education: professional membership: experience

George W. Evans

President

Evans Power Consulting, Inc.

of 4

EDUCATION: Master of Science, Applied Mathematics, Georgia Institute of Technology, 1976

Bachelor of Science, Applied Mathematics, Georgia Institute of Technology, 1974

PROFESSIONAL MEMBERSHIP: Institute of Electrical and Electronic Engineers

EXPERIENCE:

Mr. Evans is currently the President of Evans Power Consulting, Inc. He has served the electric power

utility industry for thirty-five years. His primary areas of expertise include market price forecasting,

integrated resource planning, the analysis of purchased power, system operations, net power costs,

interruptible rates, the optimal scheduling of generator maintenance, the computer simulation of electric

power systems, the integration of renewable generation and demand-side management. As an expert

witness in these areas, Mr. Evans has submitted expert testimony on 52 occasions, before the public utility

commissions in Alabama, Arkansas, Colorado, Delaware, Georgia, Michigan, Mississippi, Nevada,

Oklahoma, Pennsylvania, South Carolina, South Dakota, and Utah; and also before the FERC, and in both

state and federal court. He is an expert in the computer modeling of electric power systems and the use of

PROMOD IV, Strategist, GRID, POWERSYM, EGEAS, ELFIN and ENPRO.

Specific Experience Includes:

2011-Present Evans Power Consulting, Inc.

Michigan Environmental Council – Presented expert testimony concerning the economic

operation of the coal fleets of DTE Electric Company and Consumers Energy Company.

Developed an hourly after-the-fact process to evaluate the cost-effectiveness of the coal

fleets.

Michigan Environmental Council – Presented expert testimony on the Integrated Resource

Plans of DTE Electric Company and Consumers Energy Company.

South Carolina Office of Regulatory Staff – Testified for staff on the proposed portfolio of

Demand-Side Programs proposed by South Carolina Electric & Gas, Duke Energy Progress

and Duke Energy Carolinas; and performed annual reviews of the DSM programs and the

DSM rate riders of the three companies.

Utah Department of Public Utilities – Testified for staff in two PacifiCorp rate cases

concerning net power costs, testified on PacifiCorp’s application to install Selective

Catalytic Reduction Systems on two coal units, and performed a review of PacifiCorp’s

thermal maintenance practices and procedures.

Arizona Corporation Commission – Evaluated the 2012 and 2014 Integrated Resource

Plans of Arizona Public Service Company, Tucson Electric Power Company, UNS Electric,

Case No. U-18142Exhibit AG-1Page 1 of 4

George W. Evans

President


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Arizona Electric Power Cooperative, and the Salt River Project; and presided over public

meetings concerning the IRPs.

1997-2011 Slater Consulting

Utah Department of Public Utilities – Testified in two PacifiCorp rate cases concerning the

appropriate level of net power costs, including wind integration costs and other issues.

South Dakota PUC – Testified on the Integrated Resource Plans of Black Hills Power and

Otter Tail Power, and the validity of a coal fired generation addition and a wind generator

addition.

Golden Spread Electric Cooperative – Presented expert testimony in a FERC complaint

concerning the actual operation of an economy sales agreement between Golden Spread and

Southwestern Public Service Company.

Cooper Nuclear Plant - Development of the estimated damages caused by imprudent

outages of a Nebraska nuclear generating unit.

Millstone 3 Nuclear Unit - Analysis of the replacement energy costs for the Millstone 3

nuclear unit on behalf of the co-owners.

Independent Power Producers - Presented expert testimony before the Alabama and

Mississippi PSCs concerning the construction of new combined cycle facilities in those

states.

S.C. State Energy Office - Developed a report summarizing and evaluating the Integrated

Resource Plans filed by the electric utilities of South Carolina.

1989-1997 GDS Associates, Inc.

