Exhibit 1
Analysis of
Wolverine Transmission System
Using the
Federal Energy Regulatory Commission
7-Factor Test
June 10, 2002
GDS Associates, Inc.
Engineers and Consultants
Purpose
In February 2002, GDS Associates Inc. (“GDS”) was requested by Wolverine
Power Supply Cooperative (“Wolverine” or “WPSC”) to evaluate the Wolverine
transmission facilities using the Federal Energy Regulatory Commission’s
(“Commission”) 7-Factor Test. Since Wolverine is not subject to state commission
regulation of its rates, rather than determining a retail/wholesale jurisdictional facilities
split, this analysis provides an assessment of whether Wolverine’s integrated
transmission voltage facilities actually perform a transmission function or a distribution
function according to the Commission’s 7-Factor Test. As part of this assignment, GDS
prepared and delivered a summary of the preliminary findings at the Wolverine Power
Supply Cooperative annual Power Supply Symposium held in Traverse City, Michigan on
March 4, 2002. This report more fully documents the results of GDS’ application of the
FERC 7-Factor Test to Wolverine’s transmission facilities.
Analysis Method
Detailed Information was gathered for this analysis through formal, written
requests to Wolverine. In addition, formal interviews and follow-up conversations were
conducted with key Wolverine personnel covering various functional areas, including
management, rates, planning, and operations. The gathered information included
details of:
• Background information for Wolverine and its Members
• Background information on the Michigan Municipal/Cooperative
Coordinated Pool (“MCCP”) and its Members
• WPSC system peak loads
• WPSC system generation
GDS Associates, Inc. Page 1
• Computer Aided Design format WPSC transmission one-line diagrams
• Computer Aided Design format WPSC breaker diagrams
• WPSC interconnection information
• 2003 summer peak load power flow model
• Member distribution substation lists
• Recent WPSC Regulatory filings
• Consumers Energy 7-Factor testimony
• MCCP operating characteristics and practice information
Based on this information, a detailed concept of all the uses and functions of the
WPSC transmission facilities was formed. This functional analysis was followed by a
detailed technical analysis of the 2003 summer peak power flow information to
determine a typical pattern of peak load use of the WPSC system. Finally, based on the
information developed from these analyses each of the Commission’s 7 factors were
evaluated.
GDS Associates, Inc. Page 2
Description of Wolverine Power Supply Cooperative
Wolverine is a Michigan generation and transmission (“G&T”) electric cooperative
providing wholesale service under long-term, all requirements contracts to its five
member cooperatives: Cherryland Electric Cooperative; Great Lakes Energy
Cooperative; Presque Isle Electric & Gas Co-op; Homeworks Tri-County Electric
Cooperative; and Wolverine Power Marketing Cooperative. Wolverine is regulated by
the Commission and has an approved Open Access Transmission Tariff (“OATT”) on
file. Wolverine transmits power on its OATT transmission system and sells this power at
wholesale to its member distribution cooperatives. Its four member distribution
cooperatives resell this power at retail to end-use customers located within northern
and western portions of Michigan’s lower peninsula. The service territories of the four
individual distribution cooperatives are clustered and spread out over approximately a
220-mile stretch along the western half of the lower peninsula of Michigan. The
territories of three of these cooperatives, Presque Isle, Cherryland and Homeworks Tri-
County are each contained in a distinct geographic area of the Wolverine transmission
region. The Great Lakes Distribution Cooperative, however, is comprised of distinct
areas which are not all contiguous and which span nearly the entire area of the
Wolverine transmission system. The individual member distribution cooperative service
territories are shown in the Wolverine Power Supply Cooperative map included as
Attachment 1.
GDS Associates, Inc. Page 3
Wolverine Transmission System Description
The following paragraphs provide the “raw material” that was analyzed with
respect to the Commission’s 7-Factor Test.
Wolverine’s electric power transmission voltage level facilities are comprised of
1,573 miles of 44 kV, 69 kV and 138 kV facilities. 382 miles of these facilities are radial
transmission facilities that provide transmission service to distribution substations. For
purposes of this 7-Factor analysis, these radial transmission facilities are assumed to
have, at the present time, the two characteristics of distribution that are described by
the 7-Factor Test indicators two and three (see page 10). On this basis, these radial
transmission facilities are assumed, for this analysis, to be used in local distribution. All
of the radial facilities operate at 69kV with the exception of two line segments, which
operate at 44kV. These radial facilities are shown color-coded on the map in
Attachment 2. Unless otherwise noted in the remaining discussion in this report,
reference to Wolverine’s “transmission system,” “networked …facilities,” or the
”Wolverine system” means the networked (non-radial) OATT transmission facilities.
The Wolverine OATT transmission facilities consist of 26 miles of 44 kV
transmission facilities, which are planned for conversion to 69 kV in 2003, 1,082 miles
of 69 kV facilities, and 82 miles of 138 kV facilities. The following table summarizes the
Wolverine facilities that are booked to transmission accounts.
Table 1
Voltage Mileage Function
69 kV/44 kV 382 Distribution
138 kV 82 Transmission
69 kV 1,082 Transmission
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44 kV1 26 Transmission
Attachment 3 provides the individual Wolverine line segments that comprise its
transmission system.
Wolverine’s transmission system integrates Wolverine’s generating resources
with its member distribution cooperative loads served from the member distribution
cooperative distribution systems. The following table indicates the number of
distribution cooperative substations in each area of the Wolverine system. It also
indicates the average load served from a distribution substation in each area. The
substations comprising this list are shown in detail in Attachment 4
Table 2
Wolverine Power Supply Cooperative
Distribution Substation Load
Distribution Number of Average Load
Cooperative Substations (MW)
Presque Isle 17 2.6
Cherryland 15 3.8
Homeworks Tri-County 21 2.6
Great Lakes North 29 3.3
Great Lakes West 8 2.4
Great Lakes South 33 3.1
Wolverine owns some transmission facilities that are not directly interconnected
with the Wolverine OATT transmission system. Wolverine is a joint owner of 64%
interest in the Consumers Energy (“Consumers” or “CE”) Tittabawassee-South
transmission line. Also, Wolverine has a 15 MW entitlement to transmission over the
entire Consumers Transmission grid as a result of a joint ownership interest in
1
The 44 kV is to be converted to 69 kV by the year 2003.
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Consumers’ Campbell Unit No. 3 plant. Neither of these Wolverine transmission
entitlements is included in this analysis.
Wolverine, along with eight members of Michigan Public Power Agency (MPPA)
comprise the Municipal/Cooperative Coordinated Pool (MCCP). The MCCP Agreement
between the MPPA and Wolverine establishes the operation of the pool. Four municipal
systems in the MCCP are directly interconnected with the Wolverine transmission
system. These four are Grand Haven, Lowell, Traverse City and Zeeland. The other
four MPPA members are not directly connected to the Wolverine transmission system,
but are interconnected with Wolverine through the Consumers transmission system.
These municipals are Charlevoix, Harbor Springs, Lansing and Petoskey. Wolverine
provides itself and the municipal members of the MCCP with transmission service over
its integrated transmission system to integrate MCCP resources with pool loads.
Wolverine owns and operates its integrated transmission system and has an OATT filed
with the Commission; however, the MCCP does not have a pool-wide OATT. The
following table indicates the Wolverine member locations of the direct connections
between the four municipals and the Wolverine transmission system.
Table 3
Direct Connections
Municipal Wolverine Member
Traverse City Cherryland
Grand Haven Great Lakes South
Zeeland Great Lakes South
Lowell Great Lakes South and
Homeworks Tri-County
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The Wolverine transmission system is directly interconnected with the
Consumers Energy system at 11 locations. The following table provides the
transmission interconnection points.
Table 4
Interconnection Points with
Consumers Energy
IP Voltage (kV)
Airport 138
Livingston 138
Oden 138
Alba 138
Grand Traverse 138
Pere Marquette 138
Redwood 138
Vestaburg 138
Sternberg 138
Blendon 138
Bradley 138
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MCCP Power Supply Resources
The following table summarizes the power supply resources of each MCCP
member with direct connection to the WPSC transmission system.
Table 5
MCCP Member Resource MW
Wolverine Gaylord 75
Wolverine Burnips 25
Wolverine Vestaburg 25
Wolverine Hersey 70
MPPA Members: Kalkaska 502
Petoskey, Charlevoix,
Harbor Springs &
Traverse City
City of Lansing Tower 20
Traverse City Traverse City 313
City of Zeeland Zeeland 24
All Off-System plus
Supplemental
2
Scheduled for commercial operation in November 2002.
3
Scheduled for retirement.
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Wolverine OATT Transmission Service
There are currently three WPSC OATT customers taking transmission service on
the Wolverine transmission system pursuant to five contracts for transmission service.
One such OATT customer is Kleber Limited Partnership (“Kleber”). Kleber owns and
transmits hydroelectric power from the Tower hydroelectric plant in Wolverine’s Presque
Isle area across Wolverine’s transmission system to the City of Lansing just off the
extreme south end of the Wolverine transmission system. This transmission service is
non-firm Point-to-Point transmission service.
The Great Lakes Energy member distribution cooperative takes long-term firm
Point-to-Point transmission service under Wolverine’s OATT to transmit power and
energy to its customer, Kalium. The Kalium contract expires in August 2002 and, if
renewed, will be for Network Integration Transmission Service on the Wolverine
system. Great Lakes Energy also takes network service to provide power and energy to
another customer, Ice Mountain.
Finally, Engage Energy has executed blanket firm and non-firm Point-to-Point
transmission service agreements under Wolverine’s OATT.
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The Commission’s 7-Factor Test
In Order No. 888, the Commission stated its exclusive jurisdiction over the rates,
terms, and conditions of unbundled retail transmission in interstate commerce, up to
the point of local distribution. With this assertion, the Commission also recognized the
need by utilities to know which regulator has jurisdiction over which facilities and
services in order to meet state and federal filing requirements. The Commission,
therefore, propounded several technical factors for determining what constitutes
“facilities used in local distribution.” To this end, the Commission proposed seven
indicators of local distribution to be evaluated on a case-by-case basis:
(1) Local distribution facilities are normally in close proximity to retail
customers.
(2) Local distribution facilities are primarily radial in character.
(3) Power flows into local distribution systems; it rarely, if ever, flows out.
(4) When power enters a local distribution system, it is not reconsigned or
transported on to some other market.
(5) Power entering a local distribution system is consumed in a comparatively
restricted geographical area.
(6) Meters are based at the transmission/local distribution interface to
measure flows into the local distribution system.
(7) Local distribution systems will be of reduced voltage.4
4
FERC Stats. & Regs. ¶ 31,036 at 31,771 (1996).
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The Purpose and Use of the 7-Factor Test
The Commission determined that the 7-Factor Test is specifically designed as an
aid in determining the line between transmission facilities and distribution facilities for
unbundled retail transmission by the public utility that previously provided bundled retail
service to the end-user. Thus, the Commission specifically designated the 7-Factor Test
for use in such applications as distinguished from unbundled wholesale transmission
service. Unbundled wholesale transmission service refers to transmission of electric
energy that is being sold for resale, or transmission to retail by intervening utilities.
The Commission further explained that “intervening utilities” are utilities between the
new retail generation supplier and the public utility that previously provided bundled
retail service to the end-user. In these two latter cases (unbundled wholesale
transmission and retail transmission by intervening utilities), the Commission’s case law
supports a “bright line” with respect to such transmission.
This bright line discussed by the Commission is already established for the
Wolverine transmission system. Pursuant to Michigan’s retail electric restructuring
program, Wolverine members have voluntarily begun offering unbundled services to the
largest retail customers. These Wolverine members own and operate the radial
distribution systems at 12 kV and 25 kV that provide the distribution service to the end-
user retail customers. The Wolverine-owned transmission facilities only provide
transmission of electricity that is being sold for resale. The Wolverine transmission
system is not and has never been used to provide bundled transmission and power
service to retail customers. Wolverine’s bright line, therefore, is the point that
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separates Wolverine transmission facilities from the distribution systems of its members
and other on-system wholesale customers.
