OF MICHIGAN STATE. Hearing. filed. Sincerely, SAS:tlb Atts. Parties of Record 17302/Ltr

Transcription

1 STATE OF MICHIGAN DEPARTMENT OF ATTORNEYY GENERAL 0 MERCANTILE WAY, STE. LANSING, MICHIGAN BILLL SCHUETTEE ATTORNEY GENERAL September, 0 Ms. Mary Jo Kunkle Executive Secretary Michigan Public Service Commission 00 W. Saginaw Hwy. P.O. Box 0 Lansing, Michigan 0 Dear Ms. Kunkle: Re: MPSC Case No. U-0 Staff is filing the attached Motion to Supplement and Revise Staff witness Jesse Harlow s Pre-filed Direct Testimony together with a redlined version of the amended testimony and a clean copy. Staff is also filing the attached Notice of Hearing. filed. Ms. Julie Baldwin s testimony remains unchanged and is not revised or re- Sincerely, Spencer A. Sattler (P0) Assistant Attorney General Public Servicee Division Telephone: () -0 SAS:tlb Atts. c: ALJ Theresa A. Sheets Parties of Record 0/Ltr

2 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the matter, on the Commission s own Motion, regarding the regulatory reviews, revisions, Case No. U-0 determinations, and/or approvals necessary for (e-file paperless) DTE ELECTRIC COMPANY f/k/a THE DETROIT EDISON COMPANY to fully comply with Public Acts and of 00. / TO: Counsel of Record NOTICE OF HEARING PLEASE TAKE NOTICE that the Michigan Public Service Commission Staff's Motion to Supplement and Revise Testimony will be brought on for hearing before Administrative Law Judge Theresa A. Sheets on September 0, 0 at :00 a.m. (or as soon thereafter as the parties may be heard). Respectfully submitted, MICHIGAN PUBLIC SERVICE COMMISSION STAFF Dated: September, 0 0/Mot to Supplement (NOH) Spencer A. Sattler (P0) Assistant Attorney General Public Service Division 0 Mercantile Way, Suite Lansing, MI Telephone: () -0

3 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the matter, on the Commission s own Motion, regarding the regulatory reviews, revisions, Case No. U-0 determinations, and/or approvals necessary for (e-file paperless) DTE ELECTRIC COMPANY f/k/a THE DETROIT EDISON COMPANY to fully comply with Public Acts and of 00. / MICHIGAN PUBLIC SERVICE COMMISSION STAFF S MOTION TO SUPPLEMENT AND REVISE TESTIMONY The Michigan Public Service Commission Staff moves to supplement and revise its testimony in accordance with Rule of the Commission s Rules of Practice and Procedure. 0 AC; R 0.. In support of its Motion, Staff states the following:. On August, 0, Staff filed direct testimony for two expert witnesses according to the schedule set by the presiding Administration Law Judge in this case.. Upon further review of the testimony it filed, Staff has decided to revise and supplement Mr. Jesse Harlow s testimony to clarify and complete certain statements.. Staff s proposed revisions do not substantially change its recommendations; the changes are primarily intended to add clarity.. Staff's revised and supplemental testimony does not prejudice any party to this proceeding. Staff is filing its revised and supplemental testimony before the time scheduled for rebuttal testimony, so parties

4 will have an opportunity to respond to Staff s amended testimony in the normal course of this proceeding.. Should any party require additional time to file rebuttal as a result of Staff s changes, Staff will not object to a reasonable extension.. For the ALJ s and the parties convenience, Staff is also filing a Notice of Hearing providing, on a preliminary basis, for a suggested hearing date on this Motion that corresponds with the date and time set to begin cross examination namely, September 0, 0 at :00 a.m. WHEREFORE, Staff moves that the ALJ grant this Motion and permit Staff to supplement and revise Mr. Harlow s testimony. Respectfully submitted, MICHIGAN PUBLIC SERVICE COMMISSION STAFF Dated: September, 0 0/Mot to Supplement Spencer A. Sattler (P0) Assistant Attorney General Public Service Division 0 Mercantile Way, Suite Lansing, MI Telephone: () -0

