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5.3. ERMUSR 03-14-2006~j Elk River Municipal Utilities 13069 Orono Parkway Elk River, MN 55330 March 7, 2006 To: Elk River Municipal Utilities Commission Jerry Takle John Dietz Jim Tralle From: Bryan Adams Subject: MMUA &APPA Update phone: 763.441.2020 Fax: 763.441.8099 On February 28 -March 2 2006, Jerry Takle and I had an opportunity to participate in APPA's legislative rally in Washington, D.C. The group met with all of the legislative members except for Representative Sabo. Attached are the following fact sheets and position papers for your review: I) APPA fact sheet 2) MMUA position statement `The Lack of Railroad Competition' 3) MMUA position statement `Transmission and RTO's' 4) MMUA position statement `Federal Incentives for Renewables' 5) MMUA position statement `Protecting the Interest of WAPA Customers' 6) MMUA position statement `Municipal Telecommunications' 7) MMUA position statement `Air Quality' 8) MMUA position statement `Electric Utility Service Territories- A State Issue' 9) MMUA position statement `Why Public Power?' APPA on an annual basis does a rate survey based on EIA 861 federal form. Attached is 2004 survey data including the new data and summary reflecting the statistic information with the triangle being ERMU position. This survey continues to show that the ERMU is not competitive in the industrial area, but more competitive in the residential/commercial classes. ~A~~~.~~ „"~/ Position Statement Minnesota Municipal Uti/ities Association The Lack of Railroad Competition Railroad transportation is the principal method of delivering coal to the electric generation facilities that provide power to Minnesota municipal electric utilities and their customers. This heavy reliance on rail has left these utilities vulnerable to market pressures caused by the absence of competitors in the railroad industry. Utilities and all railroad customers facing these unchecked market pressures have become known as captive shippers. The consolidation of the railroad industry that has occurred over the last twenty-five years has been stunning. When Congress passed the Staggers Rail Act in 1980, the resulting industry deregulation was supposed to have ushered in a new era of competition that would benefit customers. However, instead of experiencing the intended result, shippers endured a period of unprecedented consolidation as the number of class I railroad companies in the United States was reduced from 42 to 4. The federal government has been ineffective in its effort to control these uncompetitive rail transportation practices. In 1995 Congress abolished the Interstate Commerce Commission and gave the newly created Surface Transportation Board (STB) authority over mergers, rate and service disputes, construction, and operation and abandonment of railroad lines. Since that time, the STB has declined to use its existing legal and regulatory authority to protect railroad customers from the monopolistic practices of the railroad industry. The lack of real competition in the railroad industry, coupled with an absence of effective regulation of industry operations, has had a negative effect on many Minnesota municipal utility customers. Reviewing recent rail rate activity, it is becoming increasingly obvious that shipping costs will more than double as current contracts expire and new rates are set. Meanwhile, service continues to deteriorate dramatically. Missouri River Energy Services (MBEs), supplying wholesale power to 23 member utilities in Minnesota, is a co-owner of the Laramie River Station (LRS), a coal-fired power plant near Wheatland, Wyoming. Upon expiration of the long-term rail shipping contract LRS had with Burlington Northern and Santa Fe Railway Company (BNSF), MRES and its partners experienced an immediate doubling of rail shipping rates charged by BNSF to transport coal the 175 miles to Laramie River from mines in Wyoming's Powder River Basin. (BNSF is the only rail service.) Today, these transportation rates are more expensive than the coal itself. MRES and its