7-Factor Test Analysis
Overview
The Wolverine member distribution cooperatives provide unbundled retail access
pursuant to Michigan’s restructuring program, while at the same time providing bundled
retail services over distribution facilities to their distinct end-user customers in their
local geographic areas. Each Wolverine member receives its wholesale power supply at
its interconnection points with the Wolverine transmission system. Thus, four separate
and distinct end-user retail systems operated by Wolverine’s member cooperatives are
supplied transmission service over the Wolverine transmission system.
In addition to this, four MCCP-member cities provide retail service to end-users
within the Wolverine system area. Each of these four cities is directly connected and
receives wholesale power from the Wolverine transmission system. Each of these four
cities comprises a separate and distinct retail market area.
Wolverine pools power from four generating plants previously described that are
interconnected to the Wolverine transmission system. In addition, Wolverine members
import power through the Wolverine system ties from jointly owned generating units
located on the Consumers’ transmission system. Also, several municipal members of
the MCCP are joint owners of a 50 MW generating unit at Kalkaska which will begin
commercial operation in November 2002. This generating unit is located on the WPSC
transmission system. Three of the Kalkaska joint owners are not directly
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interconnected to the Wolverine system and receive their Kalkaska entitlements as a
Wolverine system export. The off-system MPPA cities are Petoskey, Charlevoix and
Harbor Springs. The on-system municipal with Kalkaska entitlement is Traverse City,
which is located in the Cherryland area of the Wolverine system.
The Wolverine transmission system and each of these wholesale transmission
uses of the Wolverine transmission system is depicted and quantified in the figure of
Attachment 5 to this report. This Attachment represents a “snapshot” of the projected
2003 summer peak power flows on the WPSC transmission system. This schematic
drawing depicts six distinct “bubbles” that represent the principal member cooperative
end-use areas served by the Wolverine transmission system. Three of the bubbles are
dedicated to the Great Lakes distribution cooperative members’ distinct subareas of end
use, which span the full length of the Wolverine transmission system. The remaining
three distinct bubbles on this diagram represent the other three distribution cooperative
members’ end-use areas – Presque Isle, Cherryland, and Homeworks Tri-County. The
schematic also indicates the transmission ties with the Consumers Energy transmission
system. The ties located in one end-use area are aggregated together and shown as a
single tie between WPSC and CE.
This schematic also shows the four on-system municipal members’ end-use
areas. In addition, the diagram shows the generation and load in each of the WPSC
areas. Finally, all of the transmission facilities interconnecting the various sub-areas on
the WPSC system are aggregated together and shown as single interconnecting lines
between the appropriate areas and sub-areas of the WPSC system. The numbers on
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the diagram represent the MW flows of power to load, power from generation to the
system, and transmission system power flows among the WPSC areas and sub-areas
and between the sub-areas and CE and the municipal entities. This diagram graphically
demonstrates the network transmission functions and uses represented by the various
power flows on the Wolverine transmission system.
(1) Local distribution facilities are normally in close proximity to
retail customers.
This factor is intended to test the electrical distance between the ultimate end-
users or consumers of power and the various portions of the electrical transmission
system. In a radial transmission line, the path of the power flow is well defined and
distance traveled is easily and clearly determinable. When power flows through a
networked (“looped”) transmission system the power flows over all available paths and
a single distance traveled by power ultimately delivered to a single retail customer is, in
general, indeterminable.
The facts of the Wolverine transmission system are clear. The 44 kV, 69 kV and
128 kV transmission facilities are predominately a network system that span
approximately 220 miles. Power flows over this entire looped system to Wolverine
wholesale power purchasers. It travels simultaneously over all the parallel paths from
Wolverine’s and others’ sources of power to the delivery points to wholesale customers
of the power. The distance this power travels is the entire distance of the network
system.
There are no retail customers served directly by the Wolverine 69 kV and 138 kV
transmission facilities. This fact, coupled with the simultaneous use of all the
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networked paths of this system that spans large distances shows that none of the
Wolverine 44 kV, 69 kV or 138 kV facilities are in close proximity to retail customers.
Once power leaves this Wolverine transmission system, it enters lower voltage
radial facilities owned by distribution cooperatives or municipal utilities. The flow of
power on these facilities can be traced clearly to the retail end-users. The nature and
physical configuration of these lower voltage facilities is such that power only flows a
few miles before it reaches its retail destination. Generally, design considerations limit
the distance that power travels on such facilities to be, most often, less than about 20
miles. These facts support the conclusion that Wolverine’s networked 44 kV, 69 kV,
and 138 kV facilities are transmission facilities and not local distribution facilities.
(2) Local distribution facilities are primarily radial in nature.
Wolverine’s 44 kV, 69 kV and 138 kV transmission facilities are predominately
networked facilities and are not radial or radially operated (see Table 1). The
exceptions are approximately 382 miles of 44 kV and 69 kV facilities that are short
radial segments and that serve stations that transform voltage for ultimate delivery to
retail end-users. These radial segments are treated by Wolverine, consistent with the
newly established regional practice in Michigan, as distribution function facilities.
Wolverine’s member distribution cooperative-owned and the municipal-owned
systems are the radial delivery systems that convey the power from the Wolverine
facilities to the ultimate retail end-users. These facts support the conclusion that
Wolverine’s networked 44 kV, 69 kV, and 138 kV facilities are transmission facilities and
not local distribution facilities.
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(3) Power flows into distribution facilities, but rarely (if ever) flows
out.
All looped Wolverine facilities support two-way flow of power. Networked
facilities, by nature and design, transport power flexibly and reliably from an ever-
changing mix of resources. The system is designed to automatically redistribute flows
and provide back-up functions when system elements are unavailable. This
accommodation of continuously changing power supplies and back-up function requires
each element of the networked system to support continuously varying power flow.
The flow of power into and out of the Wolverine system can be examined at
three different system levels: (1) the points of interconnection to the Consumers
Energy system; (2) internal Wolverine system flows at the borders of the members’
end-use areas; and (3) the points of interconnection to the wholesale customers served
from Wolverine’s facilities.
Wolverine’s interconnection points are sometimes referred to as Points of
Delivery (“PODs”) or Points of Receipt (“PORs”). These labels are only useful when
isolating and examining certain specific functions of the Wolverine system. Such labels
do not adequately convey all of the functions or the nature of the Wolverine facilities.
For example, the Wolverine interconnection to CE can be referred to as PODs that
convey CE supplemental power purchases from the CE system to the Wolverine system.
Or, looking at it from Wolverine’s perspective, the same points can be viewed as
Wolverine system PORs for the same power flow. Wolverine, however, can also make
opportunistic sales from its on-system resources. For this function, the CE
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interconnection points reverse flow and change their labels. For opportunity sales of
Wolverine power, the CE interconnection points become PODs from Wolverine to CE.
Indeed, several of the WPSC/CE interconnection points from time to time show
flows from Wolverine to CE. The figure in Attachment 5 shows power flows at peak
load from Wolverine to CE at Airport and Vestaburg. Wolverine representatives report
that the Airport flows have been recorded up to about 30 MW into CE, and Vestaburg
flows up to about 20 MW. In addition, the flows between Wolverine’s Great Lakes
South area and CE show the aggregate of the CE/Wolverine flows at four
interconnections. Wolverine reports that the Sternberg interconnection has been
observed to flow up to about 10 MW into CE. These flows to CE demonstrate that the
Wolverine system provides two-way flow of power.
Additionally, the Wolverine facilities provide service to six distinct geographic
areas of the four distribution cooperative members. One member, Great Lakes, serves
a larger area, which is comprised of three separate end-user areas. These six distinct
end-user areas are depicted by the “bubbles” shown in Attachment 5. Each of these
bubbles represent a geographic portion of the Wolverine 44 kV, 69 kV and 138 kV
network facilities that convey power from sources to wholesale customers and then on
to ultimate end-users. Once power enters a bubble, it is approaching the member’s
and others’ local end-user facilities that are electrically and geographically in the vicinity
of the ultimate end-users. If the Wolverine facilities only supported one-way flow of
power, once power entered these distinct end-user areas, it would not leave. The
figure shows power flowing into and out of Wolverine’s end-user areas. This graphically
GDS Associates, Inc. Page 17
depicts the Wolverine system support for two-way power flow in this peak load
modeling scenario.
The third level of the Wolverine system that can be examined for power flow
characteristics is the level of interconnection to the ultimate end-user systems. This
level shows that power flows from Wolverine 44 kV, 69 kV, and 138 kV facilities at
these PODs to distribution and rarely, if ever, flows in the opposite direction. This
demonstrates that the Wolverine transmission/distribution interface is the POD to the
end-user systems. All of the facts set forth in this section support the conclusion that
Wolverine’s networked 44 kV, 69 kV, and 138 kV facilities are transmission facilities and
not local distribution facilities.
(4) When power enters a local distribution system, it is not
reconsigned or transported on to some other market.
The Wolverine local markets are defined by Wolverine’s individual member
distribution cooperative end-use areas and Wolverine’s on-system municipal end-use
areas. The point in the system where power can be identified as entering one of these
final destination markets is that point where it can be defined as reaching its final
destination and not transported to some other market beyond that point. The power
that flows on Wolverine’s 44 kV, 69 kV and 138 kV facilities is 100% wholesale power
that cannot be identified as related to only a single specific end-user destination
market. The Wolverine transmission facilities pool the power that ultimately is delivered
to the end-user markets. The pooled power is that of the MCCP control area which
consists of Wolverine’s four member distribution cooperatives, its four on-system
municipal members, and its four off-system municipal members. Some of the power
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pooled by these entities is injected directly from generating units into the Wolverine
transmission system. Some of the power is received from the CE ties to the Wolverine
transmission system. Approximately 310 MW of the pooled power is obtained from
Wolverine member off-system resources and is transmission to the members by
Wolverine facilities. Approximately 215 MW of Wolverine member on-system resources
are pooled by these entities. The on-system power supply is transmitted by the
Wolverine facilities to the directly connected members by the Wolverine system.
Likewise, the eight municipal systems pool on-system hydro generation, and in
2003 will begin pooling 50 MW of new on-system generation to four of the municipal
systems. Of these four municipal systems, one of them on-system and three of them
off-system.
Additionally, the Wolverine system supports opportunistic off-system sales of
available energy. The markets for the Wolverine system power flow are many and
varied. Finally, the Wolverine member systems voluntarily are open to Michigan’s retail
choice program and offer wheeling services to the largest retail customers.
The Wolverine transmission system, therefore, pools and facilitates the
transmission of resources among many entities that serve distinct market areas. These
facts support the conclusion that Wolverine’s networked 44 kV, 69 kV, and 138 kV
facilities are transmission facilities and not local distribution facilities.
(5) Power entering a local distribution system is consumed in a
comparatively restricted geographical area.
The discussion associated with the preceding four points defines the ways in
which the Wolverine transmission system is used to convey power over a 220-mile
GDS Associates, Inc. Page 19
stretch of the State of Michigan. This consists of approximately 1,200 miles of
networked transmission facilities that provide no end-user service directly to retail
customers. The power flows into and out of these facilities, which support bi-directional
flows. The system is used to convey power for the varied uses of the MCCP control
area and accommodates Michigan retail wheeling. Only when power leaves this system
and is conveyed to the distribution facilities of the member systems and others does the
power finally enter a restricted geographic area where it is ultimately consumed by end-
users. These facts support the conclusion that Wolverine’s networked 44 kV, 69 kV,
and 138 kV facilities are transmission facilities and not local distribution facilities.
(6) Meters are based at the transmission/local distribution interface
to measure flows into the local distribution system.
