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STATE OF SOUTH CAROLINA Application of Duke Energy Carolinas, LLC for Approval of Energy Efficiency Plan Including an Energy Efficiency Rider and Portfolio of Energy Efficiency Programs. ) ) BEFORE THE ) PUBLIC SERVICE COMMISSION ) OF SOUTH CAROLINA ) ) COVER SHEET ) ) ) DOCKET ) NUMBER: 2007-358-E ) ) ) (Please type or print) Submitted by: Bonnie D. Sheal Address: Robinson, McFadden & Moore, P.C. PO Box 944 Columbia, SC 29202 SC Bar Number: 11125 Telephone: 803) 779-8900 Fax: Other: 803 252-0724 Email:bsheal robinsonlaw. corn NOTE: The cover sheet and information contained herein neither replaces nor supplements the filing and service of pleadings or other papers as required by law, This form is required for use by the Public Service Commission of South Carolina for the purpose of docketing and must be filled out completely. DOCKETING INFOMIATION (Check all that apply) Emergency Relief demanded in petition Request for item to be placed on Commission's Agenda expeditiously H Other: INDUSTRY {Check one) NATURE OF ACTION {Check all that apply) H Electric Electric/Gas Electric/Telecommunications Q Electric/Water Electric/Water/Telecom. Q Electric/Water/Sewer Q Gas Q Railroad Q Sewer Telecommunications Q Transportation Q Water Q Water/Sewer Q Administrative Matter Other: Affidavit Q Agreement Q Answer Q Appellate Review g Application Q Brief Q Certificate g Comments Q Complaint Q Consent Order g Discovery Q Exhibit Expedited Consideration Q Interconnection Agreement Q Interconnection Amendment Late-Filed Exhibit Letter Memorandum H Motion Q Objection Q Petition Q Request g Request for Certificatio Request for Investigatior Q Resale Agreement Resale Amendment Q Petition for Rulemaking Q Petition for Rule to Show Cause Petition to Intervene Petition to Intervene Out of Time Q Prefiled Testimony Promotion Proposed Order Q Protest Publisher's Affidavit Report Response Q Response to Discovery Return to Petition Stipulation Subpoena Q Tariff H Other; Testimony of Janice D. Hager Q Petition for Reconsideration Reservation Letter STATE OF SOUTH CAROLINA ) ) BEFORE THE ) PUBLIC SERVICE COMMISSION ) OF SOUTH CAROLINA Application of ) ) COVER SHEET Duke Energy Carolinas, LLC for Approval of Energy Efficiency Plan Including ) an Energy Efficiency Rider and Portfolio of Energy ~ DOCKET Efficiency Programs. ) NUMBER: 2007-358-E ) ) ) (Ilease type or print) Submitted by: Bonnie D. Shealy SC Bar Number: 11125 Address: Robinson, McFadden & Moore, P.C. Telephone: j~3) 779-8900 P0 Box 944 Columbia, SC 29202 Fax: (803) 252-0724 _____________________________________ Other: ___________________________________ Email: [email protected] NOTE: The cover sheet and information contained herein neither replaces nor supplements the filing and service of pleadings or other papers as required by law. This form is required for use by the Public Service Commission of South Carolina for the purpose of docketing and must be filled out completely. DOCKETING INFORMATION (Check all that apply) ~ Emergency Relief demanded in petition L1J Request for item to be placed on Commission’s Agenda expeditiously ~ Other: INDUSTRY (Check one) 1 L NATURE OF ACTION (Check all that apply) ~ Electric fl Affidavit ~ Letter []Request LI Electric/Gas ~ Agreement LI Memorandum ~ Request for Certificatie LI Electric/Telecommunications ~ Answer ~ Motion LI Request for Investigatior LI Electric/Water [I] Appellate Review fl Objection LI Resale Agreement [I] Electric/Water/Telecom. LI Application [] Petition LI Resale Amendment L] Electric/Water/Sewer (~ Brief LI Petition for Reconsideration [J Reservation Letter [I] Gas fl Certificate ~ Petition for Rulemaking []Response LI Railroad ~ Comments LI Petition for Rule to Show Cause LI Response to Discovery ~ Sewer LI Complaint LI Petition to Intervene [~ Return to Petition O Telecommunications ~ Consent Order ~ Petition to Intervene Out of Time ~ Stipulation ~ Transportation ~ Discovery D Prefiled Testimony ~J Subpoena ~ Water ~ Exhibit ~ Promotion LI Tariff fl Expedited Consideration ~ Proposed Order ~ Other: Testimony of LI Water/Sewer Janice D, Hager LI Adn~umstrativeMatter fl Interconnection Agreement [J Protest ~ Other: [J ~ Amendment O Publisher’s Affidavit fl Late-Filed Exhibit []Report

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Page 1: 1 L - dms.psc.sc.gov

STATE OF SOUTH CAROLINA

Application of

Duke Energy Carolinas, LLCfor Approval of Energy Efficiency Plan Includingan Energy Efficiency Rider and Portfolio of EnergyEfficiency Programs.

)) BEFORE THE) PUBLIC SERVICE COMMISSION) OF SOUTH CAROLINA)) COVER SHEET))) DOCKET) NUMBER: 2007-358-E)))

(Please type or print)

Submitted by: Bonnie D. Sheal

Address: Robinson, McFadden & Moore, P.C.PO Box 944Columbia, SC 29202

SC Bar Number: 11125Telephone: 803) 779-8900

Fax:Other:

803 252-0724

Email:bsheal robinsonlaw.

corn

NOTE: The cover sheet and information contained herein neither replaces nor supplements the filing and service of pleadings or other papers

as required by law, This form is required for use by the Public Service Commission of South Carolina for the purpose of docketing and must

be filled out completely.

DOCKETING INFOMIATION (Check all that apply)

Emergency Relief demanded in petition Request for item to be placed on Commission's Agenda expeditiously

H Other:

INDUSTRY {Check one) NATURE OF ACTION {Check all that apply)

H Electric

Electric/Gas

Electric/Telecommunications

Q Electric/Water

Electric/Water/Telecom.

