Letter to Energy Trust of Oregon: Request to Reevaluate Energy Trust of Oregon’s Fuel Switching Policy
View a PDF of this letter here.
To: Energy Trust of Oregon President Melissa Cribbins and Board of Directors
CC: Oregon Public Utility Commissioners and relevant Energy Trust of Oregon Staff
Subject: Request to Modernize Energy Trust of Oregon’s Fuel Switching Policy
Dear President Melissa Cribbins and Energy Trust of Oregon Board Members,
The undersigned organizations urge the Energy Trust of Oregon to modernize its Fuel Switching Policy immediately to permit and incentivize switching from gas to electric appliances and heating and cooling systems for the health and safety of Oregonians and to mitigate the devastating impacts of climate change.
Since its inception, the Energy Trust of Oregon, Inc. (“Energy Trust”) has served a vital role in providing Oregon residents and businesses with energy efficiency and renewable energy solutions. Energy Trust has also been able to innovate and adapt to emerging conditions or technologies while continuing to help its customers and communities reduce costs and save energy. Energy Trust’s Strategic Plan identifies the continuing need to innovate and adapt, highlighting challenges and emerging dynamics that will require changes in order to accomplish the organization’s energy goals and benefit customers. In particular, this plan identifies challenges relating to the need to mitigate and adapt to the harmful effects of climate change and the related need to reduce greenhouse gas emissions. Other recent Energy Trust documents similarly focus on connecting its programs to, among other things, resiliency and greenhouse gas reduction efforts. Governor Brown’s Executive Order 20-04 likewise acknowledges the urgent need to reduce emissions and protect vulnerable populations. This order, among other things, directs the Public Utility Commission to prioritize activities that advance decarbonization and reduce GHG emissions. In light of the recent climate-driven heat dome that settled over Oregon, leading to days of record breaking temperatures and a “mass casualty event” of over 100 recorded deaths across the state, the need for climate action has never been so urgent. With some program adjustments, the Energy Trust of Oregon could help lead this action.
To address these unprecedented challenges and truly serve Oregonians, Energy Trust will need to overhaul its approach to natural gas incentives. Though the full scope of how Energy Trust adapts to address these challenges may present complications, certain changes are easy. We, the undersigned, are writing today to ask that you implement one of the simple changes: revoke the Fuel Switching Policy. The Fuel Switching Policy provides that the “Energy Trust should revisit the Policy periodically to assess whether the Energy Trust is missing compelling opportunities.” It is hard to imagine a more compelling, more urgent opportunity than addressing the climate crisis, and the devastating impacts being felt across our state.
Natural gas, the majority of which comes to Oregon from fracked sources, is primarily methane. Methane is an exceptionally potent greenhouse gas, providing 84-86 times the warming power of carbon dioxide over the first 20 years (28-34 times over 100 years). Several recent studies have demonstrated the urgency to reduce methane emissions. For example, in early May, the United Nations noted that “cutting methane is the strongest lever we have to slow climate change over the next 25 years....” Also in early May, a study published in the Environmental Research Letters found that cutting methane emissions could slow the rate of global warming by about 30%. Several weeks later, the International Energy Agency (“IEA”), an historically conservative organization, issued a roadmap to meet net zero emissions by 2050 and thereby attempt to limit the worst impacts of climate change. The IEA roadmap describes a rapid reduction in fossil fuel use, including banning new fossil fuel boilers by 2025.
In addition to the obvious and severe climate impacts, natural gas presents other significant risks, including risks that are inconsistent with Energy Trust priorities. For example, several recent studies have demonstrated the indoor health impacts of natural gas. These studies have shown how natural gas appliances can lead to indoor air so degraded that it would violate ambient air standards if measured outside. They have also linked this indoor air quality to increased asthma and other health costs—costs that disproportionately impact low-income populations and communities of color. While some might be able to afford and maintain venting that would remove some of these contaminants from their homes, simply expelling these pollutants outdoors is not a solution. Recent studies have demonstrated the connection between natural gas combustion in buildings to community deaths from diminished outdoor air quality. In addition, natural gas presents other significant community safety concerns, from explosions (like the one in Northwest Portland in November 2016), to leaking distribution systems, to infrastructure located in areas with significant seismic hazards. And these hazards, as well as the overall impacts of climate change, disproportionately impact Black, Indigenous, and People of Color (BIPOC) and low-income communities—the same communities for which the Energy Trust identifies a need to improve its ability to serve.
Based on these climate, health, safety, and justice risks, many cities have banned natural gas hookups in new construction. Studies similarly recommend that states phase out utility incentive programs for natural gas appliances and heating and cooling systems. These appliances can last for 10 to 20 years, with any new purchase working to lock in these negative public health and climate warming impacts for years to come.