The Wolverine system wholesale delivery meters are located at the distribution
substation interconnection points with the 44 kV, 69 kV, and 138 kV facilities. These
meters measure the flow from the Wolverine transmission facilities and into the end-
user distribution facilities for ultimate consumption. The Wolverine 69 kV transmission
substations are equipped with supervisory control and data acquisition (“SCADA”)
meters, which are used for system control and monitoring of the two-way flow at those
transmission substations. These SCADA meter values are telemetered to a Wolverine
control center which monitors facility flows for system control. The wholesale delivery
meters at the distribution substations are the meters that measure the one-way flow of
power to the end-user systems and are the points that define the transition between
transmission and distribution. These facts support the conclusion that Wolverine’s
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networked 44 kV, 69 kV, and 138 kV facilities are transmission facilities and not local
distribution facilities.
(7) Local distribution systems will be of reduced voltage.
All of the member and other entity end-user systems that convey power to
ultimate destination markets within limited geographic areas are 12 kV and 25 kV
distribution voltages. These voltages are traditionally considered distribution level and
are reduced from the 44 kV, 69 kV, and 138 kV voltages that are Wolverine’s
transmission level voltages. These facts support the conclusion that Wolverine’s
networked 44 kV, 69 kV, and 138 kV facilities are transmission facilities and not local
distribution facilities.
Conclusion:
The Wolverine OATT transmission facilities operated at 44 kV, 69 kV and 138 kV
perform transmission functions for the transmission of wholesale power on behalf of
multiple customers on and off the WPSC system. Wolverine members have voluntarily
opened their system in advance of statutory requirements to support the State of
Michigan’s recently commenced retail open access program. In addition, the functional
and technical analysis with respect to each of the Commission’s 7 factors supports the
classification of these WPSC system facilities as transmission facilities and not local
distribution facilities.
GDS Associates, Inc. Page 21
Attachment 2
C
C
Attachment 3
page 1 of 3
TRANSMISSION LINE SEGMENT VOLTAGE MILES
ALTONA - MORLEY 69 10.37
Bagley Tap 69 0.1
BASS LAKE - WOLF LAKE 69 11.14
BLACK LAKE - HAMMOND BAY 69 12.78
BOYNE CITY - HAYES 69 11.85
BROHAM TAP 69 1.34
BROOKS TAP 69 3.22
Canadian Lakes JCT. - Canadian Lakes 69 1
CARSON CITY TAP 69 5.63
CENTRAL LAKE - GRAVES CROSSING 69 7.9
CHESTER - EATON RAPIDS 69 18.41
COLFAX TAP 69 0.08
COPEMISH - THOMPSONVILLE 69 8.86
DRENTH TAP 69 0.24
EAST BAY - BATES 69 5.89
EAST JORDAN - EASTPORT 69 11.42
EAST JORDAN JCT. - EAST JORDAN 69 2.17
EASTPORT - BARNARD 69 9.93
FINGERBOARD TAP 69 6.58
FOUNTAIN TAP 69 6.41
FOWLER - GREENBUSH 69 9.04
GARFIELD - TIMBERLEE 69 3.9
GOODWIN JCT. - GOODWIN 69 0.37
GRAND LEDGE TAP 69 3.86
GRAWN - INTELOCHEN JCT. 69 3.84
HAGENSVILLE TAP 69 5.7
HARBOR - WEST TRAVERSE 69 10.64
HILLMAN - BEAVER LAKE 69 13.12
HINTON TAP 69 0.42
INTERLOCHEN TAP 69 1.05
JOHANNESBURG TAP 69 6.84
KALKASKA TAP 69 2.13
KARLIN TAP 69 0.15
LAKE ANN-INTERLOCHEN JCT. 69 8.71
LAKE LEELANAU - SUTTONS BAY JCT. 69 4.32
LEBANON TAP 69 4.66
LEROY - HARTWICK 69 9.7
LEROY - TUSTIN 69 7.67
LEWISTON - LOVELLS 69 15.19
LINCOLN JCT. - LINCOLN 69 8.13
LOWELL TAP 69 5.28
MIDDLEVILLE TAP 69 0.42
NEW ERA TAP 69 0.07
ODEN - HARBOR 69 3.31
OSCEOLA - OSCEOLA JCT. 69 0.74
OTSEGO TAP 69 7.76
PARIS TAP 69 1.26
PELLSTON - CROSS VILLAGE 69 9.08
PIERSON JCT. - PIERSON 69 1.91
POSEN - GRAND LAKE 69 9.89
SEBEWA TAP 69 0.01
SILVER LAKE - LEMON JCT. 69 6.28
SOUTH AIRPORT TAP 69 0.08
SOUTH BOARDMAN - FIFE LAKE 69 7.95
SUTTONS BAY TAP 69 2.62
TIMBERLEE - SUTTONS BAY JCT. 69 8.45
TOWER - BLACK LAKE 69 4.21
VICTORY TAP 69 4.95
WEIDMAN - STEVENSON 69 11.45
WESTPHALIA TAP 69 3.87
WESTWOOD - CLAM RIVER 69 11.42
WESTWOOD - MANISTEE RIVER 69 11.93
WINN TAP 69 3.16
SCOTTVILLE - RIVERTON 44 6.51
WEARE TAP 44 4.72
AIRPORT 138 - CONSUMERS ENERGY 138 1.32
ALBA TO CONSUMERS ENERGY 138 138 0.36
ATLANTA - AIRPORT 138 138 30.62
BRADLEY TIE 138 138 0.51
LAKE COUNTY - PERE MARQUETTE 138 18.37
LIVINGSTON - ATLANTA 138 138 31.17
ADVANCE - ADVANCE D 69 0.91
Attachment 3
page 2 of 3
ADVANCE - ELMIRA 69 16.26
ADVANCE - WILSON 69 4.7
ADVANCE D - EAST JORDAN JCT. 69 4.66
AIRPORT - POSEN 69 16.21
ALBA - MANCELONA 69 4.51
ALLENDALE - BLENDON 69 2.11
ALPINE TO GAYLORD PLANT 69 3.41
ALTONA - HINTON JCT. 69 4.7
ALTONA - VESTABURG 69 19.52
ATLANTA - AVALON 69 12.16
AVALON - HILLMAN 69 9.58
BAGLEY - GAYLORD 69 3.32
BALDWIN - PLAINS JCT. 69 6.94
BASELINE JCT. - LEMON JCT. 69 2.39
BASS LAKE - BRETHREN 69 18.11
BLENDON - FAIRVIEW 69 7.49
BOYNE CITY - PETOSKEY 69 10.48
BURNIPS - DRENTH JCT. 69 11.3
BURNIPS - GOODWIN JCT. 69 13.09
BURNIPS - LOWELL JCT. 69 39.06
CADILLAC - LEROY 138 69 19.3
CANADA CREEK - ATLANTA 69 13.84
CASNOVIA - CEDAR SPRINGS 69 10.45
CASNOVIA - STERNBERG 69 19.39
CEDAR SPRINGS - HOWARD CITY 69 14.88
CHEBOYGAN - MULLET LAKE 69 9.38
CHESTER - MULLIKEN JCT. 69 9.18
CHESTER - VERMONTVILLE 69 10.69
COLFAX - WALKERVILLE 69 2.36
COPEMISH - BRETHREN 69 10.81
COPEMISH - KARLIN JCT. 69 13.59
CRAWFORD - VESTABURG 69 8.99
DEERFIELD - WINN JCT. 69 7.04
EAST BAY - POTTER 69 4.32
EAST JORDAN JCT. - GRAVES CROSS 69 7.14
ELMIRA - ALPINE 69 3.61
FAIRVIEW - DRENTH JCT. 69 1.1
FAIRVIEW - ZEELAND PLANT 69 0.56
FOWLER - ESSEX JCT. 69 4.71
FOWLER-WESTPHAILIA JCT. 69 10.13
GARFIELD - TRAVERSE CITY BAYSIDE 69 3.72
GAYLORD - JOHANNESBURG JCT. 69 7.43
GAYLORD PLANT TO BAGLEY 69 4
GOODWIN JCT. - WAYLAND 69 4.58
GRAND HAVEN - OSIPOFF 69 2.94
GRAND TRAVERSE - GRAWN 69 5.21
GRAVES CROSSING - ALBA 69 4.72
GRAWN - GARFIELD 69 7.87
GRAWN - KARLIN JCT. 69 6.61
HART - BASELINE JCT. 69 5.56
HART - REDWOOD 69 1.59
HART - WALKERVILLE 69 9.49
HASTINGS - GUN LAKE JCT. 69 5.61
HAWKS - HAGENSVILLE JCT. 69 7.43
HERSEY - ALTONA 69 24.02
HERSEY - LEROY 69 14.3
HERSEY - LEROY JCT. 69 14.59
HERSEY - LINCOLN JCT. 69 3.05
HERSEY - OSCEOLA JCT. 69 4.02
HERSEY - PARIS JCT. 69 3.51
HESPERIA - RODGERS 69 13.96
HILLMAN - AIRPORT 69 69 8.76
HINTON JCT. - PIERSON JCT. 69 9.25
HOWARD CITY - PIERSON JCT. 69 9.14
LAKE COUNTY - BASS LAKE 69 8.35
LAKE COUNTY- FOUNTAIN JCT. 69 6.25
LEWISTON - ATLANTA 69 12.02
LEWISTON - JOHANNESBURG JCT. 69 10.19
LINCOLN JCT. - BALDWIN 69 16.47
MANCELONA - WESTWOOD 69 6.7
MARTINY - OSCEOLA JCT. 69 10.69
MARTINY - WEIDMAN 69 8.37
MIDDLEVILLE JCT - WAYLAND 69 10.69
MILLERSBURG - HAWKS 69 9.53
Attachment 3
page 3 of 3
MULLET LAKE - FINGERBOARD JCT. 69 9.75
NEW ERA JCT. - LEMON JCT. 69 1.15
NEWAYGO - CASNOVIA 69 9.86
NORTH SHADE - ESSEX JCT. 69 3.88
NORTH SHADE - VESTABURG 69 19.29
ODEN - PELLSTON 69 11.05
ODESSA - MIDDLEVILLE JCT. 69 19.79
ODESSA TO SEBEWA JCT. 69 3.37
ONAWAY - CANADA CREEK 69 9.08
OSIPOFF - ALLENDALE 69 14.53
PARIS JCT. - BROHMAN JCT. 69 14.73
PELLSTON - CHEBOYGAN 69 18.43
PETOSKEY - ODEN 69 5.24
PLAINS JCT. - COLFAX 69 10.24
PLAINS JCT. - STAR LAKE 69 7.02
PORTLAND - LOWELL JCT. 69 20.82
PORTLAND - MULLIKEN JCT. 69 6.4
PORTLAND - WESTPHALIA JCT. 69 8.73
PORTLAND -SEBEWA JCT. 69 6.85
POSEN - HAGENSVILLE JCT. 69 6.37
POTTER - GRAND TRAVERSE 69 69 2.24
SCOTTVILLE - VICTORY JCT. 69 2.21
SHELBY - NEW ERA JCT. 69 4.21
SHELBY - RODGERS 69 5
SOUTH BOARDMAN - CADILLAC 69 28.03
SOUTH BOARDMAN - EAST BAY 69 15.93
SOUTH BOARDMAN - KALKASKA JCT. 69 8.09
STAR LAKE - LAKE COUNTY 69 7.72
STERNBERG - GRAND HAVEN 69 9.67
TOWER - FINGERBOARD JCT. 69 2.63
TOWER - MILLERSBURG 69 12.31
TOWER - ONAWAY 69 4.82
VERMONTVILLE - HASTINGS 69 23.53
VICTORY JCT. - FOUNTAIN JCT. 69 6.96
WAYLAND - GUN LAKE JCT. 69 5.58
WEIDMAN - DEERFIELD 69 9.7
WESTWOOD - KALKASKA JCT. 69 6.95
WHITE CLOUD - BROHMAN JCT. 69 8.09
WHITE CLOUD - HESPERIA 69 22.12
WHITE CLOUD - NEWAYGO 69 12.99
WILSON - BOYNE CITY 69 3.04
WINN JCT. - CRAWFORD 69 0.71
EDEN - CRYSTAL VALLEY JCT. 44 7.45
HART - CITY OF HART 44 4
HART - CRYSTAL VALLEY JCT. 44 5.18
KEWADIN - MILTON 44 3.45
SCOTTVILLE - EDEN 44 6.12
HARTWICK - MARION 12 9.71
TOTAL 1572.75
ATTACHMENT 4
Wolverine Power Supply Cooperative
List of Distribution Substations Served from Wolverine OATT Transmission Facilities
Presque Isle: Load # Great Lakes North: Load # Great Lakes South: Load #
Atlanta 3 Advance 2.1 Allendale 3.4
Airport 1.5 Alpine 4.6 Baseline 3.1
Avalon 2.4 Barnard 2 Brohman 2.7
Beaver Island (see GLN) Boyne City 5 Baldwin 4.2
