If your gas boiler goes out in Wisconsin, should the state’s energy efficiency program help cover the cost of an electric heat pump? Or only another gas boiler of higher efficiency? Should the program be seeking to reduce carbon emissions? Should it support building electrification?

These are some of the questions currently before the Wisconsin Public Service Commission (PSC), which considers changes to the statewide energy efficiency program, Focus on Energy (FOE), every four years. Decisions now will affect the 2023-2026 program cycle—a critical time to keep driving down greenhouse gas emissions from our buildings.

On March 31, the Midwest Building Decarbonization Coalition weighed in with one voice: let’s encourage decarbonization and stop protecting fossil fuel appliances from head-to-head comparisons with electricity.

“This is the key mechanism in Wisconsin for folks to make energy improvements to their homes and businesses. It’s done good work in the past but could be reconfigured to better serve the goal of decarbonization,” said Coalition Co-Director and Manager of Building Policy and Technology, Jacob Serfling. “This was a crucial phase for us to comment because of some of the big picture questions that PSC was asking about.”

FOE is also a crucial program to weigh in on because of its large footprint. All eight states in our region require electric and gas utilities to invest in energy efficiency programs. In some states, like Minnesota and Iowa, the utilities run these themselves. In Wisconsin, FOE is the unified statewide program that all the utilities in the state pay into. So, improvements to the program will impact the entire state.

Here are some highlights from our comments:

Focus on Energy should align with the state’s decarbonization goals.

The IPCC’s reports make clear that we must hit net-zero carbon emissions by 2050. As a state, Wisconsin recognizes this necessity. The Governor has a goal of 100% carbon-free electricity by 2050. We encouraged FOE to align with state-wide carbon reduction goals.

“Given that the median life for most natural gas heating equipment is 15-20 years, it is entirely possible that fossil fuel appliances incentivized by FOE and installed during Quad IV (2023-2026) would still be in operation by 2050.”

“It is critical that FOE not create a situation where it is incentivizing installations that will actually end up working against the state’s future decarbonization targets.”

Focus on Energy should support switching from fossil fuels to electricity.

Like many energy efficiency programs, FOE treats fossil fuel and electricity as apples and oranges: inefficient gas furnaces get upgraded to efficient gas furnaces, but they aren’t compared to electric heat pumps, even if the heat pump would triple the home’s energy efficiency. Keeping fuels in a silo means customers don’t see the benefits of electrification, and our communities miss out on the benefits of reduced fossil fuel use.

The reality is that fuel and electric are easily comparable as apples to apples, and the benefits of switching to electric are many.

“Goals for the program include higher energy efficiency, environmentally sound energy at reasonable cost, and promoting rural development. Supporting fuel-switching programs, especially ones aimed at electrifying homes reliant on propane or other unregulated fuels for heating and cooking, would strongly support all those goals. The higher efficiency of an air-source heat pump and relative costs of electricity compared to propane will typically result in lower utility bills and energy burden for households currently reliant on propane. This statistic may be helpful here: Customers who switch from delivered fuels to electric heat pumps can save about $447 annually on their utility bills (https://www.rewiringamerica.org/policy/bringing-infrastructure-home-report).”


The next phase of FOE quadrennial planning focuses on narrower implementation decisions, and is scheduled to take place between April and June, 2022. Along with our Coalition comments, a number of our members and partners submitted comments.

Read our full comments here. You can also learn more about FOE on their website, or read the Quadrennial planning process memo from the PSC here.


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