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A BALANCED AND AFFORDABLE

MICHIGAN LONG-TERM ENERGY

POLICY __________________________________________

A FOUR POINT PLAN

STEVEN A. TRANSETH Transeth & Associates, PLLC

105 West Hillsdale St.

Lansing, Michigan 48933

(517) 574-4440

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Executive Summary

Michigan can become a global leader in clean energy policy and green technology by

establishing a new comprehensive policy defined in terms of meeting our energy needs through

reliable and affordable generation that is free of pollution. This new direction will continue to

use energy that comes from renewable sources but will include greater reliance on clean energy

from nuclear power and natural gas and create an environment that will develop new ways to

generate energy yet discovered. The basic tenets of this new policy are:

Develop a balanced, measured and pragmatic energy policy that involves both short and

long term solutions to energy generation.

Implement rate restructuring to ensure stable and predictable rates that are affordable and

competitive.

Increase our investment and commitment in research and development.

An argument can be made that the greatest technological achievement over the past two

hundred years has been the system we have built to generate, transmit and deliver electricity to

virtually every part of the planet. Our culture captures power from this energy to drive almost

every element of our modern lives. An integral part of this success has been our ability to keep

this energy reliable and affordable for all. The fact we have been so successful has lured us into

complacency and a belief that it will always be that way. This has resulted in two critically

important disconnects to occur which if gone unchecked, will negatively impact us for decades

to come.

The first disconnect involves the simple physics between the claims of current renewable

technology and the reality of what presently that technology can deliver. This is preventing us

from developing a balanced and integrated approach to future clean energy generation and has

serious implications for our ability to meet demand and insure reliability.

The second disconnect has occurred between the direction of the current policy and the

financial impact these policies will have on affordability. Although there is a general consensus

we must move towards cleaner energy, this is being done at times with a complete disregard of

the costs. This failure to weigh the impact on rates by requiring the development and

deployment of costly technology could have serious implications for Michigan in attracting and

retaining businesses. If we are going to be successful in turning Michigan’s economy around we

cannot lose sight of the importance of insuring the affordability of electricity through

competitive rates.

The real answers to our energy problems have yet to be found. We cannot let a sense of

urgency cause us to make bad decisions. The answers are long term, defined by decades, not

years. Unfortunately, we are being torn between political and technological time. This urgency

has been politically exacerbated by term limits and is preventing us from establishing meaningful

and long term solutions to this critically important issue. We are getting ahead of ourselves and

must take the time to allow the technological side of the equation to develop. In the meantime

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we need to do all of the following: Look to those resources which can bridge the present to the

future and reduces our dependency on traditional fossil fuel generation; continue to develop

renewable energy but in a fashion which is reasoned, affordable, and addresses their limitations;

accept the fact that we have to deal with coal as a source of power for decades and find ways to

minimize its harmful emissions; and provide the means for innovation and establish Michigan as

a leader in the discovery of new and better ways to generate energy.

We need to challenge current thinking, to be proactive in establishing a regulatory

environment which fosters and provides incentives for businesses, utilities, government and

our educational institutions to work in partnership to achieve the goal of “clean” energy

that continues to be reliable and affordable for both our residents and businesses. This can

be achieved through the following four policy objectives:

1. Establish a balanced and measured approach to future clean energy generation that develops new sources of energy and effectively utilize existing resources. This will

require an understanding and education of the distinction between “clean” and

“renewable” energy. The regulatory and policy functions of state government

should be consolidated to ensure coordination and uniformity of direction.

2. Insure affordable and competitive rates for Michigan residences and businesses. This is going to require moving away from the traditional model of rate making

which is case specific based on historical data to one which is forward looking that

includes long term performance incentives, economic development and partnerships

between the utilities, private sector, universities and government to achieve

established policy and regulatory goals.

3. Create stable and predictable rates for both the utilities and their business customers. We need to create a framework that challenges current thinking and assumptions and

is proactive in establishing regulatory certainty and an environment that addresses

both our short and long term energy and economic needs.

4. Dramatically increase our investment and commitment in research and development. This should be the cornerstone of the new policy direction. Our ability to address the

variable problems of current renewable energy; to make current technology such as

nuclear power, natural gas and coal economically and environmentally viable; and to

create new sources of generation is going to be directly dependent on ensuring

adequate resources for scientific and engineering discovery.

The decisions we make regarding our energy policies over the next several years are

going to have tremendous implications for both the environment and our economy for decades to

come. It is important that we have an open debate which includes a critical review of our present

direction and a refocusing on the goals we want to achieve through the dramatic changes being

proposed in the nature and scope of energy generation, transmission and use.

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THE CURRENT ENERGY POLICY

While we have struggled with the issue of pollution for decades, it only has been in the

last five years that we have witnessed a reenergized environmental movement. One cannot open

a magazine or turn on the television and not be bombarded with the “green” message. Much of

the credit for this renewed interest must go to the 2006 documentary “Inconvenient Truth”1.

There are few who would question the veracity of the film’s message but we need to be careful

about accepting all of the solutions which are now being offered as the answer. The problem is in

determining which solutions are legitimate and which are Madison Avenue hype or Wall Street

greed. In the November 10, 2010 edition of Time Magazine, a study is cited that surveyed 5,296

U.S. and Canadian products which advertised themselves as “green”. Over 95% of these

products were found to have made unproven environmental claims. Climate change is real and a

serious problem requiring serious answers founded more in natural physics and less by labels.

As we have strived to find ways to meet the challenges of climate change we naturally

turned to the sources of the greatest contributors of human-produced greenhouse gases2 – fossil

fuel combustion sources. The original goal was to develop “clean energy” through alternative

sources but that evolved into the current policy of “green” energy achieved by renewable

sources. It is not unusual to hear these terms used interchangeably but policies based on clean

alternative energy are not the same as those grounded in renewable energy. The former is defined

by the ends achieved (reduced harmful emissions) and is inclusive of any means that results in

clean energy. The later is defined by the means (the fuel or source used to generate power) and

limits the options only to generation which meets the definition of renewable energy3.