Q Electric/Water/Sewer

Q Gas

Q Railroad

Q Sewer

Telecommunications

Q Transportation

Q Water

Q Water/Sewer

Q Administrative Matter

Other:

Affidavit

Q Agreement

Q Answer

Q Appellate Review

g Application

Q Brief

Q Certificate

g Comments

Q Complaint

Q Consent Order

g Discovery

Q Exhibit

Expedited Consideration

Q Interconnection Agreement

Q Interconnection Amendment

Late-Filed Exhibit

Letter

Memorandum

H Motion

Q Objection

Q Petition

Q Request

g Request for Certificatio

Request for Investigatior

Q Resale Agreement

Resale Amendment

Q Petition for Rulemaking

Q Petition for Rule to Show Cause

Petition to Intervene

Petition to Intervene Out of Time

Q Prefiled Testimony

Promotion

Proposed Order

Q Protest

Publisher's Affidavit

Report

Response

Q Response to Discovery

Return to Petition

Stipulation

Subpoena

Q Tariff

H Other; Testimony of

Janice D. Hager

Q Petition for Reconsideration Reservation Letter

STATE OF SOUTH CAROLINA )) BEFORE THE) PUBLIC SERVICE COMMISSION) OF SOUTH CAROLINA

Application of )) COVER SHEET

Duke Energy Carolinas, LLCfor Approval ofEnergy Efficiency Plan Including )an Energy Efficiency Rider and Portfolio of Energy ~ DOCKETEfficiency Programs. ) NUMBER: 2007-358-E

)))

(Ileasetype or print)

Submitted by: Bonnie D. Shealy SC Bar Number: 11125Address: Robinson,McFadden & Moore, P.C. Telephone: j~3)779-8900

P0Box 944Columbia, SC 29202 Fax: (803)252-0724_____________________________________Other: ___________________________________

Email: [email protected]: Thecoversheetandinformationcontainedhereinneitherreplacesnor supplementsthefiling andserviceof pleadingsor otherpapers

asrequiredby law. This form isrequiredfor useby thePublicServiceCommissionof SouthCarolinafor thepurposeof docketingandmust

befilled out completely.

DOCKETINGINFORMATION (Checkall that apply)

~ EmergencyRelief demandedin petition L1J Requestfor item to be placedon Commission’sAgendaexpeditiously

~ Other:

INDUSTRY (Checkone) 1 L NATURE OF ACTION (Checkall that apply)

~ Electric fl Affidavit ~ Letter []Request

LI Electric/Gas ~ Agreement LI Memorandum ~ Requestfor Certificatie

LI Electric/Telecommunications ~ Answer ~ Motion LI Requestfor Investigatior

LI Electric/Water [I] AppellateReview fl Objection LI ResaleAgreement

[I] Electric/Water/Telecom. LI Application [] Petition LI ResaleAmendment

L] Electric/Water/Sewer (~Brief LI Petitionfor Reconsideration [J ReservationLetter

[I] Gas fl Certificate ~ Petitionfor Rulemaking []Response

LI Railroad ~ Comments LI Petitionfor Ruleto ShowCause LI Responseto Discovery

~ Sewer LI Complaint LI Petitionto Intervene [~Returnto Petition

O Telecommunications ~ ConsentOrder ~ PetitiontoInterveneOut ofTime ~ Stipulation

~ Transportation ~ Discovery D PrefiledTestimony ~JSubpoena

~ Water ~ Exhibit ~ Promotion LI Tariff

fl ExpeditedConsideration ~ ProposedOrder ~ Other: TestimonyofLI Water/Sewer

JaniceD, Hager

LI Adn~umstrativeMatter fl InterconnectionAgreement [J Protest

~ Other: [J~ Amendment O Publisher’sAffidavit

fl Late-FiledExhibit []Report

Page 2: 1 L - dms.psc.sc.gov

BEFORE

THE PUBLIC SERVICE COMMISSION OF

SOUTH CAROLINA

DOCKET NO. 2007-358-E

In re:Application of Duke Energy Carolinas, LLCFor Approval of Energy Efficiency Plan

Including an Energy Efficiency Rider and

Portfolio of Energy Efficiency Programs

)) TESTIMONY OF) JANICE D. HAGER FOR) DUKE ENERGY CAROLINAS

))

This document is an exact duplicate, with theexception of the form of the signature, of thee-filed copy submitted to the Commission in

accordance with its electronic filing instructions.

BEFORE

THE PUBLIC SERVICE COMMISSIONOF

SOUTH CAROLINA

DOCKETNO. 2007-358-E

Inre: )Applicationof DukeEnergyCarolinas,LLC ) TESTIMONY OFForApprovalofEnergyEfficiencyPlan ) JANICE D. HAGERFORIncludingan EnergyEfficiencyRiderand ) DUKE ENERGYCAROLINASPortfolio ofEnergyEfficiencyPrograms )

)

This documentis anexactduplicate,with theexceptionof the form of the signature,of thee-filed copysubmittedto the Commissioninaccordancewith its electronicfiling instructions.

Page 3: 1 L - dms.psc.sc.gov

I. INTRODUCTION AND PURPOSE

2 Q. PLEASE STATE YOUR NAME, ADDRESS AND POSITION WITH DUKE

ENERGY CORPORATION.

4 A. My name is Janice D. Hager. My business address is 526 South Church Street,

10

Charlotte, North Carolina. I am Managing Director, Integrated Resource

Planning and Environmental Strategy for Duke Energy Corporation's ("Duke

Energy" ) operating utilities, including Duke Energy Carolinas, LI.C ("Duke

Energy Carolinas" or the "Company" ). I have held a number of different

responsibilities in my 26 years at Duke Energy, including Vice President, Rates

and Regulatory Affairs for Duke Energy Carolinas.

11 Q. WHAT ARE YOUR JOB RESPONSIBILITIES?

12 A, I have responsibility for integrated resource planning and envirorunental

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compliance planning for Duke Energy Corporation's regulated electric utilities.

In that role, I have responsibility for the long-term resource planning for Duke

Energy's Carolinas and Midwest operations, as well as planning for

environmental compliance. Duke Energy's long-range resource planning process

is conducted separately for each of the operating utilities.

18 Q. PLEASE SUMMARIZE YOUR EDUCATIONAL BACKGROUND AND

19 PROFESSIONAL EXPERIENCE.

20 A. I am a civil engineer, having received a Bachelor of Science in Engineering from

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the University of North Carolina at Charlotte. I began my career at Duke Power

Company in 1981 and have had a variety of responsibilities across the Company

in areas of piping analyses, nuclear station modifications, new generation

Direct Testimony: JAIvtcE D. HAGER

Duke Energy Carolinas, LLCPSCSC Docket No. 2007-358-E

1 I. INTRODUCTION AND PURPOSE

2 Q. PLEASE STATE YOUR NAME, ADDRESS AND POSITION WITH DUKE

3 ENERGY CORPORATION.

4 A. My nameis JaniceD. Hager. My businessaddressis 526 SouthChurch Street,

5 Charlotte, North Carolina. I am Managing Director, Integrated Resource

6 Planning and EnvironmentalStrategyfor Duke Energy Corporation’s (“Duke

7 Energy”) operatingutilities, including Duke Energy Carolinas, LLC (“Duke

8 Energy Carolinas” or the “Company”). I have held a number of different

9 responsibilitiesin my 26 years at Duke Energy, including Vice President,Rates

10 andRegulatoryAffairs for DukeEnergyCarolinas.