As the destruction from raging wildfires and the mass casualties from the recent climate-change-induced heat dome illustrate, we can no longer pretend that we have unlimited time. Based on the state of science and existing technologies, we need to and we can decarbonize now. Oregon’s HB 2021, which will provide Oregon utility customers with 100% clean electricity while prioritizing environmental justice issues, further illustrates the importance and benefits of electrification.
Gas utilities, recognizing the incompatibility of their product with decarbonization, have attempted to sell renewable natural gas or hydrogen as solutions. While these alternatives might have limited use in hard-to-electrify sectors, they represent false solutions for building decarbonization (both with respect to availability and affordability) and serve only to delay the necessary and inevitable transition from fossil fuels to clean electricity. Retaining, or worse, expanding natural gas infrastructure while recognizing the need to phase out fossil fuels will lead to stranded costs which will need to be absorbed by a shrinking number of natural gas customers—likely those least able to afford to transition to electric.
Against this backdrop, it is indefensible to continue to incentivize additional natural gas infrastructure or to maintain barriers to electrification for residential and business customers. Unfortunately, the Fuel Switching Policy, though facially neutral, does just that by requiring customers to independently determine that they will switch fuels, and communicate that, before learning about the incentives for ultra-efficient electric appliances. Instead of encouraging customers to make the necessary transition from natural gas, the Fuel Switching Policy imposes unnecessary burdens on customers and conflicts with stated Energy Trust goals. Energy Trust should not only allow incentives to convert from natural gas to electric appliances and heating and cooling systems, but should also expressly encourage it.
The undersigned organizations urge the Energy Trust of Oregon to revoke or modify its Fuel Switching Policy immediately to permit and incentivize switching from gas to electric appliances and heating and cooling systems for the health and safety of Oregonians and to mitigate the devastating impacts of climate change.
Thank you for your consideration.
Alan Journet and Kathy Conway, Co-Facilitators, Southern Oregon Climate Action Network (SOCAN)
Amy Schlusser, Staff Attorney, Green Energy Institute at Lewis & Clark Lawschool
Anne McKibben, Policy Director, Elevate
Anne Pernick, SAFE Cities and Fossil Fuel Non-Proliferation Treaty Community Manager, Stand.Earth
Bethany Cotton, Conservation Director, Cascadia Wildlands
Bill Kucha, Chair, 350 Oregon Central Coast
Brian Lee, Lead, Corvallis Interfaith Climate Justice Committee
Brian Stewart, Founder, Electrify Now
Carl Christianson, Owner, G. Christianson Construction
Cathryn Chudy, Director, Oregon Conservancy Foundation
Dineen O’Rourke, Campaign Manager, 350PDX
Dylan Plummer, Senior Campaign Representative, Sierra Club
George Hutchinson, Pacific Green Party, Treasurer
Greg Bourget, Portland Clean Air, Executive Director
J. Ron Hess, Co-Moderator, Eugene Interfaith Earth Keepers
Jonny Kocher, Associate, Rocky Mountain Institute
Karen Stahr Bloom, Team Leader, Environmental Care Team, First United Methodist Church of Corvallis
Kathleen McKinney, Board Chair, Oregon Unitarian Universalist Voices for Justice
Lenny Dee, President, Onward Oregon
Meredith Connolly, Oregon Director, Climate Solutions
Mike Bellstein, Coordinating Committee, Pacific Green Party, Linn-Benton Chapter
Nick Caleb, Climate and Energy Attorney, Breach Collective
Noelle Studer-Spevak, Board Secretary, Families for Climate
Patricia Hine, President, 350 Eugene
Peter Sallinger, Founding Member, Portland Youth Climate Council
Samantha Hernandez, Climate Justice Organizer, Oregon Physicians for Social Responsibility
Wendy Woods, Coordinator, Electrify Corvallis
Energy Trust of Oregon, Strategic Plan 2020 - 2024 (“2020 - 2024 Strategic Plan”), pp. 3, 12-13, available at https://www.energytrust.org/wp-content/uploads/2019/11/2020-2024_StrategicPlanGuide_Final.pdf (all links last accessed 7/18/2021).
Energy Trust of Oregon, attachments to Energy Trust of Oregon 2021 Annual Budget and 2021-2022 Action Plan APPROVED AMENDED, pp. 27 (Organizational Goals) & 128 (Action Plan) (May 19, 2021), available at https://www.energytrust.org/wp-content/uploads/2021/05/Amended_2021-22_Budget_Binder.pdf.
Governor Kate Brown Executive Order 20-04 (“Directing State Agencies to Take Actions to Reduce and Regulate Greenhouse Gas Emissions”), pp. 7-9 (3/10/2020), available at https://www.oregon.gov/gov/Documents/executive_orders/eo_20-04.pdf.