Michigan’s current energy policy is to focus on the development and deployment of renewable

energy, with specific priority for wind. The problem is that we are doing so to the exclusion of

other viable options, such as nuclear power, which would also reduce carbon emissions but in a

more reliable and affordable manner.

Renewable energy sources such as wind should continue to be part of our future energy

mix but we must realize and plan for the fact that it is only part of the overall answer. We must

acknowledge and plan for the limitations. The proponents of renewable energy have

successfully created a public perception that it is cheap, plentiful and reliable. The truth is that

given the current infrastructure and present technologies these sources fail to substantially meet

any of these attributes. Renewable energy is incapable of completely displacing current base

load generation or filling in the gap between demand and generation as we reduce our

dependence on fossil fuels.

For example, wind proponents have achieved great success largely due to the claim that it

will make major reductions in carbon emissions. But this can occur only if wind development

can actually result in the closing of existing base load coal generation. Not only is this

1 “An Inconvenient Truth” is a 2006 documentary film directed by Davis Guggenheim about former United States

Vice President Al Gore's campaign to educate citizens about global warming via a comprehensive slide show. 2 A greenhouse gas (sometimes abbreviated GHG) is a gas in an atmosphere that absorbs and emits radiation within

the thermal infrared range. This process is the fundamental cause of the greenhouse effect. Primary greenhouse

gases in the Earth's atmosphere are water vapor, carbon dioxide, methane, nitrous oxide, and ozone. 3 Renewable energy is energy generated from natural resources such as sunlight, wind, rain, tides, and geothermal

heat, which are renewable (naturally replenished).

http://en.wikipedia.org/wiki/2006_in_filmhttp://en.wikipedia.org/wiki/Documentary_filmhttp://en.wikipedia.org/wiki/Davis_Guggenheimhttp://en.wikipedia.org/wiki/Vice_President_of_the_United_Stateshttp://en.wikipedia.org/wiki/Vice_President_of_the_United_Stateshttp://en.wikipedia.org/wiki/Al_Gorehttp://en.wikipedia.org/wiki/Global_warminghttp://en.wikipedia.org/wiki/Absorption_(electromagnetic_radiation)http://en.wikipedia.org/wiki/Emission_(electromagnetic_radiation)http://en.wikipedia.org/wiki/Thermal_infraredhttp://en.wikipedia.org/wiki/Greenhouse_effecthttp://en.wikipedia.org/wiki/Earth%27s_atmospherehttp://en.wikipedia.org/wiki/Water_vaporhttp://en.wikipedia.org/wiki/Carbon_dioxidehttp://en.wikipedia.org/wiki/Methanehttp://en.wikipedia.org/wiki/Nitrous_oxidehttp://en.wikipedia.org/wiki/Ozone

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technology incapable of closing these facilities, it could actually cause greater harm if in the end

it results in the inefficient cycling operation of existing fossil fuel facilities . This is due in large

part to simple physics of the system. The grid has to be maintained at 60 Hz and demand must

match supply perfectly at all times. The grid operator cannot allow the system to ever be

dependent on wind’s volatility and limited capacity. Wind must be entangled with proactive,

highly dynamic conventional generation to make its capacity viable. More than 70 percent of any

wind project’s maximum capability must come from conventional generation. Due to the

inefficiencies and costs of cycling coal operations this is not a practical option to be offset by

wind and accordingly, if any generation is impacted it will be the smaller cleaner burning natural

gas units. Not a single base load coal plant will be displaced and the resulting inefficiencies in

cycling natural gas will accumulate quickly, eventually consuming and consequently burning

more fuel in the same way that an automobile does in stop-and-go traffic.4

Coal is our primary source of power, generating over 60% of Michigan’s electricity. This

is a fact we need to plan for and recognize the implications as we seek to develop new power

sources. It is not just a matter of clean energy but insuring we have a sufficient supply of

electricity to meet demand. The following chart is a list of the 10 largest generation plants in

Michigan and basically constitute the State’s base load generation fleet5. These figures illustrate

the disconnect between the perception of what current renewable energy such as wind can do and

the reality of the difficulty with which it is possible for it to displace current base load

generation. The physics are simply not there.

Ten largest Michigan generation facilities

Michigan Primary Energy Source or

Technology

Operating Company Net Summer

Capacity (MW)

1. Monroe Coal Detroit Edison Co 3,129 2. Donald C Cook Nuclear Indiana Michigan Power Co 2,069

3. Ludington Pumped Storage Consumers Energy Co 1,872

4. Midland Cogeneration Venture Gas Midland Cogeneration Venture 1,837

5. Dan E Karn Coal Consumers Energy Co 1,791

6. Belle River Coal Detroit Edison Co 1,509

7. J H Campbell Coal Consumers Energy Co 1,453

8. St Clair Coal Detroit Edison Co 1,393

9. Fermi Nuclear Detroit Edison Co 1,173

10. Covert Generating Project Gas New Covert Generating Company

1,058

15,412

With our current policy focusing solely on renewable energy, wind became the renewable

of choice because it was the only source that could be rapidly scaled up to meet the requirements

of Michigan’s imposed renewable portfolio standard (10% by 2015). As a result it enjoyed

massive governmental support through the recognition and requirements of the 2008 legislation6.

4 See “Wind Power Won’t Cool Down the Planet” by Robert Bryce; The Wall Street Journal, August 23, 2010.

5 Source: U.S. Energy Information Administration, Form EIA-860, "Annual Electric Generator Report.

6 The Clean Renewable and Efficient Energy Act, 2008 PA 295, MCL 460.1001 to 460.1195.

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We are pushing this technology before it is capable of delivering the savings we seek. This

could result in billions of dollars in taxpayer subsidies for the wind industry and higher

electricity costs for customers. Further, we cannot ignore the reliability issues of generation

fueled by very unreliable sources or the capacity issues that are naturally present when we

attempt to move from large base load facilities located near the demand centers to a more

distributive system with smaller production capabilities located closer to the energy source. In

other words, while we should continue to pursue deployment of renewable generation we cannot

ignore the limitations and must understand they are only part of the answer.

Let us not permit our quest for “everything green” to blind us into making a bad

decision. Denial of the air permits for the Rogers City and Holland coal facilities are an example.