5 S T A T E OF M I C H I G A N BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION * * * * In the matter, on the Commission s own motion, regarding the regulatory reviews, ) revisions, determinations, and/or ) Case No. U- 0 approvals necessary for The Detroit ) Edison Company to fully comply with ) Public Acts and of 00 ) ) QUALIFICATIONS AND REVISED DIRECT TESTIMONY OF JESSE J. HARLOW MICHIGAN PUBLIC SERVICE COMMISSION September, 0August, 0

6 QUALIFICATIONS OF JESSE J. HARLOW CASE NUMBER U-0 PART I 0 0 Q. Please state your full name, business address and occupation. A. My name is Jesse J. Harlow and my business address is Mercantile Way, Lansing, MI. My temporary business address is 00 West Saginaw, Lansing, MI. I am employed as a public utilities engineer in the Renewable Energy Section of the Electric Reliability Division at the Michigan Public Service Commission (MPSC or Commission). Q. Please describe your educational background. A. In 00 I earned a Bachelors of Science in Engineering from Michigan State University. Prior to my course work at Michigan State University, I was in an engineering transfer program at Lansing Community College where I was a member of the Phi Theta Kappa honor society. Q. What is your professional work experience? A. I have worked for the Commission since 00. From 00 until 00, I worked in the Energy Grants Section of the Motor Carrier, Energy Grants and Information Division. My primary responsibility was for award selection and administration of Michigan Energy Efficiency (MIEE) grants. MIEE grants made up approximately % of the total allocations from the more than $0 Million per year Low-Income and Energy Efficiency Fund. In the later part of 00, I was transferred into the Renewable Energy Section and became involved in the implementation of 00 PA (Act), focusing on electric provider s Renewable Energy Plan filings.

7 QUALIFICATIONS OF JESSE J. HARLOW CASE NUMBER U-0 PART I 0 0 Q. Have you had any other training that is relevant to your testimony? A. Yes, In 00 I attended the Institute of Public Utilities Regulatory Studies Program, a two-week program with course work designed to educate regulatory professionals. In 00, I attended the Institute of Public Utilities Advanced Regulatory Studies Program. In 0, I attended courses in both the Institute of Public Utilities Regulatory Studies Program and the Institute of Public Utilities Advanced Regulatory Studies Program. To stay abreast with the rapidly growing and evolving field of renewable energy, I have attended and continue to attend various renewable energy related seminars and conferences. I have also presented at a number of these events and others on renewable energy and 00 PA related issues. Q. Have you filed testimony or rebuttal testimony in any other cases? A. I have filed testimony and/or rebuttal testimony in the following cases: U-00 Consumers Energy Company s 00 Renewable Energy Reconciliation on transfer price; U- Detroit Edison Company s 00 Renewable Energy Reconciliation on transfer price; U- Consumers Energy Company s Amended Renewable Energy Plan on the Company s transfer price and solar program; U-0 Alpena Power Company s Biennial Renewable Energy Plan; U- Detroit Edison Company s Amended and Biennial Renewable Energy Plan on the Company s transfer price and solar program;

8 QUALIFICATIONS OF JESSE J. HARLOW CASE NUMBER U-0 PART I 0 U- Wisconsin Electric Power Company s Biennial Renewable Energy Plan on transfer price; U- Wisconsin Electric Power Company s 00 Renewable Energy Reconciliation on transfer price; U-0 Consumers Energy Company s 00 Renewable Energy Reconciliation on the Company s Pre-Act expenditures and transfer price; U-0-R Consumers Energy Company s 00 PSCR on transfer price; U- Consumers Energy Company s Biennial Renewable Energy Plan; U--R Consumers Energy Company s 0 PSCR on transfer price; U- Wisconsin Electric Power Company s 0 Renewable Energy Cost Reconciliation on transfer price; U- Consumers Energy Company s 0 Renewable Energy Cost Reconciliation on transfer price U- Detroit Edison Company s 0 Renewable Energy Cost Reconciliation on transfer price