Black Lake 3.2 Beaver Island 1.4 Brooks 3.2
Canada Creek 2 Bagley 4.1 Burnips 3.6
Cheboygan 5.4 Clam River 3.3 Cadallac 0.7
Fingerboard 2.7 Cross Village 2.4 Colfax 5
Grand Lake 1.7 Central Lake 2.9 Cedar Springs 2.2
Hammond Bay 1.6 East Jordan 2.2 Casnovia 1.8
Hagenville 2 Elmira 5.3 Drenthe 3.1
Hawks 2 East Port 3.2 Howard City 3.1
Hillman 2.4 Fife Lake 2.1 Hesperia 2.5
Lewiston 6.8 Gaylord #1 1.7 Hastings 3.2
Millersburg 1.1 Gaylord #2 3.5 Hart 1.9
Mullet Lake 2.7 Goodwin 0.9 Hartwick 3.5
Onaway 1.8 Hayes 3 Lincoln 1.7
Posen 2.1 Harbor #1 & #2 6.2 Leroy 2.5
17 Johannesburg 2.7 Middleville 2.7
CherryLand: Kalkaska 2 Morley 3.2
Bates 4.7 Lovells 5.6 New Era 2.9
Brethren 1.4 Mancelona 3.4 Newaygo 2
Copemish 2 Manistee River 4.6 Osceola 6.1
East Bay 6 Pellston 2.7 Otsego 2.5
Garfield 7.7 Petoskey 6.1 Paris 1.7
Grawn 6.8 South Boardman subsite 3 Rodgers 3.7
Interlochen 4 Wilson 3.4 Shelby 2.7
Karlin 1 West Traverse 2.9 Silver Lake 6.3
Lake Ann 4.3 Westwood 3.2 Tustin 2.2
Lake Leenanau 3.5 29 White Cloud 5
Potter 3.6 Great Lakes West: Wayland 4.4
South Airport 4.3 Bass Lake 3.6 Weare 2
Suttons Bay 2.7 Eden 1.2 Walkerville 3.2
Timberlee 1.8 Fife Lake subsite 2.1 33
Thompsonville 2.8 Fountain 2.8 Great Lake South/West
15 Riverton 1.7 Shared Station:
Homeworks: Tri-Co Stickney 1.7 Wolf Lake 2.2
Altona 6.4 Star Lake 3.9 1
Crawford 2.8 Victory Tap 2.5 Great Lakes South/Homeworks
Chester 2.2 8 Shared Station:
Carson City 1.3 Hersey 3.2
Deerfield 1.4 Pierson 5.3
Eaton Rapids 2.7 2
Fowler 1.5
Greenbush 1.5
Grand Ledge 2.4
Hinton 0.6
Lebanon 1 Avg MW #
Martin Lake 2.6 AVERAGE PRESQUE ISLE LOAD 2.6 17
Odessa 2.8 AVERAGE CHERRYLAND LOAD 3.8 15
Portland 2.7 AVERAGE GREAT LAKES NORTH LOAD 3.3 29
Stevenson 2.6 AVERAGE GREAT LAKES SOUTH LOAD 3.1 33
Sebewa 1 AVERAGE GREAT LAKES WEST LOAD 2.4 8
Vestaburg 6.4 AVERAGE HOMEWORKS/TRICOUNTY LOAD 2.6 21
Vermontville 1.4 TOTAL WOLVERINE 3.6 126
Weidman 5.5
Westphalia 3 NOTE: shared subs only included in "Total Wolverine"
Winn 2.3
21
NOTE: Loads based on 2003 summer WPSC power flow
P:\23046\007\Dist Subs List.xls
WPSC Transmission Alba Airport CE
2003 Summer Peak CE Living Attachment 5
19.7 Oden 2.4
GLN
Legend: PI
MW Cooperative Load G
G MW Generation 75
G
MW Line Flows
20.6
Grand Traverse 1 96.7
29.3
Traverse City
4.3 48 47.5
Grand
Traverse 2 16.4
CL G
CE
Kalkaska Gen
26.7 G
.3
0
GLS
Tri Co
58.7
G
G
89.9 63.1
GLW
11.3 7.5
22.9 15.2
0 106.8
G
20.3 7.7
65
Lowell
12.9
Grand Haven
39.1
38.1 19.3
CE 13.3
Pere Marquette CE Zeeland
Redwood CE
Cherryland Electric Cooperative (“CL”) Sternberg Vestaburg
Consumers Energy (“CE”) Bradley
Great Lakes Energy North (“GLN”) Brendon
Great Lakes Energy West (“GLW”)
HomeWorks Tri-County Electric Cooperative (“Tri Co”)
Presque Isle Electric & Gas Co-op (“PI”)
Wolverine Power Supply Cooperative (“WPSC”)
Exhibit 2
Exhibit 3
STATE OF MICHIGAN
BEFORE
THE MICHIGAN PUBLIC SERVICE COMMISSION
In the matter, on the Commission’s own motion, to )
make an administrative determination regarding )
the proper classification of transmission and )
distribution facilities of WOLVERINE POWER ) Case No. U-13862
SUPPLY COOPERATIVE, INC., and to submit )
Findings to the Federal Energy Regulatory )
Commission. )
AFFIDAVIT
OF
ERIC D. BAKER, P.E.
February 22, 2005
1
STATE OF MICHIGAN
BEFORE
THE MICHIGAN PUBLIC SERVICE COMMISSION
Wolverine Power Supply Cooperative, Inc. ) Case No. U-13862
Table of Contents
Qualifications……………………………………………………………………………...6
Purpose of Affidavit……………………………………………………………………….8
Wolverine Concerns……………………………………………………………………….8
Factor 1: Local distribution facilities are normally in close proximity to retail
customers….………………………………………………………………………………9
A. Proximity of Retail Customers…………………………………………………….9
B. Consumers’ 46 kV Circuit Structure Design is Typical of Distribution;
Wolverine’s 69 kV Circuit Structure Design is Not……………………………..10
Factor 2: Local distribution facilities are primarily radial in character………………….12
A. Wolverine’s 69 kV and Above Facilities Represent a Highly Looped
Network……………………………………………...…………………….……..12
B. Wolverine’s Planning Criteria for 69 kV and Above Facilities are Typical of
Transmission and Consumers’ 46 kV Planning Criteria are Typical of
Distribution………………………………………………………………………12
C. Transmission Use for Retail Service Does Not Preclude Transmission
Classification………………………………………………………………….….14
D. Load Between Breakers Does Not Preclude Transmission Classification………14
E. Wolverine Should Point to Specific Detroit Edison (DTE) Radial Facilities
Referenced in Its (Turner) Analysis……………………………………………...15
2
Factor 3: Power flows into local distribution systems; it rarely, if ever, flows out……...15
A. Power Regularly Flows Out of Wolverine’s System….…………………………15
B. Wolverine’s System is Capable of Exporting Power 90% of the Time……….…18
C. Information Included in Wolverine’s EQR is Irrelevant to Present Filing………19
Factor 4: When power enters a local distribution system, it is not reconsigned or
transported on to some other market……………………………………………………..19
A. Wolverine Reconsigns All Power Transmitted Over Its Transmission
System……………………………………………………………………………19
B. Power Entering Wolverine’s System is Transported on to Other Markets………21
C. New Technical Analysis on Participation Factors……………………………….22
Factor 5: Power entering a local distribution system is consumed in a comparatively
restricted geographical area……………………………………………………………...23
A. System Line Miles per Source is Preferred Metric………………………………23
B. Power Transmitted on Wolverine’s 69 kV System is Consumed in a Wide
Geographical Area………………………………………………………….……24
Factor 6: Meters are based at the transmission/local distribution interface to measure
flows into the local distribution system……………………………………………….…25
A. Wolverine Has Meters at 69 kV Interfaces With the Local Distribution
Systems…………………………………………..………………………………25
B. Wolverine’s EMS/SCADA System is an Industry-Leading Transmission
Product………………………………………………………………………..….26
3
Factor 7: Local distribution systems will be of reduced voltage………………………...27
A. Wolverine’s 69 kV is a Transmission Voltage………………………...………...27
B. 69 kV is a Common Voltage in the Midwest ISO…...…………………………..29
Other Matters…………………………………………………………………………….30
Summary…………………………………………………………………………………32
List of Tables
Table 1: Comparison of Looped Miles to Total System Miles…………………………..12
Table 2: Wolverine Interconnections with Outside Entities……………………………..16
Table 3: Wolverine Interconnection Power Flows………………………………………17
Table 4: Wolverine Exclusive Export Path………………………………………………18
Table 5: Consumers 46 kV and Wolverine 69 kV Service to Non-Retail Customers…...20
Table 6: System Line Miles per Source…………………......…………………………...24
Table 7: Examples of 69 kV Transmission in MISO Footprint……………….………....30
Table 8: Classification of Wolverine Facilities………………………………………….32
List of Exhibits
Exhibit 1: Distribution Underbuild Line Miles on 69 kV Transmission Lines………….34
Exhibit 2: Map of Wolverine’s 69 kV System and METC’s 138 kV and 345 kV
Systems…………………………………………………………………………………..35
Exhibit 3: Map of Consumers’ 46 kV System…………………………………………...36
Exhibit 4: Wolverine Interconnection Power Flow Graphs……………………….…37-43
Exhibit 5: Wolverine, Grand Haven and Lowell 2004 Hourly Load Duration Curve and
Generation Capacity Available Inside Wolverine’s Network…………………………...44
Exhibit 6: PJM Tag(s) and Wolverine Generation Log(s)……………………...……45-46
4
Exhibit 7: AEP Tag(s) and Wolverine Generation Log(s)………………………...…47-50
Exhibit 8: Allegheny Power Tag(s) and Wolverine Generation Log(s)……………...51-53
Exhibit 9: Dayton Power & Light Tag(s) and Wolverine Generation Log(s)………..54-55
Exhibit 10: Duquesne Light Tag(s) and Wolverine Generation Log(s)…………...…56-58
Exhibit 11: PJM Service Area……………………………………………………………59
Exhibit 12: AEP Service Area…………………………………………………………...60
Exhibit 13: Allegheny Power Service Area……………………………………………...61
Exhibit 14: Dayton Power & Light Service Area………………………………………..62
Exhibit 15: Duquesne Light Service Area……………………………………………….63
Exhibit 16: General Electric XA/21 SCADA System Functionality Brochure………64-71
5
STATE OF MICHIGAN
BEFORE
THE MICHIGAN PUBLIC SERVICE COMMISSION
Wolverine Power Supply Cooperative, Inc. ) Case No. U-13862
Eric D. Baker, being first duly sworn, deposes and says:
Qualifications
My name is Eric D. Baker. My business address is Wolverine Power Supply
Cooperative, Inc. (“Wolverine”), 10125 W. Watergate Road, P.O. Box 229, Cadillac,
Michigan 49601.
