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To: State Energy Policy Decision-Makers and Stakeholders
From: Customers First! Coalition
Date: November 20, 2003
Re: Customers First! Environmental Initiatives

Wisconsin has historically enjoyed relatively low electric rates and reliable electric service. To help ensure that this trend continues, the Customers First! Coalition works to support a balanced energy policy for Wisconsin. A balanced energy policy must include the development and construction of additional electric generation facilities, including renewable sources, building additional transmission facilities to meet growing demand needs and maintain system reliability and a strong commitment to cost-effective energy conservation.

Wisconsin will need to meet its growing energy needs and maintain and enhance system reliability through new generation and transmission construction. In conjunction with that construction, the Customers First! Coalition supports initiatives to help protect our environment and make sensible economic decisions.

Energy Conservation

1. Public Benefits
As additional infrastructure projects are proposed, it becomes increasingly important that energy conservation programs be both sufficiently funded and as effective as possible to avoid unnecessary infrastructure projects. The Public Benefits energy conservation program has been very successful in its first years of operation, forging relationships with builders, retailers and customers around the state to encourage the more efficient use of energy. According to the program evaluator, the efforts have returned benefits of over $3 for every dollar spent in the most recent reporting period. This program creates good jobs in Wisconsin, helps keep electric rates in check and improves the environment.

The Customers First! Coalition (CFC) has been involved with, and supportive of, the Public Benefits program since its inception. In 2003, CFC made its best efforts to preserve the funding, collected from state ratepayers, for the Public Benefits program. However, the legislature and the governor approved substantial cuts to the program because of the state's fiscal crisis. CFC will continue to work with legislators, the governor, the Department of Administration, and the Public Service Commission to achieve fully funded energy conservation and efficiency programs as the state enters a building cycle, mindful of the financial impact on ratepayers

2. Energy Codes Collaborative
CFC and WeEnergies (with other stakeholders) agreed to the formation of the Energy Codes Collaborative as a meaningful environmental mitigation measure. After a year of work, the collaborative is finalizing recommendations for improvements to the residential energy code, including recommendations to improve air exchange and ventilation requirements and to prohibit the use of mercury thermometers in new homes. The collaborative is also reviewing suggestions that the state pursue higher efficiency standards for appliances. In addition to technical improvements to the code, the collaborative is also concentrating on efforts to better educate builders about and enforce existing residential codes. The collaborative is now beginning a review of the commercial energy code.

CFC has been involved with the collaborative both through individual members and through the coalition. When the collaborative reaches a consensus position on residential and commercial code improvements, CFC is committed to supporting the changes in the Department of Commerce rulemaking process.

3. Economic Development through Energy Conservation and Renewables
CFC supports promoting the development of businesses in Wisconsin that produce energy efficiency and renewable energy products. However, given the condition of the state's finances, it seems unlikely that any major tax incentives are likely for these businesses over the coming biennium.

In 2002, Senator Shibilski introduced a budget amendment that would have allocated 5% of Department of Commerce Technology Development and Commercialization Grants and Loans for businesses that develop clean energy or energy efficiency technologies. If implemented this biennium, the provision would result in making available almost $300,000 in grants and loans for renewable energy and energy efficiency businesses. Such measures could help Wisconsin gain a competitive advantage in attracting businesses that produce renewable energy and energy efficiency products, which would provide environmental benefits, create jobs and drive Wisconsin's economy.

CFC supports an initiative to earmark 5% of the Technology Development and Commercialization Grants & Loans program for assistance for renewable energy and energy efficiency businesses.

Renewable Energy

1. Renewable Energy Target
CFC supports a voluntary Renewable Energy Target of at least 5% by 2011 for Wisconsin utilities. A Renewables Target is both more reasonable from a utility perspective and more meaningful from an environmental perspective. Unlike the mandatory Renewable Portfolio Standard approach, the Renewable Energy Target model allows utilities to offer the renewable energy that is acquired to meet the goal through a pricing structure designed to attract customer support, often called "green pricing". Another advantage of the Renewable Energy Target approach is that it allows utilities to count all of their existing small-scale hydro resources toward the goal (whereas the Renewable Portfolio Standard caps the amount of hydro that a utility can count). The assurance that measures will be implemented would be provided, for example, through bilateral arrangements between renewable interests and load-servers. In the case of regulated investor-owned utilities, it could also come from commitments proposed in regulatory proceedings and approved by the Public Service Commission and/or from policy guidance provided by the Public Service Commission.

2. Use of Renewables and Energy Efficient Products in State Buildings
It would be desirable for the State of Wisconsin to be more active in pursuing renewable or distributed energy options for state facilities (in partnership with the local utility). However, it is important that no effort to increase state facility use of renewable energy inadvertently results in retail deregulation. There is currently legislation on the books that directs greater use of renewable and distributed energy at state facilities; however, in practice, these laws are often insufficiently incorporated into the decision-making process for individual facilities. CFC will encourage the Department of Administration to make administrative changes to better implement existing priorities regarding increased use of renewable and distributed energy at state facilities.

This past April, Senator Cowles introduced SB 111, which requires the use of energy efficient components in the construction of state facilities. CFC supports this bill and would support other initiatives to maximize cost effective, technically feasible energy efficiency efforts at state facilities.

3. Incentivizing Small Wind & Bio-gas Projects
The farm community in Wisconsin has embraced the concept of integrating renewable energy production (particularly wind and bio-gas generation) into its business operations. As a result, the Wisconsin Farm Bureau recently identified the increase of alternative energy use and production as one of their top three policy goals. CFC strongly supports efforts to encourage more development of on-farm renewable generation in Wisconsin. Financial incentives to help make the initial investment in the generation equipment affordable are available to farmers through the Focus on Energy (FOE) program.

While some state efforts could provide additional assistance and incentives for farmers, expansion of the federal production tax credit to apply to dairy-based manure digesters would be, by far, the most significant step to encourage bio-gas development in Wisconsin. CFC supports this measure and will be in contact with Wisconsin's Congressional delegation to push for such a change in federal legislation.