STATE OF MICHIGAN
BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION
*****
In the matter of the application of
DTE ELECTRIC COMPANY
for authority to implement a power supply
cost recovery plan in its rate schedules for
2014 metered jurisdictional sales of electricity.
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Case No. U-17319
At the May 14, 2015 meeting of the Michigan Public Service Commission in Lansing,
Michigan.
PRESENT: Hon. John D. Quackenbush, Chairman
Hon. Greg R. White, Commissioner
Hon. Sally A. Talberg, Commissioner
ORDER
History of Proceedings
On September 30, 2013, DTE Electric Company (DTE Electric) filed an application, with
supporting testimony and exhibits, pursuant to 1982 PA 304 (Act 304), MCL 460.6j et seq.,
seeking authority to implement a power supply cost recovery (PSCR) plan in its rate schedules for
2014 metered jurisdictional sales of electricity, and requesting review of its five-year forecast.
DTE Electric sought a 2014 levelized monthly PSCR billing factor of 1.08 mills per kilowatt-hour
(kWh) based on 2014 PSCR costs of $1.429 billion. DTE Electric also requested a Commission
determination on whether it was likely to permit recovery of certain chemicals used to control
mercury and sulfur dioxide emissions and sought Commission approval to procure capacity
resources pursuant to MCL 460.6j(13)(b).
A prehearing conference was held on November 21, 2013, before Administrative Law Judge
Sharon L. Feldman (ALJ). The ALJ granted intervenor status to the Michigan Department of the
Attorney General (Attorney General), the Association of Businesses Advocating Tariff Equity
(ABATE), the Michigan Environmental Council and Sierra Club (MEC/SC), and the Great Lakes
Renewable Energy Association (GLREA). At a second prehearing conference held on December
13, 2013, the ALJ granted permissive intervention to the Institute for Energy Innovation (IEI). 1
The Commission Staff (Staff) also participated in the proceedings.
Evidentiary hearings were held on August 12 and 13, 2014. Thereafter, the parties submitted
initial and reply briefs. The ALJ issued her Proposal for Decision (PFD) on February 27, 2015.
On March 25, 2015, the Attorney General, MEC/SC, GLREA, and IEI filed exceptions to the
PFD, and on April 13, 2015, DTE Electric filed replies to exceptions. The record in this
proceeding consists of 995 pages of transcript and 135 exhibits.
Discussion
The ALJ provided a detailed review of the record and positions of the parties on pages 3-42 of
the PFD, which will not be repeated here. The ALJ identified several issues to be addressed,
including: (1) DTE Electric’s proposed capacity purchases; (2) PROMOD modeling issues;
(3) DTE Electric’s proposed sorbent costs; (4) DTE Electric’s coal forecast; (5) recommendations
from IEI and GLREA concerning the five-year forecast; (6) costs and other concerns associated
with the reduced emissions fuel (REF) project; and (7) spent nuclear fuel (SNF) fees. There were
no exceptions to the ALJ’s recommendations concerning the REF project, IEI’s proposals
In an order issued on March 6, 2014, the Commission affirmed the ALJ’s grant of permissive
intervention to IEI.
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concerning load forecasting and voltage control, and SNF fees. With respect to these issues, the
Commission adopts the PFD. The remaining contested issues are addressed seriatum.
Proposed Capacity Purchases
DTE Electric requested that, pursuant to MCL 460.6j(13)(b), the Commission approve
purchasing methods to obtain capacity necessary to meet future Midcontinent Independent System
Operator, Inc. (MISO) resource adequacy requirements. DTE Electric proposed that the
Commission preapprove these purchases provided that the company uses one of three least-cost
procurement methods it described. The Attorney General disputed the lawfulness of DTE
Electric’s proposal, arguing that under Section 6j(13)(b), the Commission may only approve or
disapprove an actual contract and not specific procedures that may result in a contract.
