The Wisconsin Propane Gas Association ("WPGA") is the state trade association of the propane industry with a membership of about 250 companies. Membership in WPGA includes retail marketers of propane gas who deliver the fuel to the end user, propane producers, transporters and wholesalers, and manufacturers and distributors of equipment, containers, and appliances. Propane gas fuels millions of installations nationwide for home and commercial heating and cooking, in agriculture, industrial processing, and as a clean air alternative engine fuel for both over-the-road vehicles and industrial lift trucks. More than 250,000 Wisconsin residents utilize propane to fuel their homes. Propane is uniquely popular in rural regions and in many commercial applications for its accessibility, affordability, and low-carbon footprint. Regulatory actions that potentially impact the people and business that rely on propane is an important concern to members of WPGA.
COMMENTS
Wisconsin Stat. § 196.374(3)(b)1. requires the Public Service Commission to evaluate and set goals for the Focus On Energy programs as part of a Quadrennial Planning Process. As stated in the Memorandum, statutorily identified tasks of Focus include the following:
The commission shall give priority to programs that moderate the growth in electric and natural gas demand and usage, facilitate markets and assist market providers to achieve higher levels of energy efficiency, promote energy reliability and adequacy, avoid adverse environmental impacts from the use of energy, and promote rural economic development.
In conjunction with the Commission`s obligations to continually evaluate the Focus programs, Wis. Stat. § 196.374(5m)(b) requires that the Commission ensure "that customers throughout the state have an equivalent opportunity to receive the benefits of" statewide energy efficiency and renewable resource programs. Wisconsin Stat. § 196.374(2)(a)2. identifies specific components that must be included in the Focus programs.
As defined above, the purpose of Focus on Energy is to produce energy efficiency and renewable resource programs for Wisconsin consumers, not to promote electrification. This docket boasts an "all-electric" future for Wisconsin and suggests that electric initiatives alone will help our state reach it`s decarbonization goals. It even going as far as to reference "electrification" as a priority.
By favoring one energy source, our state is missing out on the opportunity to benefit from other clean, reliable fuels that would play an important role in Wisconsin`s energy future. Electricity is not the only energy source with a low carbon footprint and for our state to rely on it to fulfill all our energy needs is not only putting consumers at risk, but it will also result in unintended environmental and economic impacts.
Contrary to popular belief, electric isn`t always better. Propane is a direct use energy. Direct use means there is no loss of propane from the tank to the end-use. The electrical grid, in contrast, is extremely inefficient in transport. Only 1/3 of the energy generated at most power plants actually arrives to consumers in the form of useable electricity. That means almost 2/3 of electrical energy is being lost - wasted. Moreover, most of this electric power is generated by burning fossil fuels, including coal. Low-carbon propane is playing an important role in the reduction of carbon dioxide (CO2) emissions measured in the US over the last decade. CO2 is a greenhouse gas.
Electrification supporters often fail to mention that widespread electrification is a complex and expensive undertaking. Without solid, substantial renewable energy plans in place, electrification would in fact do more harm to the environment. As stated in the Docket, "for jurisdictions where coal is a significant source of electricity generation, in the short-term, electrification may increase carbon emissions, though as carbon intensive generation is replaced by cleaner renewable energy sources, carbon emissions would be less." This is taking a big risk. It will require enormous investments across our electricity delivery system. The power generation, transmission and distribution sectors would have to deal with larger electric loads, especially in winter, and respond to new variabilities in demand. After all, if everybody wants to charge their electric vehicles once they get home from work, the grid must be ready.
This docket facilitates the use of the Focus on Energy program as a means to promote electrification: not "natural" market driven fuel switching. This gives utilities an unfair competitive advantage over gas and other fuel sources. This is forced electrification and is driven by initiatives that are designed to deprive gas consumers access to financial incentives and justified on the basis of purported benefits realized through fuel switching.
Not surprisingly, some of the loudest voices advocating for this type of electrification are investor-owned utilities who are dealing with flat electricity demand and pressure from shareholders to boost profits. The statute requires input from stakeholders during plan development, but unfortunately the propane industry isn`t considered a stakeholder and was not given the opportunity to provide input.
In closing, America is the world`s leading propane producer; ensuring clean, reliable domestic energy is available to homes and businesses. Here in Wisconsin the propane industry is the driving force behind thousands of jobs and millions in contributions to our state economy. Clearly, promoting electrification would have more of a negative impact than we have been led to believe.
We want an open, transparent discussion about the environmental impacts, consumer costs, and economic ramifications of forced, policy-driven electrification efforts before they`re implemented. It is our hope that the electrification provisions in the proposal are removed.
Thank you for your consideration.
Sincerely,
Emma Corning
Executive Director
Wisconsin Propane Gas Association
emma@wipga.org
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