T&E Item 4
February 26,2014
Worksession
MEMORANDUM
February 24,2014
TO:
FROM:
SUBJECT:
Program
Transportation, Infrastructure, Energy and Environment Committee
Robert H. Drummer, Senior Legislative Attorney
~
Worksession: Bill 7-14, Contracts and Procurement - Certified Green Business
Expected Attendees:
Bonnie Kirkland, County Executive Office
Eric Coffman, Department of General Services (DGS)
Grace Denno, DGS
Pam Jones, DGS
Bill 7-14, Contracts and Procurement - Certified Green Business Program, sponsored by
Councilmembers Berliner, Floreen, Riemer, Council President Rice, and Councilmembers EIrich,
Andrews, and Navarro, was introduced on January 28, 2014. A public hearing was held by the
Committee on February 11.
Bill 7-14 would create a preference for a certified green business in the law governing the
County's procurement of goods and services. It would also require the Executive to adopt a
regulation implementing the preference for a certified green business.
Background
The Department of Environmental Protection has developed a green business program
where it certifies businesses that satisfy a checklist of required actions. However, there is no
direct financial incentive for a business to be certified. This bill would provide a potential direct
financial incentive for a green business that bids on County contracts. The Bill would encourage
businesses to develop strategies for protecting the environment in their day to day operations.
Councilmember Berliner explained the purpose of this Bill in his January 14 memorandum
describing his proposed energy/environmental measures. See ©5 of Bill 4-14, T &E Item 1.
The Fiscal and Economic Impact statement for this Bill will be transmitted after March
17 (see ©6).
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Public Hearing
Assistant CAO Bonnie Kirkland, speaking on behalf of the Executive at the February 11
public hearing on Bill 7-14, generally supported the Bill. See ©7. The Executive committed to
working with the Council to "develop the most progressive and reasonable legislation achievable
that will balance both the compelling need to achieve sustainable development and the budgetary
realities faced by the County and our local businesses ... " We have not yet received specific
comments on this Bill from the Executive.
Whitney Cooper, testifying on behalf of Elysian Energy, a certified green business,
supported the Bill. (©8) Gigi Godwin, testifying on behalf of the Montgomery County
Chamber of Commerce, opposed the Bill because a percentage price preference for a certified
green business could result in a responsive, responsible low bidder losing a County contract.
(©9-11) Ms. Godwin suggested using green certification as a tie breaker in a request for
proposals that is not based on price alone. Melanie Santiago-Mosier, testifying on behalf of
WGES, also opposed using the percentage price preference for a certified green business. (©12)
Issues
1. What is the fiscal and economic impact of the Bill?
OMB and Finance requested an extension of time to submit a fiscal and economic impact
statement. They do not expect to submit it until after March 17. The fiscal impact of this Bill
would depend on the need for additional staffing resources to administer the program and the
incremental cost paid by the County for awarding a contract to a certified green business that
does not submit the lowest bid.
2. Should the Bill require a percentage price preference for a certified green business?
County procurement often struggles with competing purposes. First, the County has an
obligation to County residents to obtain the best goods and services from contractors for the best
possible price. This is often served by establishing an open competitive process for the award of
a County contract. The County sometimes, attempts to use its contracting dollars to serve a
different public purpose.
For example, the County has a Local Small Business Reserve Program that reserves
certain contracts for local small businesses. The County Procurement Law also has a Minority
Owned Business Program. The County enacted a Prevailing Wage Law that requires a County
construction contractor to pay at least the prevailing wage set by the State. The County also has
a Wage Requirements Law requiring most service contractors to pay all employees working on a
County service contract at least a living wage, currently set at $13.95 per hour. The Council is
also considering a bill to provide a local business preference for tie bids (Bill 13-14) and a bill to
require service contractors to provide employees subject to the living wage with affordable
health insurance (Bill 14-14).
2
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Each of these procurement laws supports a strong public policy, but also conflicts with
the County's overall obligation to obtain the best goods and services for the best price. The
resulting procurement system is complicated and sometimes slow.
