STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION * * * * * * * * * * * * * * * *

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1 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION * * * * * * * * * * * * * * * * In the matter of the Application of Consumers ) Energy Company for authority to increase its ) rates for the generation and distribution of electricity ) Case No. U and for other relief. ) ) MICHIGAN STATE UTILITY WORKERS COUNCIL S FIRST DISCOVERY REQUEST TO CONSUMERS ENERGY The Michigan State Utility Workers Council, Utility Workers Union of America, AFL-CIO ( the Council ), by and through its attorneys, Kelley Cawthorne, submits this First Discovery Request to Consumers Energy Company ( Consumers ) pursuant to Commission Rule 317 (1992/1997 AACS, R ). DEFINITIONS A. Document, Documents, reports, and/or correspondence, include any written, recorded or graphic matter however produced or reproduced including but not limited to, correspondence, memoranda, records, papers, pictures, reports, summaries, studies, minutes, agenda, bulletins, notices, periodicals, announcements, amendments, instructions, charts, manuals, schedules, phone logs, notes, drawings, diagrams, analyses, telegrams, agreements, printed notices, electronic mail, or any other writings of every nature whether generated or inscribed by hand or by some mechanical, computer, electronic, photographic, or other means in your possession, custody or control or the possession, custody or control of former employees, agents, current employees, agents, representatives or predecessors or predecessors in interest. The word Document means

2 the original, but if the original is not in the possession, custody or control of the persons or entities listed above, it means a copy. All copies of Documents containing any alterations, notes, comments, or other material not included in the original or copies referred to above shall be deemed separate Documents from such originals or copies. B. Identify when used in reference to a person, means to state the person s full name, last known business address and telephone number, last known residential address and telephone number, last known employment position and the name, address and telephone number of that person s employer or the chief executive officer of that person s employer. Identify when used in connection with Documents means to describe the Documents setting forth their dates, titles, authors, addresses, parties, locations and the substance thereof, with such reasonable particularity as is sufficient for production. Documents to be identified shall include both Documents in your possession, custody and control and all other Documents of which you have knowledge. C. This Discovery Request shall be considered continuing and supplemental answers shall be required immediately upon the receipt of information by you. D. The term person means any individual, corporation, governmental entity, association, educational institution, group, partnership or any other organization or legal entity. E. The term organized workforce means those employees for which the Michigan State Utility Workers Council is recognized as the sole and exclusive bargaining agent as defined by the Working Agreement between Consumers Energy Company and Utility Workers Union of America affiliated with the AFL-CIO and its Michigan State Utility Workers Council covering operating, maintenance and 2

3 construction employees and also the Working Agreement between Consumers Energy Company and Utility Workers Union of America affiliated with the AFL-CIO and its Michigan State Utility Workers Council covering customer service employees in the virtual call center facilities. INTERROGATORIES & REQUESTS FOR PRODUCTION OF DOCUMENTS UW-CE-1. Identify the age demographics of Consumers current organized workforce, including but not limited to the number of persons in each category, according to the work groups within the following Departments and within the listed age intervals: 3

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5 15645-UW-CE-2. Identify and produce any and all Documents that provide the basis for your response to UW-CE UW-CE-3. Identify the number of persons in Consumers organized workforce whose employment relationship with Consumers ended for any reason over the past 5 years according to the work groups within the following Departments and within the listed age intervals: 5

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7 15645-UW-CE-4. Identify by percentage the reasons for the ending of the employment relationships reported in response to UW-CE-3 (e.g. retirement, termination for cause, voluntary departure, etc.) UW-CE-5. Identify and produce any and all Documents that provide the basis for your responses to UW-CE-3 and UW-CE UW-CE-6. Identify the amount of funds Consumers expended on training for members of the organized workforce for each of the past 5 years according to the work groups within the following Departments: 7

8 15645-UW-CE-7. Identify and produce any and all Documents that provide the basis for your response to UW-CE UW-CE-8. Identify by date, location and subject matter each training event, seminar or session Consumers conducted for the organized workforce in each of the past 5 years according to the work groups within the following Departments: UW-CE-9. Identify and produce any and all Documents that provide the basis for your response to UW-CE-8. 8

9 15645-UW-CE-10. Identify Consumers projections for training expenses for the organized workforce for each of the next 5 years according to the work groups within the following Departments: UW-CE-11. Identify and produce any and all Documents that provide the basis for your response to UW-CE UW-CE-12. Identify Consumers projections for the retirement and turnover of the organized workforce for the next 10 years according to the work groups within the following Departments: 9

10 15645-UW-CE-13. Identify and produce any and all Documents that provide the basis for your response to UW-CE UW-CE-14. Identify Consumers projections for the hiring of persons eligible for membership in the organized workforce for the next 10 years according to the work groups within the following Departments: UW-CE-15. Identify and produce any and all Documents that provide the basis for your response to UW-CE UW-CE-16. Identify the average number of training hours required per employee in the organized workforce for each of the last 5 years for each work group within the following Departments: 10

11 15645-UW-CE-17. Identify Consumers projections for the average number of training hours required per employee in the organized workforce for each of the next 5 years for each work group within the following Departments: UW-CE-18. Identify the average training expense per employee in the organized workforce for each of the last 5 years for each work group within the following Departments: 11

