by email and hand delivery - green mountain power · 6/20/2017 · • attachment...

June 20, 2017

By Email and Hand Delivery Daniel Burke, Esq. Stephanie Hoffman, Esq. Vermont Department of Public Service 112 State Street, 3rd Floor Montpelier, VT 05620-2601 Re: Case No. 17-3112-INV – Investigation into Green Mountain Power Corporation’s tariff

filing requesting an overall rate increase in the amount of 4.98%, to take effect January 1, 2018 – Round 1 Discovery Responses

Dear Dan and Stephanie:

Petitioner Green Mountain Power (“GMP”) hereby submits its Responses to your First Round of Discovery Requests. As requested, two copies of the narrative responses are produced in hard copy and two thumb drives containing the responsive documents are enclosed. Protected documents produced under Protective Agreement are included on a CD. Also enclosed are two thumb drives containing the capital folders, which we believe have already been provided separately to Bill Schultz. Please contact me if you have any questions.

Very truly yours,

Geoffrey H. Hand, Esq. Victoria M. Westgate, Esq. Dunkiel Saunders Elliott Raubvogel & Hand, PLLC Enclosures Cc: Service List

STATE OF VERMONT PUBLIC SERVICE BOARD

Case No. 17-3112-INV Investigation into Green Mountain Power Corporation’s tariff filing requesting an overall rate increase in the amount of 4.98%, to take effect January 1, 2018

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CERTIFICATE OF SERVICE

I, Gillian Bergeron, certify that on June 20, 2017, I forwarded copies of Green Mountain Power’s Responses to the First Set of Discovery Requests from the Department of Public Service to the service list below by the delivery method noted: Ms. Judith Whitney, Clerk Vermont Public Service Board 112 State Street, Drawer 20 Montpelier, VT 05620-2701 (Responses only via email and first class mail) Daniel Burke, Esq. Stephanie Hoffman, Esq. Vermont Department of Public Service 112 State Street, 3rd Floor Montpelier, VT 05620-2601 (Responses only via email; 2 hard copies of responses, responsive/confidential documents on thumb drive/CD via hand delivery)

Shapleigh Smith, Jr., Esq. Dinse, Knapp & McAndrew, P.C. 209 Battery Street, P.O. Box 988 Burlington, VT 05402-0988 (for GLOBALFOUNDRIES U.S. 2 LLC) (Responses only via email; 1 hard copy of responses and non-confidential responsive documents on thumb drive via hand delivery)

Dated at Burlington, Vermont this 20th day of June, 2017.

By:

Gillian Bergeron Paralegal


Case No. 17-3112-INV Investigation into Green Mountain Power Corporation’s tariff filing requesting an overall rate increase in the amount of 4.98%, to take effect January 1, 2018

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Green Mountain Power’s Responses to the First Set of Discovery Requests Served by the Department of Public Service

Green Mountain Power (“GMP” or “Petitioner”), by and through the undersigned counsel, hereby responds to the first set of discovery requests served by the Department of Public Service on June 5, 2017.

General Objections

The following General Objections of Petitioner GMP are incorporated by reference into its responses to each Interrogatory, Request to Produce, and Request for Admissions reproduced below, whether or not an objection is stated in any particular response. Any response to one of the Interrogatories, Requests to Produce, or Requests for Admission given below is given without waiver of any objection, whether or not an objection is stated.

1. Petitioner objects to each Interrogatory, Request to Produce, and Request for

Admission reproduced below to the extent that it is overbroad, irrelevant, unduly burdensome, or not reasonably calculated to lead to the discovery of admissible evidence.

2. Petitioner objects to each Interrogatory, Request to Produce, and Request for Admission reproduced below to the extent that it calls for the disclosure of information or production of material privileged under the attorney-client, work-product, or any other applicable privilege.

3. Petitioner objects to each Interrogatory, Request to Produce, and Request for Admission reproduced below to the extent that it is unreasonably cumulative or duplicative, or calls for the disclosure of information or production of material that is obtainable from some other source that is more convenient, less burdensome, or less expensive, including, but not limited to, information or material that is publicly available or that has already been disclosed or produced to you in connection with another proceeding.

Case No. 17-3112-INV Petitioner Green Mountain Power’s

Responses to DPS First Set of Discovery Requests June 20, 2017 Page 2 of 202

4. Petitioner objects to each Interrogatory, Request to Produce, and Request for Admission reproduced below to the extent that it calls for the disclosure or production of confidential or proprietary information, trade secrets, or material.

5. Petitioner objects to each Interrogatory, Request to Produce, and Request for Admission reproduced below to the extent that it is vague, unintelligible, requires speculation as to the information being sought, or is otherwise incapable of a reasonable answer.

6. Petitioner objects to each Instruction and Definition listed in the requesting party’s discovery requests to the extent that it exceeds the bounds of permissible discovery or is unduly burdensome.

7. Petitioner objects to each Interrogatory, Request to Produce, and Request for Admission to the extent that the request exceeds the scope of Petitioner’s testimony and exhibits.

8. Petitioner objects to each Interrogatory, Request to Produce, and Request for Admission to the extent that the request would require Petitioner to conduct extensive document review, additional studies, analyses, and/or tests as part of its response.

9. Petitioner objects to each Interrogatory, Request to Produce, and Request for Admission to the extent that the request exceeds the scope of the requesting party’s intervention.

10. Petitioner objects to each Interrogatory, Request to Produce, and Request for

Admission to the extent that the request exceeds the scope of the issues on review.

11. Petitioner objects to each Interrogatory, Request to Produce, and Request for Admission to the extent that it calls for a legal conclusion.



INTERROGATORIES AND REQUESTS TO PRODUCE

Please provide all work papers and supporting documentation used by Mr. Coyne in the preparation of his April 14, 2017 prefiled direct testimony and exhibits. Please provide all spreadsheets with in native Microsoft Excel format with all cell formulas intact. Please also include all exhibits in native spreadsheets formats with cell formulas intact.

Please refer to the following Attachments:

• Attachment GMP.DPS1.Q1.1_Exhibit Package • Attachment GMP.DPS1.Q1.2_Stock Prices, Bond Prices, Dividend Yields • Attachment GMP.DPS1.Q1.3_Value Line • Attachment GMP.DPS1.Q1.4_Yahoo! Finance • Attachment GMP.DPS1.Q1.5_Bloomberg Betas • Attachment GMP.DPS1.Q1.6_Blue Chip Financial Forecast, Vol. 35, No. 12,

(December 1, 2016) • Attachment GMP.DPS1.Q1.7_RRA Rate Case Statistics (Confidential) • Attachment GMP.DPS1.Q1.8_Bloomberg Quarterly Bond Yields • Attachment GMP.DPS1.Q1.9_Blue Chip Financial Forecasts Vol. 36, No. 3,

(March 1, 2017) • Attachment GMP.DPS1.Q1.10_Bloomberg Market Capitalizations • Attachment GMP.DPS1.Q1.11_GMP FERC Form 1 • Attachment GMP.DPS1.Q1.12_Market to Book Ratio of Valener • Attachment GMP.DPS1.Q1.13_RRA Rank by State • Attachment GMP.DPS1.Q1.14_Capital Structure Analyses (Confidential) • Attachment GMP.DPS1.Q1.15_Bloomberg Dividend Yield Analysis (Figure 1) • Attachment GMP.DPS1.Q1.16_S&P Utilities vs. U.S. Treasury Bond Yields

Analysis (Figure 2) • Attachment GMP.DPS1.Q1.17_Utility P/E Ratios Analysis (Figures 3)

Person Responsible for Response: James Coyne Title of Person: Senior Vice President, Concentric Energy Advisors, Inc. Date: June 20, 2017



Please provide all credit rating and bond rating agency reports (i.e., Standard and Poor’s, Moody’s, Fitch) for Green Mountain Power (“GMP”) for the last two years. Please include the most recent reports for 2017, if any.

Please see Attachments GMP.DPS1.Q2.1, GMP.DPS1.Q2.2, and GMP.DPS1.Q2.3.

Person Responsible for Response: Dawn Bugbee Title of Person: VP, Chief Financial Officer & Treasurer Date: June 20, 2017



Please provide all credit rating and bond rating agency reports (i.e., Standard and Poor’s, Moody’s, Fitch) for Gaz Metro for the last two years. Please include the most recent reports for 2017, if any.

Please see Attachments GMP.DPS1.Q3.1_(2015), GMP.DPS1.Q3.2_(2016), GMP.DPS1.Q3.3_(DBRS 2015), and GMP.DPS1.Q3.4_(DBRS 2016).




Please provide copies of all articles, regulatory commission orders, rating agency reports, and other supporting documentation cited and relied upon by Mr. Coyne in his Direct Testimony and exhibits.

Please see:

• Attachment GMP.DPS1.Q1.6_Blue Chip Financial Forecast, Vol. 35, No. 12, (December 1, 2016)

• Attachment GMP.DPS1.Q1.9_Blue Chip Financial Forecasts Vol. 36, No. 3, (March 1, 2017)

• Attachment GMP.DPS1.Q4.1_VPSB Order Docket No. 8190 (Aug. 25, 2014) • Attachment GMP.DPS1.Q4.2_BEA Table 1.1.5 Nominal GDP (Jan. 27, 2017) • Attachment GMP.DPS1.Q4.3_BEA Table 1.1.6 Real GDP (Jan. 27, 2017) • Attachment GMP.DPS1.Q4.4_ Blue Chip Economic Indicators, Volume 42, No. 3,

(Mar. 10, 2017) • Attachment GMP.DPS1.Q4.5_ Bureau of Labor Statistics, Table A-10 (Mar. 16,

2017). • Attachment GMP.DPS1.Q4.6_FOMC Meeting Transcript (Dec. 14, 2016) • Attachment GMP.DPS1.Q4.7_FOMC Press Conference Transcript (Mar. 15, 2017) • Attachment GMP.DPS1.Q4.8_FOMC Federal Reserve Press Release (Mar. 15,

2017) • Attachment GMP.DPS1.Q4.9_ Value Line Investment Survey, Electric Utility

(Central) Industry, (December 16, 2016) • Attachment GMP.DPS1.Q4.10_ Federal Open Market Committee, Policy

Normalization Principles and Plans, (Sept. 16, 2014) • Attachment GMP.DPS1.Q4.11_ Remarks by Stanley (Mar. 23, 2015). • Attachment GMP.DPS1.Q4.12_ Ben Schiller, Fast Company, In Vermont, A

Forward-Thinking Utility Is Helping Customers Share Solar Power (Sept. 21, 2015) • Attachment GMP.DPS1.Q4.13_ S&P (Dec. 15, 2016) • Attachment GMP.DPS1.Q4.14_ Eugene F. Brigham and Joel F. Houston,

Fundamentals of Financial Management (Concise Fourth Edition, Thomson South-Western).

• Attachment GMP.DPS1.Q4.15_ Harris and Marston, Estimating Shareholder Risk Premia Using Analysts Growth Forecasts, Financial Management, Summer 1992

• Attachment GMP.DPS1.Q4.16_ Vander Weide and Carleton, Investor Growth Expectations: Analysts vs. History, The Journal of Portfolio Management, Spring 1988



• Attachment GMP.DPS1.Q4.17_155 FERC ¶ 63,030 (June 30, 2016) • Attachment GMP.DPS1.Q4.18_ Moody’s Investors Service, Regulated Electric and

Gas Utilities, (Dec. 23, 2013) • Attachment GMP.DPS1.Q4.19_ Gideon Weissman, Frontier Group and Bret

Fanshaw and Rob Sargent, Environment America Research & Policy Center, Lighting the Way 4: The Top States that Helped Drive America’s Solar Energy Boom in 2015 (July 2016)

• Attachment GMP.DPS1.Q4.20_ Roger A. Morin, New Regulatory Finance, Public Utility Reports, Inc., 2006




Please provide a listing of the companies that Mr. Coyne excluded from his proxy group and the reason(s) for excluding each company. Please provide supporting documentation and work papers for all quantitative analyses underlying the exclusion of each company.

Please refer to Attachment GMP.DPS1.Q5_Proxy Selection. Note that red, highlighted fields indicate failure to meet the screening criteria.




Please provide copies of all Blue Chip reports cited and relied upon by Mr. Coyne in his Direct Testimony and exhibits.

Please see:

• Attachment GMP.DPS1.Q1.6_Blue Chip Financial Forecast, Vol. 35, No. 12, (December 1, 2016)

• Attachment GMP.DPS1.Q1.9_Blue Chip Financial Forecasts Vol. 36, No. 3, (March 1, 2017)

• Attachment GMP.DPS1.Q4.4_ Blue Chip Economic Indicators, Volume 42, No. 3, (Mar. 10, 2017)



Responses to DPS First Set of Discovery Requests June 20, 2017

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Please provide GMP’s capital structure, including long-term and short-term debt for 2010 – 2017. Provide all supporting documentation analyses, work papers, and spreadsheets with cell formulas intact.

Please see Attachment GMP.DPS1.Q7. This reflects GMP’s voluntary lowering of its debt to equity ratio to lower than the utility industry preferred 50-50 ratio as a rate mitigation strategy. This is a direct benefit to the customer.




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Please provide GMP’s monthly cost and amounts of short-term debt from 2010 through 2017. Provide all supporting documentation analyses, work papers, and spreadsheets with cell formulas intact.

Please see Attachment GMP.DPS1.Q8.




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Referring to the spreadsheet titled “Rate Year 2018 Capital Structure Apr 14 filed.xlsx”, which was prepared by GMP and submitted to the Department in electronic format with the Tariff Filing, please provide the following:

a. Please provide the basis for the interest rates for the New Debt issues 4.25%

and 4.5%. Please provide all assumptions, studies, and documentation that supports these interest rates.

b. Regarding the New Debt issues of $35 million and $30 million, please explain how the Company determined these amounts. Provide all assumptions, studies, and documentation that supports these amounts.

c. Regarding the New Debt balances in part b., please explain the timing of their inclusion in GMP’s debt balance.

d. Has GMP attempted to retire or refinance the following higher cost long-term debt issues:

9/01/2030 9.64% 3/01/2022 8.65% 12/15/2031 8.91% 5/15/2028 6.83% 7/01/2036 6.53% 12/15/2023 6.90%

If so, please describe the Company’s efforts to retire this debt. If not, explain why the Company has not refinanced or otherwise retired this debt.

e. Please explain the basis for GMP’s bank loan balances for the rate year and test year. Provide all supporting documentation and work papers.

f. Please provide the basis for the monthly cost/interest rate expense for GMP’s bank loans for the rate year and test year. Provide all supporting documentation and work papers.

a. GMP just issued $80M in first mortgage bonds on April 26, 2017. The pricing

on the 30-year bond was 4.17%. After competitive bidding, GMP did a direct placement with New York Life, which avoided intermediary banker fees, which saved approximately $250,000 in bond placement costs. Since this time, the Federal Reserve has issued two 25 basis point increases. Based on the 4.17% coupon rate on our most recent issuance in April plus an additional 50 basis points in the US Treasury Yield during 2017, it is reasonable to project a pricing range of 4.25% to 4.50% during 2018, which reflects an intentional blending of maturity dates so as to minimize costs for customers. This assumes GMP will



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secure low cost long-term debt due to our strong current credit rating. This credit rating therefore translates into direct savings for customers.

b. In general, long-term bond issuances are deferred for as long as possible until our short-term line of credit liquidity is reasonably exhausted. To save money for customers, we utilize short-term borrowings as long as within a reasonable bandwidth of the credit borrowing limit as the interest rate is lower than long-term bonds.

c. In the proformed rate year capital structure, GMP assumed new long-term debt

issuance of $35M in June 2018 and $30M in September 2018. Interest expense was calculated based on issuance being made in the middle of each month. The 13-month average long-term debt balance included in our capital structure is based on outstanding debt at month-end. See also Response 9b.

d. This would be cost prohibitive for customers. That is because there is a make-whole premium requirement within our first mortgage bond supplemental indentures. Approximately every two years, we request Keybank to perform a make-whole premium calculation to determine if the market conditions are favorable to either retire or refinance high-interest-rate bonds that are outstanding. The last report, completed in July 2016, showed the premium would be $75.6 million on outstanding bonds totaling $142.0 million. It was a similar result in the 2014 study. In other words, we would incur $75.6 million of expense for customers for retiring $142 million in debt. Please see the Attachment GMP.DPS1.Q9.d for the last two evaluations performed.

e. Test year balances are based on actual outstanding borrowings at the end of each

month. Rate year balances are proformed based on the most recent financial model. Please see Attachment GMP.DPS1.Q9e.2_ test year for test year balance documentation and Attachment GMP.DPS1.Q9e.1_rate year for rate year borrowing balances.

f. Test year interest expense would be based on actual interest expense occurred. Test year average monthly borrowings and interest expense paid has been provided in Response 8. Rate year interest expense is based on projected average beginning–ending outstanding borrowing for each month and projected



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interest rate. GMP assumed an average interest rate of 1.55% for the rate year. Please see Response 11b for basis of 1.55% borrowing cost.




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Please refer to Page 26, Lines 12–23 of the April 14, 2017 prefiled direct testimony of Mr. Edmund F. Ryan. With respect to GMP’s capital structure, please provide the following:

a. A detailed explanation of the difference between the test year and rate year short-term debt balances.

b. A detailed explanation of the difference between the test year and rate year long-term debt balances.

c. A detailed explanation of the difference between the test year and rate year total equity balances.

a. Please see Response 9 and attachments GMP.DPS1.Q9e.1_rate year and GMP.DPS1.Q9.e.2_test year. Attachments show change in monthly bank loan balances. The change in short-term debt from test year to rate year is a function of balancing liquidity needs.

b. The increase in long-term debt from test year to rate year is due to the funding of plant additions, investments in affiliates Transco and joint ventures that save money for customers and the proposed higher debt to equity ratio as filed in the cost of service that reduces costs for customers.

See table below for changes between the test year and rate year 13-month average debt balances:



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The change in capital structure from test year 13-month average to rate year 13-month average includes the net equity infusions from NNEEC, net income less quarterly dividends and the proposed higher debt to equity ratio as filed in the cost of service.

c. See table below for changes between the test year and rate year 13-month average equity balance:

Green Mountain Power13 month

Average13 month

AverageTest Year Rate Year Change

000's 000's 000's

Common Stock 0$ 0$ Additional Paid in Capital $522,958 541,393 18,436 Net Equity Investment from NNEEC

Retained Earnings $168,761 234,129 65,368Interim Period & Rate Year Net Income offset by Quarterly Dividends

691,719 775,523 83,803Non-utility (7,006) (7,006) Removal of Non-Utility Operations Average Balance

684,713$ 768,517$ 83,803$



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Please refer to Page 27, Lines 12–20 of the of Mr. Ryan’s April 14, 2017 prefiled direct testimony. With respect to GMP’s financing plan through the end of the rate year, please provide the following:

a. Please describe the specific debt issues that GMP plans to retire that total $23.5 million.

b. Provide the basis for the 1.55% borrowing cost for GMP’s credit facility. Provide supporting documentation and work papers.

a.

b. The 1.55% borrowing rate was an estimate since there is no market forecast available. It was generally based on the last 12-24 months of the average interest rate charged on the outstanding short-term borrowings based on our strong credit rating that saves money for customers.


Green Mountain Power Question 11aRetirement of Long Term Bonds

2017 (*) 2018 TotalFirst Mortgage Bond 12th Supplement Mar-17 500,000$ 500,000$ First Mortgage Bond 12th Supplement Mar-18 500,000 500,000 First Mortgage Bond 14th Supplement Nov-18 15,000,000 15,000,000 First Mortgage Bond 17th Supplement Dec-18 6,000,000 6,000,000 First Mortgage Bond 21st Supplement Apr-17 780,000 780,000 First Mortgage Bond Apr-18 800,000 800,000

1,280,000$ 22,300,000$ 23,580,000$ (*) Our testimony assumed the current portion paid in 2017 and the payments in 2018



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Regulatory Accounting and Ratemaking

Please refer to the Microsoft Excel spreadsheet with the file name “2.4” that GMP provided to the Department with the electronic Lead Schedules that were filed with the Tariff Filing. Please provide the following:

a. Provide for each respective listing an indication of which of the individual plant costs and retirements listed by category were part of the Company’s FY2017 rate filing under Alternative Regulation. If included in the FY2017 filing, identify whether the plant cost is the same as it was in the FY2017 filing or if it has changed. If the amount has changed explain why.

b. Please make available for review the known and measurable supporting documentation files for the respective projects and retirements listed on each of the respective functional category lists.

c. For each of the plant costs listed in the respective functional category listings, please identify whether the project is growth related. If so, identify the percentage of costs related to growth (if other than 100% growth related) with an explanation as to why it is not 100% growth related.

d. For each of the plant retirements listed in the respective functional category listings, identify whether the retirement is associated with a project that is growth related. If so, identify the percentage of costs related to growth if other than 100% growth related with an explanation as to why it is not 100% growth related.

e. For each of the plant costs listed in the respective functional category listings, please provide the actual cost incurred to date and identify whether the project cost estimate is on target.

f. For the following plant costs listed in “Computer Software,” please explain why the cost reflected is significantly higher than the projection in FY2016 when the project was supposed to be completed:

143208: Zeacom Update 143658: BI Tech Upgrade 2016

g. For the following plant costs listed in “Production,” please explain why the cost reflected is significantly higher than the projection in FY2016 when the project was supposed to be completed:

141779: Middlesex U1 & U2 143389: 2016 Berlin PLC HMI RTU Upgrade



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h. For the following plant costs listed in “Transmission Lines,” please explain

why the cost reflected is significantly higher than the projection in FY2016 when the project was supposed to be completed:

143570: Fiber to Marshfield Dam

i. For the following plant costs listed in “Transmission substations,” please explain why the cost reflected is higher than the projection in FY2016 when the project was supposed to be completed:

138424: HSCAT 3306 PUTT 138422: HSCAT 3313 PUTT

j. For the following plant costs listed in “Hydro,” please explain why the cost reflected is significantly higher than the projection in FY2016 when the project was supposed to be completed:

143336: Belden Grapple & Rec Improvements

k. For the following plant costs listed in “Transportation” provide for each of the last 5 fiscal years the number of vehicles purchased and for each vehicle the cost recorded as well as the number of vehicles retired:

Bucket Trucks Digger Trucks Small Vehicles

a. Please see Attachment GMP.DPS1.Q12.a-e for the comparison to the FY2017 filing.

b. The capital folders containing all known and measurable information related to the projects listed in “2.4” are provided on a separate flash drive.

c. All growth-related projects were removed from the functional listing and the rate filing in accordance with rate making standards.

d. All growth-related projects including retirements were removed from the functional listing and the rate filing in accordance with rate making standards.

e. Please see Attachment GMP.DPS1.Q12.a-e for the comparison to the FY2017 filing.



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f. 143208 Zeacom Update:

The original quote from the vendor excluded, in error, the high availability and redundancy components of our current environment in the planned upgraded environment. Without these features, the upgrade would have removed the dual site configuration, leaving our call center systems at risk to a single point of failure. Prior to the start of the project, the quote was revised by the vendor to add the high availability and redundancy components into scope for the upgrade. This change required additional virtual machines, licensing, and services. It was also decided to shift our disaster recovery call center components from the Montpelier datacenter to the Rutland datacenter as we have done with most other enterprise systems to maximize operational effectiveness and efficiency for customers. This increased scope and effort as a server needed to be moved and reconfigured for the new environment.

143658: BI Tech Upgrade 2016

The FY2016 plan was to upgrade to version 2.5.0.0.4. Part way into this upgrade, GMP identified product bugs and database incompatibilities that Oracle could not support in a timely manner, which resulted in us shifting gears and upgrading to the next stable version of the software, which was 2.5.2.0.1. We found version 2.5.2.0.1 to have a completely revamped architecture, which added a great deal of unanticipated complexity. Our previous version of BI had a lot of customizations (i.e., specifically designed functions that help us maximize our ability to find patterns in data and save money for customers) that did not fit into the new architecture, which resulted in prolonged delays from Oracle support to implement the missing functionality. We also found that version 2.5.2.0.1 was not compatible with the existing version of Meter Data Management (MDM); therefore, integration testing could not occur until the MDM upgrade was completed in November 2016. These items increased the duration and scope of the project, which resulted in higher contractor costs.

g. 141779: Middlesex U1 & U2

The original budget was based upon removal of one runner for major overhaul. The runner failed inspection and testing, requiring replacement rather than refurbishment. The same approach was planned for the second unit at Middlesex at a later date (1-3 years). However, the results from the failed runner inspection and test contributed to GMP electing to rescope the project for procurement of 2



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new runners for Middlesex for safety, reliability, and good operations for customers. In addition, by replacing the two units at the same time, GMP could take advantage of engineering and economies of scale. GMP elected to proceed with the procurement of two new runners. Additionally, due to the age/condition of the runners, it was difficult to maintain flow requirements (dam spill), change gate setting and take units off line. As of February 2017, one runner has been installed and is operational; the second runner is manufactured and will be installed for a revised in-service date (per 2018 rate process) for June 2017.

143389: 2016 Berlin PLC HMI RTU Upgrade

Casco has performed several PLC projects for GMP in the past (direct to GMP and subcontracted through Eaton). The original cost opinion was based upon similar projects completed for GMP and other clients of Casco. Since the project was estimated in 2017, GMP has been working with Casco to further define the scope including additional data gathering, site visits, and preliminary engineering related to the construction project. Based on the additional information and site visit, Casco provided GMP with an updated cost, which reflects a budget decrease. There has been no change in the general scope, market conditions and further definition of the scope have led to the approximate $80k in budget reduction.

h. The estimated cost of the project for 2018 is actually lower than the estimated cost in 2016. The difference in the estimates is mainly attributed to a scope change centered on the fiber optic cable. In the 2016 estimate, GMP had planned to install fiber optic cable. Since the estimate in 2016, GMP was able to work with Sovernet to utilize its fiber optic cable eliminating the need for GMP to install fiber optic cable resulting in a lower 2018 estimate.

i. The estimated cost for project #138422 (3313 PUTT) in 2018 is higher than the estimated cost for 2016. The difference in the estimates is mainly attributed to an increase in estimated person-hours. The person-hour estimate for the 2018 estimate was revised based upon similar projects completed in previous years.

The estimated cost for project #138424 (3306 PUTT) for 2018 is actually lower

than the estimated cost in 2016. The difference in the estimates is mainly attributed to a scope change centered on the fiber optic cable. When the project was estimated in 2016, the fiber path needed to be built between GMP Websterville substation and VELCO Barre substation going through GMP



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Graniteville substation. In 2017, GMP completed rebuilding of its Graniteville substation so the fiber path and splicing though Graniteville substation is already completed. This reduced the amount of fiber optic cable required for project 138424 resulting in a lower 2018 estimate.

j. The Beldens Recreational improvements are a requirement under the new FERC

license for the Otter Creek. In addition, the grapple improves worker safety when removing debris from the river. The design for this aspect of the project was based on like kind projects when the project was first estimated.

