Written Comments
of
Sierra Club District of Columbia Chapter
Regarding the Washington Metropolitan Area Transit Authority (WMATA)
Strategic Transformation Plan
14 February 2023

Thank you for the opportunity to submit written comments on Your Metro, The Way Forward, the proposed Strategic Transformation Plan for the Washington Metropolitan Area Transit Authority (“WMATA” or “Metro”).

Sierra Club is America’s largest and most influential grassroots environmental organization, with millions of members and supporters. Here in DC, we have 3,000 dues-paying members and many thousands of supporters.

We recognize Metro is a part of what makes the DMV area a special place to live, work, and play. We express our gratitude to WMATA’s workforce for keeping Metro running despite the challenges of recent years. Our region’s ability to fully emerge from the pandemic, mitigate global warming, and ensure everyone has the ability to get around the District as sustainably and healthfully as possible depends on Metro’s ability to electrify and modernize. An effective, high-functioning transit system allows millions of people in our metro region to live in less car-dependent, more compact neighborhoods, where trips are shorter and can be taken by much more energy efficient modes like public transit. We strongly encourage Metro to comply with DC’s climate laws and embrace the opportunity—afforded by newly available federal funds—to be a more sustainable, reliable, safe, and equitable entity.

Metro faces numerous challenges, one of which is its heavy responsibility, as a major public transit entity in the nation’s capital, to help DC, Virginia, and Maryland meet their legally binding climate commitments in both the short and long term. Our national and local carbon reduction goals require both shifting more trips away from vehicles, and making sure that vehicle trips—including those on transit vehicles—are powered by clean energy.

However, Sierra Club cannot adequately provide feedback on WMATA’s plans while these plans lack concrete strategies or interim targets to support the implementation of WMATA’s climate goals. Meanwhile, WMATA is lagging behind other cities’ transit fleets in terms of the ambition of its goals and its use of readily available federal funding sources to achieve these goals.

Sierra Club recently submitted comments on the much shorter and less specific transformation plan issued by WMATA late last year, and while the slightly higher level of detail in the latest draft plan is preferable, WMATA still has a long way to go in terms of providing specificity about its goals and transparency about the tangible steps it is taking to implement these goals. In submitting these comments, Sierra Club urges Metro to improve its services and electrification efforts so that sustainable public transportation in the District can take the form of zero-emission battery-powered buses and take on a greater share of the trips that people make every day in the metropolitan area.

• I. Jumpstarting electrification

DC has some of the nation’s most ambitious climate goals. The Climate Commitment Amendment Act^[1] calls for the District to achieve a 60% reduction in greenhouse gas (“GHG”) emissions by 2032 and carbon neutrality by 2045. The Clean Energy DC Omnibus Act^[2] 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.” As noted in the DC Department of Energy & Environment (“DOEE”)’s Transportation Electrification Roadmap,^[3] which was released last August, the electrification of bus fleets is especially critical for reaching the District’s GHG emission reduction goals.

1. Electrifying WMATA’s bus fleet

DOEE’s Transportation Electrification Roadmap explicitly incorporates WMATA in its plan for achieving DC’s climate goals, stating, “[a]s WMATA finalizes its fleet transition plan, the District will work with the battery electric team to lower barriers identified in its plan, and to hasten projects for BEB [(Battery Electric Bus)] operations in the District.” DOEE emphasized WMATA’s importance in complying with DC climate law, explaining that "the transition of WMATA passenger bus assets is a critical component to meaningful transit electrification in the District” and “WMATA is a linchpin in any efforts to decrease the District’s greenhouse gases.” DOEE added, “[p]artnering with WMATA to transition the fleet of transit buses to BEBs will further drive down GHG emissions and eliminate air pollution caused by diesel fuel, decreasing exposure to air toxins for both residents and visitors.”

This Roadmap illustrates that the DC government correctly and transparently recognizes WMATA’s pivotal role in making this region cleaner, healthier, and innovative in adopting and achieving ambitious GHG emission reduction goals. This was made even more obvious in a February 1, 2022 resolution,^[4] unanimously adopted by the DC Council, calling on WMATA to electrify its fleet. Titled “Sense of the Council Urging WMATA’s Bus Fleet Electrification Resolution,” this document dictated, “Going forward, WMATA must buy only electric buses, meaning that Metro's entire fleet would be fully electric by 2038[.]” The resolution called on WMATA to “cease investment in diesel and compressed natural gas fueling infrastructure that risks becoming a stranded asset, including abandoning current plans to install compressed natural gas fueling apparatus at the Shepherd Parkway Bus Division in Southwest D.C.”

