STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION ***** In the matter of the application of ) THE DETROIT EDISON COMPANY for ) reconciliation of its power supply cost recovery plan for the 12-month period ended December 31, 2008 and to reconcile its pension equalization mechanism for the 12-month period ended December 31, 2008. ) ) ) Case No. U-15417-R ) ) At the July 1, 2010 meeting of the Michigan Public Service Commission in Lansing, Michigan. PRESENT: Hon. Orjiakor N. Isiogu, Chairman Hon. Monica Martinez, Commissioner Hon. Greg R. White, Commissioner ORDER History of Proceeding On March 31, 2009, The Detroit Edison Company (Detroit Edison) filed an application, with supporting testimony and exhibits, requesting reconciliation of its power supply cost recovery (PSCR) revenues and expenses for the 12-month period ended December 31, 2008, pursuant to 1982 PA 304, MCL 460.6j(12) et seq. (Act 304). Detroit Edison further requests reconciliation of its pension equalization mechanism (PEM) for the same period. Pursuant to due notice, a prehearing conference was held on May 6, 2009 before Administrative Law Judge Barbara A. Stump (ALJ). At the prehearing conference, the ALJ granted petitions to intervene to Attorney General Michael A. Cox (Attorney General) and the Residential Ratepayers Consortium (RRC). The Commission Staff (Staff) also participated in the proceedings. On December 9, 2009, the testimony of all witnesses was bound into the record and the parties waived cross-examination except for Angela Wojtowicz, a Supervisor in Detroit Edison’s Fossil Generation Organization. Detroit Edison, the Attorney General, the RRC, and the Staff filed briefs on February 12, 2010. Detroit Edison, the Attorney General, and the Staff filed reply briefs on February 26, 2010. The record consists of 201 pages of transcript and 29 exhibits. On March 22, 2010, the ALJ issued a Proposal for Decision (PFD). On April 5, 2010, exceptions were filed by the Attorney General and the RRC. Detroit Edison filed its replies to those exceptions on April 15, 2010. The 2005 PSCR Reconciliation During the 2005 PSCR reconciliation, the Commission had determined that an underrecovery by Detroit Edison from its commercial and industrial (C & I) customers has occurred. The Commission, therefore, ordered that Detroit Edison collect a surcharge for a 12-month period that ended in May 2008. In reconciling the recovery of the surcharge, Detroit Edison determined that it overrecovered from its C & I customers the total amount of $9,707,008, including interest. Consistent with the recent Commission practice of rolling over PSCR under/over-recoveries into subsequent PSCR proceedings, Detroit Edison has begun to refund the overrecovery to C & I customers in its 2009 PSCR factors. The 2008 PSCR Reconciliation Detroit Edison presented evidence that it experienced an underrecovery of $18,616,169 1 including interest for 2008. Additionally, Detroit Edison states that the total amount of the 2008 1 On January 25, 2010, the Commission issued an order in Case No. U-15002-R and determined that Detroit Edison’s 2007 PSCR underrecovery was $38,235,587 rather than the filed amount of $40,818,309. Applying the Commission’s prior determination in Case No. U-15002-R, the request for relief in Detroit Edison’s initial brief reflected the modification to $15,635,232. Page 2 U-15417-R PEM overcollection, after calculating monthly interest, equals $49,865,636. The only objection to Detroit Edison’s 2008 reconciliation relates to interruptible air conditioning (IAC) customers. On this point, Ms. Wojtowicz testified that the Detroit Edison’s PSCR fuel and purchased power expense of $1,360,207,000 was $54,766,000 below the forecast. 