I graduated from Michigan Technological University in 1988 with a Bachelor of
Science in Electrical Engineering. I am a Professional Engineer licensed in the State of
Michigan. I am currently enrolled in the Master of Business Administration program at
Western Michigan University’s Haworth College of Business. I have also received
training in forecasting, rates and economic operation of power systems.
After graduation, I was employed by Wolverine as an Electrical Engineer. In this
position, I was responsible for conducting power flow studies for transmission planning
and developing long-range transmission planning studies for Wolverine. I also produced
long-range demand and energy forecasts for Wolverine and each of its member
cooperatives. In 1990, I was project engineer on a load management and distribution
automation system. In September 1995, I was promoted to Rates and Planning Manager.
In this position, I was responsible for long-range power supply planning and transmission
planning for Wolverine, assisting in bulk power supply negotiations, directing
transmission planning and providing rate design and support for Wolverine and its
member cooperatives.
6
In April 1996, I was promoted to Assistant General Manager/Planning and
Engineering Manager. In this position, my duties expanded to include management of
Wolverine’s Energy Control Center personnel and its engineering department as well.
The Energy Control Center responsibilities include merchant operations and transmission
operations. The engineering group is responsible for design projects and long-range
planning for generation, transmission and distribution.
In October 2001, I was promoted to Vice President of Power Marketing. In this
position, my duties expanded to include oversight of Wolverine’s generation facilities,
relay technicians and instrumentation and communication technicians. While in the latter
two positions, I was responsible for the acquisition, siting, engineering and construction
of seven generating units totaling 175 MW at four locations, including one greenfield
location. In December 2003, my title was changed to Vice President of Power Supply &
Engineering. My duties remained the same as those in my previous position.
In June 2004, I was promoted to Senior Vice President of Engineering & Strategy.
In this position, my responsibilities changed to include oversight of Wolverine’s
transmission system operations division, which is responsible for the operation and
maintenance of Wolverine’s transmission facilities, while management of the Energy
Control Center was assigned to another division to allow the Engineering and Strategy
division to focus on long-range transmission and power supply planning. Throughout my
career, I have been involved with or responsible for long-range power supply and
transmission planning.
7
Purpose of Affidavit
The purpose of my Affidavit is to supplement the extensive technical analysis
GDS Associates, Mr. Arnold Turner and the Midwest ISO (MISO) already provided to
the Commission, to provide new additional key data supporting this extensive technical
analysis and to correct material inaccuracies included in the January 31, 2005 and April
4, 2003 Affidavits of Timothy J. Sparks.
My Affidavit will reference Case U-11283 and the Testimony of Mr. Allen C.
Erickson extensively. Further references will be directed at the Affidavits of Timothy J.
Sparks as identified above.
Wolverine Concerns
In the mid-1990s, Consumers made a strategic decision to argue for distribution
classification of its 46 kV system and 138 kV radials presumably to maximize the
number of assets under a distribution wheeling rate to assist Consumers with the looming
reality of retail choice.
In Case No. U-11283, Consumers set out to prove that its 46 kV system was
distribution despite the fact that it had always previously been classified as transmission.
In fact, prior to 1999, Consumers Energy charged for Network Transmission based upon
a Transmission Revenue Requirement (TRR) that included its 46 kV facilities. Only since
1999 has Consumers (now METC) charged for Network Transmission based on a TRR
that excluded its 46 kV system.
Now, Consumers attempts to twist the 7-Factor Test into something it is not. It is
evident from the testimony and comments of Consumers Energy in response to
Wolverine that it is attempting to change the rules of the 7-Factor Test and make it a
8
transmission test. Consumers’ approach is not only wrong, it is illogical. FERC made it
clear in Order 888 that the 7-Factor Test is a test to identify facilities serving a
distribution function and establish jurisdictional boundaries for traditionally vertically
integrated utilities. Consumers attempts to muddy the waters of seven fairly simple
factors; they have corrupted the 7-Factor Test and have tried to make it into a
transmission test. The irony of Consumers’ manufactured rules, had they been applied to
Consumers’ (now METC’s) system, is that they would have led to a conclusion that
much of the Consumers (now METC) 138 kV looped system was not transmission either!
Factor 1: Local distribution facilities are normally in close proximity to
retail customers.
A. Proximity of Retail Customers
Wolverine worked in conjunction with its largest distribution member,
Great Lakes Energy Cooperative (Great Lakes), to determine the proximity,
relative to Wolverine’s facilities, of customers in the Great Lakes system. Great
Lakes customers represent 57% of the total load of Wolverine’s four distribution
cooperatives and serves as a good proxy for the entire Wolverine network. This
analysis indicates that 11.6% of Great Lakes’ customers are within one mile of a
looped 69 kV line, and 5.3% are within one mile of a radial 69 kV line. The total
of 16.9% of Great Lakes’ customers that are within one mile of a 69 kV line is
significantly lower than the 60% comparative statistic of Consumers’ customers
within one mile of its 46 kV lines. In MPSC Case No. U-11283, Mr. Erickson
testified that,
9
“…46 kV lines have been intentionally routed as close to retail customers
as practical. Over sixty percent of Consumers Energy’s load is located
within one mile of 46 kV lines.”
Wolverine estimates that its figure of approximately 17% of customers within one
mile of transmission facilities is comparable with METC’s 138 kV system.
B. Consumers’ 46 kV Circuit Structure Design is Typical of Distribution;
Wolverine’s 69 kV Circuit Structure Design is Not
Wolverine has conducted a survey of vegetation inventory and planning
professionals to determine certain characteristics of Consumers’ 46 kV lines. Wolverine’s
survey included interviews with vegetation inventory and planning professionals in
Michigan and a review of data generated from line maintenance inspection contractors
that have completed entire inspections of Consumers Energy’s 46 kV system. This survey
of Consumers Energy’s 46 kV system indicates that Consumers’ 46 kV system is
underbuilt with lower voltage distribution circuits over the majority of its 4,342 line
miles, such that at least 60% of Consumers’ 46 kV is underbuilt with Consumers Energy
distribution voltage lines. This is very typical of distribution facilities, which are in close
proximity to retail load and typically have short spans conducive to underbuild
construction.
In contrast, Wolverine’s 69 kV lines are underbuilt with distribution on only a
very small percentage of its system. Wolverine reviewed its as-built drawings of
transmission plan and profiles to determine the amount of distribution line underbuild
installed on Wolverine’s 69 kV transmission system. This extensive analysis showed that
only an incidental amount, less than 3%, is underbuilt with lower voltage distribution.
See attached Exhibit 1 (Page 34), which summarizes the location and amount of
distribution line underbuild on Wolverine’s 69 kV transmission system. This is typical of
10
transmission facilities, which are not necessarily routed in close proximity to retail load
but rather are routed in as straight a line as practicable to connect load and generation.
Furthermore, Wolverine’s typical 450’ to 600’ spans are not conducive to underbuild
construction. In contrast, Wolverine estimates that typical spans on Consumers’ 46 kV
system are approximately 150’ to 250’ in length.
The routing for Wolverine’s transmission system was determined based on the
most direct and economical route available to connect Wolverine’s power generation
sources, transmission interconnections with other utility systems and load centers. For
example, Wolverine’s 69 kV Tower to Atlanta transmission line connects Wolverine’s
Tower generation facility with Wolverine’s Atlanta transmission substation. The routing
for this 24-mile transmission line follows a direct north-south path. Only two, 2.5 MVA
distribution substations are connected with this transmission line. To further illustrate this
point, consider Wolverine’s 69 kV lines from Portland to Burnips, White Cloud to
Rodgers and Leroy to South Boardman. These three lines traverse areas not served by
Wolverine’s member-distribution cooperatives in order to follow the most direct route as
possible, and only have 3.5 MW of connected load (divided between two distribution
substations) over 143 miles of 69 kV transmission line. This routing scenario is typical of
the remainder of Wolverine’s transmission system. In no way do these facilities resemble
distribution.
Wolverine’s 69 kV and above facilities are not in close proximity to retail
customers; therefore, Wolverine’s 69 kV and above facilities fail this test of distribution.
11
Factor 2: Local distribution facilities are primarily radial in character.
A. Wolverine’s 69 kV and Above Facilities Represent a Highly Looped
Network
Exhibit 2 (Page 35) is a map showing Wolverine’s 69 kV system and
METC’s 138 kV and 345 kV systems. Exhibit 3 (Page 36) is a map showing
Consumers’ 46 kV system. Table 1 compares the relative percentages of looped
segments with respect to total system line miles. In his testimony in Case No. U-
11283, Mr. Erickson testified that,
“More than 90% of Consumers Energy’s line miles with nominal voltage
of 120 kV and above are part of a looped network and, therefore, are
classified as transmission. The remainder are classified as non-
transmission.”
With 73% of its line miles configured as looped segments, Wolverine’s system
more closely resembles Consumers/METC’s 138 kV system (at 91% of the line miles
configured as looped segments), than Consumers’ 46 kV system (at 42% of the line miles
configured as looped segments). This supports a classification of Wolverine’s system as
transmission.
TABLE 1
Comparison of Looped Miles to Total System Miles
Consumers 46 kV Wolverine 69 kV Consumers/METC 138 kV
Looped (Miles) 1,820 1,051 3,346
Looped & Radial (Miles) 4,333 1,449 3,678
Percent Looped/Total (%) 42% 73% 91%
B. Wolverine’s Planning Criteria for 69 kV and Above Facilities are Typical
of Transmission and Consumers’ 46 kV Planning Criteria are Typical of
Distribution
Wolverine’s transmission system planning criteria are typical transmission
planning criteria. Wolverine is required to annually file FERC Form No. 715, Annual
12
Transmission Planning and Evaluation Report. Wolverine’s system is planned such that
no loss of load is acceptable as a means to meet single contingency conditions.
From Wolverine’s FERC Form No. 715 filed April 1, 2004:
“For emergency conditions (outage of a single circuit, bus, or
autotransformer), the following conditions should be met:
1. Transmission system voltages should range from 90.0 to 105.0
percent of nominal.
2. Transmission lines should not be loaded above the emergency
ampacity rating of the conductors.
3. Transmission system auto-transformers should not be loaded
above their maximum rating at a temperature rise of 65 deg C or
as determined by the IEEE loading guidelines established in
IEEE Std. C57.91.
4. Transmission facility must not exceed the emergency rating of
that facility.”
The shedding of significant amounts of customer load is not acceptable in order to
defer capital investment in Wolverine’s system. This planning criteria applied to
Wolverine’s system is significantly more stringent than criteria commonly applied to
distribution systems, including the planning criteria applied to Consumers’ 46 kV system.
Mr. Erickson, in Case No. U-11283, testified that,
“Radial facilities are characterized by the fact that loss of load can result
from a single contingency outage of lines or equipment.”
He continues,
“Although Consumers Energy’s 46 kV facilities are operated as a mixture
of radial and looped facilities, the planning of all 46 kV facilities
incorporates the acceptability of losing load due to single equipment or
line outages. Opening lines to maintain single contingency loading within
continuous thermal capability would make 84% of the 46 kV system
radial.”
Wolverine believes that Consumers could allow as much as 100 MVA load loss as
acceptable in its 46 kV planning criteria. Consumers’ planning criteria for its 46 kV
system are typical for distribution and in sharp contrast to Wolverine’s typical
13
transmission planning criteria that do not rely on load loss. These planning criteria clearly
show that Wolverine is not a distribution system.
C. Transmission Use for Retail Service Does Not Preclude Transmission
Classification
In its Response Comments, Commission Staff has stated that Wolverine’s 69 kV
facilities are primarily radial in character. Staff’s comments indicate that while some of
the facilities operating at 69 kV are looped as well as radial, all of the facilities are
primarily radial in character and dedicated to delivery of energy to local distribution.
