direct Testimony and Exhibits of Stephen G. Thornhill, Exhibit A-11(ST-2). 11 See Exhibit S-4. 12 Prefiled Direct Testimony and Exhibits of Stephen G. Thornhill, pp 20-22. 13 Prefiled Direct Testimony and Exhibits of Stephen G. Thornhill, Exhibit A-11(ST-2). 14 See Exhibit S-4. 10

DIRECT TESTIMONY OF NAOMI J. SIMPSON CASE NUMBER U-17041 PART II 1 2 3 4 5 6 During the evaluation of the preferred route and the alternative route, METC witness Mr. Thornhill states that the Preferred Route takes a more northerly path, slightly longer but providing additional distance from homes and equestrian facilities on the Thousand Oaks farm, crossing at the back of a large parcel rather than crossing the entrance way to a home and equestrian facility, and requiring less woodland clearing than the Alternate Route. 15 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Therefore, it is Staff s position that METC provided the rationale for selecting their preferred route, as well as a detailed description of one alternate route in their application. Q. Does Staff have any comments regarding the elimination of the southern route alternatives, originally identified in the routing study as route segments within the I-94 corridor, being dropped from consideration? A. METC has presented information addressing concerns with potential routes through the I-94 corridor. Several engineering challenges, construction and maintenance safety issues, and traffic flow concerns exist with a project in the I- 94 corridor. 16 METC s response to Staff s discovery request, included as Staff Exhibit S-4, 14 provides further insight to considerable obstacles along the I-94 corridor including existing water/sewer pipelines, adjacent residential and commercial development, communications facilities, road overpasses, and 15 Prefiled Direct Testimony and Exhibits of Stephen G. Thornhill, p 22. 16 Prefiled Direct Testimony and Exhibits of Stephen G. Thornhill, p 19. 11

DIRECT TESTIMONY OF NAOMI J. SIMPSON CASE NUMBER U-17041 PART II 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 potential future Michigan Department of Transportation plans for I-94 expansion resulting in clearance conflicts with a transmission line. 17 Q. What is Staff s position regarding METC s decision to remove routes through the I-94 corridor from consideration for the proposed transmission project? A. Based upon the information provided, Staff agrees with METC s decision to remove routes along the I-94 corridor from further consideration. Q. Does Staff have any comments with regard to METC s route selection process? A. Yes. The route selection process considered many social, environmental, and engineering impacts of the proposed transmission project. METC witness Stephen Thornhill s testimony highlights a number of federal, state, and local agencies involved in providing information about resources, potential issues, and land use within the study area. Criteria weights were established through consultation with local, state and federal agencies, property owner comments, 16 METC staff, and Burns & McDonnell s professional judgment. 18 Given that there 17 18 19 20 are potentially hundreds of routes that could suffice; the method of applying weighted criteria provides a systematic approach to the route screening process. Q. Is Staff aware of any zoning ordinance that prohibits or regulates the location or development of any portion of the proposed route? 17 See Exhibit S-5. 18 Prefiled Direct Testimony and Exhibits of Stephen G. Thornhill, Exhibit A-11(ST-2). 12

DIRECT TESTIMONY OF NAOMI J. SIMPSON CASE NUMBER U-17041 PART II 1 2 3 4 5 6 7 8 9 10 11 A. Yes, Staff is aware of Oshtemo Township Ordinance No. 525. This Township ordinance potentially impacts zoning relative to utility infrastructure location and development. Staff further notes that METC has addressed the impact of this ordinance through the testimony of METC witness Jason Sutton. As described in Mr. Sutton s testimony, Oshtemo Township amended its Utility Control ordinance, Number 114, with the adoption of Ordinance Number 525 on November 22, 2011. The Ordinance, as amended, contains specific requirements that would likely impact the location and development of the proposed transmission project. These requirements include: various plan submissions, Township Board approvals, Township Zoning Ordinance analysis, and undergrounding requirements. 19 12 13 14 15 16 17 18 19 20 21 In addition, Oshtemo Township witness Elizabeth Heiny-Cogswell s testimony identifies two ordinances that potentially impact the location and development of utility infrastructure by requiring development underground. The two ordinances are the Subdivision Site Condominium Ordinance No. 467 and the Cable System Regulatory Ordinance No. 371. 20 Q. Has METC included an estimated overall cost of the proposed transmission project? A. Yes. METC has provided an overall cost estimate for the project totaling $45 million dollars. Staff notes that this is an increase over the original MTEP 2009 19 Prefiled Direct Testimony and Exhibits of Jason Sutton, pp 8-10. 20 Prefiled Direct Testimony and Exhibits of Elizabeth Heiny-Cogswell, pp 13-14. 13