partners believe that BNSF is unlawfully exerting its monopoly power over these captive shippers, increasing costs to the plant by an estimated $1 billion over the next 20 years. Western Fuels Association, a cooperative supplying coal to its members, and Basin Electric Power Cooperative, operator of the Laramie River Station, have filed a request for rail shipping rate relief The captive shipping issue is not limited to utilities and affects many other large segments of our economy including agriculture, wood products and chemicals. This is best illustrated by the list of organizations supporting the rail competition reform. Supporting organizations include the following: • American Chemistry Council • American Forest and Paper Association • American Plastics Council • American Public Power Association • Edison Electric Institute • Fertilizer Institute • National Association of Wheat Growers • National Barley Growers Association • National Industrial Transportation League • National Rural Electric Cooperative Association • Portland Cement Association and others. MMUA urges Congress to pass captive rail legislation into law. Minnesota Municipal Utilities Association February 2006 ~A~~~.~~ ~,,,,~/ Minnesota Municipal Uti/ities Association Position statement Transmission and RTOs The Energy Policy Act of 2005 (EPAct 2005), while far from perfect, was a step in the right direction in several areas, and was supported by public power due to the addition of several key provisions: • Mandatory, enforceable reliability standards; • Federal backstop authority for transmission siting; • New authority by the Federal Energy Regulatory Commission (FERC) to prevent market manipulation; and • Preserving long-term transmission rights for load-serving entities. Despite the best efforts of Congress and FERC to develop efficient wholesale markets, public power communities are finding it more difficult than ever to secure reliable and reasonably priced wholesale power as a result of FERC decisions concerning the governance of the transmission network. Public power entities have encountered serious problems in dealing with the regional transmission organizations (RTOs) designated by FERC to manage the regional transmission grid. In order to continue to provide their electric customers with reliable power at reasonable rates, Minnesota municipal electric utilities will need FERC to play a more proactive role to ensure the construction of adequate transmission facilities, workable transmission policies, and adequate implementation of new rules promulgated as a result of EPAct 2005. Specifically, several key issues worth watching include: RTO Accountability. RTOs were originally formed with the idea of benefiting consumers by adopting policies promoting non-discriminatory transmission service, regional long-term planning and timely investments in transmission facilities. Instead, they have increasingly resorted to questionable pricing practices to deal with transmission congestion rather than adopting policies designed to lower costs and to improve service. At the same time, there is a growing concern that RTOs are resisting any questioning of the economic theories underpinning these actions. Other problems with the RTOs include: spiraling RTO costs, unaccountable governance, lack of understanding of end-user needs and less than satisfactory service options. Market Manipulation. Power supply markets have become more concentrated. Merely requiring open access transmission has not made those markets workably competitive. The repeal of the Public Utility Holding Company Act (PUHCA) could potentially increase the concentration of these markets. The use of locational marginal pricing (LMP) allows certain stakeholders to benefit from A/1/IA/~.