It
can be difficult to navigate.
Without a fiscal and economic impact statement,
it
is difficult to assess how much Bill 7-14
would add to the complexity of the County procurement system. However, each new
procurement preference adds an incremental layer of complexity.
This packet contains:
Bill 7-14
Legislative Request Report
OMB and Finance Memo
Testimony
Bonnie Kirkland
Whitney Cooper
Gigi Godwin
Melanie Santiago-Mosier
Circle
#
1
5
6
7
8
9
12
F:\LAW\B ILLS\ 1407 Contracts And Procurement - Certified Green Business Program\T&E Memo. Doc
3
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Bill No.
-:----=---:~=___:__=_--___:_
Concerning: Contracts and Procurement
- Certified Green Business Program
Revised: January 15, 2014 Draft No.
L
Introduced:
January 28,2014
Expires:
July 28, 2015
Enacted: _ _ _ _ _ _ _ _ __
Executive: _ _ _ _ _ _ _ __
Effective: _ _ _ _ _ _ _ _ __
Sunset Date:
-!.!N~on~e~
_ _ _ _ __
Ch. _ _, Laws of Mont. Co. _ __
COUNTY COUNCIL
FOR MONTGOMERY COUNTY, MARYLAND
By: Councilmembers Berliner, Floreen, and Riemer, Council President Rice, and Councilmembers
EIrich, Andrews, and Navarro
AN
ACT to:
(1)
(2)
(2)
create a preference in the procurement of goods and services by the County for a
certified green business;
require the County Executive to adopt a regulation implementing the preference for
a certified green business; and
generally amend the law governing the County's procurement of goods.
By adding
Montgomery County Code
Chapter
11
B, Contracts and Procurement
Article XVII
Section IIB-77
Boldface
Underlining
[Single boldface brackets]
Double underlining
[[Double boldface brackets]]
* * *
Heading or defined term.
Added to existing law by original bill.
Deletedfrom existing law by original bill.
Added by amendment,
Deletedfrom existing law or the bill by amendment,
Existing law unaffected by bill,
The County Council for Montgomery County, Maryland approves the following Act:
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BILL
No.
7-14
1
2
3
4
Article XVII is added to Chapter lIB as follows:
Article XVII. Certified Green Business Prog;ram.
IIB-77. Certified Green Business Program.
ill)
Definitions.
In this Article the following tenns have the following
5
6
meanmgs:
Certified green business
means
~
business accepted as
S!
green business
7
8
9
Qy
the Department of Environmental Protection.
Director
means the Director of the Department of Environmental
Protection or the Director's designee.
Green
business
means
S!
10
11
12
13
forward-looking
business
that
has
demonstrated innovative environmental responsibility
Qy
embedding
issues of sustainability into its day-to-day operations and supply chain
decisions.
Green business evaluation factor
means an evaluation factor in
~
14
15
request for proposals that gives an offeror credit for being
S!
certified
green business.
Percentage price preference
means the percent
Qy
which
S!
responsive
bid from
~
16
17
18
19
20
responsible bidder who is
~
certified green business may
exceed the lowest responsive bid submitted
Qy
S!
responsible bidder who
is not
S!
certified green business.
21
22
23
24
25
®
Regulation.
The County Executive must adopt
S!
regulation under
Method
~
that includes:
ill
ill
S!
checklist of required actions necessary for
S!
business to be
certified as
S!
green business;
an application process for
S!
business to be certified as
business;
~
green
26
0f:\laW\biUS\1407 contracts and procurement - certified green business program\bill
2.
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BILL
No.
7-14
27
ill
(±}
£!
percentage price preference for
£!
certified green business under
£!
solicitation for competitive sealed bidding;
£!
green business evaluation factor for use
In
28
29
30
a request for
proposals; and
31
32
33
34
35
ill
(£)
£!
list of approved private organizations and government agencies
that provide green business certification.
Certification.
The Director may:
ill
ill
directly certifY
£!
business that satisfies the checklist of required
actions established
Qy
regulation as
£!
green business; or
accept the green business certification of
£!
green business
Qy
any
private organization or government agency that the Director finds
substantially complies with the standards in applicable County
regulations.
