DC Government Buildings Must Go Net Zero to Protect Public Health

Testimony of Lara Levison
Sierra Club District of Columbia Chapter
Oversight Hearing on the Department of General Services
Committee on Facilities and Family Services
February 28, 2023

Councilmember Lewis George, thank you for the opportunity to testify at this oversight hearing on the Department of General Services (DGS), and thank you for your strong leadership on environmental issues. My name is Lara Levison, and I am the chair of the Energy Committee of the Sierra Club District of Columbia Chapter. The Sierra Club is America’s largest and most influential grassroots environmental organization, with millions of members and supporters. The DC chapter has about 3,000 dues-paying members.

Understandably, DC residents often testify at agency oversight hearings to point out what is going wrong at an agency, so I want to start by thanking DGS leadership and employees for their hard work and commitment to making things go well. 

The Sierra Club’s testimony focuses primarily on transitioning DC government buildings to net zero energy buildings, meaning buildings that are highly energy efficient, powered by electricity from renewable sources like wind and solar power, and do not burn fossil fuels at all.

We are calling for full implementation of the Greener Government Buildings Act, including funding for additional personnel in DGS’s Sustainability and Energy Management Division to manage implementation of the law.

Benefits of Net Zero DC Government Buildings

The climate crisis is upon us. Last year (2022) was the sixth-warmest year on record. Of the 10 warmest years on record, the last nine years (2014-2022) were among those 10 warmest years.^[1] Before you say, “Yay, I hate cold weather,” think about what this means for summer temperatures. Extreme heat is the deadliest type of natural disaster in the United States,^[2] which is why Mayor Bowser last year issued the Keep Cool DC plan on reducing the impacts of heat waves and protecting residents from heat waves.^[3]

DGS has a major role to play in helping the District meet its commitments to reduce the carbon pollution that is the main driver of the climate crisis. The climate commitments enacted by the DC Council last year in the Climate Commitment Act require DC to reduce greenhouse gas emissions 60% below 2006 levels by 2030 and reach carbon neutrality by 2045. The Climate Commitment Act also prohibits the District government from installing fossil fuel-burning appliances for space or water heating starting in 2025, and it requires the District government to purchase or lease only zero-emission vehicles starting in 2026. Several other recent laws also contain requirements for DGS to improve efficiency and reduce carbon pollution, including the Clean Energy DC Omnibus Act, the Clean Energy DC Building Code Act, and the Greener Government Buildings Act.

DGS isn’t just helping the planet by transitioning the DC government to net zero buildings that eliminate fossil fuel combustion–DGS will also improve public health by reducing indoor air pollution as well as outdoor air pollution. The gas company doesn’t want us to know this, but combusting gas inside buildings for space heating, water heating, and cooking causes air pollution inside our buildings that harms our health.

In an October 2022 letter to the U.S. Department of Energy, the American Lung Association and other public health organizations commented on the health impacts of gas furnaces, as follows:

“A significant amount of evidence on the detrimental health effects of exposure to air pollution shows that burned methane (natural) gas (mostly nitrogen dioxide) contributes to premature mortality and increased risk for illness including ischemic heart disease, stroke, COPD, lung cancer, type 2 diabetes, and lower-respiratory infections. There is a growing body of evidence showing an association between long-term exposure to air pollution and adverse birth outcomes. Short term exposure to high levels of air pollution can exacerbate asthma and cardiopulmonary symptoms.”^[4],[5]

Net zero buildings, as defined in DC law, reduce outdoor air pollution too. They eliminate all fossil fuel appliances, which often vent combustion fumes into the outdoors, relying instead on highly efficient electric technologies including air- and ground-source heat pumps. At the same time as our buildings are transitioning to all-electric, our electricity supply is becoming cleaner as well, thanks to the requirement for DC’s electricity supply to come from 100% renewable energy by 2032.

