Mr. Jeff DeRouen Executive Director Ken tuck y Pub 1 i c Service C o nirn i s s i o n 21 1 Sower Boulevard Frankfort, Kentucky 40601

May 20,20 13

Re: CONSIDERATION OF THE IMPLEMENTATION OF SMART GRID AND SMART METER TECHNOLOGIES Case No. 2012-00428

Dear Mr. DeRouen:

Eiiclosed please find and accept for filing the original aiid fourteen copies of the Joint Coininerits of Atinos Energy Corporation, Attorney General of the Coniiiioiiwealtli of Kentucky by aiid through his offic of Rate Intervention, Big Rivers Elecrtric Corporation, Big Sandy Rural Electric Cooperative Corporation, Blue Grass Energy Cooperative Corporation, Clark Energy Cooperative, Inc., Columbia Gas of Kentucky, Inc., Community Action Council for Lexington-Fayette, Bourbon, Harrison arid Nicholas Counties, Inc., Cumberland Valley Electric, Delta Natural Gas Company, Inc., Duke Energy Kentucky, Inc., East Kentucky Power Cooperative, Inc., Farmers Rural Electric Cooperative Corporation, Fleming-Mason Energy Cooperative, Grayson Rural Electric Cooperative Corporation, Inter-County Energy Cooperative Corporation, Jacltsoii Energy Cooperative Corporation, Jackson Burcliase Energy Corporation, Kenergy Corp., ICentucky Power Company, Kentucky IJtilities Company, Liclting Valley Rural Electric Cooperative Corporation, Louisville Gas and Electric Company, Meade County Rural Electric Cooperative Corporation, Nolin Rural Electric Cooperative Corporation, Owen Electric Cooperative, Iiic., Salt River Electric Cooperative Corporation, Shelby Eriergy Cooperative, Inc., South Kentucky Rural Electric Cooperative Corporation, and Taylor County Rural Electric Cooperative Corporation

MAY 2 0 2013 PUBLIC SERVICE

COMMISSION

LG&E and KU Energy LLC State Regulation and Rates 220 West Ma in Street PO BOX 32010 Louisville, Kentucky 40232 www.1 ge-ku .corn

Rick E. Lovekamp Manager - Regulatory Affairs T 502-627-3780 F 502-627-3213 rick.lovekamp@lge-ku.com

Mr. Jeff DeRouen May 20,201 3

Should you have any questions please contact me at your convenience.

Sincerely,

C: Parties of Record

C AL

JOINT COMMENTS OF

E GRASS ENERGY OOPERATIVE, INC., CTION COUNCIL, FOR

NICHOLAS COUNTIES, INC., RAL GAS COMPANY, TNC.,

CKY, INC., EAST KICNTUCKY POWER COOPERATIVE, ORATION, FLENIING-

MASON ENERGY COOPERATIVE, GRAYSON RURAL ELECTRIC COOPERATIVE

JACKSON ENERGY COOPERATIVE CORPORATION, JACKSON PURCHASE ENERGY COR

IKENTIJCKY , LICKING VALLEY RURAL ELECTRIC

EADE COUNTY RURAL ELECTRIC COOPERATIVE CORPORATION, NOLIN

CORPORATION, I N T E ~ - C O ~ N T Y ENERGY COOPERATIVE CORPORATION,

COW., m,NTUCKY POWER COMPANY,

PERATIVE CORPORATION, LOUISVILLE GAS AND ELECTRIC COMPANY,

RURAL ELECTRIC COOPERATIVE CORPORATION, OWEN ELECTRIC COOPERATIVE, INC., SALT RIVER ELECTRIC COOPERATIVE CORPORATION, s COOPERATIVE, INC., SOUTH KENTUCKY RURAL ELECT

