Viewing Grant Proposal: Consumers Energy Wilson Renewable Natural Gas

One of the main goals of the EIED Grants is the reduction of carbon emissions, and these grants if used properly, can make a real difference in lowering carbon emissions. However, part of this proposal includes switching customers from propane to natural gas, which does not achieve that goal. The carbon intensity difference between propane and natural gas is negligible, thus this part of the proposal does not achieve the goal of carbon reduction, and taxpayers will be paying for truly no decrease in carbon emissions. Also, Consumers Energy already has every ability to expand natural gas lines in Michigan and does not need taxpayer funds from the Low Carbon EIED grant program to do it. In fact, in 2021 Consumers Energy reported net income of over $1.3 billion dollars! In addition, Consumers Energy's proposal grossly inflates by 39% the carbon reduction savings and the cost savings of switching from propane to natural gas. Consumers Energy uses 1069 gallons of propane for an average consumer for its calculations for both carbon savings and cost savings, however for factual reference, the US Energy Information Administration (EIA) Residential Energy Consumption (REC) report lists the average Michigan residential usage at 770 gallons per customer. As evident, Consumer Energy’s numbers exaggerate by 39% the carbon savings and cost savings for consumers if switching from propane to natural gas. I encourage the MPSC to use the EIED Grants to make meaningful reductions in carbon emissions, a main goal of the legislation that created the grant program, which is not accomplished by the amounts stated in Consumers Energy's proposal. Let’s concentrate on projects that provide the greatest reduction in carbon emissions and benefits all Michiganders.

One of the main goals of the EIED Grants is the reduction of carbon emissions, and these grants if used properly, can make a real difference in lowering carbon emissions. However, part of this proposal includes switching customers from propane to natural gas, which does not achieve that goal. The carbon intensity difference between propane and natural gas is negligible, thus this part of the proposal does not achieve the goal of carbon reduction, and taxpayers will be paying for truly no decrease in carbon emissions. Also, Consumers Energy already has every ability to expand natural gas lines in Michigan and does not need taxpayer funds from the Low Carbon EIED grant program to do it. In fact, in 2021 Consumers Energy reported net income of over $1.3 billion dollars! In addition, Consumers Energy's proposal grossly inflates by 39% the carbon reduction savings and the cost savings of switching from propane to natural gas. Consumers Energy uses 1069 gallons of propane for an average consumer for its calculations for both carbon savings and cost savings, however for factual reference, the US Energy Information Administration (EIA) Residential Energy Consumption (REC) report lists the average Michigan residential usage at 770 gallons per customer. As evident, Consumer Energy’s numbers exaggerate by 39% the carbon savings and cost savings for consumers if switching from propane to natural gas. I encourage the MPSC to use the EIED Grants to make meaningful reductions in carbon emissions, a main goal of the legislation that created the grant program, which is not accomplished by the amounts stated in Consumers Energy's proposal. Let’s concentrate on projects that provide the greatest reduction in carbon emissions and benefits all Michiganders.

