2015 INTEGRATED RESOURCE PLAN - MNPower

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P U B L I C V E R S I O N C O N F I D E N T I A L I N F O R M AT I O N E X C I S E DSepte902015INTEGRATEDRESOURCEPLANmber1,201155 D oc k e t N o . E 0Printed on 100% recycled paper./RP5-1-6

Lori HoyumPolicy Manager218-355-3601lhoyum@mnpower.comSeptember 1, 2015VIA E-FILINGDaniel P. WolfExecutive SecretaryMinnesota Public Utilities Commission121 7th Place East, Suite 350St. Paul, MN 55101-2147Re:In the Matter of Minnesota Power’s Application forApproval of its 2015-2029 Resource PlanDocket No. E015/RP-15-690Dear Mr. Wolf:Minnesota Power presents for approval its 2015 Integrated Resource Plan (“2015 Plan”or “Plan”) pursuant to the requirements set forth in the Minnesota Public Utilities Commission’s(“Commission”) Order dated November 12, 2013, in Docket No. E015/RP-13-53. This Plan isbeing filed under Minn. Stat. § 216B.2422 and Minn. Rules Chapter 7843.Minnesota Power’s 2015 Plan is the next chapter in the Company’s EnergyForwardresource strategy. Minnesota Power’s EnergyForward strategy is reshaping the Company’spower supply from a predominantly coal-based energy mix to one that is more diverse, whilemaintaining low cost, reliable electricity to customers. The Plan is designed to supply MinnesotaPower customers with a safe, reliable, and affordable power supply while improvingenvironmental performance, reducing emissions, sustaining the Company’s high-quality energyconservation program and adding renewables in the near-term and natural gas in the long-term.Minnesota Power’s short-term action plan during the five-year period of 2015 through 2019 iscomprised of steps that will: a) preserve competitive base load generating resources whilereducing emissions, b) increase implementation of least-cost demand-side resources includingconservation, c) reduce reliance on coal-fired generation, and d) add renewable energy andtransmission infrastructure to the benefit of customers. The Company’s long term strategy willfocus on further reducing carbon emissions in its portfolio and reshaping its generation mixtowards a balance of approximately one-third renewable resources, one-third efficient coal-firedgeneration and one-third natural gas/other sources. This long-term strategy will position theCompany so it can successfully adapt to a range of economic and environmental futures whilemaintaining service to its customers at a competitive cost.30 West Superior Street Duluth, Minnesota 55802-2093 218-722-2625 www.mnpower.com

Mr. WolfSeptember 1, 2015Page 2The 2015 Plan is organized into six sections with supporting appendices as presented inthe Table of Contents. The supporting appendices contain in-depth information and, asappropriate, specific responses to the Order dated November 12, 2013, including all agreed-toactions by Minnesota Power.Certain portions of the Plan contain trade secret information and are marked as such,pursuant to the Commission’s Revised Procedures for Handling Trade Secret and PrivilegedData, which procedures further the intent of Minn. Stat. § 13.37 and Minn. Rule 7829.0500. Asrequired by the Commission’s Revised Procedures, a statement providing the justification forexcising the Trade Secret Data is attached to this letter.As reflected in the attached Affidavit of Service, the Executive Summary has been filedon the official general service list utilized by Minnesota Power as well as the 2013 IntegratedResource Plan service list.Please contact me at the number or the email address provided if you have anyquestions.Yours truly,Lori HoyumLH:srAttach.cc: Service List

STATEMENT REGARDING JUSTIFICATION FOR EXCISINGTRADE SECRET INFORMATIONPursuant to the Commission’s revised Procedures for Handling Trade Secret andPrivileged Data in furtherance of the intent of Minn. Stat. § 13.37 and Minn. Rule7829.0500, Minnesota Power has designated portions of its attached 2015 IntegratedResource Plan (“Plan”) as Trade Secret.Minnesota Power is requesting approval of its Plan under Minn. Stat. § 216B.2422 andMinn. Rules Chapter 7843. Minnesota Power has removed certain information from thePlan to prevent disclosure of Minnesota Power’s information regarding its methods,techniques, and process for identifying, obtaining, managing, and comparing variousresources. This is highly confidential information; Minnesota Power’s competitors, aswell as its potential suppliers, would gain a commercial advantage over MinnesotaPower if this information were publicly available. Minnesota Power follows strict internalprocedures to maintain the secrecy of this information in order to capitalize on economicvalue of the information to Minnesota Power. As a result of public availability, MinnesotaPower and its customers would suffer in providing resources to its retail load. MinnesotaPower respectfully requests the opportunity to provide additional justification in theevent of a challenge to the trade secret designation provided herein.