CORPORATION, AND TAYLOR COUNTY RIJRAL ELECTNC OPERATIVE CORPORATION

Filed: May 20,2013

ntroduction ....................................................................................................................... 1

oint Parties U n a n ~ m o ~ s ~ y Agree the Commission Should Not Adopt the 2007 Smart Grid ~ n ~ o r m a t ~ o n Standard .............................................................. 3

ies ~nanimously Agree the Commission Should Not Adopt the rt Grid Investment Standard ................................................................ 4

IV . The Joint Parties’ Collaborative ill Address Specific Smart-Technology- Related Issues Pertinent to ~ u r i s d ~ c t ~ o n a ~ Utilities ........................................................ 6

V . Conclusion and Request for rder ................................................................................. 8

1

~~~~0~~~~~~~

Atinos Energy Corporation (“Atnios”), Attorney General of the Commonwealth of

Kentucky by aiid though His Office of Rate Intervention (“AG”), Big Rivers Electric

Corporatioii (“Big Rivers”) and its ineiiiber systems: Jacltsoii Purchase Energy Coi-poration

(“JPEC”), Keiiergy Coi-p. (“Kenergy”), and Meade Couiity Rural Electric Cooperative

Corporation (“Meade Comity RECC”), Columbia Gas of Kentucky, Inc. (“Columbia”), Delta

Natural Gas Company, Inc. (“Delta”), Dike Energy Kentucky, Inc. (“Duke Kentucky”), East

Kentucky Power Cooperative, Iiic. (“EICPC”) and its inember systems: Rig Sandy Rural Electric

Cooperative Corporation, Blue Grass Energy Cooperative Coi-poration, Clark Energy

Cooperative, Inc., Cuniberland Valley Electric, Farmers Rural Electric Cooperative Corporation,

Fleming-Mason Energy Cooperative, Grayson Rural Electric Cooperative Coi-poration, Inter-

County Energy Cooperative Corporation, Jacltson Energy Cooperative Corporation, Licking

Valley Rural Electric Cooperative Corporation, Nolin Rural Electric Cooperative Coi-poratioii,

Owen Electric Cooperative, Inc., Salt River Electric Cooperative Corporation, Shelby Energy

Cooperative, Iiic., South Kentucky Rural Electric Cooperative Corporation and Taylor County

Rural Electric Cooperative Coi-poratioii, Kentucky Power Company (“Kentucky Power”),

Kentucky Utilities Company (“K~J”) , Louisville Gas and Electric Coinpaiiy (“LG&E”),

(collectively, tlie “Joint Parties”) and Coiiimunity Action Council for Lexington-Fayette,

Bourbon, Harrison aiid Nicliolas Counties, Inc. (“CAC”) (CAC joiiis these comments oiily for

the purposes of Section IV) offer these Joint Coininerits in accordance with the procedural

schedule set out in the Coiiiiiiission’s October 1 , 20 12 Order establishing this proceeding, as well

as tlie discussion among Vice Cliaiiinaii Gardner, Commission Staff, and tlie Joint Parties during

tlie Infonnal Coiifereiice field at the Coniinission oil April 19, 201 3 .

The Joint Parties appreciate the opportunity to revisit proposed Energy Independence and

Security Act of 2007 (“EISA”) Smai-t Grid Information aiid Investment Standards in this

proceeding, as well as to initiate a new collaborative effort to investigate potential areas of

agreement concerning smart-technology issues. The issues smart technologies present can be

daunting, aiid the Joint Parties look forward to worlting together to discuss and report to the

Conmission on a number of important issues concerning smart technology.

On two items, though, the Joint Parties already have a unanimous view: the Coiriinissioii

should not adopt the EISA 2007 Smai-t Grid Investnient Standard or the EISA 2007 Siiiai-t Grid

Information Standard. This is not because the Joint Parties oppose using smart technologies;