2 Tr 126-27. Ms. Wojtowicz further explained: There were no interruptions of customer load due to generation supply or transmission limitations. The interruptible air conditioners were not utilized to reduce demand. The Company generation output was the highest of the past 9 years. The average generation unit fuel cost of the Company’s resources was $17.50/MWh which was $34.62/MWh below the MISO day-ahead RTC market price of power at the Michigan Hub. The Company made almost 3,600 GWh of third party wholesale power sales with associated gross revenue of over $200 million which reduced PSCR customer’s costs. During the summer of 2008, the industrial interruptible customers were not required to curtail their interruptible load. The Company reliably served its customers by acquiring and utilizing a summer purchase power portfolio at a reasonable cost. This is evidenced by the fact that no firm customers were interrupted in 2008 and the ultimate cost of the overall portfolio was well below the actual MISO market price. 2 Tr 137. Based on the foregoing, Ms Wojtowicz stated that Detroit Edison’s electric system in 2008 was operated in a reliable, reasonable and prudent manner. Dr. Robert Loube, Vice President of an independent consulting firm retained by the RRC, disagreed, pointing to Detroit Edison’s failure to utilize interruptible air conditioning service during the summer months of 2008 to support a disallowance. Dr. Loube stated that Detroit Edison’s failure to interrupt air conditioning customers in June, July and August of 2008 caused excessive PSCR expenses, was unreasonable and imprudent, and recommended a disallowance of $1,930,571. 2 Tr 178. In reaching his recommendation, Dr. Loube analyzed the alleged fuel cost savings associated with what he determined to be the reasonable and prudent interruption for air conditioning customers during the summer months. Ultimately, Dr. Loube surmised, that purchased and net Page 3 U-15417-R interchange power costs should have been reduced during June, July, and August, resulting in a total PSCR reduction from $1,327,349,549 to $1,330,183,291. 2 Tr 177. Continuing its argument for disallowance, the RRC relies heavily on the Commission’s order in Case No. U-8880. The RRC points to specific language that reads: Interruptible rates give utilities the flexibility to reduce their fuel costs. During times of peak demand, utilities generally must begin operating their most expensive plants or purchasing additional power from high-cost sources. The availability of interruptible service allows utilities to avoid these higher costs. Dr. Loube explained that because the company paid approximately $14,700 per megawatt hour (MWh) to purchase summer capacity in 2008, the value of the interruptible service is approximately $2.6 million in terms of peak capacity. 2 Tr 174. When asked if it is possible to estimate the effect on energy savings of implementing the interruptible program in the summer of 2008, Dr. Loube stated that it is difficult to determine a precise estimate. Nevertheless, relying on the fact that weather is a key variable in determining air conditioning load, he developed a summer estimate of a maximum load shed of 66,109 MWh. 2 Tr 175. Dr. Loube explained how he developed his estimate. I began with Detroit Edison’s estimate that on the peak day, implementing the air conditioning interruptible program would save 1,262 MWH. The peak day was July 16, 2008 (footnote omitted). On July 16 the number of cooling degree days was 13. (footnote omitted) Dividing 1262 MWH by 13 cooling degree days produces a ratio of 97.08 MWH per degree day. Next I multiplied the cooling degree days for each day in June, July and August by the ratio of MWH to cooling degree days to determine the MWH savings for each day. The monthly total savings were 18,250 MWH for June, 25,434 MWH for July and 22,424 MWH for August. These calculations are shown in Exhibit RRC-4 (RL-4). 2 Tr 175. Dr. Loube estimated the savings based on fours hours of interruption per day to be 9,125 MWh for June, 12,717 MWh for July, and 11,212 MWh for August. 