WMATA Has Worst Bus Electrification Record Among Large U.S. Transit Agencies

Written Comments
of
Mike Litt, Sierra Club DC Chapter
Regarding the Fiscal Year 2024 (FY24) Proposed Budget
for the Washington Metropolitan Area Transit Authority (WMATA)

15 March 2023

Metro Board of Directors:

Thank you for the opportunity to comment on the Washington Metropolitan Area Transit Authority (WMATA)’s FY2024 Proposed Budget.^[1] Sierra Club is America’s largest and most influential grassroots environmental organization, with millions of members and supporters. Here in DC, we have around 10,000 members and supporters.

According to the District of Columbia’s Multimodal Long-Range Transportation Plan, also known as moveDC,^[2] transportation is the District’s second highest source of carbon emissions, accounting for 21% of such emissions. WMATA, which operates public transit facilities that help move around 460,000 people in the DC metro area every day,^[3] therefore, plays a critical role in meeting the District’s goals for a 60% reduction in GHG emissions by 2030 and carbon neutrality by 2045, as required by the legally binding DC Climate Commitment Amendment Act.^[4] Meeting our national and local carbon reduction goals will require both shifting more trips away from vehicles, and making sure that vehicle trips—including those on transit vehicles—are powered by clean energy.

WMATA lags far behind its sister agencies in bus electrification. Currently only one of its 1,588 buses, or 0.06% of its fleet, is electric. All of its other buses are fossil-powered.^[5] WMATA still has not released its bus electrification plan to the public, despite Sierra Club’s November 9, 2022 Public Access to Records Policy request asking for this plan. Meanwhile, WMATA persists in planning to acquire mostly fossil fuel buses in FY 2024, and to continue acquiring fossil fuel bus purchases in the coming years.^[6] Other transit agencies are far more advanced and are reaping the rewards in large federal grants to rapidly electrify their bus fleets, in terms of clean air, reduced carbon emissions, and progress towards stable fuel costs. For example, in 2022 alone, the Metropolitan Bus Transit Authority (MBTA) in Boston^[7] and Metropolitan Transit Authority (MTA) in New York City each were awarded $116 million for bus electrification,^[8] LA Metro received over $100 million,^[9] the Central Ohio Transit Authority^[10] and New York Capital District Transit Authority received over $25 million,^[11] and the Southeastern Pennsylvania Transportation Authority (SEPTA) received $23 million.^[12] Even the DC Circulator received about $10 million for bus electrification.^[13] WMATA is probably disqualified from receiving the Federal Transit Administration’s Low-No NOx grant, which is awarding roughly $1 billion a year for five years,^[14] because there is no indication that WMATA has produced the Zero-Emission Fleet Transition Plan that is a prerequisite to eligibility—as noted, WMATA did not share this plan when Sierra Club explicitly asked for it through a Public Access to Records Policy request this fall. 

The following are our recommendations for how to revise WMATA’s FY24 budget to put WMATA in the best possible position to make a shift to increased electrification, better transit service, transit-oriented development, and improved transparency in its communications to the public.

• I. WMATA Should Move Swiftly Toward an Electric Bus Fleet to Clean Our Air and Stabilize Our Climate

In order to prioritize a transition to an all-electric bus fleet, we strongly encourage WMATA to:

• Clarify exactly how many electric buses it plans on procuring during FY24.
• Acquire only electric buses beginning in FY24, and shift from its plans to purchase a majority of buses that are powered by fossil fuels such as compressed natural gas (CNG), diesel, or diesel-electric hybrid.
• Heed the DC Council’s resolution^[15] to purchase only electric buses and end WMATA’s investments in fossil fuel infrastructure.
• Jumpstart its electrification efforts in order to put forth the strongest possible applications for all available federal funds for electric buses and charging infrastructure. This is critical for both meeting WMATA’s decarbonization goals and bolstering its financial condition by reducing its need to take on debt to finance its fleet electrification.
• Complete and publicly release its Zero-Emission Bus Transition Plan.^[16]
• Include near-term electrification deliverables for MetroAccess and maintenance vehicle fleets in WMATA’s final budget.
• Provide details about how WMATA intends to “coordinat[e] with local partners and utilities to put in place the infrastructure needed to support electric buses,” a critical process that is one of its stated goals in its “FY2024 Business Plan.”^[17]

            WMATA’s stated focus on becoming “more sustainable, resilient and fiscally responsible by driving programs and partnerships that foster social wellbeing, racial and social equity, economic prosperity, and environmental stewardship”^[18] is not translating quickly enough into action. In Appendix I to its budget, WMATA acknowledges that it is performing poorly on all of its sustainability goals: its energy and water usage are increasing and its greenhouse gas emissions are not falling.^[19] The most meaningful step that WMATA can take to improve its sustainability is by purchasing only fully electric buses beginning in FY24 and going forward.

