UNITED STATES ENVIRONMEN TAL PROTECTION AGENCY

National Pollutant Discharge Elimination System – Cooling Water Intake Structures at Existing Facilities and Phase I Facilities
76 Fed. Reg. 22,174 (April 20, 2011) Docket ID No. EPA–HQ–OW–2008–0667



### The Impact of EPA’s Proposed 316(b) Existing Facility Rule On Electric System Reliability

David Schlissel Schlissel Technical Consulting, Inc. and Anna Sommer Sommer Energy, LLC

August 18, 20111 Schlissel Technical Consulting, Inc., and Sommer Energy, LLC were retained to evaluate the impact of the EPA’s proposed 316(b) Existing Facil ity Rule on electric system reliability. This report presents the resu lts of our assessment.
As part of this assessment we have reviewed the IPM modeling prepared for the EPA by ICF International, as well as the modeling performe d for the EPA’s proposed Utility Hazardous Air
Pollutants MACT rule. We also have reviewed th e numerous analyses that have been released during the past year that have i nvestigated the generating unit reti rements that could be expected from the environmental regulations under consid eration by the EPA and the related impact of these retirements on electric system reliability.
Our findings are as follows:
1. There will be no adverse reliability impact to the electric sector from adoption of any of the four proposed 316(b) Existing Facility Regulatory Options. 2. The four proposed Regulatory Options may not have any incremental plant retirement impacts over other EPA proposed rules such as the Transport Rule and Utility MACT Rule. 3. By failing to consider additional energy e fficiency, renewable energy or repowering as alternatives, EPA’s analysis likely overstat es the system costs of complying with any option of the 316(b) rule.
4. The NERC 2010 Special Reliability Scenario Asse ssment; Resource Adequacy Impacts of Potential Environmental Regulations severely overstates th e impact of the EPA’s adoption of a 316(b) Ex isting Facility Rule. 5. The May 2011 Review of the Potential Impacts of Proposed Environmental Regulations on the ERCOT System similarly significantly overstate s the impact that adoption of the 316(b) Existing Facility Rule being consider ed by the EPA would have on generating unit retirements and electric system reliability.
1. Finding: There will be no adverse reliability impact to the electric sector from adoption of Options 1, 2, 3 or 4. The EPA’s modeling analyses demonstrate that any consequential unit re tirements under any of the Regulatory Options will not adversely affect system reliability. The additional retirements (whether full or partial) cause d by a revised 316(b) rule would range from 1 GW under Option 1 to 17 GW under Options 2 or Option 3. 1 Respectively, this represents less than 0.01 percent and

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w ide3 Additionally, EPA is proposing compliance dead lines of 2022 for fossil units and 2027 for nuclear units. This means that system operators and utilities will have long lead times to construct any needed replacement capacity as a result of the 316(b) Existing Facility Rule. System operators and utilities would not have to rush replacement capacity into service as NERC currently projects that the nationwide planning reserve margin will exceed 20 percent through at
least 2019. 2

EPA’s analyses also demonstrate that the downtime to install compliance technologies will not impact electric system reliability. The potenti al impact to electric system reliability was estimated by determining the extent to which the 316(b) rule would re duce installed reserve margins during each of the compliance periods – 2013 through 2017 for non-cooling tower technologies, 2018 through 2022 for cooling towe rs at fossil fuel un its and 2023 through 2027 for cooling towers at nuclear units. Because of the lack of NERC data on spring and fall peaks,
this calculation was made usi ng winter 2017 capacity numbers. However, as EPA notes “To the extent that technology installati on occurs during the shoulder mont hs of spring and fall, when electricity demand is on average below that during the winter, the reliability impact estimated using winter demand is likely to be over-stated.” 3 The results of this analysis, shown in Table 5- 8 of the Economic and Benefits Analysis, reveal that all NERC regions will comfortably exceed their required reserves in off- peak periods even with outages related to these technology
installations. The Florida Relia bility Coordinating Council (FRCC) could see the biggest impact from generator outages, yet even so, will have seven percent more capacity than is needed to cover its 13 percent reserve margin.
2. Finding: Regulatory Options 1, 2, 3 a nd 4 may not have any incremental plant retirement impacts over other EPA proposed rules such as the Cross-State Air Pollution Rule and Utility MACT Rule. EPA’s modeling for the proposed 316(b) Existing Facility Rule does not reflect the proposed Transport and “Utility MACT” rules. This is ve ry significant as these rules will impact many of the same units affected by 316(b) and as such, it is important to know what incremental impact the proposed 316(b) Existing Facility Ru le would have on top of them.

2 See: http://www.n erc.com/page.php?cid=4%7C331%7C373

3 Page 5-20 of the Economic and Benefits Analysis.4 The modeling performed in support of the pr oposed Utility MACT rule does include the proposed Transport rule. EPA found that the Utility MACT rule could lead to an incremental 8.5 GW of plant retirements by 2030 over the base case scenario that included the Transport rule. 4 EPA did not provide a comparable number in its 316(b) analysis , but a review of EIA Form 767 indicates that thermal generating units with flue gas desulfurizati on (FGD) units (a key compliance technology for the Tran sport rule) are more likely to have recirculating cooling systems. To the extent that relationship remain s true going forward, it is reasonable to anticipate that plant retirements due to the Transport and Ut ility MACT rules are more likely to happen at units without cooling towers.
As explained in a recent report by the Analysis Group and M.J. Bradley & Associates, the results of PJM’s recent forward capacity auction show that even if exis ting generating units are retired, new energy efficiency, demand side measures and renewable resources can meet future electricity demands while maintaining electric system reliability:
To secure adequate capacity to m eet future projected power demand, PJM recently conducted its latest round of market-based bidding through its Reliability Pricing Model (“RPM”) fo rward capacity auction. On May 13, 2011, PJM announced the results of that auction, which covers the period May 31, 2014 through June 1, 2015 – a time when the Utility Toxics Rule and the Transport Rule will both be in effect. PJM’s forward capacity auction requires owners of power plan ts and other participating companies to offer (i.e., commit) resources in cluding both power plants and demandside resources, three years in advanc e so as to maintain electric system reliability. Resources that “clear” th e auction receive capacity payments; those that do not clear receive no compensation for their capacity. The results of the May 13 th 2011 auction show that while some coal plants were unable to clear the auction and may choose to retire, the region was still able to secure an ample supply of energy resources to maintain reliability. In fact, the market secure d resources sufficient to maintain a 20 percent reserve margin for the region. Out of a total of nearly 150,000 MW of capacity selected in the recent PJM auction, nearly 4,200 MW of new capacity plans to enter the market by 2014/2015, including the addition of new generation capacity resources, capacity upgrades to ex isting generation capacity resources,

4 U.S. Environmental Protection Agency (EPA). 2011. IPM Analysis of Proposed Toxics Rule. March 22, 2011. Available at: http://www.epa.gov/airmarkt/progsregs/epa-ipm/toxics.html.5 new demand resources, upgrades to existing demand resources, and new energy efficiency resources.
* * * * The generating units that failed to clear the auction – including fossil generating units that may eventually be slated for retirement – were largely offset by these new genera ting, energy efficiency, and demand response resources. In its auction re sults, PJM reported a reduction in committed coal capacity in 2014/2015 equal to 6,900 MW, and suggested that the decrease is likely related to some coal capacity reflecting the costs of environmental retrofits in their offer prices. These costs would make some coal units uneconomic relative to lower cost resources. In contrast to the reduction in committed coal capacity, however, demand resource resources increased by 4,836 MW. Commitments to conserve energy through energy efficiency increased by 142.7 MW. The auction also procured 695 MW of wind power and 45.6 MW of solar power. As indicated by the results of PJM’s most recent forward capacity auction, the region will have more than enough capacity to meet federal reliability standards set by NERC when the Utility Toxics Rule and the Transport Rule will both be in effect. Notably, more than 5 GW of new capacity came into the market with this auction, including new generation and new demand side resources such as energy efficiency and demand response. This outcome illustrates the diversity of ways that market participants can provide reliable power supplies wh ile meeting future environmental requirements. 5 3. Finding: By failing to consider repowering of existing facilities or the potential for additional energy efficiency or renewable energy as alternatives, EPA’s analysis likely overstates the system costs of comply ing with any option of the 316(b) rule. The methods of complying with the proposed Exis ting Facility Rule were an input to the EPA’s IPM modeling rather than an output of the mode l and were determined based on “an evaluation of baseline engineering factor s for facilities...in relation to the requirements of a given regulatory option.” As such, compliance was lim ited to technologies th at directly met the regulatory requirements. Other, in direct options such as repowering the facility to more efficient combined cycle technology at the same time that they would convert to closed-cycle cooling were not considered. Such repowering could re juvenate older less effi cient units that might otherwise retire because they w ould result in substantially lo wer production costs due to the newer, more efficient generating technology. This was a critical failure as repowering, when

5 Ensuring a Clean, Modern Electric Generating Fleet while Maintaining Electric System Reliability – Summer 2011 Update , Analysis Group and M.J. Bradle y & Associates, at pages 14-16.6 combined with retrofitting the unit to closed -cycle cooling, might provide a lower cost compliance alternative than repl acing it with new generation.
Reducing electric demand through energy efficien cy and/or demand response, or replacing generation with renewable energy that does not use cooling water are two options not considered by EPA in its rulemaking. Assu ming additional energy efficiency 6 or renewable resources could
be available could further reduce compliance costs. For example, EPA’s analysis of the Utility MACT rule showed that energy efficiency, by itself, reduced system-wide costs under the proposed rule by over $20 billion in 2030. Consequen tly, adding energy efficien cy as an indirect option reduced overall system-wide costs from the base case, more than making up for any costs of complying with the proposed MACT rule. Unfortunately, no similar energy efficiency sensitivity was included in the EPA’s modeling of the proposed 316(b) Existing Facility Rule.
4. Finding: The NERC 2010 Special Reliability Scenar io Assessment: Resource Adequacy Impacts of Potential Environmental Regulations severely overstates the impact of the EPA’s adoption of a 316(b) Existing Facility Rule.
NERC’s 2010 Special Reliability Scenario Assessme nt: Resource Adequacy Impacts of Potential Environmental Regulations (“NERC Special Assessment”) c oncludes that the Section 316(b) Cooling Water Intake Structures Rule “has th e greatest potential imp act on planning reserve margins,” making 37-41 GW of existing gene rating capacity economically vulnerable to
retirement. 7 As a result, NERC finds thatthe planning reserve margin s in almost half of its regions/subregions fall below its Reference Margin level by 2015.
However, the Special Assessment severely overstat es, in a number of ways, the impact of the options that the EPA actually is considering for its 316(b) Existing Facility Rule.
First, the proposed rule actua lly issued by EPA sets compliance deadlines beyond the 2018 date assumed by NERC -- 2022 for fossil units and 2027 for nuclear units. Consequently, there should be none of the significant adverse impacts that the NERC Special Assessment finds in 2015 and 2018 as it accelerated a large por tion of the plant retirements into the years before 2018.

