STATE OF MICHIGAN
BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION
*****
In the matter of the application of
)
DTE ELECTRIC COMPANY for authority to increase )
its rates, amend its rate schedules and rules governing )
the distribution and supply of electric energy, and
)
for miscellaneous accounting authority.
)
)

Case No. U-20162

At the July 2, 2019 meeting of the Michigan Public Service Commission in Lansing,
Michigan.

PRESENT: Hon. Sally A. Talberg, Chairman
Hon. Norman J. Saari, Commissioner
ORDER

On July 6, 2018, DTE Electric Company (DTE Electric) filed an application requesting
authority to increase its retail rates for the generation and distribution of electricity by $328
million, and for other forms of regulatory relief.
On July 25, 2018, Administrative Law Judge Sally L. Wallace (ALJ) conducted a prehearing
conference at which she granted petitions to intervene filed by, among others, the Michigan
Department of the Attorney General (Attorney General); the Association for Businesses
Advocating Tariff Equity (ABATE); the Great Lakes Renewable Energy Association (GLREA);
the Residential Customer Group (RCG); and the Michigan Environmental Council, Natural
Resources Defense Council, and Sierra Club (MEC/NRDC/SC). The Commission Staff (Staff)
also participated.

 On May 2, 2019, the Commission issued an order adopting a May 1, 2019, through April 30,
2020, test year and a jurisdictional revenue deficiency of $125,097,000 (May 2 order). Rates were
reset by the May 2 order to reflect the jurisdictional revenue deficiency and the expiration of the
Tax Cuts and Jobs Act of 2017 (TCJA) Credit A, 1 and new rates were authorized for application
on a service rendered basis on and after May 9, 2019. May 2 order, p. 1, n. 1, and pp. 212-213.
On June 3, 2019, DTE Electric and RCG filed petitions for rehearing pursuant to Mich Admin
Code, R 792.10437 (Rule 437). DTE Electric’s petition is accompanied by an affidavit. On
June 21, 2019, DTE Electric filed a response to RCG’s petition. On June 24, 2019,
MEC/NRDC/SC, GLREA, RCG, and the Attorney General filed responses to DTE Electric’s
petition; and ABATE, the Staff, and the Attorney General filed responses to RCG’s petition. On
June 25, 2019, the Staff filed a response to DTE Electric’s petition.

DTE Electric Company’s Petition for Rehearing
A. River Rouge Unit 3 Capital Expense
DTE Electric seeks rehearing of the Commission’s decision to exclude from rate base capital
costs of $8.45 million incurred through December 31, 2018, associated with River Rouge Unit 3
(Unit 3). May 2 order, pp. 8-12. DTE Electric contends that the decision does not comport with
controlling law because the investments made in Unit 3 were used and useful in public service,
were prudent, and made it possible for Unit 3 to provide safe, reliable, and environmentally
compliant power in the 2017-2018 time period. DTE Electric notes that these costs went towards
the replacement of pumps, motors, valves, instruments, and control system components. 4 Tr 575.

1

See, the July 24, 2018 order in Case No. U-20105.

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U-20162

 The company states that the disallowance requires DTE Electric to write off or write down the
plant such that the utility is denied a fair return on the property.
DTE Electric argues that the Unit 3 costs were justified by the net present value rate of return
(NPVRR) analysis provided in evidence. Exhibit A-12, Schedule B6; 3 Tr 367-368. DTE Electric
claims that the Commission had previously disallowed Unit 3 capital expense in prior rate cases
because the NPVRR had not been updated, and that the update provided in the instant case not
only corrects that omission but also supports the decision to continue operation of the unit. DTE
Electric posits “Past findings of the Commission have been based on the premise that the
Company provided no economic evidence to justify its costs.” DTE Electric’s petition, p. 8.
Finally, DTE Electric maintains that the decision in the May 2 order incentivizes early retirement,
and this is inconsistent with the Commission’s determination that retirement dates for the Tier 2
plants should be determined in the company’s integrated resource plan (IRP) proceeding, Case No.
U-20471. See, April 27, 2018 order in Case No. U-18419, pp. 48-49.
The Attorney General opposes the petition, arguing that it fails to meet the standard for
rehearing because DTE Electric simply presents the same arguments that were addressed by the
Commission in the May 2 order, as well as the same arguments that were rejected by the
Commission in ruling on DTE Electric’s petition for rehearing in its last rate case. See, June 28,
2018 order in Case No. U-18255. The Attorney General notes that the burden of proof was on
DTE Electric to show that the Unit 3 costs were reasonable and prudent, and argues that the May 2
order does nothing to interfere with the IRP process.
MEC/NRDC/SC also oppose the petition, stating that DTE Electric seeks to simply relitigate
this issue without providing any new argument or identifying any newly discovered evidence,
unintended consequences, or errors. MEC/NRDC/SC contend that the company again failed to

