Chairman Willie L. Phillips
Commissioner Richard A. Beverly
Commissioner Greer J. Gillis
Public Service Commission of the District of Columbia
1325 G Street N.W., Suite 800
Washington, D.C. 20005
We write to urge you to hold Washington Gas (WGL) to its merger commitment (#79) to “evolve its business model to support and serve the District’s 2050 climate goals.”[i] DC’s 2050 climate goal is carbon neutrality, which will require that Washington Gas end its methane supply business over the next 30 years.
Based on WGL’s approach to other sustainability-related merger requirements and its efforts to expand methane gas infrastructure in the District, we are concerned that the company will submit an inadequate plan. If that proves to be the case, we ask you to reject WGL’s plan immediately and require the company to file a new comprehensive plan to transition away from methane gas distribution. If WGL fails to file a comprehensive plan, the PSC should assess a continuing financial penalty on the company—which would not be paid by the ratepayers—until it files a serious and realistic plan to wind down its gas business. The plan is due on January 1, 2020, but WGL has asked for an extension to March 16th.[ii]
Just looking at the past several months, the signs of accelerating climate change are all around us. July 2019 was the hottest month for the planet since modern record-keeping began.[iii] Hurricane Dorian in September exhibited the immense size, catastrophic rainfall, and stalling behavior that scientists are tracing to climate change.[iv] While climate change is a hazard to everyone in the District, our most vulnerable residents have fewer resources to respond to the hazards of climate change – including extreme heat, air pollution, and flooding – and therefore face the greatest risks.
Rising to meet the climate challenge, Mayor Bowser has committed the District to becoming climate resilient and carbon neutral by 2050; the Mayor and DC Council have pledged that the District will comply with the Paris Agreement to limit the rise in average global temperatures to no more than 2 degrees Celsius from pre-industrial levels. The Council has strengthened DC’s climate and energy policies by passing the Clean Energy DC Omnibus Act of 2018, which requires 100 percent renewable electricity by 2032. The new law also expanded the mission of the Public Service Commission, directing the Commission to uphold the preservation of environmental quality, “including effects of climate change and the District’s public climate commitments.”[v]
WGL’s business model relies primarily on the sale and distribution of methane, a powerful global warming agent. Although methane has a shorter lifespan in the atmosphere than carbon dioxide, the greenhouse gas most responsible for climate change, methane has a global warming potential that is 84 to 87 times greater than that of carbon dioxide over a 20-year period.[vi] Recent studies show that leakage of methane from pipelines and distribution systems in large cities, including DC, is much higher than has been estimated in the past.[vii] [viii] Methane that arrives at its final destination to be combusted in our homes and commercial buildings releases a significant amount of the carbon dioxide from buildings, which are the source of 75% of greenhouse gas emissions in the District.[ix] Methane must be phased out if we are to meet our climate goals.
WGL agreed to several sustainability-related terms as part of the merger agreement in 2018,[x] but the company does not appear to be taking them seriously. For example, commitment #5 requires the company to develop 10 megawatts of renewable electricity or electricity storage within five years, but the “plan” that the company filed on January 2, 2019 was grossly inadequate. It was less than half a page in length and contained no specifics, and the Commission rightly rejected it.[xi] WGL filed an updated plan in June.[xii]
This year, WGL requested an extension of the Multifamily Piping Program (MPP) to expand gas infrastructure in the District.[xiii] Prior to the merger, WGL requested and received authorization from the Commission to conduct a pilot program to subsidize new gas piping in multifamily buildings by offering financial incentives to developers and builders. The cost is added to the rate base—which means the ratepayers are underwriting the expansion of gas infrastructure—locking in higher greenhouse gas emissions for years to come. WGL sought an extension of the program, before the pilot program had even run its course. We applaud the Commission for rejecting this extension request and noting concerns that the MPP is not consistent with the CleanEnergy DC Act or with WGL’s merger commitment to develop a new business model in alignment with DC’s climate commitment of carbon neutrality by 2050.[xiv]
Rather than expanding gas infrastructure, WGL should submit a plan, as required by merger commitment #79, to ramp down its gas distribution business and pursue new business opportunities in the clean energy sector. Gas stoves cause indoor air pollution, including the release of significant quantities of nitrogen dioxide (a respiratory irritant), carbon monoxide, and dangerous ultrafine particles.[xv] Our homes and buildings should be powered by clean electricity using highly efficient heat pumps, induction stoves, and other superior clean technologies – reducing our energy bills, eliminating the dangers of gas explosions and carbon monoxide poisoning, and improving indoor air quality.
The first step: do not make the problem worse by expanding gas infrastructure. Avoiding the worst effects of the climate crisis requires that nearly all our buildings and appliances become fully electric – powered by electricity from renewable sources – over the next several decades. This transition has the added benefit of creating new jobs and careers, many of which must be performed locally.
The next step: we need a focused effort to electrify affordable housing. For new affordable housing, electrification ensures that residents receive the cost savings from highly efficient appliances and are not left paying a larger share for maintaining our region’s gas infrastructure as the number of gas customers shrinks. For much of our existing affordable housing stock, renovation is long overdue to reduce energy costs and eliminate health hazards from lead, mold, asbestos, old wiring, pests, and fumes from gas appliances.
