WT/DS563/1, G/L/1258  
G/TRIMS/D /43, G/SCM/D120/1  
 
16 August 2018  
(18-5213) Page: 1/8 
  Original: English  
 
 
UNITED STATES  – CERTAIN MEASURES REL ATED TO RENEWABLE EN ERGY  
REQUEST FOR CONSULTA TIONS BY CHINA  
The following communication, dated 14 August 2018 , from the delegation of China  to the 
delegation of the United States , is circulated to the Dispute Settlement Body in accordance with 
Article  4.4 of the DSU.  
 
_______________  
 
 
1.  My authorities have instructed me to request consultations with the Government of the United 
States of Ameri ca ("US") pursuant to Article s 1 and  4 of the Understanding on Rules and 
Procedures Governing the Settlement of Disputes  ("DSU"), Article XXII of the General Agreement 
on Tariffs and Trade 1994  ("GATT 1994"), Article 8 of the Agreement on Trade -Related Inv estment 
Measures  ("TRIMs Agreement") , and Article s 4 and  30 of the Agreement on Subsidies and 
Countervailing Measures  ("SCM Agreement"), with respect to certain measures adopted and 
maintained by the governments of certain U.S. states and municipalities in  relation to subsidies 
and/or domestic content requirements in the energy sector . 
2.  This request identifies the measures at issue in Section I, and indicates the legal basis for  
China's complaint in Section II. 
I. MEASURES AT ISSUE  
A. The Renewable Energy Cost Recovery Incentive Payment Program ("RECIP") 
of the State of Washington  
3.  The RECIP is maintained under the legal authority of the Revised Code of Washington ( "RCW") 
Chapters 82.16.110 through 82.16.180 .  The RECIP is further implemented through Washing ton 
Administrative Code ( "WAC") Section 458 -20-273.   
4.  Under Chapter 82.16.120 of the RCW, qualifying customers of light and power businesses are 
provided by their light and power business with investment cost recovery incentives for generating 
electricity from a customer -generated electricity renewable energy system.   Similarly, Chapter 
82.16.165 of the RCW  authorizes qualifying customers to receive from relevant utilities an annual 
production incentive for each kilowatt -hour of electricity generated by a r enewable energy 
system.   
5.  As specified in Chapter 82.16.120 and 82.16.165 of the RCW, the incentive rate increases in 
certain cases where the renewable energy system uses specified parts manufactured in the State 
of Washington.   The incentive payment rate i s then multiplied by the system's gross kilowatt -hours 
generated to determine the incentive payment.   The light and power businesses and utilities that 
have provided incentive payments to qualifying customers are allowed a tax credit for the 
incentive paym ents made and various related fees, subject to certain specified limits.  
B. The Self -Generation Incentive Program ("SGIP") of the State of California  
6.  The SGIP  is maintained under the authority of Sections 360 - 380 of the California Public 
Utilities Code and the authority vested in the California Public Utilities Commission  ("CPUC ") by 
Article XII of the California Constitution  and the California Public Utilities Code .  The SGIP is further WT/DS563/1 • G/L/1258 • G/TRIMS/D /43 • G/SCM/D120/1  
 