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 meet its evidentiary burden in this case just as it had failed in three prior rate cases where the same
cost category was disallowed. MEC/NRDC/SC argue that the “used and useful” standard does not
guarantee cost recovery because the expense must still be shown to be reasonable and prudent; and
that the company’s complaint regarding the possibility of a write off should be ignored, since a
$10 million disallowance is unlikely to impact DTE Electric’s credit rating given its $17 billion
rate base.
Rule 437 provides that a petition for rehearing may be based on claims of error, newly
discovered evidence, facts or circumstances arising after the hearing, or unintended consequences
resulting from compliance with the order. As the Commission has stated many times, a petition
for rehearing is not merely another opportunity for a party to argue a position or to express
disagreement with the Commission’s decision. Unless a party can show the decision to be
incorrect or improper because of errors, newly discovered evidence, facts or circumstances arising
after the hearing, or unintended consequences of the decision, the Commission will not grant
rehearing.
All of the arguments made by DTE Electric were addressed by the Commission in the May 2
order, pp. 8-12, and the Commission is not persuaded that its decision does not comport with
precedent. Precedent reveals that the company has repeatedly seen these costs disallowed based
on its failure to demonstrate their cost-effectiveness. December 11, 2015 order in Case No. U17767, p. 14; January 31, 2017 order in Case No. U-18014, p. 17; and April 18, 2018 order in Case
No. U-18255, p. 8. As the Commission stated, “while the unit is in use, reasonable and prudent
O&M [operations and maintenance] costs should be approved to ensure safe operation and a
smooth transition to retirement. However, the updated NPVRR provided on this record does not
persuade the Commission to award the 2017-2018 capital costs to DTE Electric nor the future

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 capital expense, because the evidence is simply not conclusive on the issue of reasonableness and
prudence.” May 2 order, pp. 11-12. The petition for rehearing presents no convincing claim of
error and is denied.
B. 3G to 4G Relay Capital Expense
DTE Electric seeks rehearing of the Commission’s decision to disallow $9.6 million in capital
expense (the cost of 300 additional cell relays) associated with the upgrade of advanced metering
infrastructure (AMI) equipment from 3G to 4G. May 2 order, pp. 34-35. DTE Electric argues that
the decision has unintended consequences in that the 300 additional cell relays would assist the
company in complying with the December 20, 2018 order in Case No. U-20084. That order
approved a settlement agreement which requires DTE Electric to reduce the number of customers
receiving consecutive estimated bills. DTE Electric contends that the additional 300 cell relays
will provide better communication and will enable the company to come closer to the meter read
rate of Consumers Energy Company (Consumers).
DTE Electric also argues that the actual disallowance associated with the 300 relays should be
$2.37 million, as the company had posited in its exceptions, based on $7,900 per relay. DTE
Electric argues that the Staff’s proposed disallowance of $9.6 million comes to one-third of the
total project costs for a project that covers 3,300 relays.
RCG opposes the petition, arguing that the utility’s AMI mesh network has major design and
implementation flaws and that DTE Electric failed to substantiate its expenditures.
The Attorney General also opposes the petition, noting that the Commission already
considered all of DTE Electric’s arguments on the record and that the utility has added nothing
new. The Attorney General contends that DTE Electric’s obligations under the settlement in Case
No. U-20084 are independent of this rate case issue.

