December 04, 2025

ELPC Gives a Dam about Anglers

Advocating for Ratepayers and the Environment in Michigan Dam Sale Case

By Daniel Abrams, Senior Associate Attorney

ELPC is representing a group of Michigan-based conservation organizations to scrutinize and oppose the sale of 13 hydroelectric dams from Consumers Energy to private equity firm Hull Street Energy Partners.  With the threat of a change in ownership for the dams and surrounding riverfront properties, this is an important moment to ensure environmental and ratepayer concerns are brought to the forefront.

Public Oversight or Private Secrecy?

Consumers Energy announced the proposed $13 sale in September 2025, which would transfer ownership of the dams to Maryland-based Hull Street Energy. The deal would also enable Consumers Energy to buy back the power generated by the dams in a power purchase agreement (PPA). The Michigan Public Service Commission (MPSC) must approve PPA and the sale of the dams, taking into consideration a number of factors, including:

• Rate impacts
• The safe provision of electricity
• The public interest

Consumers Energy has safely operated these dams for over a hundred years. As a publicly regulated utility with deep roots in Michigan, Consumers operates under significant state oversight and the public has ample opportunity to provide feedback and engage on key strategic questions related to the dams.

Private equity firms are inherently quite different. Hull Street is located outside of Michigan. It’s business model and wholly private ownership present a set of risks related to the continued safe operation of the dams. If not properly accounted for, these risks will ultimately be borne by the State of Michigan and its taxpayers.

Hull Street proposes to create 13 separate LLCs, one for each dam. Under this structure, Hull Street could bankrupt, abandon, or sell them off individually. If the Commission approves the sale of the dams, it no longer has jurisdiction over future action. What if big developments pop up along the adjacent riverfront land, limiting public access for hiking, fishing, and other popular recreation? The dams would still fall under the jurisdiction of the Federal Energy Regulatory Commission, but the state and local communities would lose all oversight. This MPSC decision is Michigan’s only opportunity to stop and think about whether the dam sale serves Consumers’ ratepayers and the public interest.

Who are We Representing and Why?

ELPC is representing five Michigan-based groups: the Michigan Hydroelectric Relicensing Coalition (MHRC), Great Lakes Council of Fly Fishers International, Anglers of the Au Sable, Michigan Trout Unlimited, and Michigan Steelhead and Salmon Fishermen’s Association. These five groups have decades of experience working with Consumers Energy on these dams.

ELPC, its expert witnesses, and its clients will advance a range of arguments related to the detrimental impact of private ownership on Consumers’ fleet of dams. This includes potential ecological and natural resource impacts related to fisheries and water quality.

The thirteen dams in the proposed sale are located in six rivers throughout Michigan including the Au Sable, Manistee, Muskegon, Grand, and Kalamazoo Rivers. These rivers are highly valued among anglers. The Au Sable River, in particular, is known for world-class trout fishing. It is the in Michigan, drawing anglers from throughout the state and the Midwest. Residents and visitors across Michigan depend on healthy ecosystems and enjoy beautiful river views, so there are broad concerns about the future risks of selling the dams.

The MPSC set a schedule for the case on November 24, 2025. ELPC and its clients will file expert testimony on February 9, 2026, briefs in April and May 2026. The Commission expects to issue a final order approving, denying, or modifying the proposed sale by September 3, 2026.