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  implemented through the 2017 SGIP Handbook and  a series of CPUC  Decision s, including but not 
limited to CPUC Decision  17-04-017. 
7.  The SGIP provides financial incentives to users that install r enewable  energy distributed 
generation  technologies that are installed to meet all or a portion of the electric energy needs of a 
facility .  Pursuant to Section 379.6 of the Public Utilities Code, i n administering the SGIP, an 
additional incentive is provid ed for the  installation of eligible distributed generation resources 
manufactured in California.  
C. The Solar Photovoltaic Incentive Program ("SIP") implemented by the Los 
Angeles Department of Water and Power ("LADWP")  
8.  The SIP is a performance -based incen tive program maintained  by the LADWP under the 
mandate of the California Solar Initiative established in California Public Utilities Code Section  
2854.  The SIP is administered through program guidelines issued by LADWP.1 
9.  Under the SIP, the LADWP provides one-time incentive s to its customers who  purchase /lease 
and install solar photovoltaic systems .  An additional incentive payment is provided to qualifying 
and approved photovoltaic  equipment manufactured in the City of Los Angeles , termed as the Los 
Angele s Manufacturing Credit ( "LAMC ") pursuant to Section 8.1 of the  LADWP guidelines . 
D. The Renewable Energy Credits ("REC") requirements of the State of Michigan  
10.  The REC requirements are prescribed in the Clean  and Renewable  Energy  and Energy Waste 
Reduction  Act ("CREEWRA") of the State of Michigan as codified in Chapter 460 of Public Utilities  of 
the Michigan Compiled Laws ("MCL"), and are implemented through orders of the Michigan Public 
Service Commission (“MPSC”).  Renewable energy credits are collected, i ssued, and tracked by the 
Michigan Renewable energy Certification System, as provided in  the Michigan Renewable Energy 
Certification System Operating Procedures . 
11.  Section 1039 of Chapter 460  of the MCL provides that one renewable energy credit shall be 
granted to an owner of a renewable energy system for each megawatt hour of electricity 
generated from the renewable energy system, subject to certain conditions.  Section 1028 of 
Chapter 460 of the MCL requires Michigan electric providers to achieve a rene wable energy credit 
portfolio that consists of a proportion of renewable energy credits that increases over time and 
reaches 15% by 2021 .  Michigan electric providers may meet this standard by generating 
electricity from renewable energy systems or through  the purchase of renewable energy credits . 
12.  Pursuant to Section 1039 of Chapter 460 of the MCL, a dditional RECs known as "Michigan 
incentive renewable energy credits" are granted for electricity generated from a renewable energy 
system constructed using equ ipment made in the State of Michigan  as determined by the Michigan 
Public Service Commission ( "MPSC ").  
E. The Experimental Advanced Renewable Program ("EARP") proposed  by 
Consumers Energy Company and approved by the Michigan Public Service 
Commission  ("MP SC")  
13.  The EARP is administered  by Consumers Energy , Michigan’s largest utility  provider pursuant to 
Section 460 of the CREE WRA identified  in Part D above , as found in Chapter 460 of the MCL.   The 
EARP was approved by the MPSC in its order in Case No. U -15805.  Expansion s and/or 
modification s of the EARP have been approved by subsequent orders issued by the MPSC .2  The 
EARP is further incorporated in Section C10.3 of the Rate Book for Electric Service ( "Rate Book ") of 
Consumers Energy , versions of which have been approved by the MPSC  in cases including but not 
limited to Case No. U -15805, U -16543, U -16581, U -17301, and U -17709.  
                                                
1 For example, see the Net Energy Metering and Solar Photovoltaic Incentive Program Guidelines dated 
4 December 2015.  
2 The MPSC’s  approval of Consumers Energy’s renewable energy plans establishing and expanding EARP 
occurred when CREEWRA’s predecessor statute, the Clean, Renewable and Efficient Energy Act ( "CREEA" ) was 
still in force.  Pursuant to Section 460.1022 of CREEWRA, all re newable energy plans approved under CREEA 
and in force on the date CREEWRA came into effect (20 April 2017) remain in effect, subject to review and 
amendment within one year of the effective date of CREEWRA.  WT/DS563/1 • G/L/1258 • G/TRIMS/D /43 • G/SCM/D120/1  
 
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  14.  Under Section C10.3 of the Rate Book, a  customer participating in the EARP  is required to 
install and operate an eligible photovoltaic  solar electricity generating system constructed using 
Michigan workforce labor  or using equipment made in the State of Michigan .  The customer must 
transmit all energy generated by eligible renewable energy  equipment to Consumers Energy, 
which shall own a nd use RECs created therefrom.  In return, Consumers Energy offers a fixed rate 
for electricity transmitted from the customer.  In addition, customers  providing electricity  with a 
generating system constructed after October 1, 2011 that qualif ies for both the Michigan Labor 
and Michigan Material requirements shall be awarded an extra incentive .  
15.  In addition to measures identified in sub -sections A through E above, t his request for 
consultations also concerns any amendments, or related, successor, replacemen t, or implementing  
measure s, as well as any closely connected, subsequent measures  of the above mentioned 
programs providing subsidies and/or prescribing domestic content requirements in the energy 
sector . 
II. LEGAL BASIS OF THE C OMPLAINT  
16.  China considers that each of the measures at issue is inconsistent with the following 
provisions of the WTO covered agreements:  
 Article III:4 of GATT 1994 , because the measures at issue  appear to  embody laws, 
regulations and /or requirements  affecting the internal sale, off ering for sale, purchase, 
transportation,  distribution or use of products which provide less favourable treatment to 
products imported into the U.S.  than that accorded to like products originating in the U .S.; 
 Article 2.1 of the TRIMs Agreement , because the measures at issue appear to be 
investment measures related to trade in goods that are inconsistent with Article III:4 of 
GATT 1994 ; 
 Article 2. 2 of the TRIMs Agreement , because the measures at issue  appear to be 
investment measures related to t rade in goods which  are mandatory or enforceable under 
domestic law or under administrative rulings, and/or compliance with which is necessary 
to obtain an advantage, and which require the purchase or use by an enterprise of 
products of U.S. origin , as pro vided for in paragraph 1(a) of the Annex to the TRIMs 
Agreement ; 
 Articles 3.1(b) and 3.2 of the SCM Agreement because they appear to grant and maintain 
subsidies contingent upon the use of domestic over imported goods.  
17.  As a result of the foregoing, the mea sures at issue appear to nullify or impair the benefits 
accruing to China  directly or indirectly under the above -mentioned WTO covered  agreements.  
18.  In accordance with Article 4.2 of the SCM Agreement, China attaches to this request a list of 
evidence relate d to the measures at issue and presently available to China.   China  reserves its 
right to raise additional factual matters and/or legal claims  during the course of the consultations 
and in any future request for panel proceedings.  
19.  China  looks forward to re ceiving a reply to the present request from the U.S. and to setting  a 
mutually acceptable date and venue for consultations.  
 