11 Q. WHAT ARE YOUR JOB RESPONSIBILITIES?

12 A. I have responsibility for integrated resource planning and environmental

13 complianceplanning for Duke EnergyCorporation’sregulatedelectric utilities.

14 In that role, I haveresponsibilityfor the long-termresourceplanning for Duke

15 Energy’s Carolinas and Midwest operations, as well as planning for

16 environmentalcompliance. DukeEnergy’s long-rangeresourceplanningprocess

17 is conductedseparatelyfor eachoftheoperatingutilities.

18 Q. PLEASE SUMMARIZE YOUR EDUCATIONAL BACKGROUND AND

19 PROFESSIONAL EXPERIENCE.

20 A. I ama civil engineer,having receivedaBachelorof Sciencein Engineeringfrom

21 theUniversity of NorthCarolinaat Charlotte. I beganmy careerat DukePower

22 Companyin 1981 andhavehad a varietyofresponsibilitiesacrossthe Company

23 in areas of piping analyses,nuclear station modifications, new generation

Direct Testimony: JANICE D. HAGER 2DukeEnergy Carolinas, LLC -

PSCSCDocketNo. 2007-358-E

Page 4: 1 L - dms.psc.sc.gov

licensing, rates, and regulatory affairs, I am a registered Professional Engineer in

North Carolina and South Carolina.

3 Q. HAVE YOU PREVIOUSLY TESTIFIED BEFORE THIS COMMISSION?

4 A. Yes. I have testified before the Public Service Commission of South Carolina

(the "Commission" ) on several prior occasions, including past annual fuel cost

proceedings and a proceeding on the utility process for consideration of capacity

alternatives.

8 Q. WHAT IS THE PURPOSE OF YOURTESTIMONY?

9 A, The purpose of my testimony is to discuss the need for new capacity outlined in

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12

the Company's 2007 Integrated Resource Plan filed on November 15, 2007 in

Docket No. 87 —223 —E ("IRF' or the "Annual Plan" ) and how energy

efficiency' is reflected in the integrated planning resource models.

13 II. CAPACITY NEEDS IDENTIFIED IN THE COMPANY'S ANNUAL PLAN

14 Q. PLEASE DESCRIBE THE PURPOSE OF COMPANY'S ANNUAL PLAN?

15 A. Duke Energy Carolinas' Annual Plan is developed with the objective of meeting

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customers' needs for a highly reliable energy supply at the lowest reasonable cost,

Annually, Duke Energy Carolinas develops a resource plan for meeting

customers' energy needs, which considers a combination of: (i) existing purchase

power contracts, (ii) existing and new generation, and (iii) customer energy

efficiency options. The Annual Plan is filed with the Commission and the North

Carolina Utilities Commission on an annual basis.

' The term "energy efficiency, "as used in this testimony, includes both energy efficiency/conservation and

demand response measures.

Direct Testimony; JANKK D. HAGKR 3Duke Energy Caroiinas, LLCPSCSC Docket No. 2007-358-E

I licensing,rates,andregulatoryaffairs. I amaregisteredProfessionalEngineerin

2 NorthCarolinaandSouthCarolina.

3 Q. HAVE YOU PREVIOUSLY TESTIFIED BEFORETHIS COMMISSION?

4 A. Yes. I havetestifiedbefore the Public ServiceCommissionof South Carolina

5 (the “Commission”) on severalprior occasions,including past annualfuel cost

6 proceedingsand a proceedingon the utility processfor considerationof capacity

7 alternatives.

8 Q. WHAT IS THE PURPOSEOF YOUR TESTIMONY?

9 A. Thepurposeof my testimonyis to discusstheneedfor new capacityoutlined in

10 the Company’s2007 IntegratedResourcePlan filed on November15, 2007 in

11 Docket No. 87 — 223 — E (“IIRP” or the “Annual Plan”) and how energy

12 efficiency1 is reflectedin the integratedplanningresourcemodels.

13 II. CAPACITY NEEDSIDENTIFIED IN THE COMPANY’S ANNUAL PLAN

14 Q. PLEASE DESCRIBE THE PURPOSE OF COMPANY’S ANNUAL PLAN?

15 A. DukeEnergyCarolinas’Annual Planis developedwith the objectiveof meeting

16 customers’needsfor ahighly reliableenergysupplyat the lowestreasonablecost.

17 Annually, Duke Energy Carolinas develops a resource plan for meeting

18 customers’energyneeds,whichconsidersa combinationof: (i) existingpurchase

19 power contracts,(ii) existing and new generation,and (iii) customerenergy

20 efficiencyoptions. The AnnualPlan is filed with the Commissionand theNorth

21 CarolinaUtilities Commissionon an annualbasis.

The term“energyefficiency.” asusedin this testimony,includesbothenergyefficiency/conservationand

demandresponsemeasures.Direct Testimony: JANICE D. HAGER 3Duke Energy Carolinas, LLCPSCSCDocketNo. 2007-358-E

Page 5: 1 L - dms.psc.sc.gov

1 Q. WHAT PROCESS DOES THE COMPANY USE TO FORECAST

CAPACITY NEEDS IN ITS IRP?

3 A. The planning process considers a wide range of assumptions and uncertainties and

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develops an action plan that preserves the options necessary to meet customers'

needs. Duke Energy Carolinas' resource planning process seeks to identify what

actions the Company must take to ensure there is a safe, reliable, reasonably-

priced supply of electricity regardless of how these uncertainties unfold,

The process begins with a forecast of customer needs. The 20-year

forecast used for the 2007 IRP reflects a 1.6 percent average annual growth in

summer peak demand, while winter peaks are forecasted to grow at an average

annual rate of 1.4 percent. The forecasted growth for average annual territorial

energy is 1.4 percent.

The next step is to gather information on Duke Energy Carolinas' existing

resources. Duke Energy Carolinas' generation portfolio is composed of over

21,000 MWs of generation capacity, with about one-third of the capacity in coal-

fired generation resources, one-third of-the capacity in nuclear resources, and the

other third in hydro-electric and gas-fired generation (of about equal proportions).

In addition, as discussed in Company Witness Schultz's testimony, the Company

has approximately 700 MWs of existing demand response programs that are

roughly equivalent to peaking capacity.

