Testimony before the House Public Utilities Committee in opposition to House Bill 1473

House Bill 1473 is yet 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. 

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 


Abe Scarr

State Director, Illinois PIRG; Energy and Utilities Program Director, PIRG

Abe Scarr is the director of Illinois PIRG and is the PIRG Energy and Utilities Program Director. He is a lead advocate in the Illinois Capitol and in the media for stronger consumer protections, utility accountability, and good government. In 2017, Abe led a coalition to pass legislation to implement automatic voter registration in Illinois, winning unanimous support in the Illinois General Assembly for the bill. He has co-authored multiple in-depth reports on Illinois utility policy and leads coalition campaigns to reform the Peoples Gas pipe replacement program. As PIRG's Energy and Utilities Program Director, Abe supports PIRG energy and utility campaigns across the country and leads the national Gas Stoves coalition. He also serves as a board member for the Consumer Federation of America. Abe lives in Chicago, where he enjoys biking, cooking and tending his garden.

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