The testimony addresses deficiencies in the Detroit Edison Company’s ("the Company") Renewable Energy Plan ("REP") related to distributed solar. The author identifies a major analytical weakness underlying the Plan and the Company’s approach to distributed solar energy -- the Company fails to recognize the value of distributed solar. The testimony proposes that the Company improve and increase market opportunities for distributed solar technology in its service territory through adoption of improved program approaches, program expansion, improved resource valuation methodologies in the Company’s REP, and other processes.