36
37
38
39
40
@
Role Qj Qffice Qj Procurement and Department Qj Environmental
Protection.
41
42
ill
The Office of Procurement must review all specifications of each
using department and each cooperative purchasing agreement to
assure compliance with this Section, appropriate use of
£!
percentage price preference or
£!
green business evaluation factor,
and consistency among using departments procuring similar
goods and services.
43
44
45
46
47
48
49
ill
The Department of Environmental Protection must operate the
green certification process and maintain
E!
list of businesses that
have been certified as
£!
green business.
50
51
W
Report
f2J!.
Qffice Qj Procurement.
The Director of the Office of
52
53
Procurement, after consulting the Director of Environmental Protection,
must submit
£!
report to the County Council and County Executive
Qy
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BILL
No.
7-14
54
55
56
57
58
59
60
61
62
63
64
65
66
67
Approved:
September 30 each year on implementation of this Section for the prior
fiscal year. The report should include:
ill
ill
the dollar value of goods and services purchased from
green business;
~
certified
to the extent ascertainable, the additional 'cost of any contracts
awarded to
preference;
~
certified green business under
~
percentage price
ill
~
summary of applications for certification as
~
green business
made during the year, including the results of each application;
ill
ill
®
~
list of certified green businesses;
suggested legislative or administrative changes; and
any other relevant infonnation.
Craig
L.
Rice, President, County Council
Date
68
Approved:
69
Isiah Leggett, County Executive
Date
70
This
is
a correct copy ofCouncil action.
71
Linda M. Lauer, Clerk ofthe Council
Date
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LEGISLATIVE REQUEST REPORT
Bill 7-14
Contracts and Procurement Certified Green Business Program
DESCRIPTION:
PROBLEM:
This Bill would create a preference for a certified green business in
the County's procurement regulations.
The Department of Environmental Protection has developed a green
business program where
it
certifies businesses that satisfy a checklist
of required actions. However, there is no direct financial incentive
for a business to be certified. This bill would provide a potential
direct financial incentive for a green business that bids on County
contracts.
The goal is to encourage businesses to develop strategies for
protecting the environment in their day to day operations.
DEP, DGS, County Attorney
To be requested.
To be requested.
To be requested.
To be researched.
Robert H. Drummer, 240-777-7895
To be researched.
GOALS AND
OBJECTIVES:
COORDINATION:
FISCAL IMPACT:
ECONOMIC
IMPACT:
EVALUATION:
EXPERIENCE
ELSEWHERE:
SOURCE OF
INFORMATION:
APPLICATION
WITHIN
MUNICIPALITIES:
PENALTIES:
None
F:\LAW\BILLS\1407 Contracts And Procurement - Certified Green Business Program\LEGlSLA TIVE REQUEST REPORT. Doc
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ROCKVIlLE, MARYlAND
MEMORANDUTv1
Fcbrunry 5, 2014
10;
FROM:
Craig Rice, fr'sidcflt, County Council
,
/
Jennifer
A.
,ri:,
Qjllce of Management and Budget
Joseph F.
B~n(;l, D~
partmcnt of Finance
\J
/
SUBJECTS:
8iIl2-14. Environmetltal
Sustainability - Buildings .-. Benchmarkillg
BtllJ-! 4, Buildings . . . Energy Efficiency ·····Energy Standards
Bill 4-14. Street and Roads County Street Lights
Bill 5-14, Environmental Sustainabillty ..... Social Cost of Carbon Assessments
Bill 6-14, Environmental Susta.inability - Office of Sustainability - Established
BiU 7-14, Contracts and Procurement - Certif1ed Green Business Program
Bill 8-14, Buildings -- County Buildings .... Clean Energy
Renewahle
Technology
Bill 9-
J
4, Environmental Sustainability --Renc\,l,'able Energy -- County Purchase
Bill 10-14, Buildings -. Solar Permits .... Expedited Review
Bill 1,-; 4, Buildings .... Electric Vehicle Charging Station Permits Expedited
Review
As required
by
Scction
2-81A.
ofthe County Code, we
an:
infbrming
you
that transmittal
of
the fiscal and econmnic impact statements for the above referenced legislation will be delayed
because more time is needed to coordinate with the affected
departHlents,
collect information, and
complete our analysis of the I1scal and economic impacts. While
\Ve
an: not able to conduct the
required detailed analyses at this time,
.it
is clear that a number of these bHls could have significant
fiscal impacts.