WMATA, in contrast, could hardly be less transparent in describing its own GHG emission reduction goals and its strategies to achieve these goals. It is only at the very end of the Strategic Transformation Plan’s appendix that WMATA even mentions its goal of transitioning to a 100% zero-emission bus fleet by 2045. WMATA inexplicably couples “financial sustainability” and “environmental sustainability” in the same section of its Plan, even though its finances and environmental measures are completely distinct topics that merit separate analyses. WMATA includes the vague terms “[a]dopt decarbonization strategy” and “plan for transition to zero emission bus and non-revenue vehicle fleet” as two examples of its environmental sustainability initiatives, without any description of what these strategies concretely entail. Nowhere in its Plan does WMATA explain what its interim electrification goals are, or what steps it intends to take to achieve these goals.

From reviewing documents that WMATA has produced in other contexts and at other points in time, Sierra Club has attempted to piece together a more detailed version of WMATA’s real five-year plan. According to the Metrobus Fleet Management Plan,^[5] published in December 2021, WMATA is planning on procuring 375 methane-burning compressed natural gas (“CNG”) buses, compared to only 125 electric buses, from FY 2024 through FY 2028. Even as late as FY 2029, WMATA is planning for half of its bus purchases to be CNG-powered buses. If WMATA has made its plans more climate-friendly than this since 2021, it is impossible to tell, because WMATA’s Strategic Transformation Plan lacks any details about WMATA’s zero-emission bus procurement goals.

WMATA’s plan to acquire a mostly CNG-powered fleet for the remainder of the decade is out of step with other public transit agencies’ immediate procurements of electric vehicles. The DC Circulator fleet,^[6] by contrast, has been operating electric buses since 2018, and is planning to acquire only electric buses going forward, anticipating having a fully electric fleet by 2030. Looking at a larger local transit fleet, the Maryland Transit Administration^[7] is committed to purchasing only battery-electric buses starting now. It is acquiring seven new electric buses this year, and will acquire 70 electric buses per year beginning in 2025, which means that half of its over 700 buses should be electric by 2030.

WMATA’s plan to continue relying on CNG-powered buses is also inconsistent with DC climate law. WMATA paints an image of a cleaner fuel supply, potentially running on “renewable” natural gas (“RNG”), but CNG-powered buses—even those powered by supposedly “renewable” sources of gas—emit methane, a potent GHG with 84 times the global warming potential of carbon dioxide. According to the Washington Post,^[8] data collected by the Argonne National Laboratory shows that buses fueled with CNG have nearly the same level of GHG emissions as diesel buses in many circumstances. Increasing DC’s methane emissions will significantly undercut DC’s ability to reach a 60% emission reduction by 2030 and carbon neutrality by 2045. According to the National Capital Region Transportation Planning Board (TPB) Climate Change Mitigation Study of 2021,^[9] the scenario that gets us the closest to meeting the Metropolitan Washington Council of Governments’ goals for GHG emissions includes having 100% electric buses on the road by 2030.

Additionally, WMATA fails to acknowledge the heavy uncertainty surrounding the future technological feasibility, availability, and prices of RNG and hydrogen, which WMATA touts as alternatives to CNG. As one illustration, a recent study shows that RNG can be up to 17 times more costly than fossil gas, and even if the gas industry spent two decades ramping up sources of RNG production, the total supply of RNG would cover only up to 13% of the current demand for fossil gas.^[10] WMATA’s planning documents also fail to engage with the complications of relying on hydrogen as a source of fuel. To illustrate some of those potential issues, the Maryland Transit Administration is initiating its fleet electrification using battery-electric buses rather than hydrogen fuel cell buses, noting that battery-electric buses “are more widely available and have been deployed in greater quantities in the U.S. transit market” and “have lower initial capital costs for both rolling stock and charging infrastructure,” and hydrogen fuel cell buses can be “incompatible with existing fire safety codes.”^[11]

