In comments written by Senior Consultant Wil Gehl, the Michigan Attorney General, Citizens Utility Board of Michigan, and Michigan Municipal Association for Utility Issues advocated for strong extreme weather shutoff protections that apply to all regulated utilities. We argued that seasonal shutoff moratoria, instead of event-based shutoff practices, are necessary during predictable high-risk periods of extreme heat, cold, and poor air quality. Seasonal moratoria protect households from being disconnected just before extreme weather events if forecasts are wrong or conditions escalate faster than expected. We also recommended lower barriers to service restoration, requiring consideration of air quality as an additional protective measure, and robust reporting mechanisms.

On behalf of the Citizens Utility Board of Michigan, Lead Consultant Rick Bunch argued that Consumers Energy’s proposed $460 million rate increase is unreasonable because residential customers already pay high rates, experience poor reliability, and are being asked to absorb cost growth far exceeding inflation without clear evidence of productivity gains or improved service. He recommended limiting baseline O&M spending to productivity‑adjusted inflation, disallowing about $59.5 million in excess costs, and supporting only targeted reliability surge spending—especially for tree trimming and pole replacements—while treating most of those surge costs as regulatory assets eligible for securitization rather than full rate recovery. Bunch called for sharply scaling back undergrounding, rejecting proposed storm cost recovery mechanisms that shift risk to customers, and reforming cost allocation so residential customers are not paying most reliability costs while receiving a small share of the benefits. 

On behalf of Natural Resources Defense Council, Sierra Club, and Citizens Utility Board of Michigan, Managing Partner Douglas Jester argued that Consumers Energy’s proposed rate increase reflects a temporary “surge” in distribution spending driven by years of deferred maintenance—especially tree trimming and pole replacements—that should be deferred and securitized rather than placed into rate base to protect current customers from paying for past failures and to align cost recovery with future reliability benefits. Jester also recommended that the company fully electrify its light-duty vehicle fleet by 2030 and urged the Commission to require stronger active managed charging, longer‑term and more flexible DC fast‑charging incentives, greater focus on multifamily access, and new pilots for battery‑integrated fast chargers and vehicle‑to‑grid school buses. 

On behalf of Natural Resources Defense Council and Citizens Utility Board of Michigan, Lead Consultant Rick Bunch testified that DTEE’s proposed rate increase is excessive and would worsen already high electricity costs and energy burdens for residential customers, particularly low‑income households. Bunch recommended reducing DTEE’s requested revenue increase by $92 million, aligning operating and capital spending with historical levels, deferring surge costs caused by past under-maintenance for possible future securitization, and maintaining five-year tree-trimming cycles. He also showed that DTEE’s cash‑only payment requirement for customers actually increases costs and uncollectible expenses rather than reducing them, urging the Commission to require further justification and stronger customer assistance measures. 

On behalf of Michigan Environmental Council, Natural Resources Defense Council, Sierra Club, and Citizens Utility Board of Michigan, Senior Consultant Graham Woolley generally supported DTEE’s Transportation Electrification Plan but recommended targeted changes to reduce costs, improve fairness, and better use existing grid assets. He argued that managed EV charging  should become a permanent, expanded program, while warning that DTEE’s cost‑benefit analysis understates the plan’s value by being too narrow and short‑term. Woolley also found that DTEE’s transformer system has plenty of unused capacity, meaning widespread grid upgrades are not yet needed and any future spending should be justified with detailed, location‑specific evidence. 

On behalf of the Michigan Environmental Council, Natural Resources Defense Council, and Citizens Utility Board of Michigan, Managing Partner Douglas Jester successfully opposed DTEE’s attempt to raise the bar for Commission disallowances of poorly supported cost projections, showing that cost review creates necessary cost discipline that a regulated monopoly would otherwise not face. He also successfully argued against using inflation‑adjusted averages to predict future costs, pointing out that DTEE would have no incentive to become more efficient and productive if it were assured that it could always mark up its rates to fully recover increased costs. He recommended disallowing $1.7 million in Midwest Energy Resources Company fuel-handling O&M expenses, securitizing the costs of replacing old equipment and fixing pas maintenance failures, and requiring seasonal distribution rates to better align prices with system costs, improve equity among customers, and encourage efficient energy use.