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  WT/DS563/1 • G/L/1258 • G/TRIMS/D /43 • G/SCM/D120/1  
 
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  Statement of Available Evidence  
 
A. The Renewable Energy Cost Recovery Incentive Payment Program ("RECIP") of the 
State of Washington  
1. Wash. Rev. Code §§ 82.16.110 -180 
2. Engrossed Substitute Senate Bill 5939 , State of Washington , 65th Legislature  (2017). 
3. Wash. Admin. Code, § 458 -20-273 
4. Revised Code of Washington , Energy Independence Act, Chapter 19 -285 RCW (2007).  
5. Washington Administrative Code , Energy Independence, Chapter 194 -37 WAC (2008).  
6. Washington Administrative Code , Manufacturing, Processing for hire, fabricating, WAC 458 -20-
136 (2005).  
7. Washington State Register , Emergency Rules, Rule Ma king Order – Department of Revenue, 
WSR 12 -16-046 (July 27, 2012).  
8. Substitute  Senate  Bill 5101, State of Washington , 59th Legislature  (2005). 
9. Engrossed Substitute Senate Bill 6170 , State of Washington , 61st Legislature  (2009).  
10. Engrossed Substitut e Senate Bill 6658, State of Washington , 61st Legislature  (2010).  
11. Senate Bill 5526, State of Washington , 62nd Legislature  (2011).  
12. Engrossed Senate Bill 5128 , State of Washington , 65th Legislature  (2017). 
13. Engrossed Second Substitute House Bill 1301, Amending RCW 82.16.110, RCW 82.16.120, 
RCW 82.16.130 (201 3). 
14. Washington State Department of Revenue, Renewable Energy System Cost Recovery - Annual 
Incentive Payment Application , REV 41 0100e (2011).  
15. Washington State Department of Revenue, Community Solar Project Renewable Energy 
System Cost Recovery - Annual Incentive Payment Application , REV 41 0111e (2015).  
16. Washington State Department of Revenue, Renewable Energy System Cost Recovery 
Certification , 82.16 RCW, REV 41 0094 (2015).  
17. Washi ngton State Department of Revenue, Community Solar Projects Renewable Energy 
System Cost Recovery Certification , REV 41 0110 (2015).  
18. Washington State Department of Revenue, Special Notice, Solar Stirling Converter 
Manufactured in Washington Added to Re newable Energy Cost Recovery Incentive Payment 
Program  (August 30, 2011).  
19. Washington State Department of Revenue, Growth from Renewable Energy Cost Recovery 
Program  (October, 2016 ). 
20. Washington State Department of Revenue, Evaluation of Tax Incentives - Analysis of 
Renewable Energy System Program: Report to the Legislature  (December, 2009).  
21. Washington State Department of Revenue, Special Notice -Renewable Energy Cost Recovery 
Incentive Program -Modifications to Program  (May, 2010).  
22. Washi ngton State Department of Revenue, Washington Manufacturers Equipment Approved for 
"Made in Washington" Renewable Energy Systems Cost Recovery Incentive Payments  (September 
28, 2016). 
23. U.S. Department of Energy, Office of Scientific and Technical Inform ation, 201 1 Wind 
Technologies Market Report , DOE/GO -102012 -3472 (August, 2012).  
24. Shoreline Community College Office of the President, Notice of Intent addressed to 
Superintendent , Seattle City Light (August 12, 2009).  
25. Mason County PUD No. 1, In-State Production Incentives for Renewable Energy Development 
Program Overview , State Doc #1 ( December, 2013 ). 
26. American Council on Renewable Energy, Renewable Energy in Washington  (September, 2014). WT/DS563/1 • G/L/1258 • G/TRIMS/D /43 • G/SCM/D120/1  
 