2 Tr 175. Page 4 U-15417-R The Attorney General supports the testimony of Dr. Loube and also recommends a disallowance of $1,930,571. The Attorney General supports his position with the terms and conditions in Tariff Sheet D-4.00 concerning interruptions, which are stated as follows: HOURS OF INTERRUPTION: Central air-conditioning and/or heat pump units only will be turned off by the Company by remote control on selected days for intervals of no longer than thirty minutes in any hour for no more than eight hours in any one day. Company interruptions may include interruptions for, but not limited to maintaining system integrity, making an emergency purchase, economic reasons, or when available system generation is insufficient to meet anticipated system load. The Attorney General emphasized that the tariff recognized “economic reasons” as a key basis for interrupting service. The Attorney General did not present a witness on the issue, instead relying on Dr. Loube’s testimony: As illustrated in Exhibit RRC-3 (RL-3), under-recovery occurred only in four months during 2008, and the overwhelming majority of the under-recovery occurred during the three summer months. According to Exhibit A-5 (KDJ-2) Revised, the under-recovery in the three summer months was ($103,552,775) representing 92 percent of the total amount under-recovered during 2008. However, it is precisely in the three summer months when it would be most effective to use the interruptible program as a load management tool to reduce energy costs. Thus, implementing the interruptible program would offset the under-recoveries that occurred during the summer months and reduce the PSCR cumulative under-recovery. 2 Tr 173-174. The Attorney General argues that there is no dispute that Detroit Edison bought electricity at day-ahead prices and that Detroit Edison knew the quantity and capacity of available IAC interruptions for the next day and could have used such interruptions in its day-ahead commitments to the Midwest Independent Transmission System Operator (MISO) to reduce PSCR costs at peak pricing times. In rebuttal, Detroit Edison presented the testimony of Richard P. Pospiech, Jr., its Senior Financial Analyst-Load Research. Mr. Pospiech criticized Dr. Loube’s determination regarding the potential maximum load shed because it was based on only one weather variable, cooling Page 5 U-15417-R degree days (CDD). Mr. Pospiech stated that air conditioning load that would be available for interruption is dependent on other variables such as daily maximum temperature, daily average temperature, previous day’s average temperature, heat buildup, day of the week, weekday, humidity, precipitation, etc. When factoring in these additional weather variables, a wide range of variance in the residential air conditioning load can be experienced for days having CDDs of equal value. 2 Tr 113-14. For example, Mr. Pospiech explained that if Dr. Loube had based his ratio on one of the 13 days during the summer of 2008 on which the air conditioning loads ranged from 625 to 1130 MWh for an eight-hour potential interruption period, and the CDD for each one of those 13 days was equal to 12, then he would have calculated ratios that would have ranged from 52.1 to 94.2 MWh per CDD compared to the ratio of 97.08 MWh he actually calculated. According to Mr. Pospiech, the variance in the air conditioning loads ranging from 625 to 1130 MWh for those 13 days proves the point that air conditioning load is dependent upon a wide range of weather variables. As a result, he opined that it is inappropriate to use the ratio of 97.08 MWh per CDD, because it is based solely on one weather variable, CDD, to project residential air conditioning load. 2 Tr 114. Mr. Pospiech testified that Dr. Loube failed to consider the extra cooling load that would come back onto the company’s electric system after the interruption cycle. He referred to this as the “rebound phenomenon” that occurs when IAC customers increase their air conditioning usage to compensate for the additional heat and humidity created by cycling their air conditioners through the eight-hour interruption period. Mr. Pospiech testified that analyzing all the different weather variables as well as the rebound phenomenon results in only five days during which interruption of Page 6 U-15417-R the IAC load could have been viable during the summer of 2008 (July 16, 17, 18, and 30 and August 22), which would have resulted in an estimated load reduction of only 6,040 MWh. 2 Tr. 114-115. The Staff generally supported the position of Detroit Edison for its 2008 PSCR and PEM reconciliations and recommended that the Commission approve the company’s application subject to the $2,582,722 reduction for the company’s 2007 PSCR underrecovery. The