Sierra Club Comments on DC Green Bank Performance Targets
March 5, 2021
Clean Economy Performance Targets
Regarding both the Clean Economy and Inclusive Prosperity targets, the Sierra Club applauds the DC Green Bank’s broad consideration of inclusivity, equity, capacity-building and access alongside project-specific goals.
We suggest that in both areas, and where appropriate, numeric targets be used for the metrics proposed. For example, we recommend setting specific goals for how many community leaders or stakeholders are to be engaged, and the size of the public that the Green Bank aims to inform about clean-economy concepts. We propose further considering a metric and numeric benchmark specific to District residents, since overall targets are often described using language that references benefits to District residents.
Sustainability Performance Targets
The Sierra Club urges that these performance targets be revised to contain a target of zero financing for projects that include upgraded, renovated or new gas appliances, whether commercial or residential. The targets should also include zero financing for new connections to the existing gas network. These targets should be described as immediate standards for current project selection, rather than as eventual or aspirational goals for future project selection.
We propose editing Target SU-1 to read: “Fund AND ADMINISTER ONLY sustainable projects and programs that support decarbonization in the District, improve public health, and conserve natural resources.” Target measurements should be expanded to include a binary assessment of whether a project can be made carbon-neutral with a zero-carbon electricity source.
The current language treats a focus on carbon neutrality as an aspiration rather than a commitment guiding decisions now. We urge the Green Bank to formalize this commitment into its performance targets. The current language also leaves room for financing technologies that would produce only modest emissions reductions, and because of this, such projects may even conflict with reaching the longer-term goal of citywide carbon neutrality.
In the Introduction to the proposed targets, the Green Bank commits quite rightly to “leading the way for DC to transition to a green city that runs on 100% renewable energy, for a healthier, more resilient, and sustainable community.” The District cannot run on 100 percent renewable energy if it is still reliant on large volumes of methane gas. Delinking the District’s heating and gas-powered appliances, both commercial and residential, from fossil fuels is essential to that goal. Without adopting a no-gas standard for projects that it finances, the Green Bank cannot “align its investment strategy with DC’s climate plans, including the Sustainable DC 2.0 Plan and the goal to be carbon free by 2050.”
Inclusive Prosperity Performance Targets
The Sierra Club recognizes that inclusivity, equity, and access are key to an effective energy transition to a decarbonized clean economy. In this sense, we support efforts to ensure that the Green Bank’s financing mechanisms are available and deployed in all wards, and that gaps in financing are addressed equitably.
Financial Performance Targets
The Sierra Club applauds the Green Bank’s prioritization of its green mission in these targets, and urges further clarification of its targets and metrics around its commitment to helping the District achieve carbon neutrality in 2050, just 29 years away. Specifically, we propose adding an additional metric for Target FI-3 (regarding commercializing green investment) that explicitly measures whether the Green Bank has successfully avoided providing financing for fossil-fuel-based appliances or connections. Such procurements do not fulfill the goal of deploying “green investments;” they lock in fossil fuel dependency and are contrary to DC’s climate commitments.
Conclusion
The Green Bank is among a quiver of tools DC can draw upon to attain our greenhouse gas reduction commitment. The Green Bank’s investment of resources to this commitment should be unequivocal. The Sierra Club urges the DC Green Bank to add specifics to these performance targets to ensure that the Green Bank portfolio supports a range of projects that are compatible with DC’s emissions reduction commitments. We welcome any opportunity to discuss these issues with you in more detail.