Creating a regulatory environment which eventually discouraged the Bay City coal plant by

Consumers Energy is another. As pointed out earlier, the unavoidable truth is that fossil fuels are

going to play a role in electric generation for decades to come. Instead of ignoring this fact, we

should be insuring that sufficient resources are directed at finding ways to use these fuels in ways

that reduce harmful emissions. One such way is to replace old plants with new more efficient

ones. The Governor’s Executive Directive made the findings of the Michigan Public Service

Commission (MPSC) and the decision of the Department of Natural Resources and Environment

(DNRE) regarding new generation other than wind all but a foregone conclusion7. The narrowly

defined review process failed to consider the present positive impact of newer, cleaner burning

coal facilities and the future implications for addressing the carbon problem with the innovative

technologies proposed for all of these sites. It is ironic that these new clean coal facilities were

basically denied or shelved due to the perceived negative impact they would have on wind

development and the resulting economic gains – when in truth any gains through wind will be

pale compared to the meaningful and lasting economic impact that is possible if Michigan

became a global leader in clean coal technology.

The current policy of renewable energy has failed to answer two critical questions - how

fast and at what cost? Are we getting ahead of ourselves by building out a system based on

present technology? Are we putting in place a VHS system in a DVD world? Nearly twenty

years ago Michigan was a leader in transforming the telecommunications industry. Its landmark

legislation became the model for the nation and created the foundation to allow the industry to

move from land line handsets to the wireless computers most of us carry around in our pockets

today8. At the time cellular phones numbered only in the thousands and were the size of bricks

carried around in a briefcase. While the policy makers recognized the future of wireless

communication they did not lose sight of the primary need to keep communication services

accessible and affordable. The lesson to be learned is that although we could see and envision a

new and different telecommunication system of the future, we did not force that system before its

time but created the framework which allowed the industry to follow the technology. As a result

we avoided huge costs and problems by not mandating a system that would have been obsolete

before it ever transmitted a single phone call. For all the collective wisdom, in 1991 no one

foresaw iPhones.

7 Executive Directive No. 2009-2 - CONSIDERATION OF FEASIBLE AND PRUDENT ALTERNATIVES IN

THE PROCESS OF AIR PERMIT APPLICATIONS FROM COAL-FIRED POWER PLANTS. Issued February 3,

2009. 8 The Michigan Telecommunications Act, 1991 PA 179, MCL 484.2101 to 4842701.

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We cannot let our current economic depression prevent us from taking the necessary

steps now to insure our energy future. Michigan faces two challenges that require long range

planning and a policy that is going to be balanced in utilizing all of our resources. The first

challenge we must address is the fact that Michigan currently has the oldest generation fleet in

the nation. The second challenge involves insuring we have enough capacity to meet our power

needs as demand increases as the economy improves. These challenges are exacerbated by the

fact that these older plants will be coming off line decreasing our total capacity just as the

demand for power increases. These future energy needs require present day planning and by

incorporating a balanced, integrated approach we can minimize our ratepayer’s exposure to the

potential high costs of building new base-load generation..

The first chart below shows current projections for total electric generation for the next

30 years broken down further by projected fuel sources. While policy and technology will

impact these percentiles the inescapable truth is that our current economic problems will fade

and there will be a renewed need for new generation and capacity. We have let our current

depressed load needs due to the poor economy dictate our long-term policy and planning

decisions. It would be counter-productive to our overall economic health should just one type of

generation be pursued to the exclusion of all else. While projections have renewable energy

increasing substantially in the coming decades from roughly 10% to 25% of total generation, it is

equally important to realize that coal will continue to play a major role in electric production.

We cannot ignore this fact and should be planning for its contribution through clean coal

technology and other measured options which will minimize its harmful emissions. The second

chart is a break down of current electric generation in this country by fuel source9. Once again

the significance of these figures is that they illustrate the importance of a measured and

integrated approach to planning future energy generation. We need to refocus on the original

goal of reducing harmful emission by utilizing all options, including renewable energy, that

achieves that end while maintaining reliability, affordability and capacity. “This is not an either

or, but a need to find an integrated balance between all of our resources that ensure an

environmentally clean, safe, affordable and reliable supply of electricity.”10

9 Source: US Energy Information Administration, “Annual Energy Review 2009” (August 2010).

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Governor Christine Todd Whitman in a speech given to the Lansing Regional Chamber of Commerce on

November 16, 2010.

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Projected world net electricity generation by fuel

2009 US Electricity production by fuel source

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A BALANCED AND MEASURED

ENERGY INITATIVE

Michigan needs to develop a more affordable, practical and balanced approach to our

energy policy. We need to establish ourselves as leaders in meeting future energy needs. We

need to also recognize that we have built over the last couple hundred years an energy delivery

system based on the economics and practicality of large base load generation plants and that we

will need to be measured in our approach to transforming that system. The current policy rejects

any means of using existing resources and fails to fully explore the potential of cleaner energy

through new technologies with the very fuels which are driving our economy - nuclear power,

coal and natural gas. All of which we have sufficient supply right here in this country to last

over hundreds of years. Are we ready to say that American ingenuity and entrepreneurship are

incapable of finding a way to use these fuels cleanly? This new policy has to balance the

realities of our current energy delivery system, the practicalities of our inability to devoid

ourselves of fossil fuel generation in the near future, and the implications to our economy if we

adversely impact the affordability of rates.

Nuclear Energy. In a recent interview with the brilliant physicist Stephen Hawking, he

was asked which scientific discovery or advancement he would like to see in his lifetime. This

man who thinks in terms of equations on par with the greatest minds of our time answered: “I

would like nuclear fusion to become a practical power source. It would provide an inexhaustible

supply of energy, without pollution or global warming”.11

We are losing a tremendous opportunity for both our economic recovery and cleaner

energy by failing to support the expansion of our nuclear energy capacity. While the President’s

call for an increase in the investment for nuclear power is welcomed, we need to do so much

more to insure it will play its proper role in answering our future energy needs. As knowledge

about the potential of nuclear energy and its environmental benefits has grown, so has its appeal.

A diverse and broad-based coalition of support has formed behind this mainstay energy source.

