Fraser Trebilcock Davis & Dunlap, P.C.

Transcription

1 124 West Allegan Street, Suite 1000 Lansing, Michigan T (517) F (517) Jennifer Utter Heston jheston@fraserlawfirm.com (517) May 19, 2016 Ms. Mary Jo Kunkle Executive Secretary 7109 W. Saginaw Hwy. Re: MPSC Case No. U R Dear Ms. Kunkle: Enclosed herewith for filing in the above-referenced matter, please find the attached statement from the Retail Energy Supply Association and Certificate of Service. The attached statement is submitted pursuant to Rule 413 of the Commission's Rules of Practice and Procedure, R If you have any questions, please feel free to contact my office. Thank you. Very truly yours, Fraser Trebilcock Davis & Dunlap, P.C. JUH/ab Enclosures cc: All parties of record. Jennifer Utter Heston FRASER TREBILCOCK DAVIS & DUNLAP PC LANSING DETROIT GRAND RAPIDS

2 May 19, 2016 Honorable Sally A. Talberg, Chairman Honorable Norm Saari, Commissioner 7901 West Saginaw Highway P.O. Box Lansing, MI RE: MPSC Case No. U R In the matter of the application of SEMCO ENERGY GAS COMPANY for reconciliation of the gas cost recovery plan for the 12 month period ending March 31, 2015 Dear Chairman and Commissioner, On June 30, 2015 SEMCO Energy Gas Company ( SEMCO or Company ) filed an Application with the ( Commission ) requesting approval of its Gas Cost Recovery ( GCR ) reconciliation for the 12 month period beginning April 1, 2014 and ending March 31, A prehearing conference was held on September 9, 2015 during which a case schedule was set. On September 8, 2015 SEMCO amended its application and filed revised testimony. The Retail Energy Supply Association ( RESA ) 1 consists of gas suppliers who participate in both the gas customer choice ("GCC") and end use transportation ("EUT") Programs offered by SEMCO. RESA is a broad and diverse group of retail energy suppliers who share the common vision that competitive retail energy markets deliver a more efficient customer oriented outcome than a regulated utility structure. RESA members are licensed to sell natural gas to retail customers in Michigan as Alternative Gas Suppliers ("AGS"), including to customers in SEMCO s GCC program. 1 The comments expressed in this filing represent the position of the Retail Energy Supply Association (RESA) as an organization but may not represent the views of any particular member of the Association. Founded in 1990, RESA is a broad and diverse group of more than twenty retail energy suppliers dedicated to promoting efficient, sustainable and customer oriented competitive retail energy markets. RESA members operate throughout the United States delivering value added electricity and natural gas service at retail to residential, commercial and industrial energy customers. More information on RESA can be found at

3 It has come to our attention that during the pendency of this proceeding, the Attorney General ( AG ) witness submitted proposals relating to the SEMCO GCC program that RESA suppliers believe are unworkable and ill advised. The AG recommends certain changes to the GCC program without taking into consideration all elements of program design. For example, the AG suggestion that alternative gas suppliers should pay the highest spot cost of gas for any annual shortfall is not balanced and well thought out. The proposed year end reconciliation creates additional price exposure for suppliers that is both unnecessary and costly for consumers. In rebuttal testimony, SEMCO indicates that the Company sees no merit in the AG s proposed modifications to the GCC program. RESA points to the rebuttal testimony of SEMCO witness Mr. Jay Skillman who explains in detail the reasons why the Commission should reject the AG s modifications to SEMCO's GCC tariff. As experienced stakeholders in the GCC program, RESA concurs with SEMCO that the AG's proposed modifications to the SEMCO GCC program should be rejected by the Commission. RESA suppliers, who have a rich background of participation in Michigan GCC programs, believe the AG s modifications not only lack merit but would be detrimental to the SEMCO GCC program. Further, a GCR reconciliation proceeding is not an appropriate forum to vet a major redesign of a GCC program. RESA had no notice that changes to SEMCO's GCC program would be at issue in this case. The Commission should not change the GCC programs without hearing from interested stakeholders and taking into consideration other changes that would also be required to ensure a functional GCC program. Sincerely, Darcy Fabrizius Michigan State Gas Chair Retail Energy Supply Association

4 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the matter of the Application of ) SEMCO ENERGY GAS COMPANY for ) Reconciliation of the Gas Cost Recovery ) Plan for the 12-month period ending March ) 31, 2015 ) ) Case No. U R CERTIFICATE OF SERVICE Angela R. Babbitt hereby certifies that on the 19 th day of May, 2016, she served the attached statement from the Retail Energy Supply Association and this Certificate of Service on the persons identified on the attached service list via electronic mail. Angela R. Babbitt

5 Service List for U R Administrative Law Judge and via U.S. Mail Honorable Martin D. Snider 7109 W. Saginaw Hwy. Counsel for SEMCO Energy Gas Company Richard J. Aaron Theodore J. Greeley Dykema Gossett PLLC 201 Townsend, Ste. 900 Lansing, MI Kristin M. Smith General Counsel SEMCO Energy Gas Company 1411 Third St., Ste. A PO Box 5004 Port Huron, MI Counsel for MPSC Staff Heather M.S. Durian Bryan A. Brandenburg 7109 W. Saginaw Hwy., 3 rd Floor durianh@michigan.gov brandenburghb@michigan.gov Counsel for Attorney General Michael E. Moody ENRA Division 525 W. Ottawa St., 6 th Floor Williams Building Lansing, MI Moodym2@michigan.gov 2