Harry Lanphear
Administrative Director
Maine Public Utilities Commission 26 Katherine Drive
Hallowell, ME 04347
RE: Sierra Club Comments on Amendments to Portfolio Requirement Rule (Chapter 311), Docket No. 2020-00212
To Whom It May Concern:
The Sierra Club respectfully submits the following comments in response to the Public Utilities Commission request for public comment on amendments to the Portfolio Requirement Rule (Chapter 311) in Docket No. 2020-00212. Founded in 1892, the Sierra Club is the nation’s oldest grassroots environmental organization with approximately 800,000 members in all 50 states, including nearly 6,000 members in Maine. The Sierra Club’s mission involves advocating for ambitious and just climate solutions, including reductions in greenhouse gas (GHG) emissions across all sectors, a transition to 100 percent clean energy, and an increase in energy efficiency.
A reduction in building sector emissions will be critical to meeting Maine’s ambitious GHG emissions reduction target of 45% below 1990 emissions levels by 2030 and 80% below 1990 emissions levels by 2050.1 At present, the building sector (residential and commercial) accounts for 30% of the state’s CO2 emissions from fossil fuel combustion; the sector relies overwhelmingly on fossil fuels and other carbon-emitting combustible energy sources for space and water heating.2 Beneficial electrification is the only realistic way to reduce emissions from the building sector, and will be increasingly successful as Maine’s updated renewable portfolio standard (RPS) policy transitions the state’s electricity grid from 40% to 80% renewable energy by 2030.
Any thermal RPS designed to reduce GHG emissions should primarily incentivize adoption of electric heat pumps, as heat pumps represent the most promising way to reduce fossil fuel end-use consumption in Maine’s homes and businesses. Electric heat pumps reduce carbon emissions compared to fossil fuel appliances even with today’s electric grid,3 and are cost effective to purchase and operate. 4 The legislature recognized the importance of heat pump adoption with the passage of the Efficiency Maine Trust Act, aiming to install 100,000 new heat pumps by fiscal year 2024-25.5 Including heat pumps in the thermal RPS would help the state reach this target—the thermal RPS should be expanded to include heat pumps outright. Based on the current statutory text, when paired with solar panels heat pumps can and should be included as a facility that produces thermal energy using sunlight, as that is the clear function of the combined technology. To exclude heat pumps from the thermal RPS would be a missed opportunity for the state to incentivize heat pump adoption to meet its statutory target and to reduce GHG emissions.
Combustible thermal fuels such as biomass, biogas, and biofuel will not help Maine reach its climate commitments and will only prolong reliance on fossil fuel and carbon-emitting infrastructure. While incentivizing heat pump adoption will set the state on a path to meet its climate change commitments, encouraging reliance on combustible GHG-emitting fuels is counterproductive to achieving those goals. Biomass is not carbon neutral on any relevant time scale and has very high combustion emissions of carbon dioxide.6 Further, biomass combustion in wood boilers and furnaces is responsible for emissions of particulate matter and other harmful pollutants, contributing to a wide range of acute and chronic health problems.7 Biodiesel similarly cannot provide significant GHG emissions reductions over gas or conventional heating oil—depending on the production process, the feedstock, and the timeframe of the analysis, biodiesel may be responsible for even more GHGs than fossil fuels on an energy-equivalent basis.8 Current heating infrastructure is also unlikely to readily accommodate biodiesel blends
above 20 percent, further reducing the potential for biofuel to deliver substantial emissions reduction.9 Likewise, biogas is not a viable solution to reduce emissions; switching from burning one hydrocarbon to burning another is not a long-term solution to the climate problem. Moreover, other states that have explored biogas as a possible solution, such as California, have concluded that there is insufficient affordable biogas available to serve as a substitute to meet energy demand.10 The draft California Energy Commission report found that even in a scenario incorporating optimistic biogas cost assumptions, reliance on biogas to decarbonize gas supply would impose steep costs on all sectors of the economy that use gas.11
Finally, Maine’s thermal RPS should not offset electricity providers’ responsibility to achieve 100% renewable electricity. The state’s existing RPS obligations on electric providers are an effective driver of renewable energy development and are essential to ensuring GHG reductions in the electric sector. The efficacy of any additional thermal RPS depends on the existing obligations to ensure that the electricity used to heat buildings is generated from non- GHG emitting sources. Responsibility for meeting a thermal RPS would more appropriately fall on heating fuel providers than electricity providers. Cross-subsidization of non-electric technologies, particularly carbon-emitting technologies, by electric ratepayers is inappropriate— electric ratepayers should not bear the cost of incentivizing transition to non-electric heating fuels. An increase in costs for electric ratepayers would perversely make cleaner electricity less cost-competitive with dirtier non-electric alternatives and would be counterproductive to achieving Maine’s GHG emissions reduction goals.
Respectfully submitted,
Sarah Krame
Associate Attorney
Sierra Club Environmental Law Program