6 Energy efficiency refers to measures that reduce end-use electrical consumption,

7 2010 Special Reliability Scenario Assessment; Reso urce Adequacy Impacts of Potential Environmental Regulations , at page iv.7 Second, NERC failed to allow for a variance of a ny kind in any 316(b) Existing Facility Rule adopted by EPA. In fact such a variance (also referred to as “alternativ e requirements”) from a closed-cycle cooling performance standard is in cluded in EPA’s Phase I rule for new facilities. 8 In addition, EPA explained in a document genera ted during the OMB review process that its proposed “one-size-fits-all” regul atory options for entrainment (i.e., Options 2 and 3) would include “variances [as] would be necessary to address the site-specific limitations on installation of closed-cycle.” 9

Indeed, ERCOT’s recent Review of the Potential Impac ts of Proposed Environmental Regulations on the ERCOT System noted that the “proposed [E PA 316(b)] regulations provide for flexibility and development of site-specific solutions:”

There is sufficient discussion in th e regulations about site-specific solutions to indicate that power plants that are operated infrequently to maintain system reliability under peak load conditions may not be required to install expensive closed-loop cooling equipment. 10 Significantly, EPA did not attempt to model the e ffect of a variance (because the agency did not know which plants might seek and qualify for a variance), but EPA’s IPM modeling nevertheless found that a closed-cycle cooling mandate, even without a variance, would cause no more than
17 GW of retirements. If a vari ance were factored into the mode ling, the number of retirements would be less than the 17 GW EPA projecte d and far less than the 37-41 GW that NERC considered economically vulnerable.
Third, the NERC Special Assessment is based on an economic approach that identifies which units may retire if the generic required cost of compliance with the proposed environmental regulation exceeds the cost of replacement power, which is considered to be gas-fired capacity. 11 However, the Special Assessment does not assu me that any replacement capacity actually is added to the system. In other words, even though it assumes that a substantial amount of existing capacity would be retired and, c onsequently, that planning reserv e margins would be inadequate,

8 See proposed 40 CFR 125.94(d)(4).

9 See E.O. 12866 Review Draft (EPA-HQ-OW-2008-0667-1295.1) at page 125 of 383.

10 Id, at page 15.

11 Id, at page 8.8 no additional capacity is being built. This is an unrealistic and unreasonable assumption which heavily biases the Special Assessment.
Indeed, the Special Assessment itself presents a long list of potential actions that system operators and companies can take to minimize the adverse impact of plant retirements on electric system reliability. For example, the NERC repor t notes that companies can seek waivers or extensions from the pending EPA regulations. 12 Other actions that the Special Assessment lists for mitigating system reliability concerns include:

• Advancing in-service dates of fu ture or conceptual resources

• Addition of new resources not yet proposed

• Increased demand-side management and conservation

• Early action to mitigate severe losses including - planning and constructi ng retrofits immediately - managing retrofit timing to keep capacity supply by region stable

• Increase in capacity import transfer capabilities

• Developing or explorin g newer technologies

• Use of more gas-fired generation

• Repowering of coal-fired generation as combined cycle units 13 However, despite listing these measures as options for offsetting generating unit retirements, the Special Assessment then assumes that none of these measures are actually adopted or implemented as no new supply-side capacity or demand-side measur es are added in place of any of the retired capacity.
In fact, a significant portion of the generating unit retirements made public to date have been accompanied by an announcement that the plant owners plan to replace the ca pacity being retired with new generating facilities. For example, X cel Energy has replaced three of its coal-fired power plants with efficient new combined cycle capacity since 2002 and is now seeking permission from the Minnesota Public Utilities Commission to repower a nother two coal units

12 Id, at page 40.

13 Id.9 with combined cycle technology. 14 Xcel has told the Minnesota PUC that replacing the two existing coal units with new combined cycl e technology actually will increase its system capacity by 410 MW -- that is, 680 MW of new co mbined cycle capacity less the 270 MW of existing coal capacity being retired. 15

Other utilities, such as Progress Energy and Duke Energy are taking similar actions. As Progress Energy explained in its 2010 Integrated Resour ce Plan filing in North Carolina Utilities Commission Docket No. E-100, Sub 128, the Co mpany is planning to replace 1500 MW of older, inefficient coal capacity with 1500 MW of state-of-the-art gas-fired combined cycle capacity.
As stated in last year’s plan, th e current environm ent presents many significant challenges to deal with fr om a resource planning perspective, e.g., historic levels of fuel pr ice volatility, tremendous economic uncertainty, potential federal enviro nmental legislation dealing with regulation of carbon emissions, proposal s for Federal renewable portfolio standards, the proposed new Envir onmental Protection Agency (“EPA”) Transport Rule, the expected EPA Maximum Achievable Control Technology (“MACT”) mercury rule, the potential consideration of coal ash as hazardous waste by EPA, and customer behavior and usage changes. What continues to be one of the most notable examples of such uncertainty is the potential for environmental and climate change legislation. Even though at the time of this filing there appears to be a temporary loss in legislative momentum with respect to cl imate change it is widely assumed there will ultimat ely be legislation of some form resulting in a mandate to reduce th e carbon output from the Company’s generation fleet. This potential legi slation paired w ith proposed and expected EPA regulations regarding greenhouse gas emissions led to the Company’s decision to retire three coal units at each of its Lee and Sutton facilities and construct new state of th e art efficient natural gas combined cycle units at those sites.
These same considerations have cause d the Company to conclude that it should plan to retire its remaini ng uncontrolled coal units in North Carolina at the beginning of 2015. It s hould be noted that this projected date is still subject to movement pending the outcome of many of the legislative initiatives listed in th e Company’s Coal Retirement Plan approved by the North Carolina Utili ties Commission as well as continued movement in underlying fuel prices. As a cumulative result of the new

14 Xcel Energy Minnesota 2010 Resource Plan, at pages 6-2 and 6-3.

15 Id, at page 6-12.10 gas fired combined cycles being cons tructed at the Lee and Sutton sites and the associated retirement of elev en coal units at the Lee, Sutton, Weatherspoon and Cape Fear sites, the Company will have replaced approximately 1500 MWs of unscrubbed coal generation with 1500 MWs of state of the art gas fired genera tion. Benefits of this portfolio modernization include both environm ental benefits, in the form of significant reductions in the output of SO 2 , NO x , mercury and CO 2 , as well as fuel diversification benefits resu lting from the addition of the new gas fired generation. [Progress Energy Caro linas] continues to evaluate the best course of action with regard to its South Carolina Robinson coal plant. 16 Fourth, the Special Assessment overstates the amount of existing capacity that would be economically vulnerable under any new 316( b) Existing Facility Rule by using unreasonably low replacement costs (in $/ MWH) that are based on an assumed 90 percent capacity factor for new combined cycle units. 17 No analysis or assessment, of which we are aware, has assumed that a new gas-fired combined cycle unit will achieve a 90 percent annual capacity factor on a sustaine d basis. Instead, it is generally accepted that new combined cycle units can be exp ected to achieve betw een 65 percent and 75 percent annual capacity factors. The aver age replacement costs in $/MWH will be higher with such a range of more reasonable capacity factors becau se the same capital and fixed operating costs will be spread over fewer MWHs than if it is assumed that the new unit will achieve a 90 percent annual capacity factor. Consequently, it is reasonable to expect that fewer existing generating units would be economically vul nerable, and hence retired, if a lower annual capacity factor were us ed for the replacement gas capacity in the analysis.
5. Finding: The May 2011 Review of the Potential Impac ts of Proposed Environmental Regulations on the ERCOT System similarly significantly ov erstates the impact that adoption of the 316(b) Existing Facility Rule being considered by the EPA would have on generating unit retirements and electric system reliability.
ERCOT’s recent Review of the Potential Impacts of Pr oposed Environmental Regulations on the ERCOT System (“ERCOT Review”) concl uded that approximately 1,200 MW of coal-fired

16 Progress Energy Carolinas 2010 Integrated Resource Plan – NCUC Docket No. E-100, Sub 128 , September 13, 2010, at page 3.

17 2010 Special Reliability Scenario Assessment; Reso urce Adequacy Impacts of Potential Environmental Regulations , at pages 44-45.11 capacity and 8,100 MW of gas-fired generation w ould be retired as a result of a closed-loop cooling tower requirement. 18 However, like the NERC Special Assessment, the ERCOT Review severely overstates the impact of the EPA’s adoption of any of the regulatory options it is currently evaluating for a 316( b) Existing Facility Rule.
First, the ERCOT Review notes that the “p roposed [EPA 316(b)] regulations provide for flexibility and development of site-specific solutions:”

There is sufficient discussion in th e regulations about site-specific solutions to indicate that power plants that are operated infrequently to maintain system reliability under peak load conditions may not be required to install expensive closed-loop cooling equipment. 19
However, the ERCOT Review nevertheless assume s that there would be no such “flexibility” and that, instead, the EPA will require that closed-loop cooling tower systems be installed by 2017 at all existing facilities that cu rrently utilize on ce-through cooling. 20

Second, the ERCOT Review does not assume that any replacement generation would be built despite its acknowledgement that:
A robust wholesale energy market s hould provide sufficient new sources of generation to replace retired units if there is adequate time for changing market conditions to incent new investment. 21

And: In the scenarios resulting in significant retirements of existing generation, it is expected that much of the reti red generation would be replaced with new generation capacity. Analysis of potential generation expansion was not included in the scope of this analysis. 22 As discussed above with regard to the NERC Sp ecial Assessment, this is not a reasonable assumption. It leads to unnecessarily and unrealistic ally dire predictions a bout system reliability.
Moreover, the Review also acknowledged that in many cases, the 8,100 MW of older gas steam capacity that may be subject to re trofit requirements are less effi cient and less flexible than new

18 Table 3, at page 12.

19 Id, at page 15.

20 Id, at pages 2 and 7.

21 Id, at page 9.

22 Id, at page 12.12 quick-start gas-fired generation a nd are nearing the end of their us eful lives. Consequently, those units may be retired in the near future whet her or not the EPA adopt s any of the regulatory options for a 316(b) Existing Facility Rule curren tly under consideration. This is especially true if the integration of additional variable gene ration sources (“wind”) in ERCOT continues to place increased value on quick-start gene ration, as noted in the ERCOT Review:
Older gas-steam generation typically has significant range between maximum and minimum output, but it cannot start and stop quickly in response to changing market needs. The integration of variable generation in ERCOT has led to increased value in quick-start genera tion. This trend is expected to become more pronounced when the transmission improvements designed for the Competitive Renewable Energy Zones (CREZ) [are] complete, currently sche duled for late 2013. The analysis in this study does not assume any increa se in wind generation, so impact of the CREZ build-out would further erode [the] market value of older gassteam generation. 23 For these reasons, the ERCOT Review does not provi de a realistic view of the impact that the EPA’s adoption of any of the regulatory options fo r a 316(b) Existing Facility Rule that it is currently considering.

23 Id, at page 16.David Schlissel Page 1 Schli ssel Technical Consulting, Inc. 

## David A. Schlissel

President Schlissel Technical Consulting, Inc. 45 Horace Road, Belmont, MA 02478 (617) 489-4840 david@schlissel-technical.com

SUMMARY I have worked for thirty six years as a consultant and attorney on complex management, engineering, and economic issues, primarily in the field of energy. This work has involved conducting technical investigations, preparing economic analyses, presenting expert testimony, providing support during all phases of regulatory proceedings and litigation, and advising clients during settlement negotiations. I received undergradua te and advanced engineering degrees from the Massachusetts Institute of Technology and Stanford University, respectively, and a law degree from Stanford Law School.

