350 DC • Audubon Naturalist Society • Catholic University Environmental Club • Center for Biological Diversity • Chesapeake Climate Action Network • Citizens’ Climate Lobby - DC Chapter • CleanChoice Energy • DC Consumer Utility Board • DC Environmental Network • DC Solar • DC Statehood Green Party • DC Voters for Animals • Earthjustice • Food & Water Watch • Fossil Free American University • Friends Meeting of Washington • Green America • Green Compass • Greenpeace USA • GRID2.0 • Georgetown University Fossil Free • Honeydew Energy Advisors • Interfaith Power & Light (DC.MD.NoVA) • Ipsun Solar • League of Women Voters of DC • Moms Clean Air Force DC Chapter • SEIU 32BJ • Sierra Club DC Chapter • Solar United Neighbors • Sunrise GW
April 22, 2020
Dear Councilmember McDuffie,
Thank you for your leadership on climate change, specifically shepherding the Clean Energy DC Omnibus Act through the DC Council Committee on Business and Economic Development. That legislation put DC on a path toward electricity from 100 percent renewable sources by 2032, the strongest clean electricity standard in the nation.
With DC’s electricity utility headed toward zero carbon emissions, DC must now turn its attention to our gas utility, Washington Gas. Greenhouse gas emissions from Washington Gas pose a serious threat to the climate. Other toxins from gas combustion cause indoor air pollution that is a threat to the health of families in DC. Washington Gas says it will deal with these problems by mixing gas from animal manure with fracked gas. Manure gas has the same emissions as fracked gas, and manure gas costs more than many DC families can afford. Electric alternatives to gas-fired systems will create healthier homes and help DC lead the fight against climate disruption.
We ask that your committee hold a hearing to examine the climate and health threat posed by emissions from the gas utility.
The climate threat from gas
Official estimates show methane gas from the utility is responsible for about a fifth of DC’s greenhouse gas emissions. Research suggests emissions from the gas sector are much higher. A study that examined gas leaks in several East Coast cities, including DC, found leaks of methane from gas distribution pipes are double official estimates. Worse still, there is serious methane leakage before the gas even gets to utilities. Those emissions – from fracking, transmission, storage, and processing – are projected to be 60 percent higher than official EPA estimates. These methane leaks are particularly concerning, because methane has a climate impact 84 to 87 times greater than carbon dioxide.
The health threat from gas
Like any fossil fuel, methane gas emits noxious fumes when burned. The resulting mix of nitrogen dioxide (NO₂) and other pollutants can have serious health ramifications. Nitrogen dioxide exposure results in increased respiratory symptoms, asthma attacks and hospital admissions. Long-term NO₂ exposure is likely to cause asthma, especially in children, and can increase the risk of diabetes, cancer, and premature death. Children living in homes with a gas stove have a 42 percent increased risk of asthma. Many homes with gas-burning appliances frequently exceed EPA outdoor air quality standards, but because indoor air is unregulated by the EPA, the toxic fumes are legal. The New England Journal of Medicine concluded “gas is associated with health and environmental hazards and reduced social welfare at every stage of its life cycle.”
Washington Gas climate commitment
When the Canadian fracked gas supplier AltaGas purchased Washington Gas in 2018, the settlement agreement approved by the DC Public Service Commission stated that the combined company would “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).” DC’s climate commitments, which the gas utility is now obligated to uphold, include a 50 percent reduction of greenhouse emissions by 2032 and carbon neutrality by 2050, as well as ensuring that new buildings operate at net zero carbon by 2030 and all buildings are net zero carbon by 2050. It is impossible to meet these climate commitments as long as Washington Gas relies on a gas combustion business model.
The Clean Energy DC Omnibus Act requires the Public Service Commission to uphold “the preservation of environmental quality, including effects on global climate change and the District’s public climate commitments.” It is the responsibility of the Committee on Business and Economic Development to provide appropriate oversight to ensure that the Commission abides by the law.
On March 16, Washington Gas submitted its climate business plan to the Commission. The plan calls for using what the utility calls “renewable gas,” also called “biomethane,” from sources like cow manure and rotting material in landfills. Biomethane releases greenhouse gases and other pollutants, including smog-forming nitrogen oxides, ammonia and hydrogen sulfide. Switching from fracked methane to manure methane does nothing to address the substantial harm to the climate from methane leaks, because both gases are methane.
