Date: June 22, 2021
To: Washington Metropolitan Area Transit Authority (Metro) Board
CC: Washington, DC, Council; Signatories on Open Letter to Metro
From: Metro Electric Bus Coalition
Re: Analysis of Metro staff Metrobus Fleet Plan
On Thursday, June 24, Metro Executive Vice President for Capital Planning Tom Webster will present to the entire Metro Board the Metro staff’s proposed plan for transitioning the Metrobus fleet to electric buses, which the Metro Board Executive Committee approved on June 10.
An analysis of the Metrobus Fleet Plan by the Metro Electric Bus Coalition (member organizations are listed at the end of this memo) found significant inaccuracies and misrepresentations (detailed below), indicating that the staff is not providing the Metro Board the information it needs to make an informed decision about the future of the Metrobus fleet.
The coalition is calling on the Metro Board to direct the staff to adopt a more ambitious timetable to transition the Metrobus fleet to electric buses to put Metro on par with major city bus authorities across the country and smaller bus agencies in the Washington, DC, region.
Although the Metro staff proposal would just meet the Clean Energy DC Act’s deadline of 2045 for 100-percent, zero-emission vehicles, it would fail to meet the law’s goal of 50-percent, low- and zero-emission vehicles by 2030. Indeed, under the staff proposal, only 275 of Metro’s 1,540 buses—18 percent—would be electric by 2030 (slide 25 of the Metro staff’s PowerPoint presentation).
More than 50 federal, state and local elected officials—including members of Congress and the DC Council—have called on Metro to electrify 100 percent of its bus fleet no later than 2045 and 50 percent of its fleet by 2030.
Staff Electric Bus Procurement Schedule Lags Behind Other Transit Agency Plans
Metro signed a contract in 2018 with New Flyer for as many as 542 buses—392 diesel and 150 compressed natural gas (CNG)—to be delivered by 2023. Metro currently owns only one battery-electric bus and plans to procure a dozen more from several manufacturers for a pilot project scheduled to conclude toward the end of 2023. (Note that in 2019, Metro originally planned to conclude the pilot project by the end of December 2022. Now the 12 pilot project buses will not even be delivered until late next year.) Metro will begin its next five-year procurement cycle in fiscal year (FY) 2022, with deliveries anticipated to begin in FY 2024.
The Metro staff bus electrification proposal recommends that the agency:
1) Purchase a combination of fossil-fuel buses and electric buses during the next five-year procurement cycle, which runs from 2024 through 2028. Over that time, the staff proposes that only 25 of the 100 buses Metro buys annually to replace its oldest buses be electric, so by 2028, only 125 of Metro’s fleet of 1,540 buses—8 percent—would be electric. The rest would be a combination of diesel, diesel-electric hybrids and CNG.
By contrast, the Los Angeles County Metropolitan Transportation Authority plans to transition 100 percent of its 2,320 buses to electric by 2030 and the Biden administration’s goal in its American Jobs Plan is to electrify 50,000 transit buses by then, which would cover approximately 80 percent of the public transit buses in the United States.
2) Begin buying only zero-emission buses by 2030. By contrast, the Maryland Transit Administration will begin buying only electric buses for its 760-bus fleet beginning in 2023. If Metro waits until 2030 to purchase only electric buses, it will not have a 50-percent zero-emissions fleet until 2035, the same year San Francisco plans have its 1,100 municipal buses all-electric. Other large California transit agency bus purchases will be at least 25 percent electric from 2023 to 2025, 50 percent from 2026 to 2028, and 100 percent after 2029.
3) Reach a 100-percent, zero-emission bus fleet by 2045. Although this timetable would meet the very last year of the DC energy law deadline, there is no reason why Metro cannot transition to a zero-emission fleet more quickly. Bus fleets in Chicago, Seattle and New York City—which has 5,800 buses—are aiming to be all-electric by 2040. Closer to home, the DC Circulator and Alexandria’s DASH system plan to have an all-electric fleet by 2029 and 2035, respectively.
Metro Staff Understates the Number of Battery-Electric Buses Nationwide
The Metro staff states that there are 500 battery-electric buses in service today with an additional 500 on order (slide 19 of its PowerPoint presentation). Those numbers are out of date. According to Calstart, at the end of 2020, there were 2,700 battery-electric buses on U.S. roads or on order.
Metro Staff Fails to Consider Bus Lifecycle Costs
Battery-electric buses are significantly cheaper to operate and maintain than fossil fuel buses over their lifetime. An October 2020 Sierra Club analysis included 2017 calculations by the Argonne National Laboratory of the total lifetime cost of owning buses by fuel type. Argonne found that the lifetime cost of a battery-electric bus would be $1,124,899, diesel: $1,365,925, CNG: $1,271,426, and hybrid diesel-electric: $1,538,679. Hybrids currently comprise 55 percent of the Metro fleet.
Metro Staff Overstates the Cost of Electric Bus Infrastructure
The Metro staff contends that it will cost about $400,000 per bus for charging infrastructure (PowerPoint, slide 29), which approximates the price of a fast charger. A fast charger, which costs about $495,000 according to the National Renewable Energy Laboratory, can serve a number of buses over the course of a day, not just one. A depot charger, typically used for overnight charging, costs $50,000, according to NREL. While transit agencies can use a depot charger for one bus, platooning techniques would enable them to charge more than one.
