February 15, 2023
Via Electronic Mail
D.C. Construction Codes Coordinating Board
Department of Buildings
1100 4th St. SW
Washington, D.C. 20024
Re: Upcoming CCCB Vote on All-Electric Commercial Construction Code
Dear Acting Chair Fetterman:
Sierra Club urges the D.C. Construction Codes Coordinating Board (“CCCB” or “the Board”) to vote in favor of an all-electric construction code at its February 16, 2023 meeting. Approving this measure is integral to complying with D.C.’s binding climate law and protecting public health in the District, and there is ample evidence that D.C.’s electric grid has more than enough capacity to support this measure.
D.C.’s administrative agencies and committees are responsible for implementing D.C. law, including the District’s legal commitments to reduce greenhouse gas emissions. The Clean Energy D.C. Building Code Amendment Act requires net-zero emissions from new or substantially improved buildings by 2026.[1] And with the Climate Commitment Amendment Act requiring a 45% reduction in greenhouse gas emissions city-wide by 2025,[2] an all-electric code is a logical interim step before the next code cycle has to meet the more stringent net-zero requirement. This code will also help enable D.C. to comply with the Climate Commitment Amendment Act’s future requirements of a 60% reduction in emissions by 2030 and carbon neutrality by 2045.[3] In order to comply with these ambitious emission reduction requirements, the D.C. government should take immediate action to reduce greenhouse gas emissions from the building sector, which causes the vast majority—roughly 72%—of the city’s total greenhouse gas emissions. This is especially critical because the methane released from burning gas in buildings is 84 times more potent as a greenhouse gas[4] than carbon dioxide.
Powering new buildings with electricity from increasingly renewable sources instead of on-site fossil fuel combustion will also protect public health across the District. Dozens of peer-reviewed scientific studies dating back to the 1970s have linked indoor exposure to methane gas—often from gas stoves—to asthma and other diseases. As one example, a 2013 report[5] analyzing 41 different studies concluded that children living in homes with gas stoves face a 42% higher risk of having asthma. Burning gas in buildings also releases a number of hazardous air pollutants, including benzene, a known carcinogen.[6] A greater usage of gas also increases the likelihood that gas will leak. The D.C. Department of Energy and Environment has stated, “gas leaks degrade air quality, promoting the formation of surface level ozone and formaldehyde, both of which are damaging to health.”[7] Requiring commercial buildings to be fully electric would eliminate these public health risks from exposure to gas in buildings.
Further, there is no basis to further delay the adoption of an all-electric commercial construction code on the basis of capacity concerns. At the December 2022 CCCB meeting, Pepco Regional President Donna Cooper said an all-electric commercial construction code is feasible with D.C.’s electric grid. David Schatz, Pepco’s Director of Strategy, also confirmed that the D.C. grid can accommodate all-electric new commercial buildings. These affirmations are consistent with Pepco’s publicly available data and conclusions. On August 27, 2021, Pepco filed with the D.C. Public Service Commission a study titled “An Assessment of Electrification Impacts on the Pepco DC System,”[8] which conveyed the following conclusions:
- “Historically, Pepco has reliably managed annual peak demand growth rates well in excess of 2%”;
- “If electrification is the primary pathway for achieving the District’s decarbonization goals, we estimate that peak demand will grow at an average annual rate of 1.4% to 1.7% between 2021 and 2050”; and
- “On average, the system will grow at a rate that is higher than recent observed growth but well below growth rates that Pepco has reliably managed in the past[.]”[9]
For all of the above reasons, Sierra Club urges the CCCB to approve the proposed all-electric commercial construction code at its upcoming meeting.
Sincerely,
Sari Amiel
Associate Attorney
50 F St. NW, Eighth Floor
Washington, D.C. 20001
[1] D.C. Law 24-177 (2022).
[2] D.C. Law 24-176 (2022).
[3] Id.
[4] UN Environment Programme, Methane Action: Tackling a Warming Planet (Nov. 5, 2021), https://www.unep.org/news-and-stories/speech/methane-action-tackling-warming-planet.
[5] Weiwei Lin, et al., Meta-analysis of the effects of indoor nitrogen dioxide and gas cooking on asthma and wheeze in children (Aug. 20, 2013), https://academic.oup.com/ije/article/42/6/1724/737113?login=false.
[6] Eric D. Lebel, et al., Composition, Emissions, and Air Quality Impacts of Hazardous Air Pollutants in Unburned Natural Gas from Residential Stoves in California (Oct. 20, 2022), https://pubs.acs.org/doi/full/10.1021/acs.est.2c02581.
[7] Formal Case No. 1154, In the Matter of Washington Gas Light Company’s Application for Approval of a PROJECTpipes 2 Plan, & Formal Case No. 1130, In the Matter of the Investigation into Modernizing the Energy Delivery System for Increased Sustainability, 2021 Fugitive Methane Emission Survey of the District of Columbia, filed Oct. 31, 2021 (available at https://edocket.dcpsc.org/apis/api/filing/download?attachId=143587&guidFileName=d93076fd-4fbd-4537-9947-27db2f19f967.pdf).
[8] Formal Case No. 1172, In the Matter of the Implementation of the Climate Business Plan, An Assessment of Electrification Impacts on the Pepco DC System, filed Aug. 27, 2021 (available at https://edocket.dcpsc.org/apis/api/Filing/download?attachId=140553&guidFileName=1211ecc8-254d-4fc1-9143-10c8442e3fbc.pdf).
[9] Id. (emphasis added).