Manure gas supply is insufficient to meet demand
Vastly insufficient quantities of manure gas exist to replace current consumption of fracked gas. The American Gas Foundation found that even if 100 percent of all the country’s biomethane feedstocks – animal manure, sludge from wastewater treatment plants, decomposition gas from landfills, crops grown for the purpose decomposing into gas, and decomposing wood – were processed into gas, it would offset only 10 percent of current gas consumption. Because of this, the business plan states that Washington Gas will source its manure gas from areas far beyond the District’s boundaries, thereby depleting the volume of manure gas available for other jurisdictions. Despite such exhaustive sourcing, the company projects that only 58 percent of its gas will come from biomethane by 2050, a clear failure to achieve zero carbon emissions.
Manure gas is expensive
Manure gas is exorbitantly expensive. Last year, CenterPoint Energy Minnesota Gas sought approval from the Minnesota Public Utilities Commission for a manure gas pilot program. Minnesota's attorney general found that even with the “overly optimistic” assumptions made by the gas utility, the cost of such gas is "unreasonably high," with traditional gas costing $0.40 per therm and manure gas costing $3.89 per therm – 10 times higher. Minnesota’s attorney general included in his filing the chart below to demonstrate the extreme cost of what Minnesota’s gas utility called “renewable natural gas” or “(RNG).”
The Minnesota Public Utilities Commission rejected the gas utility’s manure gas pilot in a 5-0 vote.
Among the reasons for the high cost of manure gas and the need for massive manure subsidies is that the gas emitted by animal manure, human waste, and landfills must be processed and upgraded to remove impurities before it can be sent into gas pipelines. Upgrading raw manure gas into pipeline-grade gas is capital intensive, requiring long-term project financing. Even after the manure gas is processed into pipeline-grade gas, it must be transported to the existing gas network, requiring millions of dollars in spending on new pipelines. Building pipelines to large feedlot operations – which are typically located far from gas mains – is estimated to cost between $1.2 million and $3 million per site, and building pipelines to a landfill costs between $1.5 million and $3 million.
Because of the lack of sufficient manure supply, the exorbitant cost of manure gas, and the continued methane emissions associated with any type of gas fuel, the Washington Gas manure plan will not meet DC’s climate commitments nor the commitment Washington Gas made in its 2018 merger agreement.
A real zero-emissions business model for the gas utility
Washington Gas Light Company was founded in 1848 to provide gas lighting in DC. Its business model has evolved substantially since then and lighting is no longer a major part of the company’s business. In 2013, Washington Gas rebranded itself WGL, with a goal of “transforming our company” through solar and distributed energy. Today, WGL is fundamentally a company that enables households to heat their homes and heat their water. The company can continue to serve this fundamental purpose without selling gas and contributing to the climate crisis. To achieve this goal, WGL would own and service two proven zero-carbon technologies for heating services:
- Clean energy micro-district heating systems that require a network of pipes in the ground that carry hot water in the winter and cold water in the summer from central units which generate the hot or cold water through geothermal energy, industrial-scale heat pumps, and sewage waste heat extraction.
- Air- or ground-source heat pumps that heat and cool homes, offices and other buildings in areas that are not well suited for renewable energy district heating.
Continuing its fundamental mission of providing heat through clean energy would allow WGL to grow a customer base in a way consistent with the District's and WGL’s climate commitments. Such a business model allows WGL to transition out of the gas and climate disruption business and into the business of providing heat without greenhouse gas emissions.
DC is a low-lying city, with some neighborhoods mere feet above sea level, and DC sits along two tidal rivers, making us particularly vulnerable to sea level rise from climate change. To safeguard the future of DC and the planet, we must end combustion-based energy.
The undersigned organizations request that the DC Council Committee on Business and Economic Development hold a public hearing with Washington Gas, the Public Service Commission, and community stakeholders to discuss pathways for DC’s gas utility to reduce its greenhouse gas emissions 50 percent by 2032 and to end all greenhouse gas emissions by 2050.