PROFESSIONAL EXPERIENCE Electric Resource Planning - Analyzed the economic costs and benefits of energy supply options. Examined whether there are lower cost, lower risk alternatives than proposed fossil and nuclear power plants. Evaluated the economic and system reliability consequences of retiring existing electric generating facilities. Investigated whether new electric generating facilities are used and useful. Investigated whether new generating facilities that were built for a deregulated subsidiary should be included in the rate base of a regulated utility. Assessed the reasonableness of proposed utility power purchase agreements w ith deregulated affiliates. Investigated the prudence of utility power purchases in deregulated markets.
Coal-fired Generation – Evaluated the economic and financial risks of investing in, constructing and operating new coal-fired power plants. Analyzed the economic and financial risks of making expensive environmental and other upgrades to existing plants. Investigatedwhether plant owners had adequately considered the risks associated with building new fossilfired power plants, the most significant of wh ich are the likelihood of federal regulation of greenhouse gas emissions and construction cost increases.
Power Plant Air Emissions – Investigated whether proposed generating facilities would provide environmental benefits in terms of reduced emissions of NO x , SO 2 and CO 2 . Examined whether new state and federal emission standards would lead to the retirement of existing power plants or otherwise have an adverse impact on electric system reliability.
Power Plant Water Use – Examined power plant repowering as a strategy for reducing water consumption at existing electric generating facilities. Analyzed the impact of converting power plants from once-through to closed-loop systems with cooling towers on plant revenues and electric system reliability. Evaluated the potential impact of the EPA’s Proposed Clean Water Act Section 316(b) Rule for Cooling Water Intake Structures at existing power plants.David Schlissel Page 2 Schlisse l Technical Consulting, Inc. Electric System Reliability - Evaluated whether existing or new generation facilities and transmission lines are needed to ensure adequate levels of system reliability. Investigated the causes of distribution system outages and inadequate service reliability. Examined the reasonableness of utility system reliability expenditures. Power Plant Repowering - Evaluated the environmental, economic and reliability impacts of rebuilding older, inefficient generating facilities with new combined cycle technology. Power Plant Operations and Economics - Investigated the causes of more than one hundred power plant and system outages, equipment failures, and component degradation, determined whether these problems could have been anticipated and avoided, and assessed liability for repair and replacement costs. Examined power plant operating, maintenance, and capital costs. Evaluated utility plans for and management of the replacement of major power plant components. Assessed the adequacy of power plant quality assurance and maintenance programs. Examined the selection and superv ision of contractors and subcontractors.
Nuclear Power – Reviewed recent cost estimates for proposed nuclear power plants. Examined the impact of the nuclear power plant life extensions and power uprates on decommissioning costs and collections policies. Examined the reasonableness of utility decisions to sell nuclear power assets and evaluated the value received as a result of the auctioning of those plants. Investigated the significance of the increasing ownership of nuclear power plants by multiple tiered holding companies with limited liability company subsidiaries. Investigated the potential safety consequences of nuclear power plant structure, system, and component failures. Transmission Line Siting – Examined the need for proposed transmission lines. Analyzed whether proposed transmission lines could be installed underground. Worked with clients to develop alternate routings for proposed lines that would have reduced impacts on the environment and communities. Electric Industry Regulation and Markets - Examined whether generating facilities experienced more outages following the transition to a deregulated wholesale market in New England. Evaluated the reasonableness of nuclear and fossil plant sales, auctions, and power purchase agreements. Analyzed the impact of proposed utility mergers on market power. Assessed the reasonableness of contract provisions and terms in proposed power supply agreements. Expert Testimony - Presented the results of management, technical and economic analyses as testimony in more than 100 proceedings before regulatory boards and commissions in 35 states, before two federal regulatory agencies, and in state and federal court proceedings. Litigation and Regulatory Support - Participated in all aspects of the development and preparation of case presentations on complex management, technical, and economic issues. Assisted in the preparation and conduct of pre-trial discovery and depositions. Helped identify and prepare expert witnesses. Aided the prepar ation of pre-hearing petitions and motions and post-hearing briefs and appeals. Assisted counsel in preparing for hearings and oral arguments. Advised counsel during settlement negotiations.David Schlissel Page 3 Schlisse l Technical Consulting, Inc. TESTIMONY, AFFIDAVITS, DEPOSITIONS AND COMMENTS Kansas State Corporation Commission (D ocket No. 11-KCPE-581-PRE) – June 2011 The reasonableness of the proposed environmental upgrades at the La Cygne Generating Station Units 1 and 2.
Arizona Corporation Commission (Docket No. E-01345A-10-0474) – May 2011 The reasonableness of Arizona Public Service Company’s proposed acquisition of Southern California Edison’s share of Four Corners Units 4 and 5.
Public Utility Commission of Colorado (Docket No. 10M-245E) – September, October and November 2010 The reasonableness of Public Service of Colorado’s proposed Emissions Reduction Plan.
Indiana Utility Regulatory Commission (Cause No. 43114 IGCC 4S1) – July and November 2010 The reasonableness of Duke Energy Indiana’s new analyses of the economics of completing the Edwardsport Project as an IGCC plant.
Oregon Public Utility Commission (Docket LC 48) – May and August 2010 Comments and Reply Comments on Portland Ge neral Electric Company’s 2009 Integrated Resource Plan.
South Dakota Public Service Commission (Docket No. EL-09-018) – April 2010 The reasonableness of Black Hills Power Company’s 2007 Integrated Resource Plan and the Company’s decision to build the Wygen III coal-fired power plant.
Michigan Public Service Commission (Docket No. U-16077) – April 2010 Comments on the City of Holland Board of Public Works’ 2010 Power Supply Study.
Illinois Commerce Commission (Tenaska Clean Coal Facility Analysis) – April 2010 Comments on the Facility Cost Report for the proposed Taylorville IGCC power plant.
North Carolina Utilities Commission (Docket No. E-100, Sub 124) – February 2010 The reasonableness of the 2009 Integrated Resource Plans of Duke Energy Carolinas and Progress Energy Carolinas.
Mississippi Public Service Commission (Docket No. 2009-UA-014) – December 2009 The costs and risks associated with the proposed Kemper County IGCC power plant.

Public Service Commission of Wisconsi n (Docket No. 05-CE-137) –December 2009 and January 2010 The costs and risks associated with the proposed installation of emissions control equipment at the Edgewater Unit 5 coal-fired power plant.David Schlissel Page 4 Schlisse l Technical Consulting, Inc. Public Service Commission of Wisconsin (D ocket No. 05-CE-138) –September and October 2009 The costs and risks associated with the proposed installation of emissions control equipment at the Columbia 1 and 2 coal-fired power plants.
Public Service Commission of Michigan (Docket No. U-15996) – July 2009 Comments on Consumer Energy’s Electric Generation Alernatives Analysis for the Balanced Energy Initiative including the Proposed Karn-Weadock Coal Plant.
Public Service Commission of Michigan (Docket No. U-16000) – Juy 2009 Comments on Wolverine Power Cooperative’s Electric Generation Alternatives Analysis for the Proposed Rogers City Coal Plant. Georgia Public Service Commission (Docket No. 27800-U) – December 2008 The possible costs and risks of proceeding with the proposed Plant Vogtle Units 3 and 4 nuclear power plants.

Public Service Commission of Wisconsi n (Docket No. 6680-CE-170) – August and Sepember 2008 The risks associated with the proposed Nelson Dewey 3 baseload coal-fired power plant.
Indiana Utility Regulatory Commission (Cause No. 43114 IGCC 1) – July 2008 The estimated cost of Duke Energy Indiana’s Edwardsport Project.
Public Service Commission of Maryland (Case 9127) – July 2008 The estimated cost of the proposed Calvert Cliffs Unit 3 nuclear power plant.
Ohio Power Siting Board (Case No. 06-1358-EL-BGN) – December 2007 AMP-Ohio’s application for a Certificate of Environmental Compatibility and Public Need for a 960 MW pulverized coal generating facility.
U.S. Nuclear Regulatory Commission (Docket Nos. 50-247-LR, 50-286-LR) – November 2007 and February 2009 The available options for replacing the power generated at Indian Point Unit 2 and/or Unit 3.
West Virginia Public Service Commission (Case No. 06-0033-E-CN) – November 2007 Appalachian Power Company’s application for a Certificate of Public Convenience and Necessity for a 600 MW integrated gasification combined cycle generating facility.
Iowa Utility Board (Docket No. GCU-07-01) – October 2007 Whether Interstate Power & Light Company’s adequately considered the risks associated with building a new coal-fired power plant and whether that Company’s participation in the proposed Marshalltown plant is prudent.
Virginia State Corporation Commission (Case No. PUE-2007-00066) – November 2007David Schlissel Page 5 Schlisse l Technical Consulting, Inc. Whether Dominion Virginia Power’s adequately considered the risks associated with building the proposed Wise County coal-fired power plant and whether that Commission should grant a certificate of public convenience and necessity for the plant.
Louisiana Public Service Commission (Docket No. U-30192) – September 2007 The reasonableness of Entergy Louisiana’s proposal to repower the Little Gypsy Unit 3 generating facility as a coal-fired power plant.

Arkansas Public Service Commission (Docket No. 06-154-U) – July 2007 The probable economic impact of the Southwestern Electric Power Company’s proposed Hempstead coal-fired power plant project.
North Dakota Public Service Commission (Case Nos. PU-06-481 and 482) – May 2007 and April 2008 Whether the participation of Otter Tail Power Company and Montana-Dakota Utilities in the Big Stone II Generating Project is prudent.
Indiana Utility Regulatory Commission (Cause No. 43114) – May 2007 The appropriate carbon dioxide (“CO 2 ”) emissions prices that should be used to analyze the relative economic costs and benefits of Duke Energy Indiana and Vectren Energy Delivery of Indiana’s proposed Integrated Gasification Combined Cycle Facility and whether Duke and Vectren have appropriately reflected the capital cost of the proposed facility in their modeling analyses.

Public Service Commission of Wisconsin (Docket No. 6630-EI-113) – May and June 2007 Whether the proposed sale of the Point Beach Nuclear Plant to FPL Energy Point Beach, LLC, is in the interest of the ratepayers of Wisconsin Electric Power Company.
Florida Public Service Commission (Docket No. 070098-EI) – March 2007 Florida Light & Power Company’s need for and the economics of the proposed Glades Power Park.
Michigan Public Service Commission (Case No. 14992-U) – December 2006 The reasonableness of the proposed sale of the Palisades Nuclear Power Plant.
Minnesota Public Utilities Commission (Docket No. CN-05-619) – November 2006, December 2007, January 2008 and November 2008 Whether the co-owners of the proposed Big Stone II coal-fired generating plant have appropriately reflected the potential for the regulation of greenhouse gases in their analyses of the facility; and whether the proposed project is a lower cost alternative than renewable options, conservation and load management.David Schlissel Page 6 Schlisse l Technical Consulting, Inc. North Carolina Utilities Commission (Docket No. E-7, Sub 790) – September 2006 and January 2007 Duke’s need for two new 800 MW coal-fired generating units and the relative economics of adding these facilities as compared to other available options including energy efficiency and renewable technologies.
New Mexico Public Regulatory Commission (Case No. 05-00275-UT) – September 2006 Report to the New Mexico Commission on whether the settlement value of the adjustment for moving the 141 MW Afton combustion turbine merchant plant into rate base is reasonable.
Arizona Corporation Commission (Docket No. E-01345A-0816) – August and September 2006 Whether APS’s acquisition of the Sundance Generating Station was prudent and the reasonableness of the amounts that APS requested for fossil plant O&M.