Net zero buildings also increase the comfort and productivity of their occupants–which will include more and more school children as DC schools are built or renovated–because they are insulated from extremes of temperature, incorporate more natural light, and (as already explained) eliminate indoor air pollution from burning fossil fuels.

Strategic Energy Management Plan

Making the transition to net zero buildings requires extensive planning. The Sierra Club is disappointed that the DGS “Energy Management Plan,” which was finally released in June 2022, does not provide anything like a clear or complete roadmap. Legislation that Mayor Bowser signed into law in 2019 required DGS to develop a strategic energy management plan for reducing energy and water use across the DGS portfolio of buildings by January 2020. We appreciate that the pandemic created some additional challenges, but still, the plan was shockingly late at two and a half years after the due date.

The energy management plan has some useful concepts and information in it. However, it fails to provide the timelines and cost estimates that the Clean Energy DC law specifically requires for a net-zero energy retrofit program and for reductions in energy use and greenhouse gas emissions.^[6] It is very difficult to extract information on what funding is needed, and when it is needed, from this plan. Without a doubt, DGS knows which government buildings will need to be built or renovated over the next several years. The Sierra Club calls on DGS to provide clear and transparent information on the funding and personnel needed to implement the requirements under DC law for increasing energy efficiency and transitioning to net zero energy in those buildings.

The Sierra Club also calls on DGS to resume providing data to the public on energy use in buildings managed by DGS. Cutting-edge highly energy-efficient buildings need to be properly managed and maintained, and the public should be able to monitor energy use in our public buildings.

Greener Government Buildings Act

Councilmember Lewis George, thank you for co-introducing the Greener Government Buildings Act, which passed the Council in December. DGS should immediately begin implementing and funding this new law, which requires that new or substantially improved buildings managed by DGS be net zero energy buildings.

A net zero building generates energy on-site over the course of a year equal to the amount of energy the building consumes. This requires minimizing the building’s energy consumption through efficiency measures while maximizing the generation of renewable energy on-site. In some cases, a building’s energy needs can be satisfied with on-site solar energy and geothermal heat pumps. If any additional energy is needed for the building, it must be provided by renewable energy from electricity that directly serves the building, such as through a power purchase agreement, not through the purchase of unbundled renewable energy credits (RECs).

The Mayor’s Fiscal Year 2024 budget proposal must include substantial multi-year funding for DGS to implement the Greener Government Buildings law. While DGS’s Energy Management Plan does not provide sufficient information, it is clear that DGS does not currently have enough resources for implementation. The fiscal impact statement for the bill, which is in the October 2022 committee report, states, “Funds are not sufficient in the fiscal year 2023 through fiscal year 2026 budget and financial plan to implement the bill.”^[7] The funds needed in FY2023, which is the current year, are required to bring projects that are already in the pipeline into compliance with the net zero mandate. The Sierra Club urges DGS to reallocate funds in this year’s capital budget to ensure that these projects are net zero.

DGS urgently needs to staff up in the Sustainability and Energy Management office to ensure the timely and effective implementation of the net zero law. The Fiscal Impact Statement for the bill identified a need for four additional employees (4 FTEs) starting in the current fiscal year (2023). The Sierra Club urges DGS to initiate the process for filling these positions, or hiring contractors. We all know it can take a while to find the right people for specialized roles. Probably by the time DGS is ready to make job offers, we’ll be well along in the current fiscal year. If DGS waits till October 1st to post the jobs, they may not be filled for several more months. The Sierra Club strongly urges DGS and the Council to include the necessary funding for these four FTEs in the budget for FY24 and ongoing.

The Sierra Club also urges DGS to be transparent regarding the budget for implementing this law as well as related requirements such as the Building Energy Performance Standards.

While net zero buildings sometimes–though not always–require more funding than conventional buildings, they use little energy, so their utility bills are much lower, saving money for taxpayers and DC agencies. Unfortunately, standard budgeting practices, including in the DC government,  can pose an obstacle to improving energy efficiency in buildings. This is because the additional expense of energy efficient features comes out of the project budget, which is part of the capital budget, while the energy savings accrue to the program or operational budget.