First NameLast NameEmailAddressDelivery MethodView Trade SecretService List NameJuliaAndersonJulia.Anderson@ag.state.m Office of the Attorneyn.usGeneral-DOCCompany Name1800 BRM Tower445 Minnesota StSt. Paul,MN551012134Electronic ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListChristopherAndersoncanderson@allete.com30 W Superior StElectronic ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListMinnesota PowerDuluth,MN558022191William A.Blazarbblazar@mnchamber.comMinnesota Chamber OfCommerceSuite 1500400 Robert Street NorthSt. Paul,MN55101Electronic ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListJonBrekkejbrekke@grenergy.comGreat River Energy12300 Elm CreekBoulevardElectronic ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListElectronic ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListElectronic ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListElectronic ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListElectronic ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListElectronic ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListElectronic ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListMaple comFredrikson Byron200 S 6th St Ste lete.comMinnesota Power30 W Superior e.mn Department of Commerce.us85 7th Place E Ste 500Saint state.mn.usMN Department ofAgriculture625 North Robert StreetSt. nce32 Lawton StSaint Paul,MN55102BenjaminGerberbgerber@mnchamber.com Minnesota Chamber ofCommerce400 Robert Street NorthSuite 1500St. Paul,Minnesota551011

First NameLast allia Interstate Power and Lightntenergy.comCompanyCompany NameAddressDelivery MethodView Trade SecretService List Name4902 N. Biltmore LaneElectronic ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListMadison,WI53718JaniceHallN/ACook County Board ofCommissioners411 W 2nd StCourt HouseGrand Marais,MN55604-2307Paper ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListLoriHoyumlhoyum@mnpower.comMinnesota Power30 West Superior StreetElectronic ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListPaper ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListDuluth,MN55802PaulJamesN/ATown of ToftePO Box 2293Tofte,MN55615EricJensenejensen@iwla.orgIzaak Walton League ofAmericaSuite 2021619 Dayton AvenueSt. Paul,MN55104Electronic ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListMichaelKrikavamkrikava@briggs.comBriggs And Morgan, P.A.2200 IDS Center80 S 8th StMinneapolis,MN55402Electronic ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListJohnLindellagorud.ecf@ag.state.mn.us Office of the AttorneyGeneral-RUD1400 BRM Tower445 Minnesota StSt. Paul,MN551012130Electronic ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListChad TMarriottctmarriott@stoel.com900 SW 5th Ave Ste 2600Electronic ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListElectronic ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListElectronic ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListStoel Rives nergy CENTS Coalition823 7th St ESt. ba Hydro360 Portage Ave FL 16PO Box 815, Station MainWinnipeg,ManitobaR3C 2P4Canada2

First NameLast NameEmailCompany NameAddressDelivery MethodView Trade SecretService List NameMarion AnnMcKeeverN/ASatellites Country Inn9436 W Hwy 61Paper ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListElectronic ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListElectronic ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service omMinnesota Power30 W Superior .comStoel Rives LLP33 South Sixth StreetSuite 4200Minneapolis,MN55402David W.Nilesdavid.niles@avantenergy.c Minnesota Municipal Power Suite 300omAgency200 South Sixth StreetMinneapolis,MN55402Electronic ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListThomas L.OsteraasN/APaper ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListExcelsior Energy150 South 5th Street Suite2300Minneapolis,MN55402BrittSee BenesN/ACity of Aurora16 W 2nd Ave NPO Box 160Aurura,MN55705Paper ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListRonSpangler, Jr.rlspangler@otpco.comOtter Tail Power Company215 So. Cascade St.PO Box 496Fergus Falls,MN565380496Electronic ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListJohn LincStinejohn.stine@state.mn.usMN Pollution ControlAgency520 Lafayette RdElectronic ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListElectronic ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListElectronic ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service ListSaint op Weinstine225 S 6th St Ste 3500Capella TowerMinneapolis,MN554024629Daniel PWolfdan.wolf@state.mn.usPublic Utilities Commission 121 7th Place EastSuite 350St. Paul,MN5510121473

First NameLast NameEmailCompany NameAddressDelivery MethodView Trade SecretService List t ofTransportationMN Dept of Transportation395 John Ireland BlvdSt. Paul,MN55155Electronic ServiceNoGEN SL MinnesotaPower IntegratedResource Plan Service List4

MINNESOTA POWER 2015 RESOURCE PLANPETITION FOR APPROVALSeptember 1, 2015Docket No. E015/RP-15-690Minnesota Power’s 2015 Integrated Resource Plan