U.S. District Court for the District of Mont ana (Billings Generation, Inc. vs. Electrical Controls, Inc, et al., CV-04-123-BLG-RFC) – August 2006 Quantification of plaintiff’s business losse s during an extended power plant outage and plaintiff’s business earnings due to the shor tening and delay of future plant outages. [Confidential Expert Report]
Deposition in South Dakota Public Utility Commission Case No. EL05-022 – June 14, 2006
South Dakota Public Utility Commission (Case No. EL05-022) – May and June 2006 Whether the co-owners of the proposed Big Stone II coal-fired generating plant have appropriately reflected the potential for the regulation of greenhouse gases in their analyses ofthe alternatives to the proposed facility; the need and timing for new supply options in the coowners’ service territories; and whether there are alternatives to the proposed facility that are technically feasible and economically cost-effective.
Georgia Public Service Commission (Docket No. 22449-U) – May 2006 Georgia Power Company’s request for an accounting order to record early site permitting and construction operating license costs for new nuclear power plants.
California Public Utilities Commission (Docke ts Nos. A.05-11-008 and A.05-11-009) – April 2006 The estimated costs for decommissioning the Diablo Canyon, SONGS 2&3 and Palo Verde nuclear power plants and the annual contributions that are needed from ratepayers to assure that adequate funds will be available to decommission these plants at the projected ends of their service lives.
New Jersey Board of Public Utilities (Docket No. EM05020106) – November and December 2005 and March 2006 Joint Testimony with Bob Fagan and Bruce Biewald on the market power implications of the proposed merger between Exelon Corp. and Public Service Enterprise Group.David Schlissel Page 7 Schlisse l Technical Consulting, Inc. Virginia State Corporation Commission (Case No. PUE-2005-00018)– November 2005 The siting of a proposed 230 kV transmission line.

Iowa Utility Board (Docket No. SPU-05-15) – September and October 2005 The reasonableness of IPL’s proposed sale of the Duane Arnold Energy Center nuclear plant. New York State Department of Enviro nmental Conservation (DEC #3-3346-00011/00002) – October 2005 The likely profits that Dynegy will earn from the sale of the energy and capacity of the Danskammer Generating Facility if the plant is converted from once-through to closed-cycle cooling with wet towers or to dry cooling.
Arkansas Public Service Commission (Docket 05-042-U) – July and August 2005 Arkansas Electric Cooperative Corporation’s proposed purchase of the Wrightsville Power Facility.
Maine Public Utilities Commission (Docket No. 2005-17) – July 2005 Joint testimony with Peter Lanzalotta and Bob Fagan evaluating Eastern Maine Electric Cooperative’s request for a CPCN to purchase 15 MW of transmission capacity from New Brunswick Power.
Federal Energy Regulatory Commission (Docket No. EC05-43-0000) – April and May 2005 Joint Affidavit and Supplemental Affidavit with Bruce Biewald on the market power aspects of the proposed merger of Exelon Corporation and Public Service Enterprise Group, Inc.
Maine Public Utilities Commission (Docket No. 2004-538 Phase II) – April 2005 Joint testimony with Peter Lanzalotta and Bob Fagan evaluating Maine Public Service Company’s request for a CPCN to purchase 35 MW of transmission capacity from New Brunswick Power.
Maine Public Utilities Commission (Docket No. 2004-771) – March 2005 Analysis of Bangor Hydro-Electric’s Petition fo r a Certificate of Public Convenience and Necessity to construct a 345 kV transmission line

United States District Court for the Sout hern District of Ohio, Eastern Division (Consolidated Civil Actions Nos. C2-99-1182 and C2-99-1250) Whether the public release of company documents more than three years old would cause competitive harm to the American Electric Power Company. [Confidential Expert Report]
New Jersey Board of Public Utilities (Docket No. EO03121014) – February 2005 Whether the Board of Public Utilities can halt further collections from Jersey Central Power & Light Company’s ratepayers because there already are adequate funds in the company’s decommissioning trusts for the Three Mile Island Unit No. 2 Nuclear Plant to allow for the decommissioning of that unit without endangered the public health and safety.David Schlissel Page 8 Schlisse l Technical Consulting, Inc. Maine Public Utilities Commission (Docket No. 2004-538) – January and March 2005 Analysis of Maine Public Service Company’s request to construct a 138 kV transmission line from Limestone, Maine to the Canadian Border.
California Public Utilities Commission (A pplication No. AO4-02-026) – December 2004 and January 2005 Southern California Edison’s proposed replacement of the steam generators at the San Onofre Unit 2 and Unit 3 nuclear power plants and whether the utility was imprudent for failing to initiate litigation against Combustion Engineering due to defects in the design of and materials used in those steam generators.

United States District Court for the Southern District of Indiana, Indianapolis Division (Civil Action No. IP99-1693) – December 2004 Whether the public release of company documents more than three years old would cause competitive harm to the Cinergy Corporation. [Confidential Expert Report]
California Public Utilities Commission (A pplication No. AO4-01-009) – August 2004 Pacific Gas & Electric’s proposed replacement of the steam generators at the Diablo Canyon nuclear power plant and whether the utility was imprudent for failing to initiate litigation against Westinghouse due to defects in the design of and materials used in those steam generators.

Public Service Commission of Wisconsin (Docket No. 6690-CE-187) – June, July and August 2004 Whether Wisconsin Public Service Corporation’s request for approval to build a proposed 515 MW coal-burning generating facility should be granted.

Public Service Commission of Wisconsin (Docket No. 05-EI-136) – May and June 2004Whether the proposed sale of the Kewaunee Nuclear Power Plant to a subsidiary of an out-ofstate holding company is in the public interest.
Connecticut Siting Council (Docket No. 272) – May 2004 Whether there are technically viable alternatives to the proposed 345-kV transmission line between Middletown and Norwalk Connecticut and the length of the line that can be installed underground.
Arizona Corporation Commission (Docket No. E-01345A-03-0437 – February 2004 Whether Arizona Public Service Company should be allowed to acquire and include in rate base five generating units that were built by a deregulated affiliate.
State of Rhode Island Energy Facilities Siting Board (Docket No. SB-2003-1) – February 2004 Whether the cost of undergrounding a relocated 115kV transmission line would be eligible for regional cost socialization.David Schlissel Page 9 Schlisse l Technical Consulting, Inc. State of Maine Department of Environmen tal Protection (Docket No. A-82-75-0-X) – December 2003 The storage of irradiated nuclear fuel in an Independent Spent Fuel Storage Installation (ISFSI) and whether such an installation represents an air pollution control facility.
Rhode Island Public Utility Commission (Docket No. 3564) – December 2003 and January 2004 Whether Narragansett Electric Company should be required to install a relocated 115kV transmission line underground.

New York State Board on Electric Generation Siting and the Environment (Case No. 01-F1276) – September, October and November 2003 The environmental, economic and system reliability benefits that can reasonably be expected from the proposed 1,100 MW TransGas Energy generating facility in Brooklyn, New York.
Wisconsin Public Service Commission (Case 6690-UR-115) - September and October 2003 The reasonableness of Wisconsin Public Service Corporation’s decommissioning cost collections for the Kewaunee Nuclear Plant.
Oklahoma Corporation Commission (Cause No. 2003-121) – July 2003Whether Empire District Electric Company properly reduced its capital costs to reflect the writeoff of a portion of the cost of building a new electric generating facility.
Arkansas Public Service Commission (Docket 02-248-U) – May 2003 Entergy's proposed replacement of the steam generators and the reactor vessel head at the ANO Unit 1 Steam Generating Station.
Appellate Tax Board, State of Massachusetts (Docket No C258405-406) – May 2003 The physical nature of electricity and whether electricity is a tangible product or a service.
Maine Public Utilities Commission (Docket 2002-665-U) – April 2003 Analysis of Central Maine Power Company’s proposed transmission line for Southern York County and recommendation of alternatives.
Massachusetts Legislature, Joint Committees on Government Regulations and Energy – March 2003 Whether PG&E can decide to permanently retire one or more of the generating units at its Salem Harbor Station if it is not granted an extension beyond October 2004 to reduce the emissions from the Station’s three coal-fired units and one oil-fired unit.
New Jersey Board of Public Utilities (Docket No. ER02080614) – January 2003 The prudence of Rockland Electric Company’s power purchases during the period August 1, 1999 through July 31, 2002.David Schlissel Page 10 Schlisse l Technical Consulting, Inc. New York State Board on Electric Generation Siting and the Environment (Case No. 00-F1356) – September and October 2002 and January 2003 The need for and the environmental benefits from the proposed 300 MW Kings Park Energy generating facility.

Arizona Corporation Commission (Docket No. E-01345A-01-0822) – May 2002 The reasonableness of Arizona Public Service Company’s proposed long-term power purchase agreement with an affiliated company.

New York State Board on Electric Generation Siting and the Environment (Case No. 99-F1627) – March 2002 Repowering NYPA’s existing Poletti Station in Queens, New York.
Connecticut Siting Council (Docket No. 217) – March 2002, November 2002, and January 2003 Whether the proposed 345-kV transmission line between Plumtree and Norwalk substations in Southwestern Connecticut is needed and will produce public benefits.
Vermont Public Service Board (Case No. 6545) – January 2002 Whether the proposed sale of the Vermont Yankee Nuclear Plant to Entergy is in the public interest of the State of Vermont and Vermont ratepayers.
Connecticut Department of Public Utilit y Control (Docket 99-09-12RE02) – December 2001 The reasonableness of adjustments that Connecticut Light and Power Company seeks to make to the proceeds that it received from the sale of Millstone Nuclear Power Station.
Connecticut Siting Council (Docket No. 208) – October 2001 Whether the proposed cross-sound cable between Connecticut and Long Island is needed and will produce public benefits for Connecticut consumers.
New Jersey Board of Public Utilities (Docket No. EM01050308) - September 2001 The market power implications of the proposed merger between Conectiv and Pepco.
Illinois Commerce Commission Docket No. 01-0423 – August, September, and October 2001 Commonwealth Edison Company’s management of its distribution and transmission systems.

New York State Board on Electric Generation Siting and the Environment (Case No. 99-F1627) - August and September 2001 The environmental benefits from the proposed 500 MW NYPA Astoria generating facility.

