As the new home of WISPIRG's environmental work, Wisconsin Environment can be contacted with any questions regarding this testimony.
I would like to thank members
of Governor Doyle’s Energy Task Force for allowing me to address you this morning
and for allowing members of the public to comment as well. This is an exciting
moment in Wisconsin; energy policy is critical to any other effort we undertake
as a state, whether it is to grow our economy, enhance our quality of life,
and protect and preserve our natural environment. However, if Wisconsin is going
to seize the opportunity of renewable energy for our state, we need public policy
that not only supports new generation, but that also ensures that we are generating
energy from truly clean and sustainable sources and at levels that make future
renewable energy economically advantageous relative to heavily subsidized fossil
fuel plants. It is also critical that we stabilize and segregate all public
benefits money to ensure that the full cost-savings and innovative technology
investments are maintained no matter what other financial pressures our state
is facing.
To those ends, WISPIRG would
make the following recommendations to the Task Force:
Support a Strong 10%
by 2013 Target
- Wisconsin should follow its priorities for the addition of new sources of
energy by investing in renewable energy and energy efficiency projects before
approving new fossil fuel plants. Given that 7740 MW of new coal and gas have
either been approved or proposed in the last few years and only 418 MW of wind,
even with a 10% RPS, Wisconsin has a long ways to go to diversify its fuel mix.
- Renewable energy should be generated in Wisconsin whenever possible. Without
promoting new in-state generation, it is conceivable that Wisconsin could miss
out on the opportunities to create new jobs, generate income for local communities,
and become a leader in this high tech industry despite adopting a 10% renewable
energy target. If utilities are allowed to meet new renewable generation goals
through projects anywhere in their system, it is estimated that they would choose
to generate over 80% of all new wind energy at out-of-state wind farms. It would
be ironic if neighboring states such as Iowa and Minnesota, and even the providence
of Manitoba, were the economic beneficiaries of Wisconsin’s commitment to cleaner
energy.
- Wisconsin needs to adopt clear definitions about what will be counted as renewable
energy and it is important that the state only except definitions that count
emission-free, new generation, and environmentally sound projects. For this
reason, the definition of acceptable hydroelectric power should remain as it
is under our current Renewable Portfolio Standard that being no hydroelectric
projects over 60 MW and total generation counted is capped at .6% are counted
towards the RPS. While there are some efforts to allow all hydroelectric power
to be counted under a new target, this would essentially undermine efforts to
bring new generation of clean energy on line. In 2002, over 450 MW of hydropower
was produced in Wisconsin and if all of this were to count towards a renewable
energy goal, it would effectively wipe out 20% of new wind or other renewable
energy from being generated. In addition, including hydroelectric power as preferable
to wind, solar, and biomass is not beneficial as it has larger adverse environmental
impacts because the dams reduce water level, alter water temperature, and hold
back silt and debris which can bury fish spawning grounds.
- Wisconsin should maximize continued new generation of clean and sustainable
energy in our state by limiting utilities’ ability to bank credits of energy
that they have already produced to meet future obligations to three years. Currently,
Wisconsin is the only state in the nation that allows for indefinite banking
of credits to allow utilities to meet their obligations under our RPS. As a
result of this, Wisconsin utilities were able to meet their 2011 RPS goal by
2002, without having to bring any additional generation projects online.
- Renewable energy currently being generated to meet other state’s mandates
should not be counted for any new Wisconsin target. Not only does this undermine
efforts to spur new developments in Wisconsin, more importantly, it creates
the appearance of double-counting and undermines the spirit of generating new
renewable energy period. Ensuring that the same energy was not being double
counted to meet two state’s mandates, would require a separate tracking and
administrative process that will only add to the expense and the complexity
of the a Wisconsin RPS.
- Wisconsin should be aggressively working to generate renewable energy and
should be getting 20% of our electricity from clean and sustainable sources
of energy by 2020. Given our state’s abundant wind and biomass potential, coupled
with the declining costs of renewable energy projects and our need to diversify
our economy, Wisconsin should be looking beyond the next decade and planning
to meet our growing energy needs with all around beneficial sources of energy
rather than continuing to meet our needs with coal and natural gas.
- Any discretion given to the Public Service Commission to excuse utilities
from meeting defined goals should have clear guidelines. Currently, it is proposed
that a utility can apply for extension on the timeline for ‘economic’ or ‘technological’
infeasibility. However, those are very general terms and mere inconveniences
or slightly higher costs should not be considered valid reasons for not meeting
target timelines.
Protect the Public Benefits Fund
- It is critical that the Public Benefits Fund be set up as a segregated account
that can not be tapped by the Governor’s office or the Legislature to be used
as general funds. The security of the Public Benefits Fund is critical not only
to foster more beneficial energy efficiency projects, but also because unlike
other funds, the misappropriation of these funds means that not only is the
initial investment lost, but also all savings that could be obtained through
the project. Independent audits of the Focus on Energy Program have found that
for every dollar the state invested, there was a savings of five dollars.
- Public Benefit Fund should be limited to helping as many residential and small
businesses as possible. The goal of the public benefits fund is to provide funds
and expertise to small users who want to improve their energy efficiency but
would not have the financial means to do upfront investments. It is not be used
for a few large projects, such as the $1 million grant to General Motors Plant
in Janesville.
- Investment amounts in Public Benefits Fund should be set at the present day
continuation of the 1995 levels trajectory. Investments to the Publics Benefit
Fund peaked in 1995 and then declined after changes in the program were made.
Funding levels for the program should be set at the levels they would have grown
to if the program was not altered.
Other Energy Improvements
Wisconsin Could Make
- Wisconsin should adopt a mechanism for adopting the most efficient building
codes as they come online.
- Wisconsin should commit to furnishing all new government buildings with Energy
Star appliances.
- Wisconsin should adopt a model appliance efficiency bill which would require
that a set percentage of appliances sold in the retail market be Energy Star
appliances.
