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MINNESOTA DEPARTMENT OF <br /> COMMERCE <br /> I <br /> BEFORE THE MINNESOTA PUBLIC UTILITIES COMMISSION <br /> COMMENTS OF THE <br /> MINNESOTA DEPARTMENT OF COMMERCE <br /> DIVISION OF ENERGY RESOURCES <br /> DOCKET No. E234, E101/SA-16-922 <br /> I. BACKGROUND <br /> Elk River Municipal Utilities (the Municipal) is an electric municipal utility organized and <br /> existing under the laws of the State of Minnesota. Connexus Energy(the Cooperative) is an <br /> electric distribution cooperative organized and existing under the laws of the State of <br /> Minnesota. <br /> II. SUMMARY OF PROPOSAL <br /> On November 14, 2016, the Municipal and the Cooperative, collectively the Parties,jointly <br /> filed a petition under Minn. Stat. 2166.39, subd.3, asking the Minnesota Public Utilities <br /> Commission (Commission)to modify the Parties' service territory boundaries. Approval of <br /> the Parties' request would transfer the Affected Area from the Cooperative to the Municipal. <br /> III. DEPARTMENT ANALYSIS <br /> A. TRANSFER OF THE AFFECTED AREA FROM COOPERATIVE TO MUNICIPAL <br /> Exhibit A to the Petition is a map that depicts the boundary of the Affected Area. According <br /> to the Petition, the Affected Area involves approximately 1,644 acres with 60 residential <br /> customers, 140 commercial customers and zero industrial customers. <br /> Although the Parties do not have a separate legal description prepared of the Affected Area, <br /> 61 <br />