DTE Electric Renewable Energy Plan
Synapse provided expert witness testimony to Earthjustice and the Sierra Club regarding DTE Electric Company's (DTE) annual Renewable Energy Standard compliance plan. The purpose of this testimony was to evaluate whether DTE is meeting the renewable energy generation requirements set forth by Michigan's Act 235 of 2023. Specifically, Synapse assessed the reasonableness of DTE's load forecast and its projections for major sources of load growth, such as data centers and manufacturers. We focused on whether DTE had adequately accounted for the potential for high load growth and evaluated the risk of non-compliance with the Renewable Energy Standard if DTE fails to properly plan for load growth from data centers in its Renewable Energy Plan filing.
Our findings indicated that DTE's amended load forecast does not support its renewable energy buildout to meet the Renewable Energy Standard targets. Additionally, DTE’s load forecast in its amended plan shows lower projected load growth compared to its 2022 Integrated Resource Plan (IRP). We also observed that DTE did not consider alternative load scenarios in its amended plan, failing to address the potential impact of higher-than-expected load from new data centers, other large customers, or increased electric vehicle (EV) demand. As a result, if load grows faster than projected, DTE could face a risk of non-compliance with the Renewable Energy Standard or incur higher compliance costs that would be passed on to ratepayers.
We recommended that the Commission propose DTE to amend its Renewable Energy Plan to include a sensitivity analysis for high load growth in all future Renewable Energy Compliance Plan (RECP) filings. This analysis would help ensure that DTE stays on track to meet the Renewable Energy Standard, even if load increases more quickly than its current baseline projections. It should specifically consider the impact of new data centers in DTE's service area.