This document presents the testimony of Bradley Cebulko on behalf of multiple environmental and community organizations in Oregon Public Utility Commission Docket UG-490. The testimony addresses concerns about Northwest Natural Gas’s proposed Line Extension Allowances (LEAs), arguing that continued subsidies for gas system expansion are costly and undermine Oregon’s decarbonization goals. It also critiques the company’s planning assumptions, highlighting the financial and regulatory risks of over-reliance on gas infrastructure. The testimony provides recommendations for eliminating LEAs and aligning utility policies with state climate mandates.