For the first time in decades, the vast majority of Americans now support the development of

nuclear power. One of the advantages of nuclear energy is the technology already exists and

possesses the potential of efficiently generating high amounts of electricity from a single plant.

Nuclear energy is clean, reliable and can be affordable with changes in current law and policy.

Of equal importance is the true impact on the economy this renaissance in nuclear power could

have. This is also an example of this country losing an opportunity to be a leader in an

immerging technology, something which has not been lost in China and Japan. While the capital

costs of large nuclear plants are very high, they can run continuously without interruption day

and night, year after year. Consequently, while the initial capital may be high, the long-term

maintenance and operational costs are relatively low.

Nuclear power provides many times the power density of fossil fuels and can be

contained in a small area. Concerns about its safety because of exaggerated news accounts of the

damage inflicted by the Three Mile Island/Chernobyl accidents, along with the dramaturgy

wrought by Hollywood, have allowed fear mongering to prevail over sound science. The RTO

directly to our east is PJM and is the nation’s largest regional grid with 51 million customers.

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Time Magazine, November 15, 2010.

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PJM uses nuclear power for 35 percent of its generation, and has done so safely for over twenty

years.

Despite not building a single nuclear plant in thirty years, the US still has more nuclear

facilities than any nation in the world. US nuclear plants have a capacity factor of 92 percent,

significantly better than any other generating system. Even though nuclear power has only 11

percent of the nation’s installed capacity, it nonetheless satisfies 20 percent of demand. For the

last thirty years, France has employed nuclear power for 80 percent of its electricity

consumption. The French reprocess most of the spent fuel, capturing the uranium and other

materials so that they can be sent through the reactors again, greatly reducing the volume of

waste and all but eliminating the need for storage facilities such as Yucca Mountain.

It was not that long ago a nuclear reactor anywhere near a population center would have

been unthinkable. Things have changed. Writing in the Washington Post, Patrick Moore, a

founding member of Greenpeace who sailed on the group's first protest against nuclear weapons

testing in 1971, noted: “Nuclear energy is the only large-scale, cost-effective energy source that

can reduce these (carbon) emissions while continuing to satisfy a growing demand for power."

Today, supporting nuclear power as a clean alternative has become quite mainstream.

The question for many has shifted from whether to build nuclear plants to where and how. In his

2010 State of the Union speech, President Obama advocated "…building a new generation of

safe, clean nuclear power plants." In February, the administration offered to guarantee a loan for

construction of the first nuclear plant to be built in the United States since the 1970s.12

That same

month, billionaire Bill Gates gave his backing to the nuclear power renaissance, investing $50

million in Terra Power, a nuclear power research company that is hoping to design a new

generation of reactors. These new power stations are capable of providing safe, reliable, and

affordable energy on a much smaller scale than their traditional large counterparts. These new

smaller facilities are an example of both the potential of nuclear power as a clean fuel source and

an economic stimulus in the development of the mini-nuclear power plants.

When nuclear scientists talk about the size of a reactor, they're talking about maximum

electrical output, not square footage. The world's largest reactors can generate over 2,000

megawatts of electricity, enough to power about 1.5 million households. A program being run by

the Department of Energy is focusing on models that would produce about 300 megawatts,

enough for Knoxville, Tenn., according to Dan Ingersoll of Oak Ridge National Laboratory.

They may go even smaller, producing 50-megawatt reactors that could power small towns or

even individual work sites, such as manufacturing facilities, and other large energy users that

may be located far from the main energy grid.

There are potential huge economic advantages to the development of local reactors. Their

localized nature means they can be built close to the end users. Between 4 and 10 percent of the

electricity produced by U.S. power plants vanishes as it travels through power lines on its way to

users. Building smaller plants and putting them closer to population centers could cut that figure

significantly. More significant to these savings is the billions which will be saved on the

12

Federal loan guarantee of $8.3 billion to help the Southern Company and two partners build twin reactors in

Burke County, GA..

http://en.wikipedia.org/wiki/Capacity_factor

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construction costs of large multi-state transmission lines currently being proposed. "It's getting

very difficult and very expensive to lay new transmission lines," says Ingersoll. "This offers the

possibility of providing isolated communities with power" at affordable rates.

Natural gas. “Natural gas has always been the ugly stepchild of our national energy

debate, never enjoying the political muscle of oil and coal, and never capturing the imagination

like solar panels and wind farms. And to top it all off, it was in short supply. But that is

changing, and now this stepchild is being touted as the hope of the future - the answer to our

energy problems.” November 14, 2010, CBS 60 Minutes

The environmental credentials of natural gas as a cleaner source of electricity are strong.

Modern gas plants emit much less harmful emissions and can be installed faster and at much

lower capital cost than other sources of electricity. This makes natural gas a vital ally today in

meeting our future energy needs as we move to more permanent solutions for clean energy such

as nuclear power, renewables and new technologies. A report by the Congressional Research

Service makes the case. Coal-fired power currently accounts for 80% of carbon emissions from

the power sector, and for around one-third of the country’s total emissions. If we would double

the utilization rate of its existing natural gas turbines to around 80%, it would displace nearly

one-fifth of the carbon emissions from coal-fired power plants – at little or no additional cost.

Michigan is in a unique position to capitalize on this renewed vitalization of natural gas.

Natural gas is affordable, relatively clean and now (through new technologies) in abundant

supply. In addition to being a domestically abundant and secure source of energy, the use of

natural gas also offers a number of environmental benefits by providing immediate reductions in

harmful emissions. The main advantages are:

Is more environment-friendly than oil or coal, producing far less harmful emissions. For

the same amount of heat, natural gas emits 30% less carbon dioxide than oil and 50% less

than the traditional means of burning coal.

Is cheap and cost effective. The current pricing is expected to remain for the foreseeable

future.

Can be safely stored and burned – a huge advantage for Michigan with the best storage

capabilities in the nation.

The domestic reserves of natural gas fields are underutilized and present potential supply

for several hundred years.

Emits 60 to 90% less smog-producing pollutants.

Due to clean burning process, it does not produce ashes after energy release.

