Submitted Comments on the Ad-hoc Water Conservation Template

							      Submitted Comments on the Ad-hoc Water Conservation Template

From: Wilusz, Edward J.
Sent: Friday, May 09, 2008 7:44 AM
Subject: Comments on Focus On Water Template

The following comments are submitted on behalf of the members of the Wisconsin Paper Council
regarding the May 5 draft of the Focus on Water template. In addition, we have solicited
comments from other business groups.

Our view on state energy efficiency assistance programs, in general, is that the highest priority
should be given to projects that would result in the greatest energy savings and, therefore,
greenhouse gas emission reductions, regardless of what type of project it is. In other words, the
state should start with the biggest bang for the buck and work its way down the list of potential
projects. We don’t know what the priority order would be, but the state needs to undertake this
type of assessment.

One of our fundamental concerns with the Focus on Water template is that it proposes to take
scarce financial resources and earmark them for a specific purpose when we have no idea about
the comparative value of the purpose. We don’t know if water/wastewater projects are a high,
medium, or low priority within the broader context of energy efficiency. If they turn out to be low,
why would the state earmark specific funds for that purpose, particularly if higher priority projects
are not earmarked?

There was discussion at one of the work group meetings about the fact that industrial wastewater
treatment plant operators are not taking advantage of Focus on Energy programs that could
reduce energy use at the treatment plant. We checked with some of our members and the
reason is that, within the broader context of the operation of a paper mill, wastewater treatment
plant projects never make the cut. There are other energy efficiency projects at a paper mill that
deliver more bang for the buck. This same type of analysis needs to be done on a statewide
basis. Until such an assessment is done, we believe that templates like this put the cart before
the horse.

However, since it appears that once a template is developed it lives forever, we offer the following
specific comments:

        •    As written, the template blurs the distinction between energy efficiency and water
            conservation. Energy efficiency – and its connection to potential GHG reductions –
            should be the clear focus. Water conservation, by itself, is not necessarily related to
            GHG emissions. The template should focus more clearly on energy efficiency.
        •    Go slow. Let the Focus on Energy program sort out the potential demand for
            water/wastewater energy efficiency projects. As the template says, “there has been
            little effort to evaluate the energy and greenhouse gas implications of various water
            supply and wastewater treatment options.”
        •    Forego specific funding recommendations. The broader energy efficiency template
            calls for a massive increase in funding. If water/wastewater projects turn out to be
            high priority, take the funding from this pot of money.
        •    We oppose new fees or taxes.

Edward J. Wilusz
Vice President, Government Relations
Wisconsin Paper Council