DIRECT TESTIMONY OF NAOMI J. SIMPSON CASE NUMBER U-17041 PART II 1 estimate of $39,800,002. METC sites several reasons for the revised cost 2 estimate presented in their application. 21 The substation estimates decreased with 3 4 5 6 7 8 9 10 11 12 the refined scope of work. However this was countered by an increased scope of work at the Argenta and Milham sites. In addition, overhead line costs have been further refined as to the overall number and cost of structures, wires, fiber optic communications wire, and related labor. METC was also able to incorporate new information from the routing study which further refined the cost estimates. Q. Has METC provided information supporting the need for the proposed transmission project, including identification of known future wholesale users of the proposed transmission line? A. Yes. METC has provided information supporting the project need based upon system reliability. The proposed transmission line allows METC to be compliant 13 with NERC s mandatory reliability standards. 22 METC s witness Mr. Capra has 14 15 provided Exhibit A-2 (CC-2) illustrating the potential overload scenarios of the current system. Additionally, METC has provided an estimated amount of time 16 required to conduct the replacement of a transformer. 23 This also provides insight 17 about the time required to replace a transformer if one should fail. 18 19 20 21 METC witness Mr. Capra s testimony also identifies a concern for other connection losses: the 345 kv sources into the Argenta station, the 138 kv facilities that bring the power down to the Kalamazoo area or the connection 21 See Exhibit S-6. 22 Prefiled Direct Testimony and Exhibits of Carlo Capra, p 6. 23 See Exhibit S-7. 14

DIRECT TESTIMONY OF NAOMI J. SIMPSON CASE NUMBER U-17041 PART II 1 between these two sets of facilities. 24 The Weeds Lake project would help to 2 3 4 reduce the risk of a widespread outage across the Kalamazoo area by providing an alternate source of power on the 138 kv system that services the Kalamazoo area. 25 5 6 7 8 9 10 11 12 13 14 15 16 17 METC identified Consumers Energy Company as the most likely wholesale user of the proposed transmission line, however, METC noted that all transmission customers taking service under the MISO open access transmission tariff are potential users of the proposed line. 26 Q. Has METC included an estimate of quantifiable and nonquantifiable public benefits of the proposed transmission line affiliated with its application? A. Yes, METC has included estimated quantifiable and nonquantifiable public benefits. According to METC witness Carlo Capra, The proposed transmission line allows METC to fully meet NERC s mandatory reliability standards. 27 Additionally, the proposed transmission project largely benefits the customers in the greater Kalamazoo and Battle Creek area by reducing the risk of rolling brownouts or blackouts 2829 and increasing the transfer capacity in the area at least 18 500MW. 30 The line will also benefit all METC customers by reducing system 24 Prefiled Direct Testimony and Exhibits of Carlo Capra, p 12. 25 Prefiled Direct Testimony and Exhibits of Carlo Capra, p 5. 26 Prefiled Direct Testimony and Exhibits of Carlo Capra, p 17. 27 Prefiled Direct Testimony and Exhibits of Carlo Capra, p 16. 28 Prefiled Direct Testimony and Exhibits of Carlo Capra, p 12. 29 See Exhibit S-11. 30 See Exhibit S-8. 15