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 The Staff similarly opposes the petition on grounds that the utility’s arguments were addressed
by the Commission, while advocating for a different disallowance amount which appeared in the
Staff’s initial brief but not on the record.
The Commission is not persuaded to grant rehearing, since all of DTE Electric’s arguments,
including those addressing the disallowance amount, were addressed in the May 2 order, pp. 3435. The Commission was aware of the outcome of Case No. U-20084 at the conclusion of the rate
case, and the Commission sees no unintended consequences from the decision. The petition for
rehearing presents no convincing argument and is denied.
C. Demand Side Management Program Capital Expense
DTE Electric seeks rehearing of the Commission’s decision in the May 2 order to disallow
$6.2 million in capital expense associated with the programmable communicating thermostat
(PCT) program. May 2 order, pp. 37-39. DTE Electric states that it is seeking reconsideration not
of the full amount of the disallowance, but of $5.1 million in actual costs incurred to implement
the program. DTE Electric indicates that $5.1 million was spent through the end of the bridge
period to develop the software platform that is essential to implement and run the program. DTE
Electric states that it had enrolled 6,017 customers by May 29, 2019. This date is 27 days after the
issuance of the May 2 order; thus, the company offers new evidence by affidavit.
The Attorney General opposes the petition, characterizing it as simply a relitigation to obtain a
different result. The Attorney General points out that the affidavit is not part of the record in this
case and does not meet the definition of newly discovered evidence because it simply records
events that occurred after the close of the record.
The Staff also opposes the petition, arguing that the attached affidavit does not constitute
newly discovered evidence.

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 Though DTE Electric seeks rehearing on a lesser amount, the Commission is not persuaded to
change the disallowance. DTE Electric essentially made these arguments in exceptions (albeit
seeking more money and providing proof of fewer enrollments) and they were addressed by the
Commission in the May 2 order, pp. 38-39. Even assuming that further enrollments have occurred
since the record closed in this matter, the Commission does not find that this constitutes newly
discovered evidence or facts or circumstances arising after the hearing which should result in a
rehearing. The Commission is hopeful that enrollments will continue to increase between rate
cases because that is the intended result. The petition for rehearing is denied.
D. Rider 18 Banked Credits
DTE Electric seeks rehearing of the Commission’s determination that when a residential
customer ends participation in the distributed generation (DG) Rider 18 program “any existing
credit on the customer’s account will be either applied to the power supply portion of the
customer’s bill or refunded to the customer if the customer leaves the residence.” May 2 order,
p. 200; 8 Tr 3892, 4172. DTE Electric argues that this results in unintended consequences in light
of the fact that, in the remainder of the DG discussion, the Commission limited the application of
outflow credits to the power supply component of the customer’s bill. May 2 order, p. 182. The
company contends that allowing a refund “would circumvent the power supply limit the
Commission recognized with respect to the outflow credit calculation.” DTE Electric’s petition,
p. 14. DTE Electric contends that any refund would actually be the same as issuing a credit for
non-power-supply charges such as distribution or fixed customer charges. DTE Electric posits that
this is contrary to MCL 460.1177(4) and the Commission’s findings regarding the outflow
calculation.