indeed, many of Kentucky’s utilities have already deployed smart technologies in a variety of

economical ways. Rut as the Joint Parties explain further below, tlie proposed standards are

variously redundant or potentially countelproductive, aiid the Coinmission should not adopt

them. Given the diversity of constituencies and interests the Joint Pai-ties represent, their

unanirnous view opposing the proposed staiidards is particularly significant.

The Joint Parties ftii-ther recommend the following topics to investigate collaboratively to

seek potential conseiisus iii the sinai-t-technology area: customer privacy, opt-out provisions,

cyber-security, customer education (including health-related education), dynaiiiic pricing, AMR

and AMI deployment (including prepaid meters and reiiiote discoiuiectioiis), cost recovery for

smart-technology deployments, and how iiatural gas coiripanies might participate in the electric

sinai-t grid. The Joint Parties propose to produce a report for the Commission conceiiiiiig these

topics by June 30, 2014, at which point the Joint Pai-ties’ Collaborative would end. Therefore,

tlie Joint Pai-ties respectfully ask tlie Commission to issue an order by July IS, 2013, that (1)

decliiies to adopt or impose in any form the EISA 2007 Sniai-t Grid Information and Investment

2

Staridards arid (2) approves the proposed topics arid procedural schedule for the Joint Pai-ties’

Collaborative.

2007 Smart Grid Information Standard

The Joint Parties unanimously oppose adopting the EISA 2007 Sinai-t Grid Information

Standard on the ground that it could require utilities to rnalte uneconomical investinents. The

staridard would require utilities to provide customers direct access to a wide ai-ray of data,

apparently without regard for the costs or benefits of providing the data:

Prices: Purchasers arid other interested persons shall be provided with infoiiiiatioii 011 time-based electricity prices in the wholesale electricity market, arid time-based electricity retail prices or rates that are available to the consumers.

Usage: Purchasers shall be provided with the iiurnber of electricity units, expressed in kWh, purchased by them.

Intervals and Projections: Updates of information on prices and usage shall be offered on a daily basis, shall include hourly price and use iiifoiiiiatiori, where available, and shall include a day-ahead projection of such price information to tlie extent available.

Sources: Purchasers aiid other interested persons shall be provided ailnually with written iiifoi-rnation on the sources of the power provided by the utility, to tlie extent that it caii be deteriniiied, by type of generation, iiicluding greenhouse gas einissioiis associated with each type of generation, for intervals during which such inforination is available oil a cost-effective basis.

Custoiiier data: Customers shall be able to access their own iriforinatiori at aiiy time tluougli the internet aiid by other meaiis of coiiiinuiiicatioii elected by the electric utility for smart grid applications. Other interested persons shall be able to access informatioii not specific to any customer

3

through the Iiiteniet. Customer-specific information shall be provided solely to that customer.

The current offering of time-based or time-of-use pricing optioiis is limited to voluntary

pilot programs and such pricing options have not yet beeii widely adopted in ICeiituclty. As a

result, the Joint Pai?:ies believe there is iio need to require utilities to provide tlie extensive

pricing, interval, and projection infoimatiori the EISA 2007 Sinai?: Grid Inforination Standard