The same can be said of almost all of METC’s 138 kV facilities. Further,
Consumers states on page 15 of its Initial Comments in Section II.B.2.b.,
“For example, before Consumers transferred its transmission facilities
and before FERC Order No. 888 Open Access Tariff, those facilities
provided relatively little wholesale service. Since they were largely used
to serve the needs of Consumers’ own retail customers, they only
incidentally were used for wholesale delivery to other utilities. But they
were just as much transmission facilities then as they are now.”
[Emphasis added.]
This statement confirms that although a transmission system is largely
used for service to retail customers, it does not preclude that system from being
characterized as transmission.
D. Load Between Breakers Does Not Preclude Transmission Classification
The existence of distribution substations fed from Wolverine’s system does not
make this system radial in character. In fact, there are in excess of 200 distribution
substations fed directly from METC’s 138kV transmission system. Mr. Sparks’ statistics
on this subject are grossly misleading.
Wolverine’s system is clearly not a radial system and therefore fails this test of
distribution.
14
E. Wolverine Should Point to Specific Detroit Edison (DTE) Radial Facilities
Referenced in Its (Turner) Analysis
When DTE spun off its transmission component to ITC, the criteria used to
determine the transmission/distribution nature of its 120 kV radials were the
characteristics of the load being served. If the radial served a single retail customer, then
it was classified as distribution. If the radial serviced a distribution substation, then it was
classified as transmission. This point is further clarified when the Otsego distribution
substation was added to the Robin/Wabash to Imlay Pumping radial. This 120 kV radial
was originally classified as distribution and owned and operated by DTE. However, when
DTE added the Otsego distribution substation, a substation designed to serve multiple
retail customers, the line segment from Robin/Wabash to Otsego was reclassified as
transmission and came under the control of ITC. The remaining portion of the radial,
Otsego to Imlay Pumping station, remained under the control of DTE.
Factor 3: Power flows into local distribution systems; it rarely, if ever,
flows out.
A. Power Regularly Flows Out of Wolverine’s System
The following table lists all of Wolverine’s interconnections with other
entities at 69 kV and 138 kV.
15
TABLE 2
Wolverine Interconnections with Outside Entities
Voltage Entity Facility
Wolverine 69 kV to MPPA 69 kV Traverse City L&P G Traverse Sub (GV 422)
Wolverine 69 kV to MPPA 69 kV Traverse City L&P G Traverse Sub (GV 822)
Wolverine 69 kV to MPPA 69 kV Traverse City L&P Hall Street Substation
Wolverine 69 kV to MPPA 69 kV MPPA Kalkaska Generation
Wolverine 69 kV to MPPA 69 kV Grand Haven BL&P Grand Haven North Sub
Wolverine 69 kV to MPPA 69 kV Grand Haven BL&P Grand Haven Substation
Wolverine 69 kV to MPPA 69 kV Grand Haven BL&P Osipoff Substation
Wolverine 69 kV to MPPA 69 kV Zeeland BPW Fairview Sub (Zeeland)
Wolverine 69 kV to MPPA 69 kV Zeeland BPW Fairview Sub (Riley)
Wolverine 69 kV to MPPA 69 kV Zeeland BPW Zeeland Substation
Wolverine 69 kV to MPPA 69 kV City of Lowell Lowell Substation
Wolverine 69 kV to METC 138 kV METC G Traverse Sub (#1 XFMR)
Wolverine 69 kV to METC 138 kV METC G Traverse Sub (#3 XFMR)
Wolverine 69 kV to METC 138 kV METC Alba Substation
Wolverine 69 kV to METC 138 kV METC Blendon Substation
Wolverine 69 kV to METC 138 kV METC Bradley Substation
Wolverine 69 kV to METC 138 kV METC Oden Substation
Wolverine 69 kV to METC 138 kV METC Redwood Substation
Wolverine 69 kV to METC 138 kV METC Sternberg Substation
Wolverine 69 kV to METC 138 kV METC Vestaburg Substation
Wolverine 138 kV to METC 138 kV METC Pere Marquette Substation
Wolverine 138 kV to METC 138 kV METC Livingston Substation
Wolverine 138 kV to METC 138 kV METC Airport Substation
A number of these interconnections exhibit two-way flow. Table 3 illustrates that
two-way flow is exhibited on nearly 50% of Wolverine’s interconnections to other
entities. In addition, MPPA’s 50 MW Kalkaska CT generation facility and Grand
Haven’s 87 MW base load Sims 3 generation facility are 100% dependent upon
Wolverine’s 69 kV system to flow their output power to the various MPPA members.
This supports a classification of Wolverine’s system as transmission.
16
TABLE 3
Wolverine Interconnection Power Flows
Flow Out of Flow Into Flow Into
Flow Out of WPC (% of WPC WPC (%
Voltage Entity Facility WPC (MWh) Time) (MWh) of Time)
Wolverine 69 kV to MPPA 69 kV TCL&P Hall Street Sub
Wolverine 69 kV to MPPA 69 kV TCL&P G Traverse (GV422) 315,961 100.0% 0 0.0%
Wolverine 69 kV to MPPA 69 kV TCL&P G Traverse (GV 822)
Wolverine 69 kV to MPPA 69 kV GHBL&P G Haven North
Wolverine 69 kV to MPPA 69 kV GLBL&P Grand Haven 41,882 29.0% 98,139 71.0%
Wolverine 69 kV to MPPA 69 kV GLBL&P Osipoff
Wolverine 69 kV to MPPA 69 kV ZBPW Fairview (Zeeland) 30,592 77.0% 4,814 23.0%
Wolverine 69 kV to MPPA 69 kV Lowell Lowell 40,204 100.0% 0 0.0%
Wolverine 69 kV to METC 138 kV METC Sternberg 9,537 28.0% 61,849 72.0%
Wolverine 69 kV to METC 138 kV METC Vestaburg 275 0.7% 150,181 99.3%
Wolverine 69 kV to METC 138 kV METC Airport 3,292 12.5% 83,353 87.5%
Data Source: 2004 Interchange data from Wolverine’s Energy Control Center.
Power routinely flows out of the Wolverine 69 kV transmission system. As you
can see from attached Exhibit 4 (Pages 37 and 38), power flows out of the Wolverine 69
kV transmission system to Traverse City Light & Power and the City of Lowell 100% of
the time. Again, referencing Exhibit 4 (Pages 39 and 40), we see that power flows out of
the Wolverine 69 kV transmission system to Grand Haven 29% of the time and to
Zeeland through the Fairview tie 77% of the time. Finally, power flows out of
Wolverine’s 69 kV transmission system to METC 28% of the time through the Sternberg
substation, nearly 13% of the time through the Airport substation and nearly 1% of the
time through the Vestaburg substation. See Exhibit 4 (Pages 41 through 43).
Contrast these statistics to Consumers’ 46 kV system. In MPSC Case No.
U-11283, Mr. Erickson testified that,
“Consumers Energy’s 46 kV system generally does not transfer power
back into the 138 kV network. A review of 1995 and 1996 hourly 138/46
kV flow data showed flow into the 138 kV system occurred rarely,
occurring at only three of 108 substations. Those flows occurred about
one-third of the time at two substations and less than 1% of the time at the
other.”
17
B. Wolverine’s System is Capable of Exporting Power 90% of the Time
Exhibit 5 (Page 44) shows the hourly load on the Wolverine transmission system
during 2004. This is another example of data that Mr. Sparks chooses to ignore.
Wolverine’s system is capable of exporting power 90% of the time. Wolverine has
performed power flows to support this capability. Contrast this against Consumers’ 46
kV network where net power export never occurs due to the fact that Consumers’ 46 kV
load always exceeds the approximately 500 MW of connected 46 kV generation. The fact
that Wolverine’s system is typically a net importer of generation is because the majority
of connected generation is peaking capacity and is uneconomical to run during many
hours of the year. However, this generation is available to support the grid.
It is also important to note that the Wolverine 69 kV and above network is the
exclusive path of export for generation that it does not own. See Table 4.
TABLE 4
Wolverine Exclusive Export Path
Size (MW) Sources Owners Sinks
Grand Haven,
Traverse City,
Sims 3 and Grand Petoskey,
87 Grand Haven
Haven Diesels Charlevoix, Harbor
Springs, Zeeland
and Lowell
Grand Haven,
Traverse City,
Traverse City,
Petoskey, Harbor
Petoskey,
50 Kalkaska Springs,
Charlevoix, Harbor
Charlevoix and
Springs, Zeeland
Lowell
and Lowell
18
C. Information Included in Wolverine’s EQR is Irrelevant to Present Filing
The information provided by Consumers on Wolverine’s EQR is irrelevant to this
filing. Wolverine does have a FERC Open Access Transmission Tariff (OATT) to allow
non-discriminatory access to its transmission system by third parties. The number of
participants currently using the transmission service does not determine whether such
service should be classified as transmission. The “handful of neighboring municipal
utilities” (page 18 of Consumers’ Initial Comments dated January 31, 2005) and the four
distribution members of Wolverine that do rely on Wolverine’s 69 kV transmission
system represent approximately 1,208 MW of peak load and over 338,000 customers in
Michigan.1
The conclusion is that Wolverine’s 69 kV transmission system fails the Factor 3
test of distribution.
Factor 4: When power enters a local distribution system, it is not
reconsigned or transported on to some other market.
A. Wolverine Reconsigns All Power Transmitted Over Its Transmission System
Factor 4 is really a very simple and specific two-part test. The first part of the test
clearly states that power entering a distribution system is not reconsigned.
Since Wolverine is a generation and transmission (G&T) cooperative, all of the
power that Wolverine takes title to is transmitted over its transmission system for
reconsignment, either to one of Wolverine’s member distribution cooperatives or to third
parties in other markets, who then correspondingly take title at the point of delivery.
1
Wolverine’s four distribution members comprise 428 MW peak and over 208,000 customers; the
municipal utilities of Charlevoix, Grand Haven, Harbor Springs, Lansing, Lowell, Petoskey, Traverse City
and Zeeland comprise 780 MW peak and over 130,000 customers. Data based on summer 2005 projections.
19
Contrast this to Consumers’ 46 kV system. In MPSC Case No. U-11283,
Mr. Erickson’s testimony states,
“A limited number of 46 kV facilities supply non-retail customers.
However, the vast majority of power entering the 46 kV system is not
reconsigned or transported onto some other market.”
Mr. Erickson’s testimony further states that,
“Service to MCCP at 46 kV is about 0.5% of Consumers peak load,
wholesale to Bay City is about 0.9% of Consumers peak load and the
remaining delivery points are about 0.9% of Consumers peak load.”
Table 5 clearly shows that 100% of the power transmitted through Wolverine’s 69
kV and above system is reconsigned, contrasted against the 2.3% of power reconsigned
over Consumers’ 46 kV system. This data clearly shows that Wolverine’s 69 kV and
above system does reconsign power and that Wolverine’s 69 kV and above system
clearly fails this test of distribution.
TABLE 5
Consumers 46 kV Service to Non-Retail Customers
Non-retail Customer %
MCCP 0.5
Bay City 0.9
Remaining Delivery Points 0.9
Total 2.3
Wolverine 69 kV Service to Non-Retail Customers
Non-retail Customer %
Grand Haven 13.3
Lowell 1.5
Zeeland 1.3
Kalkaska 9.2
Tower Kleber Limited Partnership 0.1
Remaining Delivery Points 74.6
Total 100.0
Data Source: Wolverine’s 2004 summer peak demand.
20
B. Power Entering Wolverine’s System is Transported on to Other Markets
The second part of Factor 4 clearly states that power entering a distribution
system is not transported on to some other market.
Setting aside the argument that Wolverine’s member distribution cooperatives are
not another market, an argument that Wolverine vehemently disagrees with, it is
impossible to conclude that Michigan municipals are not another market. Furthermore, it
is even more a stretch to conclude that utilities in Ohio and Pennsylvania are not another
market.