TABLE OF CONTENTSI.About Minnesota Power . 1II.2015 Resource Plan . 3Key Items Shaping the Plan . 5Integrated Resource Plan Process Streamlining . 6Creating a More Flexible and Diverse Fleet . 7Wisely Planning for Growth and Inherent Business Cycles . 7Sound Coal Unit Direction . 7Competitive Renewable Supply Ahead of RES Target . 8Solar Energy Strategy Launch . 9Expanding Potential for Energy Efficiency and Distributed Generation ("DG") . 9Natural Gas Additions and Market Purchases: Well-timed toOptimize Opportunities . 10Technological Evolution . 10Updates Since the Last Approved Minnesota Power Resource Plan . 11Resource Plan Overview: Short and Long-term Action Plans . 14Short-term Action Plan (2015 through 2019) . 14Long-term Action Plan (2020 through 2029) . 15Plan Implementation Potential Impacts on Costs . 16Summary: 2015 Plan Designed to Meet Customer Needs. 16III. Current Outlook . 18Changes Since November 2013 Commission Approval of the 2013 Plan . 18Current Outlook for Large Power and Resale Customers . 21Expected Minnesota Power Load and Capability . 25Base Case . 28High and Low Sensitivities for Demand and Energy . 32Annual Electric Utility Forecast Report ("AFR2015") Outlook Demand and Energy . 34IV. 2015 Plan Development . 35Evaluation Framework . 35Handling Uncertainty . 39Analysis Process . 40Coal-fired Generation Considerations . 43Conclusions for Small Coal . 55Alternative Swim Lanes for Small Coal Generation . 56Expansion Planning for New Generation Resources . 57Developing the Preferred Plan . 59Natural Gas . 62Minnesota Power’s 2015 Integrated Resource PlanTable of ContentsPage i

Wind Generation . 63Bilateral Bridge Transactions . 63Solar Generation . 64Demand-side Management . 66Distributed Generation Programs . 67Energy Efficiency . 67Characteristics of Minnesota Power's Preferred Plan . 69Customer Cost Impact of Preferred Plan . 75Analysis and Insights – Comparison of Preferred Plan to “Swim Lane”Alternatives and Sensitivity Analysis . 80V.Short-term Action Plan . 86Plans to Meet Short-term Need (2015 through 2019) . 86Four Key Contingencies . 88VI. Long-term Action Plan . 89Plans to Meet Long-term Need (2019 through 2029) . 89Table of FiguresFigure 1: US Paper Demand 2006-2007 . 24Figure 2: Peak Demand by Season. 26Figure 3: Energy by Customer Class. 26Figure 4: Projected Summer Season Capacity Position. 28Figure 5: Base Case Summer Season Load and Capability . 30Figure 6: Base Case Winter Load and Capability. 31Figure 7: Base Case Energy Position. 32Figure 8: High and Low Demand Outlook Sensitivities . 33Figure 9: High and Low Energy Outlook Sensitivities. 33Figure 10: High and Low Demand Outlook Sensitivities with AFR2015 . 34Figure 11: Plan Development Process - Steps 1 and 2. 42Figure 12: Plan Development Process – Steps 3 and 4 . 43Figure 13: BEC1&2 Levelized Product Cost as Varying Capacity Factors with NoCO2 Regulation Penalty . 47Figure 14: BEC1&2 Levelized Product Cost as Varying Capacity Factors with 21.50/ton CO2 Regulation Penalty. 47Figure 15: THEC1&2 Levelized Product Cost as Varying Capacity Factors with NoCO2 Regulation Penalty . 51Minnesota Power’s 2015 Integrated Resource PlanTable of ContentsPage ii

