General Offices:

One Energy Plaza

Jackson, MI 49201

LEGAL DEPARTMENT

SHAUN M. JOHNSON

Senior Vice President

and General Counsel

Tel:

(517) 788-0550

Robert W. Beach

Ian F. Burgess

Fax: (517) 768-3644

Don A. D’Amato

Gary A. Gensch, Jr.

Matthew D. Hall

Emerson J. Hilton

Georgine R. Hyden

Chantez P. Knowles

Katie M. Knue

*Washington Office:

1730 Rhode Island Ave. N.W. Tel:

Suite 1007

(202) 778-3340

MELISSA M. GLEESPEN

Vice President, Corporate

Secretary and Chief

Washington, DC 20036

Fax: (202) 778-3355

Compliance Officer

Writer’s Direct Dial Number: (517) 788-7107

Robert F. Marvin

Jason M. Milstone

Rhonda M. Morris

Deborah A. Moss*

Michael C. Rampe

Scott J. Sinkwitts

Theresa A.G. Staley

Janae M. Thayer

Anne M. Uitvlugt

Aaron L. Vorce

KELLY M. HALL

Vice President and Deputy

General Counsel

Writer’s E-mail Address: ian.burgess@cmsenergy.com

Eric V. Luoma

Adam C. Smith

Bret A. Totoraitis

Assistant General Counsel

January 6, 2022

Attorney

Ms. Lisa Felice

Executive Secretary

Michigan Public Service Commission

7109 West Saginaw Highway

Post Office Box 30221

Lansing, MI 48909

RE: MPSC Case No. U-20630 – In the matter, on the Commission's own motion, to

establish a workgroup to review the Technical Standards for Electric Service and to

recommend potential improvements to the standards.

Dear Ms. Felice:

Enclosed for electronic filing in the above-captioned proceeding, please find Comments of

Consumers Energy Company on Proposed Technical Standards for Electric Service.

This is a paperless filing and is therefore being filed only in PDF.

Sincerely,

Digitally signed

by Ian F. Burgess

Date: 2022.01.06

15:28:35 -05'00'

Ian F. Burgess

S T A T E O F M I C H I G A N

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

In the matter of the Commission’s own motion, )

to establish a workgroup to review the

Technical Standards for Electric Service and to )

)

Case No. U-20630

recommend potential improvements to the

standards.

)

COMMENTS OF CONSUMERS ENERGY COMPANY

ON PROPOSED TECHNICAL STANDARDS FOR ELECTRIC SERVICE

The Michigan Public Service Commission (“MPSC” or the “Commission”) issued its

Order and Notice of Hearing (“Order”) on October 26, 2021, in Case No. U-20630, regarding the

adoption of revised Technical Standards for Electric Service. The Order, with the proposed rules

attached, scheduled a public hearing for December 9, 2021 to allow presentations by interested

persons and set a final deadline for written comments at 5:00 pm on January 6, 2022. The proposed

rules modify the existing Technical Standards for Electric Service in Mich Admin Code, R.

460.3101 – 460.3804, which were last amended by the Commission in its December 20, 2018

Order in MPSC Case No. U-18043.

Stemming from the September 11, 2019 Commission Order in Case No. U-20464, which

includes the final Michigan Statewide Energy Assessment and associated jurisdicitonal

recommendations, the Commission opened the docket in Case No. U-20630 to estalish

workgroups, led by Staff, for the purpose of reviewing the current Technical Standards for Electric

Service and to recommend potential improvements to the standards. Consumers Energy Company

(“Consumers Energy” or the “Company”) participated in multiple stakeholder sessions, hosted by

the MPSC Staff, between December 3, 2019 and March 12, 2020. The Company also provided

1

feedback in response to two draft rules sets on August 28, 2020 and November 25, 2020, in

addition to other comments filed by Consumers Energy in the Case No. U-20630 docket.

The proposed rules will govern the electric services that the Company provides to its

electric customers; therefore, Consumers Energy has a direct interest in this proceeding. The

Company appreciates the opportunity to collaborate on revising the Technical Standards for

Electric Service, and appreciates the Staff for having taken Consumers Energy’s comments into

consideration. The Company does not have additional comments to share at this time, but

reiterates its recommendations expressed in its previous comments filed by the Company in this

Case No. U-20630 docket.

