December 10_ 2010 INDIANA UTILITY REGULATORY COMMISSION by chenmeixiu

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									                                   STATE OF INDIANA

                    INDIANA UTILITY REGULATORY COMMISSION

VERIFIED PETITION OF INDIANAPOLIS                       )
POWER & LIGHT COMPANY REQUESTING                        )
THE INDIANA UTILITY REGULATORY                          )                 FILED
COMMISSION TO APPROVE (1) NEW AND                       )            December 10, 2010
ENHANCED DEMAND SIDE MANAGEMENT                         )           INDIANA UTILITY
AND ENERGY EFFICIENCY PROGRAMS; (2)                     )      REGULATORY COMMISSION
RATEMAKING RECOGNITION OF SUCH                          )
COSTS, INCLUDING TIMELY RECOVERY OF                     )
ASSOCIATED COSTS, INCLUDING LOST                        )
REVENUE AND PERFORMANCE INCENTIVES                      ) CAUSE NO. 43960
PURSUANT TO STANDARD CONTRACT RIDER                     )
NO. 22 IN ACCORDANCE WITH INDIANA CODE                  )
8-1-2-42(a) AND 170 lAC 4-8-1 ET SEQ.; (3)              )
ASSOCIATED ACCOUNTING AUTHORITY,                        )
INCLUDING AUTHORITY TO DEFER COSTS,                     )
INCLUDING CARRYING CHARGES INCURRED                     )
TO IMPLEMENT CORE DSM PROGRAMS AND                      )
OTHERWISE COMPLY WITH THE PHASE II                      )
ORDER IN CAUSE NO. 42693; AND (4)                       )
REVISIONS TO RATE REP.                                  )

               INDIANAPOLIS POWER & LIGHT COMPANY'S
     SUBMISSION OF SUPPLEMENTAL DIRECT TESTIMONY AND EXHIBITS

       Indianapolis Power & Light Company, by counsel, hereby submits the supplemental

direct testimony and exhibits of its witnesses Ken Flora, Lester H. Allen, Joan M. Soller and

James L. Cutshaw.

                                          Respectfully submitted,

                                         ~ay-~
                                          P. ason Stephenson (No. 21839-49)
                                          Barnes & Thornburg LLP
                                          11 South Meridian Street
                                          Indianapolis, Indiana 46204
                                          Telephone: (317) 231-7749
                                          Facsimile: (317) 231-7433
                                          Email: jason.stephenson@btlaw.com

                                          Attorney for Indianapolis Power & Light Company
                                  CERTIFICATE OF SERVICE

           The undersigned hereby certifies that on December 10,2010, a copy of the foregoing was

 served by email transmission upon Karol H. Krohn, Office of Utility Consumer Counselor, PNC

 Center, 115 W. Washington Street, Suite 1500 South, Indianapolis, Indiana 46204 at

 kkrohn@oucc.in.gov and infomgt@oucc.in.gov.




                                             ~~
                                              P. Jason Stephenson

P. Jason Stephenson (No. 21839-49)
Barnes & Thornburg LLP
11 South Meridian Street
Indianapolis, Indiana 46204
Telephone:     (317) 231-7749
Facsimile:     (317) 231-7433
Email: jason.stephenson@btlaw.com

Attorney for Indianapolis Power & Light Company




!NOSOI 1243249vl



                                                -2-
                               Petitioner’s Exhibit KF-S1




VERIFIED SUPPLEMENTAL DIRECT TESTIMONY

                  OF

              KEN FLORA

             ON BEHALF OF

 INDIANAPOLIS POWER & LIGHT COMPANY

            CAUSE NO. 43960
                                                                        Petitioner’s Exhibit KF-S1


            VERIFIED SUPPLEMENTAL DIRECT TESTIMONY OF KEN FLORA

 1   Q1.   Please state your name, employer and business address.

 2   A1.   My name is Ken Flora. I am employed by Indianapolis Power & Light Company (“IPL”

 3         or “Company”), One Monument Circle, Indianapolis, Indiana, 46204.


 4   Q2.   What is your position with IPL?

 5   A2.   I am Director, Regulatory Affairs.


 6   Q3.   Are you the same Ken Flora who prefiled Direct Testimony in this Cause on

 7         October 15, 2010?

 8   A3.   Yes.


 9   Q4.   What is the purpose of your supplemental testimony in this proceeding?

10   A4.   The purpose of my testimony is to (1) provide an introduction of witnesses that are

11         providing supplemental testimony at this time; (2) discuss the status of IPL’s request to

12         recover lost revenues; and (3) describe IPL’s proposal to deploy electric vehicle (“EV”)

13         charging equipment and to implement tariffs that support electric vehicle charging.


14   Q5.   Who is providing supplemental testimony at this time?

15   A5.   Below is a brief summary of the witnesses that will be providing supplemental testimony:


16            •   Witness Soller provides supplemental testimony that describes IPL’s proposed

17                Electric Vehicle Charging Plan.


18            •   Witness Allen provides supplemental testimony to sponsor modifications to IPL’s

19                Air Conditioning Load Management Adjustment, Standard Contract Rider No. 13.




                                                                                           Flora -- 1
                                                                                 Petitioner’s Exhibit KF-S1


1                •   Witness Cutshaw provides supplemental testimony to update cost recovery

2                    schedules to reflect (1) the removal of IPL’s request for recovery of lost revenue

3                    and (2) the inclusion of costs related to IPL’s proposed Electric Vehicle Charging

4                    Plan.


5    Q6.     In your direct testimony you indicated that IPL would update or supplement its

6            prefiled testimony in this proceeding, as necessary or appropriate, upon the issuance

 7           of an order in Cause No. 43911.1 Has an order been issued in Cause No. 43911?

 8   A6.     Yes. On November 4, 2010, the Commission issued its Order in Cause No. 43911.


 9   Q7.     Do you have an update to make in this proceeding based on the Commission’s

10           Order in Cause No. 43911?

11   A7.     Yes. In Cause No. 43911, the Commission approved IPL’s request to implement an

12           Energy Efficiency Schools Program – Audits but denied IPL’s request to recover lost

13           revenue from its Core and Core Plus DSM programs. As a result of the Commission’s

14           ruling, IPL is withdrawing its request to recover lost revenue for its Core and Core Plus

15           DSM programs in this proceeding.


16   Q8.     Do you have any other updates to make in this proceeding?

17   A8.     Yes. IPL has spent more than a year investigating EVs and related charging equipment,

18           also referred to as Electric Vehicle Supply Equipment (“EVSE”). IPL conducted this

19           research to better understand and predict the potential impact to IPL and the ability to

20           reliably serve its customers. Since the filing of its case-in-chief, IPL has finalized a plan


     1
             IPL requested Commission authority to implement an Energy Efficiency Schools Program – Audits and to
     recognize lost revenue incurred as a result of the implementation of Core and Core Plus DSM programs.



                                                                                                     Flora -- 2
                                                                          Petitioner’s Exhibit KF-S1


 1          to accommodate the use of EVs in its service territory and to gain further insight into the

 2          potential impact from the use of EVs.


 3   Q9.    Please describe IPL’s research activities?

 4   A9.    IPL is a partner with Project Plug-IN, a cooperative group of industry and government

 5          entities working cooperatively to develop, deploy, demonstrate, market, and evaluate a

 6          range of plug-in vehicles powered by an integrated charging infrastructure located at

 7          homes, businesses and parking facilities. IPL has had meetings and shared information

 8          with project partners to develop its plan to deploy EVSE.           IPL is also actively

 9          participating in the Edison Electric Institute’s Electric Transportation Task Force.

10          Furthermore, as discussed by Witness Soller in her supplemental testimony, IPL has

11          conducted its own due diligence regarding EVSE manufacturers, technical standards and

12          EV technology.


13   Q10. Please elaborate on the potential impact EVs and EV charging may have on IPL’s

14          distribution system.

15   A10.   As Witness Soller describes in her supplemental testimony, IPL and other electric utilities

16          are concerned that unmanaged EV charging may necessitate upgrading distribution

17          facilities or building new generating plants to ensure EVs do not have a detrimental

18          impact on a utility’s ability to reliably serve its customers. This concern is especially

19          great in residential areas that attract several EVs in a compact area, a phenomenon known

20          as clustering.


21   Q11. Why is it important for IPL to take a proactive approach to manage the use of EV

22          charging in its service territory now?



                                                                                            Flora -- 3
                                                                           Petitioner’s Exhibit KF-S1


 1   A11.   There appears to be significant momentum for EVs in the United States and it is likely

 2          that EVs will become more prevalent in Indianapolis in the near term. IPL believes it is

 3          better to be actively engaged in the development stage by managing the implementation

 4          and evaluating the potential impact on the utility distribution system.


 5   Q12. You mentioned the use of managed EV charging. Please explain this concept.

 6   A12.   Managed EV charging refers to the use of systems including EVSE and electric

 7          consumption feedback tools as well as time-of-use (“TOU”) rates to encourage customers

 8          to charge their EVs during off peak times. The objective is to promote charging during

 9          off-peak periods when generation capacity is more prevalent and prices are generally

10          lower.


11   Q13. Please describe IPL’s EV Charging Plan.

12   A13.   IPL is planning to deploy EVSE and to implement TOU rates to manage EV charging in

13          its service territory (“EV Charging Plan”). Witness Soller more fully explains IPL’s EV

14          Charging Plan in her supplemental testimony. IPL’s EV Charging Plan will provide an

15          indication of whether TOU rates are effective at influencing when customers charge their

16          EVs. The software will provide feedback to customers regarding their energy (fuel)

17          consumption and will help IPL monitor the impact of EVs.                  Witness Cutshaw’s

18          supplemental testimony addresses IPL’s request to recover the cost of the equipment and

19          software in this proceeding through Standard Contract Rider No. 22. IPL has developed

20          two tariffs relating to its EV Charging Plan – an experimental TOU EV charging rate and

21          a public EV charging rate – both of which have been filed pursuant to the Commission’s

22          30-day administrative filing procedure.




                                                                                              Flora -- 4
                                                                          Petitioner’s Exhibit KF-S1


 1   Q14. How will IPL’s EV Charging Plan serve the public interest?

 2   A14.   The project will provide IPL customers with opportunities to reduce transportation fuel

 3          costs and manage vehicle charging in a grid-friendly manner by responding to price

 4          signals. The project will enable IPL to monitor vehicle energy usage of and utilize actual

 5          local data to understand the impacts on its facilities to plan for future vehicle

 6          deployments and enhance effective rate design. The information obtained through the

 7          project and the implementation of rates that encourage off-peak charging for EVs support

 8          IPL’s continuing objective to provide customers with the reliable electric service.


 9   Q15. Does this conclude your supplemental testimony?

10   A15.   Yes.




                                                                                             Flora -- 5
                                      VERIFICATION

          I, Ken Flora, Director, Regulatory Affairs of Indianapolis Power & Light Company,

affirm under penalties of perjury that the foregoing representations are true and correct to the

best of my knowledge, information and belief.



                                                   Ken Flora

                                                   Dated: December 10,2010



INDSOI 1239706vl
                                       Petitioner’s Exhibit JMS-S1




      VERIFIED SUPPLEMENTAL DIRECT TESTIMONY

                          OF

                   JOAN M. SOLLER

                    ON BEHALF OF

        INDIANAPOLIS POWER & LIGHT COMPANY

                    CAUSE NO. 43960




SPONSORING PETITIONER’S EXHIBITS JMS-S2 THROUGH JMS-S5
                                                                                         Petitioner’s Exhibit JMS-S1


            VERIFIED SUPPLEMENTAL DIRECT TESTIMONY OF JOAN M. SOLLER

 1   Q1.      Please state your name, employer and business address.

 2   A1.      My name is Joan M. Soller. I am employed by Indianapolis Power & Light Company

 3            (“IPL” or “Company”), One Monument Circle, Indianapolis, Indiana, 46204.