WMATA should also be increasing electric charging infrastructure at its bus garages. In its December 2021 Fleet Management Plan, Metro noted that “[t]he rate at which Metro can transition to electric buses will be largely constrained by facility and charging system capacities, and both areas will take a decade or more to build out.” WMATA cannot simply use these long lead times of reconfiguring its bus garages as an excuse not to electrify its fleet; multiple major transit agencies around the country are working on upgrading their bus facilities at the same time that they transition their fleets to electric buses. In the same December 2021 report where WMATA acknowledged that it needs to prepare its garages for electrification, it counterintuitively admitted that it is increasing CNG fueling capacity at its Shepherd Parkway and Bladensburg garages. This is the pivotal time for Metro to be acquiring federal funds and taking concrete steps to build out a clean battery-electric fleet, not further entrenching itself in a dirty, outdated fossil fuel-based transit system. While WMATA’s plans to open the new Northern Bus Garage^[12] with 100% zero-emission buses are a laudable step, WMATA should not be powering that new building with fracked gas in lieu of electricity.

There are also cost savings associated with electrifying WMATA’s fleet sooner. As a Sierra Club report on WMATA’s bus fleet shows, there would be a savings of at least $350 million over a 15-year time period if 50% of WMATA’s fleet were electric. According to that report, fully electrifying WMATA’s fleet would save the DMV region more than $8 million per year in health care costs.^[13]

WMATA should heed the DC Council’s resolution and GHG emission reduction mandates in DC law by formally committing to buying only electric buses beginning in 2023, rather than any additional buses that use CNG, RNG, or hydrogen, and to ceasing its plans to expand its gas infrastructure. Sierra Club urges WMATA to produce a final version of its Strategic Transformation Plan that incorporates the above feedback about increasing transparency and specificity, and includes concrete details about how WMATA plans to achieve its fleet electrification goals. This would be consistent with the DC Council’s resolution on WMATA, which called on WMATA to “commit to releasing an annual progress report identifying milestones, challenges, and ongoing actions that facilitate rapid electrification.”

WMATA should be hastening its timeline toward zero-carbon emissions with a cleaner, all-electric bus fleet and infrastructure, not locking us into a future with more polluting methane, a greenhouse gas more potent than the carbon dioxide emitted by petroleum-fueled buses, or the continued negative health effects and harms from fossil fuel combustion.

2. Taking advantage of federal funding

In its Strategic Transformation Plan, WMATA repeatedly groups financial sustainability with environmental sustainability, potentially as a means of implying that WMATA may not be able to achieve the latter if it lacks the former. However, WMATA should not be creating a false choice between bolstering its financial condition and transitioning to a zero-emission bus fleet. WMATA should be applying for and acquiring millions of dollars in available federal funding, which would enable WMATA to achieve both of these goals simultaneously. In doing so, WMATA would be adhering to the DC Council resolution’s instruction that WMATA “immediately apply for applicable federal funding[.]”

The Infrastructure Investment and Jobs Act provides an unprecedented amount of federal funding for acquiring zero-emission transit buses. For example, the Low-No NOx grant program, administered by the Federal Transit Administration, contains $1.1 billion to allocate toward state and local governments’ purchases or leases of zero-emission transit buses and “supporting facilities.”^[14] A total of $1.7 billion is currently available in federal grants under that program, and WMATA should apply^[15] for these funds by the upcoming April 13, 2023 deadline. Sierra Club is willing to provide support and assistance to WMATA in applying for grants such as these. As another example, the Competitive Bus & Bus Facilities grant program allocates $1.9 billion toward purchasing and leasing zero-emission buses and bus equipment.^[16] Additionally, the Congestion Mitigation and Air Quality Improvement grant program provides $2.5 billion to states for “the purchase of diesel replacements, or medium-duty or heavy-duty zero emission vehicles and related charging equipment.”^[17] We urge WMATA to seek funding under these grants, and any other available funding, for the purposes of swiftly and effectively electrifying its fleet.

Metro is lagging behind other cities’ transit agencies in its applications and acquisitions of federal grants. It is very difficult to find any public information about WMATA’s attempts to acquire federal funds, and the Strategic Transformation Plan includes no reference to the existence of these grants, much less WMATA’s plans to apply for funds under these grants. If one carefully reads Metro’s FY2023 budget, it becomes apparent that Metro received $0.6 million in funding under the Congestion Mitigation and Air Quality Improvement grant program, which is a relatively low sum. And although the grant amount is not specified in Metro’s FY2023 budget, the Federal Transit Administration’s list of awarded Low-No NOx grants does reflect that Metro received a $4.1 million Low-No grant for purchasing electric buses and charging infrastructure.

