By Adam Pagnucco.
Pepco has asked the county council to pause its work on Bill 13-22 (now known as the “electrocution bill”), which would mandate electrification of most additions, major renovations and new construction of buildings in the county. The bill is intended to replace building equipment using gas with equipment using electricity. But it has potentially enormous costs to building owners, tenants, taxpayers and ratepayers. And since the electric grid relies mostly on natural gas, coal and nuclear power, its environmental benefits are questionable at best.
In its letter to the council dated November 2, the day before the council’s Planning, Housing and Economic Development (PHED) committee considered the bill, Pepco stated its commitment to decarbonized energy several times. However, Pepco is concerned about the bill’s impacts on its distribution system and is requesting time to study them. Pepco wrote:
It is important for Pepco to perform an assessment evaluating the impacts of the proposed requirement to electrify all new construction in Montgomery County. Pepco must understand the implications of this policy for our existing infrastructure in our Maryland service territory. We believe this study is needed to inform our distribution planning, which would include location-specific analysis of load growth and capacity needs on the distribution system as well as the effectiveness of various approaches to addressing that growth. Pepco is currently in the process of conducting this internal study, which will supplement the state-mandated Maryland Public Service Commission electrification study. The details of the state study are still emerging, and a working group is underway at the Commission to determine its scope and findings. We, respectfully, request that the county does not act until these studies are completed.
Pepco used variations of the word “affordability” five times in its letter, an obvious reference to the fact that ratepayers will bear the cost of any needed modifications to Pepco’s system. Also clear is that only 4% of the grid’s energy comes from hydro, wind and solar so any costs will yield minimal environmental benefits.
The PHED committee, composed of Hans Riemer (chair), Will Jawando and Andrew Friedson, did not agree to Pepco’s request to pause action on the bill but extended its regulation deadline by a year. They also heavily amended the bill by adding numerous exemptions and removing additions and major renovations. They then voted unanimously to pass the bill as amended, which now heads to the full council.
We reprint Pepco’s letter below, as well as a similar letter the company sent to D.C.’s Construction Code Coordinating Board, which is considering similar measures to the county council’s bill.
*****
November 2, 2022
Via Email
The Honorable Hans Riemer, Chair
Planning, Housing, and Economic Development Committee
Montgomery County Council
Council Office Building 100 Maryland Avenue Rockville, Maryland 20850
RE: 13-22 Buildings – Comprehensive Building Decarbonization
Dear Chair Riemer:
Thank you for your continued leadership and valued partnership in the fight to mitigate the effects of climate change in the region and around the state. As you know, Pepco stands with Montgomery County in addressing climate change, with a strategic focus on increasing the resiliency and reliability of the grid in an affordable and equitable manner, as outlined in the Montgomery County Climate Action Plan (“MCCAP”). Our Company provided comments on the MCCAP, and we look forward to being an active partner in helping the county reduce greenhouse gas (“GHG”) emissions. We take this time to reiterate that achieving a decarbonized future will require ongoing analysis regarding infrastructure investments as well as technology upgrades to advance a clean energy future that aligns with local goals. With an increase in significant weather events, as a result of climate change, our investments must be able to support a more resilient grid that can withstand the worst impacts of climate change on the operations of the electric distribution system and ultimately our customers.
As the electric utility that serves the majority of Montgomery County, Pepco recognizes that we have a unique and important role in helping to make this transition to a more decarbonized future, equitable and affordable, through our platform – the electric grid. Every day, we are working to make the grid smarter, stronger and cleaner, with affordability being foundational. As part of the Exelon family of companies, in 2021, we announced a new goal targeting a reduction in GHG emissions of at least 50% below 2015 levels by 2030, and net zero emissions by 2050. At Pepco, we are working to align our operations, grid investments, and customer product offerings and services with Maryland’s climate change and clean energy goals. This means, reducing our own GHG emissions from operations and working to inform and advocate for policies and processes that enable further decarbonization, in alignment with the goals set forth by the jurisdictions in which we take great privilege in serving.
In follow-up to the recent Planning, Housing and Economic Development Committee meeting, in which the District of Columbia Electrification Study performed by Brattle was referenced, we would like to provide a few clarifications. Please know that the Brattle Study does not evaluate system capacity and planning needs in Maryland. The Brattle Study focused, exclusively, on the District of Columbia and assumptions informed by the District’s climate change mitigation goals and corresponding plans. Therefore, a separate study that considers the electric distribution system serving Maryland residents, as well as the Maryland-specific goals and timelines, would be required to understand current system capacity and future planning needs. This study will also help to inform the critical discussion, regarding affordability, which is foundational to our company, our customers and the communities that we are a part of and privileged to serve.