Clean coal technology. Electricity runs our computers, our kitchen appliances, our

televisions and radios. It charges our cell phones and helps us surf the Internet. It powers our

businesses and industries, our schools and hospitals. Electricity enhances our quality of life,

making us safer and more comfortable. Coal currently provides over half of America’s electricity

generation and more than twice as much as the next-highest contributor. Just as modern life is

unimaginable without electricity, so is the notion that we could meet our growing energy needs

without coal for years to come. The United States has more coal than any other fuel. A quarter

of all the known coal in the entire world is here in America, and large coal deposits can be found

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in 38 states. In fact, we have more coal than the entire Middle East has oil. At the current rate of

consumption, we are capable of meeting domestic demand for more than 200 years. We need to

acknowledge that coal is not the problem, but the carbon emissions from burning coal. The

challenges are great but clean coal is a reachable goal if we turn our commitment into action.

We can achieve this through the development of technologies which will reduce emissions –

while at the same time, continue to provide affordable, reliable electricity. Policies like cap and

trade and the current regulations being imposed by the Federal Energy Protection Agency (EPA)

have harmful implications because it will ultimately do little to lessen our dependency on fossil

fuels but will substantially raise the cost of energy. We can and should be working with our

power producers and the federal government to develop, demonstrate, and deploy the next

generation of advanced technologies that will make it possible to reduce and eliminate the

harmful emissions of coal.

Hydropower. One of the best kept secrets in advancing clean energy in this State is the

hydroelectric pumped-storage generation facility located in Ludington, Michigan. This, and the

possibility of similar facilities, represents tremendous possibilities for clean energy, load

balancing and efficient use of wind power (see below). This plant stores energy in the form of

water, pumped at off-peak periods (usually at night) from Lake Michigan, which is at a lower

elevation, into a man-made reservoir at a higher elevation. Low-cost off-peak electric power is

used to run the pumps. During periods of high electrical demand, the stored water is released

from the reservoir back into Lake Michigan through the turbines and the generated electricity is

sold at the higher peak demand prices.

Reversible turbine/generator assemblies act as pump and turbine. These types of systems

are economical because it flattens out load variations on the power grid, permitting thermal

power stations such as coal fired and nuclear power plants to provide base-load electricity at

peak efficiency, while reducing the need for "peaking" power plants that are costly to run. In

addition to efficient energy management, pumped storage systems help control electrical network

frequency and provide reserve generation. Wind and thermal plants are much less able to

respond to sudden changes in electrical demand, potentially causing frequency and voltage

instability. Pumped storage plants, like other hydroelectric plants, can respond to load changes

within seconds.

This is also an excellent example of how best to use wind in the total energy picture.

Because the low-peak pumping period is usually at night and this is the most dependable period

for wind, wind turbines could be used in an effective manner that should smooth out the

variability of energy captured from this generation source.

FOUR POINT ENERGY PLAN

First: Insure affordable and competitive rates for Michigan residents and businesses.

While we must continue to strive for cleaner energy, it is equally important to remember

that the very fabric of our modern lives is the result of, and dependent on, affordable and reliable

http://en.wikipedia.org/wiki/Turbinehttp://en.wikipedia.org/wiki/Nuclear_power_planthttp://en.wikipedia.org/wiki/Voltage

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energy. We cannot ignore the economic implications of the present policy. There has been a

huge disconnect between the main driving principles of the current policy and the financial

impact those policies will have on the ratepayers. These policies if gone unchecked will have a

lasting impact on our long term economic recovery. As an example, in October of 2008 (just

prior to the passage of PA 295) the average base rate for residential customers in the DTE

service area was $73.13. The current average rate is now $87.87, or an increase in less than two

years of $14.74 (over 20%). We have gone from below the regional average to one of the

highest. Of this increase, over 74% or $10.92 is directly contributable to the legislative mandates

for renewable energy, energy efficiency and rate de-skewing.13

While there is general agreement

we need to move towards cleaner energy, this must be done in a way that avoids any damaging

impact on our society should the cost for electricity no longer be affordable and competitive.

Energy is literally and figuratively the fuel of our economy and our success is dependent

on finding a way to insure it remains reliable and affordable. It is clear that there is broad

support for the development of cleaner fuels and a reduction in carbon emissions. However,

what is most important to our residents and businesses is that we keep our energy affordable and

reliable. More than anything else people want to walk into their homes and businesses and when

they flip the switch the lights are going to come on and it is not going to cost a lot to do so. This

is going to be a critical element to our future success in attracting and retaining business in this

State. These two concepts (clean and affordable energy) need not be incompatible - they only

become such when renewable energy is pursued with such determination that it is believed we

must do so at all costs. Such disregard for the harmful economic impact of these decisions will

result in us doing more damage than if we did nothing. As the economy improves a demand for

more energy will follow. If we do not insure there is measured new, sufficient and affordable

generation in place, the gap between demand and supply will only widen. Utilities will be forced

to buy electricity from the open market, which means generation from outside the state and this

will result in higher, unpredictable rates for residents and businesses, doing little to improve our

state’s economy.

Because of the costs associated with the development and deployment of present

renewable technologies, we have to look carefully at any claims of economic growth. We have

to weigh what gains we achieve through the creation of jobs in this industry against the costs that

will be felt in others. At best this industry will create jobs in the hundreds and new

manufacturing firms will be few. The gains we realize in this sector will be more than offset in

lost jobs and economic growth in others. There are far too many examples of businesses

deciding not to come to Michigan or existing firms selecting not to expand or simply relocating

because of high energy costs.

The move to clean energy technology holds great promise but we have to do so in a

manner that maintains perspective and is inclusive of all options. For example, the potential of

redirecting our efforts in the development of a robust nuclear energy manufacturing industry

holds far greater long-term economic promise than what can be achieved with the present

policy.14

13

Detroit Edition – Typical Residential Customer (Rate D-1) Rate Changes from October 2008 to January, 2011. 14

See “Switch to Nuclear Power” an article co-authored by former Michigan Governors

Milliken, Engler and Blanchard, Detroit Free Press, April 21, 2009.