Metro Staff Endorses New CNG Fueling Station Based on Questionable Availability of “Renewable” Methane
The Metro staff plan calls for a new $5.3 million CNG fueling facility at its Shepherd Parkway Garage in Southwest DC and increasing the percentage of CNG buses to about 50 percent of its fleet. If Metro ultimately commits to electrifying its fleet as quickly as other bus authorities, however, it makes no sense to spend millions of dollars on what would become a stranded asset.
The apparent reason the Metro staff’s plans to expand its CNG bus fleet is to enable the agency to claim it will meet the Clean Energy DC. Act’s goal of reducing carbon emissions by 50 percent by 2032. It purports to accomplish that by purchasing negative emissions credits from “renewable” natural gas (RNG), or biomethane, which comes from animal waste, landfills, and wastewater treatment facilities. The staff proposal relies on CNG and RNG for 80 percent of Metro’s carbon emission reductions through 2030, with 93 percent of the cuts coming from RNG.
Relying on RNG is problematic for two major reasons:
First, there’s a limited supply: According to a 2019 American Gas Foundation (AGF) study, even after ramping up production, RNG could only replace between 6 to 13 percent of total natural gas demand. It would never be able to replace the methane currently used in homes, buildings and power plants, much less expand the amount of CNG used as transportation fuel, and Metro would be competing with others for relatively small quantities.
California, for example, has the largest potential of any state to generate biomethane from waste in the country. However, according to a 2017 Union of Concerned Scientists analysis, “if biomethane were captured from all potential sources of organic waste in California, the resulting supply would meet approximately 3 percent of the state’s [annual] demand for natural gas.”
Second, it’s expensive: According to the AGF report, RNG would be at least two to five times more expensive than fracked gas.
The Metro staff proposal offers no details about its plans for RNG. It notes that the agency has no contract for RNG. It does not provide an estimate of the quantity that would be required based on Metro’s evolving bus fleet composition. It does not cite a price for the RNG, which will cost more than CNG. It does not provide a start date for RNG delivery, and the longer the delay, the less time Metro will have to claim offsets. And it does not mention the source of the RNG. In any case, different RNG sources have different offsets because not all RNG offers the same climate benefit.
As the 2017 Union of Concerned Scientists analysis of biomethane concluded: “Increasing consumption of natural gas in the transportation sector is not a solution for significantly reducing climate emissions.”
Metro Board Member Falsely Suggests that Electric Buses Are Not Cleaner
Finally, Metro Board Member Matt Letourneau’s comments during the November 11, 2020, Metro Board meeting and again at the Executive Committee meeting on June 10 indicate that he is not aware that battery-electric buses are significantly cleaner than diesel, diesel-electric hybrids and CNG buses. Letourneau, who represents Northern Virginia, questioned the need to transition to electric buses and would prefer that Metro increase the percentage of CNG buses in its fleet and install new CNG fueling infrastructure.
“It doesn’t make a lot of sense to convert to electric buses that will be running on electricity coming from natural gas,” he said last November, “and then not necessarily invest in CNG buses and then act like we’ve really done something, because we haven’t.” In fact, electric buses are better for the climate than diesel, diesel-electric hybrid and CNG buses across the country, regardless of the electricity source.
According to a 2018 Union of Concerned Scientists analysis based on 2016 Environmental Protection Agency power plant emissions data, battery-electric buses have 70 percent lower lifecycle carbon emissions than diesel buses, 65 percent lower than CNG buses, and 60 percent lower than diesel-electric hybrids in the Washington metro area. The electric grid in the region has gotten cleaner in the last five years, so lifecycle electric bus carbon emissions now would likely be around 5 percent lower.
How Should the Metro Board Respond to the Metro Staff’s Proposal?
The Metro Board should direct Metro staff to revise its proposal. If accepted in its current form, it would condemn the DC region to decades of bus tailpipe carbon and toxic pollution. Other transit agencies across the country and in our region are facing the same challenges as Metro to replace their fossil fuel fleets with zero-emission buses. But unlike Metro, they are addressing these challenges head on and have ambitious plans to transition as quickly as possible. There is no reason why Metro cannot do the same.
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The Metro Electric Bus Coalition includes: Audubon Naturalist Society, Breathe DC, Center for Clean Air Policy, Chesapeake Climate Action Network, Chispa Maryland, Citizens’ Climate Lobby, DC Climate Coalition, DC Environmental Network, Earthjustice, Electric Vehicle Association of Metropolitan Washington, DC, Environment America, Environmental Working Group, Faith Alliance for Climate Solutions, Friends of the Earth, Generation180, Green Latinos, Greenpeace USA, Interfaith Power & Light, Labor Network for Sustainability, Moms Clean Air Force, Northern Bus Barn Neighbors, Northern Bus Garage Community Environment Committee, Public Citizen, Sierra Club, 350 Loudoun and Union of Concerned Scientists.