Utility Regulators Must Uphold DC's Climate Commitments

Written Testimony
Sierra Club DC Chapter
PR24-0288, Public Service Commission Richard Beverly
Confirmation Resolution of 2021
Committee on Business and Economic Development
Monday, November 8, 2021

Thank you for the opportunity for the Sierra Club DC Chapter to submit written testimony on the nomination of Richard Beverly for a second term on the DC Public Service Commission (PSC).

The Climate Crisis Requires Urgent Action Now

As the agency that oversees the services provided and rates charged by the regulated electricity and gas utilities in the District, the PSC has an essential role in reducing the climate crisis and guiding our community  through decarbonization of all sectors of the economy, including the electricity supply, heating and cooling of buildings, and transportation, in a just and equitable manner.

The science is completely clear now: the climate crisis is here. As predicted, climate change is hurting the most vulnerable people first and worst, namely low-income and black and brown communities. The rainfall from Hurricane Ida was so intense that people drowned in their own basement apartments, including in Rockville, Maryland.

The flooding is dramatic, but the worst hazard to human life is not fully recognized, and that is extreme heat, which literally kills people, especially those who can’t afford to cool their homes. Almost two hundred people died in the heat wave earlier this year in the Pacific Northwest. To protect human life and earth’s ecosystems, the climate crisis requires urgent action now.

Commissioner Beverly and Grid Modernization

The climate crisis requires transformation of the electricity grid to support decarbonization through a massive increase in clean, renewable energy generation and energy efficiency, while maintaining and improving affordability. The modern grid must support ever-increasing levels of distributed energy resources, including renewables, efficiency, and electricity storage--as opposed to the traditional approach of moving electricity from centralized generating stations to the consumer.

The PSC’s progress on grid modernization to support clean energy and greenhouse gas emission reduction has been slow, proceeding largely through Formal Case 1130 workgroups. Grid modernization is among the most difficult challenges before the Commission because it entails both technological and economic transformation of the District’s energy management system. Commissioner Beverly championed stakeholder involvement in the process and has demonstrated informed insights and made recommendations for steps to advance grid modernization, as evidenced by statements he attached to Commission orders (e.g. FC1130 Order#20286, 1/24/2020). Commissioner Beverly’s leadership and vision in this area is recognized, appreciated and needed.

Interconnection of Solar Facilities to the Grid

The Sierra Club is concerned by persistent reports of delays on the part of Pepco in connecting solar facilities to the electricity grid. The Chesapeake Solar and Storage Association recently filed a report with the PSC (Formal Case 1050) documenting this pattern of delays and proposing solutions. The Sierra Club urges the PSC to take expeditious action on these concerns. The District has set aggressive requirements for solar energy development, and interconnection delays are dragging down the ability to meet these requirements.

Support for Qualifications for Commissioners

While Commissioner Beverly has extensive expertise in the issues before the PSC, this has not been the case for several recent nominees.

This is not a time for PSC commissioners to learn on the job. We need commissioners who have the knowledge and vision to steer the District through the transformation that is already well underway in the energy sector, while ensuring that energy remains affordable and reliable.

Many boards and agencies in the District can be led effectively by individuals with good management skills, who learn the subject matter on the job. While good management is always valuable, the responsibilities of a PSC Commissioner require extensive knowledge of energy policy, climate solutions, and utility regulation, and the vision to press forward with all possible speed to reduce our greenhouse gas emissions. We are fortunate that many individuals with deep experience in energy and climate policy reside in the District.

That’s why the Sierra Club strongly supports the emergency legislation passed by the DC Council requiring that the next two nominees (after this current nomination process) have these qualifications: “one member shall have experience in electric grid modernization and renewable energy integration or technology and, where possible, issues impacting the environment, and one member shall have experience in consumer protection.”[1]

The Commission Must Provide Leadership to Move “Beyond Gas”

As clearly stated in DC’s climate plan, to meet this District's climate commitments, we must stop burning fossil fuels in our buildings for space heating and water heating. The PSC must take leadership, in coordination with other DC government agencies and the DC Council, to facilitate this transition so that it is expeditious, just, and positive for the District’s business community, residents and especially low and moderate income families.

Methane is exceptionally hazardous to the Earth’s climate, and recent studies indicate that the actual amounts of methane escaping from gas distribution systems in older cities, including Washington, DC, are far higher than previous estimates. Rather than allowing AltaGas to spend upwards of $4 billion dollars of ratepayer money to repair the gas distribution system, the PSC should direct the gas utility to repair only the gas leaks that are large or are dangerous, while working with the DC government and all stakeholders to manage the needed transition off gas.

We are proposing that WGL continue to evolve its business model away from gas entirely. In fact, WGL Holdings is already selling goods and services in addition to gas. As stated on the company’s website, “WGL is a diversified energy business that provides natural gas, electricity, green power, carbon reduction and energy services.” This would not be the first time the company has transformed itself: Washington Gas Light (now WGL) was founded in 1848 to provide gas lighting, which is now rare and purely decorative.

The Commission’s Role is to Serve the Public Interest

The electric and gas companies are corporations for which the number one priority is to make returns on investment for their shareholders. The companies have armies of experts and lawyers to advocate for the interests of their shareholders. The PSC should focus on serving the interests of the public and ratepayers and should make its top priority the just and equitable transition from fossil fuels to clean and affordable energy.