What is the Gestation Period for the Comprehensive Energy Plan?
In the summer of 2014 a DC-based contracting team provided the final draft of the Comprehensive Energy Plan to what was then called DDOE – the District Dept. of Environment. The consultants asserted that the plan was in fact a report intended to be the basis for stakeholder discussion. This was stressed as a key part of the planning process because unless all the players – the utilities, the SEU, the PSC, the commercial building owners and advocacy communities could come to agreement on coordinated next steps – then there was no plan. The plan got caught up in the transition from the Gray to Bowser administration and was not released. Instead, a new contract for a new plan was signed in 2015. The new plan was released to a very limited “peer review” this past autumn. I prepared CUB’s comments, stressing the need for a full public comment period before the document was delivered to the DC Council.
The new plan was delivered to what is now known as DOEE – The Department of Energy & Environment, and it was substantially different from the plan that had been delivered in 2014. Among the most obvious change is the name – the Clean Energy DC. When things take so long that names change during the process, it’s a sign that progress may be lacking in other more substantive areas. This was the concern we expressed in our comments, highlighting numerous points, many of which were addressed in the revised version now out for public comment. Several concerns, however, we feel remain valid.
1. The CEP appears to be an aspirational statement, and as such it does present a bold vision. However, it arrives without any clarity on how it will be used to guide future actions, and the extent to which stakeholders will be involved in finalizing objectives and actions. A “living document” is not a meaningful phrase absent clarity about why, who, how and when it will be revised with what priorities.
2. Greenhouse Gases (GHG) are important, but only a single driver of DC energy transition.
Climate change and greenhouse gases (GHG) are among many factors that are driving the opportunity for transition. Overall reduction of per-capita District energy consumption through greater consumer control, better provisions for renewable energy production, and other goals should also be in focus. It may simplify reporting to use a single goal as the driver for the plan, but it will limit the perspective and context. For example, absent a goal to ensure ratepayer equity or protections, such features are not contained in the plan at all. Energy policy cannot be exclusively considered a technical optimization problem.
3 The plan does not include priorities or sequencing. All actions appear to be equally valuable and ready to implement, regardless of cost or cost-effectiveness. There is no indication of which actions should be prioritized, if sequencing among actions would optimize outcomes, or any suggestion of timing – near, medium or long term. Key priorities are those that require the fullest attention by the DC Council and Mayor, and should be protected from diversion or dilution. Such focus is also essential for building the public support required to transform the energy structure of the city.
4 The actions identified in the plan represent good municipal best practices and the identification of technical opportunities appropriate for DC. Now, the challenge is to get from an aspirational statement to an implementable plan that can be embraced by the public, the government, home and building owners, and the utilities. We have to ask, at this rate, how long is that going to take? The plan is available on the web for public comment - http://doee.dc.gov/cleanenergydc .