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Focus on Energy: Quadrennial Planning Process V

WLGCC appreciates the opportunity to provide comments on the Commission’s Focus on Energy Quadrennial Planning Process. The Commission oversees Wisconsin’s statewide energy efficiency and renewable resource programs and is required to evaluate and set goals for Focus programs. We believe the Commission can best enable the Focus on Energy administrator and implementation team to meet expectations by granting the Focus administrator greater flexibility, allowing them to respond effectively to evolving market opportunities.

Individual Electric Metering

Demand Response (DR) Aggregation in Wisconsin

WLGCC supports swift implementation of demand response (DR) aggregation in Wisconsin so that all customers can benefit from the clean energy economy. We propose that the Public Service Commission allows retail customers like homes, businesses, and local governments to participate in DR programs through third-party aggregators. We also encourage the Commission to use existing MISO frameworks. This approach can help reduce peak energy demand, lower electricity costs, and enhance grid reliability.

WEC Oak Creek Testimony

Wisconsin needs to grow the stock of available housing, keep it affordable, and reduce energy burdens for residents. To achieve these objectives, housing developers and building owners should be able to pursue cost-effective whole-building clean energy technologies like rooftop solar and heat pumps. To facilitate this, WLGCC recommends several updates to the Commission’s individual electric metering rule to help minimize delays, reduce obstacles to affordable housing development, and streamline processes for developers, utilities, and PSC staff

WEC Paris Testimony

Many local communities across the state have demanded that their local governments achieve net zero emissions by 2050. All major investor-owned utilities in Wisconsin have also set net zero goals by 2050, and local governments are dependent upon these utilities to reach their goals so that they can reach their own. WLGCC has intervened in WEPCO’s proposal to construct seven natural gas-fired engines in Kenosha County to educate the Commission on the progress that local governments have achieved towards their clean energy goals, and urges the Public Service Commission to prioritize more cost-effective and sustainable alternatives to meet capacity needs, such as energy efficiency and demand response programs, which align with the state’s energy priorities.

Focus on Energy Fuel Neutral Savings Goal

We recommend the Quad IV energy savings goal shall be an overall MMBtu goal without fuel-specific savings targets. The program should continue to track and report kWh and therm savings. This approach allows for greater flexibility in how energy savings are pursued, particularly with the market moving towards electrification and increased heat pump adoption.

Focus on Energy Savings Attribution

WLGCC supports adjusting Focus on Energy’s savings attribution framework to allow full attribution of gross savings for projects and measures receiving co-funding from Focus on IRA Home Energy Rebates (HER) programs. We believe this is appropriate given the substantial support that Focus on Energy is offering to the HER programs, including administrative and implementation infrastructure as well as trade ally / contractor networks.

Investigation of Parallel Generation Purchase Rates

Training for Residential Energy Contractors Grant Program

Given the expected launch of the Home Energy Rebate programs (HER) within the next several months, it is important for the Commission to award these training funds as quickly and efficiently as possible, while ensuring that the funds are directed to filling known workforce gaps that will affect HER program deployment.

Home Energy Rebate Programs

The formula funds available to Wisconsin through the Inflation Reduction Act for the Home Energy Rebate Programs provide an incredible opportunity to improve energy efficiency and electrification adoption in residential homes in communities all across Wisconsin. The decarbonization of residential housing is essential in order for local governments to reach their community-wide greenhouse gas reduction goals.

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Strategic Energy Assessment (SEA)

WLGCC commends the commission’s efforts in the Strategic Energy Assessment (SEA) but emphasizes the need for proactive statewide planning to address rapid electrification, industrial growth, and decarbonization goals. We recommend expanding modeling to include efficiency, demand response, and an investigation into the future role of natural gas.