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 RCG opposes the petition, arguing that allowing DTE Electric to force the customer to forfeit
the value of the energy provided to the grid would amount to an unjust enrichment to the utility
and a confiscation of the property of the customer.
GLREA opposes the petition on similar grounds, and notes that DTE Electric has presented no
information as to how its proposal would alter the economics of the outflow compensation
program. GLREA urges the Commission to allow for time and experience with the new tariff,
which may result in further refinement in future rate cases.
The Attorney General also opposes the petition, arguing that the utility fails to make an apples
to apples comparison because a refund is not the same as a credit. The Attorney General contends
that DTE Electric’s proposal would deprive the customer of the value of the energy added to the
grid, and that the refund does not circumvent the power supply restriction.
The Staff also opposes the petition, arguing that DTE Electric fails to explain how the refund
could apply to the non-power supply portion of a bill where the customer is no longer billed.
The Commission addressed DTE Electric’s arguments in the May 2 order, pp. 180-182, 200,
and finds no unintended consequences resulting from its decision. As the Commission explained,
the inflow/outflow methodology approved in the rate case is in conformance with MCL
460.6a(14), and is not governed by MCL 460.1177(4). May 2 order, pp. 180-182; April 18, 2018
order in Case No. U-18383, pp. 13-15. However, even if MCL 460.1177(4) was the controlling
law, the approved outflow credit and refund mechanism comply with the language of that statute.
With respect to an outflow credit, MCL 460.1177(4)(b) states:
The credit shall appear on the bill for the following billing period and shall be limited to
the total power supply charges on that bill. Any excess kilowatt hours not used to offset
electric generation charges in the next billing period will be carried forward to subsequent
billing periods. Notwithstanding any law or regulation, distributed generation customers
shall not receive credits for electric utility transmission or distribution charges. The credit
per kilowatt hour for kilowatt hours delivered into the utility’s distribution system shall
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 be . . . [t]he electric utility’s . . . power supply component, excluding transmission charges,
of the full retail rate during the billing period or time-of-use pricing period.
The outflow credit approved in the May 2 order is calculated on the basis of power supply less
transmission, is applied to power supply charges on the bill, reflects neither transmission nor
distribution, and is carried forward to subsequent billing periods, all of which comports with the
quoted language. However, the statute does not address the situation where the customer
terminates participation in the program and leaves the residence. At that point, the customer can
no longer receive a credit because there is no bill to credit against. DTE Electric’s position would
result in the customer providing energy to the utility without compensation. The Commission
found that the customer is entitled to the value of the energy provided to the grid in the form of a
refund that is equal to what the outflow credit would be if a credit were an option. May 2 order, p.
200; 8 Tr 4172. 2 Because the value of the refund will be calculated on the basis of the outflow
credit methodology, that value will reflect neither transmission nor distribution and thus is
consistent with MCL 460.1177(4). The Commission finds no unintended consequences or error,
and the petition for rehearing is denied.
Residential Customer Group’s Petition for Rehearing
Again, Rule 437(1) provides that a petition for rehearing must be based on “a claim of
error . . . a claim of newly discovered evidence, on facts or circumstances arising subsequent to the
close of the record, or on unintended consequences resulting from compliance with the decision or
order.” As the Commission has stated many times, a petition for rehearing will be denied if it

2

Rider 18 provides “Upon customer termination from the Distributed Generation Program,
any existing Outflow credit on the customer’s account will be applied to the power supply
component and PSCR [power supply cost recovery] components of the customer’s future bills for
customers who remain in the residence. Outflow credit will be refunded to customers who do not
remain in the residence.” May 2 order, Attachment B, p. 77; Tariff Sheet D-117.00.
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 merely expresses disagreement with the Commission’s decision. In its petition, RCG makes no
mention of newly discovered evidence, facts or circumstances arising after the hearing, or
unintended consequences of the May 2 order. The Commission thus assumes that RCG intends to
assert a claim of error on each issue.
A. The Historical Test Year
RCG argues that the Commission should have adopted its proposal for use of a historical test
year adjusted for known changes rather than a projected test year.
DTE Electric opposes the petition, noting that RCG has simply reprinted its exceptions and
has acknowledged that its position is contrary to established regulatory practice.
The Staff also opposes the petition, noting that RCG has simply copied its exceptions, all of
which were considered and addressed by the Commission in the May 2 order.
The Attorney General, while never stating that she supports the petition, “requests that the
Commission carefully consider this issue, both in this case and on a forward-going basis. The AG
argues that the Commission should consider instituting a bright-line rule, to avoid ongoing
interpretation issues with what is meant by a ‘future projected test year.’” Attorney General’s
answer to RCG’s petition, p. 4. The Attorney General suggests that a projected test year should
commence no more than two months after the date of a rate case filing.
ABATE supports the petition, arguing that the historical test year may have produced a
revenue sufficiency in this case, and the Commission should consider restricting the test year to
the historical test year because of the impossibility of thoroughly analyzing all of the data built
into a projected test year.