requires. Tlie EISA 2007 Sinai? Grid Iiiforiiiation Standard takes 110 accouiit of the ecoiioniics

of serving the different custorriers and service teiyitories in ICentucky; ratlier, it would iinpose a

one-size-fits-all requireinent that all utilities provide their custoiiiers the saiiie ltiiids of

iiifoi-niation in presuinably siiiiilar, if not identical, ways. Such a standard would alinost

certainly require some, if not all, utilities to inalte ciui-reiitly uneconomical investments in

customer-facing inforination technology.

Instead, tlie Joint Parties recomiiieiid that the Coirirnissioii coiitiriue to use its existing

review processes and authority to ensure utilities are providing customers the inforination they

iieed in ecorioiiiical ways. That will allow the Coinmission’s review of infoiiiiatiori provision to

customers to recognize each utility’s unique characteristics, including the unique costs aiid

benefits of providing cei-taiii kinds of inforination in certain ways to each utility’s customers.

III. The Joint Parties Unanimously Agree the Commission Should Not Adopt the EISA 2007 Smart Grid Investment Standard

The Joint Pai-ties unaiiimously oppose adopting the EISA 2007 Smart Grid Investineiit

Standard on the grounds that it would be largely reduiidaiit while potentially stifling useful

In the Matter of Corisiderntion of the Iiiipleineritation of Sinart Grid arid Sinart Meter Technologies, Case No. 1

2012-00428, Order at 5 (Oct. 1,2012).

4

iilnovatioii in smart-technology proposals, iiicludiiig potential cost-recovery methods. The

standard would require as follows:

Each State shall consider requiriiig that, prior to undei-taltiiig iiivestrnents in iionadvaiiced grid technologies, an electric utility of the State deinonstrate to the State that the electric utility considered an investment in a qualified Sinai? Grid systein based on appropriate factors, iiicluding:

total costs;

cost-effectiveness;

iiiiproved reliability;

security;

system performance; arid

societal benefit.

The EISA 2007 Smai-t Grid Investiiient Standard also requires each state to consider rate recovery of Siiiai-t Grid capital expeiiditures, operating expenses, aiid other costs related to the deployineiit of sinart grid technology, iiicluding a reasoiiable return on the capital expenditures. As part of the rate recovery consideration, each state is to also consider recovery of the reinairiirig book-value of obsolete equipinent associated with smart grid

The Joint Pai-ties unaniinously support using cost-benefit analysis for all utility irivestineiit

proposals preseiited to tlie Cornmission. Rut because the Coinmissiori already has tlie ability and

duty to review the costs and benefits of utility proposals, tlie proposed standard is unnecessary;

nioreover, iiitervention by advocates such as the Attoi-ney General already helps ensure tlie

thorough review of utility proposals. 111 addition to being largely redundant, the proposed

standard may inhibit useful iimovation to the extent it iiitroduces constraiiits oii what can be

considered when utilities make smart-grid-related proposals, includiiig constraints or1 costs arid

5

benefits to consider, as well as cost-recovery methods. Therefore, the Joint Pai-ties respectfully

recommend that the Coinmissioii decline to adopt the EISA 2007 Sinai-t Grid Investiiieiit

Standard in favor of coiitiiiuiiig to use its existing autliority to review utility proposals to ensure

they are cost-effective and that each utility’s means of cost recovery is appropriate on a case-by-

case basis.

As noted previously in these Joint Comments, the Joint Parties do not oppose tlie