Although Duke Energy Carolinas' capacity mix is approximately one-third

coal, one-third nuclear, and one-third hydroelectric and gas-fired, the energy mix

is approximately 50% nuclear and 50% coal-fired generation. Gas-fired

Direct Testimony: JANICK D. HAGER

Duke Energy Carolinas, LLCPSCSC Docket No. 2007-358-E

1 Q. WHAT PROCESS DOES THE COMPANY USE TO FORECAST

2 CAPACITY NEEDSIN ITS IRP?

3 A. Theplanningprocessconsidersawide rangeof assumptionsand uncertaintiesand

4 developsan action planthat preservesthe optionsnecessaryto meetcustomers’

5 needs.Duke EnergyCarolinas’ resourceplanningprocessseeksto identify what

6 actionsthe Companymust taketo ensurethereis a safe, reliable, reasonably-

7 pricedsupplyofelectricityregardlessofhowtheseuncertaintiesunfold.

8 The processbegins with a forecastof customerneeds. The 20-year

9 forecastusedfor the 2007 IRP reflectsa 1.6 percentaverageannualgrowth in

10 summerpeak demand,while winter peaksare forecastedto grow at an average

11 annualrateof 1.4 percent. The forecastedgrowth for averageannualterritorial

12 energyis 1.4 percent.

13 The nextstepis to gatherinformationon Duke EnergyCarolinas’existing

14 resources. Duke Energy Carolinas’ generationportfolio is composedof over

15 21,000MWs of generationcapacity,with aboutone-thirdofthe capacityin coal-

16 fired generationresources,one-thirdof. thecapacityin nuclearresources,andthe

17 otherthird in hydro-electricandgas-firedgeneration(of aboutequalproportions).

18 In addition,as discussedin CompanyWitnessSchultz’stestimony,the Company

19 has approximately700 MWs of existing demandresponseprogramsthat are

20 roughlyequivalentto peakingcapacity.

21 AlthoughDukeEnergyCarolinas’capacitymix is approximatelyone-third

22 coal,one-thirdnuclear, andone-thirdhydroelectricand gas-fired,the energymix

23 is approximately 50% nuclear and 50% coal-fired generation. Gas-fired

DirectTestimony:JAr~iCED. HAGER 4DukeEnergy Carolinas,LLCPSCSCDocketNo. 2007-358-E

Page 6: 1 L - dms.psc.sc.gov

generation and hydroelectric generation provide only a small percentage of the

current energy needs of the Duke Energy Carolinas' customers.

3 Q. PLEASE DESCRIBE HOW LOAD FORECASTS AND RESOURCE

NEEDS ARE BALANCED IN THE IRP.

5 A. To meet the future needs of Duke Energy Carolinas' customers, it is necessary to

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understand the load and resource balance. For each year of the planning horizon,

Duke Energy Carolinas develops a load forecast of energy sales and peak

demand. To determine total resources needed, the Company considers the load

obligation plus a target planning reserve margin, which is currently set at 17

percent. The capability of existing resources, including generating units, energy

efficiency programs, and purchased power contracts, is measured against the total

resource need. Any deficit in future years will be met by a mix of additional

resources that reliably and cost-effectively meets the load obligation.

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Hager Exhibit No. 1 shows the existing resources and resource

requirements to meet the load obligation, plus the 17 percent target planning

reserve margin. Beginning in 2007, existing resources, consisting of existing

generation, energy efficiency, and purchased power to meet load requirements,

total 21,330 MW. The load obligation plus the target planning reserve margin is

20,907 MW, indicating sufficient resources to meet Duke Energy Carolinas'

obligation through 2008. The need for additional capacity, shown in the Table

below, grows over time due to load growth„unit capacity adjustments, unit

retirements, existing energy efficiency program reductions, and expirations of

Direct Testimony: JAwcE D. H&GKRDuke Energy Carolinas, LLCPSCSC Docket No. 2007-358-K

1 generationand hydroelectricgenerationprovideonly a small percentageof the

2 currentenergyneedsoftheDukeEnergyCarolinas’customers.

3 Q. PLEASE DESCRIBE HOW LOAD FORECASTS AND RESOURCE

4 NEEDSARE BALANCED IN THE IRP.

5 A. To meetthe future needsof DukeEnergyCarolinas’customers,it is necessaryto

6 understandtheloadandresourcebalance. For eachyearofthe planninghorizon,

7 Duke Energy Carolinasdevelops a load forecast of energy sales and peak

8 demand.To determinetotal resourcesneeded,the Companyconsidersthe load

9 obligation plus a target planning reservemargin, which is currently set at 17

10 percent. The capability of existing resources,including generatingunits, energy

11 efficiencyprograms,andpurchasedpowercontracts,is measuredagainstthetotal

12 resourceneed. Any deficit in future years will be met by a mix of additional

13 resourcesthatreliably andcost-effectivelymeetsthe loadobligation.

14 Hager Exhibit No. 1 shows the existing resources and resource

15 requirementsto meet the load obligation, plus the 17 percenttarget planning

16 reservemargin. Beginning in 2007, existing resources,consistingof existing

17 generation,energyefficiency, and purchasedpower to meet load requirements,

18 total 21,330MW. Theloadobligationplus thetargetplanningreservemarginis

19 20,907 MW, indicating sufficient resourcesto meet Duke Energy Carolinas’

20 obligationthrough2008. The needfor additional capacity,shownin the Table

21 below, grows over time due to load growth, unit capacityadjustments,unit

22 retirements,existing energy efficiency program reductions,and expirationsof

DirectTestimony:JANICE D. HAGER 5DukeEnergyCarolinas,LLCPSCSCDocketNo. 2007-358-E

Page 7: 1 L - dms.psc.sc.gov

purchased-power contracts. The need grows to approximately 6,600 MW by

2017 and to 10,700 MW by 2027 as shown in Table 1 below.

Table I

Cumulative Resource Additions to Meet A 17 Percent Planning Reserve

Margin

Year20072008

201020112012201320142015201620172018201920202021202220232024202520262027

CumulativeCapacity Additions

Needed

60430990

2,3403,1904,0304,6305,5406,0906,6207,0207,4307,8808,2708,6709,0709,4709,88010,28010,680

67 Q. DID DUKE ENERGY CAROLINAS PERFORM QUANTITATIVE

ANALYSES IN THE RESOURCE PLANNING PROCESS?

9 A. Yes. Duke Energy Carolinas' resource planning process provides a framework

10 for the Company to assess, analyze and implement a cost-effective approach to

meet customers' growing energy needs reliably. In addition to assessing

Direct Testimony: JANrcs D. HAGER

Duke Energy Carolinas, LLCPSCSC Docket No. 2007-358-K

purchased-power contracts. The need grows to approximately6,600 MW by

2 2017andto 10,700MW by 2027asshownin Table 1 below.