Sightline Institute, Is Your “Natural” Gas Actually Fracked? available at https://www.sightline.org/2017/10/30/is-your-natural-gas-actually-fracked/
United Nations Economic Commission for Europe, “The Challenge,” available at https://unece.org/challenge.
Climate and Clean Air Coalition (CCAC) and the United Nations Environment Programme (UNEP), Global Assessment: Urgent Steps Must be taken to reduce methane emissions this decade (5/6/21), available at https://www.unep.org/news-and-stories/press-release/global-assessment-urgent-steps-must-be-taken-reduce-methane
Ilissa B Ocko et al 2021 Environ. Res. Lett. 16 054042, available at https://iopscience.iop.org/article/10.1088/1748-9326/abf9c8
UCLA Fielding School of Public Health Department of Environmental Health Sciences, Effects of Residential Gas Appliances on Indoor and Outdoor Air Quality and Public Health in California, p. 6 (4/2020), available at https://ucla.app.box.com/s/xyzt8jc1ixnetiv0269qe704wu0ihif7
Id. at p. 26-27.
Seals, Brady, “Indoor Air Pollution: the Link between Climate and Health” (5/5/2020), available at https://rmi.org/indoor-air-pollution-the-link-between-climate-and-health
Seals and Prescott, “Uncovering the Deadly Toll of Air Pollution from Buildings” (5/5/2021) (discussing Harvard T.H. Chan School of Public Health study), available at https://rmi.org/uncovering-the-deadly-toll-of-air-pollution-from-buildings/; see also Jonathan J Buonocore et al 2021 Environ. Res. Lett. 16 054030, available at https://iopscience.iop.org/article/10.1088/1748-9326/abe74c.
See https://thegasindex.org/ (showing significant leakage rates in Portland, OR).
NAACP, Fumes Across the Fence-Line: The Health Impacts of Air Pollution from Oil & Gas Facilities on African American Communities (11/2017), available at https://naacp.org/resources/fumes-across-fence-line-health-impacts-air-pollution-oil-gas-facilities-african-american, and
Fossil Fueled Foolery: An Illustrated Primer on the Top 10 Manipulation Tactics of the Fossil Fuel Industry, Fossil Fueled Foolery 2.0: An Illustrated Primer on the Fossil Fueled Industry's Deceptive Tactics (4/2021), available at https://naacp.org/articles/new-naacp-report-fossil-fueled-foolery-20.
2020 - 2024 Strategic Plan, p. 4.
Though California cities have been leading the way (https://www.sierraclub.org/articles/2021/06/californias-cities-lead-way-gas-free-future), other major cities have also worked to phase out gas, including Seattle (https://www.kuow.org/stories/seattle-bans-natural-gas-in-new-buildings). Closer to home, Multnomah County prohibited the use of fossil fuels in new and remodeled county buildings (https://www.multco.us/sustainability/news/multnomah-county-board-first-state-restrict-fossil-fuel-use).
Rocky Mountain Institute, Regulatory Solutions for Building Decarbonization: Tools for Commissions and Other Government Agencies, p. 31 (7/2020), available at https://rmi.org/insight/regulatory-solutions-for-building-decarbonization/.
Borenstein, Seth, “Study: Northwest heat wave impossible without climate change” (7/7/2021), available at https://apnews.com/article/climate-climate-change-science-environment-and-nature-935be069af34aad472074d42097af85e.
https://olis.oregonlegislature.gov/liz/2021R1/Measures/Overview/HB2021.
Roberts, David, “The false promise of “renewable natural gas” (2/20/2020), available at https://www.vox.com/energy-and-environment/2020/2/14/21131109/california-natural-gas-renewable-socalgas; “Green Hydrogen in Natural Gas Pipelines: Decarbonization Solution or Pipe Dream?” (11/30/2020), available at
Oregon Citizens Utility Board, “COMMENTS OF THE OREGON CITIZENS’ UTILITY BOARD ON OREGON PUBLIC UTILITY COMMISSION EXECUTIVE ORDER 20-04 WORK PLANS,” p. 4 (10-28-2020), available at https://www.oregon.gov/puc/utilities/Documents/EO20-04-Comments-CUB.pdf.
California realized the need to reduce natural gas infrastructure and consumption, eliminating in August 2019 their counterpart to the Fuel Switching policy (https://www.greentechmedia.com/articles/read/2020-looks-like-the-breakout-year-for-building-decarbonization-in-californi#gs.ybleag) and providing significant additional funding to incentivize conversion to heat electric heat pumps (https://www.greentechmedia.com/articles/read/california-moves-to-tackle-another-big-emissions-source-fossil-fuel-use-in-buildings).