ecoriornical use of smart technologies. But the Joint Pai-ties do oppose inandatory standards that

could stifle innovation or otherwise curtail each utility’s ability to irnpleinerit what is inost

economical aiid sensible for its customers and service territory; that is why the Joint Parties

oppose the EISA 2007 Smai-t Grid Investment Standard.

PV. Issues Pertinent to Jurisdictional Utilities

The Joint Pai-ties believe it would be lielpfiil to themselves and tlie Coinmission for the

Joint Pai-ties to engage in a collaborative process to investigate aiid analyze areas where

sirnilarities between utilities aiid agreement aiiiorig the Joint Pai-ties inay exist coiicerning sinart

The Joint Parties propose to address the following topics iii their collaborative

effoi-t: customer privacy, opt-out provisions, cyber-security, customer educatioii (including

health-related education), dyiiainic pricing, AMR and AMI deployment (including prepaid

meters aiid remote discormections), cost recovery for smart-technology deployments, and how

iiatural gas compaiiies might participate in the electric srnai-t grid. The Joint Pai-ties recognize

Because Atmos, Columbia, and Delta provide only gas service, they .join only this section of the Joint Comments. Further, Columbia believes that the AMR devices it deploys are not part of the definition of “smart technologies” as used in this proceeding. Also, CAC plans to participate in the Collaborative andjoins only Section IV of these Joint Comments.

6

that they separately addressed a iiuinber of these topics in Case No. 2008-00408 and in this

proceeding, but they believe it will be productive to work together on these issues to try to

achieve consensus where possible. At this point, the Joint Pai-ties do not anticipate being able to

reach the same level of conseiisus on each issue, so the level of detail and kinds of

recoriimeiidatioiis tlie Joint Pai-ties’ repoi-t will contain will likely vary froin issue to issue. But

the Joint Pai-ties coininit to approach these topics afresh and to discuss thein in good faitli to

reach consensus to the greatest reasoiiable extent, and to provide useful inforination arid

recoinineiidatioris to the Cominission in their final report.

Because it will require significant time and effort froin all of tlie Joint Pai-ties to discuss

the proposed topics, the Joint Parties propose to limit their discussions to the proposed topics to

ensure they can produce a repoi-t for the Coiiiinission in a reasonable time. More specifically, the

Joint Pai-ties propose to meet eight times to discuss these issues over tlie coiirse of a year, and

thereafter to present a repoi-t of recoiiiineiidatioiis to the Coniiiiission by June 30, 2014, which

would conclude the Joint Pai-ties’ Collaborative. The Joint Parties propose to use the July 23,

20 13 informal conference in this proceeding as a scheduling and coordination meeting to

establish dates for the eight topic-specific iiieetiiigs in 2013 and 2014, aiid to discuss a schedule

for drafting the report to the Commission. The Joint Parties invite tlie Commission Staff to

participate in all Collaborative meetings.

As pai-t of their Collaborative, the Joiiit Pai-ties fiii-tlier propose to aixmge tlie events for

the Coinrnissioners and Coinmissioii Staff discussed at the April 19, 201 3 informal conference,

namely an Envision Center tour, ai1 equipment and software viewing, and presentations by EPRI

and/or the Cooperative Research Network. The Joiiit Parties have discussed these events arid

propose the following dates fioin wliicli the Coinmission may choose:

