DC Chapter Calls on Historic Preservation Board to Embrace Solar Energy

Testimony
of
Mark Rodeffer
Chair, Sierra Club DC Chapter
before
DC Historic Preservation Review Board
 regarding
Sustainability Guide for Older and Historic Buildings draft


Thank you for holding this hearing today on the Historic Preservation Review Board’s draft Sustainability Guide for Older and Historic Buildings.

My name is Mark Rodeffer. I’m the chair of the Sierra Club DC Chapter. The Sierra Club is the nation's oldest, largest and most influential environmental advocacy group. The Sierra Club has 3,000 dues-paying members in DC. Our top priority is fighting climate change.

Climate commitments vs. history of intransigence
DC has made climate commitments to reduce greenhouse gas emissions to net zero by 2050 and to generate at least 10 percent of our electricity from solar panels in DC a decade before that.

Unfortunately, the Historic Preservation Review Board (HPRB) has not been an ally in the fight against climate change. You have repeatedly denied applications for solar panels in historic districts, in one case with an HPRB member stating that the "desire to save the planet" is laudable but less important than members of this panel being “upset” at seeing solar panels on row houses.

HPRB’s draft guidelines are flawed
The Sierra Club appreciates that the HPRB is seeking a way forward in accepting the fact of climate change and the need for rooftop solar. However, we believe the HPRB’s draft solar guidelines are inadequate. The proposed guidelines are at odds with DC’s climate commitments and solar requirements and fail to recognize the severity of the climate crisis.

The guidelines state that solar panels must be installed “so that they do not result in a perceptible change in the building’s massing, height or roofline, as seen from public street view.” The guidelines also state that solar panels must be installed "to minimize visibility from public street view." These are two different standards. Are solar panels required to have no perceptible view from the street or minimized visibility? The answer, according to the guidelines, is both. This inconsistency could easily be gamed by those who oppose solar.

The guidelines state that solar panels must be “coplanar and flush with the roof.” This would in many cases increase the cost and reduce the efficiency of solar panels, putting them out of reach for many. It is inequitable and unsustainable to increase the cost of electricity while decreasing electricity generation at the same time DC faces a housing affordability crisis and the planet faces a climate crisis.

The guidelines also state that solar panels must be “in a complementary color with the roof finish to avoid a discordant appearance.” Solar panels are black, so this rule effectively bans solar on any roof that is any color other than black. Because one in five buildings in DC is designated historic, more than in Boston, Chicago, and Philadelphia combined, and given the rapid pace at which DC is adding new historic districts, limiting solar panels to roofs of only one color runs directly counter to DC’s climate commitments and solar requirements.

The guidelines encourage “the use of a solar skin or solar shingles that match the texture and appearance of the roof.” Solar panels that match the texture of shingles do not exist. Given the severity of the climate crisis and DC’s appropriately robust climate goals, we cannot afford the time and money it would take for such panels to be developed.

The guidelines state that “conduit for connections to electric meters should be run inside the building or in a manner that is not prominent on a primary elevation.” This is completely impractical in DC’s thousands of row houses. In an older brick rowhouse, requiring conduit inside the structure is so cost prohibitive that it is essentially an outright ban on solar installations.  

Historic districts or solar exclusion districts?
I asked an entrepreneur at a DC-based solar company what he thought of the HPRB’s proposed guidelines. He said to me in an email: “We, for one, have a moratorium on historic districts because of all the issues and complications that come along with them. Until the HPRB shows that they can be reasonable about the aesthetics of solar, we are not inclined to take the risk of getting drawn into a protracted process. Hopefully this debate gets them in that direction, but these guidelines don't give me much hope.”

Conclusion
The Sierra Club urges the HPRB to amend its draft guidelines to recognize the severity of the climate crisis. Simply put, no solar installation should be prohibited because of concerns that rooflines of the past are more important than the future of humanity. If the HPRB does not take action to significantly expand solar installations in historic districts, the Sierra Club believes a legislative remedy will be needed.

DC is a low-lying city that sits along two tidal rivers, making us particularly vulnerable to sea level rise from climate change. I live in Southwest DC, a few blocks from the DC Historic Preservation Office. My co-op building sits eight feet above sea level. Climate change is an existential threat to DC. We must take bold action to expand renewable energy and solar power or we must accept that we have no hope of safeguarding our future and no hope of preserving our history.