EDITOR’S NOTE: This story was updated on Jan. 2, 2024, to include comments received from the Department of General Services.
Last year, the D.C. Council passed a law prohibiting newly constructed buildings owned by the city from using fossil fuel heating systems. Now, a $103 million project headed by the Department of General Services includes plans for gas-burning boilers in a new D.C. Archives building. It’s scheduled to begin construction next year on the University of the District of Columbia’s campus.
“There’s no wiggle room in the law — it literally says on-site combustion of fossil fuels is not allowed,” said Matthias Paustian of the Sierra Club. “We are talking about a building that will be in existence, starting perhaps in the second half of this decade, and we’re still building it with fossil fuels.”
The District just released its Carbon Free DC plan on Dec. 1, while Mayor Muriel Bowser attended an international climate change conference. According to the plan, almost all of the city’s homes and buildings should be fossil fuel-free in 17 years. It’s a key step toward meeting the overall goal of carbon neutrality by 2045.
“We have all these plans: the Clean Energy DC plan, Sustainable DC, Climate Ready DC — they’re all great… question is, are they real?” said Jim Dougherty, a member of the District’s Commission on Climate Change & Resiliency, at a Dec. 14 roundtable about the Archives building project.
“The decision that’s coming up on the Archives building will be the test — whether this is all just flowery talk, or whether there’s been a real change,” Dougherty continued. “What I would say to the mayor is, ‘You have talked the talk quite well. And now it’s time to walk the walk.’”
The D.C. Archives building is scheduled to finish construction in summer 2026, according to the Department of General Services (DGS). The Greener Government Buildings Amendment Act officially went into effect on Oct. 8 and requires new government buildings to meet net-zero standards and run fully on electricity.
DGS said in an emailed statement that the agency was “still exploring the operational impacts this legislation will have on its current projects and will continue discussing requirements and obligations as part of the ongoing building permitting process.”
At the roundtable hearing hosted by Council member Anita Bonds, more than 30 public witnesses spoke, and over a dozen expressed concerns about the plan’s failure to follow the Greener Government Buildings Amendment Act.
“When it is burned, gas emits health-harming pollutants,” said Barbara Briggs of Beyond Gas DC. “The decision at hand is whether a major new D.C. government building will comply with D.C. law, contribute to the attainment of D.C.’s climate goals and to the future health of D.C. residents — or if it will not.”
In a presentation at the roundtable, DGS operations manager Allam Al-Alami said that the designs met the city’s legal requirements when they were submitted to the D.C. Zoning Commission in September. During the agency’s 45-minute presentation, representatives only mentioned the Greener Government Buildings Amendment Act by name once. Even then, it was in reference to other projects, not the D.C. Archives itself.
An Acute Need and a Long, Complicated Process
Today, the District’s historical records remain scattered at over a dozen different archives, where D.C. pays for other entities to store them. Some documents are held at a facility in Ward 2 operated by D.C.’s Office of Public Records, but that building was never intended for the purpose long-term. According to one DGS report, “physical and mechanical deficiencies prevent proper care and preservation of the historical records” at the site.
Architectural designer and historian Neil Flanagan, who has used city records extensively for a long-running project about how the District wiped out a thriving Black community in Northwest, describes the current archives building more bluntly.
“The facility is a dump,” he said in an interview. “It’s really inadequate.”
Plans to build a new home for the District’s records have been in the works for over a decade, stalled largely by funding issues. The city chose an architecture firm, Hartman-Cox, in 2015, but it took several more years for the project to get the money it needed.
Flanagan said that even once the Council committed new funding, DGS never fully updated the objectives and requirements for the design.
“DGS has basically been working off the same contract since 2015, and a lot has happened, particularly in the climate world, since 2015,” said Flanagan. “When they issued the contract for design services [in 2022], they took a contract that was clearly written in 2018. … It had the wrong budget in it.”
Moving Forward With a Fossil Fuel Plan — For Now
The Department of General Services presented the designs by Hartman-Cox to the Zoning Commission in September of this year. The commission approved the plan — which also requires the demolition of a big building on UDC’s campus — in October, a few weeks after the new law requiring government buildings to meet net-zero standards had gone into effect.
