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Petitioner's Confidential Exhibit No. 1 Northern Indiana Public Service

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Petitioner's Confidential Exhibit No. 1 Northern Indiana Public Service REDACTED Petitioner’s Confidential Exhibit No. 1 Northern Indiana Public Service Company LLC Page 1 VERIFIED DIRECT TESTIMONY OF ANDREW S. CAMPBELL 1 Q1. Please state your name, business address and title. 2 A1. My name is Andrew S. Campbell. I am the Director of Regulatory Support 3 & Planning for Northern Indiana Public Service Company LLC 4 (“NIPSCO”). My business address is 1500 165th Street, Hammond, Indiana 5 46320. 6 Q2. Please describe your educational and employment background. 7 A2. I graduated from Purdue University Calumet with a Bachelor of Science in 8 Mechanical Engineering and graduate studies in Interdisciplinary 9 Engineering. Additionally, I graduated with a Master of Business 10 Administration from the University of Notre Dame. I began my 11 employment with NIPSCO in June of 2009 as an Operations Analysis 12 Engineer. In September of 2011, I was promoted to the Manager of 13 Operations & Market Support and, in May of 2013, assumed the role of 14 Manager of Planning & Regulatory Support. In September of 2017, I was 15 promoted to my current role as Director of Regulatory Support & Planning. 16 Prior to joining NIPSCO, I worked as an engineer for an industrial Confidential – Excluded from public access per A.R. 9(G) REDACTED Petitioner’s Confidential Exhibit No. 1 Northern Indiana Public Service Company LLC Page 2 1 manufacturing company that specialized in engine attachments for marine 2 and small power generation applications. I am also a veteran of the Army 3 National Guard. 4 Q3. What are your responsibilities as Director of Regulatory Support & 5 Planning? 6 A3. As the Director of Regulatory Support & Planning, I am responsible for 7 leading the regulatory support and financial planning functions for the 8 Energy Supply & Optimization (“ES&O”) department within NIPSCO, 9 whereby my team supports NIPSCO’s operations within the electric and 10 natural gas markets. More specifically, my team is responsible for leading 11 all electric and natural gas rate case related support activities for the ES&O 12 department, supporting the forecast and reconciliation of NIPSCO’s Fuel 13 Adjustment Clause (“FAC”), Regional Transmission Organization (“RTO”) 14 Adjustment, Resource Adequacy (“RA”) Adjustment, Green Power Rider, 15 Gas Cost Adjustment (“GCA”), leading the development of NIPSCO’s 16 natural gas and electric hedging programs, and supporting NIPSCO’s 17 financial and business planning cadence. Most recently, I have been 18 leading the commercial execution of NIPSCO’s generation strategy 19 outlined within its Integrated Resource Plan submitted October 31, 2018 REDACTED Petitioner’s Confidential Exhibit No. 1 Northern Indiana Public Service Company LLC Page 3 1 (“2018 IRP”). 2 Q4. Have you previously testified before this or any other regulatory 3 commission? 4 A4. Yes. Most recently, I submitted testimony before the Indiana Utility 5 Regulatory Commission (“Commission”) in NIPSCO’s request for a 6 certificate of public convenience and necessity (“CPCN”) to purchase and 7 acquire (indirectly through a joint venture structure) a (1) a 265 megawatt 8 (“MW”) solar joint venture (the “Bridge I Project”); (2) a 435 MW solar and 9 75 MW energy storage joint venture (the “Bridge II Project”); and (3) a 200 10 MW solar and 60 MW energy storage joint venture (the “Cavalry Project”) 11 currently pending in Cause No. 45462; NIPSCO’s request for a modification 12 of the Commission’s February 19, 2020 Order issued in Cause No. 45310 for 13 authorization to use a contract for differences currently pending in Cause 14 No. 45463; NIPSCO’s request for approval and associated cost recovery of 15 a (1) a Solar Energy Purchase Agreement between NIPSCO and Brickyard 16 Solar, LLC dated June 30, 2020 (the “Brickyard Project”), and (2) a Solar 17 Generation and Energy Storage Energy Purchase Agreement between 18 NIPSCO and Greensboro Solar Center, LLC dated June 30, 2020 (the 19 “Greensboro Project”) currently pending in Cause No. 45403; NIPSCO’s Confidential – Excluded from public access per A.R. 9(G) REDACTED Petitioner’s Confidential Exhibit No. 1 Northern Indiana Public Service Company LLC Page 4 1 request for a CPCN to purchase and acquire (indirectly through a joint 2 venture structure) a (1) 102 MW wind farm (the “Rosewater Project”) in 3 Cause No. 45194, and (2) 302 MW wind farm (the “Crossroads Project”) in 4 Cause No. 45310; NIPSCO’s request for approval and associated cost 5 recovery of a wind purchased power agreement with (1) Jordan Creek 6 Wind Farm LLC in Cause No. 45195 (the “Jordan Creek Project”), and (2) 7 Roaming Bison Wind Farm LLC in Cause No. 45196 (the “Roaming Bison 8 Project”). I previously submitted testimony in NIPSCO’s electric rate case 9 in Cause No. 45159; NIPSCO’s gas rate case in Cause No. 44988; NIPSCO’s 10 request for approval of its 2018 Hedging Plan, 2019 Hedging Plan, and 2020 11 Hedging Plan (Cause Nos. 38706‐FAC‐118, 38706‐FAC‐122, and 38706‐ 12 FAC‐126); NIPSCO’s request for approval of an amendment to NIPSCO’s 13 2017‐2018 financing authority (Cause No. 45020); and in some of the 14 following tracker filings: GCA tracker filings (Cause No. 43629‐GCA‐XX), 15 FAC tracker filings (Cause No. 38706‐FAC‐XX), RA Adjustment tracker 16 filings (Cause No. 44155‐RA‐XX), and RTO Adjustment tracker filings 17 (Cause No. 44156‐RTO‐XX). 