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  27. Washington State Department of Revenue, Summary of 2009 Tax Legislations  (May, 2009).  
28. U.S. Energy Information Administration, State of Washington Electricity Profile  (2014). 
29. U.S. Energy Information Administration, State of Washington Electricity Profile  (2017). 
30. U.S. Energy Information Administr ation, State of Washington Energy Profile  (2015).  
31. U.S. Energy Information Administration, State of Washington Energy Profile  (2016). 
32. U.S. Energy Information Administration, State of Washington Renewable Electricity Profile  
(2012).  
33. Clark Public Utilities, Steps for Participation in Washington State's Renewable Energy 
Production Incentive Program Production Metering Agreement . 
34. Washington State Department of Revenue, Special Notice, Renewable Energy System Cost 
Recovery Program – Production Inc entive  (September 23, 2009).  
B. The Self -Generation  Incentive Program ("SGIP") of the State of California  
1. State of California Public Utilities Code , Division I, Part I, Chapter 2.3, Article 6.  
2. California Constitution,  Article XII Public Utilities.    
3. California Assembly Bill no. 970 , an Act to amend , inter alia , Section 372 of the Public Utilities 
Code (September 7, 2000).  
4. California Assembly Bill no. 2267, an Act to amend , inter alia , Section 37 9.6 of the Public 
Utilities Code (September 28, 2008).  
5. Senate Bill no. 412 , an Act to amend , inter alia , Section 379.6 of the Public Utilities Code, 
relating to electricity, Chapter 182 (October 11, 2009).  
6. Senate Bill no. 861 , an Act to amend , inter alia , Sections 379.6 of the Public Utilities Code 
(June 20, 2 014). 
7. California Assembly Bill no. 1478 , an Act to amend, inter alia , Section 379.6 of the Public 
Utilities Code (September 27, 2014).  
8. California Assembly Bill no. 1637 , an Act to amend, inter alia , Section 379.6 of the Public 
Utilities Code (September 26,  2016).  
9. California Public Utilities Commission Decision 01 -03-073, Interim Opinion: Implementation of 
Public Utilities Code Section 399.15(b), Paragraphs 4 -7; Load  Control and Distributed Generation 
Initiatives  (March 27, 2001 ). 
10. California Public Utility C ommission  Decision 08 -11-044, Decision Addressing Eligible 
Technologies under the Self -generation Incentive Program (SGIP) and modifying the process for 
evaluating SGIP Program change requests Decision on Advanced Storage Technologies  (November 
21, 2008).  
11. California Public Utility Commission Decision 11 -09-015, Decision Modifying the Self -
Generation Incentive Program and Implementing Senate Bill 412  (September 8, 2011).  
12. California Public Utility Commission Decision 11 -12-030, Decision Adopting SGIP  Annual 
Budget for 2012, 2013 and 2014  (December 15, 2011).  
13. California Public Utilities Commission Decision 14 -12-033, Decision Authorizing Pacific Gas and 
Electric Company, Southern California Edison Company, San Diego Gas & Edison Company, San 
Diego Gas & Electric Company, and Southern California Gas Company to Continue to Collect Funds 
for the Self Generation Incentive Program Pursuant to Public Utilities Code Section 379.6 as 
Amended by Senate Bill 861  (December 8, 2014).  
14. California Public Utilities Com mission Decision 15 -12-027, Decision Partially Suspending 
Disbursement Of 2016 Program Year Funds and Acceptance of New Applications for the Self -
Generation Incentive Program  (December 17, 2015).  
15. California Public Utilities Commission Decision 16 -06-055, Decision Revising the Self -
Generation Incentive Program Pursuant to Senate Bill 861, Assembly Bill 1478, and Implementing 
Other Changes  (June 23, 2016 ). WT/DS563/1 • G/L/1258 • G/TRIMS/D /43 • G/SCM/D120/1  
 