This project was completed in May 2017, therefore it was subject to an interim analysis of cost. When estimated for the 2018 rate process, the project was almost completely constructed. For the recreational improvements, the design changed through the various regulatory agency approvals. For example, the location of the canoe portage changed, which required more flights of stairs/landings and a canoe slide for transport. In addition, the grapple scope of work changed from original. The original scope related to the electrical, hydraulic elements and foundation aspects were not included and these aspects added cost to the project that were not originally anticipated. Ultimately, the change in project costs were due to the additional components needed to get the grapple loader in service originally missed in the estimation.

k. Please see Attachment GMP.DPS1.Q12k.1_additions and Attachment

GMP.DPS1.Q12.k.2_retirements for the last 5 years of vehicle additions for small vehicles, buckets and diggers as well as the retirements in this period.

Person Responsible for Response: Matthew Haley Title of Person: Supervisor of Operations Accounting Date: June 20, 2017



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Finance and Capital Planning

Please provide the financial and operational goals, objectives, targets and/or other direction from Gaz Metro (or other parent entity) to Green Mountain Power (GMP) for each of the years 2015, 2016, and 2017 in the most detailed form available.

None exist. GMP operates independently from Gaz Metro and receives no financial or operational goals or objectives from Gaz Metro. The only financial arrangement is quarterly dividends paid to Northern New England Energy Corporation, U.S holding company of Gaz Metro (“NNEEC”), and equity infusions received from NNEEC.




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Please provide all financial and operational GMP goals, objectives, and targets for each of the years 2015, 2016, and 2017 in the most detailed form available for:

GMP enterprise-level; Each department or division within GMP.

DPS.A14. Please see Responses 22 and 24.




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Please provide detailed GMP organization charts showing for every position title:

a. The current incumbent (or vacant); b. The superior position; c. All subordinate positions; d. Organization name, e.g., the department, division, or section name; e. Cost center name and number.

Consistent with our flat organizational culture, which elevates efficient,

customer-focused operations over bureaucratic hierarchy, GMP does not maintain an organizational chart as described in this request. If specific information on individual departments or employees by position is required, GMP will promptly provide it upon specific request.

Person Responsible for Response: Mari McClure Title of Person: VP, Chief Talent & Support Operations Date: June 20, 2017



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Please identify each GMP organizational unit that is responsible for capital projects and its:

Scope of asset responsibilities (e.g. transmission, substations, information technology, generation, or facilities);

Capital project phase responsibilities (e.g., planning, engineering, construction, contracting, project management, contract management, plant accounting, or quality control).

Please see the prefiled testimony of Brian Otley, John Fiske, and Josh

Castonguay, which provides this information in narrative form. Answering further, please see Attachment GMP.DPS1.Q16 for a listing by scope of responsibility showing the responsibility by phase.




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Please describe in detail GMP’s executive incentive compensation programs for each of the years 2016 and 2017 including:

a. The participants; b. Performance metrics, targets, and bands; c. Payout pool formulas; d. Payout formulas;

Please see Attachments GMP.DPS1.Q17.a, GMP.DPS1.Q17.b, and

GMP.DPS1.Q17.c.




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Please provide the 2016 executive compensation program payouts by participant with the details on how each component of the payout was calculated.

Please see Attachment GMP.DPS1.Q18 and Response 17.




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With respect to GMP’s capital budgets for 2015, 2016, and 2017, please provide in their most detailed form:

a. The initial capital budget sent for review to Gaz Metro or any other corporate affiliate, parent, or superior entity;

b. Any response from Gaz Metro or any other corporate affiliate, parent, or superior entity to GMP’s initial capital budget(s);

c. GMP’s final capital budget for 2015, 2016, and 2017. The following are GMP’s final capital budgets for 2015-2017. This information

is also submitted to Gaz Metro but for informational purposes only. As to the balance of this Request, no such information exists as GMP operates independently of Gaz Metro and Gaz Metro does not provide input on GMP capital budgets.

Please see:

Attachment GMP.DPS1.Q19.1_2015 Capital; Attachment GMP.DPS1.Q19.2_2016 Capital; and Attachment GMP.DPS1.Q19.3_2017 Capital.




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Please describe the GMP’s financial model in detail and how it reflects GMP’s overall business model.

Since 2012, GMP has been using a financial modeling/forecasting tool from

“Utilities International” or “UI”.

We have installed the planning and budgeting module, which allows us to create financial models and forecasts along with the budgeting model that we use exclusively for capital planning.

The actual financial monitoring is done through the Oracle environment which is a fully integrated system. We have been on the Oracle platform for over 15 years. In the last 4-5 years, we have invested in a very sophisticated Business Intelligence (“BI”) tool that is available company–wide.




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Does the GMP financial model calculate capital expenditures needed to meet earnings, net income, or other financial targets?

a. If not, why not? b. How does the GMP financial model incorporate capital expenditures?

No. GMP makes decisions for capital projects in upcoming years based on

what is needed to provide safe, reliable, cost-effective service to customers and then all financial metrics flow from that. As described by Mr. Otley in his testimony, every year, capital budget owners forecast projects needed to continue to provide safe, reliable, cost-effective service to customers in the coming year. Every project then goes through a screen of must do, should do, and would like to do and is reviewed by a subset of leadership team members. This final capital budget is then approved by GMP for the coming year. With respect to how GMP’s financial model incorporates capital expenditures, see Response 20.




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Please provide GMP’s final financial model run for each of the years 2015, 2016, and 2017 relevant to any planned capital expenditures and their impact on financial targets.

Due to its electronic form, GMP’s financial model, as explained in Response 20, is available for review upon request at GMP’s offices in Colchester. With respect to financial targets, see Response 21.




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Please refer to Page 5, Line 16 of Mr. Brian Otley’s April 14, 2017 prefiled direct testimony. Please describe how GMP’s capacity to perform capital projects is determined on a yearly basis.

a. Please also describe in detail GMP’s capacity to perform capital projects in each of the years 2015, 2016, and 2017 and provide copies of any documents that detail such how such determinations were made by GMP. GMP’s capacity planning for capital projects is as follows. We have been executing our annual capital project plans for many years and have built strong institutional understanding about the volume and variety of projects we can deliver in a capital year for customers. We rely less on formal capacity planning models than we do on management experience and track record on delivering the intended outcomes. Our capacity to execute capital projects is a factor of good scope definition coupled with resource availability, including internal employees, external contractors (when needed), and equipment availability (when needed). These resources get factored with consideration to dynamics that may reduce their total capacity to do work, including schedule conflicts, seasonal limitations (length of the construction seasons), storm/outage response, and professional trainings, among others. As part of streamlining the list of capital project candidates each year, capital managers run assessments (again, less based on formal planning models than on experience and track record) to determine the combination of projects that can fit into a capital year based on the variety of project attributes contained in the overall portfolio of projects.

GMP’s capital project capacity from 2015 to 2017 has remained relatively consistent internally. In any given year, however, the combination of projects requiring internal and external labor will have an impact on the overall capacity if measured by either number of projects or budget dollars of those projects. Higher reliance of internal resources has a limiting effect on overall capacity, whereas higher reliance on external resources has an expanding effect on overall capacity.

Person Responsible for Response: Brian Otley Title of Person: Senior VP & Chief Operations Officer Date: June 20, 2017



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Please provide copies of GMP’s strategic plans for each of the years 2015, 2016, and 2017 in the most detailed forms available.

Please see Attachment GMP.DPS1.Q24.1 and Attachment GMP.DPS1.Q24.2




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Please refer to Page 3, Line 6 of Mr. Otley’s April 14, 2017 prefiled direct testimony. Please provide copies of any documents or other evidence that support Mr. Otley’s assertion that GMP has the second lowest electric rates in New England.

a. Please also identify the New England utility that has electric rates lower than GMP and state GMP’s understanding for why that utility is able to achieve lower rates than GMP.

Mr. Otley’s statement that GMP has and will continue to have the second lowest rates in New England, including the 4.98% increase proposed in this proceeding, is based on the latest Edison Electric Institute Typical Bill and Average Rate survey data available at the time of the filing. The average rates of New England investor-owned electric utilities providing data as of June 30, 2016 show that GMP had an average rate of 13.96 cents per kWh. The next lowest average rate is for Unitil in New Hampshire with an average rate of 14.70 cents per kWh. If GMP rates were increased by 4.98%, it would increase the GMP average rate metric to 14.66 cents per kWh which is still below the third lowest utility in the EEI report. The relevant New England utility average rates from the report are included as Attachment GMP.DPS1.Q25.

a. The electric utility that has an average rate lower than GMP in the referenced survey is the Maine Public Service district of Emera Maine. GMP has not performed an analysis of the reasons that the average rate is lower for this utility during this particular reporting period. During many years prior, the Maine Public Service average rate has been higher than GMP.

Person Responsible for Response: Scott Anderson Title of Person: Manager of Rates Date: June 20, 2017



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Please refer to Page 3, Line 19 of Mr. Otley’s April 14, 2017 prefiled direct testimony. Please provide a listing, in the most detailed form available, of the operational savings that have been harvested by leveraging systems and automation in each of the last five years and are planned for 2017.

The precise operational savings associated with automation and leveraging provide value every day. The Company has recognized the efficiencies from our investment in systems and automation through lower overall operating expenses. The savings show up in more efficient processes, which in turn allows employees to do other, higher value, customer-focused work and has helped reduce head count by harvesting attrition and moving resources around in the organization where these savings have occurred and not replacing positions when attrition occurs. Operational savings that have resulted from leveraging systems and automation over the last five years include:

• Advanced Metering Infrastructure (AMI): GMP deployed AMI in the 2012-

13 timeframe. AMI changed the method by which GMP recorded and captured information about electric usage, voltage quality, and outage events. AMI spawned systems integration projects that connected our customer information system, meter data management system, geospatial information system, outage management system, and customer self-service portal, among others. These systems and the integration among these systems changed many workflows and operational processes within GMP and have been an important element of our cost reductions over the past five years. See Response 42 for a copy of GMP’s most recent Smart Grid/AMI report filed with the Public Service Board.

• Customer Information System (CIS): In advance of deploying AMI and as a component of our federal smart grid grant, GMP replaced its decades old CIS. Before that, accommodating any changes to the way customers are billed, due to regulatory changes or new customer tariffs required custom development by a contract development firm. Changes required long lead-times, extensive testing and high costs to implement. With the new CIS, most changes are accomplished through configuration changes or the creation of new rule sets, which can be performed quickly and less expensively, saving customers money and time. Customer Self Service



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Portal (CSS): Since 2012, GMP has replaced a vendor-supplied CSS with an internally developed CSS. While doing internal software development is not our preference, in situations where we cannot procure a suitable solution from the commercial market we will do internal development. That was the case with CSS. Over the past three years, CSS has expanded the number of self- service transactions that GMP customers are able to complete via the portal rather than calling into the GMP call center. As a result of our expanded on-line service capability, our volume of inbound calls to our call center has reduced in each of the past three years. This call reduction has allowed us to deliver a higher quality of service to the customers who do access the call center while also allowing us to not replace call center representative attrition when it has happened, thus delivering operational savings to customers.

• Grid Automation: starting in earnest with GMP’s federal smart grid grant in 2011, GMP has been installing automation devices on its sub-transmission and distribution system. These devices allow us to do several things, including managing substation operations remotely from our control centers (which saves truck rolls and give us better real-time intelligence), re-route power in the event of a fault in order to return service to more customers sooner (which improves reliability to a larger group of customers), and use fault detection to pin-point the location of faults which allows us to provide responding crews more precise locations to begin their damage assessments (which shortens outage times and enhance employee safety).




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Please refer to Page 5, Lines 17–18 of Mr. Otley’s April 14, 2017 prefiled direct testimony. Why were the capital projects listed in the GMP Tariff Filing and Petition not categorized as “must do, should do, and would like to do?”

These questions were screens used as part of the review process leading up to the proposed capital projects included in the 2018 rate case. The listed projects were those chosen for completion based on that screening process.




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Please refer to Page 17 of Mr. Otley’s April 14, 2017 prefiled direct testimony. Please state why the capital projects listed in the GMP Tariff Filing and Petition were not categorized according to the five criteria of Safety, System Reliability, Cost, Culture, and Innovation listed in Mr. Otley’s testimony?

DPS1.A28. The capital projects were categorized in Mr. Otley’s exhibit, Exh. GMP-BO-1. This designation is also included for each capital project as part of its capital folder documentation and may be viewed under the financial analysis tab.




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Please list for each of the capital projects included in GMP’s Tariff Filing and Petition, the total amount of the project, the responsible GMP department or division with oversight over the project, and:

a. Indicate for each project whether it is must do, should do, or would like to do; and

b. Indicate for each whether it is for safety, system reliability, cost, culture, innovation, efficiency, capacity requirements, customer requested, or regulatory and tariff requirements. Please see Attachment GMP.DPS1.Q29.




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Please provide in a native Microsoft Excel spreadsheet, to the extent available, a summary of the last ten years and next five years of capital expenditures for each GMP department or division by the major categories of capital expenditures for each department or division and the total capital expenditures for each year.

DPS1.A30. Please see Attachment GMP.DPS1.Q30. Years 2009-2016 are actual capital expenditures and years 2017 to 2021 are projected capital expenditures.




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Please provide copies of all current Transmission and Distribution (T&D) long-term system plans that guide or inform GMP’s T&D capital investment planning and programs.

DPS1.A31. Please see:

• Attachment GMP.DPS1.Q31.1_Multi-Year Capital Work Plan; • Attachment GMP.DPS1.Q31.2_T&D Integrated Resource Plan; • Attachment GMP.DPS1.Q31.3_PSB Rule 4.900 Electricity Outage Report; • Attachment GMP.DPS1.Q31.4_Rutland Area Reliability Plan; • Attachment GMP.DPS1.Q31.5_Hinesburg Areas Reliability Plan; • Attachment GMP.DPS1.Q31.6_2015 Vermont Long Range Transmission Plan; • Attachment GMP.DPS1.Q31.7_VSPC Annual Report 2013; • Attachment

GMP.DPS1.Q31.8_2014_GMP_IRP_Innovation_Chapter_113014_Clean_&_Final;

• Attachment GMP.DPS1.Q31.9_VSPC Annual Report 2015; and • Attachment GMP.DPS1.Q31.10_VSPC Annual Report 2016.

Person Responsible for Response: John Fiske Title of Person: Leader of Engineering Date: June 20, 2017



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Please describe how the T&D long-term system plans are coordinated with and are consistent with GMP’s strategic planning documents requested in Interrogatory No. 12 above.

Objection: GMP reasserts General Objection 1 as the Question refers to Interrogatory No. 12, but appears to be referencing Interrogatory 24. Without limiting or waiving the foregoing objection, GMP has assumed the reference was intended to be to Question 24 and responds as follows.

The coordination of the T&D plan and the capital planning of the company

happens throughout the year and is formalized during the annual budgeting process. The portfolio of T&D projects identified and selected, as described in witness John Fiske’s testimony on Page 5, starting on line 10, are vetted through GMP’s overall capital budget review process to determine the final T&D capital budget. This overall capital budget process is further described in witness Brian Otley’s testimony. T&D capital projects are selected to maintain and improve safety and reliability of the power system for our customers.




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Please list and describe each of GMP’s T&D individual capital project prioritization processes (for example: transmission, distribution, or substation projects). For each T&D individual capital project prioritization process, please provide:

A detailed description and flow chart; The system tools used; The scoring and/or ranking scheme.

GMP’s process to identify and select T&D individual capital projects is

discussed in the testimony of John R. Fiske, page 5, starting on line 10 through page 6 line 3. GMP reviews and utilizes this Multi-Year Capital Work Plan (Microsoft Excel) as shown in Attachment GMP.DPS1.Q31.1_Multi-Year Capital Work Plan to identify projects for transmission lines, transmission substations, and distribution substations to prioritize the projects based upon a variety of factors as listed in Mr. Fiske’s testimony. Prioritization is accomplished by discussing the benefits of a given project, assessing the consequences of not doing a project, and the risk to the Company and customers of deferring the project in order to complete other projects. Representatives from Engineering, Operations and Operations Technology attend planning sessions to discuss project details and decide whether deferring certain projects is justified due to the positive benefits or higher immediacy associated with other projects. Projects that have overlapping benefits for customers are usually are given higher priority over other projects. The degree of criticality will influence where a project falls in the multi-year capital plan. For example, a transformer with certain failing dissolved gas test results will result in immediate replacement because power cannot flow to the customer without the transformer. The availability of resources is another important factor that is considered when prioritizing projects. Consideration is given to the breakdown of specific projects in different geographic and functional areas and to the number and type of resources necessary to complete these projects. For example, Electrical Maintenance crews are required for distribution substation projects, transmission substation projects, and some transmission line projects. Therefore, individuals from different areas of the Company discuss how the available crews can be dispatched over the year to address the entire priority list of projects. If the workload looks excessive, then decisions will be made regarding whether to defer certain projects to later years or to hire outside contractors. GMP does not utilize a flow chart in this process of prioritization.



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Please reference witness Brian Otley’s testimony for more information on scoring and ranking.




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Please provide the prioritization score or ranking for each 2017 and 2018 T&D individual capital project

Please reference Response 33 above for the process GMP utilizes in prioritizing T&D individual capital projects. For the 2017 and 2018 T&D individual capital projects, the company prioritization is shown in Attachment GMP.DPS1.Q29.




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Please list each of the GMP’s T&D blanket capital project prioritization processes (e.g., for transmission, distribution, or substations). For each of the T&D blanket capital project prioritization processes, please provide:

A detailed description and flow chart The systems or tools used The scoring and/or ranking scheme

As described in the testimony of John R. Fiske, page 8, starting on line 19, the

T&D blankets include Distribution Equipment Purchases, blankets within the Distribution Substations and Transmission Lines and Transmission Substations categories and Distribution Lines. This response addresses prioritization of the blanket capital projects and not whether they are growth and removed from rate base which is discussed in Mr. Fiske’s testimony. The Distribution Equipment Purchases are for transformers, meters, and regulators and capacitors. This equipment is necessary for proper customer service and reliability. These expenditures are to install new or replace failed or deteriorated equipment to maintain system capability and reliability. GMP does not utilize a flow chart or tools for prioritizing these projects nor does GMP score or rank projects in the Distribution Equipment Purchase blanket. There are no alternatives to having this equipment, therefore the blanket capital Distribution Equipment Purchases are must-do projects. See Attachment GMP.DPS1.Q29. The blankets within Distribution Substations and Transmission Lines and Transmission Substations are to cover unforeseen failures or other safety or reliability risks associated with distribution substations, and transmission lines and transmission substations. GMP does not utilize a flow chart or tools for prioritizing these projects nor does GMP score or rank these projects as the projects typically involve replacing or repairing failed or deteriorated equipment that needs to be addressed immediately and therefore are must-do projects. See Attachment GMP.DPS1.Q29. The Distribution Line blanket projects are described in John Fiske’s testimony, starting page 12, line 7 and ending on page 13, line 11. The priority of Distribution Line projects is driven by the category under which the project falls, but all are must do projects. For category 1 projects, Responder (Outage Management System), ArcGIS (ESRI Global Information System) and Business Intelligence systems are utilized to prioritize distribution line reconstruction and



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rebuild projects for improving safety, efficiency, and reliability. The Responder system is utilized to collect customer and system information, the ArcGIS is utilized to create and maintain asset data used in Responder, and Business Intelligence is utilized to query the Responder data to generate reports to aid in the identification of circuits with the worst performance as well as customers who have experienced a high number of outages over a short period of time. These reports help GMP decide which projects should be undertaken. Category 1 project prioritization for Distribution Line Blanket projects is explained in the Company’s 4.900 Electricity Outage Reporting beginning on page 15. For category 2 projects, customer-requested projects, GMP prioritizes these projects based upon when the job is ready for construction, and customer has paid. For Category 3 projects, state and municipality initiated road or bridge construction, GMP prioritizes these projects based upon when the job is ready for construction which is driven by the road or bridge construction schedule. For Category 4 projects, third party reconstruction, GMP prioritizes these projects based upon when the job is ready for construction which is driven by the third-party attachment tariff. See also Attachment GMP.DPS1.Q29.




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Please provide the prioritization score or ranking for each 2017 and 2018 T&D blanket capital project.

Please refer to Response 35 above regarding prioritization score or ranking of T&D blanket capital projects.




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Please provide the policies, procedures, guidelines, and a description of the overall T&D capital prioritization, review, approval, implementation, and control process.

The policies and procedures are described in the testimony of Brian Otley and John Fiske. Please refer to Response 33 above for the prioritization of T&D capital. Please refer to witness Brian Otley’s testimony for the review and approval of capital budget projects at pages 5–7, 13-16. Please refer to John Fiske’s testimony on pages 4-7 regarding the review, approval, implementation and control process designed to have projects constructed consistent with the schedule and budgeted costs.




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Please describe in detail how each unit or team with oversight GMP T&D projects monitors and manages capital project performance (e.g., schedule and budget variances, scope and cost change orders, operational savings achieved, customer service improvements achieved, or kilowatt hours saved).

Please refer to Response 37 above for schedule and budget variances, scope and cost change orders. GMP has weekly Engineering and Operations meetings to review all T&D projects for budget, schedules, scope changes, and resource constraints. GMP tracks information that could be utilized to ascertain operational savings, and customer service improvements via the responder system. However, GMP does not generate reports as it has been our experience that upon completion of the projects, the objective of the expenditure has been achieved. If the objective had not been achieved, GMP would find out through customer inquiries, field work feedback, or continuation of outages.




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Please provide all capital project performance summary information (e.g., schedule and budget variances, scope and cost change orders, operational savings achieved, customer service improvements achieved, or kilowatt hours saved) for each of the 2016 T&D capital projects.

Please find the requested information for the 2016 T&D individual Capital Projects which includes projects from October 1, 2015 to September 30, 2016 in Attachment GMP.DPS1.Q39 for schedule and budget variances. As stated in response 38 above, GMP tracks information which could be utilized to ascertain operational savings, and customer service improvements via the responder system. However, GMP does not generate summary reports as it has been our experience that upon completion of the projects, the objective of the expenditure has been achieved. If the objective had not been achieved, GMP would find out through customer inquiries, field work feedback, or continuation of outages.




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Please provide the documentation for each of the following capital projects in the 2017 capital plan that describes project scope, justification, expected benefits, internal reviews, and project approvals:

Project 143591: South Brattleboro RBLD Project 148622: East Jamaica Bkr/Rly/RTU/Sec Project 148596: Sharon Sub - GMP Portion Project 148600: Reconductor L37 (MST to Flor) Project 148595: Cambridge Transmission L131 Project 143570: Fiber to Marshfield Project 148592: Cambridge Substation Project 148598: Marble Street Bus Upgrade

Project 138419: HSCAT 3312 87L

Please refer to the individual project capital folders for the scope of work, justification, and expected benefits. The internal reviews were completed prior to submittal and project approvals were made during budget approval as referred to in Response 19.




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Please describe in detail the expected performance improvements (e.g., reliability, customer service, employee safety, public safety, energy efficiency or conservation) expected as a result of implementation of the 2017 and 2018 capital plans.

Please refer to the individual project capital folders for an explanation of the financial and other benefits that will result from each project. This information can be found on the financial analysis tab.




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Please provide GMP’s multi-year Smart Grid Plan and detailed listing(s) of associated annual capital additions.

The primary expenses and capital spending associated with the Smart Grid project were expended several years ago. Because this project is largely complete, there is no ongoing Smart Grid plan beyond the original business case. Some capital expenditures related to Smart Grid do still occur in the form of meter replacements, which are found in the functional category of “Meters.” At this stage of the initiative, the only other anticipated remaining action is to consolidate the head-end AMI infrastructures, as those systems are presently separate environments, each controlling their respective legacy meter territories. GMP tentatively plans to consolidate the head-ends in the post-2018 timeframe, so this project would likely appear in the functional category of “Computer Hardware” in a subsequent filing. A copy of GMP’s 2016 Smart Grid Measurement and Verification Report, which includes a report on capital spending, is provided as Attachment GMP.DPS1.Q42.

Person Responsible for Response: Rob Bingel Title of Person: Manager, Forecasting & Analytics Date: June 20, 2017



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Please refer to Page 8, Line 12 of the April 14, 2017 prefiled direct testimony of Mr. John R. Fiske’s. Mr. Fiske implies that the reliability metrics of the past five years support the statement that there has been a measurable improvement in customer reliability due to Smart Grid and other T&D capital improvements. Please provide a description of the Smart Grid and other T&D Capital improvement projects completed in the past five years including quantification of the resulting customer reliability improvements achieved.

On page 8 of Mr. Fiske’s prefiled direct testimony, he explains how the T&D

capital expenditures advance the goals of GMP and its customers by improving the safety and reliability of the system. For reference, a list of T&D projects completed in the last five years is shown in Attachment GMP.DPS1.Q43_5 Year Projects with project descriptions. With respect to Smart Grid investments over the past five years, please see GMP.DPS1.Q42. See also Response 42 and the testimony of Brian Otley at page 25. GMP does not systematically quantify customer reliability improvements as a normal course of business experience shows that after completion of a reliability project, the anticipated improvement in reliability is achieved. Moreover, reliability improvements can be achieved in many different ways and quantification of these improvements is not always possible. For example, replacement of equipment at the end of its service life does not reveal a quantifiable reliability improvement as the project removed the component before it failed. Another example is the installation of a SCADA-controlled motor-operated load break switch on the transmission system, which provides remote fault isolation and re-energization of a line without the need to dispatch a crew. Likewise, installation of animal fences prevents outages. For example, at the North Elm Street substation, GMP had three (3) squirrel- related events over a five (5) month period. GMP installed an animal fence shortly after the February 2014 event and has not had any further outage events. Another example is Line 8 in Sharon where GMP had 12 outages from December, 2014 to end of October, 2016. GMP is rebuilding the line in four phases with only the last phase left to complete. In the past eight months, GMP has only had one outage on that line, and it was caused by a tree on a section of the line has not yet been completed.




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Please provide in native Microsoft Excel format any spreadsheets that show all T&D system performance metrics (e.g., reliability, customer service, employee safety, public safety, or energy efficiency or conservation) tracked for each year 2012-2016 and the 2017 targets for each metric by work center, division, or region (however GMP T&D is organized). Objection. GMP reasserts General Objection 1 as the Request is overly broad and unduly burdensome in that it asks for any spreadsheet in GMP’s possession that may show any aspect of the requested metrics. Without limiting or waiving the foregoing objection, GMP has collected summary documents that track T&D system performance metrics and responds as follows:

Please find attached Six (6) Microsoft Excel spreadsheets providing Service Quality Performance metrics entitled:

1. Attachment GMP.DPS1.Q44.1_GMP SQ 2012 2. Attachment GMP.DPS1.Q44.2_GMP SQ 2013 3. Attachment GMP.DPS1.Q44.3_GMP SQ 2014 4. Attachment GMP.DPS1.Q44.4_GMP SQ 2015 5. Attachment GMP.DPS1.Q44.5_GMP SQ 2016 6. Attachment GMP.DPS1.Q44.6_GMP SQ 2017 Q1

Also attached are five (5) PDF that show daily outage statistics. The company utilizes this data to track its SAIFI and CAIDI performance on a daily basis. Additionally, the report provides, by District, the outage performance and outage details to assist in directing resources to focus in the area of need. This report was developed in 2013 and the following files provide data from 2013 to 2017 year to date (in both PDF and Excel format), entitled:

1. Attachment GMP.DPS1.Q44.7_Daily Outage-Stat 2013 2. Attachment GMP.DPS1.Q44.7_Daily Outage-Stat 2013 - Excel 3. Attachment GMP.DPS1.Q44.8_Daily Outage-Stat 2014 4. Attachment GMP.DPS1.Q44.8_Daily Outage-Stat 2014 - Excel 5. Attachment GMP.DPS1.Q44.9_Daily Outage-Stat 2015 6. Attachment GMP.DPS1.Q44.9_Daily Outage-Stat 2015 - Excel 7. Attachment GMP.DPS1.Q44.10_Daily Outage-Stat 2016 8. Attachment GMP.DPS1.Q44.10_Daily Outage Stat 2016 - Excel 9. Attachment GMP.DPS1.Q44.11_Daily Outage-Stat 2017



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10. Attachment GMP.DPS1.Q44.11_Daily Outage Stat 2017 - Excel

Person Responsible for Response: Ken Couture, Mike Burke Title of Person: Leader of System Operations, Chief Field Ops Executive Date: June 20, 2017



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Please describe each GMP T&D equipment condition monitoring and assessment program and how this information is used to identify, prioritize, and budget equipment maintenance, repair or replacement for each category of T&D asset for:

Poles; Transmission and Sub-transmission lines; Distribution circuits; Transmission substations; Distribution substations; Any other T&D asset.