The ALJ found that the Commission resolved this issue in the June 19 and September 11,
2014 orders in Case No. U-17496. In those orders, addressing a similar request by Consumers
Energy Company (Consumers), the Commission denied the company’s request for approval of
auction procedures, finding that Consumers could hold a capacity auction without Commission
approval. Further, the Commission determined that Consumers could request approval of any
actual long-term contracts resulting from an auction either in a PSCR reconciliation or in a
separate case. However, because this is a PSCR plan case, where the Commission is charged with
evaluating the reasonableness and prudence of the decisions underlying the company’s plan, the
ALJ recommended that the Commission generally approve DTE Electric’s proposed procedures to
acquire capacity to meet MISO’s requirements under Section 6j(6), and take up in the future any
contracts that might be entered into under Section 6j(13)(b).
The Attorney General filed an exception in which he argued that construing Sections 6j(6) and
6j(13) in pari materia requires the Commission to disallow any capacity charges that are incurred
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before Commission approval of an agreement, notwithstanding previous Commission orders that,
he contends, misinterpreted the sections at issue. The Attorney General asserts:
Within the overall context of Subsections (6) and (13) of MCL 460.6j, the word
‘prior’ refers to disallowing capacity charge costs incurred by a utility under a
power purchase agreement (‘PPA’) unless the Commission has previously
approved recovery. And although it may be true that the Commission can approve
capacity charges after a PPA is executed and before a utility incurs any such
capacity charges, MCL 460.6j(13)(b) says costs must be disallowed in a
reconciliation order when the underlying capacity charges were not approved
before the utility incurred the costs. Thus, the word ‘prior’ in subsection 6j(13)(b)
provides the clear textual basis in the statute for inferring that costs incurred before
the Commission reviews and approves capacity charges in a PPA shall be
disallowed.
In sum, the Commission should rule that approval of capacity charges before DTE
Electric Company incurs them and seeks recovery is required by MCL
460.6j(13)(b) even though it may not be necessary to approve them for purposes of
this case because DTE Electric seeks no recovery in this case.
Attorney General’s exceptions, pp. 3-4.
In response, DTE Electric expresses support for the ALJ’s findings and conclusions on this
issue, however, according to the company, the Attorney General now takes the position that any
capacity charges must be disallowed in a reconciliation if charges were not approved in the
associated plan proceeding. DTE Electric maintains that the ALJ’s recommendation “properly
gives legal and practical effect to the PSCR plan and reconciliation provisions of 1982 PA 304,
MCL 460.6j et seq[,]” and that the Commission should reject the Attorney General’s attempt to
create limitations to capacity purchases that the Legislature never intended. DTE Electric’s replies
to exceptions, pp. 5-6.
DTE Electric adds that there is a more fundamental reason to reject the Attorney General’s
exception. The company points out that the plain language of MCL 460.6j(13)(b) applies only to
“capacity charges associated with power purchased for periods in excess of 6 months unless the
utility has obtained the prior approval of the commission.” DTE Electric’s replies to exceptions,
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p. 3 (emphasis supplied). DTE Electric argues that because it plans to purchase capacity without
associated power, Section 6j(13)(b) does not apply, and the Attorney General’s exception is moot.
The Commission finds the PFD well-reasoned and adopts the ALJ’s findings and conclusions
on this issue. As discussed in the PFD, the Commission has addressed the concerns associated
with the approval of purchasing procedures in the June 19 and September 11, 2014 orders in Case
No. U-17496, and it concurs with the ALJ that there is no reason to revisit the matter here.
Further, the Commission observes that although DTE Electric’s argument concerning the
applicability of Section 6j(13)(b) to the purchase of capacity only appears to have some merit, the
Commission nevertheless finds that the argument, presented late in this proceeding, should be
addressed more fully in a future case if this issue is presented.
PROMOD Modeling Issues
DTE Electric forecasted its generation using a production cost simulation program, PROMOD
IV, which is widely used in the electric industry. According to DTE Electric, PROMOD simulates
economic dispatch of generation units based on multiple inputs including fuel cost and
consumption, emissions, environmental regulations, market-based electric prices, and maintenance
schedules.
MEC/SC raised concerns about the inputs and projections from DTE Electric’s modeling.