 4   Q2.      What is your position with IPL?

 5   A2.      I am Manager of Corporate Planning.


 6   Q3.      Are you the same Joan M. Soller who prefiled Direct Testimony in this Cause on

 7            October 15, 2010?

 8   A3.      Yes.


 9   Q4.      What is the purpose of your supplemental testimony in this proceeding?

10   A4.      The purpose of my supplemental testimony is to describe IPL’s proposed Electric Vehicle

11            (“EV”) Charging Plan developed to assist in managing and collecting data about the

12            potential impact of EVs in IPL’s service territory. Manufacturers are rolling-out plug-in

13            hybrid electric vehicles (“PHEVs”) and pure battery electric vehicles (“BEVs”) across

14            the nation. Think City vehicles, for example, are expected to be available in Indianapolis

15            in December of 2010. IPL has been working with vehicle manufacturers, equipment

16            manufacturers and other utilities through Project Plug-IN to address the need for Electric

17            Vehicle Supply Equipment (“EVSE”) and rate structures to enable customers to operate

18            EVs.1


19   Q5.      What updates is IPL proposing to make to its request in this proceeding concerning

20            EVs?

     1
              Project Plug-IN is an initiative to foster the creation of an electric transportation ecosystem in Indiana
     which I describe more fully in this testimony.
                                                                                                                 Soller -- 1
                                                                       Petitioner’s Exhibit JMS-S1


1    A5.   At this time, IPL is proposing to recover its costs to purchase and install EVSE in public

2          and private locations throughout its service territory to serve BEVs and PHEVs. The

3          EVSE IPL proposes to install will enable IPL to evaluate the impact of EVs on IPL’s

4          distribution system and obtain to information necessary to manage future expansion of

5          EVs in its service territory.


6    Q6.   What exhibits are you sponsoring?

7    A6.   I am sponsoring the following exhibits:


 8         Petitioner’s Exhibit JMS-S2                 Project Plug-IN Stakeholders and Roles

 9         Petitioner’s Exhibit JMS-S3                 Proposed EV Tariffs

10         Petitioner’s Exhibit JMS-S4                 Proposed Public Charging Locations

11         Petitioner’s Exhibit JMS-S5                 EV Charging Plan Budget Workpapers

12

13   Q7.   How did you prepare for this supplemental testimony?

14   A7.   I have completed electric vehicle research and participated in industry trade groups

15         including the Edison Electric Institute’s Electric Transportation Task Force and Energy

16         Systems Network (“ESN”).


17                                         RELIEF REQUESTED

18   Q8.   Please explain IPL’s update to its request in this proceeding in connection with its

19         EV Charging Plan?

20   A8.   IPL is requesting timely recovery of non-funded costs relating to its EV Charging Plan

21         incurred (1) to purchase and install approximately 200 EVSE throughout IPL’s service

22         territory and (2) to evaluate, measure and verify use of the EVSE by EV drivers over a



                                                                                          Soller -- 2
                                                                                        Petitioner’s Exhibit JMS-S1


 1            three year period (2011 through 2013).2 The EVSE will include software tools to track

 2            the quantity of electricity used to charge the EVs.                    This data will be provided to

 3            individual customers/drivers with tools to pre-program vehicle charging through an

 4            Internet-based access. IPL will also use this data to evaluate the impact of the EV

 5            Charging Plan to IPL’s electric distribution system. IPL expects to incur approximately

 6            $1,053,000 in associated non-funded costs over the three year period.


 7   Q9.      How is IPL proposing to recover these costs?

 8   A9.      As explained in more detail in Witness Cutshaw’s supplemental testimony, IPL is

 9            proposing to recover the costs through its Standard Contract Rider No. 22.


10                                  IPL’S PROPOSED EV CHARGING PLAN

11   Q10. Why has IPL developed its EV Charging Plan?

12   A10.     IPL developed its EV Charging Plan to prepare for electric transportation in Central

13            Indiana. Many studies, including the recently released Electric Vehicles in America: The

14            question is no longer “whether” they will come, but “how fast” and “where first”,

15            indicate that EVs will be deployed in cities where auto industry investments,

16            infrastructure, policies and EV consumer education prevail.3 Through the efforts of ESN

17            and Project Plug-IN to optimize Indiana automotive industry expertise and assets, IPL is

18            deeply engaged to proactively prepare for EVs. Efforts to do so are expected to address

19            issues and minimize hurdles for customers and other electric transportation stakeholders.


20   Q11. Where will the EVSE be installed?


     2
              IPL intends to utilize about $610,000 in Department of Energy (“DOE”) funds to offset pilot project costs
     which I describe more fully in this testimony.
     3
              While the report, in which Indianapolis is listed as an aggressive follower city, is copyrighted, an electronic
     copy may be requested at this link: http://www.rolandberger.com/expertise/publications/2010-10-14-rbsc-pub-
     PEV_Readiness_Study_Electric_Vehicles_in_America.html.
                                                                                                                Soller -- 3
                                                                         Petitioner’s Exhibit JMS-S1


 1   A11.   The EVSE will be installed in both private residences, transportation fleets and in public

 2          areas. The EVSE installed in private residences and transportation fleets will be available

 3          to customers who own or lease EVs and contract with IPL to take service under a time-

 4          of-use (“TOU”) rate. The EVSE is intended as an incentive coupled with the TOU rate to

 5          promote EV charging during off-peak periods. IPL will also make EVSE available in

 6          public areas such as parking garages and businesses. EV charging in public areas is

 7          particularly critical to counter range anxiety by potential customers of EVs.


 8   Q12. How is IPL proposing to implement the rates to be paid by EVSE users?

 9   A12.   IPL has developed two tariffs relating to its EV Charging Plan – an experimental TOU

10          EV charging rate and a public EV charging rate – both of which have been filed pursuant

11          to the Commission’s 30-day administrative filing procedure. While approval of these

12          two tariffs is not being requested in this proceeding, they are closely related to IPL’s

13          updated request in this proceeding.


14   Q13. Who will own and maintain the EVSE?

15   A13.   IPL will own and maintain the EVSE that is being deployed.


16   Q14. How did IPL determine and select the EVSE equipment it proposes to install?

17   A14.   IPL, in conjunction with several other electric utilities, issued a joint Request for

18          Information in 2009 (the “RFI”) to gain a better understanding of the technical

19          capabilities of the equipment and the market manufacturing timeline, and to evaluate the

20          availability and price of EVSE, to which twelve vendors responded. Because the RFI

21          identified only a limited number of commercially available devices, IPL issued a

22          subsequent Request for Quote in 2010 (“RFQ”) to gather more accurate cost and

23          technical information.
                                                                                            Soller -- 4
                                                                              Petitioner’s Exhibit JMS-S1


1        Based on the RFI and RFQ, IPL learned that the automotive industry has developed three

2        levels of charging equipment as summarized in Table 1 below.


                                         Table 1 - Charging Parameters


                    Charge Type                 Estimated Demand            Possible Charge Tines

                   Level 1 - 120 v                    1 – 2 kW                     10 to12 hrs
                   Level 2 - 240 v                    3 - 19 kW                     4 to 6 hrs

                Level 3 - 480 v or DC             50 kW – 200 kW                     ~ 1/2 hr
3


4        A standard plug configuration for Levels 1 and 2 charging known as “J1772” or the “J-

 5       plug” was finalized in early 2010 by the Society of Automotive Engineers (“SAE”) for

6        use in the United States.4 All EVs sold in the United States will be compatible with the J-

7        plug because Level 3 or DC equipment standards have not been developed. Purchasing

8        Level 3 chargers at this time would put IPL at risk of investing in equipment that may not

 9       be compatible with the industry standard that is ultimately adopted.


10       Among the three levels of charging equipment, Level 1 requires the lowest voltage and

11       longest period of time to charge, while Level 2 is quicker and Level 3 requires the least

12       amount of time to charge. The amount of time to charge depends upon the vehicle,

13       battery design and the specific charge level. PHEVs require less electricity demand and

14       energy than electric only vehicles which are sometimes called BEVs. The EVSE costs

15       increase as the charging time decreases.




     4
         For more information, see http://teva2.com/J1772.html and http://en.wikipedia.org/wiki/SAE_J1772.
                                                                                                    Soller -- 5
                                                                        Petitioner’s Exhibit JMS-S1


 1          While there are pros and cons to the various levels of charging equipment, IPL has

 2          elected to install Level 2 EVSE. The longer charge times associated with Level 1 was a

 3          significant disadvantage. Among the faster Level 2 and Level 3 charging equipment,

 4          Level 2 has advantages over the Level 3 set-up, which off-set the faster charge available

 5          under Level 3. As I already noted above, there is no set standard for Level 3 charging

 6          plugs and vehicle manufacturers do not plan to equip all vehicles with the Level 3 “super

 7          fast” charging capability. EVSE manufacturers are in the process of completing the UL

 8          listing process, which is necessary to successfully deploy the devices for use in homes

 9          and public spaces.


10          IPL established criteria to select specific EVSE equipment based on the RFI and RFQ

11          responses which include: use of the J-plug, successful product UL listing, ability to begin

12          to deliver products in 2010, total cost of ownership, integration with customer and utility

13          facing software through two-way communicating technologies, company stability and

14          company experience. Negotiations with EVSE vendors continue.


15   Q15. When does IPL anticipate the EVSE will be needed in its service territory?

16   A15.   ESN has received a grant to subsidize the cost of an initial deployment of Think City

17          vehicles through Project Plug-IN that are expected to begin arriving in the Indianapolis

18          area in mid-December, 2010. IPL anticipates installing fifty (50) public or fleet Level 2

19          EVSE and one hundred and fifty (150) residential Level 2 EVSE over a two-year pilot

20          period. In order to provide Level 2 EVSE to early vehicle owners, IPL anticipates

21          installing some of its residential Level 2 EVSE in December 2010. IPL anticipates its

22          EVSE will be deployed within the 2010 to 2012 calendar years.




                                                                                            Soller -- 6
                                                                       Petitioner’s Exhibit JMS-S1


1           As Project Plug-IN partners purchase and take delivery of the Think City vehicles, IPL

2           intends to continue its deployment of Level 2 EVSE to support charging needs beginning

3           in the December 2010 timeframe and continuing into Quarter 1 of 2011. Through my

 4          discussions with vehicle manufacturers and dealers, I have gained an appreciation for the

 5          need to closely collaborate with each other to ensure customers’ needs are satisfied. The

 6          adoption of EVs is changing the way dealers sell cars and the way utilities prepare for

 7          additional electricity demands.   For example, customers likely will not be able to

 8          purchase an EV and drive it home the same day due to the need to assess customers’

 9          electrical facilities to accommodate vehicle charging.          In fact, some vehicle

10          manufacturers, such as Nissan, have established web-based questionnaires and

11          reservation systems to facilitate this process. Early providers will help to establish

12          business practices and routine communication paths for future providers.


13   Q16. Please explain why the proposed installation dates seem so aggressive?

14   A16.   As many aspects of EVs are evolving, IPL’s proposed timeline is dependent upon the

15          availability of EVs, EVSE and Department of Education (“DOE”) funding. IPL has

16          worked very closely with EVSE vendors that have either completed or are nearing

17          completion of successful UL listing. The recently completed Think City vehicle design

18          specifications for data logging were incorporated into IPL’s plan for EVSE data

19          capabilities. Lastly, IPL is able to utilize DOE funding for EVSE through two separate

20          grants – IPL’s Smart Grid Investment Grant (“SGIG”) (described in my direct testimony

21          in this proceeding), and a separate Smart Grid Technology Grant through the State of

22          Indiana and ESN (“SGTG”). These allocations are available through April 2013 for

23          SGIG (which IPL intends to use for residential locations) and September 2011 for SGTG

24          (which IPL intends to use for public or fleet locations). With many moving pieces, EV
                                                                                          Soller -- 7
                                                                              Petitioner’s Exhibit JMS-S1


1           stakeholders have worked expediently and collaboratively to develop plans that will

2           accommodate least common denominators for multiple EVs such as a variety of user

3           interfaces. These efforts are likely to benefit customers by providing tools to easily

4           establish EV driving behaviors upon receipt of their vehicles. IPL is attempting to

5           understand changing customer electricity needs, new technologies and to assist its

6           customers during their transition to using EVs.


7    Q17. Please describe Project Plug-IN.

8    A17.   Project Plug-IN is an initiative started in 2009 by ESN to integrate electric vehicles and

9           ‘smart grid’ technologies to develop a “clean-tech” green transportation ecosystem

10          through industry-led pilot projects.5        Petitioner’s Exhibit JMS-S2 is a list of the

11          stakeholders engaged in Project Plug-IN (comprised of battery, component and vehicle

12          manufacturers, universities, and governmental entities) and the roles of each entity. As a

13          stakeholder, IPL is especially engaged with planning the deployment of EVSE. Specific

14          elements of Project Plug-IN are expected to continue to evolve as EVs are introduced in

15          central Indiana. Partners involved with imminent EV readiness activities, including Duke

16          Energy Indiana (“Duke”), IPL, ESN, and Think, meet weekly to facilitate logistics related

17          to EVSE installations, data logging capabilities, vehicle reservation and deliveries.