Staff presented no witnesses and did not address the RRC’s proposed disallowance. The ALJ found that Detroit Edison operated its system and incurred fuel and purchased and interchanged power costs in a reasonable and prudent manner. The ALJ recommended that the Commission issue an order consistent with those findings. The ALJ recognized that the only dispute among the parties to the proceedings was the issue on whether Detroit Edison’s decision not to interrupt customers in the IAC program during 2008 was reasonable and prudent. The ALJ found that “the primary purpose of the IAC program is to help Detroit Edison maintain system integrity, to make an emergency purchase, or when available system generation is insufficient to meet anticipated system load. The ALJ further stated that: Although the Company may also interrupt service for economic reasons, that is not the primary purpose of the program. In other words, the program does not exist simply to reduce PSCR expenses. Rather, the IAC tariff grants discretion to Detroit Edison for determining whether and when to interrupt service. PFD, p 17. The ALJ found that Detroit Edison exercised its discretion and used the IAC load as a capacity management tool, interrupting IAC customers when distribution, transmission, or generation would not have available to serve the load. Page 7 U-15417-R The ALJ was also persuaded that customers’ air conditioning use is dependent upon a wide range of weather variables and not on the one variable, the CDD. According to the ALJ, the evidence shows that use of these additional weather variables results in a wide range of variance in the air conditioning load for days that have CDDs of equal value. The ALJ found that Detroit Edison’s analysis demonstrated that there were only five days during the summer of 2008 for which interrupting the IAC load could, in hindsight, have been practical. The ALJ further agreed with Detroit Edison that the RRC appeared to suggest that the company test its customers’ interruption limits to determine how much customers will tolerate interruption of their air conditioning before they leave the rate. The ALJ concluded that even if Detroit Edison could produce such information or data, it would be speculative and, again, it would still be subject to numerous weather variables. Detroit Edison did present evidence to explain why there were no opportunities for using the IAC tariff to reduce PSCR costs. Again, using its more reliable multi-factor weather analysis, the company demonstrated that, under the circumstances that existed in 2008, there were only five days during the summer of 2008 that interrupting the IAC load would have been practical. In its exception to the PFD, the RRC argues that the complete failure of Detroit Edison to plan for and evaluate the opportunities to use the IAC tariff to reduce PSCR costs in 2008 is unreasonable and imprudent. The RRC disagrees with the ALJ in finding that the RRC’s evidentiary presentation was grounded on hindsight. The RRC maintains that it is the initial decision of Detroit Edison to outright reject the use of the IAC as a load management tool that is unreasonable and imprudent. Furthermore, the RRC argues, it makes no sense that Detroit Edison would not have evaluated and considered the potential merits of interrupting IAC customers to minimize PSCR costs. Page 8 U-15417-R The Attorney General’s exceptions mirror those of the RRC, pointing to the evidence that PSCR customers were burdened by the cost of the discount to IAC customers in 2008 by more than $9.5 million dollars, which could have been reduced by through the reasonable and prudent use of the IAC tariff to reduce PSCR costs. The Commission agrees with the ALJ’s well reasoned analysis. Specifically, the Commission is persuaded that the interruptible space-conditioning service rate tariff provides Detroit Edison with the discretion to utilize its program as a capacity management tool. Although the company may have interrupted the IAC customers for economic reasons in 2008, the Commission is not persuaded that challenges to Detroit Edison’s exercise of its discretion on that issue from the RRC and the Attorney General warrant a