November 7, 2022
Dear Ms. Cooper,
The Sierra Club was disappointed that DC’s Construction Codes Coordinating Board (CCCB) voted down a proposed all-electric code for new buildings after last-minute and vague objections from Pepco. As you know, technical experts at the CCCB have been considering the code update for much of the year, and they agreed to a compromise allowing a large number of exemptions to the all-electric requirements for new buildings, including for commercial kitchens, hospitals, detention facilities, certain university buildings, standby power, rooftop grills, and ornamental fireplaces.
S&P Global and Bisnow reported that you sent a letter to the CCCB on behalf of Pepco in September citing general concerns about the building code, but that Pepco never followed up with any specifics, and that instead you sent an email to CCCB members minutes before the vote re-attaching your original letter outlining unspecified concerns while offering no suggestions to address Pepco’s unknown objections.
Pepco’s position is perplexing, considering that Pepco’s own electrification study submitted to the DC Public Service Commission concluded that electrifying 95% of all DC buildings and 100% of DC’s passenger vehicles would require electricity usage “significantly below historical rates of growth that have been reliably managed by Pepco for decades.” The CCCB proposal to require all-electric new buildings is far more modest than the scenario in Pepco’s electrification study of electrifying 95% of all buildings – not only new buildings, but also existing buildings – on top of electrifying 100% of passenger vehicles. Given that DC has taken no action to electrify 95% of existing buildings and 100% of passenger vehicles and has no plans to do so, Pepco’s grid concerns seem unfounded. Pepco has offered nothing beyond vague generalities to explain its concerns.
The Sierra Club hopes that Pepco’s fight against an electric building code is not a cynical attempt by Exelon to use its ownership of Pepco to stymy the trend of all-electric buildings so that Exelon can protect profits from fracked gas utilities it owns in Maryland, Pennsylvania, and Delaware. Exelon is a member of the Consortium to Combat Electrification, which according to E&E News has stated its mission is to "create effective, customizable marketing materials to fight the electrification/anti-natural gas movement." Exelon’s membership in the Consortium to Combat Electrification may explain why Pepco and Exelon-owned gas utility BG&E fought legislation in the Maryland legislature for all-electric new buildings and why Pepco and BG&E similarly battled all-electric new buildings in Montgomery County, Maryland.
Pepco spokesperson Addie Kauzlarich said in a statement to Bisnow that, “Pepco stood ready to act on any code changes that resulted from the vote.” Pepco’s electrification study demonstrates that DC’s electric grid is indeed ready for any increased winter electricity usage resulting from transitioning buildings from fossil fuel to efficient electric heating. The chart labeled “Baseline Load Growth in Sensitivity Case” in Appendix B of Pepco’s electrification study shows a 2020 summer peak of more than 2,000 MWh and a 2020 winter peak below 2,000 MWh. Assuming electrification of 95% of existing buildings and 100% of passenger vehicles – a scenario far more aggressive than the CCCB proposal to electrify only new buildings – the chart shows winter peak not exceeding the 2020 summer peak until some time between 2030 and 2035. This demonstrates that the grid can handle increases in winter electricity usage for the next seven to 12 years. The chart expresses summer and winter peaks only with bar graphs, without providing the specific numerical values for winter and summer peak load.
The Sierra Club requests that you share with us and with the CCCB the specific data on historical winter peak load and summer peak load over the last 20 years. Your electrification study shows that you have this data readily available, as summer peak over the period 1950 to 2020 is plotted in a graph in the “Summary of findings” section at the beginning of the study, and winter peak is plotted for the year 2020 in the “Baseline Load Growth in Sensitivity Case” chart in Appendix B.
In addition to the historical winter peak load and summer peak load, we ask that you provide to the Sierra Club and to the CCCB the specific numerical values for the projection of winter and summer peak load from the simulation in your electrification study over the period 2022 to 2050.
Based on the “Baseline Load Growth in Sensitivity Case” chart in Pepco’s electrification study, we have no doubt that the data will demonstrate that the CCCB’s building code proposal poses no threat to the grid and that as promised, Pepco will be “ready to act on any code changes.”
We look forward to hearing from you.
Sierra Club DC Chapter