3 Table 1

4 Cumulative ResourceAdditions to Meet A 17 PercentPlanning Reserve

5 Margin

I CumulativeCapacity Additions

Year Needed2007 02008 602009 4302010 9902011 2,3402012 3,1902013 4,0302014 4,6302015 5,5402016 6,0902017 6,6202018 7,0202019 7,4302020 7,8802021 8,2702022 8,6702023 9,0702024 9,4702025 9,8802026 10,2802027 10,680

67 Q. DID DUKE ENERGY CAROLINAS PERFORM QUANTITATIVE

8 ANALYSES IN THE RESOURCE PLANNING PROCESS?

9 A. Yes. Duke Energy Carolinas’resourceplanningprocessprovidesa framework

10 for the Companyto assess,analyzeand implementa cost-effectiveapproachto

11 meet customers’ growing energy needs reliably. In addition to assessing

Direct Testimony: JANICE D. HAGER 6Duke Energy Carolinas, LLCPSCSCDocketNo. 2007-358-E

Page 8: 1 L - dms.psc.sc.gov

qualitative factors, a quantitative assessment was conducted using a simulation

model.

A variety of sensibvities and scenarios were tested against a base set of

inputs for various resource mixes, allowing the Company to better understand

how potentially different future operating environments such as fuel commodity

price changes, environmental emission mandates, and structural regulatory

requirements can affect resource choices, and, ultimately, the cost of electricity to

customers,

9 Q. WHAT WERE THE RESULTS OF THE COMPANY'S QUANTITATIVE

10 ANALYSES?

11 A. The quantitative analyses suggest that a combination of additional base load,

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intermediate, and peaking generation, renewable resources, and energy efficiency

programs is required over the next twenty years to meet customer demand reliably

and cost-effectively.

III. ENERGY EFFICIENCY IN THE COMPANY'S 2007 ANNUAL PLAN

16 Q. HOW WERE ENERGY EFFICIENCY PROGRAMS REFLECTED IN

17 THK COMPANY'S 2007 ANNUAL PLAN?

18 A. The 2007 IRP reflects the impacts of the energy efficiency programs proposed in

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the Company's Application for Approval of Energy Efficiency Plan, Including an

Energy Efficiency Rider and Portfolio of Energy Efficiency Programs (the

"Application" ), as well as additional impacts from currently unidentified sources,

See Table 2 below for the projected impacts of the Company's energy efficiency

efforts over the planning horizon.

Direct Testimony: JANtcK D. HAGERDuke Energy Carolinas, LLCPSCSC Docket No. 200 l-358-E

I qualitative factors,a quantitativeassessmentwas conductedusing a simulation

2 model.

3 A variety of sensitivitiesand scenarioswere testedagainsta baseset of

4 inputs for variousresourcemixes, allowing the Companyto better understand

5 how potentiallydifferent future operatingenvironmentssuchas fuel commodity

6 price changes, environmental emission mandates, and structural regulatory

7 requirementscanaffect resourcechoices,and,ultimately,the costof electricityto

8 customers.

9 Q. WHAT WERE THE RESULTS OF THE COMPANY’S QUANTITATIVE

10 ANALYSES?

11 A. The quantitativeanalysessuggest that a combinationof additional baseload,

12 intermediate,and peakinggeneration,renewableresources,andenergyefficiency

13 programsis requiredoverthenext twentyyearsto meetcustomerdemandreliably

14 andcost-effectively.

15 III. ENERGYEFFICIENCY IN THE COMPANY’S 2007ANNUAL PLAN

16 Q. HOW WERE ENERGY EFFICIENCY PROGRAMS REFLECTED IN

17 THE COMPANY’S 2007ANNUAL PLAN?

18 A. The 2007 IRP reflectsthe impactsof the energyefficiencyprogramsproposedin

19 theCompany’sApplicationfor Approvalof EnergyEfficiencyPlan, Including an

20 Energy Efficiency Rider and Portfolio of Energy Efficiency Programs (the

21 “Application”), aswell asadditionalimpactsfrom currentlyunidentifiedsources.

22 SeeTable 2 below for the projectedimpactsof the Company’senergyefficiency

23 effortsovertheplanninghorizon.

Direct Testimony: JANICE D. HAGER 7Duke Energy Carolinas, LLCPSCSCDocketNo. 2007-358-E

Page 9: 1 L - dms.psc.sc.gov

Table 2

Projected Energy Efficiency Results in MW

Year20082009201020112012201320142015201620172018201920202021202220232024202520262027

Total Conservation40

110175237302373437499565635700762789789789789789789789789

Total DSM

761898

1,0161,0161,0161,0161,0161,0161,0161,0161,0161,0161,0161,0161,0161,0161,0161,0161,0161,016

Total MW Im acts801

1,0081,1901,2531,3181,3881,4531,5151,5811,6511,7161,7781,8051,8051,8051,8051,8051,8051,8051,805

The impacts for the first four years are those reflected in the Application

as shown on page 3 of the Application, with the exception that the Table in the

Application includes projected accomplishments from the Advanced Power

Manager pilot program. The projected accomplishments for the pilot program are

too preliminary at this point to include them in the projected energy efficiency

accomplishments for planning purposes. The accomplishments for this and other

pilot programs will be incorporated into future plans once there is greater

certainty of their likely impacts. The projected impacts for the remaining years

were developed assuming the Company would continue to achieve energy

efficiency at the same rate as the first four years for an additional eight years.

Direct Testimony: JANlcK D. HAGKRDuke Energy Caroiinas, LLCPSCSC Docket 1Vo. 2007-358-E

Table 2

2 Projected Energy Efficiency Resultsin MW

L Total Conservation Total DSM Total MWImpactsL 2008 40 761 801

2009 110 898 1,0082010 175 1,016 1,1902011 237 1,016 1,2532012 302 1,016 1,3182013 373 1,016 1,3882014 437 1,016 1,4532015 499 1,016 1,5152016 565 1,016 1,5812017 635 1,016 1,6512018 700 1,016 1,7162019 762 1,016 1,7782020 789 1,016 1,8052021 789 1,016 1,8052022 789 1,016 1,8052023 789 1,016 1,8052024 789 1,016 1,8052025 789 1,016 __________________

2026 789 1,016 1,8~JI 2027 789 1 1,016 1,805]

3

4 Theimpactsfor the first four years arethosereflectedin the Application

5 asshownon page3 of the Application, with the exceptionthat the Table in the

6 Application includes projected accomplishmentsfrom the Advanced Power

7 Managerpilot program. The projectedaccomplishmentsfor thepilot programare

S too preliminaryat this point to include them in the projectedenergyefficiency

9 accomplishmentsfor planningpurposes.Theaccomplishmentsfor this andother

10 pilot programswill be incorporated into future plans once there is greater

11 certaintyof their likely impacts. Theprojectedimpactsfor the remainingyears

12 were developed assumingthe Company would continue to achieve energy

13 efficiencyatthesamerateasthefirst four yearsfor an additionaleight years.

