Viewing Grant Proposal: DTE Gas Osceola County Natural Gas Expansion

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 $1.0 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).

This is a handout to DTE and does nothing to reduce carbon emissions. Misappropriation of funds and a handout to DTE. They have plenty of money to pay for this themselves.

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 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.

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.

I do not support subsidizing DTE with taxpayer funds to expand natural gas lines. This does not help achieve the goal of carbon reduction.

We strongly oppose this proposal. 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 of 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 natural gas expansion – which is growing to be the largest source of emissions from many communities in Michigan. Using the applicant’s calculation, they see a 14% decrease in emissions when switching from propane to natural gas. However, that 14% is negligible when compared to the reductions that would happen if the 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 childhood asthma cases, adding to the score of research demonstrating the negative health effects from the use of natural gas in our buildings and their associated upstream emissions – something else that was not analyzed in this proposal. All this information can and should also be viewed in the context of how selecting this project would provide funds and future profits to a company who reports earning hundreds of millions of dollars a year in profit. This is especially relevant as the applicant who stands to profit from this expansion of service will be spending less than the taxpayers and the home and business owners for the project. Therefore, the funds for this grant should not be awarded to this project and should instead be awarded to projects that are seeking to make meaningful decreases to carbon emissions through renewable, zero-emission technologies. Projects like this one are inherently against the stated goal of the grant by locking in carbon, methane, and other GHG emissions for decades to come. This is precisely the type of project we should NOT be funding.

I strongly oppose this proposal as it is incredibly disingenuous to the purpose of the grant. 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 of 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 natural gas expansion – which is growing to be the largest source of emissions from many communities in Michigan. Using the applicant’s calculation, they see a 14% decrease in emissions when switching from propane to natural gas. Notably they erroneously do not account for the upstream emissions of natural gas production when making this determination. They note it as negligible, which is an unfair estimation from a company that stands to profit off this expansion that is hardly reduces carbon emissions by using funds for low-carbon energy. But, even when ignoring that reality, that 14% is still negligible when compared to the reductions and consumer savings that would happen if the 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 childhood asthma cases, adding to the score of research demonstrating the negative health effects from the use of natural gas in our buildings and their associated upstream emissions . All this information can and should also be viewed in the context of how selecting this project would provide funds and future profits to a company who reports earning hundreds of millions of dollars a year in profit. This is especially relevant as the applicant who stands to profit from this expansion of service will be spending less than the taxpayers and the home and business owners for the project, despite those individuals and businesses still having to pay the applicant for the service and suffer from the health impacts upon completion of the project. Therefore, the funds for this grant should not be awarded to this project and should instead be awarded to projects that are seeking to make meaningful decreases to carbon emissions through renewable, zero-emission technologies. Projects like this one are inherently against the stated goal of the grant by locking in carbon, methane, and other GHG emissions for decades to come. This is precisely the type of project we should NOT be funding as we transition to a cleaner, healthier, and more affordable Michigan.