14

Revisions to the mandatory nature of the Renewable Portfolio Standard (RPS). The RPS

and many of the governmental mandates found in the 2008 legislation, and similar issues

currently being debated on the national level, are ideas which are sound conceptually but whose

practical implications may prove to be costly. The RPS forces the industry to move faster than

the technology is capable of achieving the goal of reducing carbon emissions while maintaining

reliability, capacity and affordability. Wind is being pursued not because it is the best source of

renewable energy but because it was the only present technology capable of being scaled up to

meet the minimum goal of 10% by 2015.15

The current wind project being pursued in the

Thumb would not even be considered but for the existence of the RPS. There are some who

would advocate that this is exactly the point of the governmental mandate. However, it has

reduced the debate to how are we going to pay for this development without first having the

debate on whether it should be built in the first place. The proponents of wind start from a

position which presumes the legitimacy that wind is the only technology worth pursuing. There

are other means to achieving the same end that incorporates the concepts of the new policy

advocated in this paper that will drive the right singles, at the right time, at an affordable cost.

One option which could be pursued is instead of mandates, provide incentives through

rate restructuring that award advancement in new clean energy technology and deployment.

Revisions to energy optimization (EO). The 2008 legislation (295 PA 2008) took a very

simplistic approach to establishing EO mandates which has resulted in some unintended

consequences and higher rates for smaller utilities.16

While the cheapest kW saved is the kW not

used, the “one size fits all” approach of PA 295 fails to accommodate the inability or difficulty of

certain cooperative and municipally owned utilities in meeting the statutory requirements. The

Act should be amended to allow all of the following:

More discretion for the MPSC to implement alternative approaches to meeting the

legislative mandates.

Unlimited annual carry forward of any credits when numbers exceed standards.

That the collected surcharge can be spent on any EO program that is offered for

all customer classes.

Second: Create a rate structure that is stable and predictable for both the ratepayers and

power providers.

It would be a mistake to solely focus on affordability, for to do so ignores the other side

of the equation of insuring reliability. Both the ratepayers and the utilities benefit from a

regulatory structure that ensures rates are stable and predictable. Reliability of our energy supply

and stability of pricing are two critically important goals we need to achieve with any new policy

initiative. This will require an examination and a restructuring of the current way we determine

and set rates. As important as affordability is, it is also critical for business customers and the

regulated utilities to have a stable environment that allows for planning and encourages capital

investment for expansion by ensuring the predictability of the rate base and energy costs.

15

Section 21 of 2008 PA 295, MCL 460.1021. 16

Sections 71 to 97 of 2008 PA 295, MCL 406.1071 to 460.1097.

15

Neither of these important players to economic growth benefit from “yo-yo” rate making and

every effort should be made to build an environment that provides regulatory certainty. The

following are a few key elements to achieving this goal:

The Michigan Public Service Commission. The MPSC is one of the most powerful and

influential regulatory agencies in state government. It makes decisions nearly daily that impact

the financial situation of every citizen and business entity. Any attempt to revitalize the

economy and achieve a stable and predictable rate structure will require the proactive and

positive functioning of this body.

In 1996, the State Energy Office was transferred from the Commission to the Department

of Commerce (now DELEG).17

This move along with similar decisions has resulted in the

State’s energy policy being determined by multiple individuals and agencies spread out over

several Departments. This and all energy related governmental functions should be eliminated or

transferred to the Commission which would serve as the primary authority over the state’s

energy policy. This will strengthen and coordinate the regulatory and non-regulatory energy

planning, policy and program capabilities by streamlining the process, providing accountability,

and insuring the Governor has the means to efficiently affect change

The current cap on customer choice.18

This is a difficult issue and pits two legitimate

positions and should not be decided without due diligence in examining both sides. It is not as

simple as finding the lowest rates for our business customers by singularly focusing on what is

possible today. To do so is potentially pursuing short-term gains at the expense of much greater

long-term costs. On the other hand, customer choice has grown as a viable means of keeping

energy costs down and there is no magic to the current 10% cap. The unavoidable fact is we

have chosen to operate under a framework in which we are reliant on regulated power providers

that have an obligation to serve, sustain capacity, maintain the infrastructure and are subject to

government mandates not shared by the alternative energy suppliers. There is a balance that must

be struck between insuring our business customers have the lowest possible rates and not doing

harm to the financial wellbeing of the regulated utilities. A scenario that involves uncertainty in

rate base means these utilities will be unable to raise capital with reasonable financial terms to

make the kind of investments necessary for our long-term economic growth. In the long run this

may cause much greater harm to the very businesses which now seek rate relief under customer

choice.

Open deliberation of our energy issues has been the hallmark for Michigan going back to

the passage of the customer choice act when we made our first effort at restructuring the energy

industry.19

This effort proved to have its flaws but we did get much of it right. Significantly, we

managed to avoid the mistakes of divesture that California paid for so dearly and the complete

deregulatory missteps many other states now consider “unmitigated disasters”. We need to be

careful in how we handle the customer choice issue. It found its origin in the time of

deregulation and has continued with success in part due to the present highbred model which is

uniquely Michigan’s and consequently, will demand a unique solution.

17

Executive Order No. 1996-2. 18

Section 10a of 1939 PA 3, MCL 460.10a. 19

The Customer Choice and Electricity Reliability Act, 2000PA 141, MCL 460.10 to 460.10cc.

16

It is not just a matter of immediate economics but a recognition that long-term solutions

to our recovery are going to require the active participation of our regulated utilities – especially

Detroit Edition and Consumers Energy. It is through their size and resources that we will be able

to realize gains in new technology and make the multi-million dollar investments that are not

possible with the alternative energy suppliers. In order for these utilities to continue to be

partners in insuring our economic growth they need predictability regarding their rate base to

attract investors.

Annual rate review. Regulatory lag is that time between a utility's request for new rates

and the granting of the rates by the MPSC. The relationships between regulatory lag, asset life,

construction costs and utility return requirements can have significant implications for the

utilities and consumers. Regulatory lag has been a major contributor to the extreme rate swings

of recent years and has caused utility managers to act inefficiently and caused great frustration to

their customers. One requirement which would greatly reduce regulatory lag would be annual

rate review. Once a base line rate case was completed any subsequent reviews could be limited

to only those features which changed from the year before. Not only would this have the benefit

of flat lining rate increases and the timely identification of industry problems, but would greatly

reduce the cost for the MPSC and the utilities of these very expensive and time consuming rate

cases.

