Earlier this year, the Michigan Public Service Commission (MPSC) reopened Case No. U-20140 to review extreme weather condition policies that were established by each of Michigan’s regulated utilities in 2018. These policies are meant to protect Michigan households by providing criteria for the suspension of disconnections during periods of “extreme hot and cold weather,” which are inherently dangerous and can be deadly for those without access to heat and air conditioning.
The MPSC indicated in its order that due to the increasing frequency and severity of extreme weather events, it has become necessary to revisit these policies and solicit feedback on the need for updates. Last week, the Citizens Utility Board of Michigan (CUB) joined several other groups in filing comments responding to the Commission’s order. In those comments, we strongly advocate for a permanent and universal moratorium on disconnections. As we stated in our comments:
Universal protections would ensure no customer slips through a gap and suffers or dies without power during an extreme heat wave or cold snap. As the full toll of impacts from disconnections are becoming even clearer, we believe protections from heat and cold will only go so far to protect vulnerable customers.
Under current policies, utilities suspend disconnections only during periods in which certain weather conditions are forecasted. The exact criteria for the initiation of a suspension varies among utilities. Michigan’s two largest utilities, DTE and Consumers Energy, use weather forecasts to predict when temperatures will fall below or rise above certain thresholds that initiate the need for a suspension of shutoffs, i.e. a disconnection moratorium.
But these disconnection prevention policies that are conditioned on forecasted weather patterns will never be fully effective in protecting all utility customers due to the inherent inaccuracies of weather reporting. For example, customers in an area where temperatures have fallen below 15 degrees during winter could still face electric and gas disconnections if the weather forecast predicted that the temperatures would remain at 16 degrees or higher.
Furthermore, these temporary, weather-based shutoff suspensions have done nothing to protect utility customers who were disconnected prior to their enactment; those who were disconnected before a period of extreme heat or cold remain disconnected despite the onset of a new qualifying weather event. This has meant that relatively few customers in need of protections have been served by the current policies. Based on data provided in a DTE quarterly report under docket U-18120, our calculations show that only about 3.25% of DTE customers facing shutoff were protected in December 2024.
Barring a universal, year-round moratorium on shutoffs, we recommend the next-best solution: seasonal shutoff suspensions that occur during the hottest and coldest months of each year, regardless of measured or predicted weather patterns. These calendar-based thresholds would cover peak heating and cooling seasons in each region of the state. This means the moratorium season would vary to reflect the differences in climate between different zones of the state. As we explained in our comments:
The Commission should identify specific temperature and humidity thresholds that should be consistent across the state then require each utility to propose when those conditions commence and end, in an average year, across their service territories.
Utilities with large service territories, such as Consumers and DTE, should propose multiple zones within their service territories. The zones should be defined by climate differences across large utility territories and urban heat island effects.
This approach would eliminate failures to protect households due to weather forecast inaccuracies. If implemented, this approach should be coupled with an effort to identify households that have already been disconnected and reconnect them at the beginning of each moratorium season.
In the event that the Commission chooses to allow the continued use of weather-based moratorium thresholds—our worst-case scenario—we recommend the Commission prescribe uniform temperature thresholds for use by all regulated utilities. While they may be more or less common in certain areas of the state, certain temperatures will pose the same set of health risks regardless of zip code. We also advocate that humidity and air quality be considered as moratorium criteria, as all of these factors pose health risks for customers. Customers require power to mitigate those risks, such as power for air conditioning.
You can view our full comments here.