First, MEC/SC questioned the results showing the uneconomic operation of Trenton Channel 7
and 8 coal units for the plan year and unit 7 for much of the five-year forecast. Next, MEC/SC
raised concerns about the designation of all coal units as must-run, contending that this was not the
most economical option for ratepayers. Finally, MEC/SC presented its own PROMOD analysis
using corrected costs for sorbents that demonstrated significant periods of uneconomic operation
for several of DTE Electric’s coal units. MEC/SC therefore requested that: (1) the Commission
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issue a Section 7 warning that DTE Electric would be unlikely to recover costs associated with
continued operation of Trenton Channel 7 after April 2016, unless DTE Electric makes a clear
commitment to retire the unit by that time; (2) that the Commission issue a Section 7 warning that
DTE Electric would be unlikely to recover excess costs during the months when the company bids
its coal units as must-run and they operate at a loss; and (3) that DTE Electric would be unlikely to
recover the costs of certain sorbents and pollution control equipment based on the company’s
erroneous cost information and modeling.
Among other findings, some of which were uncontested, the ALJ found persuasive DTE
Electric’s rebuttal explaining that the cost difference between the company’s must-run scenario,
compared to MEC/SC’s more specific analysis, was de minimus. She further found that DTE
Electric demonstrated that the modeling it uses for PSCR planning purposes differs from the way
the company actually bids its units into the MISO market, thus addressing MEC/SC’s fundamental
concern about the company’s PROMOD modeling. The ALJ found that no warning was necessary
and that any issues concerning the company’s modeling and actual bidding could be addressed in
the reconciliation proceeding.
MEC/SC takes exception, arguing that the PFD should have better recognized the value of
accurate forecasting, an issue that is central to a PSCR plan case. As such, MEC/SC maintained
that a Section 7 warning is appropriate. MEC/SC quoted the Commission’s December 4, 2014
order in Case No. U17097, in which the Commission acknowledged the challenges of forecasting
as well as the need for the company to improve its forecasting methods in order to mitigate the
risks to both the company and ratepayers as energy and capacity markets become more
constrained. MEC/SC points out that PSCR plan cases are the only proceedings where a utility is
required to explain its projections and allow for scrutiny by the Commission and other parties.
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MEC/SC contends that “the PROMOD results are the underlying basis of the company’s filing
and, therefore, should reflect how DTE actually expects to operate its system.” MEC/SC’s
exceptions, p. 3. MEC/SC further observed that accurate modeling is essential to assuring that the
company is taking all steps to minimize the cost of fuel, as required under the act, using the
company’s practice of entering into multi-year contracts for coal as an example. According to
MEC/SC, “[o]nly through accurate forecasting can it be ensured that the amounts of coal being
contracted for are reasonable.” Id. at 4.
In response, DTE Electric repeats arguments from its brief and reply brief, namely that the
PROMOD modeling used in this proceeding is the same that the company has historically used in
PSCR and rate cases. According to DTE Electric, MEC/SC has failed to establish that the
company’s method does not achieve a reasonable level of precision, given that day-to-day
conditions may differ significantly from the projection. DTE Electric emphasizes testimony, and
the ALJ’s finding, that the company’s actual bidding of units necessarily differs from its
projection. DTE Electric reiterates that the company performs biweekly economic forecasts, on
the basis of which commitment status of individual units is established.
The Commission agrees with DTE Electric that for PSCR planning purposes the company’s
modeling with respect to unit dispatch is reasonable. As DTE Electric points out, the company
files its plan case three months before the beginning of the plan year using the best information it
has available at the time of the filing. During the course of the plan year, the must-run status of
many units is changed depending on actual conditions in the days or weeks ahead. The
Commission also recognizes MEC/SC’s concern that inaccurate modeling could cause the
company to operate obsolete units that should be retired, however, in this proceeding PROMOD is
not being used for that purpose. Indeed, decisions about plant investments or retirements require
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different inputs and a much different type of modeling than the limited analysis here, the primary
purpose of which is to develop a reasonable PSCR factor. The Commission therefore adopts the
ALJ’s analysis and conclusions on this issue.
