Testimony of Barbara Briggs
Sierra Club District of Columbia Chapter
Oversight Hearing on the Department of General Services
Committee on Facilities
February 21, 2025
Councilmember Lewis George, thank you for this opportunity to testify at this oversight hearing on the Department of General Services, and thank you for your leadership. My name is Barbara Briggs. I’m a member of the Executive Committee of the Sierra Club District of Columbia Chapter, and I’m testifying on behalf of the organization. The Sierra Club is America’s largest and most influential grassroots environmental organization, with millions of members and supporters. In DC, we have about 2,100 dues-paying members and many thousands of additional supporters.
ENERGY
The District government should lead the way for the private sector in improving energy efficiency, reducing climate pollution, and improving climate resilience. The Sierra Club sees some steps in the right direction at DGS, but much room for improvement as well.
Building Energy Performance Standards and Energy Savings Performance Contracts
DC’s Building Energy Performance Standards (BEPS) apply to large buildings owned by the DC government as well as privately-owned buildings and require significant improvements in energy efficiency across this sector.
Standard budgeting practices, including in the District’s budget, can pose an obstacle to improving energy efficiency in buildings. This is because the additional expense of energy efficient features comes out of the capital budget, while the energy savings accrue to the operational budget.
For the past two years, the Sierra Club has testified in this committee on the benefits of Energy Savings Performance Contracts (ESPCs), which can help solve this budgetary problem. ESPCs are a mechanism used to pay for today’s facility upgrades with tomorrow's energy savings – without tapping the capital budget. An ESPC is a partnership between an energy service company (an 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.
The Sierra Club commends DGS for developing and awarding the DC government’s first Energy Savings Performance Contract. This process will not only save taxpayers money by reducing energy costs, but will also improve indoor air quality and comfort for the occupants of DC buildings. The Council will need to approve the preliminary award, and we urge you to do so promptly so that the next phase, the Investment Grade Audit, can proceed as soon as possible.
DGS will still need additional staff and funding to implement BEPS as well as net zero energy requirements. The Sustainability and Energy Management Division includes only 11 positions, two of which are currently vacant, according to the organizational chart that DGS provided to the committee. This division should be funded to hire at least two more staff in FY26 for this important work.
Appropriated funding is needed for two purposes. First, the Energy Service Company (ESCO) must be compensated out of annual DC government appropriated funding. Furthermore, as the BEPS energy efficiency retrofits are implemented, funding is needed to include building electrification measures that will be required to convert buildings off fossil fuels, but will not generate energy efficiency savings in the near term. DGS noted in its response to Question 120 that a federal electrification project, at the Ronald Reagan Building and International Trade Center, “highlighted the importance of incorporating supplemental funding into Energy Savings Performance Contracts (ESPCs) when pursuing large-scale electrification initiatives. The Federal Government allocated $22.7 million to supplement third-party financing for this ESPC project.”
Similarly, DGS noted in the answer to Question 219 that “most modernizations and new construction projects require an additional $1-4 million to install geothermal wells.” While the up-front cost of geothermal heat pumps is higher than for air source heat pumps, geothermal heat pumps are substantially more energy efficient because they rely on underground temperatures that are much more consistent than air temperatures.
Greener Government Buildings Act
The Greener Government Buildings Act (GGBA) requires buildings owned by the District, or with significant DC government funding, 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 any fossil fuels like methane gas. The requirement applies to new and substantially renovated buildings.
We appreciate that DGS has identified “constructing all new facilities above 10,000 square feet to the Net Zero readiness standard” as a key objective. However, we are concerned about the use of the term “net zero readiness” throughout DGS’s performance oversight responses (Question 205, for example). The law requires “net zero energy compliance” for new and substantially renovated buildings, not “net zero energy readiness.” Are these buildings “net zero energy ready” because they are not powered 100% by renewable energy resources? We recognize that a number of DC government facilities will not be able generate all the energy they need onsite, because of space constraints that limit solar panels or geothermal wells. In these situations, the law provides that the requirement for renewable energy can–and should–be met through power purchase agreements.
Climate Commitment Act
The Climate Commitment Act sets greenhouse gas reduction goals for the District and also prohibits the District government from installing fossil fuel-burning appliances for space or water heating starting in January 2025.
In the Sierra Club’s view, the law allows DGS to conduct emergency repairs to gas boilers and water heaters. However, under pressure from DGS and the Mayor’s office, the Council in January passed emergency and temporary legislation that will give DGS more leeway to replace significant components of gas-burning systems, potentially extending their use by many years.