The following transactions are examples of power that enters Wolverine’s
transmission system and is “transported on to some other market”:
• On January 27, 2005, from 13:00 to 14:00 power generated at Wolverine’s Burnips
station was transported on Wolverine’s transmission system to the PJM market. See
Exhibit 6 (Pages 45 and 46).
• On August 28, 2004, from 15:00 to 18:00 power generated at Wolverine’s Hersey
station was transported on Wolverine’s transmission system to the AEP market. See
Exhibit 7 (Pages 47 through 50).
• On July 27, 1999, from 12:00 to 20:00 power generated at Wolverine’s Burnips and
Hersey stations was transported on Wolverine’s transmission system ultimately to
the Allegheny Power market. See Exhibit 8 (Pages 51 through 53).
• On July 22, 1999, from 20:00 to 21:00 power generated at Wolverine’s Hersey and
Vestaburg stations was transported on Wolverine’s transmission system ultimately
to the Dayton Power & Light market. See Exhibit 9 (Pages 54 and 55).
21
• On July 22, 1999, from 18:00 to 20:00 power generated at Wolverine’s Hersey and
Vestaburg stations was transported on Wolverine’s transmission system ultimately
to the Duquesne Light market. See Exhibit 10 (Pages 56 through 58).
This data clearly shows that power entering the Wolverine 69 kV and above
network is transported to other markets and that Wolverine’s 69 kV and above system
clearly fails this test of distribution.
C. New Technical Analysis on Participation Factors
First, it is important to note on this point that significant power flow analyses
were completed in the GDS Report and the MISO Report. In fact, most conclusions in
these reports were substantiated by load flow analysis. Assertions that Wolverine has not
presented power flow analyses are erroneous.
Second, Consumers absurdly attempts to apply an extremely narrow test (MW-
mile) to attempt to show Wolverine’s transmission system as distribution instead of
literally applying the test. Factor 4 has little, if anything, to do with MW-mile analysis.
The factor is attempting to determine if a system is ever used to reconsign power or
transport power to another market. It seems Consumers wants to confuse this simple test
with superfluous information because the literal application of the test so convincingly
proves that Wolverine’s 69 kV and above network is not a distribution system.
Nevertheless, Wolverine has engaged Stephen S. Miller, P.E., of Commonwealth
Associates, Inc. to provide expert technical analysis in the area of participation factors.
Please see Mr. Miller’s Affidavit in which he discusses new findings that support the
earlier technical analyses of GDS Associates, Inc., Mr. Arnold Turner and the MISO.
22
Even in the absence of Mr. Miller’s supplemental power flow analyses,
Wolverine clearly fails this test of distribution.
Factor 5: Power entering a local distribution system is consumed in a
comparatively restricted geographical area.
A. System Line Miles per Source is Preferred Metric
In MPSC Case No. U-11283, Mr. Erickson offers a measure of the average length
that power flows as an indication that Consumers’ 46 kV system is distribution under
FERC Factor 5. His measure of the length of the flow path is based on the average length
of line, which, without the provision of any detailed analysis, might be assumed to be the
distance between breakers on the 46 kV system. This measure of average length of power
flow is flawed, however, because it essentially assumes that the source of the power into
the 46 kV system (whether a tie to a higher voltage, or a generator) is at one end of the
line segment being measured and the load is at the other end. This is the same as
assuming that every other “node” (breaker substation) in Consumers’ 46 kV system has
either generation or a tie to a higher voltage connected to it. This is certainly not the case.
Instead of using Mr. Erickson’s measure of the average distance power flows, a
technically significant metric for use is system line miles per source. This measure more
accurately simulates power flow on the system emanating from the sources, which are
generators or ties to higher voltages, to the loads. The implicit assumption is that the
average distance that power flows is half the distance between sources. This average
distance is typically a longer distance than an average line length. Mr. Erickson’s average
line length is more an indication of the density of sectionalizing stations/devices and the
network topology than power flow distances.
23
Table 6 compares this measure, based on the number of ties to higher voltages
and generation interconnections, for Consumers’ 46 kV system, METC’s 138 kV and 345
kV systems and Wolverine’s 69 kV system. As shown in Table 6, using this metric for
Wolverine’s 69 kV system indicates power flow distances that range between those of
METC’s 138 kV and 345 kV systems. All three of these higher voltage systems exhibit
average power flow distances significantly greater than those of Consumers’ 46 kV
system. This supports a classification of Wolverine’s system as transmission.
TABLE 6
System Line Miles per Source
Line Miles Average Distance
System No. of Sources Line Miles per Source Power Flows
Consumers 46 kV 116 4,330 37 19
METC 138 kV 65 3,346 52 26
Wolverine 69 kV 20 1,450 73 36
METC 345 kV 14 1,948 139 70
Data Source: 2005 MISO summer peak model; 2002 Platt’s Directory of Electric Power Producers and Distributors.
B. Power Transmitted on Wolverine’s 69 kV System is Consumed in a Wide
Geographical Area
The following are examples of power transmitted on Wolverine’s 69 kV system
and consumed in diverse, wide geographical areas:
• PJM market (per Exhibit 11 (Page 59), parts of Michigan, Ohio, Kentucky, Illinois,
Indiana, West Virginia, Virginia, Delaware, Pennsylvania, New Jersey, Maryland).
• AEP market (per Exhibit 12 (Page 60), parts of Michigan, Ohio, Indiana, Kentucky,
West Virginia, Virginia).
• Allegheny Power market (per Exhibit 13 (Page 61), parts of Maryland, Ohio,
Pennsylvania, Virginia and West Virginia).
24
• Dayton Power & Light market (per Exhibit 14 (Page 62), 24 counties in West
Central Ohio).
• Duquesne Light market (per Exhibit 15 (Page 63), southwestern Pennsylvania).
Again, Factor 5 leaves no room for compromise as Mr. Sparks attempts to indicate
in his testimony and affidavit. The factor requires that power entering a distribution
system is consumed in a comparatively restricted geographical area. Wolverine’s 69 kV
and above facilities fail this test of distribution.
Factor 6: Meters are based at the transmission/local distribution
interface to measure flows into the local distribution system.
A. Wolverine Has Meters at 69 kV Interfaces With the Local Distribution
Systems
Factor 6 of the 7-Factor Test clearly states, “Meters are based at the
transmission/local distribution interface to measure flows into the local distribution
system.” Wolverine has meters at all 69/12.5 kV and 69/24.9 kV substations. Contrast
this against a Great Lakes 24.9 kV circuit: Wolverine steps down and meters the voltage
at 69 kV to 24.9 kV and Great Lakes subsequently steps the voltage down again to 12.5
kV. There is no metering at the 24.9/12.5 kV transformation.
In MPSC Case No. U-11283, Mr. Erickson’s testimony states that,
“Supervisory Control and Data acquisition (SCADA) devices are installed
on the transmission system to monitor flows and control switching
equipment. SCADA equipment is installed in substations, which transform
voltage from 138 kV to 46 kV. SCADA equipment is generally not installed
in Consumers Energy substations, which transform the voltage from 46 kV
to lower voltage. The location of Consumers Energy’s SCADA devices
supports a conclusion that Consumers Energy’s 138/46 kV substations are
the interface between its transmission and local distribution systems.
Application of this indicator supports a conclusion that the 138 kV system
should be classified as transmission and the 46 kV system should be
classified as distribution.”
25
Mr. Erickson’s testimony introduced SCADA into the discussion of Factor 6. Mr.
Erickson concludes that since “SCADA equipment is installed in substations which
transform voltage from 138 kV to 46 kV” that the lower voltage system must be
distribution. That statement is not compelling because METC has SCADA at its 345 kV
to 138 kV substations and this does not mean that the 138 kV system must be
distribution.
This entire argument is moot when Factor 6 is applied as it is written: “Meters are
based at the transmission/local distribution interface to measure flows into the local
distribution system.” Wolverine meters are located at the 69/12.5 kV and 69/24.9 kV
interface between Wolverine’s transmission system and its member distribution systems.
B. Wolverine’s EMS/SCADA System is an Industry-Leading Transmission Product
However, since Mr. Erickson does bring up SCADA, it is important to understand
that Wolverine has in place a robust, real-time EMS/SCADA system. This XA/21system,
sold by General Electric Company (GE), is an industry-leading product for optimization
of generation and transmission systems. There are over 100 systems installed worldwide
at some of the world’s largest utilities, including Southern Company, Southern California
Edison, San Diego Gas & Electric and National Grid (UK). The XA/21 has a modular
architecture containing applications targeted specifically for transmission systems.
Examples of this are in the Generation Dispatch and Control (GDC) suite, such as
Interchange Scheduling, Automatic Generation Control and Reserve Monitoring.
Wolverine’s contract with GE includes licensing for all of those modules. The XA/21
also has a suite of Power Network Applications (PNA) modules that Wolverine licenses
26
as well. Examples of these modules are the State Estimator, Contingency Analysis,
Powerflow and Security Constrained Dispatch.
In contrast, GE also offers distribution monitoring products called ENMAC and
GE Smallworld PowerOn. Many of the larger vertically integrated utilities that have the
XA/21 for their transmission system also have one of these products or a similar product
to perform their distribution management functions. Since Wolverine’s 69 kV and above
system is transmission, Wolverine does not use ENMAC, GE Smallworld PowerOn or
any similar distribution product. A brochure illustrating the transmission functionality of
GE’s XA/21 system is included as Exhibit 16 (Pages 64 through 71).
The functionality of Wolverine’s XA/21 EMS/SCADA system is superior to the
level of functionality used by Consumers Energy to monitor its 46 kV system. There is
really no comparison between the visibility and control that Wolverine has of its 138 kV
and 69 kV transmission system and that which Consumers Energy has of its 46 kV
distribution system.
This factor indicates that Wolverine’s 69 kV and above system is not a
distribution system.
Factor 7: Local distribution systems will be of reduced voltage.
A. Wolverine’s 69 kV is a Transmission Voltage
In the 7-Factor Test, the FERC sets out to codify the characteristics of a
distribution system. Persons familiar with the power industry and, specifically,
distribution facilities, appreciate these general characteristics, including the fact that
distribution lines are of a reduced voltage. The reduced voltages allow safer routing
through populated areas, lower clearances and inexpensive installation costs for this
27
portion of the system that represents the majority of the line-length in any electrical
system. These reduced voltages represent the ‘curb-side’ voltage from which residential,
commercial and most industrial customers take service through a service transformer.
These service transformers are typically a pole-top transformer, but sometimes pad-
mount transformers are used, especially for larger loads. The exception to this is the
infrequent industrial customer with a large load that might take service at a higher voltage
because it has its own substation on site, or at least its own high-voltage transformers.
Knowing that there are exceptions to every rule, the FERC allowed for these exceptions
by adding language like “normally” to Factor 1, “primarily” to Factor 2, and “rarely, if
ever” to Factor 3. The FERC included no such qualification for Factor 7: “Local
distribution systems will be of reduced voltage.” The room for interpretation, instead, is
in the manner in which one defines “reduced”. In his testimony in this case, Mr. Sparks
would propose that Wolverine’s 69 kV system is distribution because there exist higher
voltages in Michigan, namely, 120 kV, 138 kV, 230 kV, 345 kV and 765 kV. Mr. Sparks’
argument is one of semantics, not of real-world functional/technical use of the Wolverine
system. In fact, one could have made the argument, just as arbitrarily, that 138 kV is local
distribution because there exists three higher voltages in the state.
Instead, Wolverine literally applies a functional/technical treatment of this factor.