Respectfully submitted,

CONSUMERS ENERGY COMPANY

2

STATE OF MICHIGAN

DEPARTMENT OF ATTORNEY GENERAL

P.O. BOX 30755

L

ANSING, MICHIGAN 48909

DANA NESSEL

ATTORNEY GENERAL

January 6, 2022

Ms. Lisa Felice

Executive Secretary

Michigan Public Service Commission

7109 West Saginaw Highway

Lansing, MI 48917

Dear Ms. Felice:

Re:

MPSC Case No. U-20629, U-20630 and U-21150

In the matter, on the Commission’s own motion, to establish a workgroup to review the

service quality and reliability standards for electric distribution systems and to recommend

potential improvements to the standards.

In the matter, on the Commission’s own motion, to establish a workgroup to review the

Technical Standards for Electric Service and to recommend potential improvements to the

standards.

In the matter, on the Commission’s own motion, to propose revisions to the rules

governing consumer standards and billing practices of electric and natural gas utilities

regulated in accordance with 1919 PA 419, as amended; 1939 PA 3, as amended; and 1965 PA

380.

In its November 4, 2021, order in Case Nos. U-20629, U-20630, and U-21150, the

Commission requested comments from interested parties regarding the proposed

service quality and reliability standards, and also proposed revisions to rules

governing consumer standards and billing practices of electric and natural gas

utilities. The proposed service quality and reliability standards include customer

bills credits when electric utilities fail to meet specified levels of performance and

the provision for an incentive mechanism to encourage electric utilities to improve

the level of performance of the electric distribution system.

The Attorney General (AG) is pleased to provide comments that will assist the

Commission in finalizing the aforementioned standards and rules. The overriding

objective of the Attorney General is that the reliability and service quality of the

electric distribution system of Michigan utilities must improve from current levels

and there should be an urgency to achieve significant performance improvement. In

that regard, paramount in the Attorney General’s comments below are the

principles that standards and rules must be fair and reasonable to both customers

and utilities, and that the failure to achieve the stated standards and service

quality levels has financial consequences for the utilities or cooperatives under the

commission’s jurisdiction.

The Attorney General’s comments below pertain to those sections of the service

quality and reliability standards filed with the November 4, 2021 Commission order

in Case No. U-20629. Reference to utility or utilities also includes cooperatives

under the commission’s jurisdiction.

PART 1: GENERAL PROVISIONS

PART 2: UNACCEPTABLE LEVELS OF PERFORMANCE

The Attorney General does not agree with the proposed revisions to Part 1 and Part

2 of the Service Quality and Reliability Standards for Electric Distribution Systems.

As expressed in her August 27, 2020 comments (attached to these comments), the

creation of the gray sky conditions creates a greater restoration time for customers

than the prior rules that contain just normal and catastrophic conditions. In fact,

since these prior comments, it appears that the problem identified by the Attorney

General has worsened in these new revised rules. In addition, no rule has been

included to address the protecting customers in the event of a major disaster such

as the discussed in the National Association of State Utility Consumer Advocates

2019-01 resolution. A disaster preparedness plan on how the utilities plan to

respond and work with the cities, townships, police, consumer advocates, and

community groups in their territories is also needed in these rules.

As to the outage credits, the Attorney General believes the amount is still not

sufficient to address the cost incurred by customers following an electric outage. As

expressed in her prior comments in this docket and others, the outage credits need

to be automatic and the amount the credit doesn’t properly take into account all the

costs incurred by customers. The Attorney General provided a snapshot of costs

incurred by customers as a result of the summer outages and believes that the

Commission should conduct further investigation into the proper amount of the

credit. The development of a disaster relief fund, as suggested by the Attorney

General, would also help alleviate some of the burdens experienced by customers

following a lengthy electric outage. The Commission can make an addition to Part I

and create R 460.704. In R 460.704 the Commission could create the authority to

create disaster preparedness plans and require utilities to file within 6 months of

these rules being adopted to address such plans before the Commission.

Moreover, the standards define the unacceptable level if service is not restored or

the response to a wire down is not achieved in a set number of hours for at least

90% of the affected customers or incidents. As written, the standards do not provide

for a maximum acceptable service restoration time or response time for the

remaining 10% of the power outages and wire-down situations. The remaining 10%

is often the source of most customers complains when it takes several days or weeks

for customers to have electric service restored. The Commission should remove the

gray sky condition as discussed above and create maximum acceptable service

restorations times or response times. If the Commission adopts the proposed rules,

then the Attorney General recommends that the Commission establish the following

maximum service levels:

R460.722(a) All weather conditions – AG Recommendation: Maximum

restoration time within 4 days (96 hours) for 100% of all customers experiencing

sustained interruptions. No more than 50 exceptions above 96 hours will be

acceptable within a calendar year for unusual and difficult service restoration

situations.

