DTE Electric Co. is encouraging Michigan regulators to support its integrated resource plan after an administrative law judge criticized the company's vision for meeting energy and capacity needs.
The DTE Energy Co. subsidiary on Jan. 9 filed with the state Public Service Commission exceptions to a proposal for decision released in December 2019 by Administrative Law Judge Sally Wallace. In that proposal for decision, Wallace pointed to what she saw as flaws in the plan and suggested that regulators reject it and require DTE to refile as soon as two years after a final decision is made in the case.
The integrated resource plan, or IRP, filed in March 2019 includes a fixed course of action for 2020-2024 and four proposed courses of action for 2025 and beyond. Wallace argued that this approach does not meet statutory requirements for the company to file a single, long-term plan.
But DTE said its plan meets statutory requirements and insisted that flexibility is the right approach given how quickly technology is evolving.
Through its plan, DTE aims to cut CO2 emissions 50% by 2030 and 80% by 2040 by retiring coal-fired generation and investing in renewables. In the near term, DTE is to retire its River Rouge, St. Clair and Trenton Channel facilities by 2022. The company also plans to shutter its Belle River facility by 2030 and Monroe facility by 2040.
Responding to the proposal for decision, DTE told the commission it offered only one IRP that has a fixed portion and a flexible portion.
"The fixed part of the plan is certain," DTE said. "The flexible part of the plan has certain aspects that are fixed, but also commits to not selecting a specific resource or set of resources to replace the Belle River capacity at this time, and rather, allows supply- and demand-side technologies to continue to evolve."
DTE said its briefs and testimony show that the most prudent thing to do is to wait before picking a resource that will not be needed for a decade. "If the company were to commit to an asset prematurely, the company might miss opportunities to explore other resource options that become available prior to filing the next IRP," DTE said.
The company also disagreed with the judge's findings that it should have conducted a request for proposals before filing the plan and that its retirement analysis for the Belle River facility was insufficient. Moreover, insisting that its plan is sound and complies with all requirements, DTE pushed back against a recommendation for the commission to reject the plan and direct that it be refiled within 24 to 30 months of the final order in the case.
Whether or not regulators approve or reject the current plan, DTE should not have to file another IRP for four to five years, the company said. Such a time frame would allow DTE to learn about and assess new technologies and incorporate findings of ongoing policy efforts by the regional grid operator and state officials, the filing added.
The Midcontinent ISO is looking into how best to integrate distributed energy resources into its policies and practices, while the MI Power Grid initiative announced by Gov. Gretchen Whitmer and the commission in October 2019 seeks to help Michigan adapt to the changing energy industry.
"If the company is required to begin the analysis for its next IRP immediately after receipt of the commission's final order in this case, we may have to make assumptions without input from these important policy efforts," DTE said.