GMP’s T&D equipment monitoring and assessment programs or asset

management efforts can be described as falling into two main categories. The first category considers the electrical characteristics of the system, specifically voltages, loads, and system performance. The second category considers the physical condition of the various components that comprise the T&D system. These two categories are described in turn:

1. Electrical Characteristics

Monitoring GMP utilizes the data described below to conduct its T&D system planning, operational procedures, maintenance expenditures and capital upgrades. GMP’s approved Integrated Resource Plan filed in 2014 also provides an overall description of the Company’s planning process to assure that the electric system continues to deliver power to its customers safely and reliability while achieving balance between costs and benefits There are a number of data sources used by GMP to monitor its transmission and distribution system. The information used to monitor the system includes the following:

• Observations by line workers, substation technicians, other field

employees and engineering staff in the course of their daily duties.

• The VELCO Long-Range Transmission Plan, which is updated every three years. The Long-Range Transmission Plan considers forecasted load



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growth over a 20-year period and identifies portions of the GMP subtransmission system that might need to be upgraded.

• Line and equipment loading obtained from GMP’s supervisory control and data acquisition (SCADA) database. This database contains real power, reactive power, the status of capacitor banks, and phase data for the majority of our subtransmission lines and a number of our distribution feeders. SCADA data is used to calibrate transmission and subtransmission load flow models that are used in planning studies. SCADA data is also utilized to review fault interrupting device performance and sequence of events.

• Substation and circuit MV90 data, which includes real and reactive load and voltage data for substations and individual circuits. Selected substations have per phase metering to further enhance the understanding of critical circuit loading.

• Advanced metering infrastructure (AMI) uses meters that collect large amounts of data that are deployed at most customers’ service entrances. GMP collects, sorts and utilizes increasingly detailed data, including energy use, real power, reactive power, and voltage levels for each participating customer. This data is stored in the meter data management system (MDMS), which is used to calibrate load flow models.

• Additional monitoring equipment, including thermal demand ammeters and revenue meters, for those distribution feeders that are not monitored by SCADA or MV90.

• Microprocessor-based relays, such as the Schweitzer SEL-351, collect and store data including per phase current, voltage, real power, reactive power, and neutral currents. These relays have been installed at a number of substations and their data can be retrieved as needed. This data is for loadflow studies, system fault device performance and sequence of events.

• Load loggers are portable devices that attach to an individual phase wire and record current flow in 1-, 5-, or 15-minute intervals. These devices are useful for analyzing phase balancing and determining spatial load



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distribution across a given circuit. This information is often used when doing planned outage analyses as well as power quality improvements.

• Tong tests are instantaneous current readings taken with a recording ammeter. Tong testing is useful for balancing loads and verifying load estimates. This information is often used when doing planned outage analyses.

• Per Act 250, developers planning new load additions greater than 100 kW must submit an Ability-to-Serve request to GMP. These requests are stored in a database, and review of these proposed load additions and their respective analyses can provide an indication of system adequacy and the potential for future constraints.

• Outage history and outage analyses, including identification of distribution feeders with the poorest reliability performance, are helpful in identifying system problems. Similarly, customer complaints, such as those involving reliability concerns, low voltage, and voltage flicker are valuable in identifying system weaknesses.

• GMP’s geographic information system is used to locate aging infrastructure and equipment that may be in need of replacement.

2. Physical Condition

GMP employs a number of monitoring and assessment programs to evaluate the physical condition of the components of the T&D system. Identified safety concerns are given the highest priority for repair and replacement. These monitoring and assessment programs are described below: Pole Inspections GMP inspects all poles on its subtransmission and distribution system once every 10 years. Subtransmission poles are provided a full excavation inspection that entails a 360-degree removal of the soil to 18 inches below the ground line. The



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below grade portions of the poles are then wrapped and treated with an antifungal compound. GMP also checks the integrity of the subtransmission poles by: visually inspection, including with binoculars to closely examine pole tops as well as ground line to detect splits, holes, and abrasions; performing core boring; and carrying out sound tests for portions of the pole both above and below ground to detect soft spots or other internal imperfections. When decay is detected, the pole will be chemically treated and examined to see if any restoration method can be used to extend the life of the pole, such as adding structural braces to extend the life and strengthen the pole. If the life of the pole cannot be extended, it will be replaced. For a zero-life pole priority pole, our guideline is within 30 days, unless the pole is considered a danger pole, in which case we treat it as an emergency and replace it immediately. Poles that are deemed condemned, meaning just below threshold of structural strength but not a danger are replaced within approximately a year. All poles marked with deficiencies by Osmose (Pole Testing Contractor) in the field are assessed by field personal as to whether they are safe to climb during emergency response or maintenance. GMP reviews the above-mentioned pole treating and inspection records as well as age, location and criticality of the transmission line to assess replacements. Distribution poles are excavated to six inches below grade on two sides of the pole. Visual inspections, including with binoculars to examine pole tops as well as ground line are performed to detect splits, holes, and abrasions. GMP also performs core boring and sound tests for portions of the pole above the ground. Decayed distribution poles that fail inspection are simply replaced because, by that time, they generally fail to meet the current specifications for height and class. Substation Inspections/Preventive Maintenance GMP inspects its substations on a monthly basis. These inspections detect and report on any condition that compromises the safety, security, and functionality of a substation and its associated equipment. Substation inspections consider all major equipment including, but not limited to, transformers, circuit breakers, regulators, battery banks, capacitor banks, switches, fences and gates. Substation inspectors consider a large number of check-list items to detect deficiencies in



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security, environmental performance, or operational performance. Actionable items are documented and prioritized, and repairs are scheduled as needed. Conditions requiring immediate attention are directly reported to the control center so that crews can be dispatched for repairs. In addition, certain substation equipment is subject to periodic preventative maintenance testing. Preventative maintenance testing can also identify deficient equipment, thereby triggering any necessary repair or replacement of components. Underground Distribution Surface equipment associated with underground distribution, including pad-mounted transformers, metal terminating cabinets (“MTC”), and pedestals are periodically inspected for structural failures, shifting along the base, rust, transformer fluid leakage, and signage integrity. Identified deficiencies result in the repair or replacement of deficient equipment and components. Please reference Attachment GMP.DPS1.Q31.2_T&D Integrated Resource Plan for additional information related to Underground Utility Damage Prevention.

Aerial Patrols

Every spring and fall, GMP flies helicopters to perform aerial patrols of its entire subtransmission system. During these patrols, GMP visually inspects for danger trees, broken cross arms, floating phases, cracked insulators, displaced cotter pins, and other problems that can negatively affect the performance of the transmission lines. In addition, GMP regularly patrols the system by helicopter after major weather events looking for impending issues (e.g., trees hanging precariously over energized conductors, damaged equipment, washed-out poles, etc.) that have not yet caused an outage. Infrared Inspections During the peak load period in August, GMP flies an additional aerial patrol to conduct infrared scans of both transmission lines and substations. Infrared scans employ an infrared camera mounted directly to the helicopter to identify hot spots that can indicate a failing conductor, corroded splice, loose connection, or other problem area where a line or substation is stressed and vulnerable to failure. From the ground, GMP also periodically performs substation infrared scans using hand-held infrared cameras.



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Worst Performing Circuits Accumulated deterioration on distribution lines can be detected by GMP’s efforts to identify its worst performing circuits. GMP uses business analytics query tools to analyze and generate reports, including monthly reports, to identify customers who have experienced a high number of outages over a short period of time. These reports help GMP to decide where improvement dollars may best be invested. Outage history and outage analysis, including identification of distribution feeders with the poorest reliability performance, are helpful in identifying system problems. Although a circuit may be identified as a “worst circuit,” improvements may not be possible or merited upon further analysis. By way of example, if a car pole accident is the reason for a majority of the customer hours out on a feeder, there may be no justification for undertaking additional improvements beyond repair of the damage done by the accident. Also, changing the operation of a given circuit may be the best way to address an operating issue, which requires effectively no financial investment. Other measures employed, to date, to improve the reliability of poor-performing circuits include road-side rebuild projects, controls upgrades, protection upgrades, and transmission automation and reconstruction projects. Relay Monitoring/Preventive Maintenance GMP’s protective relays are monitored through a three-step process: • Alarms: The majority of GMP’s relays are microprocessor based. These

relays continuously self-monitor and send an alarm to the control center whenever a functional failure, drift in calibration, or communication failure is detected.

• Event Data Analysis: Following the operation of a microprocessor-based relay, event data is downloaded and subsequently analyzed by the engineering team to ensure that the relay, fault interrupting and automatic reclosing schemes operated correctly.



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• Periodic Testing: Microprocessor relays and electronic-based relays are scheduled for testing on ten-year intervals. Electromechanical relays are scheduled for testing on four-year intervals. Relay testing ensures proper relay functioning and ensures that programmed settings remain within tolerances.

The above T&D equipment monitoring and assessment programs is used in the following manner to identify, prioritize, and budget equipment maintenance, repair, or replacement for:

a. Poles –

1. The following are used to identify and prioritize pole replacements

including Pole Inspections, Aerial Patrols, Infrared Inspections, Worst Performing Circuits, Observations by line workers and engineering staff, Long Range Transmission Plan, Line and Equipment Loading, Outage History and Outage Analyses, GMP’s Geographic Information.

2. Priority is based upon the criticality of the test results or observations from the Pole Inspections, Aerial Patrols, Infrared Inspections and Observations by line workers and engineering staff.

3. Other factors driving pole replacements include Worst Performing Circuits, Long Range Transmission Plan, Line and Equipment Loading, Outage History and Outage Analyses, GMP’s Geographic Information. The priority for these pole replacements is typically driven by the project rather than pole condition. For example, relocating a line road side for reliability or relocating poles for a state or municipality driven work.

b. Transmission and Subtransmission Lines –

1. The following are used to identify and prioritize line replacements

including Observations by field works and engineers, Pole Inspections, Aerial Patrols, Infrared Inspections, Long Range Transmission Plan, SCADA data, Outage History and Outage Analyses, and Geographic Information.

2. Line replacements are prioritized based upon study results and system needs. As described in John Fiske’s testimony on Page 5, Line 10 through page 3 line 3, GMP identifies and selects projects.



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c. Distribution Circuits –

1. The following are used to identify and prioritize Distribution Circuit projects including Observations by line workers and engineering staff, SCADA Data, MV90 data, AMI data, Thermal Demand Meters, Microprocessor Based Relays, Load Loggers, Tong Tests, Outage history and Outage analyses, GMP’s geographic information, Pole Inspections, Underground Distribution Inspection, Aerial Patrols, Infrared Inspections, Worst Performing Circuits, and Relay Monitoring.

2. Distribution Circuit component replacements utilize information from the above-mentioned monitoring and assessment programs to study/analyze the system and determine its safety, efficiency and reliability. For example, outage history and outage analyses have identified the 20 worst circuits. GMP has further reviewed this system to target which components of the circuit to replace to improve reliability.

d. & e. Transmission Substation and Distribution Substations - 1. The following are used to identify and prioritize Transmission and

Distribution Substations projects including Observations by line workers and engineering staff, Long Range Transmission Plan, SCADA Data, MV90 data, AMI data, Thermal Demand Meters, Microprocessor Based Relays, Outage history and Outage analyses, GMP’s geographic information, Substation Inspections, Worst Performing Circuits, and Relay Monitoring/Preventive Maintenance.

2. Transmission Substation and Distribution Substations prioritize projects based upon study results and equipment testing results to determine safety, efficiency and reliability. Page 5, Line 10 through page 6, line 3 of John Fiske’s testimony, GMP describes how it identifies and selects projects.

Person Responsible for Response: John R. Fiske Title of Person: Leader of Engineering Date: June 20, 2017



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Please provide in native Microsoft Excel format any spreadsheets that provide an annual summary of distribution circuit outages by each cause tracked (e.g., trees, animals, equipment failure, and pole hits) experienced for the last five years.

Please see the attached annual PSB Rule 4.900, Electricity Reliably Reporting, Outage Data Excel files data files for the period 2012 to 2016 (Attachments GMP.DPS1.Q46.1 – GMP.DPS1.Q46.6).

In 2012, GMP North (Legacy GMP) and GMP South (Legacy CVPS) filed separate PSB Rule 4.900 filings. GMP was only able to locate GMP North outage data submission in Excel format. The GMP South outage data submission is in .PDF format.

Person Responsible for Response: Ken Couture Title of Person: Leader of System Operations Date: June 20, 2017



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Please provide in native Microsoft Excel format any spreadsheets that provide an annual summary of distribution substation outages by each cause tracked (e.g., animal and equipment failures) experienced for the last five years.

GMP does not track the information in the manner requested. However, the 4.900 annual filings report outages on a system-wide basis for distribution lines, distribution substation and transmission circuits. See Response 46.




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Please provide in native Microsoft Excel format any spreadsheets that provide an annual summary of transmission circuit outages by each cause tracked (e.g., trees, animals, and equipment failure) experienced for the last five years.

DPS1.A48. See Response 47.




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Please identify each of the 2017 and 2018 T&D capital projects chartered to reduce T&D system outages by outage cause (e.g., animals, trees, and equipment failure) and system component (e.g., transmission lines or substations or distribution lines or substations).

Exh. GMP-JRF-1 identified all 2017 and 2018 T&D capital projects that are

being done to improve reliability. The column headed “Criteria” identifies these projects. This question seems to imply that a reliability project is designated to address specific reliability outage causes (e.g., animals, trees, and equipment failure) for specific system components (e.g., transmission lines or substations or distribution lines or substations). This is not always the case because a given project might address a number of reliability improvements. For example, the main drivers for Project 143292 Graniteville Distribution Substation are asset maintenance replacement of the transformer which will improve reliability for customers. Ancillary reliability benefits include animal protection, feeder backup, and replacement of other equipment near the end of its useful life such as breakers and relays. To respond to the question, two columns have been added to the original Exh. GMP-JRF-1, included in John Fiske’s testimony to indicate whether a capital project was targeted to reduce system outages for a specific cause (“Reliability Improvements for Outages Due to:”) and to identify the system component (“System Component to Experience Reduced Outages”). Please refer to Attachment GMP.DPS1.Q49.

Person Responsible for Response: John R. Fiske Title of Person: Leader of Engineering Date: June 20, 2017



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Please provide the most recent summary report of distribution circuit performance analysis, by circuit and substation.

Please see Attachment GMP.DPS1.Q50_Outages by Feeder.

Person Responsible for Response: Mike Burke, Ken Couture Title of Person: Chief Field Ops Executive, Leader of System Operations Date: June 20, 2017



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Please describe in detail each planned vegetation management related capital project for 2017 and 2018 including the scope, cost, circuit, and objective.

Per the guidance of the DPS, GMP has no capital projects that are solely for

Vegetation Management. GMP only capitalizes vegetation management when there is trimming done as part of a broader capital project in order to allow that capital project to be built. These types of projects could include a line rebuild, pole replacement, service connect, line extension, etc., where vegetation management is needed to clear an area for the installation of new facilities or replacement of existing facilities. The significant vegetation management performed by GMP that is not done along with, or in preparation for, a capital project is part of our T&D maintenance program, which is treated as an O&M expense.

Person Responsible for Response: Mike Burke Title of Person: Chief Field Ops Executive Date: June 20, 2017



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Please identify and list each GMP T&D asset management-related program.

The GMP T&D asset management-related programs are:

1. Vegetation Management 2. Pole Inspections 3. Underground Utility Damage Prevention 4. Aerial Patrols and Infrared Detection 5. Breaker Testing 6. Transformer Testing 7. Battery Testing 8. Substation Inspections 9. Relay Testing

Please see also Responses 45 and 53.




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Please provide the following information for each GMP T&D asset management related program:

The T&D assets covered; A description of the key features and elements; The information system or tools used; An explanation of how T&D is utilizing the program for its capital

investment decision-making; A listing of T&D organizational elements (consistent with the organization

charts requested above) that utilize and/or support the asset management program.

Please see Response 45. For a summary of asset management programs and responsibilities, please see Attachment GMP.DPS1.Q53. Please see Response 15 regarding organization charts.




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Please provide the following information regarding GMP’s overhead pole inspection and maintenance program:

Plans, procedures, or guidelines for the overhead pole inspection and maintenance program;

A description of key features and elements of the program and any changes implemented in the past five years;

Annual summaries of the inspection and maintenance plan and actual work completed for the past five years;

The number of installed poles, average pole age, and the number of defective poles identified for replacement in each of the past five years;

How GMP is utilizing the program results for its capital investment decision-making in evaluation of existing lines to be rebuilt.

a. Please see Response 45 regarding pole inspections. Please refer to Attachments GMP.DPS1.Q54.1 and GMP.DPS1.Q54.2. b. See answer Response 45 for key features of the program. Within the last 5 years, GMP changed the percentage of poles inspected per year. We now inspect 10% of our poles per year. We used to inspect 33% each year for three years in a ten-year period. This change smooths out the costs over a ten-year period for a less dramatic impact on cost in any given year. c. As explained above, we now inspect approximately 10% of our poles per year. The following table identifies the number of poles inspected in each of the last five years:

2012- 14317 2013- 11624 2014 – 14299 2015 – 14333 2016 – 19272

The following table identifies the actual number of poles replaced in each of the past five years:

2017 2016 2015 2014 2013 2012

Distribution 3039 5446 5239 3373 2801 4194

Transmission 190 352 209 128 203 625



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Total new poles/year 3229 5798 5448 3501 3004 4819

d. As of June 15, 2017, the number of distribution poles is 292,714 with an average age of 31.1 years, and the number of transmission poles is 18,506 with an average age of 37.4 years. The inspection program identified the following number of poles for replacement in the following years:

Year 2012 2013 2014 2015 2016 Distribution Poles

252 60 181 87 212

Transmission Poles

1 9 2 4 3

e. GMP utilizes the pole inspection data in parallel with reliability and safety data (location of line) to make decisions on whether we replace structurally deficient poles as they are identified or during a larger capital improvement project to upgrade the whole line. These projects would be identified to improve reliability for our customers or safety for our workers. These factors include but are not limited to, location of line, roadside versus cross country, recent reliability performance of line, total age of facilities, poles and wire.




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Please provide a five-year history of budgets and actual spending under the eight Blanket Work Orders listed in Exhibit GMP-JRF-1.

Please see Attachment GMP.DPS1.Q55 for historical blanket spending. Please note that we have not included the budgeted amount for FY2012 due to differences in budgeting pre-merger, which does not allow for each category of blanket to be directly assigned.




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Please reconcile how the GMP five-year meter blanket growth rate of 40.28% and the transformer blanket growth rate of 52.90%, as described on Page 11, Lines 5–6 or Mr. Fiske’s prefiled direct testimony, comport with the GMP’s expected annual customer growth of 0.5%, as described on Page 10, Lines 18–19 of Mr. Fiske’s prefiled direct testimony.

As described in John Fiske’s testimony Page 10, 19-21 and Page 11, 1-3, GMP utilized information in the ITRON report (an independent third-party forecaster that GMP uses to forecast sales changes per the Public Utility Commission and Department of Public Service approved regulation plan), which identified the expected increase in the customer base for 2017 and 2018. The .5% (rounded up from .45%) customer growth rate identified in the report was the annual growth over a ten-year period. Rather than applying an annual increase of .5%/year, GMP used the identified 2017 and 2018 customer numbers to more accurately reflect the expected meter and transformer growth rates for these years. In summary, while the customer growth rate might only be .5%, the meter and transformer blanket growth rate is a cost growth rate, not a customer growth rate. Thus, the approximately.5% increase in the number of meters or transformers needed for growth is multiplied by the cost of the meters or transformers in order to determine the cost due to growth. That growth cost is then compared to the total blanket meter or transformer budget to determine the blanket growth rate which will naturally be a much larger percentage than the relatively small rate of customer growth. The chart below identifies the information from the report used in the calculation.

Table 2: Residential Customer and Use Forecast

Table 4: Commercial Customer and Use Forecast

Annual Growth Rate

CUSTOMERS CUSTOMERS TOTAL

2016 220,803 40,363 261,166 2017 221,698 41,054 262,752 0.61% 2018 222,816 41,481 264,297 0.59% 2019 223,944 41,906 265,850 0.59% 2020 224,970 42,114 267,084 0.46% 2021 225,807 42,226 268,033 0.36% 2022 226,650 42,415 269,065 0.39% 2023 227,483 42,639 270,122 0.39% 2024 228,290 42,839 271,129 0.37%



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2025 229,139 43,036 272,175 0.39% 2026 229,978 43,247 273,225 0.39%

over 10 years 0.45%

Based on the chart, it can be seen that the difference in the total number of customers between 2017 and 2016 was 1,586 new customers and between 2018 and 2017 was 1,545 new customers. GMP calculated an average cost for a meter installation to be $172.66 in 2016 dollars. Applying a 1.22% CPI resulted in an average 2017-meter cost of $174.77 and average 2018-meter cost of $176.90. Utilizing this information, the meter costs associated with the new customers would be $277,180 (i.e. [1,586 customers * $174.77 per meter installation]) for 2017 and $273,308 (i.e. [1,545 customers * $176.90 per meter installation]) for 2018. The estimated total budget for meter blankets was $679,314 for 2017 and $687,601 for 2018. The total growth percentages of the meter budget were calculated as 40.80% (i.e. [$277,180/$679,314]) in 2017 and 39.75% (i.e. [$273,308/$687,601]) in 2018. The average of these values (40.80% and 39.75%) calculates to the 40.28% referenced in the testimony and represents the overall percentage of the meter blanket budget for growth and is therefore removed from the rate filing. The same methodology applies to transformers. Based on the chart, it can be seen that the difference in the total number of customers between 2017 and 2016 was 1,586 new customers and between 2018 and 2017 was 1,545 new customers. GMP calculated an average cost for a transformer installation to be $1,250.00 in 2016 dollars. Applying a 1.22% CPI resulted in an average 2017 transformer cost of $1,265.25 and average 2018 transformer cost of $1,280.69. Utilizing this information, the transformer costs associated with the new customers would be $2,006,687 (i.e. [1,586 customers * $1,265.25 per transformer installation]) for 2017 and $1,978,660 (i.e. [1,545 customers * $1,280.69 per transformer installation]) for 2018. The estimated total budget for transformer blankets was $3,744,063 for 2017 and $3,789,741 for 2018. The total growth percentages of the transformer budget were calculated as 53.60% (i.e. [$2,006,687/$3,744,063]) in 2017 and 52.21% (i.e. [$ 1,978,660 /$3,789,741]) in 2018. The average of these values (53.63% and 52.21%) calculates to the 52.90% referenced in the testimony and represents the overall percentage of the transformer blanket budget for growth, and is therefore removed from the rate filing.

Person Responsible for Response: John R. Fiske



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Title of Person: Leader of Engineering Date: June 20, 2017



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Please refer to Page 8, Lines 20–21 of Mr. Otley’s prefiled direct testimony. Mr. Otley states that GMP has added a two months’ buffer to the physical in-service dates on all plant additions to allow for contingencies and final accounting. What impact does the addition of the two months’ buffer have on the cost of service calculation?

The two-month buffer to the in-service dates of all plant additions reduces the rate year 13-month average plant in service balance, which reduces rate base and cost of service for customers.




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Please refer to Page 2, Lines 16–18 of Mr. Otley’s prefiled direct testimony. Mr. Otley states that GMP is producing some of the highest levels of customer satisfaction and trust of any utility in the country. Please provide the quantitative evidence and/or documentation to support this claim.

The J.D. Power and Associates report that was attached as Exh. GMP-SC-1

and referenced in the testimony of Steve Costello, includes data on customer satisfaction. As the report shows, GMP is ranked No. 1 among midsize utilities in the East, with a score of 681, nine points better than the No. 2 company. Exh. GMP-SC-6, the Vermont Service Quality Performance Index, demonstrates overall customer satisfaction of 94 percent in 2016. Exh. GMP-SC-2, the fourth-quarter Metrix Matrix reports, demonstrates satisfaction in that quarter of 93 percent. Exh. GMP-SC-3, the annual customer satisfaction report from Metrix Matrix, showed 88 percent of customers surveyed report a high level of trust in the company. Our contacts at Metrix Matrix reported to us that these types of numbers place GMP among the top utilities in the country for customer satisfaction. According to Metrix Matrix, GMP’s satisfaction is statistically significantly higher than the 87% average found in the Research America benchmark of other northeast energy providers.

Person Responsible for Response: Steve Costello Title of Person: VP Customer Service Date: June 20, 2017



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How does the multi-year trend of employee (and public) safety metrics support GMP’s historical and planned spending on safety improvements?

GMP’s Service Quality Plan includes certain safety metrics that are reported each year. These metrics include GMP’s OSHA recordable injury rate and GMP’s days away, restricted or transferred (DART) incidence rate. In the years 2014 to 2016, GMP’s OSHA recordable injury rate fell each year, from 6.85, in 2014, to 6.10 in 2015 and 5.61 in 2016. GMP’s DART incidence rate was also reduced each year, from 4.14 in 2014 to 2.19 in 2015 and to 1.56 in 2016. These metrics are related to GMP employee safety. We believe our investment in safety training and equipment, including the capital projects that have safety components in them, is delivering on GMP’s safety objectives, both for employees and the public.

Answering further, GMP puts safety at the core of its culture. Whether for employees, customers, partners, contractors, suppliers, stakeholders or any other entities that interact with our work we work hard to prioritize a culture that puts safety and the accountability for safety of self and others front and center. Safety incidents are interesting to track and learn from over time. One of our strongest lessons has been that a strong safety focus and culture is never complete and one can never rest. When we make good progress on a certain safety front such as trips and falls, another front will show up in our measurements such a tick bites or underground dig-ins. We work in an ever changing and dynamic environment, so there is no formulaic solution for creating a great safety culture. While our safety statistics and performance over the past several years has been solid and improving, we can never be satisfied, or complacency will set in. GMP has invested in equipment, training, education and awareness messaging as part of our investment in operating safely. While these things are important and are good investments year over year, I think the best thing we’ve done related to safety is simply talk about it openly and honestly and a lot. Every GMP meeting begins with a group pledge of, “I am GMP safety.” Each week our entire workforce re-confirms their individual commitment to striving for an incident-free week as part of our Monday morning kick-off meeting. And, most importantly, we have changed the culture such that when a safety incident does occur, the person involved in the incident helps their co-workers by sharing the incident details and how the incident might have been prevented in the interest of learning and raising awareness rather than feeling judged. We expect to continue our investment in safety in a



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variety of ways and always with an eye towards learning from what other effective organizations are doing in this important area.