R460.722(b) Catastrophic conditions – AG Recommendation: Maximum

restoration time within 7 days (168 hours) for 100% of all customers experiencing

sustained interruptions. No more than 100 exceptions above 168 hours will be

acceptable within a calendar year for unusual and difficult service restoration

situations.

R460.722(c) Gray Sky conditions – AG Recommendation: Maximum restoration

time within 5 days (120 hours) for 100% of all customers experiencing sustained

interruptions. No more than 50 exceptions above 120 hours will be acceptable

within a calendar year for unusual and difficult service restoration situations.

R460.722(d) Normal conditions – AG Recommendation: Maximum restoration

time within 3 days (72 hours) for 100% of all customers experiencing sustained

interruptions. No more than 10 exceptions above 72 hours will be acceptable within

a calendar year for unusual and difficult service restoration situations.

R460.723(1) Wire Down all conditions – AG Recommendation: Maximum

response time within 240 minutes (4 hours) for 100% of all first responder wire-

down notifications.

R460.723(2) Wire Down Non-Metropolitan area – AG Recommendation:

Maximum response time within 360 minutes (6 hours) for 100% of all first

responder wire-down notifications.

R460.724(b) New Service Installation – AG Recommendation: Maximum

installation time for new service requests within 30 business days.

PART 3: RECORDS AND REPORTS

R460.732 Annual report contents. AG Recommendations:

Subpart (b) through (g), should also require that the utility identify and explain all

situations where service restoration and service levels exceeded the maximum

acceptable level.

Subpart (i) through (l), should be revised to include the threshold hours for

reporting customer credits recommended by the Attorney General in section

R460.744 below.

Subpart (m), the requirement for electric utilities with 1 million or more customers

to list the 10 worst performing circuits could be very limited given the hundreds of

circuits operated by the large electric utilities. This requirement should be changed

to the top 20% worst performing circuits.

Subpart (n), the requirement for electric utilities and cooperatives with less than 1

million customers to list the worst performing 1% of circuits could be very limited

given the number of circuits operated by the large electric utilities. This

requirement should be changed to the top 10% worst performing circuits.

Subpart (q), the requirement to report the number of CELID cases for indices

CELID8hours, CELID24hours, and CELID48hours excludes reporting of other

cases between CELID8hours and 48hours and any cases longer than 48 hours. The

requirement should be changed to report cases between CELID8hours and 48 hours

in 8-hour increments and also cases above 48 hours in total.

PART 4: FINANCIAL INCENTIVES AND CUSTOMER ACCOMMODATIONS

R 460.741 Approval of incentive and penalties by the commission.

AG Recommendation: This section should be revised to add penalties to be assessed

to utilities if they fail to meet a threshold level of performance or repeatedly fail to

achieve the minimum performance standards established in R 460.722, R 460.723,

R 460.724, and R 460.151(2)(a) and (b). It is critical to create an incentive and

penalty mechanism that is symmetrical. In the approved customer rates, electric

utilities recover the cost to operate and maintain distribution facilities, including

repair costs, in order for the utilities to provide the level of service defined in the

aforementioned standards. Furthermore, electric utilities recover the cost of capital

investments, including a return on those investments. If some or all of the service

and the reliability standards are not met repeatedly year after year, customers are

not receiving the expected value for costs paid and included in rates.

Therefore, it is necessary for customers to recover the lost value in future years in

the form of penalties imposed on the utilities by the commission. Similarly, if

utilizes achieve performance levels that exceed the stated performance levels or tied

to national average reliability performance standards, they should be rewarded

with incentive payments. Furthermore, it is necessary to begin a performance

incentive and penalty mechanism with some urgency given the under-performance

of Michigan electric utilities relative to other electric utilities in the U.S. [CUB

Utility Performance Report, 2020 Edition (CUB Report), available at:

https://d3n8a8pro7vhmx.cloudfront.net/cubofmichigan/pages/1152/attachments/original

/1602176971/CUB_of_MI_Utility_Performance_Report_2020_Edition.pdf?1602176971 ]

The Attorney General recommends the following revisions:

Rule 41.