In contrast, other transit agencies have publicly available information about the millions of dollars in federal grants for zero-emission buses that they have already received. For example, in the Philadelphia region, the Southeastern Pennsylvania Transportation Authority (“SEPTA”) is using $23 million in recently acquired federal funds to electrify its fleet of transit buses.^[18] In Boston, the Metropolitan Bus Transit Authority (“MBTA”) received $116 million for purchasing battery-electric transit buses.^[19] New York’s Metropolitan Transit Authority (“MTA”) also received $116 million in federal grant money for electric buses.^[20] By failing to acquire significant sources of these federal funds, WMATA is undercutting both its financial and environmental sustainability, and publicly falling behind its sister transit agencies.

Sierra Club strongly recommends that, either in this Strategic Transformation Plan or through other publicly available planning documents, WMATA provide information and regular updates about its applications and acquisitions of sources of federal funding. Sierra Club is familiar with the requirements for obtaining these grants and would like to serve as a resource for assisting WMATA in acquiring and efficiently using federal grants for electrification. However, in order to make this possible, WMATA must be more transparent with Sierra Club, other environmental organizations, and members of the general public.

3. Using credible metrics for sustainability targets

Sierra Club strongly urges WMATA to develop reliable metrics that track its progress toward meeting GHG emission reduction and other sustainability goals, and to create public-facing dashboards to display this data.

It is critical that there be transparency and adequate documentation on how WMATA’s environmental metrics are calculated in order to ensure public confidence, particularly in relation to its metric on GHG emissions—this data and documentation must be readily accessible to and viewable by the public. For calculating GHG emissions, we recommend that WMATA use Argonne National Laboratory's Alternative Fuel Life-Cycle Environmental and Economic Transportation (AFLEET) tool.^[21] It is also important that this data be refreshed on a periodic basis and the latest refresh date be displayed. WMATA may want to look into using data visualization software like Qlik Sense or Tableau, which can be set to automatically refresh and can be embedded in a web page. Lastly, there should be a way for WMATA’s customers to communicate with the team that is responsible for managing the data, and ideally be provided a specific point of contact at WMATA, in case customers have any questions, concerns, or feedback about WMATA’s emissions-tracking metrics.

We also noticed that the types of sustainability metrics in the Strategic Transformation Plan look different from those included in WMATA’s FY2023 proposed budget, which appeared to show Metro falling short of its targets for water use, energy use, and GHG emissions for FY2019 - FY2021. Concerningly, these metrics appear to have been dropped altogether from the final FY2023 budget. If WMATA genuinely intends to reduce its GHG emissions and resource usage, it should also provide reliable metrics of these variables in a publicly accessible format.

The Strategic Transformation Plan should also explain the differences in sustainability metrics between the plan and WMATA’s FY2023 budget, which environmental variables WMATA intends to measure, the metrics that WMATA intends to use for these variables, and whether progress has been made toward meeting WMATA’s GHG emission reduction goals.

• II. Increasing ridership

In addition to directly reducing GHG emissions by electrifying its fleet, WMATA has a large role to play in reducing vehicle emissions in DC by increasing residents’ usage of public transit. According to the District of Columbia's Multimodal Long-Range Transportation Plan, also known as “moveDC”, transportation is the District’s second leading source of GHG emissions, accounting for 21% of such emissions.^[22]

Increasing transit ridership is key to reaching the DOEE’s Sustainable DC 2.0^[23] targets for increasing the use of public transit to 50% of all commuter trips in all wards and reducing GHG emissions by 60% from the transportation sector by 2032, a key step toward reaching the District’s overarching goal of carbon neutrality by 2050.

1. More frequent, reliable trips

Sierra Club is heartened that WMATA’s Strategic Transformation Plan includes a near-term focus on implementing more frequent service on the Green, Yellow, and Orange lines, metrics for measuring the percentage of customers’ rail trips with six minutes or better frequency, and operational changes to improve reliability through maintenance and operations plans. We are pleased to see WMATA’s move toward more frequent service by increasing service^[24] in February to 12 minutes for certain Blue, Orange, and Blue Plus line trips, and expanding eight-minute frequency to more Red Line trips.

As moveDC explains, transit’s convenience and attractiveness to the public is determined by high-frequency service, defined as a five minute or lower wait for rail and 10 minutes or lower for buses. This tracks with WMATA’s Better Bus Network project survey,^[25] which found that “[s]horter wait times and on-time arrivals are among the most important factors for current and potential customers.”