~I Minnesota Municipal Uti/ities Association Pasiti®n st~terne~nt Federal Incentives for Renewables Two federal issues important to Minnesota municipal utilities should be addressed in any energy legislation passed by Congress-Clean Renewable Energy Bonds (CREBs) and Renewable Energy Production Incentive (KEPI). Minnesota municipal utilities have long embraced the use of renewable generation to meet the electric energy needs of the citizens of their communities. They have been motivated by the need to secure wholesale power that will result in reliable and reasonably priced service to their customers. It was for that reason, more than 50 years ago, that municipal utilities in western Minnesota began making commitments to purchase wholesale power from federal hydroelectric dams, at a time when power from conventional sources would have been less expensive and, it seemed, possibly even more reliable. It is with this same sense of responsibility that municipal utilities are approaching the effort to develop wind and other renewables in order to meet a portion of their electricity needs. Minnesota law requires that municipal power agencies, G&T cooperatives and IOUs make a "good faith effort" to generate or procure one percent of the electricity needs of the retail customers in their systems from "renewable" resources by 2005, and to increase the amount by one percent each year, reaching 10% by 2015. An added biomass mandate is included, requiring one-half percent of electric sales to come from biomass sources by 2010, and one percent by 2015. Power from renewable resources and advanced technologies continues to be more expensive than power from traditional generation sources. Federal investment incentives are needed to encourage the construction of these facilities. The federal government has determined that tax policy is a viable mechanism to encourage renewables and provides private developers with the Production Tax Credit (PTC), a federal tax credit for electricity generated from qualifying renewable energy projects. However, investment tax credits made available to privately-owned utilities and energy production companies do not create incentives for publicly-owned or rural electric cooperative utilities, which serve 25% of the nation's electricity load. Clean Renewable Energy Bonds (CREBs). To address this lack of equity, Congress enacted the CREBs program in the Energy Policy Act of 2005 (EPAct 2005). CREBs is a debt instrument which can be offered for qualified renewable facilities under section 45 of the tax code. Investors receive credits against their federal income tax liability instead of the traditional interest that is usually paid by the issuer. The municipal utility or cooperative is liable for the face value of the bond, and saves by owing no interest on the bond. The federal government would essentially pay the "interest" in the form of tax credits. The CREBs program will provide public power systems greater certainty and AwAii.~~ Minnesota Municipal Uti/ities Association Position Statement Protecting the Interests of WAPA Customers The Western Area Power Administration (WAPA) is one of four federal power marketing administrations (PMAs). WAPA markets and delivers reliable, cost-based hydroelectric power within a 15 state region of the central and western United States. WAPA is very important to Minnesota municipal utilities, providing wholesale power allocations to 47 municipal electric utilities serving over 200,000 people in the western third of the state. WAPA's 17,000-mile transmission system carries electricity from 55 hydropower plants operated by the Bureau of Reclamation, the U.S. Army Corps of Engineers and the International Boundary and Water Commission. In marketing electricity, WAPA must follow many laws, regulations and policies, some of which are unique to that agency. Included in these laws is the Reclamation Project Act of 1939, which requires WAPA to give preference in selling federal power to certain types ofnon-profit organizations including cities, rural electric cooperatives, state and federal agencies, irrigation districts, public utility districts and Native American tribes. WAPA customers in Minnesota are served by the Upper Great Plains Region office located in Billings, Montana, which, in turn, provides electric service from the seven dams of the Pick-Sloan Missouri River Program, developed as a result of Congressional ~, N W O 0 0 N N O 3 Z T N X V W U1 Ul 1-+ 0 .