In the Wolverine system, the true distribution voltages are at 12.5 kV and 25 kV. These
are the voltages at which customers take service through the service transformer, and
these are the voltages of the lines that leave the distribution substations to distribute the
energy to individual customers. Wolverine’s 69 kV system does not serve customers
directly. Even the few relatively large industrial customers whose load warrants a
28
dedicated substation, take service at a reduced voltage (typically, the 69 kV is
transformed to 12.5 kV at the distribution substation, and then transformed further to
lower voltages – 480 V or 240/120 V, for example, before entering their facilities). These
two voltages, 12.5 kV and 25 kV, are the reduced voltages, the true distribution voltages,
on Wolverine’s system. The 69 kV is the transmission voltage. This factor clearly
supports a classification of transmission for the Wolverine system.
B. 69 kV is a Common Voltage in the Midwest ISO
Wolverine’s network is at a typical transmission voltage appropriate in design
and configuration. Wolverine has classified its 69 kV assets since the late 1940s as
transmission in accordance with REA’s, then RUS’s, then FERC’s Uniform System of
Accounts. Mr. Sparks has made several erroneous and misleading comments regarding
the use of 100 kV as the cut-off for transmission. He even infers that MISO does not
recognize 69 kV transmission. Both of these assertions are patently false. The FERC
refused to establish such a simple “bright line” test. In fact, this is the very reason for the
7-Factor Test.
Furthermore, 69 kV is a common transmission voltage throughout the Midwest.
MISO states in its January 31, 2005 Comments that,
“The pole miles of 69 kV transmission facilities for the Midwest ISO’s
investor-owned utilities is 18,606 miles out of a total of 63,105 pole
miles or approximately 30% of all transmission pole miles within the
Midwest ISO region.”
Table 7 shows just a few of the companies that MISO refers to that have 69 kV
transmission facilities.
29
TABLE 7
Examples of 69 kV Transmission in MISO Footprint
Company 69 kV Line Miles
American Transmission Company LLC 3,519.3
Cincinnati Gas & Electric Company 535.7
PSI Energy, Inc. 2,511.7
Southern Indiana Gas and Electric Company 538.5
Wolverine Power Supply Cooperative, Inc. 1,457.0
Northern States Power Company (Wisconsin) 1,034.8
FirstEnergy’s American Transmission Systems, Inc. 2,285.8
Northern Indiana Public Service Company 1,623.9
Union Electric Company 32.7
Data Source: 2003 FERC Form 1 for all companies.
Wolverine’s transmission system is not a reduced voltage system typical of
distribution systems and clearly fails this test of distribution.
Other Matters
Consumers’ attempts to discredit the joint planning benefits of a joint
transmission zone are shameful. Consumers fails to recognize today what it has failed to
recognize for decades—that joint planning is a two-way street. In response to Mr. Arnold
Turner, Consumers argues on page 8 of Timothy J. Sparks’ January 31, 2005 Technical
Review that,
“WPSC can interconnect with METC right now, as it has done in many
places, regardless of whether or not it belongs to a joint pricing zone with
METC. What WPSC means is that it could connect to the METC
transmission system more cheaply because it could shift most of the cost to
Consumers Energy customers. Similarly, WPSC can connect with
Consumers Energy’s 46 kV system right now. WPSC just has to ask.
WPSC would then pay METC its transmission rate as well as Consumers
Energy’s Wholesale Distribution Service rate, which would not change if
WPSC participated with METC in the METC pricing zone. Turner’s
assumed benefits are an illusion.”
This statement illustrates exactly the reason that joint planning and a joint zone
will benefit Consumers’ customers. Consumers does not take into consideration
30
Wolverine’s transmission system in the planning of its distribution system. There are
several areas on the Wolverine network that Consumer Energy’s customers would have
benefited from ties to the Wolverine system. In fact, Consumers has taken specific steps
to ignore the presence of the Wolverine system. In the late-1990s, Consumers
disconnected from the Wolverine network in Hersey, Michigan. This radial 46 kV
network of Consumers in the Reed City area benefited from a tie with Wolverine at this
location as Wolverine’s system generally exported power to the lower-voltage end of
Consumers’ 46 kV lines. Subsequent to disconnecting from Wolverine, Consumers’
customers faced several significant outages in the Reed City area, while simultaneously,
Wolverine’s network was growing even stronger at Hersey due to the addition of 50 MW
of generation. Other examples, include the Zeeland and Redwood areas of the Wolverine
network where interconnections to Wolverine’s system offered potentially cheaper and
more robust options for Consumers, yet Wolverine’s overtures for joint planning were
rebuffed. Perhaps, an even more damning example is the Leelanau Peninsula. In this
case, an overture from one of Wolverine’s member-distribution cooperatives to
Consumers to explore the interconnection of Wolverine’s and Consumers’ radial systems
to mutually improve reliability was spurned on the grounds that Consumers did not want
to give any credence to Wolverine that it’s system could support Consumers in any way.
Consumers would apparently rather jeopardize its system reliability or pursue
more expensive or duplicative system improvements than utilize Wolverine’s system
where appropriate. Presumably, Consumers does this to perpetuate its long-standing
argument that Wolverine does not have a transmission system. Consumers’ apparent
31
disregard for customer reliability is inconceivable to Wolverine who is owned by its
customers.
Summary
Application of the FERC 7-Factor Test leads to the conclusion that, with the
exception of 69 kV radial lines and associates facilities that serve a single retail account,
the lines of Wolverine which transmit electricity at 69 kV and above, including all
associated facilities, should be classified as transmission under the FERC 7-Factor Test
criteria. In contrast, all 69/12.5 kV and 69/25 kV step-down facilities including all
associated facilities should be classified as distribution facilities. A breakdown of these
facilities and their classification follows:
TABLE 8
Classification of Wolverine Facilities
Description Transmission Distribution
138 kV Lines 80.2 Miles N/A
138/69 kV Stations 12 N/A
69 kV Lines 1,053.4 Miles N/A
69 kV Radials 394.3 Miles 3.9 Miles1
69 kV Transmission Stations 33 N/A
69 kV Distribution Stations N/A 134
46 kV Ties N/A 32
1
Radials serving dedicated substations including Morley 2, Osceola, Reynolds, Sebewa and Winn.
2
Milton, Plains Road and Resort.
32
DISTRIBUTION UNDERBUILD LINES MILES ON 69 kV TRANSMISSION LINES
DIST. U/B DIST. U/B
LINE NAME MILES LINE NAME MILES
LINE MILES LINE MILES
Advance - Boyne City 8.11 Hersey - White Cloud 26.33
Advance - East Jordan Jct. 5.60 Hillman - Airport 8.76 0.27
Advance - Elmira 17.20 Hillman - Beaver Lake 13.12 5.33
Airport - C.P. Co. Tie 1.32 Hinton Tap 0.42
Airport - Posen 16.25 Interlochen Tap 1.05
Altona - Morley 10.37 Johannesburg Tap 6.84 0.65
Altona - Pierson 15.89 Kalkaska Tap 2.13
Altona - Vestaburg 19.52 Kewadin - Milton 3.45 0.68
Atlanta - Airport 138kV 30.62 Lake County - Bass Lake 8.35
Atlanta - Hillman 21.74 Lebanon Tap 4.66
Baldwin - Walkerville 19.51 Leroy - Hartwick 9.70
Baseline Tap (D.C. w/ HT-SH) 0.21 Leroy - Tustin 7.67
Bass Lake - Brethren 18.11 Lewiston - Atlanta 12.02
Bass Lake - Wolf Lake 11.14 0.20 Lewiston - Lovells 15.19
Black Lake - Hammond Bay 12.78 1.90 Lincoln Tap 8.13
Boyne City - Hayes 11.85 Livingston - Atlanta 138kV 31.17
Boyne City - Petoskey 10.48 Lowell - Portland 26.10 0.79
Brohman Tap 1.34 Middleville Tap 0.42
Brooks Tap 3.21 Millersburg - Hawks 9.53 0.37
Burnips - Lowell Junction 37.06 Odessa - Wayland 30.48 0.51
Burnips - Wayland 17.81 Osceola Tap 0.74
Canadian Lakes Tap 0.99 Otsego Tap 7.76 0.83
Carson City Tap 5.63 0.74 Paris Tap 1.26
Casnovia - Cedar Springs 10.40 0.11 Pellston - Cheboygan 18.43
Casnovia - Grand Haven 29.06 Pellston - Cross Village 9.08
Cedar Springs - Howard City 14.86 4.77 Petoskey - Pellston 16.32
Cheboygan - Tower 21.76 0.72 Pierson Jct - Howard City 9.14 0.11
Chester - Eaton Rapids 18.41 Plains Junction - Star Lake 7.02
Chester - Vermontville 10.69 0.13 Portland - Chester 15.58
Copemish - Brethren 10.81 Portland - Fowler 18.86
Copemish - Thompsonville 8.86 Portland - Odessa 9.72
Crawford - Vestaburg 8.99 Posen - Grand Lake 9.89
Drenthe Tap 0.23 Redwood - Hart 1.59
East Bay - Bates 5.89 Rewood Tie
East Bay - Grawn 11.86 Scottville - Eden 6.12
East Jordan - Eastport 11.42 Scottville - Lake County 15.42
East Jordan Jct - Westwood 23.07 Scottville - Riverton 6.51 1.36
East Jordan Jct. - East Jordan 2.17 Shelby - Rodgers 5.00
Eastport - Barnard 9.93 Silver Lake Tap 6.28 0.20
Eden - Hart 12.63 0.71 South Boardman - East Bay 15.93
Elmira - Gaylord (LV-AA D.C.) 14.33 South Boardman - Fife Lake 7.95 1.45
Fairview Tap (Zeeland D.C Tap) 0.62 South Boardman - Leroy 47.33
Fingerboard Tap 6.58 Star Lake - Lake County 7.72
Fountain Tap 6.41 1.88 Suttons Bay Tap 2.62
Fowler - Greenbush 9.04 Timberlee Tap 0.17
Fowler - Vestaburg 27.88 0.51 Tower - Atlanta 27.74
Gaylord - Lewiston 17.62 Tower - Black Lake 4.21
Goodwin Tap 0.36 0.27 Tower - Millersburg 12.31 0.37
Grand Haven - Burnips 37.63 Traverse City Light & Power Tie 1.30 0.77
Grand Ledge Tap 3.86 2.42 Vermontville - Hastings 23.53
Grand Traverse Tap 0.47 0.23 Victory Tap 4.95
Graves Crossing - Central Lake 7.90 Walkerville - Hart 9.49
Grawn - Copemish 20.20 Wayland - Hastings 11.19 1.93
Grawn - Lake Ann 12.54 Weare Tap 4.72 0.27
Grawn - Lake Leelanau 24.45 Weidman - Crawford 17.46 6.78
Hagensville Tap 5.70 Weidman - Stevenson 11.45 0.61
Harbor - West Traverse 10.64 Westphalia Tap 3.87
Harbor Tap 2.87 0.43 Westwood - Clam River 11.42
Hart - Shelby 12.83 0.31 Westwood - Manistee River 11.93
Hawks - Posen 13.80 0.18 Westwood - South Boardman 15.04
Hersey - Altona 24.02 White Cloud - Casnovia 22.85 0.28
Hersey - Baldwin 19.52 White Cloud - Rodgers 36.08 1.01 U/B miles
vs. total
Hersey - Leroy 138kV 14.59 0.20 Winn Tap 3.15 69kV line
Hersey - Weidman 23.08 miles ratio
TOTALS 1529.37 40.28 2.6%
Exhibit 1, Page 34
Exhibit 2, Page 35
Exhibit 3, Page 36
Exhibit 4, Page 37
Exhibit 4, Page 38
Exhibit 4, Page 39
Exhibit 4, Page 40
Exhibit 4, Page 41
Exhibit 4, Page 42
Exhibit 4, Page 43
Wolverine, Grand Haven and Lowell 2004 Hourly Load Duration Curve and
Generation Capacity Available Inside Wolverine's Network
500
450
400
350
300
250
200
150
100
50
0
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Load Curve Generation
Exhibit 5, Page 44
Exhibit 6, Page 45
Exhibit 6, Page 46