(1) The commission may authorize an electric utility or cooperative to receive a

financial incentive if it exceeds all of the service quality and reliability standards

adopted by these rules and exceeds national average reliability performance

standards. The commission may also authorize financial penalties and

increase credits to customers as provided in these rules if an electric

utility fails to repeatedly meet one or more of the service quality and

reliability standards established in R 460.722, R 460.723, R 460.724, and R

460.151(2)(a) and (b) and national average reliability performance

standards. [Bolded text proposed by AG]

(2) A request for approval of an incentive mechanism must include financial

penalties for failing to repeatedly achieve service quality and reliability

standards and national average reliability performance standards, must be

made in either of the following proceedings, and must be conducted as a contested

case under chapter 4 of the administrative procedures act of 1969, 1969 PA 306,

MCL 24.271 to 24.288: [Bolded text proposed by AG]

(a) A rate case proceeding.

(b) A single-issue proceeding filed specifically to address adoption of an incentive

program.

(3) An electric utility or cooperative shall not file an application seeking approval of

an incentive mechanism, including financial penalties and credit increases to

customers for failing to meet threshold performance levels and for failing

to repeatedly achieve service quality and reliability standards and

national average reliability performance standards, until it has exceeded all

of the service quality and reliability standards adopted by these rules continuously

for a period of not less than within 6 months from the effective date of

implementation of the service quality and reliability standards.

[Strikethrough and addition of bolded text proposed by AG]

R 460.742 Criteria for receipt of an incentive or assessment of financial

penalties: [Bolded text proposed by the AG]

Rule 42. (1) If an electric utility or cooperative qualifies has received approval for

implementation of an previously approved incentive and financial penalty

mechanism, it shall file an application seeking authority to implement the incentive

mechanism payment and/or penalty amounts at the same time that it submits the

annual report required by R 460.732. [Strikethrough and addition of bolded text

proposed by AG]

(2) An electric utility or cooperative shall not apply for qualify to receive a financial

incentive approved by the commission unless all of the following criteria were met

during the previous 12Months calendar year: [Strikethrough and addition of

bolded text proposed by AG]

(a) All required reports have been filed in a timely manner.

(b) All required reports fully comply with the requirements as determined by the

commission.

(c) The electric utility's or cooperative’s actual performance for the year shall

have exceeded achieved an overall performance score of more than 100%

above the target level for the combined service quality and reliability

standards as defined within the incentive and penalty mechanism.

Consumer Billing Standard R 460.151(2)(a) and (b) shall also be included in

the proposed incentive and penalty mechanism. [Strikethrough and addition

of bolded text proposed by AG]

(d) The electric utility or cooperative shall have fully responded to any inquiries

about the content of the reports made by the commission or its staff in a timely

manner.

(3) The commission may impose financial penalties, as defined within the

financial incentive and penalties mechanism, for an electric utility or

cooperative failing to achieve an overall service quality and reliability

standards performance score of 100% for the year or for failing to achieve

a performance standard for three or more consecutive years. [Bolded text

proposed by AG]

The Attorney General also recommends that the commission issue guidelines to the

electric utilities and cooperatives that will guide their filing for an incentive and

penalty mechanism. The Attorney General’s proposed guidelines are outlined later

in this document.

R 460.744 (Rule 44) Customer accommodations (Bill Credits) for failure to restore

service after a sustained interruption due to gray sky and catastrophic conditions.

AG Comment/Recommendation: The proposed restoration time to trigger bill

credits to customers is set at 96 hours for catastrophic conditions or twice the stated

time of 48 hours established in the performance standards defined in R 460.722.

Similarly, for grey sky conditions, the proposed restoration time to trigger bill

credits to customers is set at 48 hours or twice the stated time of 24 hours

established in the performance standards defined in R 460.722. This doubling of

the restoration time to trigger bill credits is unjust and unfair to customers. If the

standards of performance in R 460.722 are appropriate and reasonable, then it is

appropriate to use those same standards to trigger bill credits to customers when

those performance levels are not met. Therefore, the Attorney General recommends

that the performance levels to trigger bill credits to customers be set at the same

levels as those established in R 460.722 and to eliminate the gray sky condition.

R 460.745 (Rule 45) Customer accommodations (Bill Credits) for failure to restore

service after a sustained interruption during normal conditions.

AG Comment/Recommendation: The proposed restoration time to trigger bill

credits to customers is set at 16 hours or twice the stated time of 8 hours in the

performance standards defined in R 460.722. This doubling of the restoration time

is unjust and unfair to customers. If the standards of performance in R 460.722 are

appropriate and reasonable, then it is appropriate to use those same standards to

trigger bill credits to customers when those performance levels are not met.