We have attached a copy of correspondence submitted, in September, to the District of Columbia Construction Codes Coordinating Board (Attachment). This letter provides further details, regarding the Brattle Study, and recent climate mitigation actions, plans and goals, that advance the need for further analyses by Pepco.
It is important for Pepco to perform an assessment evaluating the impacts of the proposed requirement to electrify all new construction in Montgomery County. Pepco must understand the implications of this policy for our existing infrastructure in our Maryland service territory. We believe this study is needed to inform our distribution planning, which would include location-specific analysis of load growth and capacity needs on the distribution system as well as the effectiveness of various approaches to addressing that growth. Pepco is currently in the process of conducting this internal study, which will supplement the state-mandated Maryland Public Service Commission electrification study. The details of the state study are still emerging, and a working group is underway at the Commission to determine its scope and findings. We, respectfully, request that the county does not act until these studies are completed.
We look forward to working with Montgomery County to enhance climate resilience, reduce carbon pollution, and improve public health affordably and equitably. We stand ready to provide our expertise as Montgomery County considers implementing new electrification goals in partnership with all stakeholders.
Please do not hesitate to contact us with any questions that you may have. We look forward to our continued collaboration as the county considers climate change mitigation options. To facilitate a timely response, please contact William Ellis, Director of External Affairs, at wrellis@pepco.com.
Sincerely,
William Ellis
*****
September 14, 2022
Via Email
Danielle Gurkin, Chairperson
Construction Code Coordinating Board
Department of Consumer and Regulatory Affairs
1100 4th Street, SW
Washington, DC 20024
danielle.gurkin1@dc.gov
Dear Chairperson Gurkin,
I am writing on behalf of Pepco to offer our assistance and seek a collaborative partnership to help the District achieve its leading climate and resiliency goals. I am advised that the Construction Code Coordinating Board (“CCCB”) is scheduled to review and consider a proposal from the Commercial Energy Technical Advisory Group (“TAG”) regarding a full electrification proposal for residential and commercial properties. As the electric distribution company serving the District of Columbia, we have the critical responsibility and privilege to develop, maintain, and adapt the core infrastructure system that will be instrumental in enabling the District’s important decarbonization strategies. Therefore, we respectfully request to partner with the CCCB, and other key stakeholders, as subject matter experts on this critically important matter.
We greatly appreciate the District’s commitment to meet important climate change and resiliency benchmarks. At Pepco, we share this commitment, and we look forward to working collaboratively with the CCCB to support the District in achieving its leading climate and clean energy goals. Pepco recently completed a broad District electrification study that assumed certain timelines for electrification; however, 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. 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 data and information from this analysis will help Pepco provide informed technical advice to the CCCB in its assessment and will help avoid unintended adverse impacts on residents and businesses in the District. Partnering together, we can help ameliorate technical concerns by having subject matter experts at the table to provide guidance and counsel in partnership with the various entities that will be impacted. For example, we understand that the proposed TAG code proposals make significant revisions to electric vehicle charging infrastructure. We can help the CCCB identify future trends and the system planning needs and ensure that system reliability and resiliency are considered in the assessment.
Pepco is committed to providing safe, reliable, affordable, and clean energy service to our over 350,000 customers. We are committed to make the District more resilient to the effects of climate change and to mitigate the impact equitably and inclusively, with consideration of system reliability, resiliency, and security. Most recently, we filed with the Public Service Commission a 5-Year Action Plan and the 30-Year Transition Strategy as part of a broader Climate Solutions Plan. This Climate Solutions Plan builds upon Pepco’s 2020 Climate Commitment, in which the company committed to reducing its own greenhouse gas footprint 70% by the end of 2025, achieve net zero emissions in alignment with the District’s goals and help our customers and communities do the same, particularly through building decarbonization and transportation electrification.
We look forward to working with you to enhance climate resilience, reduce carbon pollution, and improve public health affordably and equitably. We stand ready to provide our expertise as the District considers implementing new electrification goals in partnership with all stakeholders.
Thank you for your consideration. We are available to meet to discuss these issues in more detail and work through how we can most effectively collaborate to achieve critical climate goals.
Sincerely,
Donna Cooper
Pepco, Region President
cc: Construction Codes Coordinating Board