Consumers Energy already has every ability to expand natural gas lines to the rural parts of Michigan. Consumers Energy does not need to utilize taxpayer funds through the Low Carbon EIED grant program to expand natural gas as proposed in this project. Consumers Energy reports hundreds of millions of dollars in profits annually and has more than enough resources to expand natural gas lines without taxpayer funded grants. Instead, the MPGA would argue that these grants should go to benefit local units of government with projects that benefit large communities. Additionally, this grant program does not require the utility companies to fix or upgrade their existing lines to protect their existing customers. Instead, natural gas leaks cause methane discharges, among the worst air pollutants and greenhouse gases. Methane is a super pollutant that is up to 83 times more potent as a greenhouse gas than carbon dioxide in its ability to trap heat in the atmosphere. Consumers Energy reports that their estimated annual methane emissions to be tens of thousands of megatons. Above all, this grant program is intended to prioritize projects that reduce carbon emissions, and these proposals simply do not achieve that goal. Carbon intensity is expressed in grams of carbon dioxide equivalent per megajoule of energy provided by that fuel, and the carbon intensity difference between propane and natural gas is negligible. In fact, according to a recent study conducted by GTI Energy for the Propane Education and Research Council (PERC), the carbon intensity of propane consumed here in Michigan is 77.64 gCO2eq/MJ whereas the carbon intensity for compressed natural gas (CNG) is 78.21-80.59 gCO2eq/MJ. Going from propane to natural gas provides no meaningful reduction in carbon emissions, and, in fact, may result in more greenhouse gas emissions through increased fugitive methane emissions by the utilities. If this proposed project is approved, then taxpayers will be paying for truly no decrease in the carbon emissions. Of course, another factor not considered in the calculation of low carbon intensity is just how much carbon will be generated to dig up communities identified in these seven proposals to bury the new gas lines. By contrast, the propane infrastructure for customers is built to last for decades and is entirely recyclable including tanks, gas lines, valves, regulators, etc. at end of service life. Because propane systems are onsite energy systems (like solar or wind energy), there is no need to tear down trees, dig up right of ways to bury gas mains, nor otherwise harm the environment. Much like the claims for a lower carbon reduction are inflated, Consumers Energy inflated the cost savings by switching from natural gas to propane. Consumers Energy uses a basis of 1069 gallons for an average propane consumer. For factual reference, the US Energy Information Administration (EIA) Residential Energy Consumption (REC) report lists an average residential usage in at 770 gallons per customer. The most recent calculations performed by Frost and Sullivan for PERC’s Annual Retail Propane Sales Report indicates that an average residential propane account in Michigan consumes 588 gallons per year. Even using the higher, more conservative amount of 770 gallons per year, Consumers Energy has inflated its calculations by 39 percent. This greatly exaggerates any savings for consumers switching from propane to natural gas. Also exaggerated were the savings that homeowners will receive from the switch from propane to natural gas. Consumers Energy acknowledges that homeowners will have upfront expenses to make the fuel switch to natural gas. However, it is likely to cost homeowners thousands of dollars to buy or convert furnaces, water heaters, stoves, and/or clothes dryers. Additionally, those homeowners will have out-of-pocket expenses for customer attachment program (CAP) to make the fuel switch. As savings to homeowners is a priority of the Low Carbon EIED program, these projects again miss that mark. The Michigan Propane Gas Association encourages you to reject this proposal for failing to adequately meet the program criteria. This project: • Fails to benefit the largest number of end-use customers by targeting a limited number of propane end-users. • Fails to meaningfully reduce customer energy burdens by overexaggerating propane use of customers. • Fails to support the reduction of carbon emissions as propane and natural gas emit nearly an identical amount of carbon, and natural gas emits methane which when emitted directly into the air is 83 times more potent a greenhouse gas than carbon dioxide. • Fails to provide any evidence to support Environmental Justice and Equity Principals Instead, the MPGA continues to encourage you to consider using this new grant program to focus on switching large industrial, agricultural and commercial operations that are currently using fuels such as coal, oil, or diesel to lower carbon intense fuels. Projects such as the Genesee County Digesters at Ragnone Wastewater Treatment Plant, the City of Lansing Wastewater Treatment Facility Solar PV and Aeration, the Kent County Bioenergy Facility, the Midland Cogeneration Venture Carbon Capture and Sequestration Feed Feasibility Study, and the Traverse City Solar and Battery Energy Storage at Wastewater Treatment Plant seemingly make better cases for lowering carbon intensity in our state. These projects also seem to impact many more Michigan residents. Projects like these will provide the greatest reduction in carbon and emissions while providing the greatest benefits to overall end-use customers.

One of the main goals of the EIED Grants is the reduction of carbon emissions, and these grants if used properly, can make a real difference in lowering carbon emissions. However, part of this proposal includes switching customers from propane to natural gas, which does not achieve that goal. The carbon intensity difference between propane and natural gas is negligible, thus this part of the proposal does not achieve the goal of carbon reduction, and taxpayers will be paying for truly no decrease in carbon emissions. Also, Consumers Energy already has every ability to expand natural gas lines in Michigan and does not need taxpayer funds from the Low Carbon EIED grant program to do it. In fact, in 2021 Consumers Energy reported net income of over $1.3 billion dollars! In addition, Consumers Energy's proposal grossly inflates by 39% the carbon reduction savings and the cost savings of switching from propane to natural gas. Consumers Energy uses 1069 gallons of propane for an average consumer for its calculations for both carbon savings and cost savings, however for factual reference, the US Energy Information Administration (EIA) Residential Energy Consumption (REC) report lists the average Michigan residential usage at 770 gallons per customer. As evident, Consumer Energy’s numbers exaggerate by 39% the carbon savings and cost savings for consumers if switching from propane to natural gas. I encourage the MPSC to use the EIED Grants to make meaningful reductions in carbon emissions, a main goal of the legislation that created the grant program, which is not accomplished by the amounts stated in Consumers Energy's proposal. Let’s concentrate on projects that provide the greatest reduction in carbon emissions and benefits all Michiganders.