9 DIRECT TESTIMONY OF JESSE J. HARLOW CASE NUMBER U-0 PART II 0 Q. What is the purpose of your direct testimony? A. The purpose of my direct testimony is to present Staff s recommendations regarding Company witness Angela P. Wojtowicz s requests on page APW, Lines - of her pre-filed testimony. Specifically, the Company has requested the application of transfer prices to certain contracts: U- Transfer Prices proposed for contracts and Company-owned projects submitted to the Commission for approval between July, 0 and the date of this Case filing (i.e., June, 0). And 0 MPSC Staff Transfer Prices proposed for contracts and Company-owned projects submitted to the Commission for approval after the date of this Case filing (i.e., June, 0). Q. Can you please list the renewable contracts and Company-owned projects that the U- Transfer Prices would apply to? A. Yes. The Commission has previously approved these contracts and associated them with U- Transfer Prices: Echo Wind Park Tuscola Wind II Pheasant Run and Pheasant Run II This refers to the transfer price schedule that is the subject of the Company s active 0 renewable cost reconciliation in Case No. U-. This transfer price schedule refers to the 0 MPSC Staff Transfer Price Schedule as filed in Case No. U-00 on March, 0 and proposed by the Company in this case in Exhibit A-. Staff intends to file this transfer price schedule in the Company s 0 renewable cost reconciliation in Case No. U-. The process for developing this transfer price schedule is the result of the Commission s December 0, 0 Order in Case No. U- that required the Company, Staff and interested parties to participate in a technical conference concerning the development of transfer prices.

10 DIRECT TESTIMONY OF JESSE J. HARLOW CASE NUMBER U-0 PART II 0 0 Due to the fact that the Commission has already addressed the transfer price schedules associated with these contracts at the time the contracts were approved, additional approvals are not necessary. Q. Can you please list the renewable contracts and Company-owned projects that the Company has requested to associate with the 0 MPSC Staff Transfer Prices? A. Yes. Big Turtle Wind Farm (contract approval currently under Commission review) Future Company-owned wind build DTE-owned solar Phase (. MW) Q. Please provide background information on when a transfer price schedule is established. A. The transfer price schedule is to be established on a yearly basis in the renewable cost reconciliation. The Commission provided recent direction on transfer price schedules: The Commission supports the Staff s annual filing of its proposed transfer price schedule in Case No. U-00, which will be updated by the Staff each April, and will be available to all utilities for planning purposes from 0 through 0. The Commission will review the transfer price schedule in each reconciliation case. Order in Case No. U-, June, 0, p. Q. For new renewable energy contracts, what transfer price is applicable? A. Typically, Tthe Commission will approves a transfer price for new renewable energy projects in the utility s next renewable energy reconciliation proceeding or

11 DIRECT TESTIMONY OF JESSE J. HARLOW CASE NUMBER U-0 PART II 0 0 subject to final approval of a transfer price schedule proposed in a pending reconciliation proceeding. It is the Commission s practice to approve a transfer price for the project from the most recently approved schedule of transfer prices or from the schedule of transfer prices proposed in a pending reconciliation proceeding (subject to approval). Q. What is the most recently approved schedule of transfer prices for DTE Electric? A. The Commission s December 0, 0 Order in Case No. U- rejected the Company s amended transfer price schedule and required the Company, Staff and interested parties to participate in a technical conference concerning the development of transfer prices. This Order put DTE Electric in a unique situation in which the most recently approved schedule of transfer prices was, and still is, the schedule established in the 00 renewable energy plan. The schedule proposed in the 00 renewable energy plan is now four years old. Q. In light of this, what is your opinion of Ms. Wojtowicz s updated transfer price schedules? A. Utilizing the updated transfer price schedules as proposed by Ms. Wojtowicz will allow the Company to use a transfer price schedule that more closely resembles current long term power purchase agreements for the non-renewable component of the renewable generation and potentially utilize a transfer price schedule that is consistent with the Consumers Energy Company. The Commission s June, 0 Order in Case No. U-(Consumer Energy Company s 0 renewable cost reconciliation) ordered the Company to utilize Staff s transfer price schedule. Staff proposed the same schedule in Case No. U- (DTE Electric Company s 0 renewable cost reconciliation) which is currently pending.

