Viewing Grant Proposal: DTE Gas Delta County Natural Gas Expansion

Quite simply, these proposals do not achieve the goal of carbon reduction. The carbon intensity difference between propane and natural gas is negligible. If this proposal is selected, then taxpayers will be paying for truly no decrease in carbon emissions. These funds should be used for projects that actually do decrease the our carbon footprint. Also, If this proposal is selected, then taxpayers will be paying the expansion costs for a company that already reports hundreds of millions of dollars in annual profits. This company can obviously afford to expand its customer base without using tax payer dollars.

Natural gas utilities already have every ability to expand natural gas lines to the rural parts of Michigan. DTE Gas does not need to utilize taxpayer funds through the Low Carbon EIED grant program to expand natural gas as proposed in this project. DTE 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, Ferrellgas would argue that these grants should go to benefit local units of government with projects that benefit large communities. • DTE Gas inflates the cost savings by switching from natural gas to propane. • DTE uses 1050 gallons of propane use for its base calculation. 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. Using the basis of 770 gallons per year as an average propane use, DTE Gas has inflated its calculations by 36 percent. These numbers greatly exaggerate 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. DTE Gas acknowledge that homeowners will have upfront expenses to make the fuel switch to natural gas, and rebates of up to $500 will be provided. • 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 miss that mark. Quite simply, these proposals do not achieve the goal of carbon reduction. The carbon intensity difference between propane and natural gas is negligible. If this proposal is selected, then taxpayers will be paying for truly no decrease in carbon emissions. This project 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. DTE Gas should fix their existing leaking pipelines before they should be considered for any pipeline expansion. 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. The natural gas utilities will needlessly tear down trees and dig up right of ways to bury gas mains. 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. Projects like these will provide the greatest reduction in carbon and emissions while providing the greatest benefits to overall end-use customers. As a propane company in the Upper Peninsula and Delta County community, I employ 8employees in this area. This project seriously jeopardizes my ability to continue providing these local jobs and careers in this area.

I understand that 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, switching from propane to natural gas does not achieve that goal. The carbon intensity difference between propane and natural gas is negligible, thus this proposal does not achieve the goal of carbon reduction. If this proposal is selected, taxpayers will be paying for truly no decrease in carbon emissions. Also, DTE 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 DTE Energy reported net income of over $900 million dollars! In addition, DTE’s proposal grossly inflates by 36% the carbon reduction savings and the cost savings of switching from propane to natural gas. DTE uses 1050 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, DTE’s numbers exaggerate by 36% 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 DTE’s proposal. Let’s concentrate on projects that provide the greatest reduction in carbon emissions, which 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, switching from propane to natural gas does not achieve that goal. The carbon intensity difference between propane and natural gas is negligible, thus this proposal does not achieve the goal of carbon reduction. If this proposal is selected, taxpayers will be paying for truly no decrease in carbon emissions. Also, DTE 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 DTE Energy reported net income of over $900 million dollars! In addition, DTE’s proposal grossly inflates by 36% the carbon reduction savings and the cost savings of switching from propane to natural gas. DTE uses 1050 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, DTE’s numbers exaggerate by 36% the carbon savings and cost savings for consumers if switching from propane to natural gas. This project does not require DTE to fix or upgrade their existing lines leaking natural gas 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. DTE should fix their existing leaking pipelines before they should be considered for any pipeline expansion. 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 DTE’s proposal. Let’s concentrate on projects that provide the greatest reduction in carbon emissions and benefits all Michiganders.

Natural gas utilities already have every ability to expand natural gas lines to the rural parts of Michigan. Neither Consumers Energy nor DTE Gas need to utilize taxpayer funds through the Low Carbon EIED grant program to expand natural gas as proposed in this and the six other projects. Both Consumers Energy and DTE report hundreds of millions of dollars in profits annually, and both utilities have more than enough resources to expand natural gas lines without taxpayer funded grants.

As the name implies, these Grants should be focused on using Taxpayer funds to “Lower Carbon” emissions. As a Michigan taxpayer, I am in favor of lowering our carbon emissions. However, this proposal which is requesting $1.26 million dollars from the Low Carbon EIED Grant is not accomplishing that. Let’s put these funds towards projects that can provide SIGNIFICANT carbon reduction. The request for this proposal had the objectives of supporting the reduction of carbon emissions and greenhouse gasses (GHGs) along with providing end-use customers access to low carbon energy facilities. This proposal does not succeed in either of these objectives. Converting customers already on one of the cleanest burning fossil fuels, propane, to another clean burning fossil fuel, natural gas, makes little to no difference. Propane and natural gas have very similar carbon footprints. Therefore, this proposal is not providing any real reduction in carbon emissions and is not providing end-users with a better low carbon energy facility. These customers already have access to a very clean fuel - propane. What is most concerning with this proposal is that DTE is wanting to replace propane with natural gas which is composed of 70%-90% METHANE - the worst Greenhouse Gas! Any leaks in these natural gas systems have horrific consequences for global warming due to the direct emission of methane, which is considered to be 80 times worse than CO2 for global warming! DTE even published in 2017 that over 25,000 Metric Tons of methane leaked from their own facilities and pipelines. A simple 1% reduction in natural gas leaks or emissions would drastically outweigh this entire proposal. Again, I strongly discourage funding this proposal as it has no true merit towards reducing carbon emissions, greenhouse gasses, or decreasing global warming. This proposal will simply use taxpayer dollars to convert clean burning propane households to clean burning natural gas households, while increasing the distribution and possibly emission of methane (arguably the worst GHG).

Our taxpayer funds for carbon emissions reduction should not go towards expanding natural gas. This is DTE misdirecting funds to try and fund their business when it does nothing to reduce emissions.

DTE Gas already has every ability to expand natural gas lines to the rural parts of Michigan. DTE Gas does not need to utilize taxpayer funds through the Low Carbon EIED grant program to expand natural gas as proposed in these seven projects. DTE 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. DTE Gas reports that their estimated annual methane emissions to be tens of thousands of megatons each. 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 any of these proposed projects were approved, then taxpayers will be paying millions of dollars 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, DTE Gas inflates the cost savings by switching from natural gas to propane. DTE uses 1050 gallons of propane use for its base calculation. 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, DTE Gas has inflated its calculations by 36 percent. Also exaggerated were the savings that homeowners will receive from the switch from propane to natural gas. DTE Gas acknowledges that homeowners will have upfront expenses to make the fuel switch to natural gas, and rebates of up to $500 will be provided. 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 the above-listed proposals 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.

Why can't DTE fork out the money to fix the pipes that need fixing already!!! Are these new lines going to leak like the one in the great lakes? Why are we going to let DTE tear up Michigan's beautiful ecosystems just to put in a new natural gas line that aren't needed in the first place? You would put more carbon into the air just by trenching these new lines, bringing the materials to trench these new lines, making the materials for these new lines....point blank...it ain't smart.