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  16. California Public Utilities Commission Resolution E -4824, Adoption of revised Self -Generation 
Incentive Program Rules pursuant to Decision (D.) 16 -06-055 (February 9, 2017)  
17. California Public Utility Commission Decision  17-04-017, Decision Revising the Self -Generation 
Incentive Program Pursuant to Assembly Bill 1637 and Granting the Petition for Energy Indust ry 
Association  (April 6, 2017 ).  
18. Advice Letter of Southern California Edison Company, Pacific Gas and Electric Company, 
Southern California Gas Company, and Center for Sustainable Development, Revisions to the Self -
Generation Incentive Program Handbook Pur suant to Resolution E -4824 (February 23, 2017)  
19. Advice Letter of Southern California Edison Company, Pacific Gas and Electric Company, 
Southern California Gas Company, and Center for Sustainable Development,  Revisions to the Self -
Generation Incentive Progra m Handbook  Pursuant to D.17 -04-017 Implementing Assembly Bill 
1637 and  Granting the Petition for Modification of D.16 -06-055 by the  California Solar Energy 
Industries Association  (May 17, 2017)  
20. California Public Utility Commission Resolution E -4887, Adopti on of revised Self -Generation 
Incentive Program developer definition pursuant to Decision (D.) 16 -06-055 and other revisions to 
the SGIP Handbook  (October 12, 2017)  
21. California Public Utility Commission Decision 17 -10-004, Decision Establishing Equity Budget 
for Self -Generation Incentive Program  (October 13, 2017).  
22. Self-Generation Incentive Program Handbook , 2016 (February 8, 2016).  
23. Self-Generation Incentive Program Handbook , 2017 (February 23, 2017). 
24. California Public Utilities Commission  official webs ite, 2016 Incentive Rates by Eligible 
Technologies  under SGIP . 
25. California Public Utilities Commission, Request for California Supplier status under SGIP Form . 
26. California Public Utilities Commission,  California Manufacturer Application  Form.  
27. California Pub lic Utilities Commission, List of SGIP approved California Suppliers  (2016). 
28. Application Forms available on the website of Pacific Gas and Electric Company , V.2 (2015). 
29. Application Forms available on the website of Southern California Gas Company, SGIP  
Incentive Claim Form , V. 3 (2015).  
30. Application Forms available on the website of Centre for Sustainable Energy California, SGIP 
Incentive Claim Form , V. 3 (2015).  
31. Application Forms available on the website of South California Edison, SGIP Incentive Claim 
Form, V.3 (2015).  
32. California Public Utilities Commission, Self-Generation Incentive Program Modification 
Guideline  (PMG) (July 1, 2006).  
33. California Public Utilities Commission, 2012 SGIP Impact Evaluation Program Outlook  
(February, 2014).  
34. California Public Utilities Commission official website, History & Organizational Structure . 
35. Itron, Final Report: 2014 -2015 SGIP Impact Evaluation  (November 4, 2016).  
36. American Council on Renewable Energy, Renewable Energy in California  (September, 2014).  
37. U.S. Energy Information Administration, California State Electricity Profile  (2015). 
38. U.S. Energy Information Administration, California State Electricity Profile  (2017). 
39. U.S. Energy Information Administration, California Renewable Electricity Profile  (March , 
2012).  WT/DS563/1 • G/L/1258 • G/TRIMS/D /43 • G/SCM/D120/1  
 