Therefore, the Attorney General recommends that the performance levels to trigger

bill credits to customers be set at the same levels as those established in R 460.722.

R 460.746 Customer accommodations (Bill Credits) for repetitive interruptions.

AG Comment/Recommendation: The proposed number of repetitive interruptions to

trigger bill credits to customers is set at 6 instead of the stated number of 4

interruptions in the performance standards defined in R 460.722. The higher

number of repetitive power interruptions is unjust and unfair to customers. If the

standard of performance in R 460.722 is appropriate and reasonable, then it is

appropriate to use the same number of power interruptions to trigger bill credits to

customers when that performance level is not met. Therefore, the Attorney General

recommends that the performance level to trigger bill credits to customers be set at

the same level established in R 460.722.

The Attorney General also recommends that the commission make it clear that any

bill credits paid by the utilities will not be recoverable in future rate cases.

PART 5: WAIVER AND EXCEPTIONS

R 460.751 Waivers and exceptions by electric utilities.

(3) An electric utility or cooperative need not meet the standards or grant the

credits required by parts 2 and 4 of these rules under any of the following

circumstances:

(a) The problem was caused by the customer.

(b) There was a work stoppage or other work action by the electric utility's or

cooperative’s employees, beyond the control of the electric utility or cooperative,

that caused a significant reduction in employee hours worked.

(c) The problem was caused by an "act of God." The term "act of God" means an

event due to extraordinary natural causes so exceptionally unanticipated and

widespread within the utility service area, and devoid of human agency that

reasonable care would not avoid the consequences and includes any of the following:

[Bolded text proposed by AG]

(i) Flood.

(ii) Tornado.

(iii) Earthquake.

(iv) Fire caused by other than the utility or cooperative, its employees or

agents. [Bolded text proposed by AG]

(d) The problem was due to a major system failure attributable to, but not limited

to,

any of the following:

(i) An accident caused by other than the utility or cooperative, its employees

or agents. [Bolded text proposed by AG]

(ii) A man-made disaster caused by other than the utility or cooperative, its

employees or agents. [Bolded text proposed by AG]

(iii) A terrorist attack.

(iv) An act of war.

(v) A pandemic preventing the utility, or cooperative, from performing

service restorations from a power outage. [Bolded text proposed by AG]

CONSUMER STANDARDS AND BILLING PRACTICES

The Attorney General’s comment below pertain to those sections of the consumer

standards and billing practices filed with the November 4, 2021 Commission order

in Case No. U-21150

AG Comment/Recommendation: The proposed service quality and reliability

standards removed subpart (a), (b) and (c) from Rule 460.724 with the intent to

transfer those standards to the consumer standards and billing practices Rule

460.151. It appears that R 460.724 (c) was inadvertently not transferred.

Therefore, the Attorney General recommends that this standard be added to R

460.151(2)(b) to read as follows: “An electric utility shall have a complaint response

factor of 90% or more within 3 business days.”

COMMISSION GUIDELINES FOR DISTRIBUTION SYSTEM INCENTIVE AND

PENALTY MECHANISM

AG Comment/Recommendation: To guide the development of an effective incentive

and penalty mechanism that will improve the performance of the electric

distribution systems of Michigan utilities, the Attorney General proposes that the

commission direct electric utilities to file an application as soon as possible to

implement a mechanism that includes the following metrics and meets the following

guidelines.

1. Include the service quality and reliability standards in R 460.722, R 460.723, and R

460.724.

2. Include consumer standards and billing practices R 460.151(2)(a) and (b).

3. Include the utility’s annual goal to improve the SAIDI (Excl. MED).

4. Include service restoration O&M cost per incident (threeဨyear rolling average, including

MED).

5. Include an annual goal to reduce the number of customers who experienced one or more

power outages during the year of 1 hour or longer.

6. Include a metric to reduce the number of power outages from trees, wind & weather.

7. Include a metric to reduce the number of power outages from equipment failures.

8. Include a metric for the number of miles of line cleared annually for vegetation for LVD

and HVD circuits.

9. Include a metric to measure performance against national average reliability performance

standards.

10. Each standard, goal, or metric should have an appropriate weight as a percentage of

100%.

11. Annually the utility or cooperative would file the actual results showing how it performed

against each individual standard, goal or metric, and a scorecard showing how it

performed on an overall basis.