Costs of Sorbents
DTE Electric projected the costs of sorbents to be used in conjunction with control systems to
decrease emissions of various air toxics and particulate matter as required under federal
environmental regulations. See, Exhibit A-2. DTE Electric requested that the Commission
indicate whether it is unlikely to permit recovery of these costs as reasonable and prudent costs of
fuel burned, beginning in the 2016 plan year. The Attorney General objected to DTE Electric’s
request on grounds that although Section 6j(7) (Section 7) allows the Commission to indicate
items in the five-year forecast, which, on the basis of present evidence, it may not approve
recovery, the statute does not permit the Commission to make an a priori assessment of the
reasonableness and prudence of future costs.
MEC/SC recommended that the Commission issue a Section 7 warning that the proposed costs
may be disallowed on grounds that the company’s estimates concerning the costs of the sorbents
have varied substantially from case to case and from recent estimates provided to the Michigan
Department of Environmental Quality. MEC/SC further argued that burning REF coal may
require larger amounts of sorbent and that the use of these materials may not be economically
justified. In rebuttal, DTE Electric argued that its estimates were based on the best information
from its vendors at the time the case was filed. DTE Electric added that its economic analysis of
the use of sorbents and implementation of other pollution controls was a means of screening to
determine the relative value of building new generation compared to retrofitting existing plants
with pollution controls.
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The ALJ found MEC/SC’s position on sorbent cost variability persuasive, observing that DTE
Electric presented conflicting estimates concerning the amount of sorbent that might be required
and that the more recent estimates provided by MEC/SC indicate that DTE Electric has likely
significantly understated the variable costs of pollution control measures. The ALJ determined
that, consistent with previous Commission orders, sorbent costs are the type of cost that may be
recovered as part of PSCR, however, issues concerning capital investments for related pollution
control equipment should be deferred to rate case proceedings.
MEC/SC takes exception to the ALJ’s finding on this issue. Recognizing that the
recommendation in the PFD is consistent with the Commission’s order in Case No. U-17097,
MEC/SC nevertheless maintains:
[T]hat decision does not distinguish between two distinct elements of MEC/SC’s
claims regarding [dry sorbent injection] DSI and [activated carbon injection] ACI:
(1) that DTE has not demonstrated that its decision to retrofit several aging coal
units with DSI and ACI is reasonable and prudent given that there are likely lower
cost resource options, and (2) that DTE’s PROMOD modeling does not incorporate
a reasonable projection of the variable operating cost of the planned DSI and ACI
usage on certain of the Company’s coal units.
MEC/SC’s exceptions, p. 5. MEC/SC continues by noting that a reasonable projection of the
variable costs associated with pollution control equipment is essential in a PSCR proceeding,
regardless of whether or not the investments in retrofits for pollution control are deemed
unreasonable in a rate case.
In response, DTE Electric contends that MEC/SC’s exception on this issue is improper
because it questions the Commission’s December 4, 2012 order in Case No. U-17097 (December 4
order). According to DTE Electric, the proper way to have claimed an error in the December 4
order would have been by a petition for rehearing or clarification of the order, not by attempting to
relitigate the issue in this proceeding. DTE Electric further points out that the Commission has
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repeatedly determined that issues concerning capital costs and plant retirement are appropriately
addressed in a rate case, and not in a limited PSCR proceeding, and that sorbent costs are the type
of cost that can be recovered under the PSCR.
The Commission reiterates that the plan and forecast provisions of Act 304 refer to “existing
sources of electric generation.” MCL 460.6j(3); MCL 460.6j(4). As such, the inclusion of
sorbents in a plan and forecast is appropriate. However, the Commission acknowledges that the
costs for sorbents and associated capital investments are included in DTE Electric’s pending rate
case, Case No. U-17767, and it is preferable to examine both the operations and maintenance costs
and capital costs for DSI and ACI in that proceeding. Adjustments can be made in future PSCR
proceedings based on the Commission’s determinations in the rate case.
Coal Forecast
MEC/SC contended that DTE Electric seriously underestimated the cost of coal in its five-year
forecast, pointing to the fact that the coal prices projected in this case were substantially reduced
from those in the forecast presented in the company’s previous PSCR plan proceeding. MEC/SC
added that the changed forecast deviates substantially from other industry forecasts and was
presented with no explanation. MEC/SC raised concerns that DTE Electric is making decisions on
the dispatch of its coal units, and on the feasibility of installing pollution control equipment on
these units, using a forecast that the MEC/SC contended lacked credibility.