18   Q18. Is IPL’s EV Charging Plan consistent with Project Plug-IN?

19   A18.   Yes. IPL has been working with and through Project Plug-IN to develop the initiatives

20          that are necessary to facilitate EVs in IPL’s service territory. Project Plug-IN has not

21          established uniform policies to be applied to every service territory. Instead, the purpose

22          of Project Plug-IN is to facilitate communication while recognizing the unique


     5
            See http://www.cincorp.com/energysystemsnetwork/ for more information about ESN.
                                                                                               Soller -- 8
                                                                          Petitioner’s Exhibit JMS-S1


1           characteristics of each utility’s service territory. Project Plug-IN has been a valuable

2           resource for IPL to meet manufacturers and to keep abreast of the likely availability of

3           EVs in its service territory.


4                                       EVALUATION OF DATA

5    Q19. How will EV charging data be collected and over what period of time?

6    A19.   IPL has been working closely with its ESN partners over the last eighteen months to

7           finalize plans to gather electricity consumption, miles driven, state of charge of batteries,

8           and other information to assess battery conditions through data logging equipment on the

9           initial group of Think vehicles. This data will be transmitted through General Packet

10          Radio Service (“GPRS”) technology (typically used for cell phone communication)

11          through Purdue University and support aggregate analysis for grid impact studies and

12          long-term forecasting. In addition, IPL plans to implement web-based tools that allow

13          vehicle users to preset or program charging activities to optimize TOU rates and access

14          their specific energy usage data from EVSE and include a scalable solution to integrate

15          with IPL’s Home Energy Management System in the future. IPL intends to share non-

16          confidential information with project stakeholders including the Midwest Independent

17          Transmission System Operator, Inc. (“MISO”), State Utility Forecasting Group

18          (“SUFG”), the Office of Utility Consumer Counselor (“OUCC”), and the Indiana Utility

19          Regulatory Commission (”IURC”) through an annual report.


20   Q20. How will this data be utilized?

21   A20.   IPL and Duke have discussed using the data to understand system impacts on their

22          respective facilities and system reliability as well as to design and verify EV rates and

23          possibly propose effective rate modifications, and incorporate the information in long-

                                                                                              Soller -- 9
                                                                        Petitioner’s Exhibit JMS-S1


1           term planning models such as Integrated Resource Plans (“IRPs”). SUFG and MISO are

2           interested in long-term forecasting applications as well. In addition, the stakeholders

3           anticipate assessing the battery testing lessons learned for considerations in future

4           Ancillary Services Market (“ASM”) functionality, tariffs, and business practice language.

5           IPL, Duke and MISO have conducted initial project discussions and anticipate continuing

6           to collaborate in the coming months.


 7                      UNIQUE ASPECTS OF IPL’S SERVICE TERRITORY

 8   Q21. What specific characteristics of IPL’s service territory present challenges and

 9          opportunities for EV success?

10   A21.   IPL’s central metropolitan hub is uniquely positioned to serve as the hub in a public

11          electric vehicle charging ecosystem. According to Indianapolis Downtown Inc., while

12          the downtown population exceeds 19,000 people, over 127,000 come to work and over

13          48,000 students attend classes near the central business district.6    According to the

14          Indianapolis Convention & Visitors Association, nearly 22 million visitors positively

15          impact the local economy.7 This combined volume of people in the City utilizes public

16          parking spaces that exceed 66,000 and present an excellent opportunity to support electric

17          vehicle deployment. The central location of Indianapolis presents opportunities to raise

18          awareness of EVs and reduce concerns about the ability to regularly use electric vehicles

19          for commuting without running out of “juice” or energy in the battery, which some

20          electric vehicle experts have named “range anxiety.”




     6
            See http://www.indydt.com/factsheet.cfm?&lm=ai.
     7
            See http://indypressreleases.wordpress.com/.



                                                                                          Soller -- 10
                                                                        Petitioner’s Exhibit JMS-S1


 1          The fact that utilization of the actual facilities will not be known until public charging

 2          equipment is deployed presents business case challenges. However, IPL believes public

 3          charging equipment has the potential to positively influence use of EVs.


 4   Q22. Public charging appears to present unique challenges with multiple customers.

 5          How does IPL plan to address those challenges?

 6   A22.   Project Plug-IN partners discussed public charging extensively over the past 18 months

 7          and considered many ownership and operational options. Retail partners are open to

 8          hosting EVSE on their property, but hesitate to invest in equipment based on uncertain

 9          levels of EV use and associated charging activity. There are a few metropolitan areas

10          with public EVSE including Portland, Oregon and San Jose, California, where the

11          municipal governments own the EVSE and are offering free usage for a pilot period.

12          While this may appeal to early users, free usage may foster a sense of entitlement for free

13          fuel.   In addition, free charging does not provide a revenue stream for equipment

14          operation and maintenance (“O&M”) expenses or replacement costs.


15          An additional challenge for EV stakeholders is determining price points for charging

16          session fees that are cost-based but also appeal to potential customers. The amount of

17          electricity consumed and equipment costs are both elements to consider when

18          establishing an appropriate charging session fee. IPL proposes to own and manage its

19          public EVSE on Project Plug-IN partner properties where customers may pay a fixed

20          usage fee during the pilot period. IPL would report the costs and revenues through

21          annual reports.   Transparent reporting of the business case parameters may foster

22          additional independent EVSE investments. Given the small scale of the proposed pilot




                                                                                           Soller -- 11
                                                                         Petitioner’s Exhibit JMS-S1


 1          and emergence of third-party service options, IPL is investigating prepaid and swipe card

 2          options with EVSE vendors to ease customer use and avoid billing complexities.


 3   Q23. Has IPL developed draft public charging business case information and completed

 4          break even analysis scenarios?

 5   A23.   Yes. Break even (“B/E”) analysis scenarios based on a flat fee of $5.00 per session

 6          indicate the best-case timing of B/E in 2015 if two vehicles per day are charged at each

 7          EVSE during Years 1 to 5 with escalations up to three charges per day in Years 6 to 10. I

 8          am not aware of any public charging studies based on actual field data and customer

 9          responses, which supports the need for the Indianapolis area pilot. IPL’s staff continues

10          to engage with industry stakeholders to share and gather information as well.


11                  POTENTIAL IMPACT ON IPL’S DISTRIBUTION SYSTEM

12   Q24. What impact does IPL anticipate EVs to have on its electric distribution system?

13   A24.   It is difficult to predict the potential impact of EVs to the IPL distribution system, which

14          is precisely why IPL is proposing this pilot project. Variances in battery design, vehicle

15          design, driving patterns, charging behavior and weather are expected to affect energy

16          consumption. The concentration of EVs on individual circuits, electricity requirements

17          of the vehicles, existing transformer capacity and individual charging behavior will all

18          affect the impact to the IPL’s distribution system.


19   Q25. How has IPL forecasted energy consumption due to EVs?

20   A25.   IPL included forecasted consumption in the load forecast of its 2009 IRP where 10% of

21          the total vehicles are EV in 2020. Many studies report a wide range of possible adoption




                                                                                            Soller -- 12
                                                                                    Petitioner’s Exhibit JMS-S1


 1           rates from 1.5% to 10%.8 EV readiness is expected to directly influence the availability

 2           and adoption of EVs. Vehicle manufacturers are planning launch cites based in part upon

 3           customer offerings such as subsidized EVSE, the prevalence of public charging, special

 4           EV electric tariffs and state and local tax incentives.


 5   Q26. What have you learned from other studies?

 6   A26.    National studies performed by parties interested in EV deployment indicate a range of

 7           results about the potential impact of wide-scale deployment of EVs based upon a variety

 8           of assumed inputs. While specific findings vary, most studies agree that unmanaged

 9           charging will likely stress the capacity of existing electric grid infrastructure while

10           managed charging can use existing capacity. The Electric Power Research Institute

11           (“EPRI”) and individual utilities have completed recent studies about possible impacts to

12           distribution systems; however the majority of these entities plan to wait to publish results

13           with data from actual driving and charging experiences.


14           In addition, the recently formed Electrification Coalition comprised of transportation

15           electrification advocates cite the need for utilities to assess load capabilities and possibly

16           upgrade transformers to adequately serve new EV load.9                     IPL proposes to leverage

17           transportation electrification industry data and pilot data to determine a range of potential

18           impacts based on actual experiences in Indiana.


19   Q27. How does IPL plan to manage impact on its distribution system?




     8
                According to presenters at a recent EV conference “Business of Plugging IN” held in Detroit which may be
     downloaded at http://www.bpiconference.com/agenda.
     9
                See the November 2009 Electrification Roadmap report at pages 101-102. This report may be downloaded
     at http://electrificationcoalition.org/electrification-roadmap.php.

                                                                                                          Soller -- 13
                                                                                      Petitioner’s Exhibit JMS-S1


 1   A27.     IPL plans to communicate extensively with electric vehicle dealers and owners to identify

 2            affected service locations and load requirements of specific battery designs. IPL is

 3            committed to offering ‘smart’ EVSE coupled with time-varying or TOU rates for EV

 4            owners to incent off-peak charging to manage the impact on its distribution system. IPL

 5            anticipates a primary benefit of the proposed pilot is to assess the possible grid impacts

 6            through analysis of collected granular charging data to proactively plan for future EV

 7            deployments.


 8                                      FRAMEWORK FOR TOU RATES

 9   Q28. Please describe the basis for developing EV TOU rates.

10   A28.     IPL has developed two experimental EV rates – one energy-only rate for customer

11            premise charging (Rate EVX) and a public charging rate (Rate EVP), both of which IPL

12            proposes to be made available through December 2012.10 IPL relied upon an assessment

13            by Christensen Associates Energy Consulting, LLC to develop the EVX tariff. Due to

14            the availability of DOE funding, the customer premise charging tariff (Rate EVX)

15            includes an option for IPL to provide an EVSE without a monthly lease fee. Should

16            customers opt to provide their own non-advanced EVSE, they may still participate in the

17            TOU EV rate (Rate EVX) or utilize the standard tariff rate. A copy of the tariffs is

18            attached hereto as Petitioner’s Exhibit JMS-S3.


19   Q29. Does IPL anticipate initially offering a whole-house rate or vehicle-only rate for an

20            electric vehicle owner?




     10
               As discussed previously, IPL is seeking approval through the 30-day administrative filing process for these
     tariffs. If approved through the quicker 30-day administrative filing process, EV tariffs will be available to
     customers sooner, when several customers will already have EVs.
                                                                                                            Soller -- 14
                                                                                     Petitioner’s Exhibit JMS-S1


1    A29.    IPL’s initial offering is for a stand-alone electric vehicle rate which would be in effect for

2            all seasons and billed simultaneously as a net-metered amount.


3    Q30. How will IPL separately meter the EV usage?

4    A30.    IPL considered many metering options to collect EV kWh and to net-meter it separate

5            from the whole-house meter. Ideally, IPL intends to optimize the use of its Advanced

6            Metering Infrastructure (“AMI”) which IPL is in the process of deploying to collect and

7            transmit interval EV kWh consumption information. In the interim, other technologies

8            were considered including the existing Automated Meter Reading (“AMR”) system

9            coupled with the Tendril AMR to Zigbee gateway system, a transitional AMI system,

10           current interval meters which are manually read through handheld computerized devices,

11           standard measuring integrated circuit (IC) chips in EVSE units, and revenue grade meter

12           IC chips in the EVSE coupled with AMI.11 The most cost effective and efficient solution

13           appears to be to use a revenue grade IC chip in the EVSE which communicates with the

14           AMI meter using Zigbee. Based on research and conversations with other utilities and

15           vendors, I have not found other entities deploying this solution to date. As an interim

16           step and to prove the technology, IPL plans to use manually read interval meters in

17           parallel with the revenue grade IC chip in the EVSE in the homes of five employees

18           willing to participate in the Think pilot for up to one year and to report comparative

19           results. IPL will have the capability to test the EVSE meter solution remotely and

20           recognize the whole-house meter as the primary source for billing data.


21   Q31. How did IPL develop the public charging tariff (Rate EVP)?



     11
               Standard measuring IC chips are rated to provide data accuracy of +/- 3.0 % while revenue grade IC chips
     are rated for +/- 0.05% accuracy.
                                                                                                           Soller -- 15
                                                                                      Petitioner’s Exhibit JMS-S1


1    A31.     IPL designed the Rate EVP with six cost components: energy usage, installation costs,

2             connectivity, transaction fee, sales tax and IRT taxes. While the SGTG may be used to

3             recover part of the EVSE expenses, it does not cover the service installation expenses,

 4            which are significant.12 IPL included the non-funded installed capital costs as a cost

 5            element in the fee calculations over a five year period to maintain an attractive rate to

 6            incent equipment usage. A TOU element was considered, however, IPL believes this

 7            may confuse customers and lead to complaints and that a flat fee will be simpler for

 8            customers to understand. Since customers may voluntarily choose whether or not to

 9            charge their vehicles in public locations, the fees should be easy to understand to gain the

10            benefit of actual experience and data. A map of proposed public charging locations is

11            attached hereto as Petitioner’s Exhibit JMS-S4.