~ 3 3 c a 0 authorization in 1944. The Office of Management and Budget is currently recycling an earlier proposal to reallocate $365 million in costs for authorized but undeveloped irrigation projects for payment by Pick-Sloan customers. We strongly object to this approach by OMB, since those projects could be authorized by the federal government at any time. Even if the irrigation projects are not developed, power customers should not be singled out to bear the entire burden for those costs. Other key issues include: • The current short-term authorization for the Corps of Engineers and the Bureau of Reclamation to use PMA customer receipts to fund the operation and maintenance of hydro projects should be made permanent. • Use of PMA customer receipts to fund hydro project operation and maintenance should occur only after review and approval by PMA customers. • PMA security costs should be paid by the general budget of the Bureau, and not borne by the PMAs and their customers. • The appropriations process must provide adequate funding for purchased power and wheeling programs. ~~~~..~~ Minnesota Municipal Uti/ities Association P®~ition Statement Municipal Telecommunications Modern, affordable telecommunications infrastructure is key to economic growth in the 21St century. Unfortunately, some areas in Minnesota are without this infrastructure. Others suffer with unreliable, slow, or expensive service. Studies show that the U.S. is rapidly falling behind other industrialized countries in the deployment of broadband services. A key factor in this fact is the lack of a national broadband policy. MMUA and its national affiliate-the American Public Power Association (APPA)-urge Congress to adopt pro-consumer policies that will foster the deployment of broadband delivery systems by any entity willing to do so, including municipalities and public power systems. Why municipal telecommunications? Municipal utilities are at the cutting edge of providing broadband technology service in Minnesota and across the nation by offering a variety of wireless, DSL, broadband power line and fiber optic broadband services. Technological advances, especially Wi-Fi, a wireless network protocol that uses unregulated spectrum often used for wireless local area networks, is being put into place to improve existing municipal operations. This technology makes high-speed, low-cost Internet access available on a ubiquitous, mobile basis. Perhaps because of technological advances, telecom and cable companies are seeking to restrict municipal telecom services. Lawmakers should resist any such effort. The interests of entrenched telephone and cable companies must not be placed above the right of citizens to meet their own needs for essential infrastructure. Municipal communications utilities: (1) drive economic development, serve existing business and industry and attract new ones; (2) improve the efficiency of the city and other local government institutions, including utilities; (3) keep customer savings in the community, where further economic activity is spurred; (4) provide a wide variety of other public purposes that citizens, tlu-ough their elected and appointed officials, demand. In short, they close the digital gap that existed before their establishment. Courts thwart Congressional intent. The Telecommunications Act of 1996 provides that states cannot ban "any entity" from providing telecommunications services. 