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Planning beyond Rate Cases: Michigan Orders Utilities to File Five-Year Distribution Investment and Maintenance Plans

In November 2018, the Michigan Public Service Commission (MPSC) issued an order setting a date of June 30, 2020, for Consumers Energy Company (Consumers) and DTE Electric Company (DTE) to file updates to their five-year distribution investment and maintenance plans. The order provided guidance on what should be included in the next versions of the plans.

Key Details of Michigan’s Electric Grid Distribution Plans

  • In 2017, the MPSC launched an initiative to provide increased visibility needed for comprehensive evaluation of distribution investments beyond the 12-month snapshot typically used in utility rate cases.
  • A rapidly evolving energy landscape, increasing distribution investment, aging infrastructure, reliability concerns, and the need to incorporate advanced technologies (such as distributed energy resources and electric vehicles) motivated the MPSC to launch the initiative
  • The order requires that investments be examined through a transparent process complete with stakeholder engagement and analysis of the short- and long-term implications of proposed investments
  • Consumers and DTE filed their initial five-year distribution investment and maintenance plans in April 2018
  • In September 2018, MPSC staff issued its “Michigan Distribution Planning Framework,” which included seven recommendations regarding proposed disclosures for the utilities’ next set of distribution and maintenance plans
  • The subsequent MPSC order provides guidance to the utilities on what should be included in the next version of the plans along with next steps for additional elements not required in the next set of plans:
  • Dynamic System Load Forecasting – The MPSC chose not to require utilities to have a dynamic approach to load forecasting but encourages use and discussion of advanced forecasting methods
  • Publicly Available Hosting Capacity Information – Rather than requiring utilities to publicize hosting capacity studies, the MPSC believes the next step is to hold a technical conference in order to gather information on hosting capacity studies
  • Consumer Data Access and Enablement – While the MPSC chose not to prescribe a particular platform for customer data access, it made it clear that it expects utilities to provide consumers with consumption data in an easy-to-use and timely manner
  • Non-Wires Alternatives – The MPSC chose to not require utilities to publish suitability criteria for non-wires alternative (NWA) projects nor cost information for alternative approaches to capacity investments but believes further discussions related to criteria for NWAs should take place
  • Cost-Benefit Analysis – The MPSC chose not to require the utilities to create a common cost-benefit methodology but believes a technical conference focused on a common cost-benefit methodology would be beneficial
  • Replacement/Upgrade Criteria – The MPSC did not adopt the staff’s recommendation to develop replacement/upgrade criteria for aging assets due to concerns about a one-size-fits-all approach
  • Workforce Adequacy Plans – The MPSC also decided not to require utilities to include a workforce adequacy and development plan in their next distribution plan, as it believes the focus should be on the implementation

Implications

In its order, the MPSC addresses what have become common elements of utility distribution plan filing requirements, such as California’s Distribution Resource Plans, New York’s Distributed System Implementation Plans, and Minnesota’s Integrated Distribution Plans. Rather than require utilities disclose everything recommended by the MPSC staff, the MPSC opted for further exploration, discussion, and technical conferences on various issues. While these activities may ultimately result in additional requirements for Michigan’s utilities, both before and after their next five-year distribution investment and maintenance plan filings due in mid-2020, these activities could also provide opportunities to create more efficient filing processes in the long run.

More Information

Michigan Public Service Commission: Case No. U-20147, Filing No. 0029

Michigan Public Service Commission: Case No. U-20147, Filing No. 0017

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