12                                                    EVSE AS DSM


13   Q32. Why is IPL proposing to recover costs associated with the EVSE as part of its DSM

14            filing?

15   A32.     The EVSE is being provided to customers in connection with a customer agreement to

16            utilize a TOU rate. The purpose behind this structure is to influence a customer’s load

17            shape to ensure that charging an EV does not occur during peak electric use periods.

18            This is accomplished both through pricing and the provision of equipment that enables

19            customers to schedule charging to occur during off-peak periods. While this is not taking

20            an existing load and moving it to an off-peak period, it is an attempt to recognize a new

21            potential load and shape that load to off-peak periods. IPL estimates the average owner

     12
              The SGTG may only cover technology purchases, not installations. IPL intends to install separate meters
     with new service points at each public charging location. The estimated cost to do so is about $50,000 at each of five
     locations due to the need to penetrate concrete vaults. Neither of the two grants considers this approximate
     $250,000 as an allowable cost.
                                                                                                            Soller -- 16
                                                                       Petitioner’s Exhibit JMS-S1


 1          who drives an EV about 1,000 miles per month (or 12,000 miles per year) may consume

 2          200 kWh per month (or 2,400 kWh per year) which represents about a 20% increase in

 3          average monthly consumption of 1,000 kWhs per month.           However, the household

 4          demand may rise by 75% based upon 3.3 kW for the EVSE with average demand of 4.5

 5          kW if the charging is not managed. IPL proposes to get in front of this demand impact

 6          through this pilot program.


 7   Q33. Why is IPL proposing to recover the costs associated with the EVSE in public

 8          locations as part of its DSM filing?

 9   A33.   While EVSE installed in public locations does not include TOU or timers to encourage

10          charging during off-peak periods, the availability of public EVSE is a mandatory

11          component of anticipating the needs for EVs.        The public charging equipment is

12          necessary to address range anxiety and should be included in IPL’s overall EVSE

13          management programs.


14   Q34. Has IPL evaluated how inclusion of its proposed EV Charging Plan impacts the cost

15          effectiveness of its overall DSM filing?

16   A34.   Yes. IPL evaluated the cost effectiveness of its Core Plus Programs with the inclusion of

17          the EVSE program and IPL’s Core Plus Programs remain cost effective. Including the

18          EVSE expenditures in the overall Core Plus Programs results in a slight drop under the

19          Total Resource Cost from a net present value of $40.1 million to $39.7 million. The

20          benefit cost ratio of the Core Plus Programs dropped from 2.37 to 2.31 with inclusion of

21          the EVSE expenditures.




                                                                                         Soller -- 17
                                                                                 Petitioner’s Exhibit JMS-S1


1                            PRELIMINARY CUSTOMER MARKETING PLANS

2    Q35. How does IPL plan to market its proposed EV Charging Plan to potential

3               customers?

4    A35.       IPL plans to work closely with vehicle manufacturers, local auto dealers, ESN and local

5               partners to develop and circulate educational materials. IPL has also contacted the

6               consortium of Indiana University institutions that has acquired American Recovery and

7               Reinvestment Act (“ARRA”) funding to foster public EV awareness to optimize

 8              resources. Ivy Technical Institute and Purdue University are in the process of developing

 9              EV workforce development programs with input from Project Plug-IN partners that are

10              expected to foster public awareness.         The 2012 Super Bowl Committee members,

11              including IPL employees, have also been engaged in marketing discussions and

12              expressed interest in showcasing electric vehicles as part of its “1st and Green”

13              sustainable “green” living initiative.13 Stakeholders including the OUCC and IURC

14              Consumer Services staff are welcome to participate in collaborative efforts. Program

15              administration costs include creating marketing materials to effectively communicate

16              with potential EV owners.


17   Q36. How are other Project Plug-IN partners supporting marketing efforts?

18   A36.       Simon Property Group has discussed providing public advertising space for Project Plug-

19              IN. Other Project Plug-IN partners who are willing to install EVSE for public use have

20              described plans to designate special EV parking zones with painted floor space and

21              signage to increase public awareness. Specific project information will likely be included

22              on the Project Plug-IN and IPL website with links to national resources such as the

23              Rocky Mountain Institute and the Electric Drive Transportation Association.

     13
          See http://www.indianapolissuperbowl.com/find/1st%20and%20green for more information.
                                                                                                  Soller -- 18
                                                                        Petitioner’s Exhibit JMS-S1


 1                               PROJECT COSTS AND TIMELINE

 2   Q37. Please describe the resource analysis performed by IPL for this project.

 3   A37.   IPL considered project costs for a stand-alone option as well as one that builds upon its

 4          DSM programs approved in Phase II of its prior DSM proceeding in Cause No. 43623,

 5          which includes the deployment of AMI Home Energy Management Systems and On-line

 6          Energy Feedback tools.      These technologies provide the communication backbone,

 7          metering and web-based tools to enable EV owners and IPL to access a holistic energy

 8          consumption view. This integrated approach is expected to minimize customer confusion

 9          and best use IPL information technology resources.


10   Q38. Please describe the project costs.

11   A38.   Petitioner’s Exhibit JMS-S5 contains detailed information of equipment purchase costs,

12          installation costs, software fees, and connectivity fees over a three (3) year period based

13          upon RFQ responses and extensive discussions with vendors with whom IPL continues to

14          negotiate. The most significant expense category is equipment installation costs followed

15          by data analysis/evaluation, measurement and verification expenses. IPL also anticipates

16          working with Purdue University on EV transportation and distribution system impact

17          studies to build upon an active initiative that the parties are funding independently from

18          this proceeding.


19   Q39. How will the DOE grant funds be used?

20   A39.   Specific DOE SGIG and SGTG funds are shown as a credit on the worksheets that

21          comprise Petitioner’s Exhibit JMS-S5. At a high level, the SGIG funds account for

22          $308,000 while SGTG funds account for $302,000. In this proceeding, IPL is requesting

23          authority to recover the remaining $1,053,000 from its customers.

                                                                                           Soller -- 19
                                                           Petitioner’s Exhibit JMS-S1


1   Q40. Does this conclude your supplemental testimony?

2   A40.   Yes.




                                                                           Soller -- 20
                                          VERIFICATION

             I, Joan M. Soller, Manager, Corporate Planning ofIndianapolis Power & Light Company,

 affirm under penalties of perjury that the foregoing representations are true and correct to the

 best of my knowledge, information and belief.




                                                      Dated: December 10, 2010




INDSO I I240738v 1




                                                                                     Soller -- 21
November 2010                                  Summary of Project Plug-IN Stakeholders and Issues                                               Cause No. 43960
                                                                                                                                      Petitioner's Exhibit JMS‐S2
Entity/Group                                Specific Companies                        Role/Issues
Utilities                                   IPL, Duke Energy, Midwest ISO, PJM        Coordination of technical electrical issues, 
                                                                                      facilitating the installation of EVSEs, grid impact, 
                                                                                      load forecasting, demand response business 
                                                                                      practices, metering
Battery Manufacturers                       EnerDel, ITOCHU, Altairnano               Battery requirements, limited home‐energy storage 
                                                                                      pilot  
Vehicle Manufacturers                       Nissan, Navistar, Smart USA, THINK,       Vehicle Availability, technical design and standards 
                                            Bright Automotive, Rolls Royce            and electrical requirements, utility transformer 
                                                                                      loading concerns and processes to educate and 
                                                                                      enroll customers
Governmental Entities                       State of IN Economic Development          Vehicle rebate programs, green fleet initiative, 
                                            Corporation                               installing charging for state fleet vehicles, economic 
                                                                                      development for partners
                                            City of Indianapolis ‐ Office of          Permitting – electrical, structural, historic   district 
                                            Sustainability                            variances for street side charging, combining 
                                                                                      parking meter with charger
                                            Federal Department of Energy (DOE)        While DOE is not a formal member of PPI, IPL will 
                                                                                      share aggregate EV data collected as part of its 
                                                                                      smart grid project including customer experiences, 
Regulators                                  Indiana Utility Regulatory Commission               /
                                                                                      Time varying rates, cost recovery and/or 
                                            (IURC)                                    accounting treatment 
Electric Vehicle Supply Equipment (EVSE)    Aerovironment, etec, GE, Couloumb,        These vendors are not formal members of PPI, but 
Vendors                                     CMI, SPX, Clipper Creek                   platy a key role to provide equipment, installation 
                                                                                      requirements, interface with Society of Automotive 
Universities                                Purdue, Notre Dame, Indiana University    Data Analysis, public educational campaigns, EV 
                                            and Ivy Tech Community College.           website "hub", workforce development

Local commercial customers                  Simon Property Group, Denison Parking,    Locations for public charging 
                                            Indiana Museum of Art
Automotive suppliers                         Remy, BAE Systems, Cummins, Delhi        Understanding charging system components 

Consulting and Software Entities            Rocky Mountain Institute, IBM, SAIC,      Integration for web‐viewing, home energy 
                                            and Gridpoint                             management, utility aggregate data views, and 
                                                                                      billing at public locations 
                                                                                     Petitioner's Exhibit JLS-S3
Indianapolis Power & Light Company                I.U.R.C. No.E-16                          Original No. 130
One Monument Circle
Indianapolis, Indiana

                                         RATE EVX
                            EXPERIMENTAL TIME OF USE SERVICE
                   FOR ELECTRIC VEHICLE CHARGING ON CUSTOMER PREMISES

AVAILABILITY:
Available to Customers concurrently served under any of the following retail electric rates: Rate RS, Rate SS,
Rate SH, or Rate SL, exclusively for charging of such Customers’ licensed electric vehicles (EVs) using
electricity provided by the Company at locations on such Customers’ premises within the Company’s assigned
utility service area. Participation is voluntary. Energy consumption metered and billed under this tariff shall be
used exclusively for charging electric vehicles.

The Company reserves the right to periodically interrupt service to test demand response strategies and system
results. The Company does not anticipate receiving demand response revenues or providing monetary credits to
Customers at this time.

EQUIPMENT:
For the first 150 eligible Customers who take service under this rate, the Company will procure, pay for, install,
own, and maintain: (1) Level 2 (120/240 volt) EV charging equipment (limited to one (1) unit per residential
Customer) and (2) any separate metering equipment required to participate.

Service under this rate must be supplied through a separately metered circuit. Company installation will include a
dedicated 40 amp circuit and up to a 30 ft. run between the Customer’s electrical panel and the EV charging
equipment, which will become Customer’s property upon installation. Customers agree to install and maintain
any additional necessary equipment. Such installations must conform to current National Electric Code (NEC)
specifications. Charging may only be accomplished using an SAE approved J1772 plug.

For additional eligible Customers who take service under this rate, the Company will procure, pay for, install,
own, and maintain any separate metering equipment required to participate. Customers shall be responsible for
procuring, paying for, installing, and owning the EV charging equipment, a dedicated 40 amp circuit, and any
additional necessary equipment. Customer procured EV charging equipment must meet UL listing standards.

If, prior to the conclusion of a twelve (12) month period on this rate, the Customer requests that the Company
remove the EV charging equipment and any separate metering equipment, the Customer shall pay a removal fee
of $100, to reimburse the Company for all costs associated with removal of such equipment.

If, during the term of this rate, the Customer requests removal and relocation of the charging equipment and
meter within the Company’s service territory, the Customer shall pay all costs associated with removal and
relocation of the charging equipment.

METERING AND BILLING:
EV charging service will be separately metered and identified on the bill in accordance with the Company's
applicable rate schedule. Should interval gaps occur, consumption will be billed at the appropriate off-peak rate.

CHARACTER OF SERVICE:
Sixty cycle alternating current energy, ordinarily delivered and measured at 120/240 volts single phase three
wire, 120/240 volts three phase four wire, or 120/208 volts three phase four wire, at the option of the Company.

RATE:
The Energy Charge shown hereafter plus the Fuel Cost Adjustment, the Environment Compliance Cost
Recovery Adjustment, and the Core and Core Plus Demand-Side Management Adjustment calculated in
accordance with Rider No. 6, Rider No. 20 and Rider No. 22, respectively.