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For each generating resource added since the 2013 merger with Central Vermont Public Service Corporation, please provide the following information:

The name of the resource; The type of resource, e.g., wind, solar, natural-gas fired, or nuclear; The physical location of the resource; The maximum reliable capacity of the resource (in mega-watts); The capacity of the resource (in mega-watts) counted toward achieving the

Company’s capacity requirement; The month and year of acquisition.

Please see Attachment GMP.DPS1.Q60_New Generating Resources. This file

includes all physical generating units that GMP has either purchased or entered into a PPA agreement with, for the energy and/or capacity output, plus PPA for system energy or capacity. Included in these resources are units in which GMP previously may have held an entitlement but since the merger have either been purchased or new PPAs have been entered into.

Person Responsible for Response: Josh Castonguay, Douglas C. Smith Title of Person: VP & Chief Innovation; Director, Power Supply Date: June 20, 2017



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For each demand-side resource added since the 2013 merger with Central Vermont Public Service Corporation, please provide the following information:

A description of the resource; The type of resource, e.g., energy efficiency or demand response; The peak demand reduction provided by the resource (in mega-watts) by

year for the years 2013 through 2018; The peak demand reduction (in mega-watts) counted toward achieving the

Company’s capacity requirement by year for the years 2013 through 2018.

Pursuant to Vermont statute, the Public Utility Commission oversees development, performance, and funding of Vermont’s Energy Efficiency Utility (EEU) Program. The EEU Program works to provide energy efficiency services to residential and business electricity, natural gas, and thermal-energy-and-process-fuel consumers throughout Vermont. Vermont is unique in that the EEU is separate and apart from the distribution utility and is appointed for a 12-year term by the Commission. In GMP’s service territory, Efficiency Vermont is the EEU. This means that Efficiency Vermont currently provides energy efficiency resources in GMP’s service territory. The balance of information sought in this Request can be found by reference to Efficiency Vermont’s Annual Reports and Plans, publicly available at https://www.efficiencyvermont.com/about/annual-plans-reports. In addition to the EEU managed-programs, GMP has also introduced several tariff riders which incentivize demand-side resource management, including a Pilot Load Response Rider, two residential Critical Peak Pricing rate schedules, and an expanded legacy-GMP Critical Peak Rider for all large C&I rate classes.

Person Responsible for Response: Douglas C. Smith, Scott Anderson Title of Person: Director, Power Supply, Manager of Rates Date: June 20, 2017



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Please refer to Footnote 7 on Page 13 of the April 14, 2017 prefiled direct testimony of Mr. Douglas C. Smith. Please identify and/or provide any documents that show GMP’s “share of regional capacity requirements” for the years 2013, 2014, 2015, 2016, 2017, and 2018. Please also:

Describe in detail the development of the Company’s “share of regional capacity requirements;”

Please provide copies of all computations used to derive the Company’s “share of regional capacity requirements.”

Please provide the Company’s “share of regional capacity requirements” utilized in the development of the Company’s 2014 Integrated Resource Plan (IRP).

At a high level, our goal remains to maintain a low cost, low carbon, highly

reliable portfolio for our customers. a. GMP’s share of the regional capacity requirement is based on GMP’s 2016

(January – May 2018 costs) and projected 2017 (June – December 2018 costs) loads in the hour of the annual ISO peak hour. In each year, the GMP load is compared to the ISO peak load to determine the Company’s percentage share of the total ISO requirement. This share is multiplied by the estimated total ISO requirement to yield GMP’s total nominal requirement. The projected nominal values are 935 MW for January – May, and 881 MW for June – December. Please see file Attachment GMP.DPS1.Q62_Historic Capacity Requirements for the GMP share of 2012-May 2017 capacity requirements.

b. The calculation of GMP’s rate year capacity requirements is located in the excel file “7._Capacity_Model_2018_RC”, tab “1. Annual_ICR_&_FCM Values.” Values for ISO peak hour GMP 2017 load offset (reduction) come from excel files “15._Battery_Load_Reductions_RC” and “LT_PPA_Resources_2018_RC” tab “Solar FCM and TX Impacts.” These documents were provided via e-mail to DPS staff John Woodward.

c. In the 2014 IRP, the following table shows the base case estimate of GMP’s share of regional capacity requirements:

Capacity Year

Delivery Period GMP Share of Regional Installed Capacity

Requirements FCA8 June 2017 to May 2018 927 MW FCA9 June 2018 to May 2019 922 MW



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FCA10 June 2019 to May 2020 916 MW FCA11 June 2020 to May 2021 910 MW FCA12 June 2021 to May 2022 906 MW FCA13 June 2022 to May 2023 907 MW FCA14 June 2023 to May 2024 908 MW FCA15 June 2024 to May 2025 910 MW FCA16 June 2025 to May 2026 912 MW FCA17 June 2026 to May 2027 916 MW

Person Responsible for Response: Douglas C. Smith Title of Person: Director, Power Supply Date: June 20, 2017



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Please refer to Row 56 of Exhibit GMP-DCS-2, and the column marked “RY Avg. Nominal Capacity” (949 Megawatts). Please state:

Why has the Company acquired 949 MW of capacity for 2018 when the 2014 IRP predicted a summer peak demand of only 772 MW for 2018 (see page 2-11 of the 2014 IRP)?

Please describe all efforts by the Company to sell excess capacity acquired for the year 2018.

a. GMP does not expect to have a capacity surplus. GMP’s share of capacity obligations for the rate year (its share of the regional Installed Capacity Requirement, or ICR) has exceeded 900 MW in recent years and is projected to remain at similar levels; at this level GMP is a net capacity purchaser. For context, the ICR is consistently much higher than the regional peak demand because the ICR is designed to ensure adequate resources to meet New England electricity demand during peak conditions (and in all other hours) with a very high probability, after accounting for the possibility of generating unit outages (particularly unplanned ones). In order to achieve the target level of resource adequacy, the ICR reflects a substantial capacity reserve margin above the forecasted peak load, and the margin relative to actual peak loads in New England has typically ranged between 25 and 43 percent. This is why GMP’s capacity obligations are much higher than GMP’s share of the regional peak load.

Also, please note that the capacity quantities listed on Exhibit GMP-DCS-2

represent nominal figures intended to roughly indicate the potential output of each source, not the amount of capacity (sometimes much lower) that each source will provide to GMP in the Forward Capacity Market (FCM). For example, the Deerfield Wind plant is depicted on Exhibit GMP-DCS-2 at its nominal maximum output of 30 MW; GMP assumes that due to its intermittent nature, the plant will provide an average value of around 10 MW in the Forward Capacity Market. Collectively, the nominal capacity values in Exhibit GMP-DCS-2 are meaningfully larger than the values that GMP’s resources will receive in the FCM.

The projected rate year FCM capacity cost calculation, which is included in excel

file “7._Capacity_Model_2018_RC” (recently provided via e-mail to DPS staff John Woodward) reflects GMP resources’ FCM (not nominal or nameplate) values.



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Finally, we should note that our projection for peak GMP loads has dropped since the publication of the 2014 IRP; that has reduced GMP’s expected capacity obligations somewhat. b. As discussed above, GMP does not expect to have excess capacity in 2018; GMP has not engaged in any efforts to sell capacity for this period.

Person Responsible for Response: Douglas C. Smith, Chuck Watts Title of Person: Director, Power Supply; Power Supply Analyst Date: June 20, 2017



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Please provide the Company’s current load forecast for both peak demand and system energy requirements.

Please see the file Attachment GMP.DPS1.Q64_Current Load Forecast. This energy sales forecast was produced by Itron, Inc.; estimated non-PTF transmission and distribution losses, plus GMP company use were added to sales to yield GMP’s projected energy requirements (“retail load”) for the forecast period. The losses and company use volumes are based on calculated 2016 values. The load forecast depicts the declining sales phenomenon in Vermont due to net metering, efficiency, and a sluggish economy.

The peak demand values are based on Itron “base case” peaks, reduced for cumulative impacts of projected load reducer (mostly solar) generation and battery storage.

Person Responsible for Response: Charles Watts Title of Person: Power Supply Analyst Date: June 20, 2017



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Please describe in detail the development of GMP’s current load forecast.

Because this is a traditional cost of service filing, the rate year sales levels reflect Test Year (Calendar Year 2016) sales adjusted by the increase in MWh due to forecasted heat pump and heat pump water heater (hpwh) installations during the Interim Period and Rate Year. Interim and Rate Year installations of heat pumps and hpwh reflect the pace of installation of those respective units deployed during the Test Year. The increase in sales for the heat pumps and hpwh takes into account both the timing of the installation and the incremental sales associated with each unit. Itron, Inc. determined the adjustment for heat pump and hpwh sales based upon Test Year and expected Interim Period and Rate Year installations as provided by GMP and incremental usage expectations as determined by Energy Futures Group, an outside vendor.

For planning purposes, GMP requested that Itron, Inc. also provide an updated forecast, and its output may be found in Attachment GMP.DPS1.Q65. Itron, Inc. has produced previous revenue forecasts that were submitted for prior years’ base rate filings. Its forecasts are based upon regression models that use as major inputs economic forecasts, efficiency and solar net metering expectations, and weather-normalized previous sales. Please note that the output in the tab “Annual Summary” is based upon GMP’s fiscal year of October to September. Monthly sales may be found in the tab “Summary.”

Person Responsible for Response: Rob Bingel Title of Person: Manager, Forecasting & Analytics Date: June 20, 2017



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Please refer to Page 14, Lines 13–14 of Mr. Smith’s prefiled direct testimony. Please a copy provide the NextERA Seabrook power purchase agreement (“PPA”) referenced by Mr. Smith.

Please refer to the following files:

• Attachment GMP.DPS1.Q66.1_2011 NextEra Seabrook PPA • Attachment GMP.DPS1.Q66.2_2015 contract amendment • Attachment GMP.DPS1.Q66.3_one-year capacity purchase.

Person Responsible for Response: Christopher Cole Title of Person: Director, Market Operations Date: June 20, 2017



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Please provide GMP’s twenty-year power supply plan selected in the 2014 IRP, showing resources added by year and the capacity provided by each resource.

DPS1.Q67. Chapter 7 of GMP’s 2014 IRP, Resource Plan and Portfolio Evaluation, includes a discussion of an Illustrative Preferred Plan on page 7-10. The resources and the capacity amounts that were added under this plan are summarized in the following table.

GMP 2014 IRP – Illustrative Preferred Portfolio

Table of Supply Additions

Resource Addition

Nameplate Capacity (MW)

In-Service Date

Hydro 100 MW 10-1-2016 Solar PV 25 MW 10-1-2016

Onshore Wind 80 MW 10-1-2016 Onshore Wind 75 MW 10-1-2019

Solar PV 55 MW 10-1-2019 Combustion

Turbine (peaking capacity) 100 MW 10-1-2020 Solar PV 100 MW 10-1-2031

Total 535 MW Source: 12._Sensitivity_Model_IRP_.xls, ‘1) Scenario_Setup_Dashboard’ tab

As noted in the IRP, the preferred portfolio was illustrative of the major portfolio themes and the types and magnitudes of resources for GMP to explore. That is, it was not intended to be a highly tuned course of action that GMP was committing to pursue.




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With respect to GMP’s 2014 IRP:

Please describe in detail the process used by GMP to select resources for the 2014 IRP, including the name of all simulation models used and the methodology used for the screening of potential resources;

What objective function was used to select resources in the 2014 IRP?; Please describe the methodology used to ensure that the 2014 IRP is a least-

cost plan.

a. GMP used a multi-attribute process to select resources for the 2014 IRP (see

Chapter 7 for a discussion). The process calculated 15 different attributes across four categories as shown in Table 7.4.3 of the 2014 IRP (page 7-23). The resources that were selected resulted in a balance between the portfolio’s cost, flexibility, emissions and renewable percentage. The simulation model that was used is a series of spreadsheets (featuring monthly peak and off-peak quantities of energy load and sources) that GMP also uses to estimate its power costs for the purpose of budgets and base rate filings.

b. Table 7.1 (page 7-2) lists the objectives of the IRP, and on page 7-11, the resource

acquisition strategy is described as follows: “Balance low cost and low carbon with three attributes that limit risk: diversity, flexibility, and reliability.” Stated another way, the objective function was to minimize the projected cost and carbon emissions of the portfolio while maintaining diversity, flexibility, and reliability.

c. The methodology that was employed in the IRP was a combination of multi-

attribute analysis and sensitivity analysis. As a result, the cost outputs are expressed across a range of outcomes (i.e., they are not single-point estimates). The preferred portfolio was developed by comparing the performance of the potential portfolios with respect to the attributes above (in their natural units - such as projected costs, GHG emissions, renewable fraction, etc.), and selecting a mix of resources that balanced low expected costs with relatively favorable measures for the other desired attributes.




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Please refer to Exhibit GMP-DCS-2. With respect to GMP’s 2018 power supply plan:

Please describe in detail the process used by GMP to select resources for the 2018 power supply plan including the name of all simulation models used and the methodology used for the screening of potential resources;

What objective function was used to select resources for the 2018 power supply plan?

Please describe the methodology used to ensure that the 2018 power supply plan is a least-cost plan.

a. The power supply resources reflected in the 2018 rate filing are overwhelmingly

the result of long-term supply commitments that GMP has made over many years, along with Vermont policy guidance and legislation. Much of GMP’s power supply is obtained from sources that were acquired in the past decade, most notably:

• The expiration of PPAs from Vermont Yankee, and the plant’s ultimate retirement, and the expiration of the long-term Vermont Joint Owners contract;

• GMP’s entry into a smaller long-term unit-backed purchase from NextEra Seabrook, and a subsequent contract modification to add substantial volumes of capacity and much smaller amounts of energy;

• GMP’s entry (along with other Vermont distribution utilities) into a long-term PPA from HQUS;

• GMP’s acquisition of new renewable sources that reached commercial operation (or were acquired) within the past five years – most prominently including Kingdom Community Wind; Granite Reliable Wind; several GMP solar projects; and GMP’s recent Enel hydro transaction (a mix of owned units and long-term PPAs); and bilateral PPAs from other new and existing renewable sources;

• PPAs for the output of numerous Vermont renewable plants through Vermont’s Standard Offer program;

• Vermont’s baseload renewable portfolio requirement, which ultimately resulted in a long-term contract for output of the Ryegate biomass plant; and

• Large growth in Vermont’s net metered generation fleet, which will soon produce energy comparable to more than five percent of GMP’s annual energy requirements.



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The rate year power sources also include significant volumes of fixed price bilateral market energy and capacity purchases – typically for terms of less than five years – that are designed to limit GMP’s exposure to short-term market price fluctuations. These purchases were negotiated over the past five years at prices that reflected then-current market prices.

The processes and models that GMP used to evaluate and select these resources depended significantly on the particular resources being acquired. For example, large and long-term resources (e.g., HQUS, NextEra) were evaluated using relatively detailed analyses that included probabilistic simulation of potential future market outcomes. These evaluations were assisted by outside consultants – for example, La Capra Associates (now Daymark Energy Advisors) using the Aurora regional market simulation model. Smaller resources were typically evaluated primary against the projected net cost (projected cost of power from a source, less market value/revenues for the products that that source provides) of competing alternatives (e.g., other new renewables that could potentially be used to meet Vermont’s SPEED requirements or RES requirements) in a base case market environment. Shorter term bilateral energy purchases were selected by competitive bid, subject to screening for reasonableness against then-current broker price indications and consultant-generated (e.g., ESAI, IHS) forecasts of future spot market prices.

b. The resources in the 2018 rate year were overwhelmingly selected to improve the performance of GMP’s power supply portfolio over multiple years – not for 2018 in particular. There was not a single objective function, because GMP’s resources were selected to meet different needs – and often multiple needs. For example, new renewables were evaluated based on their ability to meet GMP’s long-term needs for energy, capacity, and renewables (under the SPEED framework, and more recently under the RES framework). GMP’s Integrated Resource Plans have identified and discussed these needs, and identified appropriate types of resource for GMP to explore. But in general, the objective for these resources was to help GMP to meet the power needs of its customers at the lowest reasonable expected cost, while also meeting Vermont’s renewable requirements (SPEED, then RES) and addressing portfolio goals of price stability, diversity of supply, and low emission profile.

c. GMP’s power supply plan is not designed for 2018 independently. The resources that comprise most of GMP’s power supply portfolio were evaluated (e.g., in the course of obtaining a Certificate of Public Good) for cost-competitiveness relative



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to alternatives, and for consistency with GMP’s IRP and Vermont’s energy plan.




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Please refer to Exhibit GMP-DCS-12. Please identify the name and the vendor supplying the “model” mentioned in the heading of the exhibit.

The model mentioned in the heading of GMP-DCS-12 is the set of GMP’s spreadsheet models that together produce the projected power costs contained in this rate case filing. These files were created by GMP staff and were recently provided via e-mail to DPS staff John Woodward.




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Please describe all efforts by GMP to re-negotiate or buy out of expensive existing PPAs and joint ownerships.

First, it is important to note that the GMP supply portfolio is comprised of energy and capacity PPAs of varying volume and term, along with owned and jointly owned generating resources that are also diverse in size and technology. By design, this power portfolio reflects a range of costs that vary by technology and vintage, which together provide a stable, cost-competitive, and substantially renewable energy supply for customers.

Opportunities to obtain major value for customers by simply renegotiating or buying out an existing arrangement tend to be greatly limited by the fact that the relevant counterparties (for example, the seller under a PPA that has become above-market as market price expectations have declined over time) typically have access to similar information as GMP with respect to wholesale market conditions, and thus can be expected to have a similar view of the value to GMP (and cost to the counterparty) associated with buying out of the contract. GMP has not seen recent opportunities to revisit power plant joint ownership arrangements – in large part because in each case GMP is a minority owner in a larger plant. Nonetheless, within this approach to building a diverse power portfolio, GMP regularly reviews the resources that make up the portfolio for opportunities to provide value for customers – for example, in terms of lower expected cost, lower risk, addressing GMP’s open position needs, or smoothing fluctuations in expected power costs over time. Such opportunities have typically been explored for resources that feature relatively high costs and/or short remaining terms.

Recently, for example, GMP has renegotiated two system energy contracts (BP, Nextera) which were originally negotiated during periods that featured higher market price expectations than today’s opportunities for the remainder of the contract delivery periods. In these instances, GMP has been able to use a “blend and extend” approach to buy out the higher near-term cost and spread this short-term expense over newly executed and longer-term replacement purchases. In this way, GMP was able to fill a future open position need and smooth its power costs somewhat over time, without significantly altering the economic value in the replacement contract.



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GMP has also applied this approach to long-term, resource-based contracts when opportunities become available. In 2016, GMP was able to reduce the cost of a Solar PPA that was originally executed in 2014 with groSolar, which featured a project that had not yet reached commercial operation and the cost of development had decreased. Looking forward, GMP expects to evaluate similar buy out and renegotiation approaches within the portfolio of short-term capacity contracts. GMP is also exploring revising long-term generation-backed PPAs to adapt the scheduling provisions to better align with changes in the ISO New England market, in particular to address the “Do Not Exceed” or “DNE” framework that was implemented during 2016.




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Please refer to Exhibit GMP-DCS-12. Please describe in detail the development of the “Rate Year Power Costs” shown in this exhibit.

The energy prices contained in DCS-12 are indicative “forward prices” provided to GMP by the firm ICAP and dated January 27, 2017. A copy of the applicable tab from the file is attached as Attachment GMP.DPS1.Q72_Forward Prices.




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Please refer to Page 3, Lines 10–12 of the prefiled direct testimony of Mr. Smith. Please describe in detail the cause and development of the “increase in regional capacity costs” described in Mr. Smith’s testimony.

The increase in regional capacity costs is driven by a large increase in clearing prices that occurred in ISO-NE’s annual Forward Capacity Auctions (FCAs) 8 and 9, relative to FCAs 6 and 7 (which affected the cost of GMP’s capacity obligations in the test year), and associated changes in market expectations for those capacity delivery years. GMP is a significant net buyer of capacity (through bilateral contracts, and the FCA), because our committed long-term sources are sufficient to meet much but not all of GMP’s share of regional capacity requirements. As a result, an increase in FCA clearing prices (and the prices at which bilateral capacity contracts are available) tends to increase GMP’s net power costs (although not to the same degree that many other load-serving entities in the region will likely be affected). Pages 13 to 14 of Mr. Smith’s testimony discuss this dynamic.

The primary cause of the increase in FCA prices was the transition of the ISO-NE capacity market from a condition of significant surplus relative to the minimum Installed Capacity Requirement in FCA1 through FCA7 (with the annual FCAs typically clearing at an administrative floor price) to a more balanced condition (much less surplus) in FCA8 and FCA9. This transition from surplus to balance was driven largely by the withdrawal of several thousand MW of existing capacity – most notably the Brayton Point plant in Massachusetts, the Vermont Yankee plant, and some demand side sources – from the market. As a result, significant additional thermal power plant capacity (primarily gas-fired combined cycle plants) was needed to balance the market in FCA8 and FCA9, and the resulting clearing prices for the Rest of Pool zone reflected the bids of these new resources (i.e., over $7/kW-month in FCA8 and over $9.50/kW-month in FCA9) – more than double the floor-based clearing prices that prevailed in the preceding several auctions.




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Please refer to Page 3, Lines 12–17 of the prefiled direct testimony of Mr. Smith. Please describe in detail all efforts taken GMP to mitigate capacity expenses, as described in lines 12 through 17 on page 3 of Mr. Smith’s direct testimony.

Page 3 of Mr. Smith’s testimony was referring to these mitigation strategies:

• GMP’s power supply strategy, and its resulting portfolio of long-term supply sources, which cover a substantial fraction of projected future capacity requirements.

• GMP implemented a long-term bilateral PPA with NextEra Seabrook, LLC for 150 MW of additional capacity (and modest volumes of energy). This purchase was reviewed in PSB Docket 8445.

• Ahead of each of the recent Forward Capacity Auctions, GMP implemented several bilateral power purchase agreements for capacity (without associated energy), at fixed prices. Two of these transactions which included deliveries in FCA 9 (June 2018 through May 2019) turned out to be significantly lower than the clearing price of $9.55/kW-month. The volumes and timing of GMP’s bilateral capacity purchases were:

o 150 MW for delivery June 2018 through May 2019 (1 year). o 100 MW for delivery June 2018 through May 2021 (three years). o 75 MW for delivery in June 2019 through May 2022 (three years). o 75 MW for delivery in June 2020 through May 2023 (three years).

GMP’s other efforts to mitigate capacity expenses include:

• The management of existing responsive demand resources (through retail rate riders) that address end uses that include controlled electric resistance water heaters and various commercial and industrial end uses, along with energy storage resources (i.e., Stafford Hill storage, customer-sited Tesla Powerwall units) - with the goal of limiting GMP’s net load requirements during hours in which the ISO-NE annual peak demand could be established.

• Passive load management via mandatory and voluntary time-of-use (“TOU”) price signals. All large C&I customers and the largest residential customers have mandatory TOU prices. Some residential customers take service voluntarily from TOU rate schedules, and the Company in its last rate re-design introduced expanded opportunities for customers to sign up for dynamic demand response via Critical Peak Pricing rate schedules. Over 56% of the Company’s retail sales are made via TOU or dynamically responsive rate schedules.



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• GMP recently announced an innovative pilot offering under which customers may lease Tesla Powerwall 2 units for a limited monthly fee. GMP will have the ability to dispatch the units to reduce system peak loads for the purpose of limiting GMP’s capacity obligations (as well as to pursue other forms of wholesale power savings).

• GMP recently kicked off an innovative pilot offering under which uncontrolled water heaters may be equipped with controls that will be able to limit consumption during system peak loads (as well as pursue other forms of wholesale power savings).

• GMP has also been exploring options for utilizing cold climate heat pumps as distributed resources. While there is currently no technology on the market that is ideal in all respects, GMP is testing and working with vendors to make improvements to enable the control of more of the increasing number of heat pumps being installed in GMP’s territory, and shave system peaks.

• GMP is close to making available a Level 2 electric vehicle charging service that will enable GMP to manage these relatively large residential loads, and therefore ensure we are mitigating potential increases in capacity expenses.

Several other resources that GMP has procured during this period (e.g., Enel hydro transaction; bilateral PPAs for output of renewable generating plants) also contribute meaningfully to meeting or reducing GMP’s share of regional capacity requirement (and therefore mitigating exposure to potential FCM price increases), although they were not deployed solely for that purpose.




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Please describe in detail the methodology used to develop the contributions of wind and solar generation to GMP’s capacity obligation.

DPS1.A75. GMP’s existing wind resources (with the exception of three very small (100 kW) units that GMP owns) are ISO-registered generating assets. As such, for Kingdom Community Wind, Searsburg, and Granite Reliable Wind, there are existing qualified capacity ratings, determined by ISO-NE, that GMP assumes will continue to apply in 2018. These monthly values are reflected in GMP’s capacity model. For the new Deerfield Wind project, which is assumed to achieve commercial operation before the rate year, we have assumed 10 MW of credit for all months, representing about one third of the plant’s nameplate rating.

All solar generation contained in rate case power costs is so-called behind the meter generation – that is, projects that are located behind the retail meter (in the case of many net metered generation projects) or “load reducer” projects that deliver output into GMP’s distribution system but are not ISO-registered generators. As such, capacity value from these sources is determined by the sum of generation in the hour of the ISO-NE annual peak load. The projected peak hourly generation depends on 3 factors: MW of installed solar generation, the hour of the annual peak load (e.g., hours late in the day have less generation potential than those in early afternoon), and the temperature and cloudiness existing in the peak hour (e.g., more clouds and high temperatures reduce output). GMP used a probabilistic approach to projecting total solar generation in the peak hour. Attachment GMP.DPS1.Q75_Solar Contribution reproduces portions of 2 GMP power model files and explains the calculation of solar contribution for the June – December 2018 capacity requirement periods, based on the summer 2017 ISO peak load. The following are additional details that affect the capacity value of distributed solar generation: • GMP’s share of regional capacity requirements for each FCM delivery year (June through May) is determined by its share of the ISO-NE peak load from the prior year. Therefore, the requirement for January to May of 2018 will be based on the 2016 ISO-NE peak hour load, which is estimated based on GMP’s 672 MW ISO-settled load and thus includes actual solar benefit achieved in that hour (August 12, 2016, hour-ending 15). Similarly, the requirement for June to December of 2018 will be based on GMP’s share of



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the 2017 ISO peak hour load, which will likely occur between June and September 2017. • Capacity requirements are determined based on load measurements at the transmission level, which include losses on the distribution and non-PTF transmission system. Since a substantial portion of solar generation is located near load, we have grossed up the peak-reducing value of new solar to include assumed loss savings. Finally, by reducing GMP’s load at the time of the ISO-NE peak, distributed generation including solar reduces GMP’s share of the regional Installed Capacity Requirement (ICR) – which includes a significant reserve margin above the regional peak load. Thus, in estimating the contribution of additional solar to reducing GMP’s capacity obligations, GMP has also included capacity reserve margin benefits on the increased solar volumes based on estimated capacity margins (measured relative to the annual coincident peak load) of 39% and 38% for FCA8 and FCA 9 margin, respectively, times the GMP solar volume increases. These reserve margins are consistent with the actual relationship between ISO-NE’s ICR and actual peak loads observed in recent years.