Mr. Evans served as a principal and the Manager of the System Modeling group, where he

was responsible for performing analyses, providing expert testimony and developing

customized software. He is an expert in the use of the industry standard computer models

PROMOD III, PROSCREEN II, PROVIEW, MAINPLAN, CAT II and ENPRO. A

sampling of representative assignments follows:

Tenaska, Air Liquide & Tenneco - Developed forecasts of market clearing prices for

electricity in the ERCOT region.

GEMC - Produced a forecast of market clearing prices for electricity in the SERC region

and estimated stranded costs.


George W. Evans

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Central Virginia Electric Cooperative - Designed, developed and installed software to

allow the Cooperative to purchase economy energy in an optimal manner on a daily

basis.

City of Grand Island, Nebraska - Developed the initial Integrated Resource Plan for the

City of Grand Island.

Georgia PSC - Evaluated the 1995 Integrated Resource Plans filed by Georgia Power

and Savannah Electric. Developed alternative Integrated Resource plans that were

approved by the Commission.

Nucor Steel - Audited the bills for electric service for the Nucor-Hickman Steel Mill.

Nucor Steel - Testified before the Arkansas PSC concerning the reasonableness of a

buy-through clause for interruptible customers.

Nucor Steel - Developed a comprehensive forecast of the likely levels of interruptions of

service over the next ten years.

South Dakota Public Utility Commission - Evaluated the rate filing and Integrated

Resource Plan filed by Black Hills Power & Light.

Georgia PSC - Evaluated Georgia Power's initial RFP for power, all bids received and

Georgia Power's selection process. Testified before the Georgia PSC concerning the

reasonableness of Georgia Power's evaluation process and resulting request for

certification.

Michigan Attorney General - Performed studies concerning the availability of the

Midland Cogeneration Venture and Consumer Power Company's avoided costs.

Michigan Attorney General - Developed estimates of cost reductions due to improved

projected fossil performance and changes in cogeneration levels in a Consumers Power

rate case.

Pennsylvania PUC - Testified concerning the capacity needs of a Pennsylvania utility

and the appropriate avoided costs due potential cogeneration projects.

Golden Spread Electric Cooperative - Developed detailed historical reconstructions of

five years of hourly operations of a major Texas utility to illustrate the penalties arising

to wholesale ratepayers as a result of off-system sales.


George W. Evans

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Sam Rayburn G&T - Designed, developed and implemented a PC-based software

system to facilitate daily load forecasting, optimal resource scheduling and inadvertent

accounting in a user-friendly fashion.

Tex-La Electric Cooperative - Designed, developed and implemented a similar software

system for daily load forecasting and optimal resource scheduling. This application also

included the development of an optimization process which maximizes the total

economy energy scheduled while adhering to limitations on load factor and the number

of hourly changes.

PG&E-Bechtel Generating Company - Assisted this NUG developer in forecasting the

dispatchability of a project and estimating likely costs in a power bidding solicitation.

1980-1989 Energy Management Associates, Inc. - now known as New Energy Associates

While with EMA, Mr. Evans performed product development, maintenance

programming and client support on the three major products marketed and developed by

EMA - PROMOD III, PROSCREEN II, and MAINPLAN. He is extremely well-versed

in the development of databases for these tools and in applying these tools to particular

studies.

As MAINPLAN Product Manager (1985-1989), Mr. Evans supervised and directed the

development, maintenance, and client support for MAINPLAN - the software package

that is the industry leader in the area of generating unit maintenance scheduling. The

client base for MAINPLAN grew from two clients to over thirty clients during his

involvement. Also during his tenure, a chronological production costing model was

added to MAINPLAN. This highly detailed model has been used to evaluate

interchange opportunities, the cost of forced outages, short-term fuel requirements and

unit commitment strategies.

Publications:

Backcasting - A new computer application can determine historical truth for utilities that

must refute damage claims, Fortnightly, October 1, 1993.

"Avoiding and Managing Interruptions of Electric Service Under an Interruptible

Contract or Tariff", Industrial Energy Technology Conference, April, 1995.

“Analysis and Evaluation of the Integrated Resource Plans of the Investor-Owned and

State-Owned Electric Utilities in South Carolina”, for the South Carolina State Energy

Office, April, 1998.