47 U.S. Code §253. Unfortunately, the courts have not honored the plain language of the statute and have approved state laws that prohibit local governments from providing needed telecommunications services. Missouri passed a state statute that banned local governments in Missouri from offering telecommunications services. The local governments, represented by the Missouri Municipal League, wanted the Federal Communications Commission (FCC) to preempt the state law, under Section 253. The question before the courts was, does Section 253 Minnesota Municipa/ Uti/ities Association Air Quality Position Statement The Clean Air Act (CAA) was passed in 1970 to achieve and maintain healthy air quality in the United States. As amended, CAA addresses control standards for new generating plants, protection of visibility in pristine areas, and control of acid rain precursor emissions. CAA currently includes multiple programs designed to reduce the emissions of certain pollutants for power plants. The large number of programs, their conflicting compliance deadlines, and the cost of pollution control technologies have increased the costs associated with generating electric power from fossil fuel plants. To address this patchwork of regulatory programs, the passage ofmulti-pollutant control legislation that amends and updates CAA is an important issue for the power generation sector. As Congress considers clean air reforms, any legislation to alter the current regulatory scheme for power plants should include the following concepts to achieve a proper balance of economic, energy and environmental goals: N • Limit only the emissions of sulfur dioxide (SOZ~, nitrogen oxides (NOx), and mercury (Hg). Some members of Congress support legislation that would limit emissions of carbon dioxide (C02), which would be extremely costly and could impair the security of the nation's electricity supply. A COz program involving o continued research on climate change and voluntary reduction offers a better o approach to dealing with this concern. N • Allow plant modifications that improve efficiency without increasing o emissions. The continuing uncertainty over when New Source Performance Standards apply to plant modifications must be resolved. New Source Review Z (NSR) should not be used to prevent plant owners from making modifications that T would increase plant efficiency and output without increasing emissions. • Rely on regulation or legislation that provides innovative and flexible °' mechanisms for achieving emissions goals. Using market-based programs similar to the cap and trade system for limiting S02 emissions is a more effective way to deal with controlling multiple air pollutants than the current, often `° redundant approach to reaching air quality standards. • Base legislation and regulatory reform on science and cost-effectiveness, taking into account the impact on energy reliability and security. Environmental goals are best achieved when those goals are grounded in good science, supported by the public, and addressed in the most cost-effective mariner. • Recognize existing "clean plants" and "clean utilities." Ironically, some proposals would require clean plants to further reduce pollution emissions at the same reduction rate as dirty plants, forcing customers to pay even higher costs for incremental improvements with diminishing returns. Minnesota Municipal Utilities Association February 2006 ~~~~~.~/ ~iiriv~~ Pa~iti®n St~t~m~~t Minnesota Municipa/ Uti/ities.4ssociation Electric Utility Service Territories - A State Issue In recent years, electric cooperatives have attempted to secure the passage of federal legislation that would have severely restricted the ability of municipal electric utilities to grow with their cities. These efforts were unsuccessful, but similar attempts to add service territory language to federal legislation tnay be made in the future. There is simply no need for Congress to become involved in electric utility service territories. Like most issues relating to retail electric distribution service, the designation of service territories has long been governed under state law. Minnesota's municipal electric utilities have had the right to serve annexed areas since the inception of the industry more than 100 years ago. This historic right was affirmed and preserved in the 1974 state law that established the current regulatory scheme. Our law, like that of many states, provides that a municipal electric utility has the right to serve areas annexed by the city. The law also provides that the utility previously serving the annexed area must be provided with fair compensation. Here are some important facts to remember about