October 2, 2024  
Lisa Felice  
Executive Secretary  
Michigan Public Service Commission  
7109 West Saginaw Highway  
Post Office Box 30221  
Lansing, MI 48909  
Re: Case No. U-21373 - In the matter, on the Commission’s own motion, to amend the  
rules governing electrical supply and communication lines and associated equipment.  
Dear Ms. Felice:  
Enclosed for electronic filing is Consumers Energy Company’s Comments on Proposed  
Amendments of the Rules Governing Electric Supply and Communication Lines and  
Associated Equipment and Appearance of Spencer A. Sattler in the above-captioned case.  
This is a paperless filing and is therefore being filed only in a PDF format. I have also included a  
Proof of Service showing electronic service upon the parties to this case.  
Sincerely,  
Digitally signed by  
Spencer A. Sattler  
Date: 2024.10.02  
10:15:39 -04'00'  
Spencer A. Sattler  
Phone: 517-474-6638  
Email: spencer.sattler@cmsenergy.com  
CC: Parties per Attachment 1 to Proof of Service  
S T A T E O F M I C H I G A N  
BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION  
In the matter, on the Commission’s own motion,)  
to amend the rules governing electrical supply )  
and communication lines and associated  
equipment.  
)
)
)
Case No. U-21373  
CONSUMERS ENERGY COMPANY’S COMMENTS ON PROPOSED AMENDMENTS  
OF THE RULES GOVERNING ELECTRICAL SUPPLY AND COMMUNICATION  
LINES AND ASSOCIATED EQUIPMENT  
I.  
INTRODUCTION  
On September 20, 2023, the Michigan Public Service Commission (“MPSC” or the  
“Commission”) sought permission from the Michigan Office of Administrative Hearings and  
Rules (“MOAHR”) to amend Mich Admin Code, R 460.813, within the Commission’s rules  
governing Electrical Supply and Communication Lines and Associated Equipment, to update the  
rule to adopt by reference the most current version of the National Electrical Safety Code, being  
the 2023 edition. The Commission’s request was approved by MOAHR on September 26, 2023.  
The Commission thereafter submitted the draft rules to MOAHR and the Legislative Service  
Bureau for informal approvals, which were granted on March 19 and 21, 2024, respectively.  
On August 22, 2024, the Commission issued an Order in Case No. U-21373 announcing a  
Public Hearing on September 18, 2024 where any person may present data, views, questions, and  
arguments regarding proposed amendments to the Electrical Supply and Communication Lines  
and Associated Equipment Rules. In this order, the Commission also invited interested parties to  
file written comments, suggestions, data, views, questions, argument, and modifications  
concerning the issue no later than 5:00 p.m. on October 2, 2024. Consumers Energy Company  
1
(“Consumers Energy” or the “Company”) appreciates the opportunity to provide feedback and  
offers the following comments.  
II.  
COMMENTS  
Consumers Energy is supportive of updating rules governing Electrical Supply and  
Communication Lines and Associated Equipment so they adopt by reference the most current  
version of the National Electrical Safety Code (“NESC”), being the 2023 edition. The Company  
would like to recommend that application of updated rules specifying the 2023 NESC be limited  
to new installations and extensions where both design and approval were started after the proposed  
rules take effect. This would save the Company, and ultimately customers, the time and money  
required to redesign projects that have already been approved and are awaiting construction. This  
specification is consistent with Rule 16 of the 2023 NESC which states, “Additionally, this edition  
shall become effective no later than the first day of the month after 180 days have elapsed  
following its publication date for application to new installations and extensions where both design  
and approval were started after the expiration of that period, unless otherwise stipulated by the  
administrative authority.”1  
Respectfully submitted,  
CONSUMERS ENERGY COMPANY  
1 National Electric Safety Code, 2023 edition (IEEE C2-2023)  
2
MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS  
PUBLIC SERVICE COMMISSION  
ENTRY OF APPEARANCE IN AN ADMINISTRATIVE HEARING  
This form is issued as provided for by 1939 PA 3, as amended, and by 1933 PA 254, as amended. The filing of this  
form, or an acceptable alternative, is necessary to ensure subsequent service of any hearing notices, Commission  
orders, and related hearing documents.  
