A few cities have gone to the extreme of banning natural gas, mostly in new construction. This heavy-handed approach eliminates consumer choice, stifles innovation, and diminishes the flexibility to respond to GHG emissions goals, with the least-cost solutions for consumers. Appliances will have to be replaced, and there is no doubt, electric infrastructure will need to be upgraded. In addition, consumers will be impacted with higher energy bills. All of this with no evidence the environmental impacts are substantial enough to warrant forced fuel switching. APGA hopes any policy development will be considerate of environmental benefits balanced with consumer affordability, and APGA and its members stand ready to work on this type of solution.

Particularly, Congress should replace section 433 of the Energy Independence and Security Act of 2007 (EISA) with fuel-neutral provisions that achieve real energy efficiency gains in federal buildings. In 2007, the Energy Independence and Security Act of 2007 (EISA) was passed. Section 433 of that legislation would eliminate all fossil fuel-generated energy from federal buildings by the year 2030. This ban would apply to all new or renovated federal buildings and would not allow for the direct use of natural gas, combined heat and power (CHP), or distributed generation, eliminating all fossil fuel-generated electricity regardless of emissions. Specifically:

• The ban restricts adoption of high-efficiency technologies such as CHP. This technology is currently being installed to power the capitol complex. The Department of Energy (DOE) has acknowledged the challenge of simultaneously using energy efficient CHP and waste heat recovery technology while complying with the mandated reduction in fossil fuel-generated energy.
• The ban ultimately works against energy efficiency in federal buildings. Under the legislation, a very inefficient federal building may be built or renovated in an inefficient manner as long as it draws its energy from non-fossil fuel sources.
• The threshold amount for renovations is very low and would mean almost all renovations to federal buildings would trigger mandatory compliance, resulting in many agencies not undertaking retrofits at all.
• If the infrastructure for the direct use of natural gas is not maintained, then, the low-carbon fuels of the future, like renewable natural gas or hydrogen, will not be options.

The impact to the consumer for electrification policies is staggering. With the removal of natural gas as a fuel option, New Jersey’s “State Energy Master Plan (EMP)” would eliminate more than $11.5 billion saved by households in energy expenses, and nearly $9.7 billion saved by businesses, all without establishing whether this is the least cost and most effective pathway to reduce emissions². A survey of California families shows it will cost $7,300 to retrofit a home with electric appliances and $387/year more in energy bills, yet the state’s laws lead to that result³. Further, a national study shows families would have to spend, on average $4,847, to replace four common household appliances: range, dryer, water heater, and furnace⁴. APGA encourages consideration of these dramatic costs when evaluating policies. Energy efficiency gains should not come at undue consumer expense.

^[2] Consumer Energy Alliance, “A Steady Stream of Natural Gas Provides Affordable Energy to New Jersey Residents and Helps the Garden State Grow,” https://consumerenergyalliance.org/cms/wp-content/uploads/2019/06/061219_NJ-Energy-Savings-Report_FINAL.pdf.

^[3] Navigant Consulting, “Impacts of Residential Appliance Electrification,” https://c4bes.org/wp-content/uploads/2018/09/Navigant-Report-Impacts-of-Residential-Appliance-Electrification.pdf.

^[4] Consumer Energy Alliance, “Green New Deal Would Cost American Consumers Almost $244 Billion in Just Four Appliances,” https://consumerenergyalliance.org/2019/02/green-new-deal-would-cost-american-consumers-244-billion-four-appliances/.

Natural gas distribution emissions dropped 73 percent since 1990, while utility companies added more than 760,000 miles of pipeline to get energy to an additional 20 million customers⁵. This is a testament to APGA members’ tireless work to safely provide clean-burning natural gas to state-of-the-art appliances, lowering emissions regionally and nationally. Every sector must do their part to reduce GHG emissions. Natural gas utilities and their customers are leading the way. With the right legislation, regulatory framework, and support from the federal government, these endeavors will continue.

⁵ AGA, “Understanding Updates to the EPA Inventory of Greenhouse Gas Emissions from Natural Gas Systems.” https://www.aga.org/contentassets/f4227be971f545bf8a869234d7220526/ea-2019-02-updating-the-facts-of-ghg-inventory-003.pdf.

The direct use of natural gas promotes and supports a more robust and resilient energy system. A recent report asserts that, “The operational characteristics of the natural gas transportation network, in combination with the physical properties of natural gas, effectively minimize the likelihood and severity of service disruptions. In the rare event of a disruption, impacts are typically localized and brief. History demonstrates that disruption of firm pipeline transportation and/or storage services resulting from severe weather events are extremely rare.”⁶ This resilience stands contrary to other energy sources used for appliances and equipment in homes and businesses. As an example, above-ground infrastructure makes electric utilities susceptible to natural events, such as wind storms. In California, damaged power lines have caused wildfires, resulting in major utility companies shutting down electricity as a precaution to the threats from nature. Rather than putting “all eggs in one basket” through electrification, there should be a balanced energy approach to achieve comprehensive reliability.

⁶ Natural Gas Council, “Natural Gas: Reliable and Resilient,” http://naturalgascouncil.org/wp-content/uploads/2019/04/Natural-Gas-Reliable-and-Resilient.pdf.

Allowing consumers to have a fuel choice for their appliances shouldn’t be overlooked in policymaking. Data shows that Americans prefer natural gas for cooking and space and water heating. Less than 10% of California residents would choose an all-electric home, and 80% oppose prohibiting the use of gas appliances.⁷ Another study indicates that the preferred energy source is natural gas for home heating, water heating, and cooking.⁸ As the Committee contemplates legislative options to reduce GHG emissions, APGA encourages the Committee not to pick a single solution but instead allow for maximum flexibility in meeting environmental goals with low costs.

⁷ California Building Industries Association, “California Natural Gas Poll - Consumer Survey of 3000 California Voters.”

⁸Woodland, O’Brien, and Scott, “New Homeowner Energy Preference Survey Closings March 2015 through February 2016.”

APGA does not support “winners and losers,” so when it comes to vehicle fuels, parity should be paramount. However, if the government is going to recognize the environmental benefits of certain fuels, natural gas should qualify. NGVs are some of the cleanest vehicles on the road, with the newest engines emitting zero or near-zero NOx emissions, which means significantly reduced GHG emissions when compared to gasoline or diesel engines. By only allowing electric vehicles to receive certain tax credits, government is taking a heavy-handed approach eliminating choice, stifling innovation, and diminishing the flexibility to respond to GHG emissions goals, often with the least-cost solution. As well, is the infrastructure, such as charging stations, available to support this push for a specific vehicle fuel? APGA hopes any policy development will be considerate of environmental benefits balanced with affordability, and APGA and its members stand ready to work on this type of solution.

State governments have demonstrated a long-standing commitment to reducing our dependence on foreign energy sources and pollution emitted by light and heavy-duty vehicles. The health and national security benefits of reducing both are clear, as sending money abroad to potentially hostile regimes harms our security and reducing emission of criteria pollutants and greenhouse gases improves public health and helps to protect the environment.

States have historically offered and continue to offer various incentives for NGVs and fueling infrastructure because of the critical benefits they confer.