18 Q5. What is the purpose of your direct testimony in this proceeding? 19 A5. The purpose of my direct testimony is to support NIPSCO’s request for REDACTED Petitioner’s Confidential Exhibit No. 1 Northern Indiana Public Service Company LLC Page 5 1 approval of an Amended and Restated Solar Energy Purchase Agreement 2 between NIPSCO and Green River Solar, LLC (“Green River”) dated 3 December 23, 2020 (“Green River PPA”). Green River is an indirect, wholly‐ 4 owned subsidiary of NextEra Energy Resources, LLC (“NextEra”). The 5 Green River Project is being developed in Breckinridge County and Meade 6 County, Kentucky and has an installed capacity of approximately 200 MW 7 (nameplate capacity).1 The Green River PPA provides NIPSCO with 100% 8 of the electrical output of the Green River Project and any environmental 9 attributes associated with the project for a term of 20 years beginning at the 10 Commercial Operation Date (“COD”). 11 I describe NIPSCO’s generation transition plan, including the process 12 NIPSCO followed that led to the execution of the Green River PPA. I also 13 discuss how NIPSCO will integrate the Green River PPA into NIPSCO’s 14 and the Midcontinent Independent System Operator, Inc.’s (“MISO”) 15 operations and the viability of solar energy resources generally, and the 16 terms of the Green River PPA outlining NIPSCO’s rights to the solar energy 1 All nameplate capacity MW values in my testimony are stated in alternating current. In various exhibits to the PPA, MW values may be referenced in direct current which will appear higher than the alternating current equivalent. Confidential – Excluded from public access per A.R. 9(G) REDACTED Petitioner’s Confidential Exhibit No. 1 Northern Indiana Public Service Company LLC Page 6 1 project’s production, capacity, and environmental attributes and the related 2 benefits in the form of Renewable Energy Credits (“RECs”). I also describe 3 NIPSCO’s proposal for recovering the costs associated with the Green River 4 PPA. 5 Q6. Are you sponsoring any attachments to your direct testimony? 6 A6. Yes. I am sponsoring the following attachments, all of which were prepared 7 by me or under my direction and supervision. Attachment 1‐A Verified Petition Confidential Attachment 1‐B Green River PPA Attachment 1‐C NextEra Energy Resources Information 8 9 Q7. Is the Green River PPA a clean energy project for purposes of Ind. Code 10 § 8‐1‐8.8‐2 and therefore eligible for financial incentives under Ind. Code 11 § 8‐1‐8.8‐11? 12 A7. Yes. The Green River PPA is for products generated from a solar energy 13 project – a clean energy resource under Ind. Code § 8‐1‐37‐4, a renewable 14 energy resource under Ind. Code § 8‐1‐8.8‐10, and a clean energy project 15 under Ind. Code § 8‐1‐8.8‐2(2). NIPSCO is a public utility engaged in the 16 production, transmission, delivery or furnishing of heat, light or power, 17 and an eligible business under Ind. Code § 8‐1‐8.8‐6. REDACTED Petitioner’s Confidential Exhibit No. 1 Northern Indiana Public Service Company LLC Page 7 1 Generation Transition Plan 2 Q8. Please provide some background information about NIPSCO’s 2018 IRP. 3 A8. The 2018 IRP resulted in a preferred portfolio for NIPSCO’s generation that 4 calls for (a) the retirement of 75% of NIPSCO’s coal‐fired generation by 2023 5 and 100% of the coal‐fired generation by 2028, (b) the continued operation 6 of NIPSCO’s gas‐fired Sugar Creek Generating Station (“Sugar Creek”), 7 and (c) replacement of certain retired generation units largely with wind, 8 solar, and energy storage. Section 9.4 of the IRP described a Short‐Term 9 Action Plan, which outlined the key steps NIPSCO should take to select and 10 implement resources to replace the 2023 retirements. The Short‐Term 11 Action Plan contemplated an all‐source request for proposal (“All‐Source 12 RFP”), which NIPSCO undertook on May 14, 2018 and additional RFPs, 13 which NIPSCO undertook in 2019 (the “Phase II RFPs”), as more fully 14 discussed below. Witness Augustine provides a more detailed discussion 15 of NIPSCO’s 2018 IRP and the Short‐Term Action Plan. 16 Q9.
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