                                                                                    Effective Pending
                                                                                    Petitioner's Exhibit JLS-S3

Indianapolis Power & Light Company                I.U.R.C. No.E-16                          Original No. 131
One Monument Circle
Indianapolis, Indiana


       Energy Charge June through September (Summer Months)
               For all Peak kWh                                                    12.150¢ per kWh
               For all Mid-Peak kWh                                                5.507¢ per kWh
               For all Off-Peak kWh                                                2.331¢ per kWh

Summer Months
                            Peak                         Mid-Peak                     Off-Peak
Non-Holiday Weekdays                                     10 a.m. to 2 p.m.            Midnight to 10 a.m.
                      2 p.m. to 7 p.m.
(Monday—Friday)                                          7 p.m. to 10 p.m.            10 p.m. to Midnight
Weekends and Observed                                                                 Midnight to 10 a.m.
                      N/A                                10 a.m. to 10 p.m.
Holidays*                                                                             10 p.m. to Midnight

*Observed Holidays include: Independence Day and Labor Day

       Energy Charge January through May & October through December (Non-Summer Months)
               For all Peak kWh                                            6.910¢ per kWh
               For all Off-Peak kWh                                        2.764¢ per kWh

Non-Summer Months
                            Peak                         Off-Peak
                                                         Midnight to 8 a.m.
        All Days            8 a.m. to 8 p.m.
                                                         8 p.m. to Midnight


PARTICIPATING CUSTOMER OBLIGATIONS: In addition to Customer obligations outlined in the
Company’s Rules and Regulations for Electric Service and in the Rules and Standards of Service for the
Electrical Public Utilities of Indiana prescribed by the Indiana Utility Regulatory Commission, as the same are
now in effect, and as they may be changed from time to time hereafter, Customers taking service under this rate
shall:

    (1) Supply the Company with suitable locations for installation of metering and other necessary equipment;
    (2) Provide sufficient access to their premises to install metering and other necessary equipment;
    (3) Be responsible for (and indemnify and hold the Company harmless with respect to) the adequacy,
         condition and operation of electrical wiring and electrical system on Customer premises, and ensure that
         such wiring and system meet, at a minimum, the provisions of the NEC, the governmental authorities
         having jurisdiction, and the reasonable requirements of the Company; and
    (4) Take responsibility for (and indemnify and hold the Company harmless with respect to) the adequacy,
         condition and operation of Customer-owned EV charging equipment.

STANDARD CONTRACT RIDERS APPLICABLE:

       No. 1                                                      see Page 150
       No. 6                                                      see Page 157
       No. 7                                                      see Page 159
       No. 9                                                      see Page 161




                                                                                   Effective Pending
                                                                                        Petitioner's Exhibit JLS-S3
Indianapolis Power & Light Company                  I.U.R.C. No.E-16                            Original No. 132
One Monument Circle
Indianapolis, Indiana

       No. 20                                                        see Page 179.2
       No. 21                                                        see Page 179.3
       No. 22                                                        see Page 179.5

PAYMENT:
The above rates and charges are net. If the net bill is not paid within seventeen (17) days after its date of issue, a
collection charge will be added in the amount of ten percent (10%) of the first Three Dollars ($3.00) plus three
percent (3%) of the excess over Three Dollars ($3.00).

TERM:
The anticipated term for this rate is approximately two years beginning with the date of approval by the
Commission. Participating Customers shall be required to participate for a minimum term equal to the shorter of
twelve (12) months, or through the end of the term. Until it is terminated or superseded by a new rate approved
by the Indiana Utility Regulatory Commission, this rate will remain in effect beyond the end of the term.

RULES:
Service hereunder shall be subject to the Company's Rules and Regulations for Electric Service, and to the Rules
and Standards of Service for the Electrical Public Utilities of Indiana prescribed by the Indiana Utility
Regulatory Commission, as the same are now in effect, and as they may be changed from time to time hereafter.




                                                                                       Effective Pending
                                                                                      Petitioner's Exhibit JLS-S3
Indianapolis Power & Light Company                 I.U.R.C. No.E-16                           Original No. 140
One Monument Circle
Indianapolis, Indiana


                                    RATE EVP
      EXPERIMENTAL SERVICE FOR ELECTRIC VEHICLE CHARGING ON PUBLIC PREMISES

AVAILABILITY:
Available to Customers charging their electric vehicles (EVs) at certain public charging facilities located within
the Company’s assigned utility service area. Such public charging facilities may be located at hotels, museums,
public parking facilities, etc. Participation is voluntary. Energy consumption billed under this rate shall be used
exclusively for charging licensed electric vehicles.

EQUIPMENT:
The Company will own and operate the public charging equipment and will install, own and operate any
necessary metering equipment subject to a lease agreement with the owners of the property on which public
charging equipment is located. Customer’s charging system in the electric vehicle must meet applicable
standards. Further, Customers must take responsibility for (and indemnify and hold the Company harmless with
respect to) the adequacy, condition and operation of the Customers’ charging system in the electric vehicle.

METERING AND BILLING:
EV charging service will be billed and paid for at the point of service prior to charging by means of credit, debit,
or pre-paid cards, as determined by the Company, at rates specified in this rate schedule. The charging service
will be metered separately.

CHARACTER OF SERVICE:
Sixty cycle alternating current energy, ordinarily delivered and measured at 120/240 volts single phase three
wire, 120/240 volts three phase four wire, or 120/208 volts three phase four wire, at the option of the Company.
Service provided includes use of the charging equipment, electricity needed per session, and the convenience of
charging in a public location.

RATE:
During the term of this rate, the initial service charge is a flat fee of $5.00 per charging session. The Company
may seek authority to change this rate, if approved by the Indiana Utility Regulatory Commission.

STANDARD CONTRACT RIDERS APPLICABLE:
NONE

PAYMENT:
This rate requires Customers to prepay for the voluntary service provided pursuant to this tariff by means of
credit, debit, or pre-paid cards only, as determined by the Company. Payment must be made before charging
service is rendered.

TERM:
The term for this public charging rate is the date of Commission approval continuing for approximately two
years. Until it is terminated or superseded by a new rate, this rate will remain in effect beyond the end of the
term.

RULES:
Service hereunder shall be subject to the Company's Rules and Regulations for Electric Service, and to the Rules
and Standards of Service for the Electrical Public Utilities of Indiana prescribed by the Indiana Utility
Regulatory Commission, as the same are now in effect, and as they may be changed from time to time hereafter.



                                                                                     Effective Pending
                                                                                                                               Petitioner's Exhibit JMS-S4


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                                                                                              65




                                                                                                            C
             IPL SERVICE TERRITORY                                                                          DUKE SERVICE TERRITORY

1. IPL MORRIS STREET SC.                  7. INDIANAPOLIS AIRPORT                        A. MIDWEST ISO                                            E. NOBLESVILLE DISTRICT
   1230 W. MORRIS ST.                        7801 COL. H. WEIR COOK MEM. DR.               701 CITY CENTER DR.                                        OFFICE
                                                                                                                                                      NOBLESVILLE
2. IPL ARLINGTON SC                       8. JW MARRIOTT                                 B. SIMON MALL - CLAY TERRACE
   3600 N. ARLINGTON AV.                     10 S. WEST ST.                                14390 CLAY TERRACE BLVD.                                F. CARMEL DISTRICT OFFICE
                                                                                                                                                      1441 S. GUILFORD
3. DENISON MERCHANTS                      9. STATE OF INDIANA                            C. SIMON MALL - GREENWOOD                                    CARMEL
   GARAGE                                    100 N. SENATE AV.                             1251 US HIGHWAY 31 N
   31 S. MERIDIAN ST.                     10. CONVENTION AND                             D. PLAINFIELD HQ
4. SIMON MALL GARAGE 1                        VISITORS BUREAU                              1000 E. MAIN ST, PLAINFIELD
   50 W. GEORGIA ST.                          100 S. CAPITOL AV.
                                                                                                                                                     INDIANAPOLIS POWER & LIGHT CO.
5. SIMON MALL GARAGE 2                    11. IUPUI
   129 W. MARYLAND ST.                        1040 W. MICHIGAN ST.                                                                                         PROPOSED
                                                                                                                                               R        PUBLIC CHARGING
6. IMA                                    12. ENER DEL                                                                                an AES
                                                                                                                                     company           STATION LOCATIONS
   4000 MICHIGAN RD.                          8740 HAGUE RD.
                                                                                                                                                           Cause No. 43960
                                                                                                                                                Petitioner's Exhibit JMS-S5

                                                DETAILED COSTS - EVSE
Line #                      Years                              2011                2012             2013               3 Yr Total      Unit Costs
         Residential                              (a)
   1                        Total # Participants                         75               150              150                150
   2     EVSE               EVSE Materials (b)                $     150,000    $    150,000     $          -       $       300,000     EVSE Materials                   $ 2,000
   3                        EVSE Installation Labor (c)       $     105,000    $    105,000     $          -       $       210,000     EVSE Installation Labor          $ 1,400
   4                        Prgm Admin (d)                    $      26,000    $      26,000    $          -       $        52,000
   5                        Connectivity (e)                  $      18,000 $            -      $          -       $        18,000
   6                        Software Initial                  $      18,000 $         18,000    $          -       $        36,000
   7                        Initial Assessment                $         -   $         16,000                       $        16,000
   8                        IPL Integration Costs (k)         $     120,000                                        $       120,000
  9                         SGIG Funding (f)                  $    (179,000) $     (129,000) $             -       $      (308,000)
 10                          Sub Total                        $     258,000 $       186,000 $              -       $       444,000
 11
 12                         EM&V/Data Analysis                $         -      $      16,000    $     30,000       $        46,000
 13                         Software Ongoing (j)                                                $     18,000       $        18,000
 14
 15                          Grand Total                      $     258,000 $       202,000     $     48,000       $       508,000
 16
 17      Fleet and Public EVSE Materials                                                                                               EVSE Commercial Materials        $ 8,000
 18      EVSE                # Commercial Units                          30                30               30                  30     EVSE Dual Materials              $ 5,600
                                                     (g)
 19                          Total Comm Materials             $     240,000    $          -   $            -       $       240,000     EVSE Installation Labor          $ 4,000
 20                          # Dual Units                                10                10               10                  10
                                                  (h)
 21                          Total Dual Materials             $      56,000    $          -   $            -       $        56,000
 22                       Total EVSE Materials                $     296,000    $          -   $            -       $       296,000
 23                       Software Initial                    $       6,000                                        $         6,000
                                           (i)
 24                       SGTG Funding                        $    (302,000)   $          -     $          -       $      (302,000)
 25                        Sub Total                          $         -      $          -     $          -       $           -
 26
                                          (d)
 27                         Prgm Admin                        $      46,000                                        $        46,000
 28                         Software Ongoing (j)                               $       6,000    $      6,000       $        12,000
 29                         Connectivity (e) (j)              $       2,000    $       2,000 $         2,000       $         6,000
 30                         EM&V/Data Analysis                                 $      46,000 $        25,000       $        71,000
 31                         EVSE Installation Labor (c)       $     160,000                                        $       160,000
 32                         Total IPL Svc Extension Cost      $     250,000                                        $       250,000
 33                          Grand Total                      $     458,000 $         54,000    $     33,000       $       545,000
 34
 35      All EVSEs          Gross Total                       $   1,197,000 $       385,000 $         81,000       $     1,663,000
 36      Combined           Grant Funding                     $    (481,000) $     (129,000) $           -         $      (610,000)
 37                          IPL Net Total                    $     716,000 $       256,000 $         81,000       $     1,053,000

                        (a) Number of participants is anticipated to be 150 in total, with 50% beginning in 2011 and the remainder beginning in 2012
                        (b) Residential EVSE Materials costs include equipment hardware, communication module, revenue grade meter chip within
                              the EVSE, and 5 year extended warranty (in effect through 2015)
                        (c) Installation labor as rough estimate from EVSE vendors
                        (d) Program Administration = 10% of EVSE Materials and EVSE Installation Labor. Program is expected to be administered
                              by an external party. This cost is an estimate of expected costs for that external party.
                        (e) Connectivity costs are required for data transmission from EVSE to IPL and customer web portal
                         (f) SGIG Funding covers 40.9% of costs listed in Lines 2-7 for 2011-2012. The amount shown in line 8 is rounded.
                        (g) Public Commercial Unit EVSE Materials costs include equipment hardware, communication module, and 5 year extended
                              warranty (in effect through 2015). This unit is commercial grade and has the cord encased within the unit.
                        (h) Public Dual Unit EVSE Materials costs include equipment hardware, communication module, and 5 year extended
                              warranty (in effect through 2015). This unit has two charging ports on one pedestal.
                         (i) SGTG Funding covers equipment and software costs for 2011.
                         (j) Should the program extend beyond year 3, these expenses would continue.
                        (k) IPL integration costs include IT costs for modifications to billing and integration of EVSE software for customer viewing.
                                Petitioner’s Exhibit LHA-S1




VERIFIED SUPPLEMENTAL DIRECT TESTIMONY

                   OF

            LESTER H. ALLEN

             ON BEHALF OF

 INDIANAPOLIS POWER & LIGHT COMPANY

             CAUSE NO. 43960




 SPONSORING PETITIONER’S EXHIBIT LHA-S2
                                                                      Petitioner’s Exhibit LHA-S1


           VERIFIED SUPPLEMENTAL DIRECT TESTIMONY OF LESTER H. ALLEN

 1   Q1.    Please state your name, employer and business address.

 2   A1.    My name is Lester H. Allen. I am employed by Indianapolis Power & Light Company

 3          (“IPL” or “Company”), One Monument Circle, Indianapolis, Indiana, 46204.