Sierra Club therefore encourages WMATA to work toward improving service frequency in the future to at least every 10 minutes for all rail lines and bus routes. An increase of this kind would make riding Metro a more convenient and appealing option for more DC residents and visitors, increasing ridership and revenue and reducing global warming pollution. People would be more likely to choose Metro if there was an easy to remember, across-the-board schedule that truly felt frequent. This would help with Metro’s “financial sustainability” as well. Improved service begets more ridership and, in turn, more revenue.

2. Equity

Metro should also be centering equity in its planning process. Improving transit access and ridership will help low-income communities, communities of color, and disabled individuals by facilitating residents’ ability to travel around the District and reducing air pollution in communities of concern.

The “Regional Opportunity and Partnership” section has several laudable ideas for reshaping transit’s role after the pandemic permanently reshaped travel patterns around the region. Implementing a redesigned bus network, simplifying fares, and planning for transit-adjacent land uses to maximize ridership will all help to ensure that more people can benefit from WMATA’s services. WMATA must remind its partners in local government that their investment in transit is most useful when more of their residents live and work near transit.

According to moveDC, the areas in the District with the greatest transportation needs are defined by factors such as residents’ proximity to frequent transit service and their commute times.^[26] People of color, low-income residents, and people with disabilities make up a larger percentage of the population in areas with greater transportation needs than in other neighborhoods in the District. Sierra Club recognizes transit equity as a civil right and calls for “investments in safe, reliable and affordable public transit service, including improved wages, benefits, training, and health and safety protocols to expand and retain the workforce” and ensure access to transit for all.^[27]

Last year, Sierra Club noted the release of an important new report, titled “Invest in Transit Equity, Invest in Transit Workers,” which was produced by the Alliance for a Just Society, the Labor Network for Sustainability, and Transit Center.^[28] That report describes how “inadequate investments in job quality” for our public transit workforce have worsened transit service in cities, towns, and states nationwide. The report concludes that equitable transit service depends on having adequate staffing and a “stable, skilled, and experienced public transit workforce.” By investing more in developing such a workforce, transit agencies can improve racial equity and economic outcomes across our communities. Sierra Club noted that the “report calls on transit agencies to work with their employees—through their democratically elected union representatives—to address staffing issues, including pay, benefits, health and safety protections, and training.”

            Reducing air pollution from fossil-powered buses is also especially important in communities of color and low-income communities across the District, which face disproportionately high levels of pollution and climate change impacts—resulting in an increased incidence of associated negative health outcomes, disease, and premature death. According to the District’s Transportation Electrification Roadmap, Black residents experienced three times as many deaths per capita from cardiovascular disease as white residents, and children living in predominantly Black communities have significantly higher asthma-related emergency visits—up to nearly 20 times higher—than those in majority-white communities. WMATA needs to take immediate steps to reduce this unacceptable disparity in public health outcomes, not continue to place fossil-powered buses on its roads.

Increasing and improving service in these areas and getting more people from all parts of the city out of private vehicles and off of DC’s roads are other critical steps for addressing these inequities.

3. Safety

Sierra Club appreciates the safety objective and metrics related to crimes and injuries in the Strategic Transformation Plan. Given continued tragedies in the news^[29] and questions about rail safety,^[30] we would also like to see more specifics about the different types of safety risks being addressed by Metro, such as collisions, COVID-19, crime, derailments, fires, and injuries. As noted above, Sierra Club is unequivocal in our position that “greater access to safe, reliable and affordable transit service is the shortest route to an equitable society” and that Metro should partner with transit workers and the community to take every reasonable step to ensure this objective is met—doing so is a win for our climate, our economy, and our communities.

III. Conclusion

For the reasons expressed above, we urge Metro to take bold action to electrify its fleet, increase its ridership and reliability, take advantage of all available federal grant opportunities, and drive toward a more equitable and just future for our region. This is Metro’s moment to be a sustainability leader among its sister transit agencies. We also urge Metro to be transparent and clear on its policies, so that Sierra Club and other members of the public may track its progress toward meeting its goals. We look forward to Metro’s swift action on these fronts, and are keen to partner with Metro—and hold Metro accountable—in the process of helping Metro define and achieve that success. Thank you for taking the time to consider these comments.