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Please describe in detail and provide all work papers for the methodology used to develop the energy and capacity contributions from net metering in the Rate Year.

Pages 15 through 23 of Mr. Smith’s testimony discuss in some detail the net metered volumes and associated costs that are reflected in the rate year power costs, and how they were developed. The following are key points with respect to the energy and capacity contributions. As an overview, net metering volume in GMP’s territory is in the midst of an extraordinary growth phase. The amount of net metered capacity in the rate year can be viewed in three groups:

• Projects that were installed in GMP’s service territory through 2016, and therefore were online for all or part of the test year; • Projects that were accepted through 2016 under then-current program rules but have not yet been completed; • Projects that will apply from 2017 forward under new program rules and be commissioned before or during 2018 (“NM2.0” projects). Total net metered generation for the 2018 rate year is projected at about 240,000 MWh, compared to about 113,000 MWh in the 2016 test year. The growth in net metered generation is attributable primarily to projects that have been completed since the start of the test year (so the test year volume includes only a partial year of their output, or none at all) and to assumed completion of projects that have already applied for interconnection. About 20 percent of the net metered generation reflected in the rate year power costs is associated with projects that GMP assumes will apply for interconnection from January 2017 forward, and be completed before the end of 2018. Mr. Smith also noted that based on historical trends, approximately one third of all NM energy production is assumed be used by the customer (reducing monthly retail electricity sales). The remaining volume would be booked as excess net metered production on a monthly basis, and sold to GMP (at a price similar to the average price a residential customer normally pays), which would use this energy to supplement its other energy supply sources.



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Attachment GMP.DPS1.Q76.1 shows installed kW and energy production in 2015 and 2016, and projected up through the rate year and beyond, by customer type and whether used or excess. The following are key assumptions that were used to develop the rate year net metered generation volumes reflected in the attachment: • In total, about 56 MW of additional net metered installations are assumed in 2017, and 55 MW in 2018. • This assumes that the queue of about 56 MW of projects that applied prior to 2017 will be completed over 2017 and 2018. • We assume that an additional 25 MW of NM2.0 projects will be built in 2017, and 30 MW in 2018. This pace of new net metered project development is within the range of the pace for applications and completed projects in recent years, and the prospect for significant ongoing net metered installations is supported by a declining trend in solar PV capital costs (which, all else equal, tends to improve the economic attractiveness of projects). This pace of new net metered projects is, however, far below the pace of installations in 2016, and would represent a significant reversal of the consistent upward trend in net metered installations in GMP territory since 2012. Please refer to Attachment GMP.DPS1.Q76.2 for the context of annual application and installation rates. • The pace of installation for these volumes of new net metered capacity was assumed to be roughly linear over the course of the year, except for a pronounced burst of projects completed near the end of each year. This pattern (which is reflected in the monthly quantities in Attachment GMP.DPS1.Q76.1) is consistent with project completion rates observed in the past several years. • Annual energy output for the net metering fleet reflects an average net capacity factor of 14.5 percent.

Person Responsible for Response: Douglas C. Smith; Charles Watts Title of Person: Director, Power Supply; Power Supply Analyst Date: June 20, 2017



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Please describe in detail and provide all work papers for the methodology used to develop the energy and capacity contributions from solar and wind facilities in the Rate Year.

With respect to wind facilities:

• GMP used a detailed wind study (by hour by month) to project Kingdom Community Wind’s generation, consistent with the values that were assumed in the original evaluation of the plant.

• For Granite Reliable Wind, GMP used the results of a study providing monthly capacity factors with on- and off-peak shares of production, which was reduced to yield annual output that is similar to historic production values.

• Annual Searsburg generation is based on its average for the last five years, 2012 to 2016.

• The shape of Deerfield’s modeled output is based on an hourly profile provided by Iberdrola.

• The capacity factor profile information for these sources is contained in Attachment GMP.DPS1.Q77.

• As noted in Response 1-75, rate year (FCM) capacity values for these wind plants are assumed to equal recent/current values, except for Deerfield which is assumed to have a 9.9 MW average capacity value. With respect to solar installations:

• Energy output is generally based on a 14.5% annual capacity factor assuming the AC (inverter) rating equals its DC (panel capacity) rating. For “overbuilt” installations - where the DC rating is higher than the AC rating - the capacity factor would be increased by the DC/AC ratio.

• The capacity factors used for the GMP Solar projects were project-specific (based on siting, panel size, panel tilt, and other factors), the same values presented in each project’s Certificate of Public Good docket.

• As noted in Response 75, all the solar projects are load reducers (not ISO-registered capacity resources). Capacity contributions from these projects are therefore based on a probabilistic estimate of solar output in the hour of the ISO-NE’s annual peak load, adjusted by the assumed impact of peak hour losses and the regional capacity reserve requirement.

Person Responsible for Response: Charles Watts



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Title of Person: Power Supply Analyst Date: June 20, 2017



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Please describe in detail and provide all work papers for the methodology used to develop the energy and capacity contributions from hydro facilities in the Rate Year.

GMP uses a 20-year average approach to estimating its hydro generation for the rate year (as a normalizing adjustment). These data were adjusted for a few discrete projected changes in output, most notably the Proctor and Huntington units where upgrades were recently completed. These data are contained in the excel file “4._Owned_Resources_2018_RC”, which was previously provided to the DPS. The output for each of the recently purchased Enel units is a unit-specific estimate based on information reviewed during the acquisition process.

With respect to capacity, GMP’s hydro sources are ISO-registered generating assets. As such, capacity ratings are based on ISO report values which GMP assumes will apply in 2018. Attachment GMP.DPS1.Q78 contains the projected rate year values.




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The following questions concern the model utilized by the Company to develop Rate Year power supply costs:

How does the model simulate the dispatch of GMP resources? How does the model account for forced outages of resources? How does the model account for transmission limitations?

a. The matching of loads, resources, and energy market prices is conducted in the model on a monthly basis, in peak and offpeak periods. Projected output from each energy resource is based either on its contractual or historic values, which are split into on-peak and off-peak periods, based either on contractual terms or an estimate of the on-/off-peak split of the unit’s output. For instance, a base load plant dispatch (such as the Seabrook nuclear plant) would assume the same level of hourly output across the month and allocate the output by the number of on- and off-peak hours in each month while a plant such as McNeil assumes full operation during on-peak hours and the remainder of the total projected volume as off-peak. Fossil-fired units that typically operate in a peaking mode (combustion turbines and diesel units, Wyman Unit 4, Stony Brook) are assumed to operate infrequently and only during on-peak hours. Any energy needs or excess energy for each monthly peak/offpeak period is assumed to be bought or sold through the ISO-NE spot market (i.e., day ahead and/or real-time markets).

This hourly energy model structure captures the vast majority of the seasonal and diurnal variance in the cost of purchasing GMP’s energy requirements and the revenue that GMP receives for the energy output of its generating sources (e.g., relatively high prices during peak hours of winter months, and much lower prices during off-peak hours in shoulder months). Nonetheless, ISO-NE spot market pricing can sometimes vary strongly on an hourly basis within these periods, and there is some degree of unfavorable correlation between GMP’s hourly open position and market prices (e.g., on a cold winter day when GMP customers tend to consume more electricity than average, hourly LMPs in the ISO-NE market will also tend to be somewhat higher than average). These outcomes are all reflected in GMP’s ISO-NE settlements and actual test year net power costs, but would not be fully captured in the monthly peak/offpeak model that uses simple average prices for those periods. GMP therefore performed an analysis of its actual 2013-2016 net ISO transactions to estimate the true net annual cost associated with settlement of these loads and sources, relative to using average



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monthly on- and off-peak prices. For the rate year, the additional net energy cost (reflecting effects on both GMP’s load obligation and generation sources) is estimated at $2.41 million; this is the ANI Adjustment line on Exhibit DCS-2.

b. For most resources, the model does not explicitly represent forced outages. The primary reason for this is that a substantial fraction of GMP’s supply (e.g., HQUS long-term PPA, and most bilateral energy purchases) is delivered on a firm basis, and is not contingent on the output of individual generating units. For smaller sources, the historical volumes used for forecasting the rate year generally contained forced outages, and there is also a significant amount of diversity across those sources (limiting the net impact of individual outages). The two nuclear-based sources (NextEra Seabrook PPA, Millstone 3 joint ownership) are relatively large and can have more noticeable outage effects, so specific forced outage rates were assumed for these sources: 3.0% at Seabrook and 2.1% at Millstone 3 (based on 2012-2015 average).

c. The primary impact of transmission limitations on GMP’s net power costs is typically through the congestion component of Locational Marginal Prices; these congestion charges apply to GMP’s load and its generating sources, and they can be positive or negative. Congestion charges are estimated as a net cost of $1.55 million in this filing, based on the historical congestion costs (as a percent of LMP) that were observed during the test year. In almost all cases, physical limitations are not assumed in the projected energy volumes unless such limitations have affected meaningfully historic production volumes. Most notably, the test year output of the Kingdom Community Wind plant was noticeably reduced at times due to transmission congestion in northern Vermont. GMP is presently seeking solutions to reduce or eliminate the loss of generation due to congestion, and did not reflect such reductions in output in the rate year power costs.




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The following questions concern the model utilized by the Company to develop the 2014 IRP.

How does the model simulate the dispatch of GMP resources? How does the model account for forced outages of resources? How does the model account for transmission limitations?

a. The IRP model simulates the dispatch of GMP resources using an historical average of monthly capacity factors (or forecasted capacity factors, for new resources or those for which the historical period may not be representative) for each resource, and a breakdown of the resulting output into peak and off-peak generation for each resource. The model used here was a series of spreadsheets that is essentially the same as those that GMP uses to estimate net power costs for use in base rate filings and power adjustor benchmarks.

b. The IRP model accounts for forced outages implicitly through the assigned average capacity factor of resources. When the historical forced outage rate increases, the historical average capacity factor decreases.

c. The IRP model accounts for transmission limitations through the historical average capacity factor. When the historical level of transmission limitations increases, the historical average capacity factor decreases. The IRP modeling did not explicitly account for congestion differences between locations of potential future resources. GMP determined that this was appropriate in the IRP context since the primary focus of the portfolio evaluation was portfolio goals and composition (e.g., types and amounts and timing of resources to explore), as opposed to the evaluation of specific potential resources.




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Please provide the following for each operating Joint Venture MicroGrid

(“JV Microgrid”):

a. The location; b. The electric utility operating; c. The date on which the JV MicroGrid initiated operations d. The capital cost.

There are no currently operating JV MicroGrid projects. GMP proposes to construct three JV MicroGrid projects to enter service during calendar year 2018. The status of these projects is also discussed in Response 84.

Person Responsible for Response: Kirk Shields Title of Person: Director of Development and Risk Management Date: June 20, 2017



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DPS1.Q82. Please explain GMP’s reasoning in developing three JV MicroGrids simultaneously rather than completing one such project to prove the worth of the projects.

The strategy behind developing multiple projects is designed to provide the best value to customers with limited scope and incremental development. The projects are relatively small given GMP’s overall customer loads, so gaining enough scale across different system locations, each having different load and system characteristics, contributes to lower-cost projects and provides information to determine what works well in a certain area of the system and what can be improved in terms of system operations, and load and peak reductions. Specifically, factors we considered in adopting a development strategy are:

1. Project size and volume are key considerations for tax investors. Tax investors look for reasonably sizable transactions in which to deploy capital in order to minimize transaction costs for structuring the investment. Multiple projects help provide such scale from the tax investor perspective.

2. Investment Tax Credits (ITC) of about 30% of each project’s capital cost is available to be monetized on behalf of customers which provide meaningful savings for customers. The ITC applies to both solar and battery components of the project, further leveraging the capital needed to develop the battery. The ITC is scheduled to decline beginning in years after 2019, so a 2018 development timeline harvests significant tax savings for customers ahead of the ITC decline.

3. The prospect of doing multiple projects helps to attract vendors who can use economies of scale to offer low prices.

4. GMP expects to earn a significant developer fee from the three MicroGrid projects of approximately $2,500,000 that will flow directly and completely to customers as a rate reduction strategy. When each project is completed, its value of a constructed project (fair market value) is much higher than the sum of its parts, which raises the amount of eligible ITC for the project. The difference between fair market value and cost can be returned to the developer, GMP, in the form of a developer fee for taking the risk of investing time and effort in successful project development. That developer fee flows directly and completely to customers in 2018 as a rate reduction.



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DPS1.Q83. Please provide all executed agreements concerning the JV MicroGrids.

To date, we have executed two (2) options to lease, and one (1) option to purchase, property for the projects. In addition, we have executed a Limited Scope Retention (LSR), and a subsequent extension of the LSR, with groSolar for initial development work including identifying appropriate sites. Other agreements are being developed for engineering, procurement and construction services for both the battery and solar components of the project. In addition, a System Impact Study agreement has been executed between the Hartland project company and GMP. These documents are provided as Attachment GMP.DPS1.Q83.1 through Attachment GMP.DPS1.Q83.5.




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DPS1.Q84. Please describe the current status of each JV MicroGrid.

Simultaneously with the development work that has been done to date for the proposed Hartland, Weathersfield and Newbury MicroGrid projects, GMP has continued identifying additional sites in order to select economic project sites with the highest chance of successful development for our customers. GMP strives to maintain some flexibility to select the best sites for customer projects and ultimately file CPG applications for the best sites of those identified. As part of the typical development cycle for projects, siting, development, and evaluation continue to be ongoing initiatives as GMP has committed to delivering 3 MicroGrid projects for customers as part of our overall rate reduction strategy.

To that end, we currently have 8 sites that are under evaluation and early development. Among them are three currently proposed MicroGrid projects in Hartland, Weathersfield and Newbury. In Hartland, an option to lease has been executed with the Greater Upper Valley Solid Waste District which owns the property. A system impact study is underway, CPG application materials have been assembled and the petition is being completed. There is potential for interconnection-related energy flow limitations at this site which are being studied and project suitability will be informed by the SIS. An option to lease property in Weathersfield has been executed with the landowner. The interconnection application is being developed and site layout alternatives are being evaluated. Vernal pools on the site may ultimately limit the size of a project that can be developed on the site. An option to purchase property in Newbury has been executed with the landowner. Interconnection viability is in question at this site and an alternative site may take its place in the development pipeline. There are 5 additional sites that have high potential and are being actively evaluated in Chittenden, Windsor, Caledonia, and Addison counties. Site control is being obtained and site feasibility is advancing rapidly.



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DPS1.Q85. Please provide GMP’s cost-benefit analysis for each of the JV MicroGrids.

The original cost benefit analyses are provided for the projects in Hartland,

Weathersfield, and Newbury as Attachment GMP.DPS1.Q85.




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DPS1.Q86. Please provide a breakdown of the benefits accruing to GMP’s equity

partners and GMP’s ratepayers, from the JV MicroGrids.

As the question implies, there are numerous and valuable benefits that accrue to customers, financial and otherwise. Similarly, financial benefits accrue to the tax partner as an inducement to make an investment in the project and which investment also creates financial benefits for our customers. Benefits accruing to GMP customers include:

1) Return of projected $2.5M developer fee

As described in Q82, GMP expects to earn a significant developer fee from the three MicroGrid projects of approximately $2,500,000 that will flow directly to customers as part of an overall retail rate reduction strategy.

2) Return of projected Day 1 Gain / Equity in Earnings of $7.75M

The tax equity partner’s ability to monetize and take the ITC as a tax deduction in the year the JV MicroGrids are placed in service creates a significant Day 1 Gain for GMP of about $7.75M. That Day 1 Gain is immediately returned to customers as a credit against GMP’s cost of service. To explain, Hypothetical Liquidation at Book Value (HLBV) accounting calculates the book income or loss that each partner would receive if the partnership were liquidated, and GMP will book a significant gain as net income after the partnership is fully funded.

3) Since both the solar and the battery storage components of the project are eligible for federal Investment Tax Credits (ITC) of about 30% of eligible capital costs, customers will have the benefit of the completed project at a significantly reduced cost. The tax partner will harvest the tax attributes and contribute about $15.3M of capital to the project in return for receiving tax attributes. The $15.3M of capital provided by the tax partner does not go into ratebase and is a cost savings to customers relative to the overall project capital budget. Making efficient use of the ITC in this way immediately lowers project costs on behalf of customers since the capital investment is made by the by tax investor rather than amortizing the ITC



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over the life of the project by GMP and forfeiting the time value of money.

4) With the ever-deepening penetration of distributed generation on the electric system, GMP endeavors to develop the capability of enhancing customer reliability through distribution circuit islanding during extended outages. Improving customer service reliability is a key goal that islanding will help achieve with the solar and battery storage solution.

5) Additionally, this project will strive to lower GMP’s cost of power through peak shaving (i.e. reduced capacity, transmission and ancillary services costs) for monthly and annual peaks. Peak load shaving can provide significant savings for customers since many regional market and transmission related costs are allocated to GMP based on our pro rata share of load relative to the New England load. Every MW saved through peak reductions saves money for customers. The value of these load reductions are estimated to be about $314 per kW/year as calculated in the cost benefit analysis provided in Response 85.

Benefits accruing to the tax equity partner include:

1) ITC and tax expense savings of about $11.5M

2) Cash distributions of net income of about $2.5M

Person Responsible for Response: Edmund Ryan, Kirk Shields, Karen Young Title of Person: Controller, Director of Development and Risk Management, Budget/Forecast Supervisor Date: June 20, 2017



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DPS1.Q87. Please provide GMP’s policies and procedures governing capitalizating vs. expensing items.

Please see Attachment GMP.DPS1.Q87, which is the Capitalization Policy that is in place. The procedures that govern all spending whether capital or expense originate from our annual budget and forecast process. Once the annual process is complete, approval is received and operational managers are responsible for managing their approved budget throughout the year. Internal controls related to all expenditures including purchases, expenses and employee time ensure that managers have transparency into all costs. Monthly management meetings are used to monitor and manage both capital and expense costs and for each manager to provide variance explanations if needed.




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DPS1.Q88. Please describe the linkage between GMP’s capital and operating budgets.

Based on guidance from the DPS, GMP understands this Request to be seeking how expenses are allocated between capital and expense. Answering based on this understanding, all capital projects are assigned a project number in Oracle. If an individual works on a specific capital project, they must input the project number and those hours directly on their time report. They must also code all of their remaining hours to the appropriate categories such as operations, vacation, rest-time, storms etc. It is normal practice for individuals such as our line crews to record their daily work time at the end of the shift. All hours are accounted for and the weekly time sheet is reviewed by their direct supervisor. Payroll then has many checks and balances within the payroll process to account for all hours posted. Similarly, the costs of all equipment and materials used for each project are attributed to it.




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DPS1.Q89. Please provide the long-term plans that guide the capital programs for GMP’s:

a. Communications department; b. IT department; c. Facilities department; d. Transportation department.

GMP does not maintain formal long-term plans for each capital department, but has the following guiding objectives to inform our thinking on capital projects to benefit customers in each department:

a. Communications department: GMP has expanded the reach of connectivity that exists across its operating facilities over the past decade. Because of our expanding connectivity, we are able to operate facilities and processes differently than we were able to prior to the work the communications department has done. Initially, our focus was on connecting GMP district offices. Then our work expanded to significant operating facilities such as large substations and generating plants. More recently, our work has been focused on smaller, more remote facilities such as distribution automation devices, smaller substation and generating facilities, surveillance applications and even load devices that exist behind the meter in customer settings. Our vision of a fully distributed grid depends on connectivity and intelligence existing parallel to our energy network. The communications department expands and manages that connectivity.

b. IT department: connectivity requires well-tuned systems to be in place to manage, monitor and transform the data that moves around the enterprise. At a high level, the IT department takes all of the transactional-level data and events that occur throughout our operations (as well data and events that exist outside of our operation) and makes them usable and useful to ourselves, our customers and our stakeholders. It is fair to say that our IT function has the most challenging charter in these times since they not only have to stay ahead of a fast-paced technology curve, but they also have to anticipate how our operational departments, customers and other users will be seeking to use technical advances and apply them to their specific objectives.



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c. Facilities department: for the past several years, the facilities department has been focused on creating safe and productive work environments for all GMP employees that are consistent with GMP culture for communication, transparency and collaboration. Since the merger between GMP and CVPS, this group has been busy consolidating and transforming company spaces to save money and bring a consistent employee experience across our locations. The majority of that work is now complete and there is a renewed focus on sustainability and continuing to improve the energy and environmental performance of our facilities through a focus on electricity, fuel, water and waste reductions.

d. Transportation department: the planning objective of transportation is to maintain availability of the right mix of vehicles to provide safe, reliable transport and work support for our employees across all the activities of the company. The past few years, the focus has been on reducing the ratio of vehicles to employees as we right-sized post-merger as well as creating flexible standards for the configuration of our more technical vehicles like line trucks, power production vehicles, electrical maintenance vehicles, etc. We believe our right-sizing and standardization efforts are behind us and that we are operating a more appropriately sized fleet that is lower cost to support and operate. Going forward, we will continue to focus on the greening of our fleet through investment in electrification, green fuels and other emerging fleet opportunities. As well, a focus on increasing vehicle utilization rates will be a priority for the transportation department.

Person Responsible for Response: Matthew Haley, Mari McClure, Brian Otley Title of Person: Supervisor of Operations Accounting; VP, Chief Talent & Support Operations; Senior VP & Chief Operations Officer Date: June 20, 2017



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DPS1.Q90. Please describe linkage and processes in place to ensure that the long-term plans are consistent with the GMP strategic plan for the:


The GMP team is continually monitoring priorities and strategic alignment of our projects and operating activities each week as a leadership team and then again at least twice per month at the operating team level. Our culture of frequent, concise communication, which is at the heart of how we operate, is supported by our workspaces, which are open, less formal and transparent.




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DPS1.Q91. Please describe linkage and processes in place to ensure that the capital programs are consistent with long-term plans for the:


DPS1.A91. Please see Response 90.




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DPS1.Q92. Please describe the capital project prioritization scheme for the: a. Communications department; b. IT department; c. Facilities department; d. Transportation department.

DPS1.A92. As described in my prefiled testimony, GMP uses a consistent prioritization method across capital departments. Specifically, as described on pages 5-7, GMP assigns potential capital projects by a “must do,” “should do,” “would like to do” designation, including all projects in the communications, IT, facilities, and transportation departments. This simple method is consistent across capital department process. Please see Response 29.




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DPS1.Q93. Please describe the manner by which the capital prioritization schemes enable projects to be ranked and compared to other projects for the:


Each year we work to develop a healthy balance of projects to invest in on behalf of our customers. By balance, I mean across departments, across operational functions, across short- and long-term horizons. The prioritization method, described in response to Response 92 above, helps us to manage some of that balance. It is not intended to produce a ranking necessarily (although each project is assigned one of the three categories of “must do,” “should do,” and “would like to do”). Rather, it is intended to focus our decision-making on the most critical projects, obviously, but also be a check that we’re not neglecting strategic opportunities too much for the sake of tactical needs or vice versa. It can be easy to get consumed with a narrow type of project in any given time period. Our prioritization method is a simple way we try to check our decision-making against that risk.




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DPS1.Q94. Please referring to Exhibit GMP-BO-1. Please provide the prioritization by year for each project, showing the ranking of each project within the:

a. Communications department; b. Facilities department; c. IT department; d. Transportation department.

GMP does not assign specific prioritization rankings to its capital projects beyond assigning one of the three categories of “must do,” “should do,” and “would like to do.” See Response 92. We do not assign department specific-project rankings against one another. We focus on which projects are most important for customers in the coming year.

Person Responsible for Response: Matthew Haley, Mari McClure, Brian Otley Title of Person: Supervisor of Operations Accounting; VP, Chief Talent & Support Operations; Senior VP & Chief Operations Officer Date: June 20, 2017



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DPS1.Q95. Please refer to Exhibit GMP-BO-1. Please provide the ranking for each project, within:

a. Interim 2017; b. Rate Year 2018.

Please see Responses 29 and 37.




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DPS1.Q96. Please refer to Exhibit GMP-BO-1. Please describe the process or methodology in place that ensured that project prioritization schemes in the list of Interim 2017 and Rate Year 2018 capital projects were followed in a consistent manner for the:


Please see Response 94.




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DPS1.Q97. Please refer to Page 9, Lines 4–6 of Mr. Otley’s prefiled direct testimony and Exhibit GMP-BO-1. Please provide the categorization (construction, blanket, or retirement) of each project listed in the Interim 2017 and Rate Year 2018 schedules.

Please see Attachment GMP.DPS1.Q97. A column has been added to Exhibit GMP-BO-1 labeled classification to categorize each project.




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DPS1.Q98. Please explain how capital project performance (e.g., schedule and budget variances, change orders, operational savings achieved, customer service improvements achieved, and kilowatt hours saved) is measured for the:


Please see Attachment referenced in Response 39.




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DPS1.Q99. Please provide the results of the performance evaluation for each of the 2016 capital projects for:


Please see Attachment referenced in Response 39.




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DPS1.Q100. Please explain how capital projects are scoped and defined for the: a. Communications department; b. Facilities department; c. IT department; d. Transportation department.

Objection. GMP reasserts General Objection 3, as the question is duplicative of Questions 89-98. Without limiting or waiving the foregoing objection, GMP responds as follows.

Question 9 of Mr. Otley’s prefiled testimony describes the way capital project budget scope and in-service date estimates are developed. This process is consistent among GMP’s capital departments.




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DPS1.Q101. Please explain the nature or type of justifications (beyond manager or engineer opinions) that may exist for proposed capital projects for the:


Please see capital folders identified in Response 12.




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DPS1.Q102. Please refer to Page 7, Lines 13–18 of Mr. Otley’s prefiled direct testimony. Please provide the “draft list” of all projects proposed for the Interim 2017 and Rate Year 2018 capital budgets, including their preliminary business justification and estimated cost and schedule for the:

a. Communications Department; b. Facilities Department; c. IT Department; d. Transportation Department.

Draft lists are not maintained as distinct artifacts in our process. Draft lists undergo several revisions, many of them informal, until each department has a list of proposed projects that is worthy of discussion and assessment by the capital team. These draft lists and projects evolve during the early process of building our capital plan, and therefore we do not maintain original drafts.




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DPS1.Q103. Please refer to Page 7, Line 18 of Mr. Otley’s prefiled direct testimony. With respect to the GMP capital work group referenced by Mr. Otley in his testimony, please:

a. Provide a list of the members of the capital work group that reviewed the draft list of projects proposed for the Interim 2017 and Rate Year 2018 capital budgets;

b. Provide a description of the review process; c. Provide the output of the review process.

a. Our capital work group does not have a formal membership list. The core

leadership members who are responsible for capital process include:

Brian Otley, Dawn Bugbee, Mari McClure, Josh Castonguay, Mike Burke, Betsy Bloomer, Mark Dincecco, Matt Haley, Jason Lisai, Chrissy Scheck, Cathy Petrini, Zach Casey, Ken Couture, John Voyer and John Fiske.

b. The capital review process is described in Mr. Otley’s prefiled testimony, pages 5-8.

c. The final outputs of our capital review process are the capital project folders that we submit for regulatory review as part of our rate filing.