New York State Board on Electric Generation Siting and the Environment (Case No. 99-F1191) - June 2001David Schlissel Page 11 Schlisse l Technical Consulting, Inc. The environmental benefits from the proposed 1,000 MW Astoria Energy generating facility.
New Jersey Board of Public Utilities (Docket No. EM00110870) - May 2001 The market power implications of the proposed merger between FirstEnergy and GPU Energy.
Connecticut Department of Public Utility Control (Docket 99-09-12RE01) - November 2000 The proposed sale of Millstone Nuclear Station to Dominion Nuclear, Inc.
Illinois Commerce Commission (Docket 00-0361) - August 2000 The impact of nuclear power plant life extensions on Commonwealth Edison Company's decommissioning costs and collections from ratepayers.
Vermont Public Service Board (Docket 6300) - April 2000 Whether the proposed sale of the Vermont Yankee nuclear plant to AmerGen Vermont is in the public interest.
Massachusetts Department of Telecommunications and Energy (Docket 99-107, Phase II) - April and June 2000 The causes of the May 18, 1999, main transformer fire at the Pilgrim generating station.
Connecticut Department of Public Utility Control (Docket 00-01-11) - March and April 2000 The impact of the proposed merger between Northeast Utilities and Con Edison, Inc. on the reliability of the electric service being provided to Connecticut ratepayers.
Connecticut Department of Public Utility Control (Docket 99-09-12) - January 2000 The reasonableness of Northeast Utilities plan for auctioning the Millstone Nuclear Station.
Connecticut Department of Public Utility Control (Docket 99-08-01) - November 1999 Generation, Transmission, and Distribution system reliability.
Illinois Commerce Commission (Docket 99-0115) - September 1999 Commonwealth Edison Company's decommissioning cost estimate for the Zion Nuclear Station.
Connecticut Department of Public Utility Control (Docket 99-03-36) - July 1999 Standard offer rates for Connecticut Light & Power Company.
Connecticut Department of Public Utility Control (Docket 99-03-35) - July 1999 Standard offer rates for United Illuminating Company.
Connecticut Department of Public Utility Control (Docket 99-02-05) - April 1999 Connecticut Light & Power Company stranded costs.
Connecticut Department of Public Utility Control (Docket 99-03-04) - April 1999 United Illuminating Company stranded costs.David Schlissel Page 12 Schlisse l Technical Consulting, Inc. Maryland Public Service Commission (Docket 8795) - December 1998 Future operating performance of Delmarva Power Company's nuclear units.
Maryland Public Service Commission (Dockets 8794/8804) - December 1998 Baltimore Gas and Electric Company's proposed replacement of the steam generators at the Calvert Cliffs Nuclear Power Plant. Future performance of nuclear units.
Indiana Utility Regulatory Commission (Docket 38702-FAC-40-S1) - November 1998 Whether the ongoing outages of the two units at the D.C. Cook Nuclear Plant were caused or extended by mismanagement.
Arkansas Public Service Commission (Docket 98-065-U) - October 1998 Entergy's proposed replacement of the steam generators at the ANO Unit 2 Steam Generating Station.
Massachusetts Department of Telecommunications and Energy (Docket 97-120) - October 1998 Western Massachusetts Electric Company's Transition Charge. Whether the extended 1996- 1998 outages of the three units at the Millstone Nuclear Station were caused or extended by mismanagement.
Connecticut Department of Public Utilit y Control (Docket 98-01-02) - September 1998 Nuclear plant operations, operating and capital costs, and system reliability improvement costs.
Illinois Commerce Commission (Docket 97-0015) - May 1998 Whether any of the outages of Commonwealth Edison Company's twelve nuclear units during 1996 were caused or extended by mismanagement. Whether equipment problems, personnel performance weaknesses, and program deficiencies could have been avoided or addressed prior to plant outages. Outage-related fuel and replacement power costs.
Public Service Commission of West Virginia (Case 97-1329-E-CN) - March 1998 The need for a proposed 765 kV transmission line from Wyoming, West Virginia, to Cloverdate, Virginia.
Illinois Commerce Commission (Docket 97-0018) - March 1998 Whether any of the outages of the Clinton Power Station during 1996 were caused or extended by mismanagement.
Connecticut Department of Public Utility Control (Docket 97-05-12) - October 1997 The increased costs resulting from the ongoing outages of the three units at the Millstone Nuclear Station.
New Jersey Board of Public Utilities (Docket ER96030257) - August 1996 Replacement power costs during plant outages.David Schlissel Page 13 Schlisse l Technical Consulting, Inc. Illinois Commerce Commission (Docket 95-0119) - February 1996 Whether any of the outages of Commonwealth Edison Company's twelve nuclear units during 1994 were caused or extended by mismanagement. Whether equipment problems, personnel performance weaknesses, and program deficiencies could have been avoided or addressed prior to plant outages. Outage-related fuel and replacement power costs.
Public Utility Commission of Texas (Docket 13170) - December 1994 Whether any of the outages of the River Be nd Nuclear Station during the period October 1, 1991, through December 31, 1993, were caused or extended by mismanagement.
Public Utility Commission of Texas (Docket 12820) - October 1994 Operations and maintenance expenses during out ages of the South Texas Nuclear Generating Station.
Wisconsin Public Service Commission (Cas es 6630-CE-197 and 6630-CE-209) - September and October 1994 The reasonableness of the projected cost and schedule for the replacement of the steam generators at the Point Beach Nuclear Power Plant. The potential impact of plant aging on future operating costs and performance.
Public Utility Commission of Texas (Docket 12700) - June 1994 Whether El Paso Electric Company's share of Palo Verde Unit 3 was needed to ensure adequate levels of system reliability. Whether the Company's investment in Unit 3 could be expected to generate cost savings for ratepayers within a reasonable number of years.
Arizona Corporation Commission (Docket U-1551-93-272) - May and June 1994 Southwest Gas Corporation's plastic and steel pipe repair and replacement programs.
Connecticut Department of Public Utility Control (Docket 92-04-15) - March 1994 Northeast Utilities management of the 1992/1993 replacement of the steam generators at Millstone Unit 2.
Connecticut Department of Public Utility Control (Docket 92-10-03) - August 1993 Whether the 1991 outage of Millstone Unit 3 as a result of the corrosion of safety-related plant piping systems was due to mismanagement.
Public Utility Commission of Texas (Docket 11735) - April and July 1993 Whether any of the outages of the Comanche Peak Unit 1 Nuclear Station during the period August 13, 1990, through June 30, 1992, were caused or extended by mismanagement.
Connecticut Department of Public Utility Control (Docket 91-12-07) - January 1993 and August 1995 Whether the November 6, 1991, pipe rupture at Millstone Unit 2 and the related outages of the Connecticut Yankee and Millstone units were caused or extended by mismanagement. The impact of environmental requirements on power plant design and operation.David Schlissel Page 14 Schlisse l Technical Consulting, Inc. Connecticut Department of Public Utilit y Control (Docket 92-06-05) - September 1992 United Illuminating Company off-system capacity sales. [Confidential Testimony]
Public Utility Commission of Texas (Docket 10894) - August 1992 Whether any of the outages of the River Be nd Nuclear Station during the period October 1, 1988, through September 30, 1991, were caused or extended by mismanagement.
Connecticut Department of Public Utility Control (Docket 92-01-05) - August 1992 Whether the July 1991 outage of Millstone Unit 3 due to the fouling of important plant systems by blue mussels was the result of mismanagement.
California Public Utilities Commission (Docket 90-12-018) - November 1991, April 1992, June and July 1993 Whether any of the outages of the three units at the Palo Verde Nuclear Generating Station during 1989 and 1990 were caused or extended by mismanagement. Whether equipment problems, personnel performance weaknesses and pr ogram deficiencies could have been avoided or addressed prior to outages. Whether specific plant operating cost and capital expenditures were necessary and prudent.
Public Utility Commission of Texas (Docket 9945) - June 1991 Whether El Paso Electric Company's share of Palo Verde Unit 3 was needed to ensure adequate levels of system reliability. Whether the Company's investment in the unit could be expected to generate cost savings for ratepayers within a reasonable number of years. El Paso Electric Company's management of the planning and li censing of the Arizona Interconnection Project transmission line.
Arizona Corporation Commission (Docket U-1345-90-007) - December 1990 and April 1991 Arizona Public Service Company's management of the planning, construction and operation of the Palo Verde Nuclear Generating Station. The costs resulting from identified instances of mismanagement.
New Jersey Board of Public Utilities (Docket ER89110912J) - July and October 1990 The economic costs and benefits of the early retirement of the Oyster Creek Nuclear Plant. The potential impact of the unit's early retirement on system reliability. The cost and schedule for siting and constructing a replacement natural gas-fired generating plant.
Public Utility Commission of Texas (Docket 9300) - June and July 1990 Texas Utilities management of the design and construction of the Comanche Peak Nuclear Plant. Whether the Company was prudent in repurchasing minority owners' shares of Comanche Peak without examining the costs and benefits of the repurchase for its ratepayers.
Federal Energy Regulatory Commission (Docket EL-88-5-000) - November 1989 Boston Edison's corporate management of the Pilgrim Nuclear Station.David Schlissel Page 15 Schlisse l Technical Consulting, Inc. Connecticut Department of Public Utility Control (Docket 89-08-11) - November 1989 United Illuminating Company's off-system capacity sales.
Kansas State Corporation Commission (Case 164,211-U) - April 1989 Whether any of the 127 days of outages of the Wolf Creek generating plant during 1987 and 1988 were the result of mismanagement.
Public Utility Commission of Texas (Docket 8425) - March 1989 Whether Houston Lighting & Power Company's new Limestone Unit 2 generating facility was needed to provide adequate levels of system reliability. Whether the Company's investment in Limestone Unit 2 would provide a net economic benefit for ratepayers.
Illinois Commerce Commission (Dockets 83-0537 and 84-0555) - July 1985 and January 1989 Commonwealth Edison Company's management of quality assurance and quality control activities and the actions of project contractors during construction of the Byron Nuclear Station.
New Mexico Public Service Commission (Case 2146, Part II) - October 1988 The rate consequences of Public Service Company of New Mexico's ownership of Palo Verde Units 1 and 2.