Currently, all but one of the 1,588 buses in its fleet are fossil-powered, and many will continually pollute the communities that WMATA serves for at least another decade. Appendix H shows that WMATA has a lot of ground to cover to live up to its support for sustainability. WMATA has recently acquired hundreds of dirty vehicles for its bus fleet: WMATA entered 95 new diesel buses into service in FY 2023, 101 diesel buses in FY 2022, 131 in FY 2021, 35 in FY 2020, and 75 CNG-powered buses in FY 2020. In contrast, Appendix H indicates that WMATA has entered only one electric bus into its fleet, more than six years ago.

The three states in which WMATA operates have enacted climate legislation requiring reductions in greenhouse gas emissions. DC’s Climate Commitment Amendment Act requires a 60% reduction in emissions by 2030,^[20] Maryland’s Climate Solutions Now Act requires a 60% reduction in emissions by 2031,^[21] and Virginia’s Clean Economy Act requires 100% carbon-free electricity generation by 2045.^[22] In addition to these binding regional laws, last year, the National Capital Region Transportation Planning Board set a goal to reduce regional on-road transportation sector emissions 50% below 2005 levels by 2030.^[23] WMATA’s continuing plans to acquire fossil-powered buses will jeopardize the DMV area’s ability to comply with multiple binding climate laws and goals. Based on the FY24 budget, WMATA is planning to acquire 75 fossil-fuel powered buses and only 25 new electric buses.^[24] 

Further, WMATA should confirm whether it actually plans to acquire 25 electric buses in the Bus Fleet Acquisition Program (CIP0006) during FY24, given its significant delay in acquiring and testing 12 electric buses, which it committed to initiate in 2022 as part of its electric bus pilot program (CIP0355). Problematically, WMATA explained to the DC Council earlier this year that this pilot program is delayed; WMATA now anticipates introducing the first two electric buses for the pilot program this summer, and not receiving the remaining 10 buses until next year.^[25]

If the near-term goals for WMATA’s Bus Fleet Acquisition Program are, in fact, accurate, WMATA should disclose how much of the $85.9 million in anticipated FY24 federal grants for the program are for acquiring 25 new electric buses. Sierra Club is deeply concerned that this value is likely zero. Although WMATA’s FY23 budget indicated $10.2 million in anticipated funding from federal grants for its electric bus pilot, the proposed FY24 budget shows $8.7 million in debt spending and $0.0M in federal funding for the pilot. There are currently billions of available dollars in federal funds for fleet electrification, including $1.2 billion through the Low-No NOx grant program,^[26] $469 million through the Competitive Bus & Bus Facilities program,^[27] and $2.6 billion through the Congestion Mitigation and Air Quality Improvement program.^[28] With all of these federal grant opportunities on the table, WMATA should do everything it can to avoid allocating $0 in federal funding ever again for any of its future electrification budgets. WMATA should demonstrate a strong track record and commitment to bus fleet electrification in order to put forth the strongest possible grant applications that attract the funds that are necessary every year to fully electrify its fleet.

In April 2022, and again in February 2023, WMATA mentioned that it is developing its Zero-Emission Bus Transition Plan, but it has not disclosed when the plan will be completed or whether it will release that plan to the public.^[29] Problematically, it is unclear whether this is the same document as the Zero-Emission Fleet Transition Plan, which is a prerequisite for obtaining federal funding under the Infrastructure Investment & Jobs Act (IIJA). If these are two separate documents, we urge WMATA to prepare a Zero-Emission Fleet Transition Plan as soon as possible and make this plan publicly available once it is prepared.

WMATA’s continued acquisition of fossil-fueled buses will also harm public health. Air pollution is the biggest environmental risk factor,^[30] contributing to 85,000 to 200,000 excess deaths in the United States each year. Mobile sources of air pollution emit harmful ozone, the main ingredient of smog, and particulate matter (also known as “soot”).^[31] Although the District met the Environmental Protection Agency (EPA)’s standards for fine particulate matter that is smaller than 2.5 micrometers, it did not meet the levels recommended by 101 environmental and public health organizations, including Sierra Club.^[32]

Reducing air pollution from fossil-powered buses is especially important in communities of color and low-income communities across the District, which face outsized levels of pollution and climate change impacts—resulting in an increased incidence of associated disease and premature death. According to the District’s Transportation Electrification Roadmap,^[33] 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.