DIRECT TESTIMONY OF NAOMI J. SIMPSON CASE NUMBER U-17041 PART II 1 2 3 4 5 loses during peak loading conditions therefore reducing the amount of power generation needed to meet demand. 31 Q. Has METC included an estimate of private benefits of the proposed major transmission line affiliated with its application? A. Yes. A discussion about private benefits of the proposed transmission project is 6 included in METC witness Carlo Capra s testimony. 32 The investment in the 7 8 9 10 11 12 13 14 proposed transmission project would be included in FERC-jurisdictional transmission rates. The investment would earn a rate of return set by FERC formula rates. Q. Has METC included information addressing potential effects of the proposed transmission project on public health and safety? A. Yes. METC has provided information addressing public health and safety. METC s witness Jason Sutton has indicated that METC s design and construction specifications meet or exceed the Institute of Electrical and Electronics 15 Engineers/NESC requirements. 33 According to Mr. Sutton, all of METC s 16 17 18 19 20 contractors are also required to meet all NESC and OSHA/MIOSHA standards. METC s field supervisors and engineers will monitor contractor compliance. Q. Did METC provide any other information that may relate to public health and safety beyond the physical design and construction of the transmission project? 31 Prefiled Direct Testimony and Exhibits of Carlo Capra, p 16. 32 Prefiled Direct Testimony and Exhibits of Carlo Capra, p 17. 33 Prefiled Direct Testimony and Exhibits of Jason Sutton, p 12. 16

DIRECT TESTIMONY OF NAOMI J. SIMPSON CASE NUMBER U-17041 PART II 1 2 A. Yes. METC witnesses J. Michael Silva, Dr. Mark Israel and Dr. H. Dwight Mercer provided testimony related to electric and magnetic fields (EMF). 3 4 5 6 7 8 9 10 Mr. Silva conducted measurements of magnetic fields in the area of the proposed transmission project and evaluated the EMF levels for the proposed lines. Mr. Silva concluded that [t]he EMF levels from the proposed transmission lines are below the levels recommended by credible international expert organizations for public exposures and the magnetic field levels from the line are within the range of EMF that people can experience every day in their normal living and working environments. 34 11 12 13 14 15 16 17 Dr. Israel conducted an evaluation of EMF research with a focus on laboratory studies on animals and cells relevant to cancer causation and development. Dr. Israel concluded that there is no reliable scientific basis to conclude that exposure to power frequency EMF from the proposed transmission line project will cause or contribute to the development of cancer in children or adults along the proposed project s route. 35 18 19 20 21 Dr. Mercer reviewed studies related to EMF and animal health. Dr. Mercer stated that in his opinion, there is no reliable scientific basis to conclude that the power frequency EMF from the proposed Weeds Lake 138 kv transmission line project 34 Prefiled Direct Testimony of J. Michael Silva, P.E., p 19. 35 Prefiled Direct Testimony of Mark A. Israel, M.D., p 12. 17

DIRECT TESTIMONY OF NAOMI J. SIMPSON CASE NUMBER U-17041 PART II 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 will cause or contribute to adverse health effects in animals living along the route of the transmission lines. 36 Q. Has METC provided Staff with a summary of all comments received at each public meeting and the applicant s response to those comments? A. Yes. As Staff witness Lynn Beck noted in her direct testimony, METC provided a summary of all comments received during the public meetings held in Almena Township on June 26, 2012 and Oshtemo Township on June 27, 2012. METC also provided Staff with a complete transcript of both public meetings in METC s response to Staff Discovery ST-METC-41. 37 Q. What is Staff s position with regards to the quality of the public comments summary provided in METC s application? A. After comparing the summary 38 to the transcript, 39 Staff notes that METC s summaries were over simplified or abbreviated, such that METC s summary of the questions and comments lost their originally intended meanings. Q. Does Staff offer any position regarding METC s responses to the public comments received during the public meetings? A. Although Act 30 does not require METC to respond to public comments, Staff s position is that METC should make every attempt to address commenter concerns in the interest of open and transparent communication. As noted in the public meeting summary and transcript, METC did not attempt to provide a response to several comments. Staff notes that METC did address many of these topics 36 Prefiled Direct Testimony of H. Dwight Mercer, PHD, DVM, p 13. 37 See Exhibit S-1. 38 Prefiled Direct Testimony and Exhibits of Gary R. Kirsh, Exhibit A-18 (GK-6). 39 See Exhibit S-1. 18