The ALJ found that MEC/SC primarily had issues with the coal prices projected for the 20152018 forecast period, and not the 2014 plan year, and that MEC/SC was also concerned that DTE
Electric was using a flawed forecast to decide whether to retire or retrofit aging coal units. The
ALJ noted that the Commission has previously determined that a PSCR plan proceeding is not the
appropriate venue for evaluating capital expenditures and plant retirement. Issues concerning
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capital costs or plant investment decisions should be addressed in a rate case where the company
will be expected to fully justify its plans.
MEC/SC takes exception arguing that the Commission should find that DTE Electric’s coal
forecast is relevant to this PSCR plan proceeding and urging the Commission to issue a Section 7
warning to protect customers in the event the company’s forecast is too low.
In reply, DTE Electric argues that MEC/SC’s exception is without merit. Contrary to
MEC/SC’s claim, DTE Electric asserts that it provided ample explanation for its coal cost
projections for both the plan year and five-year forecast. According to DTE Electric, the company
plans to increase purchases of lower-cost western coal while decreasing purchases of more
expensive eastern coal. DTE Electric also points to the much lower costs of contract and spot coal
for 2015, compared to 2014, along with lower transportation costs.
The Commission finds that MEC/SC’s exception should be rejected. While DTE Electric’s
coal forecast in this case may have differed significantly from its previous PSCR forecast, the
Commission finds that DTE Electric’s projected coal costs were developed using the same
methods it has used in the past. The Commission further finds that the company provided
sufficient explanation for why these costs are projected to decrease, including changes in coal
blend, lower transportation costs, and reduced demand due to the expected closure of older coal
units.
Institute for Energy Innovation and Great Lakes Renewable Energy Association Proposals
The IEI asserted that DTE Electric’s five-year forecast fails to take into account cost-effective
energy efficiency opportunities that could serve to minimize the cost of fuel as required under
Section 6j(6) of Act 304. IEI also cited various sections of 2008 PA 295 (Act 295) that require the
Commission to promote energy efficiency and that allow for additional expenditures for prudent
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energy efficiency investments. Accordingly, IEI argued that DTE Electric should be directed, on a
prospective basis, to include all cost-effective energy efficiency measures in its five-year forecast.
DTE Electric opposed IEI’s proposal on grounds that it exceeds the Commission’s authority
under Act 304. DTE Electric pointed to Section 6j(4) that only requires the five-year forecast (not
“plan” as IEI described it) to contain power supply requirements of its customers and its future
sources and costs of supply, in light of its existing sources of electrical generation and sources of
electrical generation under construction. Further, DTE Electric claimed that IEI’s proposal creates
a conflict between Act 304 and Act 295.
GLREA similarly made recommendations concerning DTE Electric’s five-year forecast. In
sum, GLREA asserted that the Commission should require the company, in future plan cases, to
align its five-year forecast with the results and recommendations of a solar collaborative ordered
on December 19, 2013, in Case No. U-17302. GLREA recommended that the Commission direct
the company to continue to evaluate the benefits of solar energy and incorporate additional solar
resources as justified by its analyses.
DTE Electric opposed GLREA’s recommendations as beyond the scope of a PSCR plan
proceeding, reiterating that Act 304 requires a plan and forecast based on existing, and not
aspirational, generation. As with the recommendations supported by IEI, the company posited
that GLREA was also setting up a conflict between Act 304 and Act 295.
Concerning the issue raised by IEI, the ALJ found that the Commission “has clearly indicated
that it does not want to review generalized arguments regarding energy efficiency and
conservation opportunities in PSCR plan cases,” observing that the Court of Appeals has affirmed
that the Commission, in its discretion, may consider energy efficiency in PSCR plan proceedings,
but it is not required to do so. PFD, p. 86. The ALJ continued, quoting the March 6, 2014 order in
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this case wherein the Commission stressed that the scope of the PSCR plan and forecast is limited
by statute and prior Commission holdings. The ALJ therefore declined to recommend that the
Commission order DTE Electric to provide the additional analyses concerning energy efficiency
requested by IEI.