 4   Q2.    What is your position with IPL?

 5   A2.    I am Team Leader, Marketing and Program Management.


 6   Q3.    Are you the same Lester H. Allen who prefiled Direct Testimony in this Cause on

 7          October 15, 2010?

 8   A3.    Yes.


 9   Q4.    What is the purpose of your supplemental testimony in this proceeding?

10   A4.    The purpose of my testimony is to sponsor the revised Standard Contract Rider No. 13 to

11          reflect IPL’s request in this proceeding to offer its Air Conditioning Load Management

12          program to all Large Commercial & Industrial (“C&I”) demand-rate customers (Rates

13          SL, PL, PH and HL).


14   Q5.    Please explain the revisions to Standard Contract Rider No. 13.

15   A5.    As I explained in my direct testimony, IPL’s Current DSM Program as approved in

16          Cause No. 43623 does not apply to Rates PL, PH and HL. In the Generic DSM Order (at

17          29, 48), the Commission indicated that all customers should be provided the opportunity

18          to participate in DSM programs. IPL’s customers served under Rate Schedules HL, PL

19          and PH represent a large portion of IPL’s sales and these customers have an opportunity

20          for some of the most cost effective energy savings. The inclusion of these customers as

21          participants is also appropriate in light of the much larger energy efficiency goals that


                                                                                           Allen -- 1
                                                                      Petitioner’s Exhibit LHA-S1


1         IPL is being required to achieve. This revision requires a modification to the tariff sheet

2         to add Rates PL, PH and HL to the list of rates eligible for Standard Contract Rider No.

3         13.    IPL inadvertently omitted to include a revised tariff sheet in its case-in-chief.

4         Petitioner’s Exhibit LHA-S2 is Standard Contract Rider No. 13 that reflects this proposed

5         modification.


6   Q6.   Does this conclude your supplemental testimony?

7   A6.   Yes.




                                                                                           Allen -- 2
                                        VERIFICATION

            I, Lester H. Allen, Team Leader, Marketing and Program Management of Indianapolis

  Power & Light Company, affirm under penalties of perjury that the foregoing representations are

 true and correct to the best of my knowledge, information and belief.


                                                     ~--
                                                     Lester H. Allen

                                                     Dated: December 10, 2010




INDSOI 124l553vl




                                                                                      Allen -- 3
Indianapolis Power & Light Company                        I.U.R.C. No. E-16                      98th Revised No. 165
One Monument Circle                                                                              Superseding
Indianapolis, Indiana                                                                            87th Revised No. 165

                                                 STANDARD CONTRACT RIDER NO. 13
                                       AIR CONDITIONING LOAD MANAGEMENT ADJUSTMENT
                                        (Applicable to Rate RS, CW (with associated Rate RS service),
                                  SS, SH, UW, CW (with associated Rate SS service), and SL, PL, PH and HL)

In addition to the rates and charges set forth in the above-mentioned Rates, an Air Conditioning Load Management Adjustment (ACLM
Adjustment) applicable for the summer months of June through September shall be made in accordance with the following provisions:
A.        Eligible Customers, with central air conditioning having an electric motor driven compressor, who establish a new electric service,
          subsequent to approval of this rider, and subsequent to the initiation of a non-participant surcharge (see paragraph C), have the
          option to participate in the Air Conditioning Load Management program. At the time the service is established, the Customer must
          elect to become a participant or non-participant. At any time thereafter, but limited to one change per year, a Customer may elect to
          change his status from participant to non-participant, or from non-participant to participant. Eligible Customers, not establishing or
          changing service, may also volunteer to participate in the program and will at that time be considered a participant. Notification of
          the Customer’s election will be made in accordance with the Company’s procedures. The Company, at its sole discretion, will
          determine which Customers will be considered to be eligible Customers.
          1.        If the Customer becomes a participant, the Company, or its contractors, will install an air conditioning load management
                    device at a time that is consistent with the orderly and efficient deployment of this program. After the device is installed,
                    the device will be activated at the next record date, and the customer will receive a credit on each bill issued in the summer
                    months following the record date, as further described below.
          2.        If the Customer becomes a non-participant, an additional charge may be added to each summer month bill, as further
                    described below.
B.      Air conditioning cycling, using the air conditioning load management device, may occur between May 1 and September 30. Record
        dates to determine participant status will be May 15, June 15, July 15, and August 15. If no non-participant surcharges are to be
        collected (per paragraph C), then the record dates will be based on the date the customer signs up. In either case, credits or charges
        will be added to bills issued in June, July, August, and September.
C.      An ACLM Adjustment charge of $5.00 may be added to each Rate RS and CW (with associated RS service) non-participant’s bill for
        each summer month that the Customer is determined to be a non-participant at the record date in the preceding month. This
        determination will be made no more than once per year. Initially, there will be no surcharge.
D.      An ACLM Adjustment credit of $5.00 will be deducted from each Rate RS and CW (with associated RS service) participant’s bill for
        each summer month that the Customer is determined to be a participant at the record date in the preceding month. In addition,
        participants may choose the half-cycle service option. The air conditioners of the half cycle participants will be cycled at no more
        than half the prescribed cycling rate of the full participants, unless an emergency exists. An ACLM Adjustment credit of $3.00 will
        be deducted from each Rate RS and CW (with associated RS service) half cycle participant’s bill for each summer month that the
        Customer is determined to be a participant at the record date in the preceding month.
E.      An ACLM Adjustment credit of $5.00 per ton of cooling capacity will be deducted from each Rate SS, SH, UW, CW (with associated
        Rate SS service), SL, PL, PH and HL C & I participant’s bill for each summer month that the Customer is determined to be a
        participant at the record date in the preceding month.
F.      In addition to the previous credits and charges that apply to eligible customers, there will be an ACLM Adjustment Factor applied on
        a KWH basis to all energy sales to all residential customers for bills rendered during the summer months. The residential class
        ACLM Adjustment Factor will be calculated as follows: the sum of the revenue shortfalls or surpluses, as determined by netting the
        non-participant charges (if any) with the participant credits, will be calculated for the four summer months of the current year.1 This
        net amount will then be divided by the forecast summer months’ energy sales to residential customers for the subsequent year. The
        resulting ACLM Adjustment credit or charge for the residential customers shall be further modified to allow for the recovery of the
        utility receipts taxes and other similar revenue based tax charges. The resulting factor will be either a credit or a charge for all energy
        sold to residential customers for bills issued in June, July, August, and September of the subsequent year. Any variance in credits or
        charges collected caused by differences in actual sales from forecast sales will be reconciled in the ACLM Adjustment Factor the
        next subsequent year.
G.      The ACLM Adjustment Factor for all bills rendered for electric services beginning with the first billing cycle for June 2010 (Regular
        Billing District 41 and Special Billing District 01) will be $0.000340 per KWH for Rate RS and CW (with associated RS service).




1
        For purposes of the ACLM Adjustment participants are defined as Residential customers who were participating on Rider
No. 13 prior to February 10, 2010.




Second step of two step increase.                                                              Effective _____________May 28, 2010
                                     Petitioner’s Exhibit JLC-S1




   VERIFIED SUPPLEMENTAL DIRECT TESTIMONY

                      OF

               JAMES L. CUTSHAW

                 ON BEHALF OF

     INDIANAPOLIS POWER & LIGHT COMPANY

                CAUSE NO. 43960




SPONSORING PETITIONER’S EXHIBITS JLC-2 (REVISED)
           THROUGH JLC-4 (REVISED)
                                                                      Petitioner’s Exhibit JLC-S1


           VERIFIED SUPPLEMENTAL DIRECT TESTIMONY OF JAMES L. CUTSHAW

 1   Q1.     Please state your name, employer and business address.

 2   A1.     My name is James L. Cutshaw. I am employed by Indianapolis Power & Light Company

 3           (“IPL” or “Company”), whose business address is One Monument Circle, Indianapolis,

 4           Indiana 46204.


 5   Q2.     What is your position with IPL?

 6   A2.     I am Revenue Requirements Manager.


 7   Q3.     Are you the same James L. Cutshaw who prefiled Direct Testimony in this Cause on

 8           October 15, 2010?

 9   A3.     Yes.


10   Q4.     What is the purpose of your supplemental testimony in this proceeding?

11   A4.     The main purpose of my testimony is to provide updated cost recovery schedules to

12           reflect the removal of the recovery of lost revenue based upon the Commission’s

13           November 4, 2010 Order in Cause No. 43911. In addition, I have reflected the recovery

14           of costs related to IPL’s proposed Electric Vehicle (“EV”) Charging Plan, including

15           Electric Vehicle Supply Equipment (“EVSE”), as discussed by Witness Soller.


16   Q5.     What exhibits are you sponsoring with this supplemental filing?

17   A5.     I am sponsoring the following exhibits:


18           1.     Petitioner’s Exhibit JLC-2 (Revised) – IPL’s existing Standard Contract Rider
19                  No. 22, Core and Core Plus Demand-Side Management Adjustment, modified to
20                  remove proposed recovery of lost revenue and reflect proposed recovery of
21                  EVSE;
22
23           2.     Petitioner’s Exhibit JLC-3 (Revised) – Cost Allocation Basis and Target
                                                                                     Cutshaw -- 1
                                                                       Petitioner’s Exhibit JLC-S1


1                 Performance Incentive by Program, modified to reflect EVSE; and
2
3          3.     Petitioner’s Exhibit JLC-4 (Revised) – Determination of Impact of Core and Core
4                 Plus DSM Adjustment – Rider 22 for Years 1, 2 and 3 of the 3-Year DSM Plan,
5                 modified to remove proposed recovery of lost revenue and reflect proposed
6                 recovery of EVSE.
7
8    Q6.   Are there any exhibits from your direct testimony which you are no longer

9          sponsoring?

10   A6.   Yes. I am no longer sponsoring Petitioner’s Exhibit JLC-5 – Determination of Projected

11         DSM Lost Revenue for Years 1, 2 and 3 for the 3-Year DSM Plan.


12   Q7.   Please describe the revisions that were made to the cost recovery schedules filed

13         with your direct testimony in the proceeding.

14   A7.   The format and structure of the revised exhibits are almost exactly the same as the

15         referenced exhibits attached to my prefiled direct testimony which they replace. The first

16         change is the removal of the recovery of lost revenue related to the kWh and kW

17         reductions resulting from the proposed DSM programs. As noted in Witness Flora’s

18         supplemental testimony, IPL is no longer requesting recovery of such lost revenue based

19         upon the Commission’s Order in Cause No. 43911 issued on November 4, 2010.

20         Accordingly, I removed the additional lost revenue recovery language that had been

21         proposed for IPL’s existing Standard Contract Rider No. 22, Core and Core Plus

22         Demand-Side Management Adjustment on Petitioner’s Exhibit JLC-2 as filed with my

23         direct testimony. I also removed Line 47 titled Projected Lost Revenue and Line 48

24         Grand Total Costs to be Recovered from Petitioner’s Exhibit JLC-4 as filed with my

25         direct testimony. Finally, as noted above, Petitioner’s Exhibit JLC-5 as filed with my

26         direct testimony is no longer necessary and I am withdrawing my sponsorship of that

                                                                                       Cutshaw -- 2
                                                                      Petitioner’s Exhibit JLC-S1


1          exhibit.


2                 The other change is to reflect recovery of costs related to the EVSE discussed in

3          the supplemental testimony of Witness Soller. I added proposed recovery language to

4          IPL’s existing Standard Contract Rider No. 22, Core and Core Plus Demand-Side

 5         Management Adjustment on Petitioner’s Exhibit JLC-2 (Revised). Please note that the

 6         red-lined language revisions on this exhibit are made to the tariff approved in Cause No.

 7         43623-DSM-1 on June 30, 2010, consistent with the presentation in my direct testimony.

 8         I also inserted Lines 46 through 50 on Petitioner’s Exhibit JLC-3 (Revised) and

 9         Petitioner’s Exhibit JLC-4 (Revised) to reflect the allocations and costs for the

10         Residential, Public Charging, Fleet and Total EVSE, respectively.


11   Q8.   Did any of the Core or Core Plus DSM costs or Estimated Sales (MWh) shown on

12         these exhibits change from the exhibits filed with your direct testimony?

