In his role as Executive Director of the Michigan Municipal Association for Utility Issues, 5 Lakes Energy Senior Consultant Rick Bunch testified against DTE’s proposed returns on its streetlighting services. He noted that DTE’s streetlight rates have increased by about 35% since 2016, despite the number of streetlights it serves increasing by less than 4% in that period. Bunch argued that DTE’s capital expenditures on streetlighting services are unreasonable; criticized the company for operations and maintenance failures that lead to poor outage performance; and challenged its practice of over-illuminating streets, which wastes energy and causes light pollution and negative public-health, environmental, and climate impacts.

On behalf of the Michigan Environmental Council, Natural Resources Defense Council, Sierra Club, and Citizens Utility Board of Michigan, 5 Lakes Energy Senior Consultant Rob Ozar urged the Michigan Public Service Commission to reject DTE Electric Company’s proposed rate recovery and return on its vegetation management and pole/pole-top-hardware inspection programs, arguing that those programs do not reflect industry standards and best available practices for outage prevention and fiscally prudent investment. For example, he maintained that an approach focusing more attention on circuits that are high-risk for outages would serve customers better than the utility’s uniform, systemwide 10-year cycle for tree inspections.

On behalf of the Attorney General of Michigan and Citizens Utility Board of Michigan, 5 Lakes Energy Senior Consultant Rick Bunch testified against DTE’s proposed Prepay Billing Program. Bunch questioned the value of the purported benefits for DTE customers and noted they could be achieved without asking customers to waive their rights per the proposed Billing Practice Rules. He also argued that customers should (and would expect to) be charged a lower electricity rate in return for paying in advance.  He further criticized the program’s design for failing to meet the needs and protect the interests of low-income customers.

5 Lakes Energy Senior Consultant Ram Veerapaneni argued that a 3-year average of End User Transportation power generation volumes should be used in setting DTE Gas Company’s rates, rather than the 5-year average proposed by the company. His testimony noted that DTE’s filing proposed using 3-year averages to predict many of its operating volumes, costs and revenues, and that DTE appeared to “use 3 year or 5-year averages…for various items depending on when the numbers are advantageous to support a higher rate increase.”

On behalf of Michigan Environmental Council, Natural Resources Defense Council, Sierra Club, and the Citizens Utility Board of Michigan, 5 Lakes Senior Consultant David Gard presented a production cost allocation analysis using the Probability of Dispatch method, which more accurately reports the time value of asset-specific utility expenses. Based on that analysis, he recommended that the Michigan Public Service Commission require utility companies to report plant-level investment and expense data and comprehensive hourly load data in future rate cases.