Direct Testimony:JANICE D. HAGER 8Duke Energy Carolinas, LLCPSCSCDocketNo. 2007-358-E

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1 Q. WHAT COSTS WERE ASSUMED FOR THESE PROGRAMS IN THE

2007 IRP?

For program costs, Duke Energy Carolinas used the revenues that would be

received under the proposed "save-a-watt" model to ensure that the programs

were beneficial to customers (i.e. , that they were cost-effective when priced at the

save-a-watt price).

7 Q. ARE THESE THE SAME COSTS USED IN THE SCREENING OF THK

PROGRAMS AS DISCUSSED BY DR. STEVIE?

9 A. No. Dr, Stevie discusses how the programs are analyzed within the DSMore

10

13

14

15

model and how the programs fare under various cost-effectiveness tests, Dr.

Stevie uses the actual cost of the programs, as well as expected load impacts, to

measure their cost-effectiveness. In contrast, for the IRP analysis, the projected

revenues under Rider EE (SC) are used as program costs. This is appropriate

because this is the cost customers will actually incur for the programs if the

Commission approves the Company's Application.

16 Q. HOW DID THK PROPOSED SAVE-A-WATT PLAN FARE IN THE 2007

IRP ANALYSIS?

18 A. In the screening phase of the resource planning process, the model selected the

19

20

23

energy efficiency options as shown on Table 2 above as part of the preferred

resource portfolio under all proposed scenarios and sensitivities, indicating the

energy efficiency resources are lower cost to customers than equivalent supply-

side alternatives. This indicates that the proposed energy efficiency programs are

part of the "optimum" resource plan. In the detailed analysis phase, portfolios

Direct Testimony: JANICK D. HAGKRDuke Energy Carolinus, LLCPSCSC Docket No. 2007-358-E

1 Q. WHAT COSTS WERE ASSUMED FOR THESE PROGRAMS IN THE

2 2007 IRP?

3 For program costs, Duke Energy Carolinas used the revenuesthat would be

4 receivedunder the proposed“save-a-watt” model to ensurethat the programs

5 werebeneficialto customers(i.e.,that theywerecost-effectivewhenpricedat the

6 save-a-wattprice).

7 Q. ARE THESE THE SAME COSTS USED IN THE SCREENING OF THE

8 PROGRAMSAS DISCUSSEDBY DR. STEVIE?

9 A. No. Dr. Stevie discusseshow the programsare analyzedwithin the DSMore

10 model and how the programsfare under variouscost-effectivenesstests. Dr.

11 Stevie usesthe actualcostof theprograms,aswell asexpectedloadimpacts,to

12 measuretheir cost-effectiveness.In contrast,for the IRP analysis,theprojected

13 revenuesunderRider EE (SC) areusedasprogramcosts. This is appropriate

14 becausethis is the cost customerswill actually incur for the programsif the

15 Commissionapprovesthe Company’sApplication.

16 Q. HOW DID THE PROPOSED SAVE-A-WATT PLAN FARE IN THE 2007

17 IRP ANALYSIS?

18 A. In the screeningphaseof the resourceplanningprocess,the model selectedthe

19 energyefficiency options as shown on Table 2 aboveas part of the preferred

20 resourceportfolio under all proposedscenariosand sensitivities,indicating the

21 energyefficiencyresourcesare lower cost to customersthanequivalentsupply-

22 sidealternatives.This indicatesthat theproposedenergyefficiencyprogramsare

23 part of the “optimum” resourceplan. In the detailedanalysisphase,portfolios

Direct Testimony: JANICE D. HAGER 9Duke Energy Carolinas, LLCPSCSCDocketNo. 2007-358-E

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including the energy efficiency resources shown on Table 2 were lower cost to

customers than those that included the Company's existing energy efficiency

programs. As discussed by Company Witness Farmer, the revenue requirements

have been updated since the Company filed its Application, An analysis of the

updated costs continues to show energy efficiency as cost-effective for customers,

In summary, the portfolios including the save-a-watt plan are lower cost to

customers than alternative portfolios that do not include the proposed energy

efficiency programs.

9 Q. HOW DO ENERGY EFFICIENCY PROGRAMS IMPACT THE

10 COMPANY'S IRP?

11 A. Duke Energy Carolinas is projecting that energy efficiency will offset the need for

13

14

15

17

generating resources that would have been required to meet customer needs by

providing approximately 1805 MWs of capacity (replacing an existing 700 MWs)

and over 2,000,000 MWHs of energy. If the implementation of the Company's

save-a-watt plan yields the results projected in the 2007 Annual Plan, Duke

Energy Carolinas will be able to avoid building at least one new 700 MW gas-

fired plant and to defer two others by a year over the next ten years.

18 Q. ARE ENERGY EFFICIENCY PROGRAMS A RELIABLE SOURCE OF

19 ENERGY AND CAPACITY?

20 A. They certainly can be. Duke Energy Carolinas has long relied upon DSM

21

22

23

programs as an integral component of its resource mix. The current DSM

programs provide approximately 700 MWs of capacity at the time of the system

peak. These programs are tested periodically to ensure their availability, and the

Direct Testimony: JANicE D. HAGERDuke Energy Carolinas, LLCPSCSC Docket No. 2007-35$-E

10

1 including the energyefficiency resourcesshownon Table 2 were lower cost to

2 customersthan those that included the Company’s existing energyefficiency

3 programs. As discussedby CompanyWitnessFarmer,the revenuerequirements

4 havebeenupdatedsincethe Companyfiled its Application. An analysisof the

5 updatedcostscontinuesto showenergyefficiencyascost-effectivefor customers.

6 In summary, the portfolios including the save-a-wattplan are lower cost to

7 customersthan alternativeportfolios that do not include the proposedenergy

8 efficiencyprograms.

9 Q. HOW DO ENERGY EFFICIENCY PROGRAMS IMPACT THE

10 COMPANY’S IRP?

11 A. DukeEnergyCarolinasis projectingthat energyefficiencywill offsettheneedfor

12 generatingresourcesthat would havebeenrequired to meetcustomerneedsby

13 providingapproximately1805MWs of capacity(replacinganexisting700MWs)

14 and over 2,000,000MWHs of energy. If the implementationof the Company’s

15 save-a-wattplan yields the resultsprojected in the 2007 Annual Plan, Duke

16 EnergyCarolinaswill be able to avoid building at least onenew 700 MW gas-

17 fired plantandto defertwo othersby ayearover thenextten years.