Minnesota's designated service territory law: • The co-ops needed the 1974 service territory law in order to obtain funding to build the Coal Creek project, which still serves today as one of their primary sources of wholesale power. To secure passage, they agreed to and supported the municipal annexation provision in the law. • The co-ops have enjoyed tremendous growth in the years since the service territory law was enacted. Their growth, which has largely come from the expansion of cities that do not own their electric service, has far outstripped that of the municipal utilities. In fact, co-ops are the fastest-growing segment of the industry in Minnesota. • The co-ops are poised to capture much of the growth around communities served by investor-owned utilities, as well as around those communities already served by co-ops. This has been happening for some time in the Twin Cities Metro area, and is beginning to occur in other parts of the state as well. • In addition to enjoying their own rapid growth, the co-ops receive fair compensation under the law when a city purchases service rights following annexation. The designation of electric utility service territory is fundamentally a state issue, fully governed by state law in Minnesota and in other states. There is no justification for Congressional involvement in the service territory issue. Minnesota Municipal Utilities Association February 2006 ~A~~,.~~ ~iiriv~~ Position Statement Minnesota Municipa/ Uti/ities Association Why Public Power? One hundred twenty-six Minnesota cities benefit from having a locally owned and locally operated municipal electric utility. Thirty-one cities have a municipal natural gas system. Fifty of our eighty-seven county seats are served by a municipal electric or gas system. A not-for-profit municipal electric or gas utility is a tremendous asset in these uncertain times. Here are some of the reasons why: • We have great service. We're part of the community and our policy makers, managers and workers are part of the community. Our crews are always on hand in the event of emergency. You don't need to call an 800 number to talk to us. • We're locally regulated. Members of the community who live in the community set rates and service practices. If you have a problem, you know who to talk to. • We're owned by our customers. There is no tension between the interests of customers and the interests of stockholders. Our focus is Main Street, not Wall Street. We work for you. • We're not in it for the money. Municipal utilities are not-for-profit and operated in the public interest. Our goal is long-term community benefit, not short-term gain. We work hard to save you money. • We're the yardstick for the industry. For generations, public power systems have set standards for rates and service that other utilities have had to meet. • We'll be there. Many of Minnesota's municipal electric utilities have served their communities for more than a hundred years. In an era when new competitors come and go faster that we can learn their names, you can count on us. We will be there when you need us. • We're Public Power. We're here for you! Minnesota Municipal Utilities Association February 2006 APPA 2004 Electric Rate Comparison RESIDENTIAL j COMMERCIAL INDUSTRIAL ¢Ikwh ~ ¢/kwh ¢/kwh Elk River Municipal Utilities ~- 8.6 ~ 7.8 ~ 7.0 -- -- _-- U.S. Utilities -- - ~_ ~_ _ _ _ ________ _ Minimum ~ 8.2 7.6 4.8 1 st Quartile ~ 8.3 7.7 5.0 __ __ Avera~ce ---- ~ 8.5 _ ~ 7.8 -~ 5.1 __ - - -- I 3rd Quartile 8.7 ! - 7.9 5.2 _ _ Maximum ___ 9.0 __ 8.0 ~ 5.3 ---- _ - Minnesota Utilities _ Minimum ~ 7.4 ~ 6.2_ 4.5 ___ _ 1st Quartile Average __--_-_ _ __ __ _7.7_ _ 7.8 --- ___ 6.5 __ ---- 6.6__ 4.8 _ 4.9 __ 3rd Quartile 8.0 6.8 -- 5.1 Maximum ~__--- 8.1 --- ~ 6.8 _ I 5_2_ -- Minnesota Publicly Owned ~_ Minimum 4.3 _ 1st Quartile _ _ 6.1 Average 7.1 ~ 3rd Quartile ~ 7.9 _ Maximum 11.3 ~ _ _ 0.0 _ 6.0 6.8 _ ~~ 7.7 13.5 ____ 0.0 _ 0.0 _ _ 4.0 _ ~2 11.3 Minnesota Investor Owned ~ ~ ~ _ _ Minimum _ j -6.9 _ __ ~_ _5.8 ~ 0.0 _ _ ____ 1st Quartile Average ~ 7.1 8.2 - 6.2 __ 7.3 i 4.1 I _ 