SOCAN Testimony in opposition to the Avista rate hike request

Alan R.P. Journet Ph.D.
Cofacilitator
Southern Oregon Climate Action Now
February 6th 2025

Testimony in opposition to the Avista rate hike request and supporting the CUB proposal

Chair Decker and Members of the Oregon Public Utilities Commission:

I write as cofacilitator of Southern Oregon Climate Action Now, an organization of some 2,000 Southern Oregonians who are concerned about the climate crisis and encourage state action to address it. As rural and coastal Southern Oregonians, we live on the frontlines of the warming, reducing snowpack, heatwaves, drought, rising sea level and the increasing wildfire risk that these trends conspire to impose on us. Because of this, we pay close attention to what is happening in the state that relates to climate.

The gas utilities have a long track record of promoting campaigns of misinformation and disinformation, in particular regarding the claim that their product “is cleaner ….than oil and coal” (igs, undated). While, to give igs some credit, I acknowledge that the article continues by explaining correctly that burning natural gas compared to burning other fossil fuels releases less carbon dioxide than other fossil fuels. However, the same article claims: “One of the reasons for this is that natural gas generates fewer harmful emissions.” This claim completely evades two huge problems with natural gas (1) the gas is toxic when used in enclosed spaces because it leaks and causes serious health problems (e.g., Gottlieb & Dyrszka 2017, Seals & Krasner 2020, O’Rourke et al. 2022), and (2) the gas leaks from extraction, through processing and transmission and distribution to the customer, and circulation through buildings. The leaked gas, known as fugitive emissions, is some 90% methane. Regrettably, methane has a global warming potential some 80 times greater than carbon dioxide on a 20-year basis (Mar et al. 2022). Given its powerful warming potential, it can readily be appreciated, I suspect, that not much leakage over the lifecycle of the gas prior to its combustion is required before this leakage completely negates the combustion benefits of the gas. Indeed, Howarth (2024), in a discussion of emissions from Liquified Natural Gas, concludes that “Even using GWP 100, the greenhouse gas footprint of LNG is always as large as or larger than that of coal.” Robert Howarth has been undertaking studies on the leakage of methane through the life cycle of natural gas usage for many years. Meanwhile, a similar conclusion was offered by Gordon et al. 2023. That gas utilities promote the canard that their product is ‘the clean fossil fuel’ without acknowledging this leakage constitutes, at best, misinformation.

It’s worth also reflecting on Avista’s Integrated Resource Plan. Avista’s resource strategy for Oregon, taken from this 2023 Integrated Resource Plan, is presented in Figure 1 where the emphasis on so-called Renewable Natural Gas (RNG) and Synthetic Methane is evident. There is abundant evidence that accurate full lifecycle assessment of RNG indicates that it is not superior to fracked natural gas (e.g., Feinstein and de Place 2021). This alone suggests that Avista has an IRP that merely pretends to reduce greenhouse gas emissions. Meanwhile, even if we accept the premise that RNG constitutes an improvement over fracked gas, a study of the potential for RNG incorporation in the state’s natural gas supply by the Oregon Department of Energy (ODOE 2018) concluded: “The gross potential for RNG production when using anaerobic digestion technology is around 10 billion cubic feet of methane per year, which is about 4.6 percent of Oregon’s total yearly use of natural gas.”

As Figure 1 illustrates, Avista anticipates RNG comprising much more than 4.6% of its total supply. Even employing [energy and fossil fuel intensive] thermal gasification technology, the ODOE (2018) study concluded the maximum would be 17.5% of Oregon’s demand. One wonders if Avista imagines the state will counter this shortfall with a massive increase in landfill and agricultural animal feedlot operations that both produce methane. Although Avista rejected the PUC concern about the quantity of RNG available to meet the desired capacity, it should be noted that relying on national supplies of RNG in Oregon would require transmitting the gas from the distant corners of the nation. The result would inevitably be substantial leakage of methane from the pipelines through which this gas is pumped, an outcome substantially negating any RNG benefits. However, Cyrs and Feldman (2020) assessed RNG supplies in the nation and concluded they could only fulfill between 4 and 7% of the nation’s fossil gas consumption. Assuming gas utilities across the nation seek to lower their greenhouse gas emissions by utilizing RNG, the supplies available nationally couldn’t possibly augment the needs of Avista. While we certainly seek to reduce emissions locally and statewide, this should not be achieved by importing gas from out-of-state and thereby simply exporting emissions to transmission lines across the country. As Saadat et al. (2020) point out, buildings account for some 40% of greenhouse gas emissions nationally, much of this attributable to the methane in natural gas. Reporting on changes to California RNG rules Squarespace (undated) concludes, “These changes encourage RNG use for hard-to-electrify sectors, …”Indeed, this is where products such as RNG and Hydrogen should be focused, not in gas pipelines to residential and commercial customers.