Certain other rate making features of the 2008 legislation will need to be reviewed and

possibly modified. Several of these rate making tools have had quite vocal detractors (i.e. self-

implementation).20

The claims are the process has been abused and resulted in unnecessarily

higher rates. To the extent these claims are true may be due to flawed implementation by the

MPSC and assessments for governmental mandates for renewable energy and energy

optimization. An examination needs to be done to determine whether these regulatory concepts

if managed properly could be key features to establishing stable and predictable rates. If

managed properly, they could result in keeping rates down and eliminate the current volatile

regulatory trend that has resulted in customers experiencing significant rate shifts.

Third: Establish a balanced and measured approach to future energy generation.

We need to be patient and trust that if history has taught us anything, with the right

leadership and direction we will find, develop, invent and create new fuel sources and better

ways to use those we have. We do not know yet what the answers are to our future energy needs

and finding those answers is going to be dependent on asking the right questions. By developing

the current policies which focus only on renewable energy we are sending ourselves down a path

that fails to consider all options and will, in the end, be unfairly costly to the consumer and create

a system that lacks reliability and capacity.

Michigan needs a new comprehensive energy policy that involves both short and long

term solutions. A policy grounded more in scientific/engineering literacy and less on mistaken or

unfounded opinions and ideas. The goal should be defined in terms of finding a way to meet our

energy needs of tomorrow through reliable and affordable generation which is free of pollution.

20

Section 6a of 1939 PA 3, MCL 460.6a.

17

The answers are long term, defined by decades, not years. The present sense of urgency

is preventing us from establishing meaningful and long term solutions to this critically important

issue. We are getting ahead of ourselves and must take the time to allow the technological side

of the equation to develop. In the meantime, we need to look to those resources which can

bridge the present to the future. Continue to develop renewable energy but in a fashion which is

reasoned, affordable, and addresses their limitations. Expand the use of nuclear power and

natural gas which can play an important role in stabilizing the energy market. Understand the

shortsightedness of a policy that prevents us from replacing old coal plants with newer and

cleaner coal facilities. Invest in research and development to insure we are the leaders in the

discovery of new and better ways to generate energy.

Energy Efficiency. The cheapest kilowatt is the kilowatt never used. Any balanced

energy policy has to focus not only on how we generate electricity but also how to conserve and

lessen the need for greater capacity in the future. Making homes, vehicles, and businesses more

energy efficient is still a largely untapped solution to addressing the problems of pollution,

global warming, energy security, and fossil fuel depletion. Many of these ideas have been

discussed for years, since the 1973 oil crisis brought energy issues to the forefront. In the late

1970s, physicist Amory Lovins popularized the notion of a "soft energy path", with a strong

focus on energy efficiency. Among other things, Lovins popularized the notion of negawatts—

the idea of meeting energy needs by increasing efficiency instead of increasing energy

production. Energy efficiency to date has primarily focused on the residential setting but

tremendous savings can be realized in the advancement of more efficient ways to generate,

transmit and distribute electricity.

Fourth: Dramatically increase our investment and commitment in research and

development.

This has to be one of the cornerstones of any new energy policy. How we handle the

coming issues concerning energy involves innovation, competition and security. This is an area

where we as a nation should be leading the world, yet find ourselves already falling behind.

Clean energy could be to the 21st century what aeronautics and the computer were to the 20

th.

This past year the U.S. spent roughly $5 billion dollars on energy research and development.

That is about one-tenth of what we spent on health care and one-twentieth on the military.21

There is little doubt that if we direct our vast resources and commitment to finding the

answers to our energy needs it will not be long before we discover a new sustainable, affordable

fuel source, or develop a way to burn coal cleanly, or invent a wind turbine or solar panel that is

capable of being located anywhere. If we continue on the current path of blindly pushing the

current technology we could end up with a solution without the means to implement because we

will be unable to back away from the billions of dollars invested in putting the wrong system into

place. These will become stranded investments which will delay the advancement of energy

technology by decades. In the end we may be doing far greater harm to the very thing we are

trying to save. Is this a risk we want to take? Is it a mistake we can afford to make? And who is

21

“Issues in Science & Technology” , article by Dan Kammen PhD, September 27, 2008.

http://en.wikipedia.org/wiki/Pollutionhttp://en.wikipedia.org/wiki/Global_warminghttp://en.wikipedia.org/wiki/Energy_securityhttp://en.wikipedia.org/wiki/Peak_oilhttp://en.wikipedia.org/wiki/1973_oil_crisishttp://en.wikipedia.org/wiki/Amory_Lovinshttp://en.wikipedia.org/wiki/Soft_energy_pathhttp://en.wikipedia.org/wiki/Negawatts

18

going to pay the cost if it turns out we were wrong? This is ratepayer risk at its worst and an

example of policy being made based on political correctness with little regard to cost.

How we generate, transmit and use energy a decade from now is going to look quite

different than it does today. Michigan is blessed to have some of the best universities in the

world, business resources second to none, and a utility industry ready to partner in the

development of new technologies that will provide lasting economic growth. It is important we

keep our vision for the future in front of us and part of that future has to include new and creative

ways to generate and use energy.

We need to find ways to provide incentives for our businesses, universities and utilities to

expand their current efforts in this area. Create an environment that invests in multiple areas of

science, engineering, skilled labor, education and research necessary to maintain our dominance

and be global leaders in new technology. The electric industry spends less on research and

development than virtually any other industry in the world. The National Science Foundation

estimates electric utilities spend less than .2% of their revenues on R&D. That compares to 10 to

20 % in many other businesses. The traditional rate setting model does not lend itself to adding

such costs into base rates nor does the nature of the business provide incentives to do otherwise.

This is partly due to historical precedent and outdated rate structuring. We need to build the

needed resources for R&D into the rate base and use these funds in a similar matter as we do

currently with LIEEF funds. Program funding or grants could be awarded as seed or match

money to encourage partnerships between the utilities and the private sector and universities.

This should not be viewed as a cost but an investment which will pay big dividends in the years

to come.

