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STATE OF MICHIGAN  
BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION  
3 In the matter, on the Commission's  
own motion, to promulgate rules  
4 governing electric interconnection  
and distributed generation and to  
5 rescind legacy interconnection and  
net metering rules.  
Case No. U-20890  
Volume No. 1  
6 _____________________________________/  
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PUBLIC HEARING  
Proceedings held in-person and via Microsoft  
Teams in the above-entitled matter before Dennis W.  
Mack, J.D., Administrative Law Judge with MOAHR, at  
the Michigan Public Service Commission, 7109 West  
Saginaw Highway, Lake Michigan Room, Lansing,  
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Michigan, on Wednesday, October 20, 2021, at 9:03 a.m.  
14 APPEARANCES:  
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BENJAMIN J. HOLWERDA,  
Assistant Attorney General  
7109 West Saginaw, Floor 3  
Lansing, Michigan 48917  
On behalf of the Michigan Public Service  
Commission Staff  
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24 REPORTED BY: Lori Anne Penn, CSR-1315  
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Penn Reporting, LLC - lori.penn@yahoo.com  
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Lansing, Michigan  
Wednesday, October 20, 2021  
At 9:03 a.m.  
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(Public hearing commenced pursuant to due notice.)  
JUDGE MACK: Good morning. This is a  
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public hearing on the Michigan Public Service  
Commission's own motion to promulgate rules governing  
electric interconnection and distributed generation and  
to rescind legacy interconnection and net metering rules.  
This is Case No. U-20890.  
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My name is Dennis Mack, I'm an  
Administrative Law Judge for the Michigan Office of  
Administrative Hearings and Rules, and I will be  
conducting this public hearing today.  
We have -- Mr. Holwerda, would you like  
to enter your appearance at this time.  
MR. HOLWERDA: Certainly. Good morning,  
your Honor. Ben Holwerda appearing on behalf of  
Commission Staff.  
JUDGE MACK: Thank you. Commission Staff  
is present here today, and any questions for them  
regarding the proposed rules can be directed through  
Mr. Holwerda.  
Consistent with the September 9 of 2021  
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Order and Notice of Hearing, this is the date and time  
for the public to provide comment to the Commission on  
the proposed rules either in person or remotely. The  
Notice was published in the Grand Rapids Press, the  
Mining Journal, and the Oakland Press. In addition,  
written comment may be submitted to the Commission's  
e-docket under Case No. U-20890 by close of business on  
November 1, 2021.  
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At this point, I will note that no one  
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has appeared at the Commission's office to submit  
comment. Is there anybody who is participating remotely  
who would like to make comment on the rules?  
I will note for the record that no one  
has requested that they would -- to make comments.  
At this point, let's go off the record.  
I will come back on the record at 9:15 and see if anybody  
appears or anybody remotely wants to make comment. So  
we'll be in recess until 9:15.  
(At 9:05 a.m., there was a ten-minute recess.)  
JUDGE MACK: We are back on the record.  
No one has appeared at the Commission's office to submit  
comment. Is there anyone participating remotely who  
would like to comment on the proposed rules?  
I would like to note for the record that  
no one has requested the opportunity to submit comment,  
Penn Reporting, LLC - lori.penn@yahoo.com  
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so we will conclude this public hearing.  
MR. TIDWELL: Actually, Judge, if you  
don't mind me adding, for those that have been muted on  
the phone, *6 to unmute.  
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JUDGE MACK: O.K. So let's note that.  
If you want to submit comment and you are online, hit *6  
and you can indicate a desire to submit comment.  
And again, I will note no one has  
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requested the opportunity to submit comment, so we will  
conclude this public hearing. We're off the record.  
Thanks, everybody.  
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(At 9:16 a.m., the public hearing concluded.)  
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Penn Reporting, LLC - lori.penn@yahoo.com  
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C E R T I F I C A T E  
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I, Lori Anne Penn (CSR-1315), do hereby  
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certify that I reported in stenotype via Microsoft Teams  
the proceedings had in the above-entitled matter, that  
being Case No. U-20890, before Dennis W. Mack, J.D.,  
Administrative Law Judge with Michigan Office of  
Administrative Hearings and Rules, for the Michigan  
Public Service Commission, 7109 West Saginaw Highway,  
Lansing, Michigan, on Wednesday, October 20, 2021; and do  
further certify that the foregoing transcript, consisting  
of Volume 1, pages 1-5, constitutes a true and correct  
transcript of my stenotype notes.  
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Lor
Penn Reporting, LLC  
lori.penn@yahoo.com  
October 21, 2021  
23 Dated: ______________________________  
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Penn Reporting, LLC - lori.penn@yahoo.com  
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STATE OF MICHIGAN  
BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION  
3 In the matter, on the Commission's  
own motion, to promulgate rules  
4 governing electric interconnection  
and distributed generation and to  
5 rescind legacy interconnection and  
net metering rules.  