Avista (Figure 1 again) also clearly relies heavily on a future with synthetic methane. It may be possible commercially to produce synthetic gas from hydrogen derived from the energy intensive electrolysis of water using renewable energy and then combine this with Carbon dioxide captured using the economically questionable process of carbon capture from industrial processes. However, NRDC (2020) indicated that synthetic gas “…is still projected to be very expensive in 2040 and 2050.” Relying on carbon capture to provide the carbon dioxide also seem optimistic. While reporting on the rules proposed by EPA that challenge industry to fulfill its promise to establish carbon capture technology to reduce emissions, Hennessy (2023) concludes “CCS doesn’t have a strong track record of actually sequestering carbon — especially for the power sector, where 90 percent of proposed carbon capture capacity has failed or never gotten off the ground.” Synthetic methane seems unlikely to provide Avista with an economically feasible option. As has repeatedly occurred with this utility, we should once again be skeptical about claims from Avista that involve emissions reductions relying on synthetic methane and the questionable CCS technology.

Additionally, abundant problems exist with the concept of incorporating Green Hydrogen into the gas mix (e.g., St. John 2022; MITClimate 2023). The latter source, quoting Raju et al. (2022) pointed out: “In a study released last summer, the California Public Utility Commission found that up to 5 percent hydrogen blended with natural gas appears safe, but higher percentages could lead to embrittlement or a greater chance of pipeline leaks.” Erdener et al. (2023) concur, pointing out that “existing gas-fired power plants or industrial processes, may not be designed to tolerate hydrogen blending beyond a given limit; for many existing gas-fired power plants, this limit is 5% volume.” In short, Hydrogen whether green, blue, gray, brown or pink, cannot contribute much to solving Avista’s greenhouse gas problem.

As has repeatedly occurred with this utility, we should once again be skeptical about claims from Avista that involve emissions reductions relying on RNG, synthetic methane and the questionable CCS technology. As demonstrated in its 2023 IRP, Avista seems to have lost sight of the fact that it is an energy company not merely a gas company. Avista’s best future seems to be in transitioning out of the gas arena and into renewable energy. Avista also seems to have abdicated the claim that it has often made that it accepts climate science and is willing to become part of the solution rather than continue as part of the problem. Avista’s track record encourages confidence in neither its IRP nor its commitment to reducing emissions rather than expanding its gas network.

In relation to the argument that all-electric construction is more expensive to build and maintain than the electric/gas alternative Tan et al. 2022, in an RMI report, concluded: “Our analysis shows that all-electric, single-family new construction is more economical to build and operate than a home with gas appliances and has lower lifetime emissions in all nine cities studied.” Meanwhile, an IRENA (2024) report concludes “The new renewable capacity added since 2000 is estimated to have reduced electricity sector fuel costs in 2023 by at least USD 409 billion, showcasing the benefits renewable power can provide in terms of energy security.”

Avista has a very obvious commitment to maintaining its business model of promoting continued increasing gas consumption rather than addressing the climate crisis for which it is partially responsible by reducing its greenhouse gas emissions with meaningful plans.

And now, to add to its efforts to continue marketing a product that is both unhealthy and exacerbates the climate crisis, Avista seeks an almost 7% rate hike from its customers (Avista 2024). This is justified on the grounds that it is “designed to increase overall natural gas base revenue by approximately $7.8 million, or 6.6%…” It is also justified by a need “to replace infrastructure and meet increasing compliance obligations…”

Regrettably, there seems to be no serious effort on the part of Avista either here or in its rejected Integrated Resource Plan, to address its responsibility to reduce the company’s contribution to global greenhouse gas emissions. We recommend, therefore, that Avista consider seriously the proposal from the Citizens’ Utility Board to substitute the immense investment required to replace its distribution pipes with a program to encourage and incentivize its users to electrify. By doing this, Avista could substantially reduce emissions resulting from its operations and simultaneously encourage its current customers to live more healthy and less polluting lives.

Respectfully Submitted

Alan Journet Ph.D.

7113 Griffin Lane
Jacksonville
OR 97530-4182
alan@socan.eco
541-500-2331
541-301-4107

Sources Cited
Avista 2023 Natural Gas Integrated Resource Plan. Avista https://edocs.puc.state.or.us/efdocs/HAA/lc81haa114738.pdf

Avista 2024 Oregon – Rate Requests, Avista https://www.myavista.com/about-us/our-rates-and-tariffs/oregon-rate-requests

Cyrs T and Feldmann J. 2020. 7 Things to Know About Renewable Natural Gas. World Resources Institute. https://www.wri.org/insights/7-things-know-about-renewable-natural-gas.