We do not agree with DGS’s position that existing gas-burning boilers and water heaters should be operated to the end of their lifespan. Combustion fumes from these systems generate air pollutants that harm our health both indoors and outdoors. The climate crisis is upon us, and to prevent the worst possible outcomes, we must act urgently to reduce greenhouse gas emissions by replacing these systems with highly efficient electric heat pump systems.
Furthermore, it is clear from DGS’s responses to the performance oversight questions that the agency does not know when the existing fossil fuel combustion systems in DC government buildings will need to be replaced. DGS provides a list of existing boilers with estimated ages but states in answer to Question 204 that “the Department has provided best estimates. More accurate and descriptive information would require an audit.” Nor does it appear that DGS is keeping track of aging boiler systems so as to plan for their replacement. DGS simply says, in response to question 177, that DGS “engages in major renovations at the request of the client agency.” As a result, unanticipated failure of these aging systems is likely to result in emergency replacements with new gas-powered systems.
The Sierra Club asks that the Council hold a hearing before making any further changes to this provision in the Climate Commitment Act. We have some concepts to propose, including the following:
- Requiring a detailed timeline and plan for replacing fossil fuel space and water heating systems with non-combustion alternatives.
- In emergency replacement situations, allowing fossil fuel combustion equipment to be installed and operated for up to 10 years, or until 2040.
- Requiring an annual report to the Council on emergency installations of fossil fuel combustion equipment.
Importance of preventative maintenance
We were surprised to read in DGS’s performance oversight responses that “DGS expanded the HVAC maintenance program from schools to include the majority of District government buildings.” It is astonishing that DGS was not already conducting maintenance of all HVAC systems. Maintenance is essential to efficient functioning of HVAC equipment and should be a high priority for DGS.
Electricity from Renewable Resources
We commend DGS for installing, with the District’s power purchase agreement (PPA) partners, three new solar photovoltaic (PV) systems in the past three years, and are heartened to hear of the large upcoming PPA with 27 sites. We see in DGS’s responses that DGS is working with the Office of the Attorney General (OAG) to finalize the terms and conditions of this new PPA, and we urge DGS and OAG to work swiftly to complete it, keeping in mind risk mitigation of any potential changes to federal tax incentives that may contribute to viability of project financing.
ZERO WASTE
DGS is not meeting its obligations to provide compost services in public schools
Sending food waste to an incinerator or landfill results in significant air pollution and methane emissions, which could be completely eliminated by composting. According to the Zero Waste DC website, an average school produces hundreds of pounds of compostable waste each day, which would be directly diverted by providing compost collection and hauling at more schools. But the impacts could reach farther: children learning best practices on food waste reduction, donation and composting at school can share their knowledge with their parents so that more families compost food scraps. DPW’s curbside compost program has proven to be successful and popular, but only 9,000 households currently participate. DPW is now deploying smart compost bins in all wards, giving residents of multi-family housing an opportunity to compost. Composting in schools offers the potential for the District to dramatically increase the amount of food waste diverted from landfills or incinerators.
Action 14 of the Zero Waste DC Plan, calls for source separation of recycling and composting in all institutional and governmental buildings by 2025, with DGS as a partner agency. Action 37 of the plan, “Zero Waste Schools,” calls for DGS and the Department of Public Works (DPW) to provide zero waste education to all school classrooms with an emphasis on “hands-on learning,” and to ensure school cafeterias instill best practices for food waste reduction, donation and composting. Unfortunately, our schools are far off track to reaching these goals.
DGS, in its response to pre-hearing question #231, indicated that it provides composting services in a mere five public schools. DGS explains that its composting service is opt-in only to ensure a proper level of engagement. That sounds like an excuse: DGS itself is responsible for providing the zero waste education that would ensure engagement. We urge DGS to include funding in the Fiscal Year 2026 budget both to provide education on composting, and to significantly expand its current compost collection and hauling service beyond the current five participating schools and return at least to the 76 schools at which it offered composting services in 2017. DGS should also update this website: https://dgs.dc.gov/node/1077642 to accurately report which schools it offers composting services. This webpage has not been updated since 2017.
In addition, DGS should ensure compliance with existing building material reuse and recycling requirements for any renovation or demolition projects of DGS-controlled buildings. Section 503 of the DC Green Construction Code requires demolition and renovation projects to salvage or recycle at least 50 percent of construction materials. Action 5 of the Zero Waste DC Plan requires all new construction, demolition, and building retrofit projects to submit a Deconstruction Plan that achieves a waste diversion rate of 80% of recoverable materials. We urge DGS to report annually on its implementation of these building material reuse, recycling and deconstruction requirements in the buildings it controls.