3.8 ___ _ 3rd Quartile 9.4 ~ 7.8 ~ 4.7 Maximum ~ 9.6 10.4 ~ 6.2 _ ---------- - --- - ____ ____ __ 1-- Minnesota Cooperativ__e_s _~ Minimum ___ 1st Quartile _ Ave_rag_e_ _ 3rd Quartile _ 6.1 _ __ 7.2 ~ __ 7.9 _ ~~ 8.5 _ ~ _ _ __ __ 0.0 ~ _ 6.4 _ 6.6______ ~ 7.5 _ _ 0.0 ___ 0.0 _ __ 3.6 __ __~ _5_2 __ Maximum , 11.3 8.8 i, 10.9 Average Revenue per kWh, 2004 (in cents) United States and Minnesota Residential Commercial Industrial Total Rey1k~ Rev/kWh Re~/kWh Br~Lk~'h U S U itities Publicly Owned Investor-Owned Cooperative 8.2 7.6 5.3 7.2 9.0 8.0 5.1 7.6 8.3 7.7 4.8 7.4 Minn o a Publicly Owned Investor-Owned Cooperative 7.4 6.8 5.2 6.3 7.9 6.2 4.5 5.9 8.1 6.7 5.0 7.3 esota Ada Water & Light Department Adrian Public Utilities Commis Aitkin Public Utilities Commis Alexandria Board of Public Work Alpha, City of Alvarado, City of Anoka, City of Arlington, City of Austin Utilities Bagley Public Utilities Barnesville Electric Department Baudette, City of Benson, City of Bigelow, City of Biwabik Public Utilities Blooming Prairie Public Utilities Blue Earth Light & Water Depart Brainerd Public Utilities Breckenridge, City of Brewster, City of Brownton, City of Buffalo Municipal Utility Buhl, City of Caledonia, City of Ceylon, City of 6.7 9.7 4.3 7.3 7.1 7.8 6.8 7.4 5.5 8.6 8.3 7.3 7.0 6.5 4.8 5.7 9.6 8.8 - 9.3 6.8 7.5 - 7.1 8.3 7.1 5.4 6.8 7.7 7.7 - 7.7 8.7 6.9 4.6 6.5 5.2 5.0 5.6 5.4 6.5 6.4 - 6.5 7.6 6.7 5.6 6.6 6.1 6.7 5.2 5.8 7.2 7.2 9.9 7.7 6.1 7.8 - 6.9 7.4 6.3 - 6.6 8.0 8.3 6.7 7.2 7.1 6.8 5.9 6.6 5.1 5.7 5.6 5.4 6.2 6.4 1 0.4 7.3 6.7 7.3 8.2 6.9 7.4 7.6 4.9 7.2 6.0 6.2 3.7 5.9 7.3 6.2 5.4 6.3 5.4 5.4 - 5.4 Residential Commercial Industrial Total Chaska Electric Department 6.8 6.1 5.8 6.1 Darwin, City of 7.3 6.3 - 7.0 Delano Municipal Utilities 8.4 8.2 6.8 7.4 Detroit Lakes, City of 5.9 6.0 4.7 5.3 Dunnell, City of 7.4 7.1 - 7.3 East Grand Forks Water, Light, 7.6 7.0 6.2 6.7 Eitzen, City of 7.8 7.2 7.8 7.6 Elbow Lake, City of 7.5 5.2 11.3 6.2 Elk River Municipal Utilities 8.6 7.8 7.0 7.7 Ely, City of 7.1 6.0 - 6.4 Fairfax, City of 6.0 6.9 6.0 6.3 Fairmont Public Utilities Commission 7.3 6.1 5.1 6.0 Fosston, City of 6.3 6.1 6.3 6.2 Gilbert Water & Light 6.5 6.6 - 6.5 Glencoe Light & Power Commission 8.3 8.0 7.1 7.8 Grand Marais Public Utilities Comm. 7.4 6.9 - 7.1 Grand Rapids Public Utilities Comm. 6.9 6.2 5.0 6.3 Granite Falls, Town of 7.3 7.7 5.3 7.4 Grove City Public Utilities 7.9 6.8 - 7.4 Halstad Municipal Utilities 5.8 5.5 - 5.7 Harmony, City of 6.2 6.2 6.2 6.2 Hawley Public Utilities Commission 7.1 6.2 - 6.7 Henning, City of 6.4 6.4 - 6.4 Hibbing Public Utilities Commission 8.6 7.9 8.1 8.2 Hutchinson Utilities Commission 7.6 7.4 6.3 6.9 Jackson, City of 6.4 6.0 5.5 5.8 Janesville, City of 6.2 6.2 - 6.2 Kandiyohi, City of 6.3 6.1 - 6.3 Kasota, City of 6.1 13.5 - 6.5 Kasson, City of 7.8 6.3 - 7.2 Keewatin Public Utilities Commission 7.1 6.7 - 7.0 Kenyon Municipal Utilities 10.5 10.6 8.4 9.4 Lake City, City of 8.7 8.2 4.9 5.8 Lake Crystal Municipal Power Plant 8.8 6.9 9.3 8.0 Lake Park Public Utilities 6.3 5.5 - 6.0 Lakefield Public Utilities 5.5 5.6 - 5.5 Lanesboro Public Utility Commission 8.1 8.0 - 8.0 Le Sueur, City of 9.8 9.1 5.4 6.2 Litchfield Public Utilities 5.0 5.2 3.9 4.6 Luverne, City of 6.9 7.7 4.7 5.6 Mabel, City of 6.6 6.5 - 6.5 Madelia Municipal Light & Power 9.6 8.8 7.2 8.4 Madison, City of 5.1 5.4 7.2 5.5 Marshall Municipal Utilities 5.2 5.7 3.9 4.1 Melrose, City of 4.3 4.8 3.8 4.1 Moorhead Public Service 5.5 6.2 4.3 5.0 Moose Lake Water & Light Comm. 6.6 6.7 - 6.7 Residential Commercial kWh Industrial R ~k~'h R Total ev/kWh Mora Municipal Utilities Rev/kWh 7.4 Rev/ 6.7 ev 6.2 6.6 Mountain Iron, City of 6.9 8.3 8.7 7.6 Mountain Lake, City of 8.1 5.7 5.5 6.5 Nashwauk Public Utilities 5.8 6.6 - 6.2 New Prague Utilities Commission 7.1 6.8 6.0 6.4 New Ulm Public Utilities 11.3 8.9 8.2 9.1 Newfolden, City of 5.5 5.1 - 5.3 Nielsville, City of 8.1 7.2 - 7.9 North Branch, City of 8.7 7.9 7.0 8.1 North Saint Paul, City of 8.6 7.7 - 8.2 Olivia, City of 5.8 4.4 7.2 6.1 Ortonville, City of 5.3 4.8 - 5.0 Owatonna Public Utilities 