Sierra Club Comments on Construction Codes Update

Jill Stern
Chair, Construction Codes Coordinating Board
Department of Consumer and Regulatory Affairs

Dear Ms. Stern,

The Sierra Club thanks you and other members of the Construction Codes Coordinating Board for your work to update DC’s Construction Codes. We were happy to see the second draft update released for public comment on July 26.

The proposed update contains measures to upgrade building energy efficiency and increase use of renewable energy, such as wind and solar, to power buildings. Energy efficiency and renewable energy must be maximized to meet DC’s climate commitment of 50 percent greenhouse gas emissions reductions by 2032 and carbon neutrality by 2050.

In the draft, Section 3, Definitions, Abbreviations, and Acronyms, defines an “on-site renewable energy system” as “photovoltaic, solar thermal, geothermal energy, biogas, wastewater thermal and wind systems used to generate energy and located on the building project.” (page 009437)

Appendix Z, Net-Zero Energy Compliance Path, states: “Acceptable sources of on-site renewable energy to be used on the building site include: Photovoltaic panels; Solar thermal systems; Wind turbines; and Biogas.” (page 009588)

The Sierra Club has concerns about the inclusion of biogas in the Codes.

Net-zero energy means all energy is produced on-site. The Blue Plains Advanced Wastewater Treatment Plant is the only facility in DC capable of producing biogas on-site. Any other biogas used in DC would have to be piped into buildings, which conflicts with the intent of net-zero energy standards.

Biogas is not a realistic option to replace fracked gas for building heating because there is not a sufficient supply of biogas. A 2017 analysis commissioned by the DC Department of Energy and Environment and submitted to the Public Service Commission (pages 45-47) found that even under the most optimistic scenarios claimed by the American Gas Foundation, a group funded by the gas industry, biogas could supply only 32% of the region’s gas consumption. The analysis also found that only 36 landfills and seven farms in the entire country produce biogas that can be transported through pipelines. None are located in DC, Maryland or Virginia.

Biogas can be delivered to buildings in a blend with fracked gas. Because there are insufficient biogas supplies for DC, any reliance on biogas would require an even larger reliance on fracked gas, which is a major contributor to DC’s greenhouse gas emissions.

Counting biogas as a renewable fuel could open a back-door pipeline to continued burning of fracked gas in DC. Such an outcome would directly contradict the energy goals of the Building Codes update and violate DC’s public climate commitments. The Sierra Club therefore respectfully requests that references to biogas as a renewable fuel be removed from the District of Columbia Construction Codes Supplement of 2017.

Sincerely,
           
Mark Rodeffer                
Chair, Sierra Club DC Chapter    

Matthias Paustian
Co-Chair, Beyond Gas Subcommittee, Sierra Club DC Chapter

CC:
Ernest Chrappah, Director, Department of Consumer and Regulatory Affairs
Tommy Wells, Director, Department of Energy and Environment
Mary Cheh, Chair, DC Council Committee on Transportation and Environment