disallowance. Primarily, the Commission finds that the positions espoused by the RRC and the Attorney General are based on impermissible hindsight. In Act 304 reconciliation proceedings, the Commission has previously stated: It is often true that with the benefit of hindsight it is possible to show that money could have been saved. This is not the test that the Commission applies in determining the reasonable and prudence of gas purchase decisions. Gas supply decisions are judged on the reasonable foreseeable circumstances existing at the time the decisions were made and not on the results of those decisions. July 25, 2006 order, Case No. U-13960-R. The Commission finds that Detroit Edison’s decision not to interrupt the IAC load for economic reasons was justified. Detroit Edison used its discretion under the current tariff to serve its customers reliably. Thus, the Commission finds that Detroit Edison’s utilization of the IAC program in 2008 as a flexible real-time operating tool was reasonable and prudent. 2008 PA 295 does, however, charge the Commission with promoting load management under appropriate circumstances to reduce annual demand and to conserve energy. The IAC or other similar tariff appears to be an appropriate tool for determining the capability of load management to reduce Page 9 U-15417-R demand. Thus, for future proceedings, the Commission encourages all parties, especially Detroit Edison, to evaluate the potential for using the IAC, other tariffs, and similar load management techniques to determine how to utilize these devises for reducing peak demand, energy conservation, and overall customer savings. The Commission further finds that Detroit Edison’s application for reconciliation of its 2008 PSCR plan and reconciliation of its PEM as reasonable and prudent. Additionally, at the end of 2008, Detroit Edison had a PEM overrecovery, including interest, of $49,865,636, and the company shall include a reconciliation of its 2008 PEM overrecovery with its 2010 PSCR reconciliation filing. THEREFORE, IT IS ORDERED that: A. The Detroit Edison Company’s application for reconciliation of its power supply cost recovery plan for the period ended December 31, 2008, is approved as modified to reflect the reduction of the underrecovery from $18,372,583 to $15,635,232 resulting from the Commission’s January 25, 2010 order in Case No. U-15002-R. B. At the end of 2008, The Detroit Edison Company had a pension equalization mechanism overrecovery, including interest, of $49,865,636. C. The Detroit Edison Company is authorized to refund the pension equalization mechanism overrecovery using three-month credit factors, beginning with the August 2010 billing month, in accordance with the method and allocations shown in Exhibit A-8 and as calculated on Attachment A of this order, but recognizing that the interest rate used after 2008 is estimated. D. With its 2010 power supply cost reconciliation filing, The Detroit Edison Company shall include a reconciliation of its 2008 pension equalization mechanism overrecovery refund that Page 10 U-15417-R replaces monthly interest rate estimates with actual interest rates, shows the actual amount refunded, and calculates any residual amounts. E. Within 30 days The Detroit Edison Company shall file tariffs sheets substantially similar to Attachment B of the order. F. The 12-month surcharge to commercial & industrial customers, based on reconciling the recovery of the 2005 PSCR reconciliation period ending in May 2008, resulted in The Detroit Edison Company overrecovering $9,707,008, including interest, from commercial & industrial customers. This amount is currently being refunded by The Detroit Edison Company and shall be rolled into the 2009 PSCR proceeding. The Commission reserves jurisdiction and may issue further orders as necessary. Any party desiring to appeal this order must do so in the appropriate court within 30 days after issuance and notice of this order, under MCL 462.26. MICHIGAN PUBLIC SERVICE COMMISSION ________________________________________ Orjiakor N. Isiogu, Chairman By its action of July 1, 2010. ________________________________________ Monica Martinez, Commissioner ________________________________ Mary Jo Kunkle, Executive Secretary ________________________________________ Greg R. White, Commissioner Page 11 U-15417-R Attachment A U-15417-R Page 1 of 1 Detroit Edison Company 2008 PEM Reconciliation Calculation of Refund Billing Factors (a) U-15417-R Interest Calculation on year-end 2008 Over - Recovery ($) Line No. (Note 1/Note 2) (b) U-15417-R Reconciliation Over Recovery Interest ($) (c) U-15417-R Reconciliation Over Recovery Principal ($) (d) (e) (f) Total 2008 Over Recovery ($) Beginning Refund Month Estimated Quarterly PEM Sales MWH (Note 3) 52,956,833 Aug-10 11,600,088 1 2 3 $51,648,681 x 0.035757 x8.5 -------------------------------------- = 12 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Note 1: Short term interest rate = 3.5757% (Exh. A-8) Note 2: Interest in 2009 reflects annual compounding of interest for the year 2008. Principal, year end, 2008 : $ 49,865,636 (Exh. A-7) x 3.5757% = $ 1,783,046 = 2008 interest Principal, year end, 2008 2008 Interest Principal, year end, 2009 1,308,151 + $ + $ $ 51,648,682 = 49,865,636 1,783,046 51,648,682 Note 3: Monthly Sales taken from 2009 PSCR Plan Case No. U-15677. Sales are adjusted using 2008 Non-LCC sales factor = 49,346 / 50,716 = 0.9730 using 2009 PSCR Plan jurisdictional sales factor for 2008 = 49,644 / 52,465 = 0.9462 and using 2009 PSCR Plan jurisdictional sales factor for 2010 = 49,706 / 52,531 = 0.9462 Note 4: C & I Revenue factor of 58.30% and Sales factor of 64.84% Note 5: Electric Choice Revenue factor of 0.79% and Sales factor of 2.95% Note 6: Residential Revenue factor of 39.50% and Sales factor of 31.38% Note 7: Unmetered Revenue factor of 1.41%, Sales factor of 0.83%, and average revenue of $0.15/kWh (g) 2008 PEM Reconciliation C&I (i) 2008 PEM Reconciliation Residential (j) 2008 PEM Reconciliation UnMetered Mills/kWh (Note 4) (h) 2008 PEM Reconciliation Electric Choice Mills/kWh (Note 5) Mills/kWh (Note 6) % (Note 7) (4.10) (1.22) (5.75) -5.16% ATTACHMENT B M.P.S.C. No. 10 - Electric The Detroit Edison Company (PEM Credit pursuant to U-15417-R) Revised First Sheet No. C-76.01 Cancels Original Sheet No. C-76.01 (Continued from Sheet No. C-76.00) C9 SURCHARGES AND CREDITS APPLICABLE TO DELIVERY SERVICE: (CONTD) C9.7.5 PENSION EQUALIZATION MECHANISM PEM CREDIT On June 24, 2010, the MPSC issued an order in Case No. U-15417-R which approved the reconciliation of Detroit Edison’s 2008 Pension Equalization Mechanism PEM and authorized a three month PEM Credit to be applied to Residential, Commercial, Industrial and Governmental tariff customers for the August, September and October bill cycles. A PEM Credit of -0.575 cents per kWh will be applied to full service metered Residential tariff customers, -0.410 cents per kWh will be applied to full service metered Commercial, Industrial and Governmental tariff customers, -5.16% will be applied to unmetered customers, and -0.122 cents per kWh will be applied to Electric Choice customers. Issued ______________, 2010 D. G. Brudzynski Vice President Regulatory Affairs Detroit, Michigan Effective for bills rendered on and after August 1, 2010 Issued under authority of the Michigan Public Service Commission dated June 24, 2010 In Case No. U-15417-R M.P.S.C. No. 10 - Electric The Detroit Edison Company (Update PEM) Eleventh Revised Sheet No. C-77.00 Cancels Tenth Revised Sheet No. C-77.00 (Continued from Sheet No. C-76.00) SURCHARGES AND CREDITS APPLICABLE TO DELIVERY SERVICE: (CONTD) C9.8 Summary of Surcharges and Credits: Summary of surcharges and credits, pursuant to sub-rules C9.1, C9.2, C9.3, C9.4, C9.5 and C9.6 of this rule. Cents per kilowatthour or percent of base bill, unless otherwise noted Total Delivery NDS SBC SBTC CIS EOS(2) Surcharges PEM CREDIT (3) ¢/kWh ¢/kWh ¢/kWh ¢/kWh ¢/kWh ¢/kWh ¢/kWh Residential D1 Residential 0.1234 0.493 0.208 0.05 0.1081 (0.575) 0.4075 D1a Farm 0.1234 0.493 0.208 0.05 0.1081 (0.575) 0.4075 D1.1 Int. Space Conditioning 0.1234 0.493 0.208 0.05 0.1081 (0.575) 0.4075 D1.2 Time-of-Day 0.1234 0.493 0.208 0.05 0.1081 (0.575) 0.4075 D1.3 Senior Citizen 0.1234 0.493 0.208 0.05 0.1081 (0.575) 0.4075 D1.4 Time-of-Day 0.1234 0.493 0.208 0.05 0.1081 (0.575) 0.4075 D1.5 Supp. Space Heating 