7

Envision Center tour, including viewing some equipment aiid software typically used in smart grid and ineter deployments at the acljoiiiirig KEMA Laboratory: August 13, 14, 15, 20, 21, or 22, 2013. If tliese date options are not conducive to the Cominission’s scliedule, tlie Joint Parties are open to consider other dates, subject to tlie availability of tlie Envision Center.

EPRI and/or Cooperative Research Network presentations at the Commission - to be determined.

V. Conclusion and Request for Order

Tlie Joint Parties appreciate the opportunity to offer tlieir perspective 011 the proposed

EISA 2007 Sinart Grid Iiiforinatioii and Investiiient Standards, as well as to propose a scliedule

and agenda for the Joint Parties’ new collaborative process. As tlie Commission is aware, the

Joint Parties represent a variety of interests and constituencies with soinetiines divergent views;

therefore, it is noteworthy that the Joint Parties unaniniously recoiiiiiiend against the

Cornmission’s adopting either of the EISA standards. In lieu of federally proposed standards

that may prove to be counterproductive in Kentucky, the Joint Parties will investigate and report

to the Cornmission concerning areas of possible broad agreement.

Therefore, tlie Joint Pai-ties respectfully ask the Coinrriissioii to issue an order by July 15,

2013, that:

1. Declines to adopt or iinpose in any forin the EISA 2007 Smart Grid Inforination

Standard;

2. Decliiies to adopt or iinpose in any foiin tlie EISA 2007 Smai-t Grid Investment

Standard;

3. Approves tlie following topics for tlie Joint Parties’ Collaborative to address:

customer privacy, opt-out provisions, cyber-security, ciistomer education

(including health-related education), dyiiainic pricing, AMR and AMI deployinent

(including prepaid meters aiid remote disconnections), cost recovery for sinai-t-

8

technology deployments, and how natural gas companies might participate in the

electric siiiai-t grid; and

4. Approves tlie following procedural scliedule for tlie Joint Parties’ Collaborative:

Organizational meeting at the Commission: July 23, 20 13

Envision Center tour, including viewing soirie equipment and software

typically used in smai-t grid and meter deployineiits at tlie adjoining

KEMA Laboratory: August 13, 14, 15, 20, 21, or 22, 2013. If these date

options are riot conducive to the Coinmission’s schedule, tlie Joint Parties

are opeii to coiisider other dates, subject to the availability of tlie Envision

Center.

EPRI and/or Cooperative Research Network presentations at tlie

Commission - to be determined.

Repoi-t by Joint Parties’ Collaborative due to Conimission: June 30,2014

9

Dated: May 20,20 13

W. Duncan Crosby I11 Stoll Keenon Ogden PLLC 2000 PNC Plaza SO0 West Jefferson Street Louisville, KY 40202 Telephone: (502) 333-6000

- arid -

Allyson K. Sturgeon Senior Corporate Attoi-ney L,G&E and KU Energy LLC 220 West Main Street Louisville, Kentucky 40202 Telephone: (502) 627-2088

Counsel for Louisville Gas nnd Electric Congpany and Kenlzrcky Utilities Company

400001.144755/973506 12

Vice President, Rates and Regulatory Affairs Atiiios Energy Corporation 3275 I-Iighland Poiiite Drive Owensboro, KY 42303-21 14

Gnnifer B. H & V " . Dennis G. Howard, 11 Lawrence W. Cook Office of Kentucky Attorney General Office of Rate Intervention 1024 Capital Center Drive, Suite 200 Frankfort, KY 40601-8204

Counsel for Attorney General of the Commonwealth of Kentucky by and through His Ofice of Rate Intervention

T1"P Tysori Kabuf Sullivan, Mountjoy, Stainback & Miller PSC 100 St. Aim Street P.O. Box 727 Owensboro, K Y 42302-0727