18 Q. ARE ENERGY EFFICIENCY PROGRAMS A RELIABLE SOURCE OF

19 ENERGY AND CAPACITY?

20 A. They certainly can be. Duke Energy Carolinas has long relied upon DSM

21 programsas an integral componentof its resourcemix. The current DSM

22 programsprovideapproximately700MWs of capacityat the time of the system

23 peak. Theseprogramsaretestedperiodicallyto ensuretheir availability, andthe

DirectTestimony:JANICE D. HAGER 10DukeEnergyCarolinas,LLCPSCSCDocketNo. 2007-358-E

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10

12

13

14

15

results of activating the programs are studied following an event to determine if

the expected results were achieved. History has shown that these programs can be

counted upon as a reliable resource.

With regard to conservation programs, once conservation measures are

installed they will likely be reliable resources as well. Conservation measures

(e.g. , weatherization or high efficiency commercial lighting) are not subject to

scheduled or forced outages. These measures, once implemented, will provide

resources with measured reliability, such that prudent inclusion into the Duke

Energy Carolinas' resource mix is possible.

One uncertainty, however, is the extent of customer participation in energy

efficiency programs. In addition to the planned measurement and verification that

will occur after the programs are implemented, the Company will be carefully

monitoring programs during roll out and make adjustments to projected program

results within the IRP process to ensure adequate reliable resources to meet

customer needs.

16 Q. WHAT ASSURANCES DOES DUKE ENERGY CAROLINAS OFFER

17

18

THAT CUSTOMERS ARE NOT PAYING FOR CAPACITY THAT IS NOT

AVOIDED?

19 A. The save-a-watt model is fundamentally based on payment for results. If the

20

21

22

23

Company estimates that we will achieve SOOMW of energy efficiency and only

achieves 300MW of savings, Duke Energy Carolinas will be compensated for the

300MW under Rider EE (SC). If the Company then has to secure 200MW of

supply elsewhere, the Company would do so and reflect the costs of the capacity

Direct Testimony: JANICE D. HAGERDuke Energy Carolinas, LLCPSCSC Docket No. 2007-358-K

1 resultsof activatingthe programsarestudiedfollowing an eventto determineif

2 theexpectedresultswereachieved.Historyhasshownthat theseprogramscanbe

3 counteduponasareliableresource.

4 With regardto conservationprograms,once conservationmeasuresare

5 installedthey will likely be reliableresourcesas well. Conservationmeasures

6 (e.g., weatherizationor high efficiency commerciallighting) arenot subjectto

7 scheduledor forced outages. Thesemeasures,onceimplemented,will provide

8 resourceswith measuredreliability, such that prudentinclusion into the Duke

9 EnergyCarolinas’resourcemix is possible.

10 Oneuncertainty,however,is theextentofcustomerparticipationin energy

11 efficiencyprograms.In additionto theplannedmeasurementand verification that

12 will occur afterthe programsare implemented,the Companywill be carefully

13 monitoringprogramsduring roll out and makeadjustmentsto projectedprogram

14 results within the IRP processto ensureadequatereliable resourcesto meet

15 customerneeds.

16 Q. WHAT ASSURANCES DOES DUKE ENERGY CAROLINAS OFFER

17 THAT CUSTOMERS ARE NOT PAYING FOR CAPACITY THAT IS NOT

18 AVOIDED?

19 A. The save-a-wattmodel is fundamentallybasedon paymentfor results. If the

20 Companyestimatesthat we will achieve500MW of energyefficiency and only

21 achieves300MWofsavings,Duke EnergyCarolinaswill be compensatedfor the

22 300MW underRider EE (SC). If the Companythenhasto secure200MW of

23 supplyelsewhere,theCompanywould do so and reflect thecostsofthe capacity

Direct Testimony: JANICE D. HAGER 11Duke Energy Carolinas, LLCPSCSCDocketNo. 2007-358-E

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10

as a cost of serving our customers. Upon approval, this would result in customers

paying for 300MW of energy efficiency and 200MW of supply from another

source. Customers will not have to pay for 500MW of energy efficiency

programs, of which 200MW did not materialize, and then pay for the additional

supply. Therefore, customers are only paying for the resources —be they energy

efficiency or supply side —that the Company actually has acquired.

The Company will update at least annually the expected level of energy

efficiency accomplishments. To the extent energy efficiency results are trending

lower or higher than expected, the IRP process will incorporate these expectations

and identify resources needed to reliably serve load.

IV. RETIREMENT OF OLD COAL PLANTS

12 Q. HO%' DOES DUKE ENERGY CAROLINAS PLAN TO IMPLEMENT

13

14

15

THE NORTH CAROLINA UTILITIES COMMISSION'S RECENT

ORDER IN ITS CLIFFSIDE CPCN PROCEEDING REQUIRING

RETIREMENT OF OLDER COAL PLANTS?

16 A. The North Carolina Utility Commission's order in March 2007 approving the

17

18

19

20

23

Company's request for a Certificate of Public Convenience and Necessity

("CPCN") for a new 800 MW clean coal generating unit requires Duke Energy

Carolinas to retire older coal-fired units (in addition to Cliffside Units 1 through

4) on a megawatt-for-megawatt basis to account for actual load reductions

realized through new energy efficiency programs up to the megawatt level added

upon completion of Cliffside Unit 6. Consequently, the Company will consider

(i) the megawatt ("MW") capacity reflected in the energy efficiency programs, (ii)

DireCt Testimony: JANICE D. HAGERDuke Energy Carolinas, LLCPSCSC Docket No. 2007-358-E

12

1 asa costof servingourCustomers.Uponapproval,this would resultin customers

2 paying for 300MW of energyefficiency and 200MW of supply from another

3 source. Customerswill not have to pay for 500MW of energy efficiency

4 programs,of which 200MW did not materialize,and thenpay for the additional

5 supply. Therefore,customersareonly payingfor theresources— be they energy

6 efficiencyorsupplyside— thattheCompanyactuallyhasacquired.

7 The Companywill updateat leastannuallythe expectedlevel of energy

8 efficiency accomplishments.To the extentenergyefficiencyresultsaretrending

9 lowerorhigherthanexpected,theIRP processwill incorporatetheseexpectations

10 andidentify resourcesneededto reliablyserveload.

