D.C. Board Rejects All-Electric Building Plan After Last-Minute Pepco Concerns

Washington, D.C.'s, plan to ban natural gas from most new commercial buildings was unexpectedly derailed last week after regional utility Pepco raised last-minute concerns about whether the grid could support the changes.

The Construction Codes Coordinating Board voted down the all-electric building proposal Thursday, a move that left green building advocates stunned, given that Pepco had released a study last year indicating electrification shouldn't be a strain on the District's power grid.

"I was really surprised," said Anica Landreneau, global director of sustainable design at HOK Architecture and an adviser working on the code changes. "It's a pretty big statement for the utility to say we conducted this study [last year], and you can't rely on it."

The vote came after Pepco sent a letter to the CCCB on Sept. 14 expressing general concerns about electrification's effects on the grid. Members of the board then met with Pepco in late September and awaited a follow-up from the utility indicating whether it would support the code changes. But that follow-up never came, according to Casey Studhalter, chair of the Commercial Energy Technical Advisory Group, which is responsible for bringing code changes to the CCCB and engaging with stakeholders.

Instead, in an email sent to the board members "about 45 minutes" before their Oct. 20 meeting, Pepco referred board members back to previous correspondence that urged the CCCB to work with Pepco to outline future infrastructure needs, Studhalter told Bisnow. 

"There was a lot of ink spilled and not a lot said. It was unclear where they stood," Studhalter said. "It was just the code board wanting assurances from Pepco, and it doesn't seem that they got those."

Pepco has been working on decarbonization plans on its own for well over a year. On Aug. 27, 2021, the utility filed a study to the Public Service Commission of D.C. outlining how it would adjust to building electrification and decarbonization.

At the time, Pepco Holdings Strategy Director David Schatz told Utility Dive that the utility was holding stakeholder meetings and developing specific strategies around different property types in the District.

Yet the utility didn’t raise objections about the code changes until well after the CCCB had begun its own public meetings. And in its 2021 filing, Pepco said that even if D.C. meets its decarbonization goals by electrifying all sectors, the additional power capacity will “remain well within the rate of system growth that Pepco DC has successfully managed and operated historically.”

Pepco declined to respond to a question from Bisnow asking what changed between August 2021 and this September that would merit further study.

In a statement, Pepco said its August 2021 study was meant as a "high-level view of electrification in the District."

"Pepco has been monitoring the process of development of these codes but has not expressed a position for or against the changes," Pepco spokesperson Addie Kauzlarich said. "Instead, Pepco stood ready to act on any code changes that resulted from the vote."

The August filing determined peak electric demand would grow at an average annual rate of 1.4% between 2021 and 2050. Between 1950 and 2020, the utility handled annual growth rates "well in excess of 2%," according to the filing.

Pepco also said in its filing last year that energy efficiency and load flexibility strategies, some of which were included in this year's code proposal, could further lower the annual growth in demand by as much as one-third. 

Studhalter said the D.C. Department of Energy & Environment is finalizing a report of its own with a preliminary finding that electrification shouldn’t pose a substantial strain on the grid.

The Sept. 14 letter, sent by Pepco Region President Donna Cooper to CCCB Chair Danielle Gurkin, said that the utility's August 2021 study wasn't built around the decarbonization timeline now being considered by CCCB and the District as a whole.

"The proposed shortened timeline, combined with a gas ban, impacted the assumptions underlying this study, and will be important to factor into the company’s planning, infrastructure considerations, technology choices, and the structure of programs and services," Cooper wrote. "Moreover, it is critical to understand the existing gas load to understand its impact on the electrical infrastructure. Such understanding requires a coordinated analysis with relevant stakeholders."

The changes included in the proposed code language would end the use of natural gas infrastructure for power, heating and cooling in most new construction and would require a certain number of electric vehicle charging stations in new commercial properties. Exceptions were included for certain kinds of commercial kitchen and lab equipment and decorative features in multifamily buildings that use gas flames.

The changes are designed to wean the District off of natural gas in order to meet its decarbonization goals. Legislation on the books would require the District to move to 100% renewable energy by 2032.

Additionally, the D.C. Council passed a law earlier this year that would essentially require the District to revert to a more stringent all-electric building code in 2026 if changes aren't made before then.

That left Landreneau scratching her head on the benefit of injecting uncertainty into the codemaking process just before a key vote, she said.

"It's just, I can't imagine the delta between 2023 and 2026 is going to be that much of an impact," Landreneau said.

There is still time to adopt the new code language if Pepco's concerns can be met. D.C. operates on a three-year code cycle, and the changes can be resubmitted as long as the CCCB is still meeting to finalize other parts of the District's building code.

But for now, Studhalter said he is still in the dark, as Pepco hasn't reached out to him since the vote last week.

"We'll be working to set up a follow-up conversation," Studhalter said. "My takeaway is the top-line statements are pretty clear that they can absolutely handle building electrification, even in a worst-case scenario."