Both the Office of Planning and the Department of Energy and Environment submitted comments to the Zoning Commission cautioning that the current design would violate the Greener Government Buildings Amendment Act. In its response, DGS argued that it was still figuring out if the new law would apply to them, and that the Archives building presents unique challenges to meeting the net-zero standards.
Storing archival records safely requires a lot of energy, because the documents have to stay at very consistent temperatures and humidity levels 24/7. The D.C. Archives plans for achieving LEED Gold status include emissions reduction strategies like putting solar panels on the roof, installing LED lighting and using good insulation to increase energy efficiency, among other things.
However, LEED Gold is not the same as net-zero, which is the standard required by the new law. The building’s limited space and high energy requirements make it impossible to provide enough energy using rooftop solar or geothermal wells, DGS representatives said during the meeting.
Burt Jackson, an outside consultant serving as project executive for DGS, said during the presentation that using gas boilers would be more energy efficient than the electric options the design team had considered.
However, advocates pointed out that none of the DGS representatives mentioned air-source heat pumps — the most common form of electric heating and cooling — during the presentation or in its earlier comments to the Zoning Commission. Asked about heat pumps by Council member Matthew Frumin, Jackson did not provide specifics, saying they “were considered” but “did not win the race.”
“Air-source heat pumps were considered during the design phase and [were] found to be inadequate for the needs of a building,” DGS said in its emailed statement. “In such spaces, atmospheric levels must be carefully maintained year-round, as to not risk damage to precious and irreplaceable documents and objects.”
In order to move on to construction, the Archives’ design will need to get permits from several other District agencies. Failing to comply with the Greener Government Buildings Amendment Act, Flanagan said, could risk a permit denial by the Department of Buildings.
DGS, which said it’s still working to figure out if the legislation applies to this building and others, also argues that the project has prioritized sustainability. The design is set to meet LEED Gold standards, which is the third out of four tiers in the sustainable construction rating system.
“The project team is actively implementing strategies to reduce the carbon footprint of the project,” the agency wrote in a statement. “This includes reviewing alternative materials to reduce the project’s carbon footprint, specifying concrete mixtures that lower the carbon emissions, and writing specifications requiring an environmental product declaration (EPD) for building materials.”
Flanagan, who worked on multiple net-zero buildings during more than 10 years in the architecture field, said that he recognizes that fully achieving net zero for the building might not be feasible. Safe record-keeping does pose energy challenges that other buildings don’t have to deal with.
But Flanagan also said the design contract does not include funding for any analyses that would enable DGS and the architecture firm to explore all options for further improving energy efficiency and reducing the building’s carbon footprint. He said that the contract hadn’t been updated to account for “a revolution” in archival sustainability practices over the last decade.
“They tried nothing and they’re all out of ideas,” Flanagan said in an email after the roundtable, writing specifically of the agency’s plans for heating and cooling the building. “DGS’s explanations at the hearing was banalities and mumbo jumbo.”
Broader Transparency Issues Lead to Further Environmental Concerns
The D.C. Archives project has faced repeated criticisms about a lack of transparency and lackluster engagement with neighbors and students. Some community members remain staunchly opposed to the demolition of the current building on the site and the location of the Archives on UDC’s campus at all. The reasons for opposition vary, but environmental issues feature on the list.
“DOEE brought this point up in their comments to the Zoning Commission — demolishing a building and building an entirely new one is the most environmentally destructive option,” said Kesh Ladduwahetty, a volunteer at UDC’s organic garden who lives a short walk from campus, in an interview. “Why build it on this site… when you could build it somewhere where you don’t have to demolish a structurally sound building?”
The D.C. Council also created an advisory group specifically for the D.C. Archives project in 2021. By statute, the group is supposed to “have access to all draft and final documents relevant to planning.” But former National Archives head Trudy Huskamp Peterson, who now chairs the advisory group, noted in her testimony that she had yet to see several important documents scheduled to come out in the fall, including the building’s LEED Gold registration and an environmental impact screening.
“At this stage in the Archives’ design and development process, DGS’s plans for environmental performance should be more clear,” a former member of the Archives Advisory Group, Caroline Pettie, said at the roundtable. “But to a large extent, they remain a mystery.”