August 16, 2023
Council of the District of Columbia
1350 Pennsylvania Avenue, NW
Washington, D.C. 20004
Re: Concerns over Project Pipes’ Climate Impacts, Ratepayer Burdens, and Poor Performance
To Councilmember Charles Allen:
In an unprecedented wave of civic engagement, hundreds of D.C. residents recently submitted comments protesting Washington Gas’s request to the D.C. Public Service Commission to spend $671.8 million of D.C. residents’ money undercutting District climate law for the third installment of Washington Gas’s “Project Pipes” proposal—which is a bid to spend at least four decades replacing miles of gas pipes in the District at an estimated cost of $4.5 billion. We urge the D.C. Council, and the Committee on Transportation and the Environment in particular, to examine the Project Pipes program’s multiple failings, including its irreconcilable inconsistency with D.C.’s statutory requirements to reduce greenhouse gas emissions, and the very real economic duress that the proposal will impose on D.C.’s low and moderate income households. Washington Gas’s $671.8 million request is particularly alarming as it is just one more incremental step in Washington Gas’s multi-decadal, multi-billion-dollar plan to siphon ratepayer dollars from its captive D.C. customers to its parent company’s shareholders and is in direct conflict with D.C.’s climate laws.
Without engaged scrutiny by the Committee on Transportation and the Environment, and the full D.C. Council, there is little likelihood that the pleas of hundreds of D.C.’s residents—which were filed in the Commission’s docket on Project Pipes—will be heard. Sierra Club, the D.C. Attorney General’s Office, the Office of People’s Counsel, and other environmental intervenors have been struggling to convince the Commission to rethink its inert approach to Project Pipes, yet WGL’s plans continue to be rubber-stamped. Accordingly, we ask that the Committee on Transportation and the Environment hold a hearing at which the Commission testifies about Project Pipes and its climate implications; attend an in-person meeting with the undersigned organizations to discuss our concerns with Project Pipes in greater detail; and compare any marginal greenhouse gas emission reductions resulting from pipeline replacements with the more direct, larger-magnitude emission reductions from electrification measures such as the Healthy Homes and Residential Electrification Act of 2023.
Although Commission dockets rarely attract filings from many utility customers, over 370 individual D.C. residents filed letters in the Project Pipes docket, expressing an outpouring of concern over the massive costs of new gas infrastructure, the inconsistency with District climate law, and the absence of any opportunity for a public hearing in the Commission’s procedural schedule. These comments include:
- “It is senseless to bill each gas customer thousands of dollars to support a system that not only must be abandoned soon, but is destroying the climate, damaging public health, and making inequality in the District worse.”
- “The District should not be spending billions of dollars to keep us locked into using dirty fossil fuels for decades past our net-zero target date of 2045.”
- “Please do not allow PROJECTpipes to continue. Our community’s environment is too important!”
- “Please direct PSC to take leadership in the process of phasing out combustion energy for heating and cooking in DC. This is critical if the District is to attain our climate goals. It is also a much better direction for the health and public safety of our residents.”
Clearly, Washington Gas customers across the District are deeply frustrated with the Commission’s repeated rubber-stamping of the costly and inefficient Project Pipes program, which is completely inconsistent with the electrified future for D.C.’s building stock that the D.C. Council has envisioned and has mandated by law.
D.C. climate laws call for phasing out gas in the District’s buildings. The District’s Climate Commitment Act of 2022 calls for a 45% reduction in the District’s greenhouse gas emissions by 2025, a 60% reduction by 2030, and carbon-neutrality by 2045. This requires electrification of D.C.’s existing buildings because 72% of D.C.’s greenhouse gas emissions are from D.C.’s buildings. Meanwhile, the Clean Energy D.C. Building Code Act of 2022 more specifically outlines D.C.’s statutory objective of building electrification by requiring that “all new construction or substantial improvements of covered buildings [ ] be constructed to a net-zero-energy standard” by 2026. The law explicitly defines net-zero as precluding fossil fuel combustion in buildings. Moreover, the D.C. government has committed to phasing gas out of its buildings—the Climate Commitment Act prevents D.C. from installing gas-powered appliances in District-owned buildings beginning on January 1, 2025 and the Greener Government Buildings Act requires new and substantially renovated D.C. government buildings to be net zero starting now.
Washington Gas’s request before the Commission for $671.8 million will lead to an estimated $4,072 increase in customers’ bills over the next five years. The $4.5 billion estimated total cost of Project Pipes translates into a roughly $27,270 bill increase for the average Washington Gas customer. New and substantially improved buildings covered by the 2022 Building Code Act—as well as all buildings that meet their energy needs through electricity rather than gas combustion—will not need any gas distribution pipes, as they will not contain furnaces, water heaters, stoves, or any other appliances that combust gas. As the District electrifies its building sector over the coming years in compliance with D.C. law, the costs of Washington Gas’s multi-billion-dollar, multi-decadal replacement of its pipelines will be spread out over fewer customers.