There are some creative mechanisms for dealing with this problem. Energy Savings Performance Contracts are a mechanism used to pay for today’s facility upgrades with tomorrow's energy savings – without tapping the capital budget. An Energy Savings Performance Contract is a partnership between an energy service company (ESCO) and a facility owner such as DGS. The ESCO designs and installs energy savings measures. Savings are monitored and verified, and the facility owner reimburses the ESCO over a certain number of years out of operating budgets.^[8] We have no doubt that the smart folks at DGS are aware of this mechanism, and we encourage the Mayor’s office and the Council to support this and other creative approaches to financing new and renovated net zero buildings.

The Sierra Club applauds the provisions in the Greener Government Buildings Act to provide trainings in net zero energy construction for facilities staff, certified business enterprises, and other interested parties. Training is an essential element of the transition to all-electric, high efficiency buildings and will yield substantial additional benefits by ensuring DC has a highly trained clean energy workforce. These training programs are another reason why DGS should staff up as quickly as possible.

Electric Vehicles

Going forward, all new and renovated DC government buildings should include charging stations for electric vehicles (EVs). While the Greener Government Building law does not explicitly require EV charging, other DC laws and policies clearly indicate the District’s commitment to eliminating fossil fuels from our vehicles as well as our buildings. The Climate Commitment Act of 2022 requires the District government to purchase or lease only zero-emission vehicles beginning in 2026. Also, federal laws passed in the last two years are giving a big boost to electric vehicle ownership.^[9] At the very least, all new and renovated DGS buildings should be wired to be EV-ready, since retrofits would be much more costly.

Building Energy Performance Standards

The Sierra Club is concerned that DGS and the Mayor’s office are not fully committed to funding and implementing retrofits to DGS buildings to comply with the Building Energy Performance Standards that were established in the 2018 Clean Energy DC law. These standards, known as BEPS, are more aggressive for District buildings than private sector buildings, because the public sector should set an example for the private sector. Again, we call for transparency in the DGS budget, so that the public can see whether and how much funding is provided for BEPS implementation. Regardless of whether electrification is required for a specific building in a specific compliance cycle, fossil fuels should be fully and completely eliminated from DGS buildings at the point in the building life cycle when major systems such as heating and cooling (HVAC) need to be replaced.

Solar Energy on DGS Buildings

We understand that DGS has developed a systematic approach to obtaining power purchase agreements for solar power to be installed at or on DC government buildings, using Certified Business Enterprise (CBE) companies. These power purchase agreements enable DGS to obtain clean electricity at stable, affordable long-term rates that reduce electricity costs for DC agencies. There is no upfront cost to the DC government since the solar companies retain the solar renewable energy credits. The Sierra Club supports maximizing the use of solar power for DC government facilities.

Zero Waste

The Healthy Schools Act, as codified in § 38–825.01 (a)(1)(J) of the District Code, calls for DC Public Schools to establish a composting program. We understand that composting was largely suspended during the pandemic but that DGS is planning to revive the program toward the end of this academic year. We would appreciate DGS reporting on the status of the school composting program or inviting District of Columbia Public Schools to report. It’s important to understand what waste diversion rate DC schools have achieved due to compost programs and what the planned waste diversion rate for next year is. Our public schools and other government buildings and facilities impact whether we achieve our goal of diverting 80 percent of the District's waste by 2030.

We also encourage DGS to abide by Section 503 of the DC Green Construction Code and salvage or recycle at least 50 percent of materials for its demolition and renovation projects. Compliance with these requirements also holds great promise in contributing to the District's waste diversion goals.

Thank you for the opportunity to testify at this DGS oversight hearing. If you have any questions, please contact Lara Levison at clean.energy@dc.sierraclub.org.