For the past eight months We Want Green Too has been involved in the intervention process, advocating for resident ratepayers in the face of DTE Electric's $574 million proposed rate increase. At this stage in the rate case, an administrative law judge reads over all of the evidence presented and makes a recommendation to the Michigan Public Service Commission (MPSC) before the commission makes the final decision.
With Time of Use (TOU) rates having recently gone into effect, Detroiters are still getting used to adjusting the demands of their schedules in an attempt to avoid peak-rate charges, which occur between 3:00pm and 7:00pm Monday through Friday — which happens to be exactly when adults are getting off work, students are coming home from school, and most people are trying to fit in evening tasks to prepare for the next day.
Adjusting one's electricity use to avoid the higher bills enforced by TOU rates means waiting to use the oven, do laundry, and turn on the computer and television until after 7:00pm. With a few hours of cooking, homework, or catching up on shows after a full day, that leaves eight hours of sleep for those waking up between 7–8am. Residents could decide to wake up earlier before their workday just to catch up on house tasks, but this is unrealistic for many. Even so, DTE suggests saving laundry for the weekends and running appliances at night, but neither option is a perfect solution for everyone. Low-income households especially have much less personal flexibility — some may have fixed incomes or work on the weekends. The expectation for households to shift their lives around DTE's rates, without any idea of what to budget for as another round of increases hangs over their heads, is tragic — completely disregarding the financial instability that most are facing today.
On top of TOU rate changes and proposed increases, DTE Electric has just notified ratepayers of new credit and debit card fees taking effect March 2nd. That means all of DTE's ratepayers will see their electricity costs rise in multiple ways within the next 45 days — and potentially three ways by this time next year (not to mention DTE's proposed increase on gas rates too). Card fees will be $2.99 per transaction, meaning customers who split their bills into multiple payments for better budgeting would pay more just for making that choice, unless they can pay cash at a payment kiosk or mail a check ahead of the due date.
Resident ratepayers will pay more if they can't manage to adjust their schedules to use electricity outside of peak hours.
Resident ratepayers will pay even more if they can't manage to pay by mail or in cash.
Resident ratepayers will pay even more than that if they can't afford to pay their bills in a single transaction.
And many of these ratepayers are low- to middle-income residents.
What Can You Do?
Administrative Law Judge Sally Wallace can only make a determination based on what's in the record — only what has already been discussed as part of the current rate case. That means raises from previous cases can't be taken into account, nor can the new unregulated card fees.
Fortunately, Judge Wallace does agree with We Want Green Too that ratepayers shouldn't be forced to pay $10 million for the credit-card processing system DTE put in place (this would be in addition to the card processing fees taking effect in March). She also saw a conflict in rates covering DTE's corporate membership payments, which account for another $1.5 million.
Most importantly, the Judge has stated that the commission must consider affordability.
Not only as part of this case, but as part of its mission as a Public Service Commission — which requires commissioners to ensure that energy costs aren't 'compromising a household's ability to meet other basic needs.' In last year's rate case we argued that many customers were already making difficult decisions between food, healthcare, and energy costs. Even more so, in today's economic climate, rising energy costs are putting a heavy strain on thousands of households.
However, the Judge legally doesn't have the final authority in these types of cases — the MPSC has the final say. If the MPSC is committed to the definition of affordability established through its Energy Affordability and Accessibility Collaborative (EAAC), the public would have more confidence that rates wouldn't increase any further and propel us into crisis.
