Suggested comments on Global Warming Task Force proposals

Posted on December 7, 2007. Filed under: Carbon, Energy Policy, Global Warming, Nuclear, Solar, Vehicles, Wind |

Ryan Schryver from Clean Wisconsin drafted suggestions for comments on the proposals made by the workgroups of the Govenor’s Global Warming Task Force. Comments can be made online at through December 14.

Work group: Electric Generation and Supply Policies

Enhanced Renewable Energy Portfolio Standard
This draft policy calls for between 15% by 2020 and 25% by 2025 renewable electricity. The electricity would come from imported renewable electricity as well as Wisconsin-produced electricity.

• Comments should focus on supporting renewable electricity goals of 20% by 2020 and 25% by 2025, which would agree with the goals in the “Energy Security and Climate Stewardship Platform for the Midwest” (“Midwest Energy Platform”), signed by Gov. Doyle and other Midwest Governors on Nov. 15.

• The renewable electricity goals should be achieved without reliance on hydro electricity from dams larger than 60 megawatts, which would exclude large Canadian hydro power.

Incentives for Combined Heat & Power
This draft policy encourages replacement of old, non-utility steam boilers with combined heat & power systems.

• Comments should encourage the strengthening of this policy to include replacement or repowering of utility power plants into combined heat and power plants. This option was deemed infeasible by the utilities, although it has been suggested for study in the “Policy Forum” policy proposal.

Relax Restrictions on Construction of New Nuclear Power Plants
This draft policy would repeal §196.493, Wis. Stats., the so-called “nuclear moratorium law,” which states that the Public Service Commission of Wisconsin (PSC) may not authorize the construction of a nuclear plant unless it finds that a facility will be available for the disposal of high-level waste from all Wisconsin nuclear plants, and that the proposed plant is economically advantageous to ratepayers based on specified factors.

This law should not be repealed. Comments on this policy could include the following concerns:

Cost: A new nuclear plant would be extremely expensive. Standard & Poor’s recently estimated the cost of a new nuclear plant at $4000 per kW; and Moody’s recently suggested $6,000 per kW. Nuclear plants currently being built in other countries continue to experience massive cost overruns and delays in completing the projects.

Safety: New nuclear plants would increase the risk of a serious reactor accident, which could threaten thousands of people and cost billions to deal with.

Nuclear Waste: For the foreseeable future, there remains no safe means of disposal for nuclear waste. Building additional nuclear plants in Wisconsin would only add to the problem in which thousands of tons of waste are sitting on the shores of Lake Michigan and along the Mississippi River.

Wisconsin as a Nuclear Waste Dump: The failure of the federal government to open Yucca Mt. in a timely fashion, if ever, increases pressure to find an alternate site for disposal of nuclear waste. The Wolf River area was studied in the past, and could be studied in the future as a disposal site for the nation’s nuclear waste.

Nuclear Does Not Help with Global Warming Pollution: While the operation of a nuclear plant may not directly produce GHG emissions, GHG emissions are released at various points throughout a plant’s lifecycle (construction, uranium mining and enrichment, spent fuel disposal, decommissioning, etc). According to MIT researchers, it could take nearly 1,000 additional nuclear plants to make a significant contribution toward reducing global warming pollution, whereas other strategies such as energy efficiency and renewable energy would be much less costly.

Work group: Electric Generation and Supply Policies (continued)

Policy Forum for Planning in the Electric Generation Sector
At the urging of the utilities, Wisconsin policy makers dismantled Wisconsin’s electricity planning process in the late 1990s. Without a comprehensive planning process, Wisconsin utilities will not make the right decisions regarding investments in energy efficiency, renewable energy, conventional power plants, and power lines. Wisconsin needs to restore a comprehensive planning process, and this policy forum would be a useful next step.

Wind Siting Reform
Legislation is needed in Wisconsin that improves the process for siting wind projects smaller than 100 megawatts in capacity. This policy encourages the passage of legislation that would give the PSC oversight over wind projects without removing the authority of local jurisdictions to place appropriate requirements on the project.

Off-shore Wind Study
This proposed policy would require state agencies to conduct a study of the technical and economic potential for generating electricity from wind farms built in the Great Lakes. Thousands of megawatts of wind electricity could be safely and economically developed without compromising the environment of the Great Lakes. This study would be a useful step toward developing wind projects in the Great Lakes.

Conservation and Efficiency Policies
In general, all of the policies from the Conservation and Efficiency working group would increase the energy efficiency of Wisconsin’s households, businesses, and institutions. Since energy efficiency and conservation are the best policies for reducing global warming pollution, all of them should be support.

That said, the most important policy is “Enhanced Energy Efficiency and Conservation Programs,” which would establish goals of saving 1.5% of electricity and 1.0% of natural gas each year by 2012. This policy should be strengthened, so that the goals of saving energy are 2% each year for electricity and natural gas by 2015, which are the goals in the “Energy Security and Climate Stewardship Platform for the Midwest” (“Midwest Energy Platform”), signed by Gov. Doyle and other Midwest Governors on Nov. 15.

Carbon Tax/Cap and Trade Policies

1. The cap & trade target will need to be stronger than 1990 levels by 2020, because it will be harder to reach these levels in other sectors and cost more.

2. We should auction all of the allowances under a cap & trade rather than give them to polluters for several reasons:
a. A giveaway rewards the biggest polluters; whereas an auction rewards early action to reduce emissions;
b. The proceeds from the auction can be used to reduce the overall cost of reaching the target (investments in efficiency);
c. Proceeds can be used for training and other job creation programs needed to shift to a clean energy economy.

