The Institute for Policy Integrity submitted comments on the Illinois Commerce Commission's (ICC) draft Phase 1 Report from its Future of Gas Workshops, providing recommendations for the ICC to consider as it plans for Phase 2 of the workshops. Our comments aimed to ensure Phase 2 of the workshops thoroughly examines pathways for decarbonizing Illinois' gas system while considering economic, environmental, and equity impacts. Key points include:
- Phase 2 should afford ICC the opportunity to learn from regulators who are early movers on gas sector decarbonization, including from difficulties those regulators encountered and how they are addressing them.
- When assessing building stock for electrification potential, Phase 2 should consider ownership and leasehold structures, as these can create split incentives that hinder adoption of low-carbon technologies.
- Comparative analyses of natural gas and alternatives should:
- Include both fuel and non-fuel alternatives like electrification and efficiency
- Include lifecycle emissions analyses over different time horizons and scenarios
- Consider affordability impacts on total household energy burden
- Examine institutional barriers to adoption in addition to technological readiness
- When exploring benefit-cost analysis frameworks, Phase 2 should:
- Ensure frameworks are technology- and fuel-neutral and will be deployed in a manner that does not put a thumb on the scale in favor of the incumbent natural gas technology
- Consider monetizing health impacts, including those associated with non-greenhouse-gas pollutants using metrics like Value of Statistical Life
- Examine using distributional analyses to identify impacts on vulnerable populations
- For alternative low-carbon technologies, Phase 2 should:
- Not assume they are truly low-carbon without analysis
- Consider lifecycle emissions and usefulness for decarbonization over time
- For renewable natural gas, examine supply limitations and potential perverse incentives
- Phase 2 should broadly consider resource diversity, not just fuel diversity, for reliability and resilience.
- When examining gas investment drivers, Phase 2 should consider alternatives to conventional infrastructure investments that could meet the same needs.
Policy Integrity also submitted two other short comments in this proceeding in response to Workshops 6 and 7.