We appreciate your past efforts to reduce DC’s greenhouse gas emissions and safeguard our most vulnerable residents. We look forward to continuing our partnership to ensure Washington Gas is on a credible path to zeroing out all greenhouse gas emissions by 2050.
Mark Rodeffer and Matthias Paustian
Sierra Club DC Chapter Beyond Gas Subcommittee
Energy Justice Legal Director
Center for Biological Diversity
Citizens’ Climate Lobby - DC Chapter
DC Environmental Network
Interfaith Power & Light (DC.MD.NoVA)
DC Conservation Advocate
Audubon Naturalist Society
CEO & Founder
Alexis Lopez Paleo
Senior Policy Advisor & Strategist
DC Voters for Animals
Chesapeake Climate Action Network
Chair, Political Policy & Action Committee
DC Statehood Green Party
CFO & Vice President for Sales
Co-Founder & CEO
Honeydew Energy Advisors
Legislative Director, Climate & Energy
DC Consumer Utility Board
Southern Region Director
Food & Water Action and Food & Water Watch
Larry Martin, PhD
Kathy P. Chiron
League of Women Voters of DC
Political and Business Strategist
Solar United Neighbors
Washington, DC Field Organizer
Moms Clean Air Force
Catholic University Environmental Club
Fossil Free American University
GU Fossil Free
Co-clerk, Peace & Social Concerns
Friends Meeting of Washington
DC Council Chairman Phil Mendelson
DC Councilmember Brianne Nadeau, Ward 1
DC Councilmember Mary Cheh, Ward 3
DC Councilmember Brandon Todd, Ward 4
DC Councilmember Charles Allen, Ward 6
DC Councilmember Vince Gray, Ward 7
DC Councilmember Trayon White, Ward 8
DC Councilmember David Grosso, At-Large
DC Councilmember Anita Bonds, At-Large
DC Councilmember Elissa Silverman, At-Large
DC Councilmember Robert White, At-Large
DC Public Service Commission Chairman Willie Phillips
DC Public Service Commissioner Richard Beverly
DC People's Counsel Sandra Mattavous-Frye
DC Department of Energy and Environment Director Tommy Wells
 Large Fugitive Methane Emissions From Urban Centers Along the U.S. East Coast, Geophysical Research Letters, July 28, 2019
 Assessment of methane emissions from the U.S. oil and gas supply chain, Science, July 13, 2018
 Methane Matters: Scientists Work to Quantify the Effects of a Potent Greenhouse Gas, NASA Earth Observatory, March 8, 2016
 Human Health Risk Assessment For Ambient Nitrogen Dioxide, Health Canada, May 13, 2016
 Human Health Risk Assessment For Ambient Nitrogen Dioxide, Health Canada, May 13, 2016
 Meta-analysis of the effects of indoor nitrogen dioxide and gas cooking on asthma and wheeze in children, International Journal of Epidemiology, December 2013
 Pollution in the Home: Kitchens Can Produce Hazardous Levels of Indoor Pollutants, Lawrence Berkeley National Laboratory, July 23, 2013
 Air Quality Issues Related to Using Biogas from Anaerobic Digestion of Food Waste, California Energy Commission, March 2016
 The Potential for Renewable Gas: Biogas Derived from Biomass Feedstocks and Upgraded to Pipeline Quality, pages 3-4, American Gas Foundation
 Natural Gas and its Contribution to a Low Carbon Future: Climate Business Plan for Washington, DC, page 4, Washington Gas, March 16, 2020
 Comments of the Office of the Attorney General, In the Matter of a Petition by CenterPoint Energy to Introduce a Renewable Natural Gas Pilot Program before the Minnesota Public Utilities Commission, page 6-7, January 8, 2019
 Renewable Natural Gas: The RNG Opportunity for Natural Gas Utilities, page 7, M.J. Bradley & Associates, 2017
 Order Instituting Rulemaking to Adopt Biomethane Standards and Requirements, Pipeline Open Access Rules, and Related Enforcement Provisions, pages 8, 30, Public Utilities Commission of the State of California, June 16, 2015
 DC Is Vulnerable To Three Types Of Flooding. Climate Change Is Making Them All Worse, WAMU, July 19, 2019