12. If the overall scorecard results exceed 100% of target, the utility or cooperative would be

eligible for an incentive payment for the year.

13. If the overall scorecard results are below100% of target and/or the utility fails to achieve

a performance standard level for three or more consecutive years the utility or

cooperative would be assessed a penalty amount for the year.

14. The incentive or penalty amount should be based on a percent of the revenue requirement

included in the Company’s current rates for distribution capital investments and O&M

expense in the most recent rolling five-year period.

15. Incentive payments and penalties should have reasonable maximum amounts to minimize

the impact of an unusual or unexpected outcome. These maximums should be set as a

percentage of the target amount.

16. If properly designed no deadband range for incentive or penalty payments should be

necessary. The deadband creates a cliff problem where as soon as the deadband is

exceeded a large payout or large penalty would need to be assessed.

These guidelines include the essential standards, goals and metrics to spur the

desired improvements to the electric distribution systems of the Michigan electric

utilities and cooperatives. The number of metrics should not be so few as to

prevents achievement of the desired outcomes, or so many as to water down the

essential metrics or make the performance measurement process unwieldy. The

Attorney General’s proposed guideline strike the appropriate balance.

The Attorney General reiterates its recommendation to the commission about the

necessity to define the key outlines of an effective performance incentive and

penalty mechanism with some specificity in order to have similar mechanisms

among the utilities. The commission should direct the utilities to present a

mechanism that follows the above-proposed guidelines within 6 months from the

implementation effective date of the service quality and reliability standards. The

performance incentive mechanisms filed by the utilities and cooperatives should be

refined through a collaborative process with Staff, the utilities, and other interested

parties before final commission approval.

In summary, the Attorney General looks forward to assist the Commission and

other parties participating in this difficult undertaking to reduce power outages and

improve the reliability of electric service provided by Michigan utilities.

Sincerely,

Digitally signed by Michael

Moody

Date: 2022.01.06 16:51:02

-05'00'

Michael

Moody

Michael E. Moody (P51985)

Assistant Attorney General

Michigan Department of Attorney General

Special Litigation Division

cc:

All Parties

STATE OF MICHIGAN

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

* * * * *

In the matter, on the Commission's own motion, to )

establish a workgroup to review the Service Quality )

and Reliability Standards for Electric Distribution )

Systems and to recommend potential improvements )

Case No. U-20629

to the standards.

)

__________________________________________)

In the matter, on the Commission's own motion, to )

establish a workgroup to review the Technical

Standards for Electric Service and to recommend

potential improvements to the standards

)

Case No. U-20630

__________________________________________)

COMMENTS OF THE MICHIGAN ELECTRIC AND GAS ASSOCIATION

Introduction

The MEGA companies¹appreciate the MPSC staff’s efforts to provide an open forum to discuss

and collect feedback on the myriad of issues raised as part of the review of the Grid Security and

Reliability Standards Workgroups. MEGA has engaged in the discussions to represent the unique

position of small utilities to ensure the staff and other stakeholders understand how the impacts

of potential changes can vary from that of larger utilities. These comments come from that

perspective.

Service Quality Standards (U-20629)

The MEGA companies offer the following feedback on the Service Quality Standards:

¹The MEGA companies are Alpena Power, Citizens Gas Company, Indiana Michigan Power Company, Michigan Gas

Utilities, Northern States Power-Wisconsin, SEMCO Energy, Upper Michigan Energy Resources Company, Upper

Peninsula Power Company.

Definitions (460.702)

MEGA has several comments or suggestions related to the new or modified definitions on

section 460.702.

The definition of utility in 460.702 (i) does not make it clear whether transmission-caused

interruptions should be included in its tracking and reporting or not.

Grey Sky Conditions (460.722)

In the proposed Rule 22(e) and (f), grey sky conditions are excluded from (e) and included in (f).

Annual Reporting Requirements (460.732)

The MEGA companies would appreciate the opportunity to see and comment on the staff format

for annual reporting as part of the development process. In addition, the following suggestions

apply to the reporting requirements:

• 460.732(o) should apply to worst performing segments, not circuits. Using segments will

directly point to areas of the system with repetitive issues. An exemption of this

requirement for small utilities would also be appropriate since they have relatively few

circuits and therefore the data wouldn’t provide the type of insight that might be gained

for a larger utility.

• 460.732(p) same device would be a better measure than circuit, or use CEMI, SAIDI,

SAIFI, CAIDI as better indicators state of the system overall. Similar to subsection (o)

above, an exemption for small utilities would be appropriate due to the lack of value in

the data.

