Testimony of Lara Levison
Sierra Club District of Columbia Chapter
Hearing on PR25-285
Director of the Department of General Services Delano Hunter Confirmation Resolution of 2023
Committee on Facilities and Family Services
July 13, 2023
Councilmember Lewis George, thank you for the opportunity to testify at this hearing on the nomination of Mr. Delano Hunter to lead the Department of General Services (DGS). 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.
The Sierra Club’s testimony will focus on sustainability initiatives in DGS that require more support from the director, DGS leadership team, and the Mayor’s office to reach fruition. We congratulate Acting Director Delano Hunter on his nomination, and we urge him to ensure that the Greener Government Buildings Act (B24-0785) and Building Energy Performance Standards are fully implemented.
The Greener Government Buildings Act requires new and substantially renovated DC government buildings to be net zero energy, 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. The Building Energy Performance Standards, known as BEPS, will improve the energy efficiency of existing government buildings.
Councilmember Lewis George, on behalf of the Sierra Club, I’m delighted to have this opportunity to thank you for including the fiscal impact of the Greener Government Buildings Act in the District’s Fiscal Year 2024 budget, ensuring that this impactful law will fully go into effect. Amidst all the other budget demands, you and your team made the effort to move this law forward, and it will bring many benefits to DC’s citizens and our environment. Thank you!
The Sierra Club believes in reusing things that are still useful, rather than throwing them away, and I’m going to reuse some of our oversight testimony from earlier this year.
Benefits of Net Zero and Energy Efficient DC Government Buildings
Evidence of the climate crisis is all around us this summer. The District has been repeatedly blanketed with the smoke from wildfires in Canada; swaths of Vermont are under water this week; and the Southeastern U.S. is baking under a massive heat dome that is taking lives, because extreme heat is the deadliest of disasters. On June 20, the Weather Channel reported that temperatures soared over 100 degrees in every state in the U.S., including Alaska and Hawaii. Worldwide, temperatures broke records for several days in a row in early July.
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 Commitment Act, passed by the DC Council last year, requires the District to reduce greenhouse gas emissions 60% below 2006 levels by 2030 and to 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 in its buildings starting in 2025–less than two years from now–and it requires the District government to purchase or lease only zero-emission vehicles starting in 2026. Several other recent DC 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.
It is critical that we recognize that increasing building efficiency and removing fossil fuel equipment will have immediate benefits for public health right here in the District. By transitioning to net zero energy buildings, which eliminate fossil fuel combustion inside buildings, DGS will improve our health by reducing both indoor air pollution and outdoor air pollution.
The gas industry doesn’t want you to know this, but combusting methane gas inside buildings for space heating, water heating, and cooking causes air pollution inside our homes, schools, recreation centers, and offices that harms our health. According to the American Lung Association, burned methane gas, particularly the nitrogen dioxide emitted, “contributes to premature mortality and increased risk for illness including ischemic heart disease, stroke, COPD, lung cancer, type 2 diabetes, and lower-respiratory infections.”,
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, including 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 Clean Energy DC law enacted 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. The Sierra Club is disappointed that the DGS “Energy Management Plan,” which was finally released in June 2022, does not provide a clear or complete roadmap.
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. It is very difficult to extract information from this plan regarding what funding is needed, and when it is needed.
We have no doubt that DGS staff know which government buildings will need to be built or renovated over the next several years. The Sierra Club asks Director Hunter to direct his team to provide clear and transparent information to the Council and the public 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 asks Director Hunter to instruct his team 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 again for your leadership on the Greener Government Buildings Act, which thanks to you will go fully into effect in the coming fiscal year. Director Hunter, we urge DGS to expeditiously implement this 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 approach 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 serves the building, such as through a power purchase agreement, not through the purchase of unbundled renewable energy credits (RECs).
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. Discovery Elementary School in Arlington, Virginia was built to a net-zero standard in 2015. So far, its energy bills every year have been $118,000 lower than for a typical school.
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 the District has a highly trained clean energy workforce.
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. We call for greater transparency in the DGS budget, so that the public can see whether and how much funding is provided for BEPS implementation.
Also, regardless of whether electrification is required for a specific building in a specific BEPS 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.
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. We have no doubt that the smart folks at DGS are aware of this mechanism, and we encourage Director Hunter, Mayor Bowser, and the Council to support this and other creative approaches to financing energy efficiency improvements for DGS buildings.
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. At the very least, all new and renovated DGS buildings should be wired to be EV-ready, since retrofits would be much more costly.
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.
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 the 2022-23 academic year. We would appreciate DGS reporting on the status of the school composting program or inviting District of Columbia Public Schools to report. We would like to understand what waste diversion rate DC schools have achieved due to compost programs, and what the plan is for the coming school year. I attempted a quick search on DGS’s website and didn’t find any information more recent than 2017. 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 email@example.com.
 Flagging the Recycling, Redemption and Refund Coalition (3RC for DC), which is campaigning for deposit-return law to end bottle & can pollution in DC. https://act.sierraclub.org/actions/DC?actionId=AR0368163&id=7013q000001bnkbAAA
 “Heat waves are the deadliest natural disasters we face. What to know to keep your family safe.”, by Elizabeth Weise, USA Today, September 8, 2022,
 Hottest Temperatures Ever Recorded in All 50 States, Weather Channel, by Linda Lam, June 20, 2023, https://weather.com/news/climate/news/hottest-temperature-recorded-50-states?cm_ven=PS_GGL_DSA_09162019_1&par=MK_GGL&tpcc=mktg-search-Google-acquisition&gclid=EAIaIQobChMI2Pys1oWJgAMV6qJaBR2-VwtJEAAYBSAAEgKVhvD_BwE.
 ‘We are in uncharted territory’: World records hottest day ever for the third time in just four days, CNBC, by Sam Meredith, Friday, July 7, 2023, https://www.cnbc.com/2023/07/07/climate-world-records-hottest-day-ever-for-the-third-time-this-week.html.
 American Lung Association et al, coalition comment letter on Increased Efficiency Standards for Non-Weatherized Gas Furnaces and Mobile Home Furnaces, October 2022, https://www.lung.org/getmedia/ffe5d90c-6bd0-43fe-a4f9-48dba32427b6/climate-and-health-coalition-letter-on-doe-gas-furnace-rule-final.pdf.
 “Gas Boilers and NOx: The Hidden Emitter,” Energy & Climate Intelligence Unit, October 18, 2021, https://eciu.net/analysis/reports/2020/gas-boilers-and-nox-the-hidden-emitter
 The CleanEnergy DC Omnibus Amendment Act (B22-0904) raised DC’s Renewable Portfolio Standard (RPS) to 100% by 2032.
 Clean Energy DC Omnibus Amendment Act, B22-0904, Title III, Section 303, “The plan shall include timelines and cost estimates for implementing (1) An energy retrofit program across at least 9% of the DGS portfolio of District government-owned buildings by square footage between 2021 and 2024 prioritizing buildings that have core systems and equipment nearing the end of their useful lives, with a goal of achieving at least 30% reductions in energy and greenhouse gas emissions; and (2) A net-zero energy retrofit program across at least 12.5% of the DGS portfolio of District government-owned buildings between 2026 and 2032.”
 Presentation of November 2019 meeting of the DMV Net-Zero Energy Coalition. Slide 37. Available at https://sites.google.com/view/dmv-nze-coalition/home/resources_1/november-1-2019-meeting
 Infrastructure Investment and Jobs Act (2021) and Inflation Reduction Act (2022)