United States District Court for the Eastern District of New York (Case 87-646-JBW) - October 1988 Whether the Long Island Lighting Company withheld important information from the New York State Public Service Commission, the New York State Board on Electric Generating Siting and the Environment, and the U.S. Nuclear Regulatory Commission.
Public Utility Commission of Texas (Docket 6668) - August 1988 and June 1989 Houston Light & Power Company's management of the design and construction of the South Texas Nuclear Project. The impact of safety-related and environmental requirements on plant construction costs and schedule.
Federal Energy Regulatory Commission (Docket ER88-202-000) - June 1988 Whether the turbine generator vibration problems that extended the 1987 outage of the Maine Yankee nuclear plant were caused by mismanagement.
Illinois Commerce Commission (Docket 87-0695) - April 1988 Illinois Power Company's planning for the Clinton Nuclear Station.
North Carolina Utilities Commission (Docket E-2, Sub 537) - February 1988 Carolina Power & Light Company's management of the design and construction of the Harris Nuclear Project. The Company's management of quality assurance and quality control activities. The impact of safety-related and environmental requirements on construction costs and schedule. The cost and schedule consequences of identified instances of mismanagement.David Schlissel Page 16 Schlisse l Technical Consulting, Inc. Ohio Public Utilities Commission (Case 87-689-EL-AIR) - October 1987 Whether any of Ohio Edison's share of the Perry Unit 2 generating facility was needed to ensure adequate levels of system reliability. Whether the Company's investment in Perry Unit 1 would produce a net economic benefit for ratepayers.
North Carolina Utilities Commission (Docket E-2, Sub 526) - May 1987 Fuel factor calculations.
New York State Public Service Commission (Case 29484) - May 1987 The planned startup and power ascension testing program for the Nine Mile Point Unit 2 generating facility.
Illinois Commerce Commission (Dockets 86-0043 and 86-0096) - April 1987 The reasonableness of certain terms in a proposed Power Supply Agreement.
Illinois Commerce Commission (Docket 86-0405) - March 1987 The in-service criteria to be used to determine when a new generating facility was capable of providing safe, adequate, reliable and efficient service.
Indiana Public Service Commission (Case 38045) - November 1986 Northern Indiana Public Service Company's planning for the Schaefer Unit 18 generating facility. Whether the capacity from Unit 18 was needed to ensure adequate system reliability. The rate consequences of excess capacity on the Company's system.
Superior Court in Rockingham County, New Hampshire (Case 86E328) - July 1986 The radiation effects of low power testing on th e structures, equipment and components in a new nuclear power plant.
New York State Public Service Commission (Case 28124) - April 1986 and June 1987 The terms and provisions in a utility's contract with an equipment supplier. The prudence of the utility's planning for a new generating facility. Expenditures on a canceled generating facility.
Arizona Corporation Commission (Docket U-1345-85) - February 1986 The construction schedule for Palo Verde Unit N o. 1. Regulatory and technical factors that would likely affect future plant operating costs.
New York State Public Service Commission (Case 29124) – December 1985 and January 1986 Niagara Mohawk Power Corporation's management of construction of the Nine Mile Point Unit No. 2 nuclear power plant.
New York State Public Service Commission (Case 28252) - October 1985 A performance standard for the Shoreham nuclear power plant.
New York State Public Service Commission (Case 29069) - August 1985 A performance standard for the Nine Mile Point Unit No. 2 nuclear power plant.David Schlissel Page 17 Schlisse l Technical Consulting, Inc. Missouri Public Service Commission (Cases ER-85-128 and EO-85-185) - July 1985 The impact of safety-related regulatory requirements and plant aging on power plant operating costs and performance. Regulatory factors and plant-specific design features that will likely affect the future operating costs and performance of the Wolf Creek Nuclear Plant.
Massachusetts Department of Public Utilities (Case 84-152) - January 1985 The impact of safety-related regulatory requirements and plant aging on power plant operating costs and performance. Regulatory factors and plant-specific design features that will likely affect the future operating costs and performance of the Seabrook Nuclear Plant.
Maine Public Utilities Commission (Docket 84-113) - September 1984 The impact of safety-related regulatory requirements and plant aging on power plant operating costs and performance. Regulatory factors and plant-specific design features that will likely affect the future operating costs and performance of the Seabrook Nuclear Plant.
South Carolina Public Service Commission (Case 84-122-E) - August 1984 The repair and replacement strategy adopted by Carolina Power & Light Company in response to pipe cracking at the Brunswick Nuclear Sta tion. Quantification of replacement power costs attributable to identified instances of mismanagement.
Vermont Public Service Board (Case 4865) - May 1984 The repair and replacement strategy adopted by management in response to pipe cracking at the Vermont Yankee nuclear plant.
New York State Public Service Commission (Case 28347) -January 1984 The information that was available to Niagara Mohawk Power Corporation prior to 1982 concerning the potential for cracking in safety-related piping systems at the Nine Mile Point Unit No. 1 nuclear plant.
New York State Public Service Commission (Case 28166) - January 1983 and February 1984 Whether the January 25, 1982, steam generator tube rupture at the Ginna Nuclear Plant was caused by mismanagement.
U.S. Nuclear Regulatory Commission (Case 50-247SP) - May 1983 The economic costs and benefits of the early retirement of the Indian Point nuclear plants.David Schlissel Page 18 Schlisse l Technical Consulting, Inc. REPORTS, ARTICLES, AND PRESENTATIONS The Economics of Existing Coal-Fired Power Plants , Presentation at EUCI Conference in St. Louis, MO, November 2010. Presentation to the Indiana Utility Regulatory Commission on the Need for the Proposed Duke Energy Indiana Edwardsport IGCC Project , November 2010. Reply Comments on Portland General Electric Company’s 2009 Integrated Resource Plan
, September 2010. Presentation to the Oregon Public Utility Commission on Portland General Electric Company’s 2009 Integrated Resource Plan, May 2010. Comments on Portland General Electric Company’s 2009 Integrated Resource Plan , May 2010. Comments on the Facility Cost Report for Tenaska’s Proposed Taylorville IGCC Plant , April 2010. Comments on City of Holland Board of Public Work’s 2010 Power Supply Plan , April 2010. Phasing Out Federal Subsidies for Coal , April 2010. Comments on Draft Portland General Electric Company 2009 Integrated Resource Plan
, October 2009. The Economic Impact of Restricting Mountai ntop/Valley Fill Coal Mining in Central Appalachia , August 2009. Energy Future: A Green Energy Alternative for Michigan , report, July 2009. Energy Future: A Green Energy Alternative for Michigan, presentation, July 2009. Preliminary Assessment of East Kentucky Power Cooperative’s 2009 Resource Plan , June 2009.
The Financial Risks to Old Dominion Electric Cooperative’s Consumer-Members of Building and Operating the Proposed Cypress Creek Power Station, April 2009. An Assessment of Santee Cooper’s 2008 Resource Planning , April 2009. Nuclear Loan Guarantees: Another Taxpayer Bailout Ahead , Report for the Union of Concerned Scientists, March 2009. New Hampshire Senate Bill 152: Merrimack Station Scrubber , March 2009. The Risks of Building and Operating Plant Washington , Presentation to the Sustainable Atlanta Roundtable, December 2008. The Risks of Building and Operating Plant Washington , Report and Presentation to EMC Board Members, December 2008. Don’t Get Burned, the Risks of Investing in New Coal-Fired Power Plants , Presentation at the University of California at Berkeley En ergy and Resources Group Colloquium, October 2008.David Schlissel Page 19 Schlisse l Technical Consulting, Inc. Don’t Get Burned, the Risks of Investing in New Coal-Fired Power Plants , Presentation at Georgia Tech University, October 2008.
Nuclear Power Plant Construction Costs , Synapse Energy Economics, July 2008. Coal-Fired Power Plant Construction Costs, Synapse Energy Economics, July 2008. Synapse 2008 CO 2 Price Forecasts , Synapse Energy Economics, July 2008. Don’t Get Burned, the Risks of Investing in New Coal-Fired Power Plants , Presentation at the NARUC ERE Committee, NARUC Summer Meetings, July 2008.
Are There Nukes In Our Future , Presentation at the NASUCA Summer Meetings, June 2008. Risky Appropriations: Gambling US Energy Policy on the Global Nuclear Energy Partnership
, Report for Friends of the Earth, the Institute for Policy Studies, the Government Accountability Project, and the Southern Alliance for Clean Energy, March 2008.
Don’t Get Burned
, the Risks of Investing in New Coal-Fired Power Plants, Presentation to the New York Society of Securities Analysts, February 26, 2008. Don’t Get Burned, Report for the Interfaith Center for Corporate Responsibility, February 2008. The Risks of Participating in the AMPGS Coal Plant , Report for NRDC, February 2008.
Kansas is Not Alone
, the New Climate for Coal , Presentation to members of the Kansas State Legislature, January 22, 2008. The Risks of Building New Nuclear Power Plants , Presentation to the Utah State Legislature Public Utilities and Technology Committee, September 19, 2007. The Risks of Building New Nuclear Power Plants , Presentation to Moody’s and Standard & Poor’s rating agencies, May 17, 2007. The Risks of Building New Nuclear Power Plants , U.S. Senate and House of Representative Briefings, April 20, 2007. Carbon Dioxide Emissions Costs and Electricity Resource Planning, New Mexico Public Regulation Commission, Case 06-00448-UT, March 28, 2007, with Anna Sommer. The Risks of Building New Nuclear Power Plants , Presentation to the New York Society of Securities Analysts, June 8, 2006. Conservation and Renewable Energy Should be the Cornerstone for Meeting Future Natural Gas Needs. Presentation to the Global LNG Summit, June 1, 2004. Presentation given by Cliff Chen. Comments on natural gas utilities’ Phase I Proposals for pre-approved full cost recovery of contracts with liquid natural gas (LNG) supplie rs and the costs of interconnecting their systems with LNG facilities. Comments in California Public Utilities Commission Rulemaking 04-01- 025. March 23, 2004.
The 2003 Blackout: Solutions that Won’t Cost a Fortune , The Electricity Journal, November 2003, with David White, Amy Roschelle, Paul Pe terson, Bruce Biewald, and William Steinhurst.David Schlissel Page 20 Schlisse l Technical Consulting, Inc. The Impact of Converting the Cooling Systems at Indian Point Units 2 and 3 on Electric System Reliability. An Analysis for Riverkeeper, Inc. November 3, 2003. The Impact of Converting Indian Point Units 2 and 3 to Closed-Cycle Cooling Systems with Cooling Towers on Energy’s Likely Future Earnings. An Analysis for Riverkeeper, Inc. November 3, 2003.Entergy’s Lost Revenues During Outages of Indian Point Units 2 and 3 to Convert to ClosedCycle Cooling Systems. An Analysis for Riverkeeper, Inc. November 3, 2003. Power Plant Repowering as a Strategy for Re ducing Water Consumption at Existing Electric Generating Facilities . A presentation at the May 2003 Symposium on Cooling Water Intake Technologies to Protect Aquatic Organisms. May 6, 2003. Financial Insecurity: The Increasing Use of Limited Liability Companies and Multi-tiered Holding Companies to Own Electric Generating Plants . A presentation at the 2002 NASUCA Annual Meeting. November 12, 2002. Determining the Need for Proposed Overhead Transmission Facilities. A Presentation by David Schlissel and Paul Peterson to the Task Force and Working Group for Connecticut Public Act 02-95. October 17, 2002. Future PG&E Net Revenues From The Sale of Electricity Generated at its Brayton Point Station