DIRECT TESTIMONY OF NAOMI J. SIMPSON CASE NUMBER U-17041 PART II 1 2 3 4 5 6 7 within their application, however the affected landowners would have benefited from complete responses to the questions posed during the public meeting process. Q. Has METC included information indicating that the proposed transmission project will comply with all applicable state and federal environmental standards, laws, and rules? A. Yes. METC has included a discussion of applicable environmental standards, 8 9 laws and rules as part of METC witness Steven Koster s Testimony. 40 goes on to explain METC s plan for complying with all environmental Mr. Koster 10 requirements. 41 METC also indicated in response to Staff discovery ST-METC- 11 12 13 14 15 16 17 18 19 20 039 that METC plans to coordinate with the Michigan Department of Natural Resources to develop the project in a manner compatible with a No Effect determination. 42 Q. Does Staff request any specific documentation of environmental regulations or associated permits and statements for the proposed transmission project? A. In the interest of transparency, Staff requests that METC electronically file all environmental permits and statements associated with the construction of the proposed transmission project on Docket No. U-17041. Electronically posting this information will provide assurance to the affected residents that METC has considered and adhered to environmental regulations within the construction area. 40 Prefiled Direct Testimony of Steven J. Koster, P.E., pp 6-8. 41 Prefiled Direct Testimony of Steven J. Koster, P.E., pp 8-11. 42 See Exhibit S-9. 19

DIRECT TESTIMONY OF NAOMI J. SIMPSON CASE NUMBER U-17041 PART II 1 2 3 4 5 6 7 8 9 10 Q. What is Staff s conclusion about METC s application pursuant to CPCN for the proposed transmission project? A. After conducting a comprehensive review and analysis of all information contained within METC s application and information provided by METC through discovery responses to all parties, Staff concludes that METC s application meets all requirements set forth in MCL 460.564, and MCL 460.567 given the provisions for proposed transmission lines other than major transmission lines as identified in MCL 460.569 (3). Q. Does this conclude your testimony? A. Yes. 11 20

S T A T E OF M I C H I G A N BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION * * * * In the matter of the application of ) Michigan Electric Transmission Company, LLC ) for a certificate of public convenience and ) Case No. U-17041 necessity for the construction of a transmission ) line in Almena Township, Van Buren County, and ) Oshtemo Township, Kalamazoo County Michigan. ) ) EXHIBITS OF NAOMI J. SIMPSON MICHIGAN PUBLIC SERVICE COMMISSION November 30, 2012

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S T A T E OF M I C H I G A N BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION * * * * In the matter of the application of ) Michigan Electric Transmission Company, LLC ) for a certificate of public convenience and ) Case No. U- 17041 necessity for the construction of a transmission ) line in Almena Township, Van Buren County, and ) Oshtemo Township, Kalamazoo County, Michigan. ) ) QUALIFICATIONS AND DIRECT TESTIMONY OF STEVEN E. KULESIA MICHIGAN PUBLIC SERVICE COMMISSION November 30, 2012

QUALIFICATIONS OF STEVEN E. KULESIA CASE NUMBER U-17041 PART I 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Q. Please state your full name and business address for the record. A. My name is Steven E. Kulesia, and my business address is the Michigan Public Service Commission s (Commission) temporary work site at 4300 West Saginaw, Lansing, Michigan 48917. Q. By whom are you employed and what is your position? A. I am employed by the Commission as Manager of the Generation and Certificate of Need Section in the Electric Reliability Division (ERD). The primary responsibility of the ERD is implementation and on-going management of Public Acts 295 and 286 of 2008, which require electric and gas providers to file plans to meet renewable energy and energy efficiency standards, and also covers provisions for application to the Commission for Certificates of Necessity for new electric generation construction, acquisition or purchase capacity by utilities. The ERD also handles applications for Certificates of Public Necessity and Convenience (CPNC) to construct transmission lines pursuant to 1995 PA 30. Q. Would you please outline your educational background? A. I obtained a Bachelor of Science degree in Resource Development from the College of Agriculture and Natural Resources at Michigan State University in 1987. Since joining the Commission, I have also attended utility training programs sponsored by the National Association of Regulatory Utility Commissioners and the Institute of Public Utilities Regulatory Research and Education at Michigan State University. Q. Would you please outline your professional experience? 1