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DPS1.Q104. Please refer to Page 18, Line 15 of the prefiled direct testimony of Mr. Otley. Please explain how field-based surveillance helps GMP provide a safer working environment for customers?

GMP has been increasing the number of sites that it surveils over time. This includes power production facilities, substations and other critical sites. For example, GMP has and continues to install surveillance equipment (cameras) at hydroelectric projects to improve public safety, dam safety and GMP field personal safety. This undertaking is consistent with FERC’S Owner’s Dam Safety requirements and GMP’s site specific Dam Safety Surveillance and Monitoring Plans. GMP has also installed surveillance equipment at PSB regulated dams based on internal risk assessments. Surveillance is especially important at high hazard dams, projects with remotely operated turbines/flow control gates and where the public has access to the downstream waterway. Surveillance also provides additional situational awareness for GMP staff in day-to-day operations and Control Center Operators by improving operation efficiency and highest and best use of field personal for response to trouble calls. Each year we have a number of events where the general public may try to gain inappropriate access to these facilities, either intentionally or unintentionally. By having surveillance in our control centers, we are sometimes able to intervene in these situations to prevent a possible bad outcome.

Just last week, our surveillance at our Essex hydro facility showed system operators that two people had entered the downstream area below the dam, ignoring posted signs warning of potential hazards. Our operators were able to gain the assistance of Essex police to help alert the people of their error and escort them from the area. This is but one example of how our increased surveillance is improving customer safety. We had a similar recent event involving youngsters in Milton, where a couple of people climbed over a fence and were trespassing below a major spillway, an extremely dangerous action. This also came to our attention thanks to video surveillance. Absent such surveillance, public safety risks would be considerably higher.




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DPS1.Q105. Please refer to Page 9, Lines 9–18 of the prefiled direct testimony of Mr. Otley and Exhibit GMP-BO-1. Please provide the project justification; the set of assumptions for internal labor and O&M expenses; the quantitative financial analysis explaining cost drivers; support for the appropriate timing; and description of alternatives identified for projects:

a. 148580: O&M Security Cameras OH; b. 153692: Increased Meter Inventory; c. 153486: 2018 OC3 Node Replacement; d. 143630: Montpelier Renovation; e. 148735: Colchester Roof; f. 143539: Purchase Land for Burl Sub; g. 148522: 2017 Server Replacement; h. 153503: 2017 Ent. Storage Infrastructure; i. 148501: 2017 EBS Upgrade & Enhance; j. 148494: 2017 IT Blanket; k. 153502: 2018 Server Upgrades; l. 153492: 2017 Enterprise Video Conf. Sys.; m. 148958: 2017 Bucket Trucks; n. 153774: 2018 Small Vehicles; o. 153765: 2018 Digger Replacements.

Please see the individual project capital folders, which include the financial analysis completed for each project. Each capital folder will include project justification, assumptions used, financial analysis and any alternatives considered.




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Power Supply

DPS1.Q106. Please describe in detail the methods and processes that GMP used to project deployment levels and renewable energy credit (“REC”) disposition decisions for the net-metering program for the rate year? Please provide copies of any underlying documentation or spreadsheets in native Microsoft Excel format that GMP has in its possession in support of the response.

The development of Net Meter generation volumes is addressed in detail in Response 76. The primary basis for the assumed volumes is completion of the queue of net metering projects that have applied for interconnection, along with an assumed pace of new applications from 2017 forward under the pricing and terms of the new net metering rules (“NM 2.0”).

Under the net metering rules that applied to projects that applied for interconnection through December 2016, net metering participants were not required to transfer RECs to GMP in order to receive solar adder payments. As a result, the REC volumes from such projects that have been transferred to GMP have not been meaningful. In contrast, new net metered projects starting in 2017 will have a substantial incentive of 6 cents/kWh in adders (the difference between a negative 3 cents/kWh adder and a positive 3 cents/kWh adder) to transfer their RECs to GMP, and our rate case assumption is that all new projects will do so. Specifically, it is projected that there will be 52,569 MWh of NM 2.0 generation in the rate year, and we assume that all of the associated RECs will be used to help meet GMP’s RES Tier II requirement. Please see excel file “9._REC_Model_2018_RC” tab “RES Calcs” line 64 (this file was recently provided via email to Department staff member John Woodward).




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DPS1.Q107. Did GMP assume an attrition rate for net meter applications in its interconnection queue?

a. If so, what is that rate and why? b. Please provide any underlying documentation or spreadsheets in native

Microsoft Excel format that GMP has in its possession in support of the response.

Yes, GMP accounted for about 3 MW worth of attrition, reflecting net metering projects that applied for interconnection and subsequently withdrew their applications. GMP did not assume an additional attrition factor for “Net Metering 1.0” projects because so few applicants had withdrawn to date, and the economic incentives for project completion appear strong (based on the favorable available payment rates and other terms, along with the prospect that solar project capital costs could decline since the projects applied).




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DPS1.Q108. With respect to the Deerfield Wind project: a. Please describe the basis for the anticipated production from the Deerfield

facility and provide any relevant supporting documentation for this production estimate (e.g. Exhibit GMP-DCS-17 “Rate Year Power Contracts” line “Deerfield PPA 3 – Production MWh”);

b. Please describe in detail any capacity benefit for GMP derived from the Deerfield Wind PPA.

c. Please provide a copy of GMP’s Deerfield Wind PPA;

a. Please see excel file “2._LT_PPA_Resources_2018_RC”” tab “Deerfield” for its

Iberdrola-generated production capacity factor estimate table (by month, by hour), which was recently provided via email to DPS staff John Woodward. The final rate case volume is 96,914 MWh/ year, which represents about a 36.9% capacity factor based on 30 MW installed.

b. It is assumed in the rate filing that Deerfield will receive 9.9 MW of average FCM capacity credit.

c. Please see Attachment DPS.GMP1.108.




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DPS1.Q109. With respect to the McNeil plant, please provide data for the rate year regarding the following:

a. Fuel cost projections; b. O&M and any anticipated upgrade costs; c. Any energy and capacity revenues received by GMP from ISO New England.

a. The rate year McNeil fuel price was projected at $66.31/MWh based on a $63.41

average test year (2016) price, escalated at 2% per year (Oct-Sept).

b. The rate case was filed using a Joint-owned (“JO”) generation O&M of $6.55 million representing the 2012 to 2016 five-year average. The test year amount for each JO unit (including McNeil) was adjusted downward by approximately 9 percent to tie to the $6.55 million five-year average. McNeil’s resulting adjusted O&M is calculated as $1,717,023, based on the test year amount of $1,894,298. Capital addition expenditures are projected at $511,920 based on a 4-year average expressed in 2018 dollars.

c. GMP, as a joint-owner, receives the nodal-specific LMP for McNeil’s production in the ISO energy market. This generally offsets the cost of an equal volume of GMP’s retail load obligation (there are minor differences between nodal LMPs reflecting the loss and congestion components of LMP; for McNeil, these yield what are generally limited differences). So long as the plant continues to achieve maximum NOx emission requirements, all energy produced also qualifies for CT Class 1 RECs, for which GMP will receive an estimated $33.46 per REC in the rate year. McNeil also qualifies for FCM capacity credit at a value about equal to its nameplate rating of which GMP’s share is about 17 MW, at the FCA8 (January to May, 2018) and FCA9 (June to December) prices.




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DPS1.Q110. Please describe in detail GMP’s processes and procedures for exploring capacity contracts versus settling capacity through ISO New England?

The Forward Capacity Market (FCM) represents a viable way for GMP and other load-serving entities to meet part of their share of regional capacity obligations – primarily through the annual Forward Capacity Auction (FCA). GMP makes bilateral capacity purchases primarily to manage the substantial uncertainty in FCA clearing prices – that is, to limit potential risks in GMP’s net power costs and retail rates due to changes in FCA price outcomes. The annual FCA has featured year-to-year fluctuations in clearing prices on the order of $2/kW-month; if such exposures are not managed they could be a meaningful source of power cost volatility for GMP going forward. As an example, if GMP were to purchase 400 MW of our annual capacity obligation directly from the annual FCA, then the associated market exposure would amount to a risk of upward retail rate pressure of about 1.5 percent in a single year for GMP customers ($2/kW-month potential FCA price variance * 400 MW * 12 months = $9.6 million / roughly $625 million GMP annual revenue requirement). Similarly, more sustained movements in capacity market prices of this magnitude could produce comparable retail rate pressure on a sustained basis.

Stable-priced capacity contracts at reasonable prices can meaningfully reduce GMP’s exposure to volatile capacity market prices, and therefore reduce the volatility of future power supply costs for GMP and its customers. To limit the exposure, GMP regularly evaluates our projected open capacity position for upcoming 5-year periods, and assesses the suitability of market contracts to fix the anticipated cost of a portion of this anticipated need. GMP typically employs load and peak projections developed from or informed by Itron, Inc., and develops its views of “base case” FCA price outcomes and potential alternative outcomes based in part on consultant forecasts and interviews with the analysts who develop them.

After establishing near-term expectations for price and volume through our update process, GMP begins exploring opportunities with counterparties to “lock in” a portion of our requirements at or below the future price outlook. We have used a number of outreach and price discovery methods in recent years. For example, in 2014 GMP reached out by phone and email to over 20 different generation owners in the ISO-NE market who collectively control well over 10,000 MW of generating capacity, most of which is located in the



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Rest of Pool zone. In this procurement, GMP ultimately awarded a contract to Nextera Seabrook for a blend of long- and short-term capacity (and much smaller amounts of associated energy).

More recently in 2015 and 2016, having already established expectations for available supply and likely participation from our process in 2014, we have employed a shorter, more limited RFP approach to receiving indicative offers from prospective suppliers. The result of this combined approach using both the forward capacity auction and negotiated short-term PPAs for capacity is a more stable cost trajectory for capacity obligations, where in each annual auction no more than 10 to 15 percent of GMP’s estimated obligations (on the order of 100 to 150 MW) is met through the FCA. Leaving a limited fraction of capacity needs to be purchased in each year’s FCA, and employing a set of layered forward purchases (with expirations to occur at least every few years), prevents GMP’s net capacity costs from becoming entirely disconnected from those that neighboring utilities in the region experience.

Person Responsible for Response: Douglas C. Smith, Charles Watts Title of Person: Director, Power Supply; Power Supply Analyst Date: June 20, 2017



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DPS1.Q111. Please refer to Page 34 of Mr. Smith’s April 14, 2017 prefiled direct testimony. Mr. Smith makes reference to replacing expiring market power contracts with renewables and longer-term PPAs. Please describe GMP’s rationale for this strategy in light of the prevailing rates for bilateral natural gas contracts and ISO New England clearing prices?

GMP’s primary rationale for increasing renewable supply is to achieve compliance with Tiers 1 and 2 of Vermont’s new Renewable Energy Standard as cost-competitively as possible. A higher fraction of renewable power in GMP’s portfolio also enhances the value (lowering the effective cost per MWh) of energy transformation projects under RES Tier 3, by reducing the fossil fuel conversion penalty. Increasing renewable supply is also consistent with GMP’s goal to provide a power supply that features low cost, low emissions, and significant price stability. Long-term PPAs (and asset ownership) are typically low-cost ways to procure renewables on a long-term basis - particularly from new plants, or existing ones that are eligible for Tier 1 and not higher-value markets.

Please note that the acquisition of additional renewable supplies is not necessarily inconsistent with prevailing wholesale market conditions. For example, GMP’s recent Enel hydro transaction (involving the acquisition of several small hydro units and PPAs for the output of two hydro units) screened favorably against GMP’s current base case forecast of current wholesale energy and capacity prices (which reflect the substantial decline in market price expectations in recent years), along with a limited estimate of RES Tier 1 compliance value. Also, GMP does not plan to meet all of its RES requirements through long-term commitments; we also plan to explore shorter-term purchases (RECs only, or bundled with power).

GMP less frequently enters into new long-term PPAs for non-renewable sources; this is primarily when such PPAs accomplish another strategic goal. For example, in 2015 GMP entered into a new long-term capacity purchase from NextEra Seabrook, to reduce GMP’s substantial exposure to volatile prices in the Forward Capacity Market.




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DPS1.Q112. With respect to Renewable Energy Standard (“RES”) Tier II compliance, please state the following:

a. Describe in detail GMP’s projections for standard offer and net-metering deployment that will contribute toward RES Tier II compliance;

b. Please also describe in detail how those projections developed; c. Please provide copies any underlying documents and spreadsheets in native

Microsoft Excel format that were used in the development of those projections.

a. RECs from new net metering (NM 2.0) projects, which cannot be resold, will be

the first RECs used to help meet GMP’s RES Tier II requirement. GMP’s projection of net metering volumes is covered in detail in Response 76.

Standard Offer energy projections reflect existing projects, along with some projects that are assumed to be commissioned through 2018. Most Standard Offer generation qualifies for premium (e.g., RPS Class 1) REC markets in Massachusetts and Connecticut. To the extent that these projects reached commercial operation after July 1, 2015 their RECs can alternatively be used to help fulfill GMP’s Tier II obligation. The rate case projection identified the additional REC volumes (after NM2.0 RECs) that would be needed for fulfillment of the remainder of GMP’s Tier II obligation, and subtracted them from the balance of RECs that would be available for sale to other markets. GMP did not assign plant-specific RECs for this purpose; RECs from recent Standard Offer projects could be used, as could RECs from other Vermont-based distributed renewable projects (e.g., GMPSolar projects, bilateral PPAs).

Please note that GMP will recognize the expenses associated with compliance with Tier II (as well as Tier I) over the course of the calendar year in which the compliance obligations are incurred. Therefore, the estimated RES compliance expenses reflected in this rate filing are those associated with calendar year 2018.

b. The amounts and timing of new Standard Offer solar and small wind project installations were based on VEPP, Inc projections. The generation output from standard offer resources is mostly based on project-specific estimates. For solar projects (the majority), the estimates use a 14.5% annual capacity factor, adjusted to estimate the impact of a DC/AC ratio greater than 1, and/or to reflect different historic generation levels. Net metered generation, which is assumed to be primarily solar, is projected as explained in Response 76.



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c. Please see excel file “2._LT_PPA_Resources_2018_RC” tabs “Standard Offer”

and “Net_Metered_2.0”. This document was recently provided via e-mail to DPS staff John Woodward. See also, Attachment GMP.DPS1.Q112_Standard Offer Projection, which reflects a VEPPI estimate of anticipated project online dates.




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DPS1.Q113. Please provide a quantitative assessment of GMP’s Tier II compliance strategy. For example, what are GMP’s projections regarding their Tier II obligations and REC holdings for 2018 after planned REC sales and purchases? Please provide detail by resource generation type.

GMP’s rate year RES Tier II compliance strategy is to first use all of its NM 2.0 Generation, as it cannot be sold like RECs from many other sources can. The remainder of the compliance volume will be met by retiring RECs from other Tier II-eligible sources. These other RECs are not specifically assigned in the rate case analysis, but would come from generation from projects completed after July 1, 2015 from such sources as the Standard Offer and/or GMP Solar projects, based on the relative market value of the RECs in other jurisdictions. GMP’s projected supply and disposal of Tier 2 RECs for 2018 is as follows:

Estimated 2018 Tier II Requirement (MWh) 67,625

Estimated 2018 Tier II-eligible Volumes (MWh): Net Metering 2.0 assigned to GMP 52,569 JV GMPSolar 35,422 Standard Offer 29,762 Other Solar PPAs 26,643 Owned Solar 2,574

Total Projected 2018 Supply 146,970

Total Used for Tier II Compliance 67,625 Assumed Use of Banked 2017 RECs for 2018 compliance 0 Assumed Banking of 2017 RECs for future compliance 0 Resulting Tier 2 Surplus/(Deficit) for 2018 79,345




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DPS1.Q114. Please describe in detail GMP’s strategy for banking RECs for Tier II compliance?

a. If GMP will have “excess” RECs in 2018, provide the anticipated number of RECs which will be banked, and when they will be used.

Banking would entail retiring more Tier II-eligible RECs than the minimum RES requirement for the current year, and setting aside the excess to help meet requirements in one of the next several years. GMP anticipates that the primary reasons to bank excess Tier II compliance would be to limit the expected cost of RES compliance to our customers, or to limit the potential variance in those costs.

In actual practice, this assessment is likely to depend substantially on GMP’s forecast of its supply of Tier II-eligible RECs in future years, relative to the annual requirements. In particular, GMP expects that it may be appropriate to bank some excess REC supply if GMP holds more than sufficient supply to meet the current year’s requirements, but may not have sufficient supply to meet the requirements in future years. Another significant consideration is the outlook for regional Class 1 REC market prices, because an alternative use for excess Tier II-eligible RECs in a year would be to resell them to out-of-state buyers (with the proceeds used to reduce GMP’s net power costs, which are ultimately paid by our customers). It would be more attractive to bank excess compliance if the REC market price outlook for a few years in the future is much higher than the price for the current year (making it more valuable to free up RECs from other sources for sale in those years), and less attractive to bank if REC market prices are expected to fall significantly.

GMP expects its Tier II-eligible REC supply in 2018 to meaningfully exceed its requirements (see Response DPS-1-113), but does not currently anticipate banking any substantial volume of Tier II-RECs for that year. This is because GMP’s projected REC supply appears adequate to meet its requirements for the following several years, and market price expectations for regional Class 1 RECs for the next several years appear moderate. Thus, GMP’s requested power costs reflect the assumption that excess Tier II-eligible RECs that are eligible for compliance in premium REC markets in other states will be sold to those markets.

Person Responsible for Response: Douglas C. Smith Title of Person: Director, Power Supply



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Date: June 20, 2017



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DPS1.Q115. Please describe in detail how GMP calculated RES Tier II compliance costs. Please provide copies any underlying documents and spreadsheets in native Microsoft Excel format that were used in the development of those calculations.

The calculated Tier II costs consist of the cost of NM 2.0 RECs used for Tier II compliance. These reflect a cost of $60/MWh - which is the additional adder cost that GMP will pay under Net Metering 2.0 to new projects that elect to assign their RECs to GMP, rather than retain the RECs for their own use. The remainder of GMP’s Tier II requirements are assumed to be met with eligible RECs from other sources. Specific plants were not assigned to this portion of the Tier II compliance volumes; GMP simply removed the associated volume of MWh from the balance of RECs that is available for sale to other markets.

Please note that if GMP ultimately meets the remainder of its Tier II requirements by retiring RECs from sources that carry a REC expense (e.g., about $30/MWh of the PPA expense for output from the JV GMPSolar projects is booked as a REC expense), then that REC expense would also be booked as a Tier II compliance expense. This assignment would not change GMP’s net REC revenues in total, but would affect the relative magnitudes of the sub-categories of net REC sale revenues and RES compliance costs.

Please see excel file “8._REC_Model_2018_RC”, RES Calc tab, recently provided via email to DPS staff John Woodward, for the recorded Tier II costs.




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DPS1.Q116. Please provide GMP’s most current projections of wholesale energy and capacity costs, as well as projections of REC costs.

a. Please describe how GMP developed these projections; b. Please provide copies any underlying documents and spreadsheets in native

Microsoft Excel format that were used in the development of those projections.

a. GMP’s understanding is that this question seeks information regarding wholesale

market prices for the three products listed; we will address price outlooks with respect to near-term (approximately four years into the future) and longer-term horizons.

Recent Forecast:

Attachment GMP.DPS1.116.1 is GMP’s most recent published outlook for energy and capacity market prices. This is the avoided cost outlook that GMP filed in December, 2016 in support of Vermont’s new Rule 4.100 - expressed in terms of annual and monthly on- and off-peak prices for energy, and monthly capacity prices.

GMP’s most recent outlook for REC market prices is presented in Attachment GMP.DPS1.116.2. This outlook is consistent with the outlook for regional Class 1 prices that GMP used in the context of evaluating its proposed GMPSolar projects in 2016, with the exception that the prices for the first several years have been lowered to reflect REC prices from more recent indicative broker sheets.

GMP plans to update its market price outlooks during Summer 2017.

Near Term Basis:

GMP uses indicative broker sheets of forward NEPOOL energy prices (for the Mass Hub delivery point, and expressed in terms of monthly peak and off-peak prices), along with NYMEX market price quotes, as primary indicators of current energy market prices for the next several years. Attachment GMP.DPS1.116.3 is an example of a recent indicative energy broker sheet. In GMP’s experience, these sources have been fairly close approximations of the prices at which GMP could purchase fixed-price blocks of energy for delivery in the corresponding months or years. While forward prices are not a forecast of spot market prices for the delivery period (rather, they reflect supply and demand for forward trades at a point in time), GMP’s experience is that the forward prices typically are consistent with a current “base



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case” outlook of spot market prices for the delivery period. Attachment GMP.DPS1.Q116.4 is an example of a recent indicative REC broker sheet (for GMP’s REC supply the MA Class 1, CT Class 1, and MA Class 2 are typically the most relevant).

Similarly, GMP uses indicative broker sheets of forward REC market prices for neighboring states as the primary indicator of current REC market prices for delivery in future years. The regional REC market is much less liquid than the energy market, so in GMP’s experience the broker sheets are somewhat less reliable indicators of the prices at which GMP could actually sell RECs forward – particularly for large volumes, and for delivery three or more years in advance. To help counter the illiquidity and limited transparency in the regional REC market, GMP also subscribes to REC market outlook service offered by Sustainable Energy Advantage, a consulting firm that focuses on renewable markets in New England, as well as renewable policy issues in other regions.

GMP uses clearing prices from ISO-NE’s annual Forward Capacity Auctions (which are conducted about three years in advance of the delivery periods) as the primary indicator of the market value of capacity (or reductions in peak load which could reduce GMP’s share of regional capacity obligations) in the near term.

Longer Term Basis:

There is only limited trading in New England for energy, RECs, and capacity for delivery five or more years in advance, and few broker price indications. GMP therefore derives its own base case market price forecasts, based on a number of sources including confidential, subscription-based services from qualified consulting firms and indicative factors such as Natural Gas futures as quoted by NYMEX. Our consultants include ESAI (primarily for energy and capacity); IHS (primarily for energy and capacity); and Sustainable Energy Advantage (primarily for REC prices and renewable market policy context). GMP Power Supply team members review trends in futures prices; periodic reports and briefings from our consultants; and interview the firms’ experts to understand the key market factors or assumptions (e.g., supply/demand balance, estimated cost of new entry for key resources, environmental policies, etc.) that drive their forecasts. The context provided by our consultants is supplemented by other research or analysis performed by GMP staff to choose the base case market price outlook. The approach summarized here is the same one that GMP used to develop avoided cost outlooks for energy and capacity in Dockets 8010



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and 8684; during 2016 GMP provided substantive testimony regarding our methods, assumptions and results.

b. Please refer to Attachments GMP.DPS1.Q116.1, GMP.DPS1.Q116.2, GMP.DPS1.Q116.3, and GMP.DPS1.Q116.4.




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DPS1.Q117. Please provide the total number of MWh produced and the total cost associated with both excess net metering purchases and the JV Solar projects.

The total volume of excess Net Metering and JV GMPSolar project energy in the rate year is 158,795 MWh and 35,422 MWh (net of a small sale from one project), respectively. The projected total cost of excess Net Metering purchases is $24,026,527. (Total other Net Metering costs are $7,136,145.) The total cost of JV GMPSolar purchases is $4,402,096 including RECs.

Please note that for accounting purposes the portion of the PPA price that is assigned to RECs (roughly $30/MWh) will be classified as an offset to REC revenue when REC revenue is recognized, or as a Tier II expense if the RECs are retired for RES compliance purposes.




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DPS1.Q118. For any IT investments or projects that involve demand-side-management and grid choreography of flexible loads, renewables, and/or storage, please describe GMP’s plans and processes in place to ensure 3rd party ability to participate.

a. Please also describe generally GMP’s overall approach to open access to grid choreography and what GMP is doing to implement that approach.

GMP, in partnership with customers, has a vision for the future of the electric grid, and energy delivery overall, that transitions the current grid model from one that is traditionally one direction and dominated by a small number of players to one that is multi-direction and having participation by many players of varying sizes and sophistication levels. That end vision is where we are heading and most of our work is with that end vision in mind. This is innovation happening in real time. The path to getting to that end vision will not be a straight line with perfect clarity about the milestones and their timing that will be achieved along the way.

At the moment, the best way to advance our vision of a multi-direction, many-participant energy system is for GMP to be putting into place certain capabilities and infrastructure that we know will be required to achieve our vision and a cost-effective energy future for customers. Because we will be responsible for grid reliability performance during any transition in models, we believe that during the initial deployment of the certain capabilities and infrastructures (such as demand-side-management controls and grid choreography, etc.) it is important to open up participation in those functions to third parties over time in a cost-effective way as we learn how to safely and reliably operate the grid under the emerging change in model.

GMP has selected software partners that have the flexibility and capabilities to integrate various distributed energy resources, regardless of who owns those resources. In our initial piloting of distributed energy resources, we have focused on direct ownership and access. This will allow GMP to confirm the value, functionality and potential customer impacts of these resources, all while making sure we maintain distribution system safety, stability and reliability. This is a key first step to creating the appropriate policies and financial structures for 3rd party aggregators or DER providers to participate in a shared access energy platform. GMP’s grid transformation vision anticipates a mix of resources that include direct customer owned, GMP owned and 3rd party owned and we view it as critical to assure that all of the resources



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contribute to a more efficiently operated grid and most importantly, directly contribute to reducing the cost for all GMP customers. This will begin to evolve quickly in 2017 and 2018 with expectations of third integration beginning throughout 2018.

Person Responsible for Response: Joshua Castonguay, Brian Otley Title of Person: VP & Chief Innovation; Senior VP & Chief Operations Officer Date: June 20, 2017



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DPS1.Q119. Please refer to Page 22, Lines 2–5 of Mr. Otley’s April 14, 2017 prefiled direct testimony, where Mr. Otley discusses GMP’s delivery of a “contemporary web environment.” Please provide any tracking or traffic data or statistics available to GMP that document customer use of the web environmental described by Mr. Otley.

The following table shows some of the web tracking data we maintain. On January 28, 2017, GMP cutover to a new web environment that was the result of capital project work. We contrast web usage statistics for a period before and after that cutover. The data indicates a substantial increase in customer use of our website and web-based self-service functions.

Websites* Date Range

Sessions Users Page Views

Avg. Pages /Session

Avg. Session Duration

Corporate greenmountainpower.com

1.1.16 > 1.27.17

749,828 634,454 1,133,071 1.51 0:00:49

1.28.17** > 6.8.17

3,017,067 1,747,675 5,359,821 1.78 0:01:41

Products products.greenmountainpower.com

1.1.16 > 1.31.17

56,038 44,142 133,014 2.37 0:02:24

1.1.17 > 6.8.17

110,796 88,517 254,171 2.29 0:02:09

Customer Self Service account.greenmountainpower.com

1.1.16 > 1.31.17

932,103 917,018 2,607,631 2.8 0:01:27

1.31.17 > 6.8.17

688,497 678,655 1,880,242 2.73 0:01:40

* GMP's web presence is presently separated into 3 distinct environments

**Greenmountainpower was cut over to new web platform on 1.28.17




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DPS1.Q120. Please refer to Page 11, Lines 3–4 of the prefiled direct testimony of Mr. Joshua Castonguay. Please describe in detail GMP’s capital investments into and ownership stake in the Millstone 3 Nuclear facility located in Waterford, Connecticut.