Erdener B, Sergi B, Guerra O, Chueca A, Pambour K, Brancucci C, Hodge B. 2023 A review of technical and regulatory limits for hydrogen blending in natural gas pipelines. International Journal of Hydrogen Energy 48 (14) 5595 – 5617. https://www.sciencedirect.com/science/article/abs/pii/S0360319922050923#:~:text=End%2Duse%20applications%2C%20such%20as,5%25%20volume%20%5B14%5D.

Feinstein L and De Place E. 2021 THE FOUR FATAL FLAWS OF RENEWABLE NATURAL GAS: Gas utilities are telling tall tales about RNG. Sightline https://www.sightline.org/2021/03/09/the-four-fatal-flaws-of-renewable-natural-gas/

Gordon D, Reuland F, Jacob D, Worden J, Shindelll D, Dyson M. 2023 Evaluating net life-cycle greenhouse gas emissions intensities from gas and coal at varying methane leakage rates. Environmental Research Letters 18 084008 https://iopscience.iop.org/article/10.1088/1748-9326/ace3db

Gottlieb B, Dyrszka L. 2017 Too Dirty, Too Dangerous: Why Health Professionals Reject Natural Gas. Physicians for Social Responsibility https://psr.org/resources/too-dirty-too-dangerous/

Hennessy P. 2023 Is carbon capture viable? In a new rule, the EPA is asking power plants to prove it. Grist https://grist.org/energy/is-carbon-capture-viable-in-a-new-rule-the-epa-is-asking-power-plants-to-prove-it/

igs undated What Makes Natural Gas the Cleanest Fossil Fuel? Interstate Gas Supply, Inc (IGS) https://www.igs.com/energy-resource-center/energy-101/what-makes-natural-gas-the-cleanest-fossil-fuel.

Mar K, Ungar C, Walderdorff L, Butler T. 2022 Beyond CO2 equivalence: The impacts of methane on climate, ecosystems, and health. Environmental Science & Policy. 134: 127-136. https://www.sciencedirect.com/science/article/pii/S1462901122001204.

MITClimate 2023 Can we use the pipelines and power plants we have now to transport and burn hydrogen, or do we need new infrastructure? Ask MIT Climate. https://climate.mit.edu/ask-mit/can-we-use-pipelines-and-power-plants-we-have-now-transport-and-burn-hydrogen-or-do-we-need#:~:text=In%20a%20study%20released%20last,greater%20chance%20of%20pipeline%20leaks.

NRDC 2020 Report: “Renewable” Gas – A Pipe Dream or Climate Solution? Natural Resources Defense Council https://www.nrdc.org/bio/merrian-borgeson/report-renewable-gas-pipe-dream-or-climate-solution.

ODOE 2018 Biogas and Renewable Natural Gas Inventory SB 334 (2017). Oregon Department of Energy. https://www.oregon.gov/energy/Data-and-Reports/Documents/2018-RNG-Inventory-Report.pdf

O’Rourke D, Caleb N, Muller K, Pernick A, Plaut M, Plummer D, Serres D, Stewart B, Studer-Spevack N, Rsongas T, Turner A. 2022 METHANE GAS: HEALTH, SAFETY, ECONOMIC, AND CLIMATE IMPACTS: A case for equitable electrification. Families for Climate. https://www.familiesforclimate.org/blog/methane-gas-health-safety-economic-and-climate-impacts.

Saadat S, Vespa M, Kresowik M. 2020 Rhetoric vs Reality: The myth of “Renewable Natural Gas” for Building Decarbonization. Earthjustice and Sierra Club. https://earthjustice.org/wp-content/uploads/report_building-decarbonization-2020.pdf

Seals B and Krasner A. 2020 Health Effects from Gas Stove Pollution. Physicians for Social Responsibility. https://psr.org/wp-content/uploads/2020/05/health-effects-from-gas-stove-pollution.pdf.

Squarespace undated. RNG Market Today: A Primer. The Coalition for Renewable Natural Gas. https://static1.squarespace.com/static/53a09c47e4b050b5ad5bf4f5/t/6759c68149f2b8344218466e/1733936777572/RNG+Market+Today-+A+Primer.pdf

St. John J. 2022 Experts say blending hydrogen into gas pipelines won’t work. Canary Media. https://www.canarymedia.com/articles/hydrogen/experts-say-blending-hydrogen-into-gas-pipelines-wont-work

Tan L, Fathollahzadeh M, Tylor E. 2022 The Economics of Electrifying Buildings: Residential New Construction RMI https://rmi.org/insight/the-economics-of-electrifying-buildings-residential-new-construction/