Dear Members of the Construction Codes Coordinating Board,
The Sierra Club is the nation’s oldest and largest environmental advocacy group with approximately 3,000 dues-paying members in the District of Columbia. We write in support of the proposed all-electric commercial building code before the Construction Codes Coordinating Board (CCCB). To ensure that DC’s commitment to carbon neutrality is met, the District must transition off building heat from fracked gas, which is responsible for about a quarter of DC’s greenhouse gas emissions, and onto electricity, which is moving toward 100% renewable sources by 2032.
The easiest and least expensive buildings to electrify are those that have yet to be built. The DC Council and Mayor Bowser have established that DC will end fossil fuel use in new buildings with passage of the Clean Energy DC Building Code Act of 2021 (B24-0420). Passed 13-0 by the Council and signed into law by Mayor Bowser, the Act requires all-electric new buildings and explicitly bans fossil fuel use in new buildings with a provision stating, “On-site fuel combustion shall not be permitted for the provision of thermal energy to the building.” The legislation requires net-zero energy buildings, a stronger standard than the all-electric code the CCCB is now considering. As DC prepares for a net-zero building code by 2026, the current proposal for an all-electric code is a logical interim step.
The Sierra Club applauds the CCCB for considering this proposed building code with a transparent process. CCCB meetings are open to the public, with meeting dates, videoconferencing links, and minutes of previous meetings posted on the CCCB website. The membership of the CCCB represents a diverse set of stakeholders, including representatives from the architectural design profession, the structural engineering profession, the commercial and industrial building industry, and the residential and multi-family building industry.
Despite the CCCB’s transparent process, the Apartment and Office Building Association of Metropolitan Washington (AOBA) is seeking to delay the CCCB’s consideration of the commercial building code “to allow for meaningful participation and dialogue from stakeholders.” Throughout the current code cycle, AOBA representatives have attended meetings of the CCCB and the CCCB’s Technical Advisory Groups, actively participating and engaging in spirited dialogue.
AOBA launched an online petition (image attached) that contains misleading statements calling into question the work of the CCCB. AOBA’s petition states that the commercial building code consists of “proposals that were not introduced or made known to the public only two weeks ago.” It is not clear what date AOBA refers to with the phrase “two weeks ago.” What is clear is that all-electric building codes have been discussed by the CCCB and its Technical Advisory Groups for much of the year. The proposed commercial building code was introduced at the regularly-scheduled July CCCB meeting and scheduled for consideration at the regularly-scheduled August meeting. After months of meaningful participation and dialogue from AOBA and other stakeholders, the CCCB should not delay consideration of the commercial code.
The Sierra Club asks that the CCCB follow the lead of Mayor Bowser and the DC Council. We urge the CCCB to move forward with an all-electric commercial building code this month to move DC closer to fulfilling our carbon neutrality commitment.
Thank you for your service. We appreciate the extraordinary time and effort that goes into updating the District’s building codes.
Sincerely,
Matthias Paustian and Mark Rodeffer
Sierra Club DC Chapter Beyond Gas Co-Chairs
CC:
Tommy Wells, Director, DC Department of Energy and Environment
Ernest Chrappah, Director, Department of Consumer and Regulatory Affairs
Mary Cheh, Chair, DC Council Committee on Transportation and Environment
Attachment: Image of AOBA online petition
Accessed on August 13, 2022 at https://p2a.co/Wr5vYqz