12 DIRECT TESTIMONY OF JESSE J. HARLOW CASE NUMBER U-0 PART II 0 0 Q. What is Staff s recommendation regarding Ms. Wojtowicz s request to utilize the 0 MPSC Staff Transfer Prices for contract filings made after June, 0? A. The 0 MPSC Staff Transfer Prices have not been approved by the Commission. The Commission s June, 0 Order in Consumers Energy s 0 renewable reconciliation case, U-, as noted above, states that the transfer price schedule will be approved in reconciliation cases. Staff recommends that for contract filings made after June, 0, the Company use the transfer price schedule that is approved in DTE Electric s 0 renewable reconciliation case (Case No. U-, due to be filed on August, 0). for contracts submitted after the new transfer price schedule is approved in that case. For contracts submitted before a new transfer price schedule is approved in Case No. U-, Staff recommends that the Company use the transfer prices that Staff proposed in Case No. U- that are pending approval. To calculate the incremental cost of compliance in this case (for planning purposes only), Staff does not object to the Company s proposal to use Staff s 0 Transfer Prices from Case No U- for contract filings made after June, 0 Staff has already filed its 0 MPSC Staff Transfer Prices for informational purposes in U-00 and intends to file them in Case No. U-. Staff supports the use of these transfer prices in this case for purposes of estimating the incremental cost of compliance. Q. Does this conclude your testimony? A. Yes. The Company filed its application in Case No. U- on August 0, 0.

13 S T A T E OF M I C H I G A N BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION * * * * In the matter, on the Commission s own motion, regarding the regulatory reviews, ) revisions, determinations, and/or ) Case No. U- 0 approvals necessary for The Detroit ) Edison Company to fully comply with ) Public Acts and of 00 ) ) QUALIFICATIONS AND REVISED DIRECT TESTIMONY OF JESSE J. HARLOW MICHIGAN PUBLIC SERVICE COMMISSION September, 0

14 QUALIFICATIONS OF JESSE J. HARLOW CASE NUMBER U-0 PART I 0 0 Q. Please state your full name, business address and occupation. A. My name is Jesse J. Harlow and my business address is Mercantile Way, Lansing, MI. My temporary business address is 00 West Saginaw, Lansing, MI. I am employed as a public utilities engineer in the Renewable Energy Section of the Electric Reliability Division at the Michigan Public Service Commission (MPSC or Commission). Q. Please describe your educational background. A. In 00 I earned a Bachelors of Science in Engineering from Michigan State University. Prior to my course work at Michigan State University, I was in an engineering transfer program at Lansing Community College where I was a member of the Phi Theta Kappa honor society. Q. What is your professional work experience? A. I have worked for the Commission since 00. From 00 until 00, I worked in the Energy Grants Section of the Motor Carrier, Energy Grants and Information Division. My primary responsibility was for award selection and administration of Michigan Energy Efficiency (MIEE) grants. MIEE grants made up approximately % of the total allocations from the more than $0 Million per year Low-Income and Energy Efficiency Fund. In the later part of 00, I was transferred into the Renewable Energy Section and became involved in the implementation of 00 PA (Act), focusing on electric provider s Renewable Energy Plan filings.

15 QUALIFICATIONS OF JESSE J. HARLOW CASE NUMBER U-0 PART I 0 0 Q. Have you had any other training that is relevant to your testimony? A. Yes, In 00 I attended the Institute of Public Utilities Regulatory Studies Program, a two-week program with course work designed to educate regulatory professionals. In 00, I attended the Institute of Public Utilities Advanced Regulatory Studies Program. In 0, I attended courses in both the Institute of Public Utilities Regulatory Studies Program and the Institute of Public Utilities Advanced Regulatory Studies Program. To stay abreast with the rapidly growing and evolving field of renewable energy, I have attended and continue to attend various renewable energy related seminars and conferences. I have also presented at a number of these events and others on renewable energy and 00 PA related issues. Q. Have you filed testimony or rebuttal testimony in any other cases? A. I have filed testimony and/or rebuttal testimony in the following cases: U-00 Consumers Energy Company s 00 Renewable Energy Reconciliation on transfer price; U- Detroit Edison Company s 00 Renewable Energy Reconciliation on transfer price; U- Consumers Energy Company s Amended Renewable Energy Plan on the Company s transfer price and solar program; U-0 Alpena Power Company s Biennial Renewable Energy Plan; U- Detroit Edison Company s Amended and Biennial Renewable Energy Plan on the Company s transfer price and solar program;