As D.C. residents with financial means increasingly transition off gas to flee the exponentially more expensive gas system, remaining Washington Gas customers are likely to be lower-income D.C. residents who cannot afford the up-front costs of electrifying their homes. These residents will be stuck paying ever-higher gas bills to prop up Washington Gas as its customer base continues to decline. Expanding investment in Washington Gas’s fossil fuel infrastructure is unfair because it imposes ever-greater energy burdens on those who can least afford it.
Attempts by Washington Gas to frame Project Pipes as a greenhouse gas reduction initiative are absurd. Even if this false claim was not facially inconsistent with D.C. law mandating a transition away from methane gas emissions, Project Pipes has been so poorly administered that it is a terrible means to achieve D.C.’s climate mandates. This is especially true when other, far less costly measures can be used to reduce greenhouse gas emissions and protect D.C. residents with low and moderate incomes, such as investing in the electrification of their homes.
Looking at Project Pipes’ performance metrics, spending estimates have ballooned from an estimated $1 billion at its inception in 2014 to a current estimate of $4.5 billion in total costs. Project Pipes is also massively behind schedule, moving at an average pace of 3.45 miles of pipe replacements per year, which, if sustained, would result in a 2107 completion year—almost one hundred years after the spending program began, 53 years past Washington Gas’s expected completion date of 2054, and 63 years after D.C. is required to reach carbon neutrality. When Washington Gas chooses which specific pipes to replace, it proposes to let many of its pipeline replacements jump ahead of normal risk assessment procedures and be dictated by the D.C. Power Line Undergrounding plan, or “DC PLUG” project, an unrelated construction project that has no apparent correlation with leakage risks of gas pipes, as well as amorphous “work compelled by others.” This calls into question the credibility of Washington Gas’s claims that it is replacing gas pipes to avoid safety concerns posed by methane leaks, a claim that lacks clear supportive documentation.
We request that the Committee on Transportation and the Environment hold a hearing at which the Commission should also testify on its plans to ensure that Washington Gas complies with D.C.’s climate commitments by transitioning from fossil fuel distribution to providing heat from efficient electric systems. The Commission should also be asked for documentation showing what fraction of WGL’s pipes have been replaced due to documented methane leaks posing safety risks. The D.C. Council should compare the outsized costs of Project Pipes with the costs of building electrification measures, such as the Healthy Homes and Residential Electrification Act of 2023, which would result in greater, more direct, and longer-lasting greenhouse gas emission reductions. Finally, we would greatly appreciate having an in-person meeting with the Committee on Transportation and the Environment to discuss our concerns with Project Pipes in greater detail.
Mark Rodeffer, Sierra Club DC Chapter
Joelle Novey, Interfaith Power & Light (DC.MD.NoVA)
Washington Interfaith Network
 Formal Case No. 1175, Matthew Erickson’s Comments on WGL’s PROJECTpipes 3 Application, filed June 13, 2023.
 Formal Case No. 1175, Ingrid Eck’s Comments on WGL’s PROJECTpipes 3 Application, filed May 2, 2023.
 Formal Case No. 1175, Steven Romero’s Comments on WGL’s PROJECTpipes 3 Application, filed April 26, 2023.
 Formal Case No. 1175, Barbara Briggs’ Comments on WGL’s PROJECTpipes 3 Application, filed April 26, 2023.
 D.C. Department of Energy & Environment, Greenhouse Gas Inventories: 2020 Emissions by Sector, https://doee.dc.gov/service/greenhouse-gas-inventories#:~:text=Emissions%20Sources%20in%20the%20District&text=In%202020%2C%20buildings%20continued%20to,%2C%20and%20gasoline%20(17%25)
 D.C. Law 24-177(b)(1) (2022) (emphasis added).
 D.C. Law 24-176 § 109e(a).
 D.C. Law 24-306 (2022).
 These calculations are average costs based on the Commission’s statement that Project Pipes applies to “nearly 165,000 gas customers” across the District. See D.C. Public Service Commission, Infrastructure Enhancements, https://dcpsc.org/Newsroom/HotTopics/Infrastructure-Enhancements.aspx.
 Formal Case No. 1175, Sierra Club Initial Comments at 15.
 WGL claims that replacing its existing gas pipes with brand-new gas pipes helps combat climate change, but its actions in implementing Project Pipes belie its contention. Again, WGL is not prioritizing pipe replacements that maximize emission reductions; it is simply replacing pipes according to chance as construction in the District unfolds. Moreover, WGL does not even have a mechanism to accurately track its supposed emissions reductions, which have a history of being over-inflated and later being revised lower and lower. In December 2021, WGL claimed that Project Pipes had reduced greenhouse gas emissions by 22,000 metric tons, but over the next year, WGL twice adjusted this estimate downward: first to 18,000 metric tons in March 2022, and then to only 12,000 metric tons in October 2022. Indeed, WGL has still failed to complete an audit of the second installment of Project Pipes. This was intended to inform the Commission’s decision whether to approve the program’s third installment, which is currently under PSC consideration. See id. at 18–19.
 Under the Clean Energy D.C. Act of 2018 and other governing legislation, the Commission is required to consider climate change in its decision-making. See D.C. Law 22-257.