Programming Languages: Visual Basic, C++ for Windows, C , FORTRAN and COBOL.


17678R-MEC-CE-85

Question:

8. Refer to the testimony of Stephen J. Nadeau, on page 2, line 22 through page 3, line 1.

a. Please explain what is meant by the unpredictable nature of the spot market, and how

it can “easily become constrained by forces affecting both supply and demand.”

b. Please identify each instance in 2015 when the Company:

i. Sought a spot market transaction for coal that was subject to the

unpredictability and/or the constraints identified in subpart (a) above;

ii. Otherwise experience the unpredictability and/or the constraints identified in

subpart (a) in the context of the Company’s spot market purchasing.

c. Please identify each instance in the past three years where the Company was unable to

purchase coal on the spot market due to the issues identified in subpart (a) above.

Response:

a. Many factors can affect the supply and demand of coal, including weather, changes in the

regulatory environment, labor constraints, mining overhead costs, etc. All these factors can

make the spot market unpredictable in both the price and quantities available to purchase.

b. There were no such instances in 2015.

c. There were no such instances within the past three years; however, the Company has

experienced such instances prior to the past three years.

_________________________________

Stephen J. Nadeau

December 9, 2016

Fossil Fuel

Digitally signed by Stephen Nadeau Date: 2016.12.09 10:37:01 -05'00'

678R0185

Exhibit AG-3Case No. U-18142Page 1 of 1

Case No.: U‐18142

Exhibit: AG‐5

Witness: Evans

Date: June 2017

Page 1 of 1

Change in 2017 Total Production Cost

Due to Monte Carlo Draws in PROMOD

Total Production Cost Savings

($000) ($000)

Company Result ‐ 5 Draws $1,614,098

Revised Result ‐ 20 Draws $1,607,562 $6,536



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18142-AG-CE-200

Question:

64. Please provide all work papers that support the Company’s rebuttal testimony. Tothe extent that any work papers are spreadsheets, please provide in electronicformat with all formulas intact.

Response:

The following Excel files are attached in their fully intact form:

1. CONFIDENTIAL WP-STW-32. WP-STW-43. WP-STW-5

Provided by Counsel July 18, 2017

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18142-AG-CE-201

Question:

65. The following questions refer to Mr. Chilson's rebuttal testimony on page 3, lines 3 through 18.

Response:

a. Is it true that the Company purchases as much as 30% of its coal needs from the spot market? If not, please explain.

b. Is it true that the Company sets the dispatch price of all coal units at the cost of coal from the spot market? If not, please explain.

c. Is it true that the Company bids all coal generation into the MISO market based on the cost of coal from the spot market? If not, please explain.

d. Would it be impossible for the Company to purchase all coal needs through the spot market? If so, please list all facts, and provide the basis for each fact that makes it impossible for the Company to purchase all coal needs through the spot market.

a. Yes. As indicated in my Direct Testimony on page 8, "Quantities of coal are secured over time that typically positions the Company to have approximately 70% to 90% of its anticipated volume secured by the fall of each year for the following year". The remainder of the coal, if needed, is purchased from the spot market.

b. No. The Company sets the dispatch price of the coals units at the variable cost of operating the units. The fuel component of this cost is the replacement cost of the coal which is the variable cost to deliver coal to the plant. This variable cost is based on spot market prices, but also includes the variable cost of transportation and any required coal conditioning such as dust suppression or freeze treatment.

c. No. The units are dispatched based on the variable cost of operation. The spot market price is only one component of the variable costs.

While it may not be impossible to purchase all coal needs through the spot market, it would be extremely impractical and not prudent because of the manner

18142-AG-CE-201Page 1 of 2

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in which coal supply chain operates. This was explained in my rebuttal testimony on page 3, lines 3 - 18.