. An Analysis for the Attorney General of the State of Rhode Island. October 2, 2002. PG&E’s Net Revenues From The Sale of Electricity Generated at its Brayton Point Station During the Years 1999-2002. An Analysis for the Attorney General of the State of Rhode Island. October 2, 2002. Financial Insecurity: The Increasing Use of Limited Liability Companies and Multi-Tiered Holding Companies to Own Nuclear Power Plants. A Synapse report for the STAR Foundation and Riverkeeper, Inc., by David Schlissel, Paul Peterson, and Bruce Biewald, August 7, 2002. Comments on EPA’s Proposed Clean Water Act Section 316(b) for Cooling Water Intake Structures at Phase II Existing Facilities, on behalf of Riverkeeper, Inc., by David Schlissel and Geoffrey Keith, August 2002. The Impact of Retiring the Indian Point Nuclear Power Station on Electric System Reliability . A Synapse Report for Riverkeeper, Inc. and Pace Law School Energy Project. May 7, 2002. Preliminary Assessment of the Need for the Proposed Plumtree-Norwalk 345-kV Transmission Line. A Synapse Report for the Towns of Bethel, Redding, Weston, and Wilton Connecticut. October 15, 2001. ISO New England's Generating Unit Availability Study: Where's the Beef? A Presentation at the June 29, 2001 Restructuring Roundtable.
Clean Air and Reliable Power: Connecticut Le gislative House Bill HB6365 will not Jeopardize Electric System Reliability . A Synapse Report for the Clean Air Task Force. May 2001.David Schlissel Page 21 Schlisse l Technical Consulting, Inc. Room to Breathe: Why the Massachusetts Department of Environmental Protection's Proposed Air Regulations are Compatible with Reliability . A Synapse Report for MASSPIRG and the Clean Water Fund. March 2001. Generator Outage Increases: A Preliminary A nalysis of Outage Trends in the New England Electricity Market , a Synapse Report for the Union of Concerned Scientists, January 7, 2001. Cost, Grid Reliability Concerns on the Rise Amid Restructuring , with Charlie Harak, Boston Business Journal, August 18-24, 2000. Report on Indian Point 2 Steam Generator Issues , Schlissel Technical Consulting, Inc., March 10, 2000. Preliminary Expert Report in Case 96-016613 , Cities of Wharton, Pasadena, et al v. Houston Lighting & Power Company, October 28, 1999. Comments of Schlissel Technical Consulting, Inc. on the Nuclear Regulatory Commission's Draft Policy Statement on Electric Industry Economic Deregulation , February 1997. Report to the Municipal Electric Utility Associ ation of New York State on the Cost of Decommissioning the Fitzpatrick Nuclear Plant , August 1996. Report to the Staff of the Arizona Corporation Commission on U.S. West Corporation's telephone cable repair and replacement programs , May, 1996. Nuclear Power in the Competitive Environment , NRRI Quarterly Bulletin, Vol. 16, No. 3, Fall 1995. Nuclear Power in the Competitive Environment , presentation at the 18th National Conference of Regulatory Attorneys, Scottsdale, Arizona, May 17, 1995. The Potential Safety Consequences of Steam Generator Tube Cracking at the Byron and Braidwood Nuclear Stations , a report for the Environmental Law and Policy Center of the Midwest, 1995. Report to the Public Policy Group Concerning Future Trojan Nuclear Plant Operating Performance and Costs , July 15, 1992. Report to the New York State Consumer Protection Board on the Costs of the 1991 Refueling Outage of Indian Point 2 , December 1991. Preliminary Report on Excess Capacity Issues to the Public Utility Regulation Board of the City of El Paso , Texas, April 1991.
Nuclear Power Plant Construction Costs , presentation at the November, 1987, Conference of the National Association of State Utility Consumer Advocates. Comments on the Final Report of the National Electric Reliability Study , a report for the New York State Consumer Protection Board, February 27, 1981.David Schlissel Page 22 Schlisse l Technical Consulting, Inc. OTHER SIGNIFICANT INVESTIGATIONS AND LITIGATION SUPPORT WORK Reviewed the salt deposition mitigation strategy proposed for Reliant Energy’s repowering of its Astoria Generating Station. October 2002 through February 2003.
Assisted the Connecticut Office of Consumer C ounsel in reviewing the auction of Connecticut Light & Power Company's power purchase agreements. August and September, 2000. Assisted the New Jersey Division of the Ratepa yer Advocate in evaluating the reasonableness of Atlantic City Electric Company's proposed sale of its fossil generating facilities. June and July, 2000. Investigated whether the 1996-1998 outages of the three Millstone Nuclear Units were caused or extended by mismanagement. 1997 and 1998. Clients were the Connecticut Office of Consumer Counsel and the Office of the Attorney Gene ral of the Commonwealth of Massachusetts. Investigated whether the 1995-1997 outages of the two units at the Salem Nuclear Station were caused or extended by mismanagement. 1996-1997. Client was the New Jersey Division of the Ratepayer Advocate.
Assisted the Associated Industries of Massachuse tts in quantifying the stranded costs associated with utility generating plants in the New England states. May through July, 1996 Investigated whether the December 25, 1993, turbine generator failure and fire at the Fermi 2 generating plant was caused by Detroit Edison Company's mismanagement of fabrication, operation or maintenance. 1995. Client was the Attorney General of the State of Michigan. Investigated whether the outages of the two units at the South Texas Nuclear Generating Station during the years 1990 through 1994 were caused or extended by mismanagement. Client was the Texas Office of Public Utility Counsel. Assisted the City Public Service Board of San Antonio, Texas in litigation over Houston Lighting & Power Company's management of opera tions of the South Texas Nuclear Generating Station. Investigated whether outages of the Millstone nuclear units during the years 1991 through 1994 were caused or extended by mismanagement. Client was the Office of the Attorney General of the Commonwealth of Massachusetts. Evaluated the 1994 Decommissioning Cost Estimate for the Maine Yankee Nuclear Plant. Client was the Public Advocate of the State of Maine. Evaluated the 1994 Decommissioning Cost Estimate for the Seabrook Nuclear Plant. Clients were investment firms that were evaluating wh ether to purchase the Great Bay Power Company, one of Seabrook's minority owners. Investigated whether a proposed natural-gas fired generating facility was need to ensure adequate levels of system reliability. Examined the potential impacts of environmental regulations on the unit's expected construction cost and schedule. 1992. Client was the New Jersey Rate Counsel.David Schlissel Page 23 Schlisse l Technical Consulting, Inc. Investigated whether Public Service Company of New Mexico management had adequately disclosed to potential investors the risk that it would be unable to market its excess generating capacity. Clients were individual shareholders of Public Service Company of New Mexico. Investigated whether the Seabrook Nuclear Plant was prudently designed and constructed. 1989. Clients were the Connecticut Office of Consumer Counsel and the Attorney General of the State of Connecticut. Investigated whether Carolina Power & Light Company had prudently managed the design and construction of the Harris nuclear plant. 1988-1989. Clients were the North Carolina Electric Municipal Power Agency and the City of Fayetteville, North Carolina. Investigated whether the Grand Gulf nuclear pl ant had been prudently designed and constructed. 1988. Client was the Arkansas Public Service Commission. Reviewed the financial incentive program proposed by the New York State Public Service Commission to improve nuclear power plant sa fety. 1987. Client was the New York State Consumer Protection Board.
Reviewed the construction cost and schedule of the Hope Creek Nuclear Generating Station. 1986-1987. Client was the New Jersey Rate Counsel. Reviewed the operating performance of the Fort St. Vrain Nuclear Plant. 1985. Client was the Colorado Office of Consumer Counsel.

WORK HISTORY 2010 - President, Schlissel Technical Consulting, Inc. 2000 - 2009: Senior Consultant, Synapse Energy Economics, Inc. 1994 - 2000: President, Schlissel Technical Consulting, Inc. 1983 - 1994: Director, Schlissel Engineering Associates 1979 - 1983: Private Legal and Consulting Practice 1975 - 1979: Attorney, New York State Consumer Protection Board 1973 - 1975: Staff Attorney, Georgia Power Project

EDUCATION 1983-1985: Massachusetts Institute of Technology Special Graduate Student in Nuclear Engineering and Project Management, 1973: Stanford Law School, Juris Doctor 1969: Stanford University Master of Science in Astronautical Engineering, 1968: Massachusetts Institute of Technology Bachelor of Science in Astronautical Engineering,David Schlissel Page 24 Schlisse l Technical Consulting, Inc. PROFESSIONAL MEMBERSHIPS

• New York State Bar since 1981

• American Nuclear SocietyAnna Sommer Page 1 of 6 

## Anna Sommer Sommer Energy, LLC 19 1⁄2 White Place Burlington, VT 05401 (802) 497

- 1978
sommer energy @gmail .com
EDUCATION McGill University , MSc in Civil Engineering and Applied Mechanics , Montreal, Canada, expected 2012. University of California, Berkeley , MS in Energy and Resou rces, Berkeley, CA, 2010. Master’s Project: The Water and Energy Nexus: Estimating Consumptive Water Use from Carbon Capture at Pulverized Coal Plants with a Case Study of the Upper Colorado River Basin Tufts University , BS in Economics and Environmental Studies , Medford, MA , 2003.

PROFESSIONAL EXPERIENCE Sommer Energy , Burlington, VT. President . May 2010

– present Provide s consulting services on electricity planning, energy efficiency, carbon capture and sequestration and energy

- water issues in a regulato ry context.

UC Berkeley, Berkeley, CA. Graduate Research Assistant . January 2009

– May 2009 Researched and wrote a policy proposal that addresses the potential contribution to climate change from the development of new coal power in the U.S.

Lawrence Be rkeley National Laboratory , Berkeley, CA. Graduate Research Assistant. September 2009

– December 2009 Drafted journal article on the economics of repowering California wind turbines.
Energy Solutions , Oakland, CA. Project Manager . July 2007

– August 2008 Provide d technical and policy assistance to local government agencies in implementing energy efficiency projects, conduct ed lighting audits of commercial facilities, and evaluate d the potential for emerging lighting technologies such as LED streetlights.
Synapse Energy Economics, Inc., Cambridge, MA

. Research Associate

. June 2003

– June 2007 Evaluated energy technologies on both the supply and demand sides, conducted analyses of environmental regulations including greenhouse gas regulations, prepared eco nomic analyses, proposed public policies to encourage renewable energy and energy efficiency development and provided support including expert testimony to clients through all phases of regulatory proceedings.
Internships: Vermont Energy Investment Corpor ation , Burlington, VT. June 2009

– August 2009 EFI/Xenergy (now KEMA Consulting, Inc.) , Burlington, MA

. September 2000

– May 2003 Zilkha Renewable Energy (now Horizon Wind Energy) , Houston, TX

. May

- August 2002Anna Sommer Page 2 of 6 PANEL TESTIMONY AND COMMENTS Minnestoa Publi c Utilities Commission (Docket No. E017/RP

- 10

- 623)

– May 2011 Comments regarding Otter Tail Power’s integrated resource plan to comply with EPA regulations and meet future capacity and energy needs. Minnesota Public Utilities Commission (Docket No. E001/RP

- 08

- 673)

– June 2011 Comments regarding IPL’s integrated resource plan to comply with pending EPA regulations and meet future capacity and energy needs. North Carolina Utilities Commission (Docket No. E

- 100, Sub 110)

– February 2007 Comments regarding the implementation of e nergy efficiency and DSM programs in North Carolina. Minnesota Public Utilities Commission ( Docket No. E017/CN

- 05

- 619)

– December 2006 Evaluation of a proposal by seven utilities to build a new supercritical pulverized coal plant including alternatives to the plant and potential for greenhouse gas regulation. North Carolina Utilities Commission (Do cket No. E

- 7, Sub 790)

– January 2007 Evaluation of a proposal by Duke Energy Carolinas to build two new supercritical pulverized coal plants including considera tion of greenhouse gas regulation and alternatives to the plant such as energy efficiency.
South Dakota Public Utilities Commission ( Docket No. EL05

- 022 )

– July 2006 Evaluation of a proposal by seven utilities to build a new supercritical pulverized coal p lant including alternatives to the plant and potential for greenhouse gas regulation.
Wisconsin Public Service Commission (Docket #6685

- CE

- 108)

– February 2006 Evaluating Wisconsin Public Power Inc.’s request for approval of a Certificate of Authority to

e xercise its option to own a portion of Prairie State Energy Campus, a supercritical pulverized coal plant.