The capital investment related to the Nuclear facility located in Waterford,

Connecticut is based on an agreement among joint owner where each owner is responsible for their ownership share of the site specific annual construction expenditures. Currently Green Mountain Power’s ownership percentage is 1.7303%. For budgeting purposes Millstone provides annual information that is used to forecast our capital expenditures. For rate making purposes a 4-year average was used based on an agreement with the DPS. This method is consistent with how the annual blanket amounts are calculated for rate making. Please see Attachment GMP.DPS1.Q120 for the calculation of the average and refer to Attachment GMP.DPS1.Q12.a-e for the amounts included in the filing.




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DPS1.Q121. Please state whether, when, and how the JV Solar projects will provide a net financial benefit to ratepayers. Please provide any available documentation, models, and spreadsheets in native Microsoft Excel that support your response.

These projects provide significant benefit to GMP customers because (1) their output will go 100% to the benefit of customers; (2) after they are depreciated at year 25, GMP customers will get the benefit of their output without further depreciation expense; (3) by combination of the developer fee and equity in affiliate contributions (both of which are being returned 100% to customers), customers will effectively pay nothing for the projects’ output for the first 5 years of their existence; and (4) the projects’ output may be used to satisfy Tier 2 of Vermont’s recently enacted Renewable Energy Standard law.

See Attachment GMP.DPS1.Q121 (Protected) for the CohnReznick model used for the 2018 rate filing.

Person Responsible for Response: Edmund Ryan, Karen Young Title of Person: Controller, Budget / Forecast Supervisor Date: June 20, 2017



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DPS1.Q122. Please state whether GMP used an RFP or bidding process to solicit vendors for various components included in the JV Solar projects, including batteries, construction, and solar panels. If so, please provide copies of any RFP or bid solicitation documents related to the JV Solar projects and a list of the recipients of such documents.

As the JV Solar project concept was being developed and evolved into a mature construction program, GMP solicited proposals from multiple individual developers over an extended period of time in order to maintain flexibility in determining the scope of the project. During discussions with potential engineering, procurement and construction (EPC) firms, a major goal for GMP was to establish a long-term partner for serial development who demonstrated the experience and capabilities to develop and construct utility-scale projects, at low cost and on-time and on-budget. GMP discussed scope, timing and costs for the proposed JV Solar projects with several potential EPC firms over an extended period of time and eventually came to agreeable commercial terms with local EPC firm groSolar in White River Junction, Vermont who successfully constructed the five projects. The scope of work that GMP sought was unusually broad and included site identification, engineering, all permitting activities, procurement for all necessary equipment (except for interconnection), all contracting and subcontracting activities for construction, commissioning and operation and also to provide maintenance services for the operating projects. This approach was effective in obtaining an excellent long-term partner for these projects. GMP did not initially consider installing batteries on these JV Solar sites and solicited no battery pricing at that time. Since construction of the JV Solar projects, GMP has evaluated adding battery storage to one JV Solar facility, in Panton, Vermont. The proposed Panton Battery project is presently pending before the Board (Docket # 17-2813-PET). GMP provided information on this project to DPS on May 9, 2017, including information on RFPs for the project, and refers to that response for further information. The battery project will be GMP-owned, and constructed on land leased by GMP from GMPSolar-Panton LLC.




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DPS1.Q123. Does GMP have in place, or plan to have in place, a capacity management agreement (CMA) in the micro grid projects? If so, describe the terms and cost of the CMA.

GMP does plan to have a CMA in place for each battery used on each MicroGrid project. GMP has not yet executed a CMA. The expected terms will cover either a 10-year period or 20-year period and the cost is expected to be about $680,000, which is already included in the capital cost. The CMA will guarantee the battery will maintain 100% of its capacity for the entire coverage period, including adding battery modules and replacing inverters as needed in order to maintain the capacity.




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DPS1.Q124. Please describe other any alternate peak shaving strategies (such as demand response and load management) that GMP considered in evaluating the cost-effectiveness of its various proposed storage projects.

GMP’s informal mantra for peak shaving is literally “crush the peak” in whatever ways we economically can, in order to lower costs (i.e. capacity, transmission, ancillary market costs that are allocated based on load, etc.) for customers. GMP currently employs various traditional methods of peak shaving including demand response with commercial, industrial and ski area customers, and in the normal course of business we seek to evaluate other opportunities as they present themselves. Further, battery storage and other forms of demand response are not necessarily mutually exclusive. In other words, one method of peak shaving doesn’t preclude the simultaneous development and implementation of another different method. In fact, as is also true for meeting load obligations with a portfolio of generation resources, GMP leverages a portfolio approach by combining different, but complimentary, tools to manage and shave peak loads to lower costs for customers. GMP anticipates that there will be significant load control options that are cost-effective, some more than battery storage in some cases. We will pursue such opportunities with the goal of lowering net costs to our customers.

GMP is utilizing or developing the following methods of peak management:

• Legacy methods of turning electric water heaters off - and requesting

demand response participants (e.g., ski areas, other commercial and industrial customers and now even residential customers) to reduce their loads - during potential system peak hours.

• Utilizing a third-party aggregating software to manage residential storage such as the Powerwall and Sonnen Battery systems, as well as electric resistance water heaters in a more dynamic way that can produce value with less interruption to a customer’s service.

• Deploying customer-owned (but utility-dispatchable) residential and small commercial battery storage systems (through Tesla Powerwall 1 and 2 pilots).

• Using distributed generation throughout the system as load reducers to reduce daytime peak loads, and now also using utility-scale battery storage systems to further leverage the peak-shaving capabilities of the increasing amount of distributed solar. As additional technologies and systems



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become available, GMP plans to actively explore them and include them in our peak-shaving strategy when feasible and cost-effective.

In the context of near-term energy storage project proposals, GMP has not performed a benefit/cost comparison against load control options for a few reasons. First, GMP does not expect that cost-effective load control strategies are likely to displace these near-term energy storage proposals as part of a low-cost peak management strategy. The amount of battery storage (MW, or peak reduction capability) that GMP has proposed or expects to propose in the near-term is fairly limited compared to the potential peak reductions (i.e., many tens of MW) that GMP expects could ultimately be achievable through a portfolio of peak management options (including various forms of controllable loads, and battery storage). Second, peak reduction is only one of the rationales for battery storage projects, and only one of the anticipated benefit streams from them. Other potential benefits include local distribution grid support, islanding, dispatch of the batteries for energy arbitrage value or ancillary service revenues, and in some cases project-specific benefits such as supporting the implementation of electrification to help meet RES Tier 3 requirements. Not all forms of load control can provide these other benefits/services. Finally, by definition the potential amounts and location of controllable load are constrained to a meaningful degree by the magnitude and location of current customer loads.

Person Responsible for Response: Kirk Shields, Douglas C. Smith Title of Person: Director of Development and Risk Management; Director, Power Supply Date: June 20, 2017



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Customer Service/Service Quality

DPS1.Q125. Please identify any GMP customer service functions that can be completed remotely or through automated systems, and describe how the company has accounted for savings through automating customer service functions.

The following service functions may be completed remotely or through automated systems: making a payment, making payment arrangements, signing up for eBilling and recurring payments, stopping service, reporting an outage, checking an outage status, signing up for text alerts, viewing current and past bills and current status of accounts, and viewing 15-minute interval usage data. Customers may also notify GMP of changes to net-metered group accounts, and change the percentage of net metered systems allocated to each group member, by email.

These processes have resulted in lower O&M expenses than would otherwise have been incurred. These savings have resulted in greater synergies flowing back to customers.




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DPS1.Q126. Please state the amount of GMP’s contributions to its Electric Assistance Program (“EAP”) through Alternative Regulation during the test year?

a. Please identify the source of those funds; b. Please state whether/how the pending rate request will contributions to

GMP’s EAP.

DPS1.A126. Section III.B.1.i of the GMP Alternative Regulation Plan (“ARP”) states that: “[i]f Actual Earnings reflect a rate of return on equity that is within a range of 50 basis points below and 35 basis points above the Board-approved rate of return on equity during the ESA Measurement Period (“Earnings Sharing Band”), there will be no Earnings Sharing Adjustor and the Company shall contribute 10% of Earnings Sharing Band earnings in excess of the Board-approved rate of return on equity to the Company’s Power Partners Program.”

Section IV.B of the GMP ARP states that: “[t]he Company shall match contributions by its customers to the Company’s Warmth Program, and the amount of the Company’s match shall not be included in rates.”

The question asks about the amount of GMP’s contribution to its Electric Assistance Program (“EAP”) through Alternative Regulation during the test year. The EAP is funded by customer fees collected on a per meter basis as originally authorized by the Public Service Board in Docket 7535 on September 6, 2012. As such, the EAP is not the program that receives contribution via the provisions of the ARP.

During the test year, GMP was not required to make a Power Partners Program contribution pursuant to section III.B.1.i. Although not required under the ARP, GMP did contribute $26,000 in the test year to the Power Partners Program which was charged to FERC account 426.1 – Donations.

GMP made a $130,000 test year contribution to the Warmth Program pursuant to section IV.B of the ARP. Warmth Program contributions are charged to FERC account 426.1 – Donations.

a. GMP’s shareholder is the source of these contributions since account 426.1 is excluded from the cost of service.



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b. The pending rate request will have no impact on contributions to the EAP program. The meter fees charged to customers do not change as a result of a change to the Company’s base rates. They are fixed by Board order. Additionally, the Alternative Regulation Plan will have expired before the rate changes take effect on January 1, 2018.

Person Responsible for Response: Edmund Ryan Title of Person: Controller Date: June 20, 2017



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DPS1.Q127. Please describe GMP’s processes for opening a new customer account any costs that are imposed on new consumers.

When a customer contacts us to create a new account, the CSR first checks to ensure the service address is within our service territory. The CSR then checks to see if the customer has had service with us before. If so, we determine if, based on past payment/credit history, a deposit should be collected under Board rules. When a new customer account is set up, there is a one-time $20 charge to start a new service. If the customer has not had service with us before, we offer the customer the opportunity to have the security deposit waived by providing a letter of credit from a bank or another utility. There are no up-front payments required. The setup fee and any deposit are included in the first regular bill. After determining whether a deposit is required, the CSR creates a field activity to have the meter read either remotely or, in the case of electro-mechanical meters, in the field. Once we have the meter reading to commence billing, the order is closed in the system and the account is made active.




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DPS1.Q128. Please describe GMP’s processes for changing the account location for current customers and any costs that are imposed on new consumers.

The process for a current customer to open a new account is essentially the same as in Question 127. Please note that the question refers to “new consumers.” In the case of changing an account location, there is no new consumer, only a new account. When a customer contacts us to move to a new location, the CSR first checks to ensure the new service address is within our service territory. When a new customer account is set up, there is a one-time $20 charge to start new service. The setup fee is included in the first regular bill. The CSR creates a field activity to have the meter read either remotely or, in the case of electro-mechanical meters, in the field. Once we have the meter reading in order to commence billing, the order is closed in the system and the account is made active. Any balance from the old account is transferred to the new account, and the old account is closed.




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DPS1.Q129. Please state whether GMP remotely disconnects accounts for customers whose service is metered with a smart meter and whether any costs associated with remote disconnections are assumed by GMP.

Yes, we do remotely disconnect accounts in cases of shutoffs for non-payment (SONP) or when a customer moves out of a location. Generally speaking, the costs of doing a disconnection are included in the cost of running the Customer Care and Meter teams. In the case of a SONP, the customer is charged $35 per the Terms and Conditions Tariff.




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DPS1.Q130. Please describe GMP’s rationale, or any benefits derived from, not assigning new account numbers for customers that move to a new service location or address.

By retaining the existing account number when a customer moves from one location to another, we are able to maintain all past history of bills, payments and credit for each individual for the customer’s use and the Company’s use. This helps ensure that any credits or past debts are not abandoned by customers who move to a new location. It also ensures that their obligations stay with them. We consider this fair to each individual customer and to the broader base of customers, as this process helps us reduce write-offs that ultimately are subsidized by all customers.




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DPS1.Q131. Please state whether GMP believes that its existing or proposed tariffs allow for GMP to charge a customer an initial service fee when the customer moves to a new service location. If so, please identify the section of GMP’s current or proposed tariff that authorize this practice.

GMP does believe that its current and proposed tariffs allow for GMP to charge a customer an initial service fee when a customer moves to a new service location. Original Sheet 4 of the current tariff contains the following special charge: Initial Service Charge: When the Company is requested by the Customer to establish a new account with the Company there shall be a charge of $20.00 for such service. No changes to this section of the tariff have been proposed in this proceeding so this special charge would continue.

The Company’s long-standing interpretation of the phrase “establish a new account with the Company” is the work that GMP performs when contacted by a customer for service at a new service delivery point. While the account number of a particular customer may not change, the Customer Service Representative (“CSR”) must still collect new information such as the new location, new phone numbers, mailing address, etc. All of these administrative data gathering tasks encompass establishing a new account. The CSR also takes this opportunity to answer any questions the customer may have and provide them the opportunity to take advantage of automatic bill paying and online account review.

Assigning some of GMP’s call center staff and AMI/Billing System costs directly to customers who require and take advantage of those resources/capabilities is a fair mechanism of cost recovery and is commonplace in the industry and avoids any cost shift to other customers.




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DPS1.Q132. Why is GMP proposing to change billing from a service rendered basis to a bills rendered basis? What are the potential benefits to GMP customers?

GMP has historically administered rate changes on a bills-rendered basis. Only recently were we asked by the former Board clerk to build the capability to make rate changes on a service-rendered basis. With service-rendered billing, customers who are on a billing cycle that is not aligned with the date of the rate change, as most customers are, will receive a more complicated bill during the billing month that straddles the rate change date. Under service-rendered billing, the usage prior to the rate change date is billed under “old” rates and the usage after the rate change date is billed under “new” rates. This has proven to be a source of customer confusion and has created additional calls to the call center. The “split” bill requirement of service-rendered billing also exacerbates the complexity of more complicated rate classes with demand charges and TOU designs and also greatly complicates the presentation of net metering bills.

GMP believes that going back to consistent bills-rendered rate changes is easier for customers to understand and minimizes the possibility of billing errors, particularly in the growing net metering billing arena. Customers whose bills are rendered prior to the date of the rate change will see all of their usage billed at “old” rates and customers whose bills are rendered after the date of the rate change will see all of their usage billed at “new” rates with no pro-rating or split bills. Given a consistent application of bills-rendered rate changes going forward will not cause any inequity among customers with different bill cycle dates. With annual rate changes, every customer would be billed a full 365 days under the same set of rates. Even with rate changes that are less periodic, as long as bills-rendered billing is consistently applied, customers will get the same number of days under every single set of rates.




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DPS1.Q133. During the past twenty nine months, the Department has received a disproportionate amount of reliability complaints regarding GMP service from the areas of Bristol and Randolph. Please state what actions that GMP has taken, if any, to remediate these reliability issues and whether GMP’s remediation measures have resulted in improvements in system reliability.

GMP has identified multiple projects in the vicinity of both the Bristol and Randolph communities, which already has and will continue to improve reliability to these areas. These proposed projects are in various stages ranging from completed, under construction, or in design. Below is a current list of projects that GMP completed in the last three years as well as a list of projects either under construction or in design.

Bristol Area

In progress:

• Lincoln: West River Road, Griggs Hill Line 7, relocate poles 67-135 to the road. In construction.

• Lincoln/Starksboro: Jerusalem Road, Sam Stokes Road, Line 731 poles 78 to 102 & line 737 poles 1-17 relocate poles to the road. Right of ways secured; required National Forest Service permit secured; ready for construction.

• Bristol: Change the feed into Upper Notch Road to feed to Lower Notch Road and relocate poles to the road. Right of ways secured; awaiting approval from National Forest Service.

• Bristol: Rte. 116 line 7, poles 35-67, rebuilding along road with tree wire. Obtaining right of way.

• Bristol: Lower Notch road, line 702, poles 26-50, relocate poles to the road. Obtaining right of way.

• Lincoln: Browns Road, West Hill line 74, relocate poles 1-54 to road. Obtaining right of way.

• Lincoln: Ripton Road, rebuilding line 74, poles 54-142, Notch Road. Obtaining right of way.

• Lincoln: Relocating Line 741 roadside. Obtaining right of way. • Lincoln: Relocating line 762 roadside. Right of way complete; ready for

construction.



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• Lincoln: Grimes Road, Mill Road Line 741, relocating line roadside. Obtaining right of way.

• Lincoln: Gove Hill, Line 742, relocate poles to road. Right of way secured; awaiting National Forest Service permit.

• Ripton: Rte. 125, Line 19, rebuild roadside. Conceptual design stage.

Completed in past 3 years:

• Lincoln: Downingsville Road Waterworks Road line 73 poles 54 -102. Relocated three phase to road.

• Starksboro: Rte. 116. Tied line 73 to 7315 to lessen exposure. • Bristol Rte. 17 /Main Street, Line 7. Rebuilt line roadside to current

construction standards. • Bristol: Hewitt Road to Rte. 116. Rebuilt line to current construction

standards. • Bristol: Carlstrom Road. Tied line to 7022 to lessen exposure

Randolph Area

In progress:

• Roxbury: Steele Hill Road, relocate poles roadside. In construction. • Randolph: Sunset Hill Road, relocate poles roadside. In construction. • Randolph Center: Transmission line 89, replace motor operated air break.

2018 construction. • Randolph Village: Transmission line 85, replace motor operated air break.

2018 construction. • Randolph, Braintree, Granville, Roxbury: Rte. 12A, Relocate line roadside.

Conceptual design stage. • Roxbury-Northfield: Relocate approximately 287 customers on the

Randolph circuit that feeds the Roxbury Mountain area to a feed from Northfield Electric, reducing exposure to these customers.



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Completed in past 3 years:

• Roxbury/Northfield: Northfield Road, Warren Mountain Road, Little Northfield Road, Stoney Brook Road. Line 82, rebuilt roadside to current construction standards.

• Roxbury/Northfield: Little Northfield Road, rebuilt roadside to current construction standards.

• Randolph Substation: Repaired breaker mechanism in breaker that feeds Brookfield, Randolph and Northfield/Roxbury area.




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DPS1.Q134. Please describe generally GMP’s processes and procedures for training consumer service representatives (“CSRs”) for handling questions or complaints on complex services, such as net-metering and time-of-use rates.

a. Please also describe resources made available to the CSRs for complex issues;

b. Please describe GMP’s escalation process for consumer questions or inquiries that CSRs are incapable of resolving and whether GMP tracks consumer inquiries that are escalated.

GMP’s CSR’s training and preparation reflects our company-wide philosophy of customer obsession, described in great detail in the prefiled testimony of Steve Costello. New GMP CSRs undergo an onboarding process that includes broad training on the variety of topics, policies and issues that routinely arise in customer service, including the importance of empathy and problem solving. This includes basic phone, system training and PSB Rules as well as more specific training on topics such as net-metering procedures and time-of-use rates. The initial training process includes five days spent learning our systems and procedures, followed by five days of working side by side with, and listening to, calls of a seasoned CSR, and learning directly from that mentor. This is followed by five days of the mentor working side by side and listening as the new CSR begins performing customer service functions. This is followed by regular, routine check-ins by the department supervisor, using data and first-hand oversight to coach and teach. As for more complex issues, as state policies have evolved over time, CSRs are provided with updated training on new rules, and copies of correspondence to be sent to affected customers. We also have monthly staff meetings where important information is shared. In general, CSRs are expected to and do resolve the vast majority of calls, even on complex topics like net-metering and TOU rates, without any escalation or additional resources required. However, these issues can be complex, so our CSRs are trained to transfer group net metering calls to our Group Net Metering/Accounting Team, which has deeper technical skills focused exclusively on net-metered accounts.

a. For those complex issues or situations in which a front-line CSR needs assistance, there are a variety of resources available. For example, within the CSR team there are subject matter experts who “specialize” in specific areas such as collections, billing, and net metering, and they can provide information to any CSR, or if necessary handle a specific customer response. The team is



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led by Mary Morris, who is also available for assistance, as are members of the aforementioned Group Net-Metering team. When CSRs need additional support or insights on technical issues related to TOU or other rates, team members routinely turn to subject matter experts within the team, or to Scott Anderson or other members of the Rates Department.

b. When a CSR cannot resolve an issue directly, we have a customer escalation team, comprised of five senior-level, experienced CSRs plus Ms. Morris who are empowered to handle such cases. We track escalations over time to improve customer service. Ms. Morris routinely circles back to CSRs who create escalations to expand their knowledge base and reduce future escalations.




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DPS1.Q135. Please refer to the Third Revised Sheet No. 23-3. For net-metering customers that use time-of-use (“TOU”) rates, please state the following:

a. The state the total number of net-metering customers that have TOU rates; b. Does time period reference peak vs. non-peak; c. Please also state how GMP monetizes net-metering rates for TOU net-

metering customers during peak hours prior to applying credits to non-peak usage.

a. GMP currently has 148 customers who net meter (individually or in groups) who

are also on a TOU rate schedule.

b. The tariff states that: “[w]hen the net metering system is served via a time-of-use rate class and more generation is produced within a time period than was consumed in that time period, then the excess kWh generation shall be used to offset any net kWh consumption in any other time period within the billing period prior to the monetization calculation.” The phrase “time period” does reference peak versus off-peak periods. It also differentiates time periods for rate schedules that have critical peak time periods.

c. Any excess generation is monetized once it is determined that excess exists in the monthly billing period. That is the purpose of the language above for TOU customers; to determine final excess generation after excess within a time period offsets any consumption in another period within the monthly billing period.

For example, if a Rate 11 TOU customer has 400 kWh of excess generation showing in the peak register and 500 kWh of consumption in the off-peak register, then there is no excess. The 400 kWh in the peak register offsets 400 kWh of off-peak consumption and the customer is billed for the remaining 100 kWh of consumption in the off-peak register at the off-peak rate.

If the customer has 400 kWh excess generation showing in the peak register and 100 kWh of consumption in the off-peak register, the first step is to determine if excess exists. 100 kWh from the excess in the peak register is used to offset the 100 kWh in the off-peak register. The result is 300 kWh excess in the peak register and 0 kWh in the off-peak register. Excess exists and is monetized at the “blended residential rate” of $0.14919/kWh per the tariff and Board Rule 5.100. This credit can be used to offset remaining non-bypassable charges on the bill or “banked” for use in a future billing period.



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DPS1.Q136. Please refer to Second Revised Tariff Sheet 56. With respect to Critical Peak Pricing (“CPP”),

a. Please state the total number of CPP customers; b. Please describe any consumer outreach or educational materials that GMP’s

provides to CPP customers; c. Please state how GMP contacts CPP customers to verify that contact

methods are up-to-date.

a. GMP currently has 15 customers on Residential Critical Peak Pricing Rate 9.

b. A link to the Company’s website that provides information to customers is provided. http://www.greenmountainpower.com/help/billing-payments/what-are-gmp-empower-rates/

A link to the blog post on the Company’s website is provided. http://www.greenmountainpower.com/2016/08/09/empower-program/

A bill insert included with bills during the fall of 2016 is included as Attachment GMP.DPS1.Q136.b.1. An on-bill message provided to customers during the June billing cycles is included as Attachment GMP.DPS1.Q136.b.2.

Call center representatives will respond to customer questions and explain the requirements of the rate schedule and can sign customers up for this service if requested.

c. GMP intends to contact customers prior to their annual anniversary on this rate

class to provide the customer with an opportunity to change rates prior to re-enrolling for another one-year period. At that time, the customer has an opportunity to verify contact information with the Company. Otherwise, there is no day-to-day procedure to verify contact information. It is the customer’s responsibility to notify the Company of any changes.


http://www.greenmountainpower.com/help/billing-payments/what-are-gmp-empower-rates/

http://www.greenmountainpower.com/help/billing-payments/what-are-gmp-empower-rates/

http://www.greenmountainpower.com/2016/08/09/empower-program/



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DPS1.Q137. Please refer to Second Revised Tariff Sheet 58. a. Please state the total number of customers using TOU rates; b. Please describe GMP’s outreach and efforts to enroll customers in TOU

rates; c. Please describe any consumer outreach or educational materials that GMP’s

provides to customers prior to enrolling in TOU rates.

a. GMP currently has 4,870 customers served on Residential Time-of-Use Rate 11.

91 of them have net metering and are included in response 135.

b. Information on the Company’s residential rate alternatives are provided on the Company’s website at http://www.greenmountainpower.com/rates/#rate-group-residential

c. Please see Response 137(b).


http://www.greenmountainpower.com/rates/#rate-group-residential

http://www.greenmountainpower.com/rates/#rate-group-residential



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DPS1.Q138. With respect to street lighting rate classes, please provide the following: a. Please provide a sample bill for each street lighting rate class; b. Please describe how GMP ensures the accuracy of street lighting billing; c. Please provide a detailed explanation of how GMP calculates and applies

rates for each class of street lighting and demonstrates what detail would be provided to a customer who inquires as to which lights/poles/maintenance the customer is paying for.

a. Sample bills for Rates 6ML, 7, 16 and 18 are provided as Attachment

GMP.DPS1.Q138.a.

b. GMP ensures the accuracy of street light billing by managing the rate change process with controls and checks. Additionally, when customers change street lights the Company follows clear procedures to ensure that customers are billed accurately. When rates change, proposed streetlight prices are loaded into our CC&B billing system test database. Prices are verified using the proposed streetlight tariffs. In addition, GMP uses the current streetlight prices to calculate the new streetlight prices based on the proposed rate increase/decrease as an additional double-check. Once prices are loaded and verified in the test system, GMP bills accounts within the test environment and verifies that the pricing is correct and the bill is calculated correctly.

Once the tariff is approved by the Board, the new prices are loaded into the CC&B billing system production database with the appropriate effective date. GMP again verifies the pricing to the streetlight tariffs and “smoke tests” a few rates to ensure everything is working properly. The billing team reviews production bills for the first few cycles where price changes are applicable and recalculates the bill to verify pricing and accuracy of the bill. The bill print vendor is given notice to hold processing of bills each day for the first few cycles of billing until the bills have been tested and verified each morning and then released for printing and mailing.

Documentation is maintained for audit purposes including the new tariffs with price changes and signed and dated test bills. Additionally, on a weekly basis, the leader of Customer Accounting/Billing reviews a report that includes any changes



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made to the rate tables in the CC&B billing system production environment and verifies that the changes are appropriate.

The following is a description of the process that ensures that customers are being billed accurately for the lights they have on the GMP system.

When a call is received by a Customer Service Representative (“CSR”) to remove a light, they prepare a field order requesting the work to be done. The field order then goes to the field designer who is responsible for that area. The designer then designs the job and gets it ready for the line crew to work. Once the line crew completes the job, the CSR for the field designer gets a notice the work is complete and removes the light from the billing system.

Similarly, when a call comes into a CSR to add or change a light, the CSR emails the request to the field designer. The designer reaches out to the customer to go over lighting types, costs and the proposed location for the light. Sometimes this requires a site visit. Once it is determined what type of light the customer desires, the designer then designs the job and gets it ready for the line crew to work. Once the line crew completes the job, the CSR for the field designer gets notified that the job is complete. The details of what type of light, how many lights, and account information are provided to the CSR to enter into the billing system.

c. When a call comes in from a customer asking to understand the streetlight bill the

first thing the Company does is review the bill with the customer. The Company reviews the number of lights of each size and technology with the customer and reconciles this information to the customer’s bill. GMP will provide the customer with a map showing locations of the lights if the customer requests this information. Field designers are also available to meet with the customer and review where the lights are located.