12 15645-UW-CE-19. Identify Consumers projections for training expenses per employee in the organized workforce for each of the next 5 years for each work group within the following Departments: UW-CE-20. Identify the average number of training hours required for an employee in the organized workforce, entering into a new job classification, to perform the full duties of that job classification for each job classification of each work group within the following Departments: 12

13 15645-UW-CE-21. Identify the average training expense required for an employee in the organized workforce, entering into a new job classification, to perform the full duties of that job classification for each job classification of each work group within the following Departments: UW-CE-22. Identify the minimum number of years required for an employee in the organized workforce, newly hired into a work group, to reach the highest job classification within that work group, for each work group within the following Departments: 13

14 15645-UW-CE-23. Identify the minimum training expense required for an employee in the organized workforce, newly hired into a work group, to reach the highest job classification within that work group, for each work group within the following Departments: UW-CE-24. Identify all persons, retained by or employed by Consumers, who have knowledge with respect to the responses provided to this discovery request. Respectfully submitted, KELLEY CAWTHORNE March 18, 2009 By: Steven D. Weyhing (P30749) 208 N. Capitol Avenue, Third Floor Lansing, MI (517) sweyhing@kelley-cawthorne.com Attorneys for Petitioner Michigan State Utility Workers Council, Utility Workers Union of America, AFL-CIO 14

15 STATE OF MICHIGAN BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION * * * * * * * * * * * * * * * * In the matter of the Application of Consumers ) Energy Company for authority to increase its ) rates for the generation and distribution of electricity ) Case No. U and for other relief ) ) CERTIFICATE OF SERVICE I, Terri J. Davis hereby certify that on the 18 th day of March, 2009, I served Michigan State Utility Workers Counsel s First Discover Request to Consumers Energy and a Certificate of Service in the above entitled matter upon the interested parties listed on the attached service list by and first class mail. Terri J. Davis 15

16 Service List for U Counsel for Consumers Energy Company Jon R. Robinson H. Richard Chambers Raymond E. McQuillan John C. Shea M. Bryan Little Consumers Energy Company One Energy Plaza Jackson, MI Administrative Law Judge Hon. Sharon L. Feldman Nancy Katsarelas, Case Coordinator Michigan Public Service Commission P.O. Box Lansing, MI Counsel for the Kroger Co. Michael L. Kurtz Kurt J. Boehm Boehm, Kurtz & Lowry 36 East Seventh Street, Suite 1510 Cincinnati, OH Counsel for Attorney Gen. Michael A. Cox Michael E. Moody Assistant Attorney General 525 W. Ottawa St., 7th Floor P.O. Box Lansing, MI Counsel for Mich. Public Service Comm. Staff Patricia S. Barone. Michael J. Orris Anne M. Uitvlugt Assistant Attorney General Public Service Division 6545 Mercantile Way, Suite 15 Lansing, MI Counsel for Energy Michigan, Inc. Eric J. Schneidewind Varnum, Riddering, Schmidt & Howlett The Victor Center, Suite N. Washington Square Lansing, MI Counsel for ABATE Robert A. W. Strong Clark Hill PLC 255 S. Old Woodward Avenue, 3rd Floor Birmingham, MI Counsel for Constellation NewEnergy, Inc. John M. Dempsey Dickinson Wright PLLC 215 S. Washington Square, Suite 200 Lansing, MI Counsel for Hemlock Semiconductor Corp. Jennifer Utter Heston Fraser Trebilcock Davis & Dunlap, P.C. 124 W. Allegan Street, Suite 1000 Lansing, MI

17 Counsel for Michigan Cable Midland Cogeneration Venture Telecommunications Assoc. Limited Partnership David E.S. Marvin Richard J. Aaron Fraser Trebilcock Davis & Dunlap, P.C. Ross K. Bower II 124 W. Allegan Street, Suite 1000 Fahey Schultz Burzych Rhodes PLC Lansing, MI Okemos Road Okemos, MI Michigan Municipal League SELF Roderick S. Coy Phil Forner Leland R. Rosier P O Box East Grand River Avenue Allendale, MI Lansing, MI aheat@altelco.net rcoy@clarkhill.com lrrosier@clarkhill.com Michigan Environmental Council Gerdau MacSteel Don L. Keskey Jennifer L. Copland Clark Hill PLC Dickinson Wright PLLC 212 East Grand River Avenue 301 E. Liberty, Suite 500 Lansing, MI Ann Arbor, MI dkeskey@clarkhill.com jcopland@dickinsonwright.com Metal Technologies, Inc. & Area Agencies on Aging Ravenna Casting Center, Inc. Association of Michigan & d/b/a Ravenna Ductile Iron Michigan League for Human Services Plant David L. Shaltz Robert B. Nelson Attorney at Law Fraser Trebilcock & Dunlap, PC 2270 Jolly Oak Road, Suite 2A 124 W. Allegaan, Suite 1000 Okemos, MI Lansing, MI dshaltz@sbcglobal.net rnelson@fraserlawfirm.com Michigan Alliance for Fair Competition, Michigan Chapter of Air Contractors of America, Southeast Chapter Air Conditioning Contractors of America, Western Michigan Air conditioning Contractors of America, National Federation of Independent Businesses, Associated Builders and Contractors of Michigan Roderick S. Coy Haran C. Rashes Clark Hill PLC 212 E. Grand River Avenue Lansing, MI rcoy@clarkhill.com 17