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 The Commission addressed RCG’s exceptions on this issue (which are identical to the
rehearing arguments) in the May 2 order, pp. 3-4. The petition for rehearing fails to meet the
standards set out in Rule 437 and is denied.
B. The Impact of Tax Law Changes
RCG argues that the rate adjustments resulting from passage of the TCJA should have no
impact on the revenue deficiency arrived at in this rate case. RCG contends that the May 2 order
“erroneously excludes any explanation of how a 40% reduction in federal corporate income tax
expense for DTE Electric results in a major increase in customer rates.” RCG’s petition, p. 9; see
May 2 order, pp. 123-124. RCG argues that the addition of any amount to the revenue deficiency
related to the effect of the TCJA is in error, and that the Commission should follow the precedent
set in Case Nos. U-8681 and U-8683 after passage of the Tax Reform Act of 1986 (TRA).
DTE Electric opposes the petition, stating that RCG has simply reprinted its exceptions and
appears to misunderstand how the revenue deficiency is calculated.
ABATE supports the petition, arguing that the ALJ never showed why it was necessary to add
the TCJA impact to the revenue deficiency.
The Commission is not persuaded that it has mishandled the rate effects of the TCJA, or that
Commission precedent demonstrates any error. In the December 27, 2017 and February 22, 2018
orders in Case No. U-18494, the Commission commenced proceedings very similar to the
proceedings commenced for the purpose of addressing the TRA. See, December 17, 1986 order in
Case No. U-8638, pp. 2-6, and January 27, 1987 order in Case No. U-8638, pp. 6-7. 3 For the
largest utilities, those cases concluded with a refund of past overcollections based on the old tax

3

However, the Commission had over six months until the TRA tax changes went into effect,
whereas, with the TCJA, the Commission had only a few days.
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 rate and a reduction to rates going forward to reflect the correct tax rate. August 4, 1987 order in
Case No. U-8681 (Consumers), and September 1, 1987 order in Case No. U-8683 (DTE Electric).
The Court of Appeals affirmed the Commission’s authority to order refunds and to adjust rates
going forward; to do so in a single issue case examining the TRA; and to determine which factors
it would consider in ascertaining the effect of the TRA. Consumers Power Co v Public Service
Comm, 181 Mich App 261, 266-268; 448 NW2d 806 (1989). The Commission finds nothing in its
handling of the TCJA that conflicts with its handling of the TRA.
The Commission assumed that all parties understood that, when rates are reset in a rate case, it
is axiomatic that those rates will reflect the current corporate tax rate. Credits A and B reflected
the amounts due to be refunded to ratepayers based on past rates that included, and future rates that
would have included, the incorrect tax rate. With the filing of a rate case, the Commission has the
opportunity to correct the tax rate going forward and the credit that had been temporarily built into
rates to reflect the correct tax rate is no longer necessary. Consistent with the July 24, 2018 order
in Case No. U-20105, Credit A expired with the resetting of rates. May 2 order, p. 1, n. 1, and
p. 212. That amount is not part of a new revenue deficiency; rather, the expiration of the credit
represents the opportunity to return to normal rates presented by the conclusion of a rate case. The
petition for rehearing presents no convincing argument and is denied.
C. Opt-Out Charges
RCG argues that opt-out charges are not cost based, and should be sharply reduced or
eliminated. RCG contends that DTE Electric’s monthly opt-out charges are substantially higher
than Consumers’ monthly opt-out charges, and states that DTE Electric’s AMI program is in
chaos.

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 DTE Electric opposes the petition, noting that RCG has largely reprinted its exceptions and
continues to assert arguments that have been repeatedly rejected by the Commission and the
courts.
The Commission addressed RCG’s arguments in the May 2 order, pp. 36-37, citing to the
numerous opinions issued by the Michigan Court of Appeals affirming the Commission’s
decisions addressing opt-out charges. RCG’s petition for rehearing cites to no error and contains
no new information, and is denied.
D. The Impact of the Order in Case No. U-20084
RCG makes two arguments in favor of rehearing with respect to issues related to the
December 20, 2018 order in Case No. U-20084 in which the Commission approved a settlement
agreement addressing purportedly non-transmitting meters that were actually transmitting. First,
RCG argues that rates should be adjusted to reflect the settlement; and, second, RCG argues that
the Commission has failed to enforce the settlement agreement in Case No. U-20084 and should
use this rate case to do so.
DTE Electric opposes the petition, noting that no ratemaking adjustments were made in this
case because the record was closed before the settlement agreement was approved.
The Commission addressed RCG’s arguments on these two issues (which were identical to the
rehearing arguments) in the May 2 order, p. 36. RCG’s petition for rehearing cites to no error and
contains no new information regarding these two issues, and is denied.
E. 3G to 4G Upgrade Program
RCG argues that the Commission should eliminate all projected capital and O&M expense
associated with DTE Electric’s AMI mesh network and should initiate an investigation into the
costs.