We do not support this project for two reasons: 1) this corporation already has the economic means to build this facility and, instead of integrating into their IRP, they are asking taxpayers to fund which is irresponsible; and 2) projects of this nature should be put on hold until we fully develop truly renewable energy solutions, and this funding opportunity should not go to projects like this. The stated goal of the EIED grant program is to develop low carbon energy infrastructure. Additionally, the MI Healthy Climate Plan calls for Michigan to reach carbon neutrality by 2050, with a prioritization on actions that will provide the most rapid gains in GHG reductions. But this proposal does not further either of these goals as it focuses on the continued use of natural gas. While using renewable natural gas can slightly reduce total carbon emissions, this reduction is negligible when compared to the reductions that would happen if homes and businesses were converted to electric and powered with 100% renewable energy. Furthermore, these calculations do not account for the public health impact from the emissions of methane, NOx, and other pollutants that are emitted through the combustion of natural gas in homes and businesses. A recent study showed that pollution from gas stoves could be attributed to 12% of the childhood asthma cases, adding to the scores of research demonstrating the negative health effects from the use of natural gas in our buildings and their associated upstream emissions – something that was not analyzed in this proposal. All this information can and should be viewed in the context of providing funds and future profits to a company who reports earning hundreds of millions of dollars a year in profit yet will be spending a significant amount less than the taxpayers who would see the benefits. Therefore, the funds for this grant should not be awarded to this project and should instead be awarded to projects that are seeking to actually make meaningful decreases to carbon emissions through renewable, zero-emission technologies. Projects like this one that are inherently against the stated goal of the grant by locking in carbon, methane, and other GHG emissions for decades to come should not be eligible for this grant, let alone considered for being awarded funds.

I do not support this project because the utilities are for-profit and can fund this work themselves and we should be putting these funding dollars toward the development of resilient, clean, renewable energy generation.

I do not support this project as this corporation already has the economic means to build this facility, but are instead irresponsibly asking taxpayers to fund this expansion; and 2) projects of this nature should be put on hold until we fully develop truly renewable energy solutions instead of questionable renewable solutions that only further the usage of nonrenewable energy. The stated goal of the EIED grant program is to develop low carbon energy infrastructure. Additionally, the MI Healthy Climate Plan calls for Michigan to reach carbon neutrality by 2050, with a prioritization on actions that will provide the most rapid gains in GHG reductions. But this proposal does not further either of these goals as it focuses on the continued use of natural gas. While using renewable natural gas can slightly reduce total carbon emissions, this reduction is negligible when compared to the reductions that would happen if homes and businesses were converted to electric and powered with 100% renewable energy. Furthermore, these calculations do not account for the public health impact from the emissions of methane, NOx, and other pollutants that are emitted through the combustion of natural gas in homes and businesses. A recent study showed that pollution from gas stoves could be attributed to 12% of the childhood asthma cases, adding to the scores of research demonstrating the negative health effects from the use of natural gas in our buildings and their associated upstream emissions – something that was not analyzed in this proposal. All this information can and should be viewed in the context of providing funds and future profits to a company who reports earning hundreds of millions of dollars a year in profit yet will be funding this project through taxpayer funds. Therefore, the funds for this grant should not be awarded to this project and should instead be awarded to projects that truly need the funding and are seeking to actually make meaningful decreases to carbon emissions through renewable, zero-emission technologies. Projects like this one that are inherently against the stated goal of the grant by locking in carbon, methane, and other GHG emissions for decades to come should not be eligible for this grant, let alone considered for being awarded funds, especially when accounting for the considerable financials of the applicant who will only stand to gain additional profit at the expense of taxpayer funds, which is irresponsible at best.

I do not support this project. Consumer's energy has the economic means to build this facility, rather than asking taxpayers for the funding.

I am strongly against this proposal. Both state and local governments have set ambitious goals for carbon neutrality, but achieving these goals can be difficult for many local governments due to a lack of financial resources – whereas large corporations that report profits of hundreds of millions of dollars should already have the funding for this work. Therefore, I strongly believe that funds from this grant program, the goal of which is to develop low carbon energy infrastructure, should not go towards projects proposed by these large corporations, including Consumers Energy. Corporations such as Consumers asking for taxpayers to fund their work is irresponsible and immoral. In addition, natural gas is not truly renewable, is not low carbon, and is associated with a wide variety of negative health impacts. Projects like this one that are inherently against the stated goal of the grant by locking in carbon, methane, and other GHG emissions for decades to come should not be eligible for this grant, let alone considered for being awarded funds.

Consumer's Energy should be using their current funding to build infrastructure, not competing for additional funds that could be employed by cash-strapped communities working to build actual renewable energy and reduce fossil fuel consumption.