13   A8.   No.


14   Q9.   Please describe the cost recovery mechanism IPL is proposing for the EVSE.

15   A9.   IPL is proposing the same cost recovery for the EVSE as currently authorized for the

16         Core DSM programs and the Other Core Plus Costs which are not subject to the

17         performance incentive. The EVSE expenditures would be forecast semi-annually along

18         with the Core and Core Plus DSM Program costs and included in the Grand Total

19         Program Costs to be recovered through Standard Contract Rider No. 22. As with these

20         other DSM program costs, forecasted expenditures would be reconciled to actual

21         expenditure in a subsequent semi-annual filing.


22   Q10. How is IPL proposing to record and segregate the EVSE costs?


                                                                                      Cutshaw -- 3
                                                                          Petitioner’s Exhibit JLC-S1


 1   A10.   As explained in my direct testimony for the expenditures for each component of the 3-

 2          Year DSM Plan, costs for each EVSE component (Residential, Public Charging and

 3          Fleet) will be recorded in the Company’s accounting system using individual project

 4          numbers, in conjunction with account numbers, to separate costs for accounting and

 5          reporting purposes. The Company’s work management and timekeeping systems will

 6          facilitate this segregation for labor, materials, and other expenses incurred.


 7   Q11. Is IPL requesting carrying charges on the EVSE costs incurred?

 8   A11.   No. As explained in my direct testimony for the 3-Year DSM Plan, since the costs will

 9          be recovered on a forecasted basis coincident with the billing to customers, IPL is not

10          requesting carrying charges on the EVSE costs incurred. However, if the program is

11          altered such that certain costs are recovered after being incurred, IPL would propose to

12          recover carrying charges on the unrecovered balance of these costs.


13   Q12. Please comment on the cost allocation basis to the customer classes proposed for the

14          EVSE costs.

15   A12.   Since the forecasted and actual costs for the Residential and Public Charging EVSE will

16          be maintained in separate projects, no allocation is required and all costs will be

17          recovered from the Residential rate class. For the Fleet EVSE, the rate class allocation

18          factors are based on each class’ share of the twelve month average system peaks from the

19          Company’s cost of service study as approved by the Commission in Cause No. 39938,

20          IPL’s last rate case. This is the same methodology proposed in my direct testimony for

21          the allocated Commercial & Industrial (“C&I”) DSM programs, and was approved by the

22          Commission in its Order in Cause No. 43623 for IPL’s current DSM program, as well as

23          in the Orders in Cause Nos. 42170, 42700 and 43403 for the Environmental Compliance

                                                                                             Cutshaw -- 4
                                                                             Petitioner’s Exhibit JLC-S1


1           Cost Recovery Adjustment.


2    Q13. Have you prepared examples to show the specific calculation to determine the

3           impact of Standard Contract Rider No. 22, Core and Core Plus DSM Adjustment

4           for Years 1, 2 and 3 reflecting the 3-Year DSM Plan including the EVSE costs?

 5   A13.   Yes. Petitioner’s Exhibit JLC-4 (Revised) provides examples that use forecasted annual

 6          costs (including target performance incentive) and billing units in order to approximate

 7          an average annual CCP-DSM Adjustment Factor for each customer class in each of the

 8          three years of the 3-Year DSM Plan. However, as noted in my direct testimony, the

 9          CCP-DSM Adjustment will be calculated and included in the Company’s semi-annual

10          filings using six months of projected costs and billing units.


11   Q14. What affect will the proposed CCP-DSM Adjustment Factor have on an average

12          residential customer using 1,000 kWh per month?

13   A14.   Based on the calculated factors on Petitioner’s Exhibit JLC-4 (Revised), the overall

14          impact is expected to be $2.52 or 3.79% for Year 1, $2.90 or 4.36% for Year 2 and $3.22

15          or 4.84% for Year 3 for an average residential customer using 1,000 kWh per month,

16          relative to the basic rates and charges in effect. These overall impacts reflect recovery of

17          the projected expenditures and performances incentives related to the 3-Year DSM Plan

18          including EVSE as proposed in this proceeding. Each of these impacts is either equal to

19          or less than what was included in my direct testimony.


20   Q15. Does this conclude your supplemental testimony?

21   A15.   Yes.




                                                                                           Cutshaw -- 5
                                       VERIFICATION

         I, James L. Cutshaw, Revenue Requirements Manager of Indianapolis Power & Light

Company, affirm under penalties of perjury that the foregoing representations are true and

correct to the best of my knowledge, information and belief.




                                                               December 10, 2010




INDSOl1241740vl
                                                           Petitioner’s Exhibit JLC-2, Page 1 (Revised)

Indianapolis Power & Light Company                I.U.R.C. No. E-16                 2nd Revised No. 179.5
One Monument Circle                                                                 Superseding
Indianapolis, Indiana                                                               1st Revised No. 179.5

                              STANDARD CONTRACT RIDER NO. 22
                CORE AND CORE PLUS DEMAND-SIDE MANAGEMENT ADJUSTMENT
                   (Applicable to Rates RS, UW, CW, SS, SH, OES, SL, PL, PH and HL)

In addition to the rates and charges set forth in the above mentioned Rates, a Core and Core Plus Demand-
Side Management (CCP-DSM) Adjustment applicable for approximately six (6) months or until superseded
by a subsequent factor shall be made in accordance with the following provisions:

A.      The CCP-DSM adjustment per KWH shall be calculated by multiplying the KWH billed by an
        Adjustment Factor established according to the following formula:

                                CCP-DSM =        P1 + P2 + EVSE       (For each rate class)
                                                        S
       where:

       1.       "P1" is the estimate of Core DSM program costs for the period from July 2010January 2011
                through December 2010June 2011, for the Core DSM programs described in the Phase II
                order of Cause No. 42693 and approved in the Phase I order of Cause No. 43623 order in
                Cause No, 43960.

       2.       “P2” is the estimate of Core Plus DSM program costs including incentives as applicable, for
                the period from July 2010January 2011 through December 2010June 2011, for the non-
                Core DSM programs approved in the Phase I order of Cause No. 43623order in Cause No.
                43960.

       3.       "EVSE" is the estimate of Electric Vehicle Supply Equipment for the period from January
                2011 through June 2011 for the EVSE program approved in the order in Cause No. 43960.



       34.      "S" is the estimated kilowatt-hour sales, for the period from July 2010January 2011 through
                December 2010June 2011 consisting of the net sum in kilowatt-hours of:

                (a)     Net generation,
                (b)     Purchases and
                (c)     Interchange-in, less
                (d)     Inter-system Sales,
                (e)     Energy Losses and Company Use


B.      The CCP-DSM Adjustment Factor as computed above for each rate class shall be further modified
        to allow the recovery of utility receipts taxes and other similar revenue-based tax charges occasioned
        by the CCP-DSM adjustment revenues.



C.     The CCP-DSM Adjustment Factor may be further modified to reflect the difference between the
       actual and estimated program costs and Customer participation levels.



                                                                       Effective __________, 2010
                                                            Petitioner’s Exhibit JLC-2, Page 2 (Revised)

Indianapolis Power & Light Company                  I.U.R.C. No. E-16                Original No. 179.6
One Monument Circle
Indianapolis, Indiana




D.         The CCP-DSM Adjustment Factor to be effective for all bills rendered for electric service beginning
           with the first billing cycles for July 2010January 2011 after approval will be:

                   $0.000927 000XXX per KWH for Rates RS, CW (with associated Rate RS service)

                   $0.000513 000XXX per KWH for Rates SS, SH, OES, UW, CW (with associated Rate SS
service)
                   $0.000221 000XXX per KWH for Rate SL, PL, PH, HL

                   $0.000000 000XXX per KWH for Rates PL, PH, HL




                                                                        Effective __________, 2010
                                                                                                                          Petitioner's Exhibit JLC-3 (Revised)

       Indianapolis Power & Light Company
       Cost Allocation Basis and Target Performance
         Incentive by Program


                                                                                                                    RS, CW       SS, SH, OES     SL, PL, PH
                                                                     Target                                                       UW, CW             HL
                                                                  Performance        Cost Allocation Basis
Line                                                               Incentive                                       Residential    Small C&I      Large C&I

 1                       Residential DSM Programs

 2                             Core Programs
 3     Home Energy Audit                                              0%            Direct for Each Program          100%
 4     Lighting Program                                               0%            Direct for Each Program          100%
 5     Energy Efficient Schools - Kits                                0%            Direct for Each Program          100%
 6     Low Income Weatherization                                      0%            Direct for Each Program          100%
 7        Total Residential Core          (P1)

8                   Core Plus Programs subject to incentive
9      Air Conditioning Load Management (ACLM) Program                8%            Direct for Each Program          100%
10     Energy Assessment Program                                      8%            Direct for Each Program          100%
11     New Construction Energy Star Plus Program                      8%            Direct for Each Program          100%
12     Second Refrigerator Pickup and Recycling Program               8%            Direct for Each Program          100%
13     Peer Comparison Energy Reports Program                         8%            Direct for Each Program          100%
13     Multi-Family Direct Install Program                            8%            Direct for Each Program          100%
14     Room Air Conditioner Pickup and Recycling                      8%            Direct for Each Program          100%
15     High Efficiency HVAC Incentives Program                        8%            Direct for Each Program          100%
16     CEMS - Home Energy Management with TOU Rates                   8%            Direct for Each Program          100%
17     CEMS - Home Energy Management without TOU Rates                8%            Direct for Each Program          100%
18         Subtotal Residential Core Plus, subject to incentive

19                         Other Core Plus Costs
20     Renewables Incentives Program                                  0%            Direct for Each Program          100%
21     Program Outreach Messaging and Other Indirect Costs            0%            Direct for Each Program          100%
22     Online Energy Feedback                                         0%            Direct for Each Program          100%
23     Energy Consumer Behavior Study                                 0%            Direct for Each Program          100%
24     Smart Appliance Pilot                                          0%            Direct for Each Program          100%
25        Subtotal Residential Other Core Plus

26        Total Residential Core Plus      (P2)


27           Grand Total Residential


28                 Commercial & Industrial DSM Programs

29                             Core Programs
30     Rebate Program                                                 0%                                                           32.21%          67.79%
31     Energy Efficient Schools - Audits                              0%                                                           32.21%          67.79%
                                                                                Allocated between Small C&I and
                                                                                      Large C&I based upon
                                                                                  relationship in ECR Allocation
33                  Core Plus Programs subject to incentive                                   Ratios
34     Air Conditioning Load Management (ACLM) Program                8%                                                            32.21%         67.79%
35     Business Energy Incentives Program                             8%                                                            32.21%         67.79%
36     CEMS - Business Energy Management without TOU Rates            8%            Direct for Each Program                        100.00%
37         Subtotal Commercial Core Plus, subject to incentive

38                        Other Core Plus Costs
39     Renewables Incentives Program                                  0%                                                           32.21%          67.79%
                                                                                Allocated between Small C&I and
40     Program Outreach Messaging and Other Indirect Costs            0%                                                           32.21%          67.79%
                                                                                     Large C&I - ECR ratios
41     Online Energy Feedback                                         0%                                                           32.21%          67.79%
42        Subtotal Commercial Other Core Plus

43        Total Commercial Core Plus        (P2)


44           Grand Total Commercial & Industrial


45     Grand Total Core and Core Plus DSM Programs


46     Residential EVSE                                               0%             Direct for Each Program         100%
47     Public Charging EVSE                                           0%             Direct for Each Program         100%
48     Fleet EVSE                                                     0%        Allocated between Small C&I and                    32.21%          67.79%
49        Total EVSE                                                            Large C&I - ECR ratios
                                                                                                             Petitioner's Exhibit JLC-4 (Revised)
                                                                                                                                      Page 1 of 3
       Indianapolis Power & Light Company
       Determination of Impact of Core and Core Plus
          DSM Adjustment - Rider 22
       (000$) and (000MWh)
                                                                                              Year 1 Totals
                                                                                                      RS, CW        SS, SH, OES     SL, PL, PH
                                                                                Target                               UW, CW             HL
                                                                   Projected Performance
Line                                                              Expenditure Incentive    Total      Residential    Small C&I      Large C&I

 1                       Residential DSM Programs

 2                             Core Programs
 3     Home Energy Audit                                             $4,142                 $4,142        $4,142
 4     Lighting Program                                              $1,085                 $1,085        $1,085
 5     Energy Efficient Schools - Kits                                $800                    $800          $800
 6     Low Income Weatherization                                      $564                    $564          $564
 7        Total Residential Core          (P1)                       $6,591          $0     $6,591        $6,591