11 IV. RETIREMENT OF OLD COAL PLANTS

12 Q. HOW DOES DUKE ENERGY CAROLINAS PLAN TO IMPLEMENT

13 THE NORTH CAROLINA UTILITIES COMMISSION’S RECENT

14 ORDER IN ITS CLIFFSIDE CPCN PROCEEDING REQUIRING

15 RETIREMENT OF OLDER COAL PLANTS?

16 A. The North CarolinaUtility Commission’sorder in March 2007 approvingthe

17 Company’s request for a Certificate of Public Convenienceand Necessity

18 (“CPCN”) for a new800 MW cleancoal generatingunit requiresDuke Energy

19 Carolinasto retire oldercoal-firedunits (in additionto Cliffside Units 1 through

20 4) on a megawatt-for-megawattbasis to account for actual load reductions

21 realizedthroughnewenergyefficiencyprogramsup to themegawattlevel added

22 upon completionof Cliffside Unit 6. Consequently,the Companywill consider

23 (i) themegawatt(“MW”) capacityreflectedin theenergyefficiencyprograms,(ii)

Direct Testimony: JANICE D. HAGER 12Duke Energy Carolinas, LLCPSCSCDocketNo. 2007-358-E

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the hours of availability over which the energy efficiency resource applies, (iii)

the blend of supply side resources required going forward, including both capacity

and energy components, (iv) the relative uncertainty of energy efficiency impact

projections and impact evaluation findings, (v) the likely persistence of energy

efficiency impacts over the planning horizon of the IRP, and (vi) the traditional

set of planning criteria and reserve margin drivers, in arriving at the appropriate

projection of MWs of capacity to be built, retired or avoided. As savings are

verified, Duke Energy Carolinas will include projected retirement dates in the IRP

filings which are subject to Commission review.

10 Q. WAS HAGER EXHIBIT NO. 1 PREPARED BY YOU OR UNDER YOUR

SUPERVISION?

12 A. Yes.

13 Q. DOES THIS CONCLUDE YOUR PRE-FILED DIRECT TESTIMONY?

14 A. Yes.

Direct Testimony: JANicE D. HAGERDuke Energy Carolinas, LLCPSCSC Docket No. 2007-358-E

13

1 the hoursof availability over which the energyefficiencyresourceapplies,(iii)

2 theblendofsupplysideresourcesrequiredgoingforward,includingbothcapacity

3 and energycomponents,(iv) therelativeuncertaintyof energyefficiency impact

4 projectionsand impactevaluationfindings, (v) the likely persistenceof energy

5 efficiency impacts over the planninghorizon of the IRP, and (vi) the traditional

6 set of planningcriteria andreservemargindrivers, in arriving at the appropriate

7 projectionof MWs of capacityto be built, retired or avoided. As savingsare

8 verified, DukeEnergyCarolinaswill includeprojectedretirementdatesin theIRP

9 filings which aresubjectto Commissionreview.

10 Q. WAS HAGER EXHIBIT NO. 1 PREPARED BY YOU OR UNDER YOUR

11 SUPERVISION?

12 A. Yes.

13 Q. DOES THIS CONCLUDE YOUR PRE-FILED DIRECT TESTIMONY?

14 A. Yes.

Direct Testimony: JANICE D. HAGER 13Duke Energy Carolinas, LLCFSCSCDocket No. 2007-358-E

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Load and Resource Balance

Hager Exhibit No. 1

Resource Requiremertts

28000

26000

24000

22000

. Additional Resources Needed to .: Meet Load Plus 17% Reserves

20000

18000

5 16OOO

ts 14OOO

12000

Purchases

DSM

10000

8000 Existing Generatng Resources

6000

4000

2000

2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027

Year

8t Existing Duke Energy Generation ta Existing Purchases (incl NUGs) Q Total DSM QAdditional Resources Needed I

Direct Testimony: JANICE D. HAGERDuke Energy Caroiinas, LLCPSCSC Docket No. 2007-358-E

14

Hager Exhibit No. 1

Load and ResourceBalance

Rosouree RGquirem~nt~

30000

28000 ::: :

28000 :

24000 Additional Resources Neededto

22000 Meet Load PIus 17% Reserves

20000Purchases - : : : : :- - - : : : : :- :

18000DSM

16000a0)14000

12000

10000

8000 Existing Generatng Resources

6000

4000

2000

02007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 202~ 2024 2025 2026 2027

Year

~Existing Duke Energy Generation lIDExisting Purchases (mci NUG5) ~1otaI DSM 0 Additional Resources Needed

Direct Testimony: JANICE D. HAGER 14Duke Energy Carolinas, LLCPSCSCDocketNo. 2007-358-E

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BEFORETHE PUBLIC SERVICE COMMISSION

OF SOUTH CAROLINADOCKET NO. 2007-358-E

In Re ))

Application of Duke Energy )Carolinas, LLC for Approval of )Energy Efficiency Plan Including an )Energy Efficiency Rider and )Portfolio of Energy Efficiency )Programs )

CERTIFICATE OF SERVICE

This is to certify that I, Leslie L. Allen, a legal assistant with the law firm of

Robinson, McFadden & Moore, P.C., have this day caused to be served upon the

person(s) named below the Testimony of Janice D. Wager in the foregoing

matter by placing a copy of same in the United States Mail, postage prepaid, in

an envelope addressed as follows:

Jeremy C. Hodges, EsquireNelson Mullins Riley & Scarborough, LLPP.O. Box 11070Columbia, SC 29211

Scott A. Elliott, EsquireElliott & Elliott, PA721 Olive AvenueColumbia, SC 29205

J. Blanding Holman, IV, EsquireSouthern Environmental Law Center200 W. Franklin Street, Suite 330Chapel Hill, NC 27516

Robert E. Tyson, Jr. , EsquireSowell Gray Stepp & Laffitte, LLCPost Office Box 11449Columbia, SC 29211

BEFORETHE PUBLIC SERVICE COMMISSION

OF SOUTH CAROLINADOCKET NO. 2007-358-E

InRe: ))

Application of Duke Energy )Carolinas, LLC for Approval of ) CERTIFICATE OF SERVICEEnergy Efficiency Plan Including an )Energy Efficiency Rider and )Portfolio of Energy Efficiency )Programs )

This is to certify that I, Leslie L. Allen, a legal assistant with the law firm of

Robinson, McFadden & Moore, P.C., have this day caused to be served upon the

person(s) named below the Testimony of Janice D. Hager in the foregoing

matter by placing a copy of same in the United States Mail, postage prepaid, in

an envelope addressed as follows:

Jeremy C. Hodges, EsquireNelson Mullins Riley & Scarborough, LLPP.O. Box 11070Columbia, SC 29211

Scott A. Elliott, EsquireElliott & Elliott, PA721 Olive AvenueColumbia, SC 29205

J. Blanding Holman, IV, EsquireSouthern Environmental Law Center200 W. Franklin Street, Suite 330Chapel Hill, NC 27516

Robert E. Tyson, Jr., EsquireSowell Gray Stepp & Laffitte, LLCPost Office Box 11449Columbia, SC 29211

Page 17: 1 L - dms.psc.sc.gov

Nanette S. Edwards, EsquireOffice of Regulatory StaffPost Office Box 11263Columbia, SC 29211

Dated at Columbia, South Carolina this 10th day of December, 2007.

Leslie L. Allen

Nanette S. Edwards, EsquireOffice of Regulatory StaffPost Office Box 11263Columbia, SC 29211

Dated at Columbia, South Carolina this 10th day of December, 2007.

Leslie L. Allen