REPORTS A Study of the Economics and Risks of Operation of Boiler 4 by the New Ulm Public Utilities Commission , prepared by Anna Sommer for Sierra Club

– Northstar Chapter and Minnesota Center for Envi ronmental Advocacy. July 15, 2011. Comments on the Technical Memorandum for the Georgia Statewide Energy Sector Water Demand Forecast, prepared by Anna Sommer and David Schlis sel for the Southern Alliance for Clean Energy. June 22, 2011. Don’t Get Burned: The Risks of Investing in New Coal

- Fired Generating Facilities, prepared by David Schlissel, Lucy Johnston, Jennifer Kallay, Christopher James, Anna Sommer, Bruce Biewald, Ezra Hausman and Allison Smith for Interfaith Center of Corporate Responsibility. February 26, 2008. Quantifying and Controlling Fine Particulate Matter in New York City, prepared by Alice Napoleon, Geoff Keith, Charles Komanoff, Daniel Gutman, Patricio Silva, David Schlissel, Anna Somm er, Cliff Chen and Amy Roschelle for Coalition Helping Organize a Kleaner Environment, Natural Resources Defense Council and Reliant Energy. August 28, 2007. Independent Administration of Energy Efficiency Programs: A Model for North Carolina, prepared by David Nichols, Anna Sommer and William Steinhurst for Clean Water for North Carolina. April 13, 2007.Anna Sommer Page 3 of 6 Integrated Portfolio Management in a Restructured Supply Market, prepared by Paul Chernick, Jonathan Wallach, William Steinhurst, Tim Woolf, Anna Sommer a nd Kenji Takahashi. June 30, 2006. Ensuring Delaware’s Energy Future: A Response to Executive Order No. 82, p repared by the Delaware Cabinet Committee on Energy with technical assistance at Synapse Energy Economics from William Steinhurst, Bruce Biewald, D avid White, Kenji Takahashi, Alice Napoleon, Amy Roschelle, Anna Sommer and Ezra Hausman . March 8, 2006. Mohave Alternatives and Complements Study: Assessment of Carbon Sequestration Feasibility and Markets, a Sargent & Lundy and Synapse Energy Economics , Inc. report prepared for Southern Ca lifornia Edison by Anna Sommer and William Steinhurst . February 2006

. Potential Cost Impacts of a Renewable Portfolio Standard in New Brunswick , prepared by Tim Woolf, David White, Cliff Chen and Anna Sommer for the N ew Brunswick Department of Energy. October 2005. Considering Climate Change in Electric Resource Planning: Zero is the Wrong Carbon Value, a Synapse Energy Economics, Inc. report prepared by Lucy Johnston, Amy Roschelle, Ezra Hausman, Anna Sommer and Bruce Biewald. September 20, 2005. Potential Cost Impacts of a Vermont Renewable Portfolio Standard , a Synapse Energy Economics, Inc. report prepared for the Vermont Public Service Board, by Tim Woolf, David E. White, Cliff Chen, and Anna Sommer. October 16, 2003.
Estimating the Environmental Benefits of Renewable Energy and Energy Efficiency in North America: Experience and Methods , a report for the Commission for Environmental Cooperation, by Geoffrey Keith, Bruce Biewald, Anna Sommer, Patrick Henn, and Mig uel Breceda, September 22, 2003. Comments on the RPS Cost Analyses of the Joint Utilities and the DPS Staff, a Synapse Energy Economics , Inc. report prepared for the Renewable Energy Technology and Environment Coalition, by Bruce Biewald, Cliff Chen, Anna Sommer, William Steinhurst, and David E. White. September 19, 2003. Cleaner Air, Fuel Diversity and High

- Quality Jobs: Reviewing Selected Potential Benefits of an RPS in New York State , a Synapse Energy Economics , Inc. report prepared for the Renewable En ergy Technology and Environment Coalition, by Geoff Keith, Bruce Biewald, David White , Anna Sommer and Cliff Chen

. July 28 , 2003.

PRESENTATIONS AND ARTICLES “The Energy and Water Nexus: Carbon Capture and Water.” A presentation at the Water and Energy Su stainability Symposium. September 28, 2010.
“Carbon Sequestration.” A presentation to Vermont Energy Investment Corporation. August 17, 2009.
“Carbon Dioxide Emissions Costs and Electricity Resource Planning.” A presentation before the New Mexico Public Regulation Commission with David Schlissel. March 28, 2007.Anna Sommer Page 4 of 6 “Electricity Supply Prices in Deregulated Markets

– The Problem and Potential Responses.” A presentation at the NASUCA Mid

- Year Meeting with Rick Hornby and Ezra Hausman . June 13, 2006.

“ IGCC: A Public Interest Perspective .” A presentation at the Electric Utilities Environmental Conference 2006. January 24, 2006.
Woolf, Tim, Anna Sommer, John Nielsen, David Barry and Ronald Lehr. “ Managing Electric Industry Risk with Clean and Efficient Resource s , ” The Electricity Journal , Volume 18, Issue 2, March 2005. Woolf, Tim and Anna Sommer. “ Local Policy Measures to Improve Air Quality: A Case Study of Queens County, New York, ” Local Environment , Volume 9, Number 1, February 2004.

INVESTIGATIONS Minnesota Public Utilities Commission ( Docket No. E017/M

- 10

- 1082 )

– ongoing Evaluation of Otter Tail Power ’ s plan to install pollution controls on the Big Stone power plant.
Indiana U tility Regulatory Commission (Cause No. 43114 IGCC 4S)

– ongoing Evaluation of prudence, gross mismanagement, concealment and fraud related to the construction of a new integrated gasification combined cycle coal plant in Duke E nergy Indiana service territ ory. Public Utilities Commission of Ohio (Case No. 10

- 503

- EL

- FOR)

– March 2011 Evaluation of Duke Energy Ohio’s IRP filing including an assessment of plant retirements and compliance with alternative energy and energy efficiency portfolio standards.
Colora do Public Utilities Commission (Docket No. 10M

- 245E)

– July 2010 Evaluation of a proposal by Public Service Company of Colorado to meet the requirements of the Clean Air Clean Jobs Act through coal plant retirements and retrofits.

Florida Public Service C ommission (Docket No. 070098

- EI)

– March 2007 Evaluation of a proposal by FPL to build a new ultra

- supercritical pulverized coal plant including alternatives to the plant and potential for greenhouse gas regulation.
Arkansas Public Service Commission (Dock et No. 06

- 154

- U)

– July 2007 Evaluation of a proposal by SWEPCO to build a new supercritical pulverized coal plant including alternatives to the plant and potential for greenhouse gas regulation. Indiana Utility Regulatory Commission (Cause No. 43114)

– Ju ne 2007 Evaluation of a proposal by Duke Energy to build a new integrated gasification combined cycle coal plant including alternatives to the plant and potential for greenhouse gas regulation.
United States Federal Court of Claims (Nos. 99

- 447C and 03

- 262 6C)

– May 2007 Evaluation of Boston Edison’s claim of negative impacts to the purchase price of Pilgrim nuclear station resulting from the DOE’s failure to begin accepting spent nuclear fuel on or about January 31, 1998

.
Public Utilities Commission of Nev ada (Docket No. 06

- 030 )

– September 2006 Evaluation of Nevada Power Company’s demand side

- management (DSM) portion of its integrated resource plan

.Anna Sommer Page 5 of 6 Nova Scotia Utility and Review Board ( P

- 128.05 )

– May 2006 Evaluation of Nova Scotia Power Inc.’s proposal t o install Low NOx Combustion Firing Systems and a common Flue Gas Desulfurization Unit on its coal

- fired power plants.
Indiana Utility Regulatory Commission (Cause No. 42873)

– March 2006 Issues regarding the proposed merger of Duke Energy and Cinergy, In c. including compliance with DSM goals in previous mergers. Indiana Utility Regulatory Commission (Cause No. 42861)

– March 2006 Issues regarding Vectren Energy’s proposal to install emission controls for SO 2 , NOx, PM and Hg including compliance with prese nt and future emissions regulations and planning analysis. Utah Public Service Commission (Docket No. 05

- 035

- 54)

– November 2005 Issues regarding the acquisition of PacifiCorp by MidAmerican Energy Holdings Company includi ng underinvestment in grid infrast ructure, environmental compliance with air regulations and investment in IGCC. Iowa Utilities Board (Docket No. SPU

- 05

- 15)

– November 2005 Evaluation of proposed sale of the Duane Arnold nuclear power plant from Interstate Power & Light to FPL

. Arkansas P ublic Utilities Commission ( Docket No. 05

- 042

- U )

– August 2005 Iss ues regarding the purchase of Wrightsville, a gas
- fired power plant , by Arkansas Electric C oop erative including appropriateness and reasonableness of the purchase. Indiana Utility Regulatory Commission (Cause No. 42718)

– May 2005 Issues regarding PSI Energy’s proposal to install $1.4 billion in control technologies for SO 2 , NOx and Hg including rate of return on investment, analysis of emissions regulation risk, scenario planning, estimates of control t echnology cost and equity of plan to ratepayers. Nuclear Regulatory Commission (Docket No. 52

- 007)

– April 2005 Issues regarding Exe lon Generation’s petition for early site permit approval for a baseload nuclear generating facility in Illinois including the Company’s analysis of alternatives. Georgia Public Service Commission (Docket No. 18300

- U)

– February 2005 Georgia Power Company rate case involving issues of cost allocation and consideration of public benefits in rate

- making for the Metropo litan Atlanta Rapid Transit Authority

.
Indiana Utility Regulatory Commission (Cause N o. 42612)

– November 2004 Evaluation of PSI Energy’s plan to offer demand side management (DSM) programs to its customers includi ng issues of program scope, funding, lost revenue recovery, shared savings incentive recovery, and third

- party administration issues.
California Public Utilities Commission (R ulemaking 04

- 04

- 003)

– August 2004 Issues in the San Diego Gas & Electric, Pacific Gas & Electric and Southern California Edison long

- term resource plans including modeling the cost of carbon regulation, modeling of renewables, scenario planning and debt equivalency. Texas Public Utility Commission (Docket No. 29526)

– June 2004 Issues in CenterPoint Energy Houston Electric LLC’s true up filing, including environmental cleanup costs, excess mitigation credits, and construction work in progress.Anna Sommer Page 6 of 6 PROFESSIONAL ASSOCIATIONS AND DEVELOPMENT Alum, Research Experience in Carbon Sequestration Member, Air & Waste Management Associati on Member, American Geophysical Union

LANGUAGES English (native), Spanish (fluent).
Resume d ated August 2011

.