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  C. Solar Photovoltaic Incentive Program ("SIP") implemented by the Los Angeles 
Department of Water and Power ("LADWP")  
1. Senate Bill 1 , Chapter 132 - Electricity: Solar Energy: Net Metering (Approved 2006  and codified 
in California Public Resources Code , Sections 25780 -25783  and California Public Utilities Code , 
Sections 2851 -2854).  
2. California Assembly Bill no. 2227 , an Act to amend  and renumber , inter alia , Section 2854 of 
California Public Utilities Code (September 27, 2012).  
3. Los An geles Department of Water and Power, the Net Energy Metering and Solar Photovoltaic 
Incentive Program Guidelines  (December  4, 2015). 
4. Los Angeles Department of Water and Power, Solar Photovoltaic Incentive Program Guidelines  
(January 1, 2017).  
5. Califor nia Energy Commission, Guidelines for California's Solar Electric Incentive Programs , Fifth 
Edition (January, 2013).  
6. Los Angeles Department of Water and Power  - Solar Incentive Program Info , energy.gov.  
7. Los Angeles Department of Water and Power,  Members of the Board of Water and Power 
Commissioners . 
8. Los Angeles Department of Water and Power,  Rules of the Board of Water and Power 
Commissioners . 
9. Los Angeles Department of Water and Power, Customer Guide to using Powerclerk (December 
4, 2015).  
10. Los Angeles Department of Water and Power, LADWP Solar Incentive Program Calculator User 
Guide  (October, 2011).  
11. Los Angeles Department of Water and Power, PV Preliminary Review Information Sheet , 
LADWP – PR (02 -2013).  
12. Los Angeles Department of W ater and Power, Solar Inspection Agreement , LADWP – SA (09 -
2012).  
13. Los Angeles Department of Water and Power, Residential Disclosure Agreement , LADWP – RD 
(09-2012) and a Non-Residential Disclosure Agreement , LADWP – ND (09 -2012) . 
14. Los Angeles Depart ment of Water and Power, Request to Forward Reservation Payment , 
LADWP – PF (04 -2016).  
15. Los Angeles Department of Water and Power, Powerclerk User Account Request Form , LADWP 
– (07-2013).  
16. Los Angeles Department of Water and Power, Solar Incentive Program Report  (April 2015) . 
17. California Public Utilities Commission Decision 06 -01-024, Interim Order Adopting Policies and 
Funding for the California Solar Initiative  (January 12, 2006 ) 
D. The Renewable Energy Credits (“REC”) requirements of the State  of Michigan  
1. Clean and Renewable Energy and Energy Waste Reduction Act,  Mich. Comp. Laws §§460.1001 -
460.1099 (2017).  
2. Mich. Comp. Laws § 460.1191 (2009) . 
3. Senate Bill 438, State of Michigan, the 98th Legislature (December 21, 2016)  
4. Michigan Renew able Energy Certification System Operating Procedures . 
5. Michigan Public Service Commission, Temporary Order in Case No. U -15800 (December 4, 
2008) . 
6. Michigan Public Service Commission, Notice of Hearing Regarding the Promulgation of 
Administrative Rules Governing Renewable Energy Plans and Energy Optimization Plans Case No. 
U-15900  (April 27, 2010) . 
7. Michigan Public Service Commission, Order in Case No. U -15900  (April 27, 2010)  WT/DS563/1 • G/L/1258 • G/TRIMS/D /43 • G/SCM/D120/1  
 
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  E. The Experimental Advanced Renewable Program ("EARP") proposed by Co nsumers 
Energy Company and approved by the Michigan Public Service Commission ("MPSC")  
1. M.P.S.C. No. 13 – Electric , Consumers Energy Company , Rate Book for Electric Service . 
2. Michigan Public Service Commission, Order in Case No. U -15805, U -15889 , May 26, 2009.  
3. Michigan Public Service Commission, Order in Case No. U -16543 , May 10, 2011.  
4. Michigan Public Service Commission, Order in Case No. U -16543 , May 26, 2011.  
5. Michigan Public Service Commission, Order in Case No. U -16543 , July 26, 2011.  
6. Michigan Public Service Commission, Order in Case No. U -16581 , May 1, 2012.  
7. Michigan Public Service Commission, Order in Case No. U -17301 , June 19 , 2014. 
8. Michigan Public Service Commission, Order in Case No. U -17709 , November 6, 2014.  
9. Michigan Publi c Service Commission, Order in Case No. U -17301 , February, 2015.  
10. Michigan Public Service Commission, Order in Case No. U -17752 , May 14, 2015.  
11. Michigan Public Service Commission, Order in Case No. U -17771 , December 22, 2015 . 
12. Michigan Public Serv ice Commission, Order in Case No. U -17792 , March 29, 2016 .  
13. Consumers Energy – Experimental Advanced Renewable Program Info , energy.gov.  
14. Consumers Energy, Corporate Overview.  
15. Consumers Energy, Experimental Advanced Renewable Program Brochure.  
16. Consumers Energy, Common questions concerning the Experimental Advanced Renewable 
Program . 
17. Consumers Energy, Experimental Advanced Renewable Program Non -Residential Application 
and Instructions.  
18. Consumers Energy, Experimental Advanced Renewable  Program Residential Application and 
Instructions.  
 
 
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