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STATE OF ILLINOISILLINOIS COMMERCE COMMISSIONILLINOIS BELL TELPHONE COMPANYPetitionerV.Docket No. 01-0078COMMONWEALTH EDISON COMPANYRespondentComplaint regarding wrongful rehsal toprovide customer-specific customer transitioncharges pursuant to Section 10-108 of thePublic Utility Act:Direct Testimony ofWILLIAM VOLLERGroup Manager for Mid-Size Businessand Multi-Site MarketsCommonwealth Edison Company

Docket No. 01-0078ComEdEx.-Voller Direct TestimonyPage 1 of71Q-Please state your name and business address.2A.My name is William Voller. My business address is 3 Lincoln Center, Oak BrookTerrace, Illinois 60181-4260.34Q-By whom are you employed and in what capacity?5A.I am employed by Commonwealth Edison Company as the Group Manager forMid-Size Business and Multi-Site Markets.67Q-Business and Multi-Site Markets.89Please describe your responsibilities as Group Manager for Mid-SizeA.My responsibilities include oversight of the accounts of ComEd's mid-size10business and multi-site customers. In this role, I have responsibility for the11Ameritech account.12Q.When did you commence that role?13A.January 1999.14Q.Please describe your background and experience prior to assuming the roleof Group Manager for Mid-Size Business and Multi-Site Markets.1516A.I began my career with ComEd in 1974. Since then, I have held a variety of sales17and marketing positions within the Company. I initially served as an account18manager in several geographic areas and, in 1983, I became the Sales Supervisor19in the Northwest Area. In 1985, I became the Superintendent of Sales Services20and in 1991 began to serve as the Area Manager for the Joliet Region. I then21served in various management position within the Energy Services Organization22(ESO). In 1999, I became the General Manager for the Mid-Size and Multi-Site23Market. Prior to joining ComEd, I graduated from the University of Notre Dame

Docket No. 01-0078ComEd Ex.-Voller Direct TestimonyPage 2 of 71with a Bachelor of Sciences in Mechanical Engineering. While employed with2ComEd, I obtained an MBA from Dominican University in 1982.3Q.What is the purpose of your testimony?4A.My testimony addresses two areas. First, I discuss the Electric Service Contract5(the “Contract”) between Ameritech and ComEd. Specifically, I outline the6number of locations recognized and served under the provisions of the Contract.7As discussed further, I explain that during the course of the Contract term only 578locations were recognized as eligible locations under the Contract at different9times. Second, I discuss the November 29, 1999 meeting between Ameritech and10ComEd regarding its request for a customer-specific customer transition charge11(CTC). As I attended that meeting, I provide a summary of the discussion at the12meeting and a more complete explanation as to why ComEd declined to provide13Ameritech with a customer-specific CTC than was provided in Mr. Ragland’s14testimony on Amentech’s behalf.15Q.and ComEd?1617Please describe generally the contractual relationship between AmeritechA.In 1997, Ameritech and ComEd entered into a Contract under which Ameritech18would curtail its electric load from time to time at ComEd’s request pursuant to19Rider 32. At the time the Contract was executed, Ameritech identified 2220locations that would participate in the curtailment program under the provisions21of the Contract. Those 22 locations were specified in Exhibit A to the Contract.22The Contract also allowed Ameritech to amend Exhibit A to add or delete23locations. To do so, Ameritech needed to provide written notice to ComEd’s

Docket No. 01-0078ComEd Ex.Voller Direct TestimonyPage 3 of71Director of Rates with a copy to ComEd’s Manager of Retail Services as specified2in Exhibit A and provided for in the Notice section of the Contract.3Q-Did Ameritech ever provide ComEd’s Director of Rates or Manager of Retail4Services with written notice of any changes in the locations under the5Contract?6A.No.7Q.Did Ameritech ever otherwise attempt to add facilities as Mr. Ragland claimson page 8 of his direct testimony?89A.Yes.ioQ.How did Ameritech add those facilities to the Contract?11A.Prior to each curtailment season, Ameritech would send its ComEd account team12a list identifying the locations that it sought to add to or remove from the13Contract. Johnson Controls, on Ameritech’s behalf, sent ComEd the lists until142000 when Ameritech merged with SBC. After the merger, ComEd did not15receive any additional lists from Ameritech or Johnson Controls.16Ameritech did not send these lists to the Director of Rates or the Manager of17Retail Services as required by the Contract, ComEd accepted these changes,18treated these locations as having been properly added to the Contract by19Ameritech, and recognized those locations as eligible for curtailment payments20under the Rider 32 provisions of the Contract.While21Q.How many locations did Ameritech add to the Contract in this manner?22A.As I mentioned, the original Exhibit A to the Contract identified 22 locations. In231998, Ameritech added 28 locations to the Contract for a total of 50 locations. I

Docket No. 01-0078CornEd Ex.Voller Direct TestimonyPage 4 of 71have attached to my testimony as Exhibit 1 a true and correct copy of the list of2locations sent by Johnson Controls to ComEd on May 15, 1998.3Q.Were any locations removed from the contract in 1998?4A.No.5Q.Were any locations added to the contract in 1999?6A.Yes. As in 1998, Johnson Controls sent ComEd a list of locations for inclusion7under Contract in 1999. The list added 7 locations to the Contract. I have8attached to my exhibit as Exhibit 2 a true and correct copy of the list received9from Johnson Controls on May 3, 1999.10Q.Johnson Controls?1112Were any locations removed from the Contract in 1999 by Ameritech orA.Yes. The list sent by Johnson Controls in 1999 did not include 6 locations that13had been identified on the 1998 list. With the 1999 additions and deletions, there14were a total of 51 locations recognized as eligible in 1999 for curtailment15payments under the Rider 32 provisions of the Contract. This May 1999 list16would have been the applicable list of locations had Ameritech terminated its17Contract with ComEd in December 1999 and elected service under Rate RCDS18and Rider PPO going forward.19Q.Are you familiar with Mr. Ragland’s direct testimony?20A.Yes, I have reviewed Mr. Ragland’s testimony.21Q.Have you reviewed Exhibit 1.4 to Mr. Ragland’s direct testimony that Mr.22Ragland claims identifies the 126 Ameritech facilities currently served by the23Contract?