Case No. U-20890  
Volume No. 2  
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PUBLIC HEARING  
Proceedings held in the above-entitled matter  
before Christopher Saunders, J.D., Administrative Law  
Judge with MOAHR, at the Michigan Public Service  
Commission, 7109 West Saginaw Highway, Lake Michigan  
Room, Lansing, Michigan, on Wednesday, June 22, 2022,  
at 9:01 a.m.  
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14 APPEARANCES:  
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MONICA M. STEPHENS,  
Assistant Attorney General  
7109 West Saginaw, Floor 3  
Lansing, Michigan 48917  
On behalf of the Michigan Public Service  
Commission Staff  
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24 REPORTED BY: Lori Anne Penn, CSR-1315  
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Penn Reporting, LLC - lori.penn@yahoo.com  
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Matthew Paul  
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Lansing, Michigan  
Wednesday, June 22, 2022  
At 9:01 a.m.  
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JUDGE SAUNDERS: Good morning. This is a  
public hearing on the Michigan Public Service  
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Commission's own motion to promulgate rules governing  
electric interconnection and distributed generation and  
to rescind legacy interconnection and net metering rules.  
This is Case No. U-20890. For the record, my name is  
Christopher Saunders, I'm an Administrative Law Judge for  
the Michigan Office of Administrative Hearings and Rules,  
and I will be conducting this public hearing today.  
Now, present we do have Staff, and we do  
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have counsel present on behalf of Staff. So  
Ms. Stephens, would you like to place your appearance on  
the record, please.  
MS. STEPHENS: Yes, your Honor. Good  
morning. Monica Stephens on behalf of MPSC Staff.  
JUDGE SAUNDERS: Thank you so much. As I  
indicated before, the Commission Staff is present here  
today, and any questions for them regarding the proposed  
rules can be directed through Ms. Stephens.  
Now, a public hearing in this matter was  
previously held on October 20 of 2021, and on April 14 of  
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2022, Consumers Energy Company and DTE Electric Company  
filed a joint petition for rehearing. On May 12 of 2022  
the Commission entered an order granting the petition for  
rehearing. Additionally, on May 26 of 2022, the  
Commission issued an order and notice of hearing setting  
this as the date and time for the public to provide  
comment to the Commission on the proposed rules. The  
notice was published in the Mining Journal and the  
Oakland Press. Additionally, written comments may be  
mailed to the Commission or submitted to the e-docket  
under Case No. 2- -- or strike that -- under Case No.  
U-20890. Written comments must be submitted by 5:00 p.m.  
Eastern Standard Time on June 27 of 2022.  
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Now, we do have I know one individual  
present who would like to make some comments. So, sir,  
would you like to step forward and please make your  
comments, and I'll ask you to identify yourself for the  
record. Will you please give me your name, state and  
spell your name, and then give me your affiliation,  
please?  
MR. PAUL: You bet, Judge. Thank you.  
Matthew Paul, I'm with DTE Energy. Sorry.  
M-a-t-t-h-e-w, last name P-a-u-l.  
JUDGE SAUNDERS: Thank you so much.  
MR. PAUL: Is it O.K. if I just sit here?  
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JUDGE SAUNDERS: Oh, absolutely. Please,  
Mr. Paul, have a seat. Would you like to go ahead and  
proceed forward in terms of your comments?  
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MR. PAUL: Yes. Thank you, Judge.  
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JUDGE SAUNDERS: Thank you so much.  
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MR. PAUL: Good morning. My name is Matt  
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Paul and I am the Executive Vice President for  
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Distribution Operations at DTE Electric, or DTE, and I'd  
like to thank all of you for providing me with the  
opportunity to share with the Judge, the Commission,  
Staff, and other shareholders, stakeholders, our  
perspective and experience regarding the interconnection  
rules and their potential impact on the safety and  
reliability of electric service in Michigan. At DTE we  
support the State of Michigan's MI Healthy Climate Plan  
and appreciate the interest in exploring potential  
interconnection rule changes that ensure safe, clean, and  
reliable electric service for everyone. DTE is fully  
committed to providing a positive customer experience for  
all customers, and I'm proud to say that since 2010 we've  
interconnected over 6,000 distributed energy resource, or  
DER, projects to our distribution system. This morning I  
would like to highlight our thoughts on a few significant  
safety and reliability operational concerns that stem  
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from the revised rules regarding the interconnection of  
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DERs.  
DTE Electric serves over 2 million  
customers in Southeast Michigan across a service  
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territory that covers over 7,600 square miles, with a  
distribution system that includes over 31,000 miles of  
overhead lines, and over 16,000 miles of underground  
lines. Our employees live in the communities we serve,  
and we do our very best to anticipate challenges and  
deliver the energy everyone needs and wants with  
excellent power quality and reliability.  
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At DTE we recognize that our customers  
share our enthusiasm for clean energy, and we know that  
many want to be more involved in their energy supply,  
thus we strive to accommodate DER interconnection  
requests as quickly and safely as possible. In that  
spirit, I would like to provide the following comments on  
the revised interconnection rules.  
So the first area I'd like to speak of is  
around our concerns that the revised rules pose  
significant safety and reliability concerns. I'm going  
to break that down into two areas; the first is  
inadvertent exports.  