Fossil Fuel Supply Department

-IifuK.cililson July 20, 2017

18142-AG-CE-201Page 2 of 2

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18142-AG-CE-202

Question:

66. In lines 16-18 on page 3 of his rebuttal testimony, Mr. Chilson states that" ... utilities must purchase much of their anticipated coal requirements ahead of time to assure security of supply."

Response:

a. Please provide all studies that the Company has performed to support this statement.

b. What is meant by "security of supply" in this statement?

c. Is it the Company's position that a secure supply of coal is required in all months? If so, please provide the basis for this position.

d. Would the Company agree that a secure supply of coal is only required in the peak months of the year? If not, please explain.

a. No such study exists. The above referenced statement is based on a study but is instead based on the Company's immense amount of experience purchasing and receiving coal for its coal-fired generating units over numerous decades.

b. The "security of supply" is the assurance that sufficient fuel is available to operate each generating plant whenever needed.

c. Yes. The Company cannot offer generation capacity into the Midcontinent Independent System Operator ("MISO") market, if fuel is not available to generate the energy for the capacity.

d. No. The forecast provided by witness Walz indicates that the coal units will provide a net benefit to the customer for all months.

~~ ~hilson

July 20, 2017


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18142-AG-CE-205

Question:

69. Please provide all data and computations used to develop Exhibit A-46, along with thebasis for all data used. To the extent that any spreadsheets were utilized, please providethe spreadsheets in electronic format with all formulas intact.

Response:

See confidential work paper STW-3 provided in the response to 18143-AG-CE-200. The values included in that work paper were generated using the PROMOD IV report agent tool.

___________________________ Sara T. Walz July 18, 2017

Electric Sourcing and Resource Planning

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18142-AG-CE-206 Page 1 of 2

18142-AG-CE-206

Question:

70. The following questions concern Ms. Walz’s statement in lines 16 through 19 on page 5of her rebuttal testimony, that “Mr. Evans has double counted the expense of a thermalunit start-up cycle”.

a. Is it Ms. Walz’s claim that Mr. Evans made modifications to the Company’sPROMOD IV input data and/or assumptions prior to producing the informationshown in Exhibit AG-7? If so, please list each claimed modification, showing theCompany’s original value and the modified value.

b. Does Ms. Walz agree that Mr. Evans has taken the information shown in ExhibitAG-7 directly from a PROMOD IV report produced using the Company’s input dataand assumptions? If not, please explain.

c. What is the basis for Ms. Walz’s claim that “Mr. Evans has double counted theexpense of a thermal unit start-up cycle”?

d. Would Ms. Walz agree that it is the Company that has double counted the expenseof a thermal unit start-up cycle by including start-up fuel in the fuel costs withinPROMOD and then also instructing PROMOD to also compute start-up fuel costsinternally?

Response:

a. No. Start-up fuel costs, along with fuel replacement costs and other components aremodeled as inputs to PROMOD IV strictly for purposes of commitment and dispatch costcalculations.

As-burned fuel costs are provided by Consumers Energy (“the Company”) witness JimK. Chilson1 and are input to PROMOD IV in order to develop Exhibit A-39 (STW-4).The as-burned fuel costs contain auxiliary fuel costs, including start-up fuel costs.

Therefore, the start-up fuel costs explicitly input to PROMOD IV and used solely forpurposes of commitment and dispatch cost calculations must be removed, so as to avoiddouble counting start-up fuel costs that are already embedded in the as-burned fuel cost.Mr. Evans neglected to remove the start-up fuel costs that are used for commitment anddispatch purposes.

b. The Company does not use the report produced by Mr. Evans and included as ExhibitAG-7. In my review of the report, I determined that the start-up fuel costs are doublecounted, as explained on pages 5 and 6 of my rebuttal testimony.

1 Detailed in Exhibits A-33 (JKC-6) and A-34 (JKC-7)

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c. See my response to part (a) of this question.

d. No. See my response to part (a) of this question.