• 460.732(s) consider an exemption for small utilities or recognition that some utilities

don’t have the systems capability to make this information readily obtainable or valuable.

Annual Report Momentary Outages (460.732(r))

There are several concerns with both the value of the data collected and reporting of momentary

outages as required in 460.732(r), particularly as it applies to small utilities, and especially on a

quarterly basis and MEGA would like this requirement eliminated.

First, as previously stated on this issue in the stakeholder process and in previous comments, the

data will not distinguish between “good” momentary outages that are designed into the system to

avoid widespread outages, and “bad” momentary outages that are truly a system failure and

cause for concern. Further, some small utilities do not have equipment that would collect this

data, and for some that have AMI, it is relatively new or in the implementation phase.

Second, expensive software upgrades will be required even for those that have advanced meters.

If the requirement is retained, MEGA requests an exemption for small utilities is appropriate or

having a threshold for companies with “mature” AMI based on the amount of penetration in the

system or number of years since full deployment.

Outage Credits (460.744 - 460.746)

The MEGA companies accept the increase in the amount of the outage credit, but annual

adjustments are cumbersome for small utilities.

Some MEGA utilities do not have systems in place to automate the credits which will be costly

to incorporate and may require significant manual processing. MEGA also has concerns with the

proposal that credits should be prohibited from recovery. As noted, these credits are intended to

be some compensation for customers experiencing outages but are not a penalty. Any amount

associated with these credits would be better spent on continued improvements to the distribution

system to avoid other issues in the future.

MEGA suggests the following changes:

• Revisiting the amount on a periodic basis, but five years or more would be more

meaningful to minimize short-term volatility in the number of billing system changes that

would be needed.

• Providing a date certain for the new credits to take effect. This provides certainty to both

customer and the utility, providing the utility some time to update its systems accordingly

to reflect the new credit. For example, if the commission were to issue an order in the

Fall by September 30, the new amount should give, at minimum, six months for utilities

to update their systems.

Outage Credit Thresholds – Repetitive Interruptions (460.746)

The reduction of the threshold of same circuit repetitive outages in 460.746 should include an

exemption for rural utilities that keeps the threshold at 7 or identify a threshold of customer

complaints for small/rural utilities with a required report about how the issue will be addressed.

No basis has been provided to support the need to change this number or the specific reduction

proposed.

Technical Standards for Electric Service Rules (U-20630)

Annual Line Clearing Report (460.3203(i))

MEGA appreciates the accommodation for small utilities from having to file a quarterly line

clearing report. As discuses in prior comments, the line clearing plans included in the small

utility rate cases have not been a source of controversy or concern. The level of data requested,

and quarterly reporting would require a significant amount of manual work to report.

MEGA notes that the customer threshold for defining a small utility has traditionally included all

the MEGA members, and MEGA requests that the customer count threshold be increased to

recognize that longstanding principle.

Solid State Meter Reporting: (460.3203(j))

Some small utilities have not yet adopted and/or are early in the process of adopting solid state

meters. As such, the requested data is either not available or data systems not currently structured

to collect or report the data as stated in the rule.

MEGA requests either an exemption for small utilities, limiting the data required to subsection

(ii) that describes how the small utility uses the data, or threshold of time after adoption of solid-

state meters would be an appropriate accommodation for small utilities.

Extension of Electric Service: (460.3411(16))

MEGA maintains the addition of this new requirement is unnecessary. Utilities should remain

responsive to customer requests for meetings and adding language to this Rule implies that there

remain unresolved issues with Rule 411. There have been court decisions and law changes in

recent years that have provided clarification of some gray areas, but at this time, the rule and

framework surrounding it are understood and working well. MEGA does not believe any

revisions are necessary.

Conclusion

MEGA reiterates its thanks to the Commission and the staff for their engagement on these topics

and consideration of these comments.

Sincerely,

Dated: January 6, 2022

Daniel Dundas

President

Michigan Electric and Gas Association

January 6, 2022

Ms. Lisa Felice

Executive Secretary

Michigan Public Service Commission

7109 W. Saginaw Highway

Lansing, MI 48917

Re: Case U-20630

In the matter, on the Commission's own motion, to establish a workgroup to review the

Technical Standards for Electric Service and to recommend potential improvements to

the standards.