Due to this
year's heavy workload on Executive branch staff in developing both a full capital
budget and an operating budget. the fiscal and economic statements \evill be transmitted
after
March
17,20]4.
JAH:fL
cc: Bonnie Kirkland, Assistant Chief Administrative Officer
Lisa Austin, Offices of the County
Exectl1ive
Joy
Nurmi, Special Assistant to the
County
Executive
Patrick Lacefield, Director, Publk Information Oflice
Marc P. Hansen, Office of the County Attorney
Robert Hagedoorn,
Department of Finance
David Platt. Department of Finance
Alex Espinosa,
Office
of
Management
and Budget
Mary'
Beck, Office of Management
and Budget
Naeem I'vlia, Office of Managernent and Budget
Felicia Zhang, Office of Management and Budget
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I
TESTIMONY ON BEHALF OF COUNTY EXECUTIVE ISIAB LEGGETT
ON ENVIRONMENTAL AND SUSTAINABILITY PACKAGE
Bills 2-14,3-14,4-14,5-14,6-14,7-14,8-14,9-14,10-14, 11-14, 12-14
February 11, 2014
Good evening Council President Rice and members of the County Council. My name is Bonnie
Kirkland and I am pleased to be here on behalf of County Executive Isiah Leggett to testify on
the package of environmental and sustainability measures introduced on February 4, 2014 by
Councilmember Berliner and others. Mr. Leggett supports Councilmember Berliner's initiative
and the Council's efforts to address the need for more sustainable development in Montgomery
County. Following up on recommendations from the Sustainability Workgroup, this package of
renewable energy, energy efficiency and sustainability measures will take the County to the next
level of environmental excellence.
Sustainable development has been defined as meeting the needs of the present without
compromising the ability of future generations to meet their own needs.
l
The path forward
requires understanding and planning: understanding how existing buildings perform and how
planned buildings are expected to perform; and designing buildings and other infrastructure that
reduce materials consumption, reuse materials, reduce energy consumption and maximize the
use of renewable resources.
County Executive Leggett recognizes that the path forward will involve substantial change and
commitment on the part of both the public sector and the private sector. He is committed to
working with the Council on this package during the coming weeks to develop the most
progressive and reasonable legislation achievable that will balance both the compelling need to
achieve sustainable development and the budgetary realities faced by the County and our local
businesses to fully implement the approved changes the legislative package requires.
Stewardship for future generations has been a cornerstone of Mr. Leggett's Smart Growth
Initiative in terms of planning for future growth at appropriate transit oriented locations. The
County Executive applauds Councilmember Berliner's and the sponsoring council members'
vision and recognition of the need for stewardship of our precious resources for future
generations.
1
International Institute for Sustainable Development quoting from the World Commission on Environment and
Development (WCED).
Our common future.
Oxford: Oxford University Press, 1987 p. 43.
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\\
Testimony; Public Hearing February I I, 2014
Whitney Cooper from Elysian Energy testifying in support of Bill 7-14. Contracts and
Procurement - Certified Business Program
I support Bill
14 Contracts and Procurement - Certified Business Program. My company,
Elysian Energy, helps the environment by reducing energy use for homeowners and
businesses. We became a Certified Green Business so that our internal practices match
our external practices of reducing energy and waste. The process of obtaining this
Certification was stringent. We realized our company needed to do more to prove
ourselves worthy of the Certification and ended up changing many processes in our day-to­
day operations in order to improve our environmental impact.
We created a Green team
that is still implementing ways to reduce energy use and waste in our business practices.
