DC building standards take on climate change
DC’s building standards take on climate change
By Maci Woyat and Corrie Poland
The DC Department of Energy and Environment (DOEE) is drafting rules for enforcing a new program aimed at the culprit of 75% of the District’s greenhouse gas emissions — buildings.
It might seem strange to think of emissions this way. Aren’t fossil-fueled power plants the issue? But thinking about end use of power can be productive, and many buildings burn fossil fuels on-site, such as gas for heating. Plus, building architecture and use has a big impact on how much energy is needed in the first place.
So to green DC, we have to change how buildings are fueled, managed and designed.
The city should have a plan for that. DOEE’s Building Efficiency Performance Standards (BEPS) will require building owners to meet higher energy performance standards to support DC’s goal of halving greenhouse gas emissions by 2032. However, some building owners are requesting delays, while others are calling for lower penalties for failure to comply with the standards. Now, the city is wavering in commitment to its own plan.
During deliberations on the city’s budget for the 2022 fiscal year, the DC Council reallocated away millions of dollars that was intended to assist building owners and public housing transition to electricity from renewable sources instead of fossil fuels. The Council should restore this funding in the next budget cycle.
Failure to stay steadfast in the fight against climate change could be disastrous for the District. For decades scientists have warned of catastrophic increases in sea levels, habitat loss, extreme heat waves, and more severe and frequent storms if we continue to pump greenhouse gases into our atmosphere. Most of downtown, the National Mall, and Anacostia will be subject to repeated coastal flooding with the potential to displace thousands of residents. It also means more heat-related deaths and mosquito-borne diseases. All of these impacts will be disastrously regressive and hit our most vulnerable neighbors first and worst.
Citizens and building owners can help stave off these impacts by pushing DOEE to follow through with higher building performance standards.
How does BEPS work?
DOEE’s BEPS office plans to evaluate buildings in multiple phases. DOEE will use a free web-based tool from the Environmental Protection Agency to support building owners in reporting their energy and water efficiency annually. DOEE will then assess whether a building has fallen below the median Energy Star score before prescribing a five-year program for the building to be compliant or face a penalty.
BEPs’ goal is to create continuous efficiency reviews that are up to date and transparent. The EPA recommends comparing energy efficiency standards to “overcome barriers that prevent the commercial real estate marketplace and public sector institutions from identifying and valuing the efficiency of existing buildings.” Not only will this benchmarking give DOEE the ability to enforce standards and track efficiency progress using the most accurate data, but it will also incentivize buyers and builders to consider efficiency in their building plans.
As of now, privately-owned buildings over 50,000 square feet and District-owned buildings over 10,000 square feet are subject to BEPS. In 2022, privately-owned buildings over 25,000 square feet will be required to be assessed, followed by privately-owned buildings over 10,000 square feet by 2025.
In their 2021 Guidebook, DOEE notes 1,662 buildings will be affected. Of those buildings, over 47% are educational or multi-family housing. Both of these building types cover a large spectrum of sizes, even within the first phase of implementation. For example, Eaton Elementary school is 52,560 square feet, while American University’s Hall of Science alone is 125,000 square feet. However, both dwarf in comparison to the new luxury apartment building at CityCenter, that totals up to 320,500 square feet. Despite these differences, all three would be subject to the first compliance cycle of BEPs. For this reason, BEPS allows building owners to apply for extensions, and owners of affordable housing buildings qualify for extended periods to meet the requirements.
Is BEPS a roadmap to building electrification?
In the same 2018 DC law that established BEPS, the DC Council required our electricity supply to be 100% renewable by 2032. The more our buildings can use clean energy like electricity from renewable sources, rather than fossil fuels, the closer we will come to achieving our climate commitments and having resilient buildings that can withstand the impacts of climate change.
However, an owner of one of the District’s more outdated buildings may only meet what is currently required to protect themselves from non-compliance. The current program enables incrementality, but what is needed for long-term success is make bold investments now rather than successive nibbles at the margins.
Consider this example: a building owner may opt to move from an inefficient fossil-fuel based HVAC system to a more efficient fossil-fuel HVAC system without considering renewable energy options or highly-efficient electric heat pumps that will be operating well beyond a single BEPs cycle. Since DC’s goal is to use 100% renewable electricity by 2032, a building owner will once again have to replace their HVAC systems to meet standards. Not only could this impede DC’s clean energy goals, but it could also put undue strain on building owners.
How can I get involved?
The DC Council needs to help building owners move toward an electrified future. Keeping building owners’ expectations realistic, enforcing smart standards that keep DC’s long-term climate vision as a priority, and providing the funding and support needed to transition to renewable electricity across all sectors of DC is critical to curbing climate change and meeting DC’s climate commitments.
The DOEE website lists the compliance rules, and proponents of BEPS can email comments to info.BEPS@dc.gov. All filings should be clearly marked “Public Comments: BEPS Compliance Regulations.”
Other opportunities to get involved in the BEPS discussion can be found on DOEE’s website including information on how to get involved with task force meetings, events, and innovation hubs.
The authors are members of the Sierra Club DC Chapter.