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 DTE Electric opposes the petition, noting that RCG simply repeats its exceptions and cites to
no evidence to support the notion that the AMI mesh network is failing.
The Commission addressed RCG’s exceptions on this issue (which were identical to the
rehearing arguments) in the May 2 order, pp. 34-35. The petition for rehearing fails to meet the
standards set out in Rule 437 and is denied.
THEREFORE, IT IS ORDERED that the petitions for rehearing filed by DTE Electric
Company and the Residential Customer Group are denied.
The Commission reserves jurisdiction and may issue further orders as necessary.

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 Any party desiring to appeal this order must do so in the appropriate court within 30 days after
issuance and notice of this order, under MCL 462.26. To comply with the Michigan Rules of
Court’s requirement to notify the Commission of an appeal, appellants shall send required notices
to both the Commission’s Executive Secretary and to the Commission’s Legal Counsel.
Electronic notifications should be sent to the Executive Secretary at mpscedockets@michigan.gov
and to the Michigan Department of the Attorney General – Public Service Division at
pungp1@michigan.gov. In lieu of electronic submissions, paper copies of such notifications may
be sent to the Executive Secretary and the Attorney General – Public Service Division at 7109
W. Saginaw Hwy., Lansing, MI 48917.
MICHIGAN PUBLIC SERVICE COMMISSION

________________________________________
Sally A. Talberg, Chairman

________________________________________
Norman J. Saari, Commissioner
I abstain.

_________________________________
Daniel C. Scripps, Commissioner

By its action of July 2, 2019.

______________________________________
Barbara S. Kunkel, Acting Executive Secretary

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 PROOF OF SERVICE
STATE OF MICHIGAN )
Case No. U-20162

County of Ingham

)

Brianna Brown being duly sworn, deposes and says that on July 2, 2019 A.D. she
electronically notified the attached list of this Commission Order via e-mail transmission,
to the persons as shown on the attached service list (Listserv Distribution List).

_______________________________________
Brianna Brown
Subscribed and sworn to before me
this 2nd day of July 2019.

_____________________________________
Angela P. Sanderson
Notary Public, Shiawassee County, Michigan
As acting in Eaton County
My Commission Expires: May 21, 2024

 Service List for Case:

U-20162

Name

Email Address

Amit T. Singh
Andrea E. Hayden
Anita Fox
Benjamin L. King
Brian W. Coyer
Bryan A. Brandenburg
Chinyere A. Osuala
Christopher M. Bzdok
Daniel Sonneveldt
David C. Bender
Don L. Keskey
DTE Energy Company
Jean-Luc Kreitner
Jody Kyler Cohn
Joel B. King
John R. Canzano
Jon P. Christinidis
Justin Ooms
Kurt J. Boehm
Laura A. Chappelle
Lauren D. Donofrio
Lydia Barbash-Riley
Margrethe Kearney
Mark N. Templeton
Megan E. Irving
Melissa M. Horne
Michael S. Ashton
Rebecca J. Boyd
Robert A. Weinstock
Robert A.W. Strong
Sally Wallace
Shannon W. Fisk
Spencer A. Sattler
Timothy J. Lundgren
Toni L. Newell

singha9@michigan.gov
andrea.hayden@dteenergy.com
afox@fraserlawfirm.com
bking@michworkerlaw.com
bwcoyer@publiclawresourcecenter.com
bbrandenburg@clarkhill.com
cosuala@earthjustice.org
chris@envlaw.com
sonneveldtd@michigan.gov
dbender@earthjustice.org
donkeskey@publiclawresourcecenter.com
mpscfilings@dteenergy.com
jkreitner@elpc.org
jkylercohn@bkllawfirm.com
kingj38@michigan.gov
jcanzano@michworkerlaw.com
jon.christinidis@dteenergy.com
jkooms@varnumlaw.com
kboehm@bkllawfirm.com
lachappelle@varnumlaw.com
lauren.donofrio@dteenergy.com
lydia@envlaw.com
mkearney@elpc.org
templeton@uchicago.edu
megan.irving@dteenergy.com
mhorne@hcc-law.com
mashton@fraserlawfirm.com
rebecca.j.boyd@gmail.com
rweinstock@uchicago.edu
rstrong@clarkhill.com
wallaces2@michigan.gov
sfisk@earthjustice.org
sattlers@michigan.gov
tjlundgren@varnumlaw.com
tlnewell@varnumlaw.com