Counsel.for Rig Rivers Electric Corporation und its nieinber distribution cooperatives: Juckson Purchase Energy Corporation, Kenergy Cosp and Meade County Rural Electric Cooperu five Corporation

- Albert A. Burchett Albert A. Burchett, Attorney at Law P.O. Box 0346 Prestonsbmg, ICY 41653

Counsel for Rig Sandy RECC

109 South First Street Nicholasville, ICY 403 56 859-8 85-46 19

Attorney for Blue Grass Energy Cooperative Corporation

GRANT, ROSE & PUMPHRE 5 1 South Main Street Winchester, Kentucky 4039 1 (859) 744-6828

Counsel for Clark Energy Cooperative, Inc.

Brooke E. Leslie, Counsel 200 Civic Center Drive P.O. Box 117 Columbus, OH 432 16-0 1 1 7

Richard S. Taylor 225 Capital Avenue Frankfort, ICY 40601

Counsel for Columbia Gas of Kentucky, Inc.

Bates 62 Skidinore 415 W. Main Streel, Suite 2 Frankfort. KY 30601

Barbourville, KY 40906

Attorney For Cumberland Valley Electric, Inc.

606-546-381 1

/Lzk Robert M. Watt I11 Stoll Keenon Ogden PLLC 300 W. Vine Street, Suite 2100 Lexington, KY 40507-1801

Counsel for Delta Natural Gas Company, Inc.

Senior Counsel Duke Energy Kentucky, 139 East 4th Street, R. 25 At I1 P. 0. Box 960 Cincinnati, OH 45201

I

David S. Samford Goss Samford PLLC 2365 Harrodsburg Road Suite R- I30 Lexington, KY 40504

Counsel for Duke Energy Kentucky, Iizc.

Mark David Goss Goss Samford PLLC 2365 Harrodsburg Road Suite B-130 Lexington, ICY 40.504

Counsel for East Kentalc@ Power Cooperative, Inc., Inter-County Energy Cooperative Corporation, and South Kentzicky Rural Electric Cooperative Coryoration

1 17 East Washington Street Glasgow, Kentucky 42 14 1 270-65 1-8884; 270-65 1-3662 (fax)

Cozinsel.for Farmers Rural Electric Coopesutive Coryosation

Suit, Price, Price & Ruark, PLLC 207 Court Square Flemingsburg, ICY 41 04 1 606-849-2338

Cotinsel, for Fleming-Mason Energy

Counsel for Grayson Rural Electric Cooperative Corporation

Respectfdly submitted by,

1.306 W. 5th St., Suite 100 P.O. Box 3440 Lo11do11, KY 40743-3440 (606) 878-8844 Fax: (606) 878-8850 Counsel for JACKSON ENERGY COOPERATIVE

.I-- R. R e i ~ a m i n ~ ~ t t e n d e n ,tdk & y d s o n PL,L,C ‘42l-W-: Main Street P .0 . Box 634 Frankfort, KY 40602-06.34

Collins & Allen Law Office Post Office Box 475 Salyersville, KY 4 1465-047s

Counsel for Lklting Valley Rural Electric Cooperative Corporation

WN, KY. $2782-0389

COUNSEL FOR NOLIN RURAL

CORPORATION ELECTRIC COOPERATIVE

' ,Crawford & Baxter, P.S.

P.O. Box 353 Carrollton, Kentucky 41 008 Phone: (502) 732-668 Fax: (502) 732-6920 E-mail: CB 5523 @a01 .com

Counsel for Owen Electric Cooperative, Inc.

Bardstown KY 40004 Counsel for Salt River Electric Cooperative

Corporation

Donald T Prather Mathis, Riggs aiid Prather, PSC 500 Main Street, Suite 5 Shelbyville, I<Y 40065

Eiiiail: dpratlier@igIou.com (502) 633-5220

Counsel for Shelby Energy Cooperative, Inc.}

,

15 Court Square - P. 0. Box 681 Lebanon, Kentucky 40033 Telephone: (270) 692-3141

Counsel for Taylor County Rural Electric Cooperative Corporation

c CA

I hereby certify that a true and accurate copy of the above and foregoing Joint Comments was served upon the following individuals by first class United States inail, postage prepaid, on the 20th day of May 20 13 :

Allen Anderson President & CEO South ICentucIty R.E.C.C. 92.5-929 N. Main Street, P.O. Box 910 Somerset, KY 42502-09 10

John B. Brown Chief Firiaricial Officer Delta Natural Gas Company, Inc. 3 6 1 7 L,exington Road Winchester, KY 40391

Anthony S. Campbell President & CEO East Kentucky Power Cooperative, Inc. 477.5 Lexington Road, P.O. Box 707 Winchester, KY 40392-0707

Judy Cooper Manager, Regulatory Services Columbia Gas of Kentucky, Inc. 2001 Mercer Road, P.O. Box 14241 Lexington, KY 40.5 12-424 1