3. The extent to which offsets (emission reductions or sequestration by sources not covered by the cap) can be used for compliance should be limited (e.g. 10% of compliance).

4. There should be no “safety valve” or “price breaks” that allow polluters to automatically miss the reduction targets. There could be periods for review to make adjustments (e.g. every 5 years).

Transportation Policies

California Cars rule (needed very badly)
GM opposes the California car saying that it sets impossible goals and simply won’t sell any of its cars that don’t currently meet this higher standard in Wisconsin if we adopt it. The reality is that they can meet the standards – they are several vehicles that already meet the standards. Automakers have opposed any real changes to CAFE since the 70’s. They can make cars and heavy trucks that go from 0-60 in under 6 seconds but somehow can’t do what Toyota and Honda can do- make fuel efficient vehicles?

They brought the state by state checkerboard policy on themselves by refusing to accept any changes in DC,

The facts: California car is the single most effective transportation strategy in the short run. It eliminates nearly one third of all auto based greenhouse gas emissions by 2020, It is an essential component of any rational approach to reducing greenhouse gasses.

Demand side strategies
All of the technology gains from hyper fuel-efficient cars will be wiped out by growth in vehicle miles driven – unless we take steps to curb our growing appetite for driving. Even a 90 mpg car would have to be accompanied by a 20% decrease in miles driven in by 2050 to meet the goal of 80% ghg reductions according to a Vancouver study. Demand side strategies are intended to reduce the need to drive everywhere.

Transit has been underfunded for 60 years and the results are plain. Wisconsin transit systems are much worse than any third world city transit system. We need a dedicated funding source – an RTA – to provide a stable funding source to expand services which have been decreasing for decades.

Transportation Demand Management is the corollary to transit. TDM provides incentives for people to use transit. TDM don’t work without good transit systems and good transit systems become better transit systems with TDM. The relationship is symbiotic. It is core to the need of reducing carbon emissions from vehicles.

Transportation Planning and Funding is a hodgepodge of strategies to encourage compact growth and to discourage sprawl. Perhaps the most controversial recommendations are the TIF proposals. Tax Incremental Financing was created to help eliminate urban blight by measuring future tax revenues that result from better development and using those dollars in advance to pay for infrastructure improvement. TIF has been enormously successful in eliminating blight. However, it has been hi-jacked by suburban developers to pay for greenfield sprawl development – directly counter to the whole idea behind TIF. It’s time to reign this tool in and eliminate it’s use for sprawl and limit it to blight elimination – or at least limit its use to already developed urban areas.

“Fix it First” This common sense policy says that before we build new highways, we need to have the money in hand to fix our existing highways.

Direct aid for compact development or Traditional Neighborhoods. This would take transportation dollars to help communities develop compact neighborhoods. Dollars would be made available for streetscaping, bike paths, pedestrian improvements, etc. The goal here is to enhance accessibility — not just mobility.

Industry Working Group
Bullet Points for Industry Work Group Policy Templates:

1. Industrial Boiler Efficiency Improvements and Industrial Boiler Fuel Switching

• The templates indicate approximately 3,000 boilers in WI. Significant GHG reductions and operation cost savings could be captured by increased efficiency and fuel conversion of all or the majority of these boilers.
• The templates propose a very large draw on FOE monies for this project, out of proportion to the contributions to FOE from the owners of these boilers. We prefer an alternative funding mechanism (perhaps a low interest loan state fund or state bonding) and a state tax incentive to incent these projects.
• Any permit problems could be addressed under the Nov. 29, 2007 MOU among US DOE-State of Wisconsin PSC-FOE-CleanTech Partners that includes a provision: “Engage EPA Region V if federal permitting becomes a barrier in implementing these technologies.”

2. Emissions Data Feedback Policy

Congratulations! This is an excellent policy template.
• Gathering annual GHG emissions data will be useful not only to industry and state government but also to industrial energy efficiency consultants, suppliers and the public.
• We support: identifying tolls to help industry measure and quantify emissions; establish sector goals; adopt energy auditing and budgeting by industrial sector; provide measuring devises, e.g. smart meters.
• We especially endorse: setting emissions reduction targets and measuring reduction in relation to impact on “quality” job metrics. Let’s use clean energy policies to promote both Wisconsin’s economy and quality job growth.
• The threshold for mandatory reporting of emissions should be set low enough to provide useful information about industry sectors that are outside the regional cap-and-trade system and that are covered by a carbon tax. This will enable analysis by industry to monitor reductions in emissions (and carbon taxes) and to “avoid” emissions creeping upward to the cap-and-trade threshold.
• The timeline for adopting this policy should be this legislative session, 2007-8.

3. Templates on Existing Programs and Education and facilitation
• Support these templates because they enhance what already works and recognize the important roles of a full range of educational, technical and labor union programs. Increased coordination should support these efforts and increase efficiencies.
4. Reduction of Emissions of High GWP Gases

• We endorse the statements submitted by the DNR (which can be viewed at )

5. Wisconsin Business Sustainability Council, Recognition and Pilot Projects for Business GHG Reductions

• Comments should indicated general support for the initiative. It is important to note there is a proposal for streamlining or regulatory release for energy related projects. We still need to include clean air act review as well as maintain extensive opportunities for local government and citizen concerns to be addressed


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3 Responses to “Suggested comments on Global Warming Task Force proposals”

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The most effective action that could be taken would be a carbon tax. This is not even mentioned in the above article. Why not?

If you click on Continue Reading at the bottom of the entry, you’ll get to more commentary, including a section on carbon.

Thanks for the reply Ed. The section on carbon does not mention carbon tax, only cap and trade.
It is my contention that a direct carbon tax is more effective and less subject to manipulation by special interests.

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