16 QUALIFICATIONS OF JESSE J. HARLOW CASE NUMBER U-0 PART I 0 U- Wisconsin Electric Power Company s Biennial Renewable Energy Plan on transfer price; U- Wisconsin Electric Power Company s 00 Renewable Energy Reconciliation on transfer price; U-0 Consumers Energy Company s 00 Renewable Energy Reconciliation on the Company s Pre-Act expenditures and transfer price; U-0-R Consumers Energy Company s 00 PSCR on transfer price; U- Consumers Energy Company s Biennial Renewable Energy Plan; U--R Consumers Energy Company s 0 PSCR on transfer price; U- Wisconsin Electric Power Company s 0 Renewable Energy Cost Reconciliation on transfer price; U- Consumers Energy Company s 0 Renewable Energy Cost Reconciliation on transfer price U- Detroit Edison Company s 0 Renewable Energy Cost Reconciliation on transfer price

17 DIRECT TESTIMONY OF JESSE J. HARLOW CASE NUMBER U-0 PART II 0 Q. What is the purpose of your direct testimony? A. The purpose of my direct testimony is to present Staff s recommendations regarding Company witness Angela P. Wojtowicz s requests on page APW, Lines - of her pre-filed testimony. Specifically, the Company has requested the application of transfer prices to certain contracts: U- Transfer Prices proposed for contracts and Company-owned projects submitted to the Commission for approval between July, 0 and the date of this Case filing (i.e., June, 0). And 0 MPSC Staff Transfer Prices proposed for contracts and Company-owned projects submitted to the Commission for approval after the date of this Case filing (i.e., June, 0). Q. Can you please list the renewable contracts and Company-owned projects that the U- Transfer Prices would apply to? A. Yes. The Commission has previously approved these contracts and associated them with U- Transfer Prices: Echo Wind Park Tuscola Wind II Pheasant Run and Pheasant Run II This refers to the transfer price schedule that is the subject of the Company s active 0 renewable cost reconciliation in Case No. U-. This transfer price schedule refers to the 0 MPSC Staff Transfer Price Schedule as filed in Case No. U-00 on March, 0 and proposed by the Company in this case in Exhibit A-. Staff intends to file this transfer price schedule in the Company s 0 renewable cost reconciliation in Case No. U-. The process for developing this transfer price schedule is the result of the Commission s December 0, 0 Order in Case No. U- that required the Company, Staff and interested parties to participate in a technical conference concerning the development of transfer prices.

18 DIRECT TESTIMONY OF JESSE J. HARLOW CASE NUMBER U-0 PART II 0 0 Due to the fact that the Commission has already addressed the transfer price schedules associated with these contracts at the time the contracts were approved, additional approvals are not necessary. Q. Can you please list the renewable contracts and Company-owned projects that the Company has requested to associate with the 0 MPSC Staff Transfer Prices? A. Yes. Big Turtle Wind Farm (contract approval currently under Commission review) Future Company-owned wind build DTE-owned solar Phase (. MW) Q. Please provide background information on when a transfer price schedule is established. A. The transfer price schedule is to be established on a yearly basis in the renewable cost reconciliation. The Commission provided recent direction on transfer price schedules: The Commission supports the Staff s annual filing of its proposed transfer price schedule in Case No. U-00, which will be updated by the Staff each April, and will be available to all utilities for planning purposes from 0 through 0. The Commission will review the transfer price schedule in each reconciliation case. Order in Case No. U-, June, 0, p. Q. For new renewable energy contracts, what transfer price is applicable? A. Typically, the Commission approves a transfer price for new renewable energy projects in the utility s next renewable energy reconciliation proceeding or subject