Docket No. 01-0078ComEd Ex.Voller Direct TestimonyPage 5 of 7IA.Yes, I have.2Q.Have you ever seen a document from Ameritech o r Johnson Controlsidentifying these 126 facilities prior to reviewing Mr. Ragland’s testimony?34A.No, not all 126 facilities. As I mentioned, Johnson Controls, on Ameritech’s5behalf, revised the locations to be served under the Contract by sending ComEd a6list prior to the curtailment season. However, Ameritech never designated more7than 57 locations over the life of the contract as eligible for curtailment payments8under the Rider 32 provisions of the Contract. Mr. Ragland’s exhibit, therefore,9contains 69 locations that have never been served and recognized under theUntil I reviewed Mr. Ragland’s testimony, I had not seen any10Contract.11documents from Ameritech or Johnson Controls including those 69 additional12locations.13Q.Has ComEd called upon Ameritech to curtail under the contract at any ofthese 69 unrecognized locations?14ISA.No.16Q.Are you familiar with the payments to Ameritech for curtailment under theContract?1718A.Yes.19Q.Would you specify the amounts that ComEd paid Ameritech for curtailmentin each year of the Contract?2021A.In 1998, ComEd paid Ameritech 358,558 for curtailment pursuant to the22Contract. In 1999, ComEd paid 304,394.74. In 2000, ComEd paid Ameritech23 318,635.72. The most recent payment in 2001 totaled 263,701.99.

Docket No. 01-0078ComEdEx.-Voller Direct TestimonyPage 6 of71Q-ComEd referred to on page 11 of Mr. Ragland’s testimony?23Do you have any knowledge of the 1999 meeting between Ameritech andA.Yes, I attended that meeting on November 29, 1999. Mr. Ragland mistakenly4states that the meeting occurred in December 1999; in fact the meeting occurred5on November 29.1999.6Q.Who was present at the meeting?7A.Ameritech requested the meeting and specifically requested that Frank Jiruska,8ComEd’s Vice President of Energy Services, attend. In addition to Mr. Jiruska,9several members of the ComEd team responsible for Ameritech’s account were10present, including Arthur Barsema, Director, Energy Services; myself; Maureen11Anton, Segment Manager; and Delso Hudson, Account Manager. Mr. Ragland12attended on Ameritech’s behalf along with Jim Karrels, Ameritech’s Regional13Infrastructure Manager.14Q.specific transition charges as it requested?1516Did ComEd explain why it was unable to provide Ameritech with customerA.Yes. Before the meeting, Mr. Lawrence Alongi, ComEd’s Director of Rates, had17sent Mr. Karrels a letter dated November 3, 1999 explaining that customerI8specific CTCs calculations were inappropriate as the contract does not contain19charges for electric service specific to the Ameritech locations. A copy of this20letter is attached to Mr. Geraghty’s testimony as Exhibit F. In other words, as21ComEd explained to Ameritech in Mr. Alongi’s letter and again at that meeting,22Ameritech’s contract simply makes Rider 32 available to Ameritech’s designated23locations and provides for fewer points of notification than would otherwise be

Docket No. 01-0078ComEdEx.-Voller Direct TestimonyPage 7 o f 71required for purposes of implementing curtailments under Rider 32. As such, the2charges for electric service under Ameritech’s Contract do not deviate from3CornEd’s standard tariffed rates and therefore the Contract does not constitute a4“customer specific electric service contract” as Mr. Geraghty explains in more5detail in his testimony on ComEd’s behalf. Because Ameritech did not have a6“customer specific electric service contract,” it was not, and is not, entitled to a7customer-specific CTC calculation. ComEd explained this to Ameritech through8Mr. Alongi’s November 3, 1999 letter and again at the November 29, 19999meeting.ioQ.Has ComEd ever changed its position as to why it is unable to provide11Ameritech with a customer-specific CTC for the locations served by the12Contract as Mr. Ragland claims on page 14 of his testimony?13A.No.ComEd has consistently advised Ameritech that it could not provide14Ameritech with a customer-specific CTC because Ameritech lacked a “customer15specific electric service contract.” When Ameritech sought further clarification,16ComEd consistently advised Ameritech that it did not have a “customer specific”17contract because it had a contract that simply made available Rider 32 curtailment18payments to eligible locations without any discounts or reductions from ComEd’s19standard base rates for those locations.20position twice in November 1999 and has reiterated it since. There simply has not21been any change in ComEd’s position regarding this matter.22Q.Does this conclude your testimony?23A.Yes, it does.ComEd advised Ameritech of this

.Johnson Controls, lnc.To: Mike Franklin I NancyCompany:Company: Johnson Controls, Inc.Xme: 1 1:41AMPages Includingcover:2Notes: Nancy, here is the list of Ameritech buildings that we need added tthe Rider 32 contract. Please find the high demands for each and pleaseget that info back to me.CraigtCreatedusing PROCOMM PLUS 2.0 forwndcm1

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