The electric grid, and our customers who  
depend on it, are very sensitive to even small changes.  
Voltage levels and other power quality characteristics  
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need to be maintained within a narrow band at all times.  
When DERs are exporting power back into the grid through  
an interconnection, it is critical that the amount of  
this reverse power flow is maintained within the tight  
limits of the distribution equipment on the grid side of  
the interconnection. Any reverse power flow above  
prescribed limits is called an inadvertent export. It is  
also critical that any disturbances from potential issues  
with DER equipment, that could cause a higher than  
allowed reverse power flow, occur for only a very short  
amount of time, which under the former rules was measured  
in milliseconds. The revised rules allow for potentially  
repeated inadvertent reverse power flow for up to 32  
seconds. With respect to grid equipment stability, 32  
seconds is a very long time, and these power disturbances  
could cause significant damage to grid or customer  
equipment such as transformers or appliances, or even  
cause equipment fires or arc flashes, any of which might  
pose safety risks to our employees or to the public. The  
inadvertent export definitions included in the revised  
rules are inconsistent with industry standards and  
practices and pose significant challenges to operating  
the grid safely and reliably. Accordingly, DTE requests  
that these definitions be removed from the rules.  
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The second area under the safety and  
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reliability concern is around screening criteria.  
As the owner and operator of the  
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distribution grid, DTE Electric is required to study and  
assess the potential impacts of any customer attachment  
or changes to the grid. These assessments have  
historically been performed using industry accepted  
screening criteria applied to each individual proposed  
interconnection.  
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For DERs, which can introduce changes to  
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power flowing either to or from the grid, the  
interconnection process was developed specifically to  
ensure that utilities carefully assess the safety and  
integrity impacts of the specific proposed DER  
interconnection before approving the application. The  
recent changes to the interconnection rules constrain  
DTE's ability to perform a complete technical assessment  
by limiting the screening criteria that utilities can  
apply. Reducing the screening criteria may in some cases  
lead to DER installations that cannot be reliably and  
safely supported by the distribution grid, which in turn  
can result in potentially dangerous overload conditions.  
Accordingly, DTE requests that the rules allow for the  
incorporation of additional screening criteria in order  
to adequately assess safety and reliability for each  
individual interconnection situation.  
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The second major concern I'd like to  
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communicate, second area of major concern is around our  
view that it's really important that DER owners fund the  
studies required to assess the safety and reliability  
aspects associated with interconnecting to the grid so  
that the financial burden of those studies is not borne  
by the remaining customers or the non-DER-owning  
customers.  
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As I mentioned earlier, it's critical  
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that DTE carefully assess the safety and reliability  
impacts of all proposed DER interconnections. Connecting  
DERs is technically complicated and requires significant  
time and effort. The cost of any studies and any grid  
upgrades needed to support DER interconnection should be  
paid for by the DER owners. The revised rules, however,  
set arbitrary caps which complicate the full and fair  
cost recovery of these studies, which in turn risks  
potentially shifting a portion of these costs from DER  
owners to our remaining customers, including those  
customers that may be least able to afford it.  
DTE requests that the Commission simplify  
and clarify these rules to ensure that DER owners fund  
the full cost of the aforementioned studies.  
This concludes my comments on behalf of  
DTE. Thank you very much for this opportunity and for  
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your time and consideration.  
JUDGE SAUNDERS: Thank you so much,  
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Mr. Paul.  
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All right. Is there anyone else present  
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who would like to make comments this morning? (No  
response.)  
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O.K. Why don't we take a brief recess  
off the record here.  
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(Recess from 9:11 a.m. until 9:28 a.m.)  
JUDGE SAUNDERS: O.K. Back on the  
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record, and the record should reflect that we did take a  
brief recess to just allow anyone else the opportunity to  
arrive who might wish to make a comment. For the record,  
I'll ask one more time, is there anyone else present who  
would like to make a comment this morning? (No  
response.)  
O.K. Hearing no response, the record  
should reflect that there is no one else present who  
wishes to make a comment this morning, so we will  
conclude this public hearing. We'll go off the record,  
and thank you everyone for your participation today.  
(Collective "Thank you".)  
(At 9:29 a.m., the public hearing concluded.)  
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C E R T I F I C A T E  
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I, Lori Anne Penn (CSR-1315), do hereby  
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certify that I reported in stenotype the proceedings had  
in the above-entitled matter, that being Case No.  
U-20890, before Christopher Saunders, J.D.,  
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Administrative Law Judge with Michigan Office of  
Administrative Hearings and Rules, at the Michigan Public  
Service Commission, 7109 West Saginaw Highway, Lansing,  
Michigan, on Wednesday, June 22, 2022; and do further  
certify that the foregoing transcript, consisting of  
Volume 2, pages 6-16, constitutes a true and correct  
transcript of my stenotype notes.  
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Penn Reporting, LLC  
lori.penn@yahoo.com  
23 Dated: June 24, 2022  
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Penn Reporting, LLC - lori.penn@yahoo.com  
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