The Public Service Commission will need to create a regulatory framework for winding down gas assets in a rapid and responsible manner and scrutinize any new gas infrastructure investments to be consistent with rapid electrification. Gas assets should be depreciated on an appropriate schedule to meet climate commitments. We have before us a challenge that is also an enormous opportunity to improve the health, safety, and financial security of Washingtonians.
We ask the Public Service Commission to require WGL to comply with its merger commitments to serve the District’s climate commitments.
Mark Rodeffer, Chair
Lara Levison, Clean Energy Committee Chair
Sierra Club DC Chapter
DC Environmental Network
Director of Faithful Advocacy
Interfaith Power & Light (DC.MD.NoVA)
Green Compass LLC
DC Conservation Advocate
Audubon Naturalist Society
Wentworth Green Strategies
Chair, Political Policy & Action Committee
DC Statehood Green Party
Chesapeake Climate Action Network
Center for Biological Diversity
Citizens’ Climate Lobby – DC Chapter
Regional Field Manager
Moms Clean Air Force, DC Chapter
Climate and Energy Program Director
Food and Water Watch
DC Consumer Utility Board
Political and Business Strategist
[i]“By January 1, 2020, AltaGas will file with the Commission a long-term business plan on how it can evolve its business model to support and serve the District's 2050 climate goals (e.g., providing innovative and new services and products instead of relying only on selling natural gas). After the business plan is filed, AltaGas will hold bi-annual public meetings to report on and discuss its progress on the business plan.” DCPSC Order No. 19396.
[ii] December 6, 2019 filing with DCPSC, Docket Number 1142 – 570, “AltaGas Ltd.'s Motion for Extension of Time to file its long-term business plan pursuant to Merger Commitment No. 79.”
[iii] National Oceanic and Atmospheric Association, “July 2019 was hottest month on record for the planet,” news release, August 15, 2019, https://www.noaa.gov/news/july-2019-was-hottest-month-on-record-for-planet.
[iv] James Bruggers, “Dorian One of Strongest, Longest-Lasting Hurricanes on Record in the Atlantic,” Inside Climate News, September 7, 2019, https://insideclimatenews.org/news/07092019/hurricane-dorian-record-climate-change-bahamas-north-carolina-gulf-stream.
[v] Code of the District of Columbia § 34–808.02. Supervision and regulation considerations. “In supervising and regulating utility or energy companies, the Commission shall consider the public safety, the economy of the District, the conservation of natural resources, and the preservation of environmental quality, including effects on global climate change and the District's public climate commitments.” https://code.dccouncil.us/dc/council/code/sections/34-808.02.html
[vi] NASA Earth Observatory, “Methane Matters: Scientists Work to Quantify the Effects of a Potent Greenhouse Gas. https://earthobservatory.nasa.gov/features/MethaneMatters.
[vii] Ramón A. Alvarez et al. “Assessment of methane emissions from the U.S. oil and gas supply chain.” Science 361, no. 6398 (July 13, 2018). https://science.sciencemag.org/content/361/6398/186
[viii] Genevieve Plant et al. “Large Fugitive Methane Emissions from Urban Centers Along the U.S. East Coast,” Geophysical Research Letters 46, no. 14 (July 28, 2019). https://agupubs.onlinelibrary.wiley.com/doi/full/10.1029/2019GL082635
[ix] “Greenhouse Gas Inventory,” Department of Energy and the Environment, DC Government, 2016 Emissions by Sector, https://doee.dc.gov/service/greenhouse-gas-inventories.
[x] Merger commitments #76 and #77 state that the company recognizes the scientific consensus that human activity is contributing to changes in the global climate,” that the company has an opportunity to be part of the solution, and the DC and federal governments retain full right to regulate greenhouse gas emissions and air quality.
[xi] January 2, 2019 filing with DCPSC, Docket Number 1142 – 470, “Re: FC 1142 - AltaGas Ltd. - Commitment No. 5 - Notice of Compliance with Filing of the Plan for the 10 MW project.” https://edocket.dcpsc.org/apis/api/filing/download?attachId=82360&guidFileName=fe985bd5-026e-4841-a32d-8da9ece07e02.PDF
[xii] June 17, 2019 filings with the DCPSC, docket number 1142 – 521, 522, 523.
[xiii] March 28, 2019 filing with DCPSC: “Re: Formal Case No. 1137 [Washington Gas’s Motion to Extend the Multi-Family Piping Program]” https://edocket.dcpsc.org/apis/api/filing/download?attachId=83888&guidFileName=1cb0abf6-6e63-4039-96fb-6098b0783b80.pdf
[xiv] Formal Case No. 1137, In the Matter of the Application of Washington Gas Light Company for Authority to Increase Rates and Charges for Gas Service, Order No. 20263, December 5, 2019. https://edocket.dcpsc.org/apis/api/filing/download?attachId=88933&guidFileName=cf7a0ebc-d182-401e-9271-810cb9c7e073.pdf
[xv] Jennifer Huber, “Use your range hood for a healthier home, advises indoor air quality researcher,” Scope, Stanford University School of Medicine blog, March 6, 2018. https://scopeblog.stanford.edu/2018/03/06/use-your-range-hood-for-a-healthier-home-advises-indoor-air-quality-researcher/