___________________________ Sara T. Walz July 18, 2017


18142-AG-CE-206 Page 2 of 2

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18142-AG-CE-207 (partial)

Question:

71. The following questions concern Ms. Walz's statement in lines 16 through 18 on page 5 of her rebuttal testimony, that " ... auxiliary fuel costs (which include startup fuel costs) are already included in the fuel costs provided by Company witness Chilson".

a. What is the basis for the start-up fuel costs included in the fuel costs provided by Mr. Chilson?

b. For each generating unit, provide the number of start-ups per calendar year used as the basis for the inclusion of start-up fuel costs in the fuel costs provided by Mr. Chilson.

c. For each generating unit, provide the total start-up fuel costs included in the fuel costs provided by Mr. Chilson.

d. Provide all data and computations used to include start-up fuel costs in the fuel costs provided by Mr. Chilson.

e. Provide all spreadsheets (in electronic form with all formulas intact) that were utilized to include start-up fuel costs in the fuel costs provided by Mr. Chilson.

f. Would Ms. Walz agree that the number of generating unit start-ups simulated in PROMOD are dependent on the forced outage rates provided as input data to PRO MOD? If not, please explain.

g. Would Ms. Walz agree that the number of generating unit start-ups simulated in PROM OD are dependent on the number of Monte Carlo draws specified as input data to PROMOD? If not, please explain.

h. Would Ms. Walz agree that the start-up costs included in the fuel costs provided by Company witness Chilson do not reflect the Company's 2017 forecasted operation of generating units? If not, please explain.

L Would Ms. Walz agree that the start-up costs included in the Company's 2017 forecasted PSCR costs do not reflect the Company's 2017 forecasted operation of generating units? If not, please explain.

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Response:

a. Auxiliary fuel is estimated based on recent actual auxiliary fuel costs for each unit.

b. The number of unit start-ups was not used to estimate auxiliary fuel costs.

2

c. Please refer to the response to 18412-AG-CE-84 for spreadsheets that include the cost as stated above. These costs can be found on the tab denoted as "AUX & OTHER COST".

d. Please refer to the response to 18412-AG-CE-84 for spreadsheets that include the cost as stated above. These costs can be found on the tab denoted as "AUX & OTHER COST".

e. Please refer to the response to 18412-AG-CE-84 for spreadsheets that include the cost as stated above. These costs can be found on the tab denoted as "AUX & OTHER COST".

~hilson July 20, 2017


18142-AG-CE-207 (Partial) Page 2 of 2

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18142-AG-CE-207 (Partial)

Question:

71. The following questions concern Ms. Walz’s statement in lines 16 through 18 on page 5 of her rebuttal testimony, that “ ...auxiliary fuel costs (which include state-up fuel costs)are already included in the fuel costs provided by Company witness Chilson”.

f. Would Ms. Walz agree that the number of generating unit start-ups simulated inPROMOD are dependent on the forced outage rates provided as input data toPROMOD? If not, please explain.

g. Would Ms. Walz agree that the number of generating unit start-ups simulated inPROMOD are dependent on the number of Monte Carlo draws specified as inputdata to PROMOD? If not, please explain.

h. Would Ms. Walz agree that the start-up costs included in the fuel costs provided byCompany witness Chilson do not reflect the Company’s 2017 forecasted operationof generating units? If not, please explain.

i. Would Ms. Walz agree that the start-up costs included in the Company’s 2017forecasted PSCR costs do not reflect the Company’s 2017 forecasted operation ofgenerating units? If not, please explain.

f. Yes. However, the projected number of generating unit start-up cycles from PROMODIV outputs are not used in developing any costs requested for recovery in this case.

g. Yes. However, the projected number of generating unit start-up cycles from PROMODIV outputs are not used in developing any costs requested for recovery in this case.

h. No. The fuel costs provided by Company witness Chilson are calculated using themonthly fuel bum forecast (in BTU) generated by PROMOD IV projections. Theprojected number of start-up fuel cycles from PROMOD IV results are not provided toCompany witness Chilson. See the response to parts (a) and (b) of this question.

i. No. See the response to part (h) of this question.

Response:

Sara T. Walz July 18, 2017


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education: professional membership: experience

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