With respect to GLREA’s recommendations, the ALJ found that, to the extent that DTE
Electric incorporates its renewable portfolio into its PSCR forecast, it should be expected to do so,
and there is no evidence that the company’s forecast does not correspond to DTE Electric’s most
recently approved renewable energy plan. Concerning GLREA’s recommendation that the fiveyear forecast include analysis of the benefits associated with expanded solar energy, the ALJ
determined that this issue should be presented in a renewable energy plan case, in accordance with
past Commission determinations.
IEI takes exception to the ALJ’s recommendation arguing that the ALJ relied too much on
prior Commission orders and that the Commission is in a position to reconsider the incorporation
of expanded energy efficiency in PSCR plan cases, which it again argues is the most appropriate
forum for these issues.
GLREA also takes exception to the ALJ’s recommendation concerning the inclusion of solar
energy in the PSCR plan and forecast. According to GLREA, the fact that DTE Electric’s PSCR
five-year forecast is consistent with the company’s most recent renewable energy plan does not
make the forecast per se reasonable and prudent. GLREA further posits that even if the forecast is
limited to existing generation, the forecast misstates the power supply requirements of DTE
Electric’s customers because it fails to account for the expansion of customer and communityowned solar generation. GLREA argues that DTE Electric’s five-year forecast showing stable or
declining solar generation is contradicted by independent analyses showing growth in customer-
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owned solar. GLREA adds that the proposed forecast is inconsistent with Governor Rick Snyder’s
recent pronouncements on Michigan’s energy future, which will involve a significant expansion of
renewable generation resources.
In reply, DTE Electric asserts that GLREA’s exceptions do not challenge any specific findings
or conclusions in the PFD. According to DTE Electric, GLREA does not cite any law or evidence
to support its objections to the PFD and, as such, GLREA’s exceptions do not comport with Mich
Admin Code, R 792.10435. DTE Electric points out that GLREA’s first exception (that inclusion
in the PSCR plan and forecast of the level of renewable energy in the company’s most recent REP
is per se reasonable) is to a finding that the ALJ did not make. Likewise, DTE Electric contends
that GLREA’s second exception (that “flawed and incomplete” forecasts may be approved simply
because issues concerning renewable energy may be addressed in REP or rate case proceedings)
was not a finding in the PFD.
The Commission finds the PFD well-reasoned, and it adopts the findings and conclusions on
these issues. As an initial matter, the Commission observes that the energy landscape and the
utility regulatory paradigm are undergoing rapid transformations, many of which have arisen after
this case was filed. There is no question that recent changes, including constrained capacity
markets, possible changes to Act 295 and other energy laws, and new federal environmental
regulations suggest a need to look more holistically at energy supply and demand projections and
diverse options to meet electricity needs in a cost-effective manner in the future. The Commission
acknowledges that the fragmented nature of current regulatory proceedings that deal with fuel and
capital investment decisions is challenging and may not lead to the best long-term solutions for
utility customers. That said, the direction that Michigan will take in addressing its energy future is
uncertain, thus, the Commission is reluctant to make significant changes to the requirements for
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PSCR plans and forecasts. Nevertheless, the issues that IEI and GLREA raise here, appropriately
addressed by the ALJ for the purposes of this proceeding, have some merit and may be revisited in
future proceedings.
THEREFORE, IT IS ORDERED that:
A. DTE Electric Company’s application for a power supply cost recovery plan for 2014
metered jurisdictional electric sales is approved.
B. DTE Electric Company’s five-year forecast is accepted as set forth in the order.
C. DTE Electric Company is authorized to implement a 2014 maximum monthly power
supply cost recovery factor of 1.08 mills per kilowatt-hour.
The Commission reserves jurisdiction and may issue further orders as necessary.
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Any person desiring to appeal this order must do so in the appropriate court within 30 days
after issuance and notice of this order, pursuant to 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
West Saginaw Hwy, Lansing, MI 48917.
MICHIGAN PUBLIC SERVICE COMMISSION
________________________________________
John D. Quackenbush, Chairman
________________________________________
Greg R. White, Commissioner
________________________________________
Sally A. Talberg, Commissioner
By its action of May 14, 2015.
________________________________
Sally Wallace, Acting Executive Secretary
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