Figure 16: THEC1&2 Levelized Product Cost as Varying Capacity Factors with 21.50/ton CO2 Regulation Penalty. 52Figure 17: Minnesota Power Preferred Plan for Small-coal Fleet . 55Figure 18: Coal Strategy for Preferred Plan for Small-coal Fleet . 56Figure 19: Updated Summer Season Capacity Position with Preferred Coal Strategy(No New resource Additions) . 60Figure 20: Minnesota Power’s Solar Resources to Fulfill Solar Energy Standard . 65Figure 21: Preferred Plan Summer Season Capacity Outlook . 70Figure 22: Preferred Plan Energy Position Outlook. 71Figure 23: Preferred Plan Power Supply Mix 2025 . 71Figure 24: Emissions Reductions Achieved and Projected with Preferred Plan . 72Figure 25: Mercury Emission Reductions Achieved and Projected with Preferred Plan . 73Figure 26: SO2 Reductions Achieved with Preferred Plan. 73Figure 27: Greenhouse Emission Reductions Achieved with Preferred Plan . 75Figure 28: Average Retail Rate Recent History and Outlook with Preferred Plan . 76Figure 29: Estimated Rate Impact Outlook by Customer Class . 77Figure 30: Regional and National Comparison of Residential Electric Rates in 2014 . 78Figure 31: Regional and National Comparison of Commercial Electric Rates in 2014 . 78Figure 32: Regional and National Comparison of Industrial Electric Rates in 2014 . 79Table of TablesTable 1:Minnesota Power Taconite Customer production . 22Table 2:BEC1&2 Results from Step 2 Analysis “Detailed Coal Analysis” . 48Table 3:THEC1&2 Results from Step 2 Analysis “Detailed Coal Analysis” . 53Table 4:Power Supply Cost Comparison Between Idle in 2017 and Shutdown in 2019 . 54Table 5:Expansion Plan Results for New Resource Additions with Preferred Plan . 61Table 6:Incremental Energy Efficiency Programs First Year Cost Levelized OverLife of Programs . 68Table 7:Overview of Preferred Plan and Swim Lane Alternatives . 81Table 8:Step 4 Sensitivities Analysis: 2015 NPV of Alternative Cost with Sensitivities . 83Table 9:Step 4 Sensitivities Analysis with 21.50/ton CO2 Regulation Penalty asBase Assumption: 2015 NPV of Alternative Cost with Sensitivities . 84Table of AppendicesAppendix A:Minnesota Power’s 2014 Annual Electric Utility Forecast ReportAppendix B:Demand Side Management (DSM)Appendix C:Existing Power SupplyMinnesota Power’s 2015 Integrated Resource PlanTable of ContentsPage iii

Appendix D:Future Resource OptionsAppendix E:Environmental Policy and Compliance AssessmentAppendix F:Transmission Planning ActivitiesAppendix G:Distribution PlanningAppendix H:Minnesota’s Renewable EnergyAppendix I:RES Rate Impact AnalysisAppendix J:Assumptions and OutlooksAppendix K:Detailed Analysis SectionAppendix L:Cost Impact Analysis by Customer ClassAppendix M: Socioeconomic Impact AnalysisAppendix N:Minnesota Power Plan Cross Reference IndexAppendix O:List of Acronyms, Terms and DescriptionMinnesota Power’s 2015 Integrated Resource PlanTable of ContentsPage iv

I. ABOUT MINNESOTA POWERMinnesota Power is transforming the way it energizes communities and businesses througha resource strategy called EnergyForward. The company that was founded as a hydroelectricutility in 1906 and grew to serve its unique customer mix with predominantly coal energy isrebalancing its generation mix by bringing more renewable power to customers while reducingits dependence on fossil fuel. EnergyForward will bring Minnesota Power to an energy mix ofone-third coal, one-third natural gas, and one-third renewables.A division of ALLETE, Inc., Minnesota Power (or “Company”) serves about 144,000 retailelectric customers and 16 municipal systems across a 26,000-square-mile service area incentral and northeastern Minnesota. ALLETE subsidiary Superior Water, Light and Powerprovides electricity to 15,000 customers, natural gas to 12,000 customers and water services to10,000 customers in northwestern Wisconsin.In 2014, 54 percent of Minnesota Power’s kilowatt-hour (“kwh”) sales served large powercustomers, primarily in the taconite mining, iron concentrate, paper, pulp, refining and pipelineindustries. Many of these industrial customers operate 24/7, which gives the utility a unique highload factor featuring a power supply with less variation in demand than most utilities.Minnesota Power has 10 Large Power customer contracts, each serving at least 10megawatts (“MW”) of load: five taconite producing facilities (two are owned by one company),one concentrate reclamation plant, one iron nugget producer and four paper and pulp mills. Theprocessing of taconite, an iron-bearing rock used to make steel, requires large quantities ofelectric power. Two additional large power customers expected to be operating soon will also bereceiving energy from Minnesota Power: PolyMet, a nonferrous mining operation awaiting finalpermitting, and Essar Steel Minnesota, a major taconite mine and processing plant now underconstruction. Essar, scheduled to begin producing taconite next year, obtains its electricity fromthe city of Nashwauk, which is served as a wholesale municipal customer. The Company alsopowers four wood products manufacturers and provides electric service to two crude oilpipelines and a refinery via contract through affiliate Superior Water, Light and Power Company.In part because of its high concentration of large customers and relatively low proportion ofresidential customers, Minnesota Power is expected to remain a winter-peaking utility for theforeseeable future. Minnesota Power’s electric load reached an all-time peak of 1,817 MW onDecember 30, 2015.Minnesota Power produces the majority of its electricity from coal-fired generation units,supplemented by a long-term purchase from Square Butte’s Milton R. Young 2 (“Young 2”)lignite coal generating station in North Dakota. The Company’s execution of EnergyForward issystematically lowering the ratio of coal used to produce energy at Minnesota Power anddramatically lowering emissions from the baseload coal units that remain. In February 2015, thelast trainload of coal was unloaded at the Laskin Energy Center (“LEC” or “Laskin”). In theweeks following, the Laskin plant was converted to use cleaner-burning natural gas. In June2015, Minnesota Power’s coal-fired Taconite Harbor Energy Center Unit 3 (“THEC3”) ceasedgeneration 48 years after it began operation. The percentage of coal-based generation on theMinnesota Power system has declined from about 95 percent in 2005 to approximately 75percent today. Additionally, major emission reduction projects at Boswell Energy Center Units 3and 4, the two largest coal generators remaining on Minnesota Power the system, areMinnesota Power’s 2015 Integrated Resource PlanSection I. About Minnesota PowerPage 1