19 DIRECT TESTIMONY OF JESSE J. HARLOW CASE NUMBER U-0 PART II 0 0 to final approval of a transfer price schedule proposed in a pending reconciliation proceeding. It is the Commission s practice to approve a transfer price for the project from the most recently approved schedule of transfer prices or from the schedule of transfer prices proposed in a pending reconciliation proceeding (subject to approval). Q. What is the most recently approved schedule of transfer prices for DTE Electric? A. The Commission s December 0, 0 Order in Case No. U- rejected the Company s amended transfer price schedule and required the Company, Staff and interested parties to participate in a technical conference concerning the development of transfer prices. This Order put DTE Electric in a unique situation in which the most recently approved schedule of transfer prices was, and still is, the schedule established in the 00 renewable energy plan. The schedule proposed in the 00 renewable energy plan is now four years old. Q. In light of this, what is your opinion of Ms. Wojtowicz s updated transfer price schedules? A. Utilizing the updated transfer price schedules as proposed by Ms. Wojtowicz will allow the Company to use a transfer price schedule that more closely resembles current long term power purchase agreements for the non-renewable component of the renewable generation and potentially utilize a transfer price schedule that is consistent with the Consumers Energy Company. The Commission s June, 0 Order in Case No. U-(Consumer Energy Company s 0 renewable cost reconciliation) ordered the Company to utilize Staff s transfer price schedule. Staff proposed the same schedule in Case No. U- (DTE Electric Company s 0 renewable cost reconciliation) which is currently pending.

20 DIRECT TESTIMONY OF JESSE J. HARLOW CASE NUMBER U-0 PART II 0 Q. What is Staff s recommendation regarding Ms. Wojtowicz s request to utilize the 0 MPSC Staff Transfer Prices for contract filings made after June, 0? A. The 0 MPSC Staff Transfer Prices have not been approved by the Commission. The Commission s June, 0 Order in Consumers Energy s 0 renewable reconciliation case, U-, as noted above, states that the transfer price schedule will be approved in reconciliation cases. Staff recommends that the Company use the transfer price schedule that is approved in DTE Electric s 0 renewable reconciliation case (Case No. U- ) for contracts submitted after the new transfer price schedule is approved in that case. For contracts submitted before a new transfer price schedule is approved in Case No. U-, Staff recommends that the Company use the transfer prices that Staff proposed in Case No. U- that are pending approval. To calculate the incremental cost of compliance in this case (for planning purposes only), Staff does not object to the Company s proposal to use Staff s 0 Transfer Prices from Case No U- for contract filings made after June, 0 Staff has already filed its 0 MPSC Staff Transfer Prices for informational purposes in U-00 and intends to file them in Case No. U-. Q. Does this conclude your testimony? A. Yes. The Company filed its application in Case No. U- on August 0, 0.

21 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION In the matter, on the Commission s own Motion, regarding the regulatory reviews, revisions, Case No. U-0 determinations, and/or approvals necessary for (e-file paperless) DTE ELECTRIC COMPANY f/k/a THE DETROIT EDISON COMPANY to fully comply with Public Acts and of 00. / STATE OF MICHIGAN ) ) ss COUNTY OF INGHAM ) PROOF OF SERVICE TINA L. BIBBS, being first duly sworn, deposes and says that on September, 0, she served a true copy of the MICHIGAN PUBLIC SERVICE COMMISSION STAFF S MOTION TO SUPPLEMENT AND REVISE TESTIMONY; NOTICE of HEARING; and JESSE J. HARLOW S REVISED DIRECT TESTIMONY (Red-Lined Version and Clean Copy) upon the following parties VIA only: DTE Electric Company Michael J. Solo, Jr. G. Dennis Schreibeis The Detroit Edison Company One Energy Plaza, WCB Detroit, MI solom@dteenergy.com schreibeisgd@dteenergy.com mpscfilings@dteenergy.com MEC Christopher M. Bzdok Emerson Hilton Olson, Bzdok & Howard 0 E. Front St. Traverse City, MI chris@envlaw.com emerson@envlaw.com Ruth Ann Liebziet, Legal Assistant Kimberly Flynn, Legal Assistant ruthann@envlaw.com kimberly@envlaw.com

22 Administrative Law Judge Hon. Theresa A. Sheets Administrative Law Judge Michigan Public Service Comm. W. Allegan St. rd Floor, North Tower Lansing, MI ELPC & Ecology Center Bradley D. Klein Environmental Law & Policy Center East Wacker Drive, Suite 00 Chicago, IL 00 Colleen Belak, Legal Assistant David Wright Ecology Center E. Liberty, Suite 00 Ann Arbor, MI 0 davidw@ecocenter.org TINA L. BIBBS Subscribed and sworn to before me this th day of September, 0. Pamela A. Pung, Notary Public State of Michigan, County of Clinton Acting in the County of Ingham My Commission Expires: --0