1. Regulatory Update Dennis Derricks May 5, 2010 Regulatory Update Dennis Derricks May 5, 2010

2. 2 Regulatory Update 2009 Rate Case 2010 Rate Re-Opener Discuss Pending 2011/2012 Rate Case Rate Design Fuel Renewables Energy Efficiency Rate Comparison

3. 3 2009 Rate Case Order Electric: - No overall increase Gas:($3.0M) (0.4%)

4. 4 2009 Rate Case - Electric Why no electric increase? –$48M Fuel Surcharge effective July 2008 –$41M lower fuel costs in second half of 2008 –Adjusted amortization periods for some deferrals –Granted new deferrals

5. 5 2010 Rate Case – Electric No general rate case filing for 2010 –Limited electric re-opener: $49.0M (5.0%) Fuel, purchased power and related costs Crane Creek Wind Project Focus on Energy payments Pension and benefit costs

6. 6 2010 Rate Case – Gas No general rate case filing for 2010 –Limited gas re-opener: $14.4M (3.5%) Focus on Energy payments Pension and benefit costs

7. 7 2010 Re-Opener Electric: –No Increase Gas:$13.5M 3.1%

8. 8 2010 Re-Opener Why no electric increase? –$18M of 2009 fuel over collection applied to 2010 base rates Remaining $11M refunded in April – May –Lower fuel costs

9. 9 2011 Rate Case April 1, 2010 Rate Request for 2011 Electric: $64.2M 6.9% Gas: $5.0M 1.2%

10. 10 2011 Rate Case - Electric Reduced sales (+$72M) –Economic recession –Energy efficiency 2009 decoupling ($14M) –Byproduct of reduced sales in 2009 –$14M Cap –Residential and small C&I only Cg-20 and smaller

11. 11 2011 Rate Case - Electric Increased payments to Focus on Energy (+$3M) –Residential and small C&I only Cg-20 and smaller KNPP loss (+$2M) –Non-contigent loss

12. 12 2011 Rate Case - Electric Decreased return (-$19M) –Higher deferred taxes –Reduced capital spending Decreased depreciation expense (-$7M) –Based on depreciation study –Assets lasting longer

13. 13 2011 Rate Case - Electric Decreased O&M (-$3.4M) –Workforce reductions 158 WPS employees 62 Integrys Business Support (IBS) employees

14. 14 2011 Rate Case - Gas Reduced sales (+$12M ) –Economic recession –Energy efficiency 2009 decoupling ($7M) –By-product of reduced sales in 2009 –Did not reach cap –Residential and small C&I only Cg-FM and smaller

15. 15 2011 Rate Case - Gas Increased payments to Focus on Energy (+$2M) –Residential and small C&I only CG-FM and smaller

16. 16 2011 Rate Case - Gas Decreased depreciation expense (-$8M) –Based on depreciation study –Assets lasting longer Decreased return (-$6M) –Higher deferred taxes –Reduced capital spending Decreased taxes (-$2M)

17. 17 2012 Rate Case Re-Opener Electric and Gas Re-Opener Issues –Fuel and related items (electric only) –Emission allowances (electric only) –2010 decoupling amortization –Increased Focus on Energy payments (electric only) –Pension and benefit costs –Increased uncollectibles

18. 18 WPS Cost Control Reduction in workforce –158 positions at WPS –62 positions at Integrys Business Support (IBS) Mandatory unpaid furloughs –All Integrys employees

19. 19 2011 Rate Case – Tentative Time Table April 1 2010 April-June 2010 September- October 2010 December 2010 January 2011 Rate Case filed at Public Service Commission Public Service Commission Review Rate Design filed at the Public Service Commission Public Service Commission rate hearings Public Service Commission rules on rate changes 2009 rate changes go into effect April 1, 2010 April-June Sept-Oct Dec. 2010 Jan. 2011 May 14, 2010

20. 20 Gas Rate Design No major design changes but for charge levels – approximate $5M increase. Increased volumetric per therm and demand rates to move closer to cost of service.

21. 21 Electric Rate Design ACT 141 Factors Cp-I2 Interruptible –Reduce termination notice to 3 years –Buyout settlements – use 105 day settlement as final –Nomination process. Real Time Pricing

22. 22 RTMP- Current Replacement of Generation Displacement Tariff in UR-119 rate case Non Firm Availability – same as Cp-I2 interruptible. Pricing – LMP +$/Mwh, $1,000/mo scheduling fee, $2.59/kW transmission demand charge, plus applicable Cp customer and customer demand charges.

23. 23 RTMP- ISSUES Address and clarify switching to/from interruptible service. Transmission cost recovery. Renewable Portfolio cost recovery. Energy Efficiency cost recovery Margin – appropriate level and reflection in rate case process. Penalties for non- compliance

24. 24 RTMP- Rate Case Process Meet with PSCW staff – discuss process implications – balance customer notice requirements and reasonable rate case time lines. Rate Design Testimony – 5/14/2010 – place holder. Potential meeting with staff, company and interested customers to resolve issues. Address in supplemental testimony.

25. 25 Fuel - 2010 Month of April – One time Refund of $11M from 2009 – 1.436/kwh. Lower than forecasted fuel costs – subject to refund as of April 1, 2010. Actual Sales lower than Forecast Modest $ - likely no action until year over.

26. 26 Renewable Energy Crane Creek – 99 Mw Iowa Wind on line. Ag Biogas Advanced Renewable Tariff Pilot –10 Mw cap –8 cents/Kwh average –Customer to complete survey on costs of installation and operation.

27. 27 Energy Efficiency WPS and CUB stipulation – excludes Large C&I. PSCW quadrennial process.

28. 28 Rate Comparison – 2009 Rates C& I Cents/kWh Percentage of WPS Residential cents/kWh Ratio C&I/Residential WPS5.94100%12.6747% WE7.04119%12.0958% WPL7.24122%11.3264% MP5.3089%7.8767% AEP-IP5.1186%7.5867% GP6.70113%10.2565% USA6.82115%11.7658% Source: EEI 2010 Winter Rate Comparison Report Rate Comparison – 2009 Rates

29. 29 Summary 2011/2012 rate case. Gas Rate Design Electric Rate Design RTMP Fuel Renewable Energy Efficiency