In addition to progress on public health, equity, and climate change, there are also cost savings associated with electrifying WMATA’s fleet sooner. As a Sierra Club report^[34] 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. As WMATA itself acknowledges in its FY24 budget, “[z]ero-emission buses have the potential to provide substantial value to the region by reducing greenhouse gas and local air pollution, providing a quieter, smoother ride, and supporting a more sustainable and livable region.”^[35]

As WMATA has also acknowledged, the transition to a zero-emission fleet requires more than just investments in buses. This is why we urge WMATA to acquire the funds necessary for charging infrastructure so it can accommodate only electric bus purchases moving forward, instead of building new fossil fuel infrastructure to accommodate WMATA’s new purchases of fossil-powered buses. WMATA should also make its discussions with Pepco and any other relevant utilities—about necessary upgrades for receiving adequate power from the distribution grid to charge its buses—transparent to the public, so interested parties can weigh in with suggestions or concerns.

We commend the important groundbreakings this year for the Bladensburg and Northern bus garage reconstruction projects that, as the proposed budget points out, will eventually enable both facilities to run 100% electric buses. WMATA’s plans have called for the expansion of methane-based CNG at Bladensburg,^[36] although it has announced plans to open that facility with a 50% electric fleet.^[37] We appreciate the work to get the Bladensburg project zero-emission ready and urge WMATA to accelerate its program even more by making that facility ready for a 100% electric bus fleet on opening day. While WMATA’s plans to open the new Northern Bus Garage with 100% zero-emission buses are a laudable step,^[38] WMATA should not power that new building with fracked gas in lieu of electricity. While WMATA’s stated plan to prepare the Western bus garage to sustain an all-electric fleet is promising, it is unclear why the timeline for that project in the proposed budget is different from the timeline presented to the public in January.^[39] WMATA should confirm whether the projected construction starting time has, in fact, changed from 2026 to 2029, and if so, explain why it expects such a long delay to arise. WMATA should also—as the DC Council called on WMATA to do last year—abandon “current plans to install compressed natural gas fueling apparatus at the Shepherd Parkway Bus Division in Southwest D.C.”^[40]

We would also like to see plans with timelines for WMATA’s electric vehicle purchases for its MetroAccess and maintenance vehicle fleets. We urge near-term electrification deliverables in the final budget for these fleets.

• II. WMATA Should Expand Public Transit Ridership by Improving Service

In order to improve service and increase ridership, which would reduce regional greenhouse gas emissions, we encourage WMATA to:

• Work toward frequency of at least every 10 minutes for all rail lines and bus routes.
• Include targets in the final budget for on-time performance.
• Indicate which parts of the budget are intended to increase on-time performance.
• Prioritize geographic areas that are in highest need of regular, reliable public transit.

We applaud WMATA for the recent opening of the Dulles International Airport rail extension, the upcoming opening of the new Potomac Yard station, plans for acquiring additional railcars, and investments in bus stop infrastructure and the Bus Priority Program. We were also pleased to see WMATA’s move toward more frequent service in February, and we welcome WMATA’s planned FY24 increases in rail service to every six to 10 minutes for Yellow and Green Line trains and every 7.5 to 15 minutes on the Orange Line. The proposed budget indicates that there will be increased frequency for the 16M, A12, and B2 bus routes, but does not appear to include what the new frequency times will be. (It looks like information for Metrorail service improvements was accidentally included on page 32 of the proposed budget instead.)

As moveDC explains, transit’s convenience and attractiveness to the public is determined by high-frequency service, defined as an average of every five minutes or better for rail and 10 minutes or better for buses.^[41] This tracks with WMATA’s Better Bus Network project survey, which found that “[s]horter wait times and on-time arrivals are among the most important factors for current and potential customers.”^[42]

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. Improved service begets more ridership and, in turn, more revenue.

Increasing transit ridership also requires improving reliability. Given the 12% drop in rail on-time performance, down to 79% in FY22, and the continued bus on-time performance of around 77%, we ask WMATA to clarify in the final budget which investments are being made to improve on-time performance and customer satisfaction across the WMATA system. The proposed budget indicates that the Automatic Train Control State of Good Repair project (CIP0251) is related to maximizing on-time performance, but WMATA should indicate any other on-time performance investments that are being made.

WMATA should continually prioritize those areas of highest need in order to improve the District as a whole. According to moveDC,^[43] 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. 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.^[44]

• III.  WMATA Should Increase Transit-Oriented Development

Sierra Club urges WMATA to prioritize equitable and sustainable development in the proposed budget’s investments in support of transit-oriented and joint development planning.

We urge WMATA to support the efforts of its Office of Real Estate & Parking (LAND) to push forward with joint development. Sierra Club is happy to assist WMATA in making it clear to its funders that they should increase their investments in transit-oriented development.

The establishment of housing production and affordability goals for Metro stations and high-capacity bus corridors will help maximize ridership potential. Ensuring DC residents have the ability to be less car-dependent and have access to neighborhood amenities and services (including grocery, healthcare, and public services) through shorter trips is an essential aspect of reducing the number of miles traveled by vehicles and mitigating the associated impacts, including pollution and congestion. We also support the proposed budget’s investment in replacing bicycle racks and lockers to support transit usage by cyclists.