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DPS1.Q139. Please state the number of revenue meters have been pulled to make ConnectDer installs and the charges for the meter pulls that are assessed to the customer.

Fiscal Year to date (June 6, 2017) GMP has sold 435 ConnectDers directly to solar installers in our service territory. The ConnectDer is installed by the solar installer during the course of connecting the residential solar array to the meter. GMP assesses no additional charges to our customers for the ConnectDer installation.

Person Responsible for Response: Betsy Bloomer Title of Person: Director, Energy Innovation Center Date: June 20, 2017



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DPS1.Q140. Please describe how GMP manages charges for equipment leasing during the disconnection process and whether these charges included on disconnection notices.

Non-payment for equipment leases and retail installment agreements shall not

constitute sufficient grounds for disconnection of electric service but may constitute grounds for disconnection or removal of the equipment. The charges for these products are not included on disconnection notices.




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DPS1.Q141. Please describe how GMP informs consumers seeking conventional water heaters about alternatives such as Heat Pump Hot Water Heaters?

Whenever GMP engages a customer about water heating services, either on the phone or over email, we discuss the option of Heat Pump Water Heaters as a more efficient alternative for customers where the application is appropriate. GMP also works with our local installers to inform customers of the offering when providing service or installation estimate calls.




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DPS1.Q142. Please describe and attach GMP’s pre-sale and point-of-sale consumer education and disclosure materials for any equipment leasing, maintenance or service agreements for all tariffed, pilot, or untariffed services.

GMP provides equipment financing, maintenance or service agreements for

the following tariffed, pilot, or untariffed services: heat pumps, heat pump water heaters and traditional water heaters. Attachment GMP.DPS1.Q142 contains consumer information sheets and retail installment contracts for the products included in the rate filing (heat pumps and heat pump water heaters), as well as a rental and service agreement for traditional water heaters. For additional information and materials available to customers on these services, please refer to GMP website pages: http://products.greenmountainpower.com/product/ductless-heat-pump/ and http://products.greenmountainpower.com/product/heat-pump-water-heater/.


http://products.greenmountainpower.com/product/ductless-heat-pump/

http://products.greenmountainpower.com/product/heat-pump-water-heater/



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DPS1.Q143. Please refer to Page 9, Lines 12–16 of the April 14, 2017 prefiled direct testimony of Steve Costello. Please identify the companies that GMP contacted regarding CSR best practices and please also explain what changes GMP has made or will make in its customer care policies and practices as a result of interviewing those “key customer-focused leads.”

GMP contacted companies we viewed as providing high-quality service to gather insights and ideas on how we could improve. They included Burlington Electric, 585 Pine Street, Burlington, Vermont; Vermont Electric Cooperative, 42 Wescom Rd, Johnson, VT; regional members of the Electric Council of New England; Southern Maryland Electric Cooperative (SMECO), 14950 Cooperative Place, Hughesville, MD, which for years has been among the top-rated similarly sized utilities in the East according to J.D. Powers and Associates; Blue Cross-Blue Shield of Vermont (BCBS), 445 Industrial Lane, Berlin, VT; New Hampshire Electric Cooperative, 579 Tenney Mountain Hwy, Plymouth, NH.; and Vermont Gas Systems, 85 Swift St, South Burlington, VT. In many cases, we continue to converse with these companies, especially through ECNE, where we routinely discuss best practices and share information on customer care with peers.

Our research and discussions about customer care practices at these companies, most notably through ECNE and with BCBS and SMECO, along with analysis of data on call volume and timing, reinforced ideas GMP was already considering or implementing, and provided new insights on how we could systematically improve customer satisfaction and service.

Our efforts to significantly improve customer service and satisfaction began with creating a customer-obsessed culture at GMP and redoubling our focus on data collection and analysis, increasing self-service functions, decreasing call volume and improving customer satisfaction. As noted in my prefiled testimony, we have worked hard to drive a customer obsession throughout the company.

While the resulting work we did is discussed at a high level in my prefiled testimony, below is a brief synopsis of key Customer Care changes we have made and processes we have improved as a result of these discussions and data analysis. Key actions include:



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• Developed improved CSR measures and raised the bar on many of our performance measures. We began providing data regarding CSR performance to the CSRs in a weekly report that includes off-phone time, handling time, number of transfers, number of calls answered, abandoned calls, and schedule adherence. The data compares CSRs in various categories and shows where each CSR ranks on each measure.

• Using that refocused collection and analysis of call center data, we were able to improve and focus ongoing coaching to address individual improvement opportunities. This detailed and ongoing training improves individual and team performance.

• Created a critical care team to enhance customer service on a handful of key high-volume days each year to improve peak period performance. This team consists of a variety of employees including officers. Individuals on the team are asked to help cover peak phone periods a few times a year, such as a handful of Mondays in certain months, days after holidays, etc. This group includes people who are available occasionally for a few hours or even a day to help out.

• Improved our internal storm backup team for customer care. We identified and trained several dozen people, many of them members of the critical care team mentioned above, to help answer phones when needed to ensure high-quality service and satisfaction during storm/outage situations.

• Replaced our outage overflow vendor with RDI, which has a Vermont call center capable of handling not only after-hours outage calls but can also quickly add support during business hours for expected or even unexpected high-volume periods. RDI has significantly outperformed the previous vendor.

• Moved a couple of time-consuming processes that used to routinely require CSRs to log out of phone queues, such as the handling of customer bankruptcies and claims, away from traditional CSR roles to other departments and staff. This has allowed CSRs to better focus on the customers who present an immediate need.

• Expanded customer self-service options via the website, texting and the integrated voice response (IVR) phone system to reduce call volume, expand customer service in many cases to a 24/7 model, and allow customers to choose how to conduct business with us. This is a continual process, with the IT and Customer Care teams collaborating on the expansion of self-service functionality.



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• Added an in-person customer payment option at the Rutland Operations Headquarters.

• Piloted and implemented outbound courtesy calls to some customers who are past due.

• Reviewed and made adjustments to our IVR system to improve functionality and customers’ experiences.

• Increased our focus on eBill and recurring payment options to increase participation and reduce customer call volume.




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DPS1.Q144. Please refer to Page 10, Lines 3–5 of the April 14, 2017 prefiled direct testimony of Steve Costello. Please describe any costs that were achieved by reducing GMP’s CSR team by 8 full time employee positions.

These savings have resulted in lower O&M expenses than would otherwise have been incurred. These savings have resulted in greater synergies, which flow back to customers.




Page 200 of 202

DPS1.Q145. Please refer to Pages 8–9, Lines 19–2 of the April 14, 2017 prefiled direct testimony of Steve Costello. With respect to payment arrangements made by Community Action Agencies (“CAAs”) by GMP customers through a web portal, please state the following:

a. Are CAA’s able to specify the amounts and dates for the payments their clients will make?

b. Alternatively, are CAAs given a range of amounts and/or dates to choose from?

c. Are CAAs able to set up extended (e.g., 12-month) payment arrangements through the web portal?

d. Can GMP propose a different payment arrangement than the one proposed by the CAA through the web portal?

e. Can GMP decline to accept a payment arrangement offered through the web portal?

f. If so, how would the CAA/customer be notified of this? g. Once established, how does the payment arrangement get entered into the

customer’s account record and/or GMP’s billing system? h. Can customers access their web portal to establish their own payment

arrangements?

This request reflects a possible misunderstanding about what can be done through the portal. The portal allows the CAA to obtain customer information (with the consent of the customer) and discuss that information with the customer before ever calling GMP. In the past, the CAA would typically call GMP with the customer on the phone and obtain the pertinent information (which is now available through the portal) from the CSR in a lengthy three-way conversation. The CAA would then have a private conversation with the customer and then place a second call to GMP to make a payment commitment, seek a payment arrangement, or both, on the customer’s behalf. The new web portal eliminates the need for the first call, and even a second call is often avoided because the CAAs often correspond with GMP via email now.

In his testimony, Mr. Costello meant to convey that the CAA can view the customers’ bills, and disconnect notices, clarify the situation, discuss and make commitments to the customer without ever speaking to a CSR through the portal. In the referenced portion of his testimony, however, Mr. Costello inadvertently omitted the words “to the customer.” The portal does not allow the CAA to actually make a payment arrangement with GMP without contacting



Page 201 of 202

GMP directly. With this clarification, we believe that questions (a) through (g) are moot. As for question (h), the answer is no. The portal is only available to CAA staff at this time. However, customers have the ability, by logging into their own account on our website, to create payment arrangements.




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Dated at Burlington, Vermont this 20th day of June, 2017.

As to Objections:

Geoffrey H. Hand, Esq. Victoria M. Westgate, Esq. Dunkiel Saunders Elliott Raubvogel & Hand, PLLC 91 College Street Burlington, VT 05402 (802) 860 – 1003 [email protected] [email protected] Attorneys for Green Mountain Power

mailto:[email protected]

mailto:[email protected]

Respondent Signature

By: Scott Anderson

Case No. 17-3112-INV Petitioner Green Mountain Power's

Responses to DPS First Set of Discovery Requests

i.\ , Vermont thislS_ day of June, 2017.

Green Mountain Power

Subscribed and sworn before me this Jq ·~y of June, 2017.

Notary Public

NameofNotary: MvlLSSC, 51-CV&V'-J

Commission Expires: 2-10-19



Vermont this />~ay of June, 2017.

Subscribed and sworn before me this d \iay of June, 2017.

NotaryPbi c

NameofNotary: ~ v1,,,_~1 CJ \,nc., I




Dated at _ _,_,f<....,..,,A"--'± ....... \=an ...... ~.......__ ___ , Vermont this \l/'aay of June, 2017.


By ~J:ui:/3~ ( ~ , tsy s1oom~r \j!ireen Mountain Power

Subscribed and sworn before me this ~ day of June, 2017.


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By: Du, .. ~ Dawn Bugbee Green Mountain Power

Subscribed and sworn before me this ~day of June, 2017.

£~':ft, I C L L Notary P~ lit

Name of Notary: E.rn,, C /lir,s I


--------Bated at C, /1 /cut..,


By: Mike Burke



'eJ't11:eE1.t tlri fr'1la:y ef-June, 2Gl-7-:-. -----------


Subscribed and sworn before me this /5'111day of June, 2017.

Notary P ilc Name of Notary: .J2.ol\y Cu J/ir1J


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Subscribed and sworn before me this /;L_'day of June, 2017.

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Name of Notary: rl~, Cl!,,i\ I


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Dated at ~,tel> ,l6 68/7 ~ , Vermont this/b-ftday ofJune, 2017.


By: Steve Costello Green Mountain Power

ft-. Subscribed and sworn before me this / h day of June, 2017.

NameofNotary: Jospp/ fi~K7~




Dated at /1bAI r PG C.... 1 ,E ~ Vermont this £~/·"'day of June, 2017.

Respondent Signatut·c


Subscribed and sworn before me this_ day of June, 2017.

~~~ Notary Public

Name of Notary:Z.c b.c.,y c_ u.....-.. '1 Commission Expires: 2-10-19



Dated at Marlborough, Massachusetts this 15th day of June, 2017.


By: ~~~ ~ oyne

Concentric Energy Advisors, Inc.

Subscribed and sworn before me this 15th day of June, 2017.

;;:/~$~ ~ Puhl'~ ~ LAUREEN G. SASSEVILLE N f N t IDI Notary Publlc

ame o o ary: COMMONWEALTH OF MASIA,CHUIETTI Mv commlAlon &pl,..

Commission E:x.pir · : October 1e, 2023



\ +h Dated at --~~~~~~<l\,;~w~\~----' Vermont this~ day of June, 2017.


By:


Subscribed and sworn before me this /r;/~.ay of June, 2017.

Name of Notary;


Dated at /;./LMI()


By:



,r,-. , Vermont this _LJday of June, 2017.

Subscribed and sworn before me this /0~ay of June, 2017.

~1~ .. Name of Notary: Jb:5,1) e) .,Af 7~ Y?A.J

Commission Expires: 2-10-19 /



Dated at Colchester, Vermont this 16th day of June, 2017.


By:

. // _z#?Yf/~--~· Mari McClure Green Mountain Power


Notary ubl1c

Name ofNotary: Penny J. Collins




Dated at Colchester, Vermont this 16th day of June, 2017.


By: Brian Otley Green Mountain Power


fl .... t I C i,L Notary Pu ljc

Name of Notary: Penny J. Collins




Dated at _~~_V:_72_17,_W~()~--' Vermont this /.6"1ay of June, 2017.


By: Edmund Ryai; Green Mountain Power

Subscribed and sworn before me this /b ~ay of June, 2017.

~~ ~ic 7

,

NameofNotary: Jt:J.spp/, ~Y~Yf,,&




I __ ,-JJ, Vermont this~ day of June, 2017.


By: ! i;:l~ Kirk Shields Green Mountain Power

Subscribed and sworn before me thio/'s:'4day of June, 2017.

~-:::(µ64--Name of Notary: Jt,i/f 11,,t £ .,k~()IU.rk-, r




, Vem1on n 1.1y1rf JLme 201""'1-. -----------


By: 0~~-~ DouglasSmith Green Mountain Power

Subscribed and sworn before me this ..L.5!._'1Jay of June, 2017.

£., ,,,, I Cl& Notary Publ ic}

Name of Notary: ? r i (\ ,., C 1/,J]j I




Dated at ~£~0_·_+(~0-_'v_ .. _cl~~---'' Vermont this ( b ~ ay of June, 2017.

Charles "Chuck" Watts Green Mountain Power

Subscribed and sworn before me this l& ~ ay of June, 2017.

Name ofNotary:ooµµi,e ~.o(2f)uµ,6




Dated at -~/__v!Z,~_r-!~Al.~t) __ ~, Vermont this 4i Aaay of June, 2017.


By:

Subscribed and sworn before me this /6 ~ay of June, 2017.

iaryublic Name ofNotary: Jost>ej fic/f.i,tr;~



Case No. 17-3112-INV

Investigation into Green Mountain Power Corporation’s tariff filing requesting an overall rate increase in the amount of 4.98%, to take effect January 1, 2018

) ) ) )

LIST OF DOCUMENTS PRODUCED

ROUND 1 DPS DISCOVERY RESPONSES

June 20, 2017

ROUND QUESTION DOCUMENT DPS1 1 Attachment GMP.DPS1.Q1.1_Exhibit Package DPS1 1 Attachment GMP.DPS1.Q1.2_Stock Prices, Bond Prices, Dividend

Yields DPS1 1 Attachment GMP.DPS1.Q1.3_Value Line DPS1 1 Attachment GMP.DPS1.Q1.4_Yahoo! Finance DPS1 1 Attachment GMP.DPS1.Q1.5_Bloomberg Betas DPS1 1 Attachment GMP.DPS1.Q1.6_Blue Chip Financial Forecast, Vol. 35,

No. 12, December 1, 2016 DPS1 1 Attachment GMP.DPS1.Q1.7_RRA Rate Case Statistics (Protected) DPS1 1 Attachment GMP.DPS1.Q1.8_Bloomberg Quarterly Bond Yields DPS1 1 Attachment GMP.DPS1.Q1.9_Blue Chip Financial Forecasts Vol. 36,

No. 3, March 1, 2017 DPS1 1 Attachment GMP-DPS1.Q1.10_Bloomberg Market Capitalizations DPS1 1 Attachment GMP-DPS1.Q1.11_GMP FERC Form 1 DPS1 1 Attachment GMP.DPS1.Q1.12_Market to Book Ratio of Valener DPS1 1 Attachment GMP.DPS1.Q1.13_RRA Rank by State DPS1 1 Attachment GMP.DPS1.Q1.14_Capital Structure Analyses

(Protected) DPS1 1 Attachment GMP.DPS1.Q1.15_Bloomberg Dividend Yield Analysis

(Figure 1) DPS1 1 Attachment GMP.DPS1.Q1.16_S& P Utilities vs. U.S. Treasury

Bond Yields Analysis (Figure 2) DPS1 1 Attachment GMP.DPS1.Q1.17_Utility PE Ratios Analysis (Figures

3) DPS1 2 Attachment GMP.DPS1.Q2.1 DPS1 2 Attachment GMP.DPS1.Q2.2 DPS1 2 Attachment GMP.DPS1.Q2.3 DPS1 3 Attachment GMP.DPS1.Q3.1_(2015) DPS1 3 Attachment GMP.DPS1.Q3.2_(2016)

ROUND QUESTION DOCUMENT DPS1 3 Attachment GMP.DPS1.Q3.3_(DBRS 2015) DPS1 3 Attachment GMP.DPS1.Q3.4_(DBRS 2016) DPS1 4 Attachment GMP.DPS1.Q4.1_VPSB Order Docket No. 8190 (Aug.

25, 2014) DPS1 4 Attachment GMP.DPS1.Q4.2_BEA Table 1.1.5 Nominal GDP (Jan.

27, 2017) DPS1 4 Attachment GMP.DPS1.Q4.3_BEA Table 1.1.6 Real GDP (January

27, 2017) DPS1 4 Attachment GMP.DPS1.Q4.4_ Blue Chip Economic Indicators,

Volume 42, No. 3, (March 10, 2017) DPS1 4 Attachment GMP.DPS1.Q4.5_Bureau of Labor Statistics, Table A-10

(March 16, 2017) DPS1 4 Attachment GMP.DPS1.Q4.6_FOMC Meeting Transcript (December

14, 2016) DPS1 4 Attachment GMP.DPS1.Q4.7_FOMC Press Conference Transcript

(March 15, 2017) DPS1 4 Attachment GMP.DPS1.Q4.8_FOMC Federal Reserve Press Release

(March 15, 2017) DPS1 4 Attachment GMP.DPS1.Q4.9_ Value Line Investment Survey,

Electric Utility (Central) Industry, (December 16, 2016) DPS1 4 Attachment GMP.DPS1.Q4.10_ Federal Open Market Committee,

Policy Normalization Principles and Plans, (September 16, 2014) DPS1 4 Attachment GMP.DPS1.Q4.11_ Remarks by Stanley (March 23,

2015) DPS1 4 Attachment GMP.DPS1.Q4.12_Ben Schiller, Fast Company, In

Vermont, A forward-Thinking Utility is Helping Customers Share Solar Power ( September 21, 2015)

DPS1 4 Attachment GMP.DPS1.Q4.13_S& P (December 15, 2016) DPS1 4 Attachment GMP.DPS1.Q4.14_Eugene F Brigham and Joel F

Houston, Fundamentals of Financial Management (Concise Fourth Edition, Thomson South-Western)

DPS1 4 Attachment GMP.DPS1.Q4.15_ Harris and Marston, Estimating Shareholder Risk Premia Using Analysts Growth Forecasts, Financial Management, Summer 1992

DPS1 4 Attachment GMP.DPS1.Q4.16_Vander Weide and Carleton Investor Growth Expectations_Analysts vs History The Journal of Portfolio Management Spring 1988

DPS1 4 Attachment GMP.DPS1.Q4.17_155 FERC 63,030 (June 30 2016) DPS1 4 Attachment GMP.DPS1.Q4.18_Moodys Investors Service Regulated

Electric and Gas Utilities (Dec. 23 2013) DPS1 4 Attachment GMP.DPS1.Q4.19_ Gideon Weissman, Frontier Group

and Bret Fanshaw and Rob Sargent, Environment America Research & Policy Center, Lighting the Way 4 _ (July 2016)

DPS1 4 Attachment GMP.DPS1.Q4.20_Roger A Morin, New Regulatory Finance, Public Utility Reports, Inc 2006

ROUND QUESTION DOCUMENT DPS1 5 Attachment GMP.DPS1.Q5_Proxy Selection DPS1 7 Attachment GMP.DPS1.Q7 DPS1 8 Attachment GMP.DPS1.Q8 DPS1 9 Attachment GMP.DPS1.Q9.d DPS1 9 Attachment GMP.DPS1.Q9.e.1_rate year DPS1 9 Attachment GMP.DPS1.Q9.e.2_test year DPS1 12 Attachment GMP.DPS1.Q12.a-e DPS1 12 Attachment GMP.DPS1.Q12.k.1_additions DPS1 12 Attachment GMP.DPS1.Q12.k.2_retirements DPS1 16 Attachment GMP.DPS1.Q16 DPS1 17 Attachment GMP.DPS1.Q17.a DPS1 17 Attachment GMP.DPS1.Q17.b DPS1 17 Attachment GMP.DPS1.Q17.c DPS1 18 Attachment GMP.DPS1.Q18 DPS1 19 Attachment GMP.DPS1.Q19.1_2015 Capital DPS1 19 Attachment GMP.DPS1.Q19.2_2016 Capital DPS1 19 Attachment GMP.DPS1.Q19.3_2017 Capital DPS1 24 Attachment GMP.DPS1.Q24.1 DPS1 24 Attachment GMP.DPS1.Q24.2 DPS1 25 Attachment GMP.DPS1.Q25 DPS1 29 Attachment GMP.DPS1.Q29 DPS1 30 Attachment GMP.DPS1.Q30 DPS1 31 Attachment GMP.DPS1.Q31.1_Multi-Year Capital Work Plan DPS1 31 Attachment GMP.DPS1.Q31.2_T& D Integrated Resource Plan DPS1 31 Attachment GMP.DPS1.Q31.3_PSB Rule 4.900 Electricity Outage

Report DPS1 31 Attachment GMP.DPS1.Q31.4_Rutland Area Reliability Plan DPS1 31 Attachment GMP.DPS1.Q31.5_Hinesburg Area Reliability Plan DPS1 31 Attachment GMP.DPS1.Q31.6_2015 Vermont Long Range

Transmission Plan DPS1 31 Attachment GMP.DPS1.Q31.7_VSPC Annual Report for 2013 DPS1 31 Attachment

GMP.DPS1.Q31.8_2014_GMP_IRP_Innovation_Chapter_113014_Clean_& _Final

DPS1 31 Attachment GMP.DPS1.Q31.9_VSPC Annual Report for 2015 DPS1 31 Attachment GMP.DPS1.Q31.10_VSPC Annual Report for 2016 DPS1 39 Attachment GMP.DPS1.Q39 DPS1 42 Attachment GMP.DPS1.Q42 DPS1 43 Attachment GMP.DPS1.Q43_5 Year Projects DPS1 44 Attachment GMP.DPS1.Q44.1_GMP SQ 2012 DPS1 44 Attachment GMP.DPS1.Q44.2_GMP SQ 2013 DPS1 44 Attachment GMP.DPS1.Q44.3_GMP SQ 2014 DPS1 44 Attachment GMP.DPS1.Q44.4_GMP SQ 2015 DPS1 44 Attachment GMP.DPS1.Q44.5_GMP SQ 2016

ROUND QUESTION DOCUMENT DPS1 44 Attachment GMP.DPS1.Q44.6_GMP SQ 2017 Q1 DPS1 44 Attachment GMP.DPS1.Q44.7_Daily Outage Stat 2013 DPS1 44 Attachment GMP.DPS1.Q44.7_Daily Outage Stat 2013 - Excel DPS1 44 Attachment GMP.DPS1.Q44.8_Daily Outage Stat 2014 DPS1 44 Attachment GMP.DPS1.Q44.8_Daily Outage Stat 2014 - Excel DPS1 44 Attachment GMP.DPS1.Q44.9_Daily Outage Stat 2015 DPS1 44 Attachment GMP.DPS1.Q44.9_Daily Outage Stat 2015 - Excel DPS1 44 Attachment GMP.DPS1.Q44.10_Daily Outage Stat 2016 DPS1 44 Attachment GMP.DPS1.Q44.10_Daily Outage Stat 2016 - Excel DPS1 44 Attachment GMP.DPS1.Q44.11_Daily Outage Stat 2017 DPS1 44 Attachment GMP.DPS1.Q44.11_Daily Outage Stat 2017 - Excel DPS1 46 Attachment GMP.DPS1.Q46.1_PSB Rule 4 900 Outage Data - 2012

- North DPS1 46 Attachment GMP.DPS1.Q46.2_PSB Rule 4 900 Outage Data - 2012

- South DPS1 46 Attachment GMP.DPS1.Q46.3_PSB Rule 4 900 Outage Data - 2013 DPS1 46 Attachment GMP.DPS1.Q46.4_PSB Rule 4 900 Outage Data - 2014 DPS1 46 Attachment GMP.DPS1.Q46.5_PSB Rule 4 900 Outage Data - 2015 DPS1 46 Attachment GMP.DPS1.Q46.6_PSB Rule 4 900 Outage Data - 2016 DPS1 49 Attachment GMP.DPS1.Q49 DPS1 50 Attachment GMP.DPS1.Q50_Outages by Feeder DPS1 53 Attachment GMP.DPS1.Q53 DPS1 54 Attachment GMP.DPS1.Q54.1 DPS1 54 Attachment GMP.DPS1.Q54.2 DPS1 55 Attachment GMP.DPS1.Q55 DPS1 60 Attachment GMP.DPS1.Q60_New Generating Resources DPS1 62 Attachment GMP.DPS1.Q62_Historic Capacity Requirements DPS1 64 Attachment GMP.DPS1.Q64_Current Load Forecast DPS1 65 Attachment GMP.DPS1.Q65 DPS1 66 Attachment GMP.DPS1.Q66.1_2011 NextEra Seabrook PPA DPS1 66 Attachment GMP.DPS1.Q66.2_2015 contract amendment DPS1 66 Attachment GMP.DPS1.Q66.3_one-year capacity purchase DPS1 72 Attachment GMP.DPS1.Q72_Forward Prices DPS1 75 Attachment GMP.DPS1.Q75_Solar Contribution DPS1 76 Attachment GMP.DPS1.76.1 DPS1 76 Attachment GMP.DPS1.76.2 DPS1 77 Attachment GMP.DPS1.Q77 DPS1 78 Attachment GMP.DPS1.Q78 DPS1 83 Attachment GMP.DPS1.Q83.1_Hartland Option to Lease DPS1 83 Attachment GMP.DPS1.Q83.2_Weathersfield Option to Lease DPS1 83 Attachment GMP.DPS1.Q83.3_Newbury Option to Purchase DPS1 83 Attachment GMP.DPS1.Q83.4_Limited Scope Retention DPS1 83 Attachment GMP.DPS1.Q83.5_Limited Scope Retention - Extension DPS1 85 Attachment GMP.DPS1.Q85

ROUND QUESTION DOCUMENT DPS1 87 Attachment GMP.DPS1.Q87 DPS1 97 Attachment GMP.DPS1.Q97 DPS1 108 Attachment GMP.DPS1.Q108 DPS1 112 Attachment GMP.DPS1.Q112_Standard Offer Projection DPS1 116 Attachment GMP.DPS1.Q116.1 DPS1 116 Attachment GMP.DPS1.Q116.2 DPS1 116 Attachment GMP.DPS1.Q116.3 DPS1 116 Attachment GMP.DPS1.Q116.4 DPS1 120 Attachment GMP.DPS1.Q120 DPS1 121 Attachment GMP.DPS1.Q121 (Protected) DPS1 136 Attachment GMP.DPS1.Q136.b.1 DPS1 136 Attachment GMP.DPS1.Q136.b.2 DPS1 138 Attachment GMP.DPS1.Q138.a DPS1 142 Attachment GMP.DPS1.Q142

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