 8                  Core Plus Programs subject to incentive
 9     Air Conditioning Load Management (ACLM) Program               $1,721        $138     $1,859        $1,859
10     Energy Assessment Program                                      $233          $19       $252          $252
11     New Construction Energy Star Plus Program                      $123          $10       $133          $133
12     Second Refrigerator Pickup and Recycling Program               $654          $52       $706          $706
13     Peer Comparison Energy Reports Program                         $381          $30       $411          $411
13     Multi-Family Direct Install Program                            $427          $34       $461          $461
14     Room Air Conditioner Pickup and Recycling                        $16          $1        $17           $17
15     High Efficiency HVAC Incentives Program                        $478          $38       $516          $516
16     CEMS - Home Energy Management with TOU Rates                     $76          $6        $82           $82
17     CEMS - Home Energy Management without TOU Rates                $215          $17       $232          $232
18         Subtotal Residential Core Plus, subject to incentive      $4,324        $345     $4,669        $4,669

19                         Other Core Plus Costs
20     Renewables Incentives Program                                    $72                    $72           $72
21     Program Outreach Messaging and Other Indirect Costs             $671                   $671          $671
22     Online Energy Feedback                                          $459                   $459          $459
23     Energy Consumer Behavior Study                                    $0                     $0            $0
24     Smart Appliance Pilot                                             $0                     $0            $0
25        Subtotal Residential Other Core Plus                       $1,202          $0     $1,202        $1,202

26        Total Residential Core Plus      (P2)                      $5,526          $0     $2,332        $5,871


27           Grand Total Residential                                $12,117        $345    $12,462       $12,462



28                 Commercial & Industrial DSM Programs

29                             Core Programs
30     Rebate Program                                                $4,300                 $4,300                        $1,385         $2,915
31     Energy Efficient Schools - Audits                              $301                    $301                           $97          $204
32       Total Commercial Core           (P1)                        $4,601          $0     $4,601                        $1,482         $3,119

33                  Core Plus Programs subject to incentive
34     Air Conditioning Load Management (ACLM) Program                $266          $21       $287                           $92           $195
35     Business Energy Incentives Program                             $951          $76     $1,027                          $331           $696
36     CEMS - Business Energy Management without TOU Rates              $21          $2        $23                           $23             $0
37         Subtotal Commercial Core Plus, subject to incentive       $1,238         $99     $1,337                          $446           $891

38                        Other Core Plus Costs
39     Renewables Incentives Program                                    $28                    $28                            $9            $19
40     Program Outreach Messaging and Other Indirect Costs             $224                   $224                           $72           $152
41     Online Energy Feedback                                          $153                   $153                           $49           $104
42        Subtotal Commercial Other Core Plus                          $405          $0       $405                          $130           $275

43        Total Commercial Core Plus        (P2)                     $1,643          $0       $782                          $576         $1,166


44           Grand Total Commercial & Industrial                     $6,244         $99     $6,343                        $2,058         $4,285


45     Grand Total Core and Core Plus DSM Programs                  $18,361        $444    $18,805       $12,462          $2,058         $4,285



46     Residential EVSE                                                $258                   $258          $258
47     Public Charging EVSE                                            $229                   $229          $229
48     Fleet EVSE                                                      $229                   $229                           $74           $155
49        Total EVSE                                                   $716          $0       $716          $487             $74           $155




50     Grand Total Program Costs (000$)                             $19,077        $444    $19,521       $12,949          $2,132         $4,440

51     / Estimated Sales (MWh)                                                             14,092.8       5,212.6        1,923.8        6,956.4

52     CCP-DSM Adjustment Factor (Mills per kWh)                                                           2.484           1.108          0.638

53     CCP-DSM Adjustment Factor (Mills per kWh)
54      Adjusted for Utility Receipts Tax                                                                  2.523           1.125          0.648
                                                                                                             Petitioner's Exhibit JLC-4 (Revised)
                                                                                                                                      Page 2 of 3
       Indianapolis Power & Light Company
       Determination of Impact of Core and Core Plus
          DSM Adjustment - Rider 22
       (000$) and (000MWh)
                                                                                              Year 2 Totals
                                                                                                      RS, CW        SS, SH, OES     SL, PL, PH
                                                                                Target                               UW, CW             HL
                                                                   Projected Performance
Line                                                              Expenditure Incentive    Total      Residential    Small C&I      Large C&I

 1                       Residential DSM Programs

 2                             Core Programs
 3     Home Energy Audit                                             $5,554                 $5,554        $5,554
 4     Lighting Program                                               $988                    $988          $988
 5     Energy Efficient Schools - Kits                                $711                    $711          $711
 6     Low Income Weatherization                                      $723                    $723          $723
 7        Total Residential Core          (P1)                       $7,976          $0     $7,976        $7,976

 8                  Core Plus Programs subject to incentive
 9     Air Conditioning Load Management (ACLM) Program               $1,821        $146     $1,967        $1,967
10     Energy Assessment Program                                      $233          $19       $252          $252
11     New Construction Energy Star Plus Program                      $128          $10       $138          $138
12     Second Refrigerator Pickup and Recycling Program               $654          $52       $706          $706
13     Peer Comparison Energy Reports Program                         $865          $69       $934          $934
13     Multi-Family Direct Install Program                            $504          $40       $544          $544
14     Room Air Conditioner Pickup and Recycling                        $16          $1        $17           $17
15     High Efficiency HVAC Incentives Program                        $468          $37       $505          $505
16     CEMS - Home Energy Management with TOU Rates                   $134          $11       $145          $145
17     CEMS - Home Energy Management without TOU Rates                $380          $30       $410          $410
18         Subtotal Residential Core Plus, subject to incentive      $5,203        $415     $5,618        $5,618

19                         Other Core Plus Costs
20     Renewables Incentives Program                                    $75                    $75           $75
21     Program Outreach Messaging and Other Indirect Costs            $700                    $700          $700
22     Online Energy Feedback                                         $133                    $133          $133
23     Energy Consumer Behavior Study                                 $125                    $125          $125
24     Smart Appliance Pilot                                          $125                    $125          $125
25        Subtotal Residential Other Core Plus                       $1,158          $0     $1,158        $1,158

26        Total Residential Core Plus      (P2)                      $6,361          $0     $2,241        $6,776


27           Grand Total Residential                                $14,337        $415    $14,752       $14,752



28                 Commercial & Industrial DSM Programs

29                             Core Programs
30     Rebate Program                                                $4,674                 $4,674                        $1,505         $3,169
31     Energy Efficient Schools - Audits                              $262                    $262                           $84          $178
32       Total Commercial Core           (P1)                        $4,936          $0     $4,936                        $1,589         $3,347

33                  Core Plus Programs subject to incentive
34     Air Conditioning Load Management (ACLM) Program                $285          $23       $308                           $99          $209
35     Business Energy Incentives Program                            $1,375        $110     $1,485                          $478         $1,007
36     CEMS - Business Energy Management without TOU Rates              $40          $3        $43                           $43             $0
37         Subtotal Commercial Core Plus, subject to incentive       $1,700        $136     $1,836                          $620         $1,216

38                        Other Core Plus Costs
39     Renewables Incentives Program                                    $25                    $25                            $8            $17
40     Program Outreach Messaging and Other Indirect Costs             $234                   $234                           $75           $159
41     Online Energy Feedback                                           $45                    $45                           $14            $31
42        Subtotal Commercial Other Core Plus                          $304          $0       $304                           $97           $207

43        Total Commercial Core Plus        (P2)                     $2,004          $0       $583                          $717         $1,423


44           Grand Total Commercial & Industrial                     $6,940        $136     $7,076                        $2,306         $4,770


45     Grand Total Core and Core Plus DSM Programs                  $21,277        $551    $21,828       $14,752          $2,306         $4,770



46     Residential EVSE                                                $202                   $202          $202
47     Public Charging EVSE                                             $27                    $27           $27
48     Fleet EVSE                                                       $27                    $27                            $9            $18
49        Total EVSE                                                   $256          $0       $256          $229              $9            $18




50     Grand Total Program Costs (000$)                             $21,533        $551    $22,084       $14,981          $2,315         $4,788

51     / Estimated Sales (MWh)                                                             14,273.5       5,248.5        1,947.5        7,077.5

52     CCP-DSM Adjustment Factor (Mills per kWh)                                                           2.854           1.189          0.677

53     CCP-DSM Adjustment Factor (Mills per kWh)
54      Adjusted for Utility Receipts Tax                                                                  2.898           1.207          0.688
                                                                                                             Petitioner's Exhibit JLC-4 (Revised)
                                                                                                                                      Page 3 of 3
       Indianapolis Power & Light Company
       Determination of Impact of Core and Core Plus
          DSM Adjustment - Rider 22
       (000$) and (000MWh)
                                                                                              Year 3 Totals
                                                                                                      RS, CW        SS, SH, OES     SL, PL, PH
                                                                                Target                               UW, CW             HL
                                                                   Projected Performance
Line                                                              Expenditure Incentive    Total      Residential    Small C&I      Large C&I

 1                       Residential DSM Programs

 2                             Core Programs
 3     Home Energy Audit                                             $6,311                 $6,311        $6,311
 4     Lighting Program                                              $1,189                 $1,189        $1,189
 5     Energy Efficient Schools - Kits                                $806                    $806          $806
 6     Low Income Weatherization                                      $863                    $863          $863
 7        Total Residential Core          (P1)                       $9,169          $0     $9,169        $9,169

 8                  Core Plus Programs subject to incentive
 9     Air Conditioning Load Management (ACLM) Program               $1,921        $154     $2,075        $2,075
10     Energy Assessment Program                                      $233          $19       $252          $252
11     New Construction Energy Star Plus Program                      $128          $10       $138          $138
12     Second Refrigerator Pickup and Recycling Program               $654          $52       $706          $706
13     Peer Comparison Energy Reports Program                        $1,390        $111     $1,501        $1,501
13     Multi-Family Direct Install Program                            $504          $40       $544          $544
14     Room Air Conditioner Pickup and Recycling                        $16          $1        $17           $17
15     High Efficiency HVAC Incentives Program                        $478          $38       $516          $516
16     CEMS - Home Energy Management with TOU Rates                     $45          $4        $49           $49
17     CEMS - Home Energy Management without TOU Rates                $134          $11       $145          $145
18         Subtotal Residential Core Plus, subject to incentive      $5,503        $440     $5,943        $5,943

19                         Other Core Plus Costs
20     Renewables Incentives Program                                    $75                    $75           $75
21     Program Outreach Messaging and Other Indirect Costs            $774                    $774          $774
22     Online Energy Feedback                                         $109                    $109          $109
23     Energy Consumer Behavior Study                                 $125                    $125          $125
24     Smart Appliance Pilot                                          $125                    $125          $125
25        Subtotal Residential Other Core Plus                       $1,208          $0     $1,208        $1,208

26        Total Residential Core Plus      (P2)                      $6,711          $0     $2,341        $7,151


27           Grand Total Residential                                $15,880        $440    $16,320       $16,320



28                 Commercial & Industrial DSM Programs

29                             Core Programs
30     Rebate Program                                                $6,005                 $6,005                        $1,934         $4,071
31     Energy Efficient Schools - Audits                              $301                    $301                           $97          $204
32       Total Commercial Core           (P1)                        $6,306          $0     $6,306                        $2,031         $4,275

33                  Core Plus Programs subject to incentive
34     Air Conditioning Load Management (ACLM) Program                $304          $24       $328                          $106           $222
35     Business Energy Incentives Program                            $1,389        $111     $1,500                          $483         $1,017
36     CEMS - Business Energy Management without TOU Rates              $16          $1        $17                           $17             $0
37         Subtotal Commercial Core Plus, subject to incentive       $1,709        $136     $1,845                          $606         $1,239

38                        Other Core Plus Costs
39     Renewables Incentives Program                                    $25                    $25                            $8            $17
40     Program Outreach Messaging and Other Indirect Costs             $258                   $258                           $83           $175
41     Online Energy Feedback                                           $36                    $36                           $12            $24
42        Subtotal Commercial Other Core Plus                          $319          $0       $319                          $103           $216

43        Total Commercial Core Plus        (P2)                     $2,028          $0       $613                          $709         $1,455


44           Grand Total Commercial & Industrial                     $8,334        $136     $8,470                        $2,740         $5,730


45     Grand Total Core and Core Plus DSM Programs                  $24,214        $576    $24,790       $16,320          $2,740         $5,730



46     Residential EVSE                                                 $48                    $48           $48
47     Public Charging EVSE                                             $17                    $17           $17
48     Fleet EVSE                                                       $16                    $16                            $5            $11
49        Total EVSE                                                    $81          $0        $81           $65              $5            $11




50     Grand Total Program Costs (000$)                             $24,295        $576    $24,871       $16,385          $2,745         $5,741

51     / Estimated Sales (MWh)                                                             14,285.9       5,164.2        1,940.3        7,181.4

52     CCP-DSM Adjustment Factor (Mills per kWh)                                                           3.173           1.415          0.799

53     CCP-DSM Adjustment Factor (Mills per kWh)
54      Adjusted for Utility Receipts Tax                                                                  3.222           1.437          0.811

								
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