• IV. WMATA Needs to Improve Transparency in Relation to Its Sustainability and Decarbonization Goals

In order to enable policymakers and interested community members to assess WMATA’s progress toward meeting its decarbonization goals and binding DMV-area climate laws, and to provide suggestions as to how WMATA can better meet those goals, we urge WMATA to:

• Include sustainability measures and targets in its final FY24 budget. The proposed budget indicates that WMATA is updating its sustainability measures and targets, but it does not explain what these updates entail or when they will be available.
• Provide a timeline for the completion of the agency-wide Sustainability Action Plan referenced in the proposed budget.
• Provide information regarding which electrification-related federal funds WMATA is applying for, as well as a copy of these applications and a copy of WMATA’s Zero-Emission Fleet Transition Plan.

            From the FY24 budget, it is unclear what the projected deliverables and sources of funding are beyond FY24 for WMATA’s electric bus pilot project, which is anticipated to extend through FY29. WMATA should disclose all of its applications for federal funds for fleet electrification so that the public can be confident that WMATA is not leaving any money on the table, and can assess and assist in WMATA’s grant-seeking efforts.

Additionally, Sierra Club noticed that no funds are allocated for the Track Pollution Prevention project (CIP0210) for the next three fiscal years, and wants to confirm that, despite this lack of funding, WMATA will be able to sufficiently prevent routine fuel spills and comply with environmental regulations.

Another area where WMATA should provide transparency is by explaining why there is a Metrorail budget line item of $6.7 million for gas and diesel fuel costs. This appears inconsistent with the proposed budget’s indication that Metrorail’s energy budget (i.e. fuel, utilities, and propulsion) consists of propulsion usage.

• V. WMATA Should Also Improve the Transparency of Its Safety Spending

In order to increase the transparency of its spending on safety measures for employees and customers, we urge WMATA to:

• Include safety targets in the appendix section of the final FY24 budget.
• Explain which parts of the operating and capital budgets are intended to help meet all safety targets.
• Update the “Human Capital by Department” chart.

We appreciate the information in the proposed budget that shows how some capital projects are expected to meet or exceed the employee and customer injury rate performance targets. The final budget should also note all projects that are expected to help meet targets for other safety metrics, including crime, rail collisions, derailments, fire incidents, and red signal overruns. We also noticed that the FY23 rail customer injury rate performance target referenced in the proposed budget is for “customer injuries per 10 million revenue miles.” However, the metrics measured in the appendices are for “customer injuries per million passengers.” We suggest using a uniform measurement.

The “Human Capital by Department” chart in Appendix C of the proposed budget appears to still list the “Safety & Environmental Management” department, which we understand has been renamed the “Safety & Readiness” department. Given the apparent restructuring of the department, questions over safety protocols,^[45] and new safety-related undertakings, such as a move toward automatic train control^[46] and plans to fix the 7000-series trains,^[47] it is unclear whether the unchanged number of personnel for the department is sufficient.

Sierra Club noticed an increased budget for Rail Vehicle Safety & Reliability Improvements (CIP0067), which has near-term deliverables to improve the 7000 Series HVAC systems and test the effectiveness of higher MERV-rated filtration systems. In the past, WMATA indicated it was working to move to MERV-10 filters on its buses and was piloting MERV-15 filters in its stations and MERV-13 filters and UVC systems on its trains.^[48]

Sierra Club also noticed that there is no FY24 funding allocated in the proposed budget for the Station Revitalization project (CIP0372) to replace fire, life, and safety systems at 18 stations. Given that there was $45.4 million planned for FY24 in the FY23 budget, WMATA should provide an update on this project so interested members of the community can understand why it is no longer being funded during FY24. WMATA should also confirm that even though there is no FY24 funding allocated for Rail Station Emergency Egress Improvements (CIP0339), emergency egress routes will be routinely checked to ensure unimpeded first responder access and customer/employee evacuation in the event of an emergency.

• VI. Conclusion

WMATA is a part of what makes the DMV area a special place to live. We make these recommendations with enormous gratitude to WMATA’s entire workforce for keeping Metro running despite significant challenges over the past few years. We also urge WMATA to meet with Sierra Club. We can be reached at cleantransportation@dc.sierraclub.org, and we are happy to help WMATA prepare strong, timely applications for federal grants so that WMATA can decarbonize its bus fleet and keep serving as the arteries of the Washington metropolitan area, with sustainable public transportation in the District taking on a greater share of the trips that people make every day. Thank you for taking the time to consider these comments.

Sincerely,

Mike Litt
Sierra Club DC Chapter
Chair, Clean Transportation Subcommittee

[1] WMATA, FY24 Proposed Budget [“Budget”], https://www.wmata.com/about/records/upload/FY2024-Proposed-Budget-1-6-23-FINAL.pdf.