General Instructions:  
Type or print legibly in ink. For assistance or clarification, please contact the Public Service Commission  
at (517) 2ꢀꢁꢂꢀꢃꢄ0.  
3OHDVHꢀ1RWHꢁ The &ommission will provide HOHFWURQLFꢀservice of documentsꢀWRꢀDOOꢀSDUWLHV in this proceedingꢁ  
THIS APPEARANCE TO BE ENTERED IN ASSOCIATION WITH THE ADMINISTRATIVE HEARING:  
Case / Company Name: Consumers Energy Company  
U-21373  
Docket No. __________________  
Please enter my appearance in the above-entitled matter on behalf of:  
1. (Name)  
Consumers Energy Company  
2. (Name)  
3. (Name)  
4. (Name)  
5. (Name)  
6. (Name)  
7. (Name)  
Spencer A. Sattler  
Name ________________________________________  
One Energy Plaza  
ꢀ I am not an attorney  
Address _______________________________________  
✔
ꢀ I am an attorney whose:  
______________________________________________  
70524  
Jackson  
MI  
Michigan Bar # is P-____________  
City _________________________ State ____________  
517  
49201  
474-6638  
_____________Bar # is: _____________  
( state )  
Zip _____________ Phone (____) __________________  
spencer.sattler@cmsenergy.com  
Email _________________________________________  
and [email protected]  
October 2, 2024  
Date __________________________________________  
Digitally signed by Spencer A. Sattler  
Date: 2024.10.02 08:58:02 -04'00'  
Signature: _____________________  
EAHR1 -ꢅꢃꢄꢆꢇꢄꢆꢇꢃꢈꢉ  
Save Form  
S T A T E O F M I C H I G A N  
BEFORE THE MICHIGAN PUBLIC SERVICE COMMISSION  
In the matter, on the Commission’s own motion,)  
to amend the rules governing electrical supply )  
and communication lines and associated  
equipment.  
)
)
)
Case No. U-21373  
PROOF OF SERVICE  
STATE OF MICHIGAN  
COUNTY OF JACKSON  
)
) SS  
)
Crystal L. Chacon, being first duly sworn, deposes and says that she is employed in the  
Legal Department of Consumers Energy Company; that on October 2, 2024, she served an  
electronic copy of Consumers Energy Company’s Comments on Proposed Amendments of  
the Rules Governing Electric Supply and Communication Lines and Associated Equipment  
and Appearance of Spencer A. Sattler upon the persons listed in Attachment 1 hereto, at the e-  
mail addresses listed therein.  
__________________________________________  
Crystal L. Chacon  
Subscribed and sworn to before me this 2nd day of October, 2024.  
_________________________________________  
Melissa K. Harris, Notary Public  
State of Michigan, County of Jackson  
My Commission Expires: 06/11/2027  
Acting in the County of Hillsdale  
ATTACHMENT 1 TO CASE NO. U-21373  
Mailing Address  
Party  
Email Address  
Administrative Law Judge  
Hon. Sally L. Wallace  
7109 West Saginaw Highway  
Post Office Box 30221  
Lansing, MI 48909  
[email protected]ov  
Counsel for Consumers Energy Company  
Spencer A. Sattler, Esq. One Energy Plaza  
Jackson, MI 49201  
spencer.sattler@cmsenergy.com  
mpsc.filings@cmsenergy.com  
Counsel for the Michigan Public Service Commission Staff  
clarkA55@michigan.gov  
Alena Clark, Esq.  
7109 West Saginaw Highway  
Post Office Box 30221  
Lansing, MI 48909  
* Receives Confidential Materials  
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