Chairperson Walsh, Vice Chairperson Delgado, Spokesperson Wheeler, honorable members of the committee: thank you for the opportunity to testify today in opposition to House Bill 1473. My name is Abraham Scarr and I am the Director of Illinois PIRG. Illinois PIRG is a statewide, citizen funded, non-partisan public interest advocacy organization that speaks out for a healthier, safer world in which we’re freer to pursue our own individual well-being and the common good.
House Bill 1473 is another proposal to grant gas grant utilities overly broad authority to spend billions of dollars with limited oversight, driving up customer bills with no guarantee of customer or public benefit.
The legislation, which purports to aim to lower greenhouse gas emissions from gas distribution utilities, neither promises nor requires any actual reduction in greenhouse gas emissions. It's only requirement is that gas utilities replace 2% of their gas supply with so-called "renewable" or "sustainable" gas by 2030.
As I have shared with this committee before, the potential benefits of using so-called renewable natural gas in the gas distribution context are dubious. The amount of potential RNG is limited, RNG is expensive, and the greenhouse gas emissions savings from RNG are questionable.
The greatest potential source for RNG is from landfill sites, most of which already have gas collection in place. While more direct emission reductions may be achieved from other potential RNG sources, such as animal manure, the RNG production potential is much smaller and the costs much higher. Ultimately, simply flaring gas onsite achieves the same or greater greenhouse gas emission reductions as injecting it into the gas distribution system and eventually burning it in someone’s furnace, and flaring can be achieved without spending billions of dollars.
The legislation proposes four metrics, or categories of metrics, none of which would measure the reduction of greenhouse gas emissions. Rather, they measure the “implementation of the proposed qualified investments” and “implementation of the proposed customer programs and qualified investments” “in support of” potential emission reductions and “ in support of a pathway to reduce, offset, or avoid” emissions. That is, they measure utility spending, spending that need only be “in support of” or “in support of a pathway to”reduce emissions.
In exchange for guaranteeing no public or customer benefit, this legislation identifies broad and vague categories of investment and formula rates to recover them. Much of the language is copied directly from the current ComEd formula rate. There are no limits to the amount of spending or to its impacts on ratepayers, and the design of formula rates restrict regulators ability to set such limits.
Formula rates have failed Illinois consumer and the public interest. The Illinois General Assembly should reject, rather than double down, on one of the worst policies passed during the ComEd bribery scheme.
Rather than passing this legislation, the General Assembly should initiate a multi-stakeholder investigation into the future of gas distribution and the potential targeted applications of RNG in a decarbonized Illinois economy.
Thank you for the opportunity to testify today. I will be happy to answer any questions