Sierra Club Comments on WMATA Strategic Transformation Plan
The Sierra Club appreciates that WMATA includes sustainability as a core goal of its five-year Strategic Transformation Plan (“the Plan”). Given that WMATA operates the sixth-largest transit bus fleet in the nation, a top priority for the Sierra Club is for WMATA to transition its Metrobus fleet to zero-emission buses, which will be the focus of these comments.
When measured against the District’s greenhouse gas emission reduction requirements, WMATA’s efforts in transitioning the Metrobus fleet fall short. The Clean Energy DC Omnibus Act requires “all public buses'' and “privately-owned fleets with a capacity of 50 or more passengers” to be “only zero-emission vehicles in the District by year 2045.” The law also establishes important interim targets, requiring 50% of public buses to be low or zero-emission vehicles by 2030, 75% by 2035, and 90% by 2040.
The Strategic Transformation Plan makes no mention of these zero-emission targets or of WMATA’s own zero-emission target of 2045 included in the Metrobus Fleet Management Plan that was approved by the WMATA Board of Directors in 2021. It is imperative that WMATA abide by the interim targets in the Clean Energy DC Omnibus Act or establish its own targets, beginning immediately with a five-year target, and incorporate these zero-emission targets into the Strategic Transformation Plan.
Consider, as a point of comparison, the District’s own transit bus fleet (Circulator) operated by the District Department of Transportation (DDOT). DDOT has already completed its pilot study and is now procuring only electric buses, which puts the Circulator on a path to being all-electric by 2029. Furthermore, the Department of Energy and Environment (DOEE) recently released its Transportation Electrification Roadmap, a section of which focuses on bus fleet transition, which WMATA should review, especially since it includes the assurance that “DOEE and DDOT will collaborate with the Washington Metropolitan Area Transit Authority (WMATA) to identify opportunities to share infrastructure and optimize the complete transition to, and operation of, electric transit buses.”
While goals like “decarbonize Metro,” “modernize design, construction, and operations to meet sustainability and resiliency challenges” are not objectionable, they are not specific enough to provide clear metrics for WMATA to measure its progress toward reaching its 2045 zero-emission goal. This is especially problematic because WMATA is currently taking steps that are inconsistent with its 2045 goal. For example, constructing a new compressed natural gas (“CNG”) fueling facility at the Bladensburg Bus Garage, a project that is set to be completed in Spring 2027, is putting in place costly new infrastructure that will force Metrobuses to continue burning methane, a greenhouse gas more potent than the carbon dioxide emitted by petroleum-fueled buses. WMATA’s statement that “[t]he expansion of CNG capacity at the Bladensburg Bus Garage allows more alternative fueled buses, effectively reducing carbon emissions and improving air quality” is inconsistent with its plan to transition toward a zero-emission fleet and with its alleged goals of decarbonizing its fleet and meeting sustainability challenges.
The Plan says WMATA’s values are “innovative, safe, ethical, customer centered, [and] equity focused.” If the Plan is to be transformative and if WMATA wants to live up to its values, then the Plan should do more to accelerate the adoption of zero-emission buses. This necessitates innovation, improvements to safety, and advances in equity in relation to the pollution from burning fossil fuels (including CNG), the health consequences of which fall hardest on already overburdened communities. A rapid transition to zero-emission buses will help mitigate climate change—an obvious ethical consideration—while responding to customer demands.
The Sierra Club strongly supports the inclusion of metrics to track WMATA’s progress in meeting emission-reduction goals, as proposed in the Plan, and the development of public-facing dashboards to display this data. To date, WMATA has not been transparent when it comes to its zero-emission plans. For example, there is no updated information on the status of the electric bus pilot that is already long-delayed—it is unclear whether electric buses have been procured and are in operation. There is also no information on whether WMATA has applied for or received federal funding to support bus electrification. There are no budget line items to gauge whether WMATA has made any investments in zero-emission buses.
The Strategic Transformation Plan proposes four sustainability metrics that we agree would be valuable metrics, with a fifth still under consideration.
- Greenhouse gas (GHG) emissions per vehicle mile
- Water use per vehicle mile
- % renewable energy procured
- % bus fleet that is zero-emission
- [facilities TBD]
It is critical, however, that there be transparency and adequate documentation on how these metrics are calculated in order to ensure public confidence, particularly in relation to the metric on GHG emissions. For calculating GHG emissions, we recommend that WMATA use Argonne National Laboratory's Alternative Fuel Life-Cycle Environmental and Economic Transportation (AFLEET) tool. Note that according to the Washington Post, data collected by the Argonne National Laboratory shows that buses fueled with CNG have nearly the same level of greenhouse gas emissions as diesel buses in many circumstances. It is also important that the data be refreshed on a periodic basis and the last refresh date be displayed. WMATA may want to look into using a data visualization software like Qlik Sense or Tableau which can be set to automatically refresh and embedded in a web page. Lastly, there should be a way for WMATA’s customers to communicate with those that are responsible for managing the data, ideally a specific point of contact, in case there are issues or questions.
The Sierra Club wants to champion and support WMATA’s sustainability goals, particularly with respect to zero-emission buses. In order to do so, we ask that WMATA fully incorporate its zero-emission goal, interim targets, and the actions it will take in the next five years into the Strategic Transformation Plan.