Further Weakening of Building Energy Efficiency Standards Would Hinder Clean Energy Transition

Sierra Club Washington, DC Chapter
Comments on the Second Proposed Rulemaking:
Application of the Building Energy Performance Standards for Privately-Owned and District-Owned Buildings

Attention:
Building Performance and Enforcement Branch
Department of Energy & Environment
Government of the District of Columbia
1200 First Street NE, 5th Floor
Washington, DC 20002
Sent via Electronic Mail to info.BEPS@dc.gov   

Thank you for the opportunity to submit comments on the revised version of the rules for implementing the Building Energy Performance Standards (BEPS). BEPS is a ground-breaking initiative to maximize energy efficiency and reduce greenhouse gas emissions from the buildings sector, which is responsible for about three-quarters of the District’s greenhouse gas emissions.

The Sierra Club DC Chapter is disappointed that DOEE has already extended the length of the first BEPS compliance period and reduced the proposed fines for non-compliance. The Sierra Club DC Chapter strongly opposes any further weakening of the BEPS regulations, slowing down of implementation, or reduction of fines. Penalties need to be high enough to incentivize compliance.

As stated in our comments in March, the Sierra Club DC Chapter strongly supports the BEPS program as an essential element of just and ambitious climate action in the District.
BEPS is one of the policy cornerstones for achieving the District’s commitment to become carbon neutral and climate resilient by 2050.

The latest report by the Intergovernmental Panel on Climate Change (IPCC) underscores the urgency of tackling the climate crisis. The IPCC found that the evidence linking human activity to climate change is unequivocal, and the results are clear to see all around the world, including extreme heat, intense storms, flooding, fire, and drought. The impacts are falling the hardest on those with the fewest resources to cope. Humanity must act swiftly if we are to avoid the most extreme scenarios. While DC has set a number of good climate and clean energy policies in place, we must do more, and do it faster. We can meet the urgent need and also serve as a model and inspiration to municipalities and states across the US that quick governmental action is warranted and possible.

While the climate crisis should compel urgent action, BEPS will also bring near-term benefits to building occupants. Energy efficient buildings are more comfortable for living, learning, and working: warmer in the winter, cooler in the summer, and quieter all year round. Also, improved efficiency of buildings will reduce air pollution, improving air quality and public health in the District. For maximum benefits to the environment and public health, DC’s building stock should be upgraded to eliminate all use of fossil fuels for space and water heating. Fossil fuel combustion in buildings causes harmful indoor air pollution as well as outdoor air pollution.

While the DC Council’s decisions on the budget are outside the scope of this proposed rule, we note our deep disappointment that during the budget process certain funds intended to assist building owners with BEPS implementation were reallocated to other priorities. The Sierra Club DC Chapter will press for this funding to be restored, whether from additional federal funds or other options.

Thank you for the opportunity to comment on the draft BEPS regulations.