Dear Ms. Felice:

Enclosed for filing in the above-referenced matter, please find the Comments of the Citizens

Utility Board of Michigan. If you have any questions, please do not hesitate to contact me.

Sincerely,

Amy Bandyk

Executive Director

Citizens Utility Board of Michigan

Citizens Utility Board of Michigan I 921 N. Washington Ave., Lansing, MI 48906 I www.cubofmichigan.org

STATE OF MICHIGAN

BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION

Case U-20630

In the matter, on the Commission's own motion, to establish a workgroup to review the

Technical Standards for Electric Service and to recommend potential improvements to

the standards.

COMMENTS OF THE CITIZENS UTILITY BOARD OF MICHIGAN

We appreciate the opportunity to comment on proposed amendments to the Commission’s

administrative rules concerning Technical Standards for Electric Service.

We generally find the proposed amendments to be acceptable or advantageous, reflecting appropriate

updates for changing conditions. However, we recommend that the Commission address certain

deficiencies in the current or proposed rules, which we address below.

Proposed Rule 460.1302 (v) provides that a sustained interruption means “any interruption that lasts

more than 5 minutes and is not classified as part of a momentary event. The duration of a customer’s

interruption must be measured from the time that the electric utility or cooperative is notified or

otherwise becomes aware of the full or partial loss of service to 1 or more customers for longer than 5

minutes.” We find this definition to be ambiguous in relation to the use of advanced metering by an

electric utility. The rule fails to specify whether an advanced meter recording the start of an interruption,

attempting to communicate the start of an interruption to a utility’s automated meter management

system, or the receipt of a communication that an interruption has begun by some element of the

utility’s automated outage management system, or the receipt of a communication that an interruption

has begun by a person working for the utility constitutes that “the electric utility or cooperative is

notified or otherwise becomes aware” of the interruption. We strongly urge that Commission adopt a

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precise definition of “the electric utility or cooperative is notified or otherwise becomes aware” of an

interruption in a way that is unambiguous with respect to advanced metering. We further urge that in

order to gain the full benefit of advanced metering systems, the Commission should define “the electric

utility or cooperative is notified” of an interruption as occurring when the start of an interruption is

recorded by an advanced meter.

Current Rule 460.3204 (2), which the Commission has not proposed to amend, requires that the electric

utility or cooperative retain for at least three years certain customer records. These required customer

records do not address service interruptions, which are potentially relevant in relation to bill calculations

due to customer eligibility for bill credits and are relevant for system-wide and locational analyses of

utility performance. These required customer records also do not address voltage levels, which are

relevant for system-wide and locational analyses of utility performance. We therefore recommend that

the Commission add the following to the list of customer records that a utility is required by Rule

460.3204 (2) to retain:

(g) the date and time of the start and of the end of each service interruption experienced by the

customer; and

(h) the date, time, and voltage level recorded on each occasion when the voltage level of service

to the customer is outside the range specified by Rule R 460.3702.

Current Rules R 460.3702, R 460.3703, and R 460.3704 together with their proposed amendments fail to

consider and make use of the fact that advanced meters are capable of measuring and reporting voltage

(and power factor) at frequent intervals in both directions at each meter. It is understandable that the

Commission’s historical approach to voltage and other power quality problems has been to address

these on a complaint basis, since routine measurement was not practical. However, both the availability

of frequent and routine measurement by advanced meters and the expected evolution of customer

requirements for electric service warrant the Commission considering that voltage and power factor

should be routinely measured, analyzed, and reported by an electric utility both with respect to

individual customers and in aggregates. Voltage excursions outside of standard limits are known to cause

wear or damage to a wide variety of customer-owned electrical equipment, for all types of customers

and maintenance of voltage levels is therefore important to customers and should be measured and

managed. Continuing to address voltage limits only on the basis of complaints is effectively a decision to

leave voltage unmanaged.

Increasing customer use of inductive and capacitive end-use devices, conservation voltage regulation,

distributed solar generation, distributed storage, and sharply increase current to individual buildings due

to electric vehicle charging and heat pumps will all cause significant changes in power flows in an electric

utility or cooperative’s distribution system that will likely be first manifest as increasing frequency of

voltage or power factor falling outside of accepted limits before these problems result in problems that

would be detected by SCADA at substations or other utility-owned grid devices. We therefore

recommend that Rules R 460.3702, R 460.3703, and R 460.3704 be further amended such that a utility

using advanced metering is expected to exploit the capabilities of advanced meters to systematically

monitor and manage voltage and power factor in its distribution system.

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