Sierra Club Comments
on
The Capital Improvement Petition Reform Amendment Act (B23-879)
to the
DC Council Committee on Housing and Neighborhood Revitalization
October 8, 2020
The Sierra Club is committed to a clean energy transition that preserves housing affordability for everyone and protects low-income residents. The Sierra Club supports ensuring that affordable housing and low-income families are not further strained by upfront costs of weatherization and electrification investments. That is why we are appreciative of the hard work of the Sustainable Energy Utility and stakeholders to develop and learn from a pilot program for providing comprehensive building decarbonization retrofits at no cost to consumers or building owners. We encourage the Council to explore expanding such a program exponentially throughout the District.
The Sierra Club's preliminary reading of this bill raises concerns that require further discussion and analysis before proceeding. We encourage the Council to direct the Mayor to convene an interagency and stakeholder task force to develop recommendations for a program to provide deep retrofits for affordable housing and low-income families at no cost to residents and building owners.
One provision in the bill would make it substantially more difficult to recover costs associated with energy efficiency upgrades that are required by a section of the Clean Energy DC Omnibus Amendment Act of 2018:
DC Official Code §42-3502.10(h)(“A housing provider may impose a rent surcharge to recover the cost of a capital improvement that is required by a federal or District statute or regulation and that takes effect after October 30, 1980, not including any building energy performance standards established by, or pursuant to, section 301 of the CleanEnergy DC Omnibus Amendment Act of 2018.”)
While such a policy may make sense, without corresponding financial support for building owners there is no clear financial pathway to achieve the goals of the Clean Energy DC Omnibus Amendment Act of 2018. Compliance with energy efficiency provisions regarding existing buildings in the Omnibus Act is a key element in achieving the District's climate commitments. The District must implement the Building Energy Performance Standard (BEPS) program created by the Omnibus Act in a way that ensures that energy savings and greenhouse gas reductions are realized in practice. Though energy efficiency pays for itself over time with reduced energy bills, financing of the upfront costs is an important part of that implementation and we are concerned that this bill has unintended consequences that could severely restrict BEPS implementation if not coupled with other policies.
The Sierra Club stands ready to work with the Council, DC government agencies, and stakeholders to ensure that DC meets its climate commitments while ensuring the costs of initial investments in energy efficiency do not fall to low income residents.