contributing to the Company’s significantly lower emission profile. A major environmental retrofitwas completed at Boswell Energy Center Unit 3 (“BEC3”) in 2009. Work is expected to becompleted later this year on a mercury emissions reduction project at Boswell Energy CenterUnit 4 (“BEC4”) that will reduce emission of mercury approximately 90 percent and also reducelevels of particulates and sulfur dioxide.Over the past decade, the Company has undertaken a systematic effort to increase itsdeployment of renewable energy. In 2006 and 2007, Minnesota Power began purchasing theentire output of the Oliver 1 and Oliver 2 wind farms built in North Dakota by NextEra Energy. In2008, Minnesota Power constructed Taconite Ridge, the first commercial wind generatingstation in northern Minnesota. The Bison Wind Energy Center (“Bison”) in North Dakota camenext, with four phases of the project completed between 2010 and 2014. Bison, now the largestwind farm in North Dakota with just under 500 MW, leverages a premier wind resource to delivercarbon-free energy to customers of Minnesota Power. Combined, these wind projects addedmore than 600 MW of renewable electricity to the Company’s generation portfolio.As the state’s largest producer of hydroelectric power with 10 federally licensed facilities,Minnesota Power is well versed in the power potential of water. Late last year MinnesotaPower’s Thomson Hydroelectric Station on the St. Louis River was returned to service 28months after a devastating flood breached a forebay canal and swamped the 107-year-oldrenewable energy facility, knocking it offline. Repair and refurbishment of other Company hydrofacilities, including work at Fond du Lac, Little Falls, Winton, Prairie River and Birch Lake, werecommemorated in a series of “Hometown Hydropower” events last summer. In 2011 and 2014,the Company signed 15 and 20-year agreements to buy 383 MW of carbon-free hydroelectricityfrom Manitoba Hydro beginning in 2020. Minnesota Power is planning the construction of theGreat Northern Transmission Line (“GNTL”) to carry this Canadian hydropower to the heart ofits industrial base on the Iron Range of Minnesota.As an integral part of EnergyForward, Minnesota Power is further diversifying its renewableenergy options to include solar energy generation. The Company is working with the MinnesotaNational Guard to build a 10 MW solar energy project on the grounds of Camp Ripley near LittleFalls, Minn. The Camp Ripley Solar Project will be the largest solar energy installation at anyNational Guard base in the U.S., covering nearly 80 acres with photovoltaic panels.Minnesota Power has used imagination and innovation in rebalancing its generation fleet.Young 2, a major source of coal-based generation, is being phased out of the Company’sresource mix as this coal generation resource is replaced by wind energy. Minnesota Power in2009 purchased a 465-mile direct current transmission line (“DC Line”) linking Young 2 in NorthDakota with Duluth Minn. It was built 30 years earlier to transport “coal by wire” from Young 2 toMinnesota Power. The lignite-fueled energy will eventually be replaced on that DC Line withrenewable wind power flowing from the Bison Wind Energy Center, delivering “wind by wire.” Acreative provision of Minnesota Power’s energy purchases from Manitoba Hydro will allow theCompany to “store” North Dakota wind energy within the Canadian hydroelectric system.Minnesota Power is bringing EnergyForward, dedicated to creating a reasonable balanceof energy generation that is depe

7829.0500, Minnesota Power has designated portions of its attached 2015 Integrated Resource Plan ("Plan") as Trade Secret. Minnesota Power is requesting approval of its Plan under Minn. Stat. § 216B.2422 and Minn. Rules Chapter 7843. Minnesota Power has removed certain information from the