The need for innovation has come on so quickly that it has outpaced the resources

available to create and develop new ideas and products. Everyone agrees carbon is a problem

but we have not yet found an effective means of dealing with it. PJM (the RTO directly to our

east) is experimenting with a project using battery technology where a unit not much bigger than

a semi-truck and can be located anywhere has the ability to produce a MW or more of electricity

on demand over a short period of time. Recently, researchers at Michigan State University

unveiled their concept of a solar power car. During 2010 NCAA basketball tournament there

were ads regarding a fuel source being developed from algae that actually consumed carbon.

There are many more examples of new technologies that were only dreamed possible just a few

years ago. Great innovations await us in energy.

19

ADDENDUM A listing of informational

and related links regarding energy

20

Addendum Contents

This addendum contains links to pertinent information regarding the energy industry.

Language of the Energy Industry (glossaries of terms)

Energy Industry Overviews

Nuclear

Natural Gas

Wind

Clean Coal Technology

Transmission

Clean Energy Economics

Recent News

Informational sites and news outlets that continually update news of the energy industry

Language of the Energy Industry

(Glossaries of terms and general information)

Title: DOE Energy Terms Glossary

Summary: Glossary of energy related terms.

Link: http://www.eia.doe.gov/glossary/index.cfm

Title: Energy Terms Glossary (California Energy Commission)

Summary: Glossary of energy related terms.

Link: http://www.energy.ca.gov/glossary/

Title: Energy Acronyms (California Energy Commission)

Summary: Acronyms for the energy industry.

Link: http://www.energy.ca.gov/glossary/acronyms.html

Title: California ISO Glossary

Summary: This PDF has key terms for understanding the very basic nature of the energy use

cycle

Link: http://www.energy.ca.gov/glossary/ISO_GLOSSARY.PDF

Title: DOE Energy Kids Glossary

Summary: Kids glossary of energy related terms and general information.

Link: http://www.eia.doe.gov/kids/energy.cfm?page=kids_glossary

Link: http://www.eia.doe.gov/kids/index.

http://www.eia.doe.gov/glossary/index.cfmhttp://www.energy.ca.gov/glossary/http://www.energy.ca.gov/glossary/acronyms.htmlhttp://www.energy.ca.gov/glossary/ISO_GLOSSARY.PDFhttp://www.eia.doe.gov/kids/energy.cfm?page=kids_glossaryhttp://www.eia.doe.gov/kids/index

21

Energy Industry Overviews

Title: Annual Energy Outlook

Author(s): US Energy Information Administration

Summary: Presents a projection and analysis of US energy supply, demand, and prices through

2035. The projections are based on results from the Energy Information Administration's

National Energy Modeling System. The AEO2010 includes Reference case, additional cases

examining alternative energy markets.

Link: http://www.eia.doe.gov/oiaf/aeo/

Title: New Report Profiles the Emissions Performance of the Top 100 Power Companies in the

U.S.

Author(s): Ceres and NRDC

Summary: Has an excellent map of the location and relative production capacity of the top 100.

It also contains data on the pollutants from these plants.

Link: http://www.ceres.org/Document.Doc?id=600

Title: Michigan State Energy Profile

Author(s): US Energy Information Administration

Summary: Quick facts, overview, and data for Michigan's energy profile.

Link: http://tonto.eia.doe.gov/state/state_energy_profiles.cfm?sid=MI

Title: Energy Explained

Author(s): US Energy Information Administration

Summary: An extensive online resource of research and data analysis of energy usage in the

US. By energy type, by state, and other key areas.

Link: http://www.eia.gov/energyexplained/index.cfm#tab2

Title: DOE Energy Efficiency and Renewable Energy Home Page

Author(s): US Department of Energy

Summary: Entry page into much quality information on clean energy technologies.

Link: http://www.eere.energy.gov/

Nuclear

Title: Nuclear Power Trends in the World

Author(s): Jorge Gonzalez-Gomez and Peter R. Hartley; The James A. Baker III Institute for

Public Policy - Rice University

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22

Summary: A concise overview of international nuclear power in the last 30 years with an

economic analysis. The economic analysis covers the building/starting of nuclear power plants

and the ongoing use of them. This paper looks at generation trends for the US the lack of

progress in nuclear power since the Three Mile Island disaster. There have been permits for

increased power output and there are a handful of applications to build new plants using newer

technologies. Has comparisons with natural gas, hydroelectric, and other energy forms

interspersed throughout. Of particular interest are the factors leading to the economics that allow

for a more balanced use of nuclear energy in comparison to fossil fuels.

Link: http://bakerinstitute.org/publications/IEEJnuclear-JorgeHartley.pdf

Title: Energy, Electricity, and Nuclear Power Estimates for the Period up to 2030.

Author(s): International Atomic Energy Agency

Summary: An annual publication — currently in its twenty-ninth edition — containing

estimates of energy, electricity and nuclear power trends throughout the world up to the year

2030. Many charts and tables showing the data for these estimates.

Link: http://www-pub.iaea.org/MTCD/publications/PDF/RDS1-29_web.pdf

Title: Nuclear Power in the 21st Century: Status & Trends in Advanced Nuclear Technology

Development

Author(s): Debu Majumdar; International Atomic Energy Agency

Summary: In depth overview of advanced types of nuclear power reactor plants. Breaks down

use of these types of plant by country and explains the details of these advanced plants.

Link: http://users.ictp.it/~pub_off/lectures/lns020/Majumdar/Majumdar_1.pdf

Title: Miniature nuclear reactors might be a safe, efficient source of power

Author(s): Brian Palmer; Washington Post

Summary: Washington Post article on miniature nuclear reactors and the possibility of adding

those as a component of the nuclear energy production cycle. Discusses the value of building

smaller reactors compared to larger reactors.

Link: http://www.washingtonpost.com/wp-

dyn/content/article/2010/09/13/AR2010091304026.html

Title: Looking beyond uranium

Author(s): Rolland Johnson

Summary: Editorial on non-uranium based nuclear reactors using thorium. Author notes that

there is a growing interest in using thorium and notes that there are more than enough thorium

reserves.

Link: http://www.washingtonpost.com/wp-

dyn/content/story/2010/09/29/ST2010092902924.html?sid=ST2010092902924

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