0.1234 0.493 0.208 0.05 0.1081 (0.575) 0.4075 D1.7 Time-of-Day 0.1234 0.493 0.208 0.05 0.1081 (0.575) 0.4075 D2 Space Heating 0.1234 0.493 0.208 0.05 0.1081 (0.575) 0.4075 D2a Farm 0.1234 0.493 0.208 0.05 0.1081 (0.575) 0.4075 D5 Water Heating 0.1234 0.493 0.208 0.05 0.1081 (0.575) 0.4075 D9 Outdoor Lighting 0.331% see note 1 see note 1 NA 0.9% -5.16% Commercial 0.208 0.05 See C9.6 D1.1 Int. Space Conditioning 0.1234 0.493 (0.410) 0.208 0.05 See C9.6 D1.7 Space Conditioning 0.1234 0.493 (0.410) D3 General Service 0.1234 0.493 0.208 0.05 See C9.6 (0.410) D3.1 Unmetered 0.848% see note 1 see note 1 NA 0.5% -5.16% D3.2 Educ. Inst. 0.1234 0.493 0.208 0.05 See C9.6 (0.410) D3.3 Interruptible 0.1234 0.493 0.208 0.05 See C9.6 (0.410) D3.4 Time-of-Day 0.1234 0.493 0.208 0.05 See C9.6 (0.410) D4 Large General Service 0.1234 0.493 0.208 0.05 See C9.6 (0.410) D5 Water Heating 0.1234 0.493 0.208 0.05 See C9.6 (0.410) D9 Outdoor Lighting 0.331% see note 1 see note 1 NA 0.5% -5.16% D10 Schools 0.1234 0.493 0.208 0.05 See C9.6 (0.410) R3 Standby Secondary 0.1234 0.493 0.208 0.05 See C9.6 (0.410) R7 Greenhouse Lighting 0.1234 0.493 0.208 0.05 See C9.6 (0.410) R8 Space Conditioning 0.1234 0.493 0.208 0.05 See C9.6 (0.410) Industrial D6 Primary Supply 0.1234 0.493 0.208 0.05 See C9.6 (0.410) D6.1 Alternative Primary 0.1234 0.493 0.208 0.05 See C9.6 (0.410) D6.2 Educ. Inst. 0.1234 0.493 0.208 0.05 See C9.6 (0.410) D7 Transitional Primary 0.1234 0.493 0.208 0.05 See C9.6 (0.410) D8 Interruptible Primary 0.1234 0.493 0.208 0.05 See C9.6 (0.410) R1.1 Metal Melting 0.1234 0.493 0.208 0.05 See C9.6 (0.410) R1.2 Electric Process Heating 0.1234 0.493 0.208 0.05 See C9.6 (0.410) R3 Standby Primary 0.1234 0.493 0.208 0.05 See C9.6 (0.410) R10 Interruptible Supply 0.1234 0.493 0.208 0.05 See C9.6 (0.410) Governmental E1 Streetlighting 0.265% see note 1 see note 1 NA 0.5% -5.16% E1.1 Energy Only 0.1234 0.493 0.208 0.05 See C9.6 (0.410) E2 Traffic Lights 1.427% see note 1 see note 1 NA 0.5% -5.16% E5 Secondary Pumping 0.1234 0.493 0.208 0.05 See C9.6 (0.410) Electric Choice EC2 Secondary 0.1234 0.493 0.208 0.05 See C9.6 -0.122 0.208 0.05 See C9.6 EC2 Primary 0.1234 0.493 -0.122 Special Contracts 0.208 0.05 See C9.6 LCC Per LCC 0.493 NA Notes: (1) The SBC and SBTC are included in this tariff’s base rates and will be separately accounted for by Detroit Edison for remittance to the Detroit Edison Securitization Funding L.L.C. (2) For EOS unmetered classes, % applies to base bill and surcharges excluding REPS and PEM Credit. (3) For PEM Credit unmetered classes, % applies to total bill net of taxes. C9 (Continued on Sheet No. C-78.00) Issued ____________, 2010 D. G. Brudzynski Vice President Regulatory Affairs Detroit, Michigan Effective for bills rendered on and after August 1, 2010 Issued under authority of the Michigan Public Service Commission dated June 24, 2010 In Case No. U-15417-R PROOF OF SERVICE STATE OF MICHIGAN ) Case No. U-15417-R County of Ingham ) Mignon Middlebrook being duly sworn, deposes and says that on July 1, 2010 A.D. she served a copy of the attached Commission orders by first class mail, postage prepaid, or by inter-departmental mail, to the persons as shown on the attached service list. Mignon Middlebrook Digitally signed by Mignon Middlebrook DN: cn=Mignon Middlebrook, c=US, email=middlebrookm@michigan.gov Date: 2010.07.02 09:08:15 -04'00' _______________________________________ Mignon Middlebrook Subscribed and sworn to before me This 1st day of July 2010 _________________________________ Gloria Pearl Jones Notary Public, Ingham County, MI My Commission Expires June 5, 2016 Service List U-15417-R Jon P. Christinidis The Detroit Edison Company One Energy Plaza Detroit MI 48226-1279 Donald E. Erickson Michigan Dept. of Attorney General Special Litigation Division, 7th Fl. 525 W. Ottawa Street, P.O. Box 30212 Lansing MI 48909 Vincent J. Leone Attorney General - PSD 6545 Mercantile Way Suite 15 Lansing MI 48911 David L. Shaltz 2270 Jolly Oak Road Suite 2A Okemos MI 48864-6932 Barbara A. Stump Michigan Public Service Commission 6545 Mercantile Way, Suite 14 Lansing MI 48911 The Detroit Edison Company Sandra K. Ennis One Energy Plaza Detroit MI 48226-1279