Paul G. Embs President & CEO Clark Energy Cooperative, Inc. 2640 Ironworks Road, P.O. Box 748 Winchester, KY 403 92-0748

David Estepp President & General Manager Big Sandy R.E.C.C. 504 1 lth Street Paintsville, KY 4 1240- 1422

Carol Aim Fraley President & CEO Grayson R.E.C.C. 109 Bagby Park Grayson, KY 41 143

Michael L. Miller President & CEO Nolin R.E.C.C. 41 1 Ring Road Elizabethtown, KY 4270 1-6767

Barry L. Myers Manager, Taylor County R .E.C. C. 62.5 West Main Street P.O. Box 100 Campbellsville, ICY 427 19

G. Kelly Nucltols President & CEO Jackson Purchase Energy Corporation 2900 Irviri Cobb Drive, P.O. Box 4030 Paducah, KY 42002-4030

Christopher S. Perry President & CEO Fleming-Mason Energy Cooperative, Inc. P.O. Box 328 Flerningsburg, KY 4 104 1

Bill Pratlier President & CEO Farmers R .E.C.C . 504 South Broadway, P.O. Box 1298 Glasgow, KY 42141-1298

Billie J. Richert CFO, Vice President-Accounting, Rates Big Rivers Electric Corporation 201 Third Street Henderson, KY 424 19-0024

Mark Stallons President & CEO Owen Electric Cooperative, Inc. 8205 Highway 127 North, P.O. Box 400 Owenton, KY 403.59

Ted Hanipton Manager, Cuiiiberland Valley Electric, Inc. Highway 25E P.O. Box 440 Gray, KY 40734

Larry Hicks General Manager Salt River Electric Cooperative Coi-p. 11 1 West Brasliear Avenue, P.O. Box 609 Bardstown, KY 40004

Kerry K. Howard CEO, Licking Valley R.E.C.C. 271 Main Street, P.O. Box 605 West Liberty, KY 4 1472

James L Jacobus President & CEO Inter-County Energy Cooperative Corporation 1009 Hustonville Road P. 0. Box 87 Danville, KY 40423-0087

Mark Martin VP Rates & Regulatory Affairs Atinos Energy Corporation 3275 Highland Pointe Drive Owensboro, KY 42303

Debbie Martin President & CEO Shelby Energy Cooperative, Inc. 620 Old Finchville Road Shelbyville, KY 40065

Burns E. Mercer President & CEO Meade County R.E.C.C. P.O. Box 489 Brandenburg, KY 401 08-0489

Gregory Starheiin President and CEO Kenergy Coi-p. P.O. Box 18 Henderson, KY 424 19

Mike Williams President & CEO Blue Grass Energy Cooperative Cop. 1201 Lexington Road, P. 0. Box 990 Nicholasville, KY 40340-0990

Ranie Wohrdias Managing Director, Regulation & Finance Kentucky Power Company 101 A Enterprise Drive, P.O. Box 5190 Fraidcfort, KY 40602

Carol Wright President & CEO Jaclcson Energy Cooperative Corporation 1 15 Jaclcson Energy Lane McKee, KY 40447

R. Benjamin Critteriden Stites & Harbison PL,LC 421 W. Main Street P.O. Box 6.14 Frankfort, KY 40602-0634

Rocco D’Ascenzo Senior Counsel Duke Energy Kentucky, Inc. 139 East 4th Street, R. 25 At I1 P. 0. Box 960 Cincinnati, OH 45201

Mark David Goss Goss Sarnford PLLC 2365 Harrodsburg Road Suite B- 130 Lexington, KY 40504

Jennifer R. Hans Dennis G. Howard, I1 Lawrence W. Cook Office of Kentucky Attorney General Office of Rate Intervention 1024 Capital Center Drive, Suite 200 Frankfort, KY 40601-8204

David S. Saniford Goss Samford PL,LC 2365 Hai-rodsburg Road Suite B-130 L,exington, KY 40504

Tyson Kainuf Iris G. Skidinore Sullivan, Mountjoy, Stainback & Miller PSC 100 St. Aim Street P.O. Box 727 Owensboro, KY 42302-0727

Rates & Skidinore 41 5 W. Main Street, Suite 2 Frankfort, ICY 4060 1

Michael L. Kurtz 1Cui-t J. Boelxn Jody M. Kyler Boelm, Kui-tz R: Lowry 36 E. Seventh Street, Suite 1510 Cincinnati, OH 45202

Brooke E. Leslie, Counsel Columbia Gas of Kentucky, Inc. 200 Civic Center Drive P.O. Box 117 ColulnbL1s, OH 43216-01 17

Richard S. Taylor 225 Capital Avenue Frankfort, KY 40601

Robert M. Watt 111 Stoll Keenon Ogderi PLLC 300 W. Vine Street, Suite 2100 Lexington, KY 40507-1801

Conqmiy and Kenlucky Utilities Coinpany