7.7 6.4 5.2 6.0 Peterson, City of 7.9 - - 7.9 Pierz Municipal Electric 8.4 7.7 5.0 7.9 Preston Public Utilities Commission 7.5 7.9 7.0 7.5 Princeton Public Utilities Commission 9.6 8.8 7.1 8.3 Proctor Public Utilities Commission 5.9 5.4 6.2 5.8 Randall, City of 5.8 7.5 6.7 6.5 Redwood Falls Public Utilities 4.8 5.3 4.9 5.0 Rochester Public Utilities 8.8 7.1 5.4 7.1 Roseau, City of 6.1 5.3 - 5.6 Round Lake, City of 7.4 10.0 7.5 7.9 Rushford, City of 7.0 6.8 6.0 6.6 Rushmore, City of 7.6 7.7 5.6 7.6 Sauk Centre Public Utilities Comm, 5.5 5.7 5.0 5.3 Shakopee Public Utilities Comm 7.9 6.9 5.3 6.2 Shelly, City of 6.6 5.4 9.1 6.4 Sleepy Eye Public Utility Comm 7.8 6.8 5.8 6.7 Spring Grove, City of 9.2 8.1 3.8 6.2 Spring Valley Public Utilities 8.1 7.3 - 7.7 Springfield Public Utilities 7.0 6.1 6.2 6.4 St. Charles, City of 8.0 7.3 6.1 7.0 St. James, City of 5.3 5.1 4.0 4.8 St. Peter Municipal Electric Utility 8.6 6.6 5.9 7.1 Staples, City of 7.6 7.7 5.3 7.0 Stephen, City of 7.4 5.4 - 6.3 Thief River Falls, City of 5.6 5.0 5.4 5.3 Truman Public Utilities 9.7 9.1 - 11.0 Two Harbors, City of 7.4 7.6 7.6 7.5 Tyler, City of 6.4 6.4 - 6.4 Virginia Department of Public Utility 7.7 7.2 - 7.3 Wadena, City of 5.3 5.6 4.7 5.0 Warren, City of 7.9 5.5 - 6.5 Warroad, City of 6.5 5.9 3.3 4.4 Waseca, City of 8.6 7.2 - 7.8 Wells Public Utilities 9.0 8.8 - 8.9 Residential Commercial Industrial Total Westbrook Municipal Light & Power 6.1 6.7 5.8 6.2 Whalan, Town of 5.4 - - 5.4 Willmar Municipal Utilities Comm. 8.0 7.0 5.6 6.6 Windom, City of 6.0 6.0 5.6 5.8 Winthrop, City of 7.3 6.6 6.0 6.8 Worthington Public Utilities 6.5 6.5 4.7 5.6 Minnesota Investor-Owned Interstate Power and Light Co 9.4 7.8 6.2 7.7 Minnesota Power Inc 7.1 6.3 4.1 4.7 Northern States Power Co 8.1 6.2 4.7 6.2 Northwestern Wisconsin Elec Co 9.6 10.4 - 9.9 Otter Tail Power Co 6.9 5.8 4.2 5.8 Minnesota cooperative Agralite Electric Coop 8.0 6.4 4.4 6.6 Anoka Electric Coop 8.6 6.7 5.3 7.7 Arrowhead Electric Coop, Inc 8.6 7.4 - 8.1 Beltrami Electric Coop, Inc 6.4 6.2 10.9 6.4 Blue Earth-Nicollet-Faribault 8.6 6.5 - 7.9 Brown County Rural Elec Assn 7.0 6.4 4.7 6.4 Clearwater-Polk Elec Coop Inc 6.8 6.1 - 6.7 Cooperative L&P Assn Lake Cnty 8.5 7.6 4.1 7.2 Crow Wing Cooperative Power & Light C 7.9 6.8 9.5 7.7 Dakota Electric Assn 8.4 7.6 5.5 7.1 East Cenu-al Energy 9.3 7.7 4.9 8.2 Federated Rural Electric Assn 6.2 5.0 - 5.7 Freeborn-Mower Coop Services 8.5 6.2 3.6 6.8 Goodhue County Coop Elec Assn 8.7 8.8 - 8.7 H-D Electric Coop Inc 8.6 - - 8.6 Heartland Power Coop 8.1 - - 8.1 Itasca-Mantrap Co-op Electrical Assn 7.5 7.5 4.5 6.6 Kandiyohi Power Coop 8.1 7.5 5.2 7.8 Lake Country Power 7.9 7.0 5.2 7.5 Lake Region Coop Elec Assn 8.7 8.0 5.9 8.5 Lyon-Lincoln Electric Coop Inc 7.5 6.0 6.5 7.2 McLeod Cooperative Power Assn 8.3 6.7 4.3 7.0 Meeker Coop Light & Power Assn 8.0 7.8 5.0 7.9 Mille Lacs Electric Coop 9.4 6.8 5.8 8.2 Minnesota Valley Coop L&P Assn 7.1 6.8 4.0 6.5 Minnesota Valley Electric Coop 8.1 5.5 - 7.1 Nobles Cooperative Electric 7.2 5.5 - 6.6 North Itasca Electric Coop Inc 11.3 7.6 5.3 10.3 Residential Commercial Industrial Total North Star Electric Coop, Inc P K M Electric Coop, Inc People's Cooperative Services Red Lake Electric Coop, Inc Red River Valley Coop Pwr Assn Redwood Electric Coop Renville-Sibley Coop Pwr Assn Roseau Electric Coop, Inc Runestone Electric Assn Sioux Valley SW Elec Coop South Central Electric Assn Stearns Cooperative Elec Assn Steele-Waseca Cooperative Electric Todd-Wadena Electric Coop Traverse Electric Coop, Inc Tri-County Electric Coop Wild Rice Electric Coop, Inc Wright-Hennepin Coop Elec Assn 7.7 6.4 - 7.3 7.4 6.6 - 7.3 8.4 7.2 - 8.2 6.2 5.8 5.1 6.1 6.8 6.5 - 6.7 8.5 8.5 - 8.5 6.9 7.2 3.6 4.7 6.1 6.5 4.3 5.8 7.9 7.4 5.0 7.6 7.1 7.9 5.5 6.6 8.0 6.5 3.6 6.5 7.4 7.1 5.6 7.2 9.8 8.1 4.8 7.9 7.3 6.5 4.5 7.1 8.1 6.8 4.8 7.6 8.9 7.0 3.5 7.7 6.5 5.7 3.9 6.3 7.6 6.4 5.5 7.0 Source: U.S. Department of Energy, Energy Information Administration, Form EIA-861, 2004 data. Prepared November 2005 by the American Public Power Association, Department of Statistical Analysis.