Those practices have the additional benefit of translating into our personal lives. We are
not only a green business we have now become a green community. We were truly proud
to have received our Green Business Certification. When trying to identify Green
businesses in Montgomery County, the Certified Green Business Program is a great place
to start, as it is a ready made and legitimate benchmark.
This Bill would give preference to companies like ours that are actually walking the walk as
well as talking the talk in protecting the environment and reducing energy use. Giving
oversight to all companies that claim to be "green" is necessary so that companies don't
use that as a marketing technique when they actually aren't doing anything to improve the
environment.
I support this Bill so that more companies like ours will make efforts to improve their
environmental practices in order to get preference for upcoming bids.
Thank you for your time and for giving us the opportunity to speak at this hearing.
It)
Elysian Energy
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z
THE VOICE OF MONTGOMERY COUNTY BUSINESS
MONTGOMERY COUNTY COUNCIL
PUBLIC HEARING
BILLS 2-14 THROUGH 12-14
FEBRUARY 10, 2014
As a Chamber of Commerce that recognizes the economic and environmental imperative of
greening the way we do business, we commend the County Council for the intent of this package
of bills. We believe that positioning our county as a place to do green business is a compelling
competitive advantage in to day's marketplace. Supporting a green infrastructure is critical, as is
growing the number of green jobs that are created to meet the needs of the new marketplace.
There are, however, areas of concern with regard to the package. Below are specific comments on
a few of the bills. Broadly speaking, the fiscal impact statements will likely address the costs
associated with the various activities. It will be important to review these so as not to impose
undo burden as we try to move the marketplace. Where possible, incentives should be deployed
to encourage adoption of new practices and attainment of environmentally sustainable goals. We
would also like to see these bills work in concert with other county regulations so there is not
confusion in following or enforcing the regulations.
We see green as part of a larger economic development strategy for the county. The Green
Business Certification program is a terrific example of the business community working in
partnership with the Department of Environmental Protection and Montgomery College to
achieve environmental goals through a voluntary program. We look forward to working with you,
the County Council, to make sure this package is able to realize the stated intention of addressing
climate change at the local level to the greatest extent possible.
Comments on specific bills:
Bill 7-14 Contracts and Procurement -Certified Green Business Program
We applaud the County Council for recognizing the Montgomery County Green Business
Certification Program and finding ways to incentivize those companies interested in working with
the county to participate. We encourage the county government - or units within it - to become
"Green Certified" and to green its own supply chain by using environmentally preferable
purchasing of products and practices where appropriate. There is a green procurement bill
requested by DGS (HB 629) pending at the state which could serve as a guide.
According to the information provided by the Council staff, "The goal is to encourage businesses to
develop strategies for protecting the environment in their day to day operations." If the goal is
Gigj Godwin, President and CEO
Montgomery County Chamber of Commerce
51 Monroe Street, Suite 1800 Rockville, MD 20850
301-738-0015
www.montgomerycountychamber.com
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indeed to encourage more businesses to adopt green practices internally (such that they can be
certified by Montgomery County or another comparable entity), the county may also want to
explore using one or more of the many tools available outside of the county procurement process
and appropriate to all businesses to incentivize that initiative.
Coincidentally, there is also a bill in the General Assembly that focuses on creating Green Business
Incentive Zones (HB 473/SB 787) which also encourages the growth and success of this new
market player by offering incentives such as tax credits.
This bill, as drafted, uses the procurement process and the opportunity to gain preference as an
incentive. The procurement process is complex. Any modification to that process should be to
make it easier to do business with the county. We are concerned that by restricting the language
to "percentage price preference" companies that do have the right products or services
l
but have
not met the green business certification preference, may be at a disadvantage that ultimately
undermines the overall effort to reduce our collective ecological footprint. Therefore, we suggest
reviewing the ways that the procurement process can be used effectively, perhaps by including
green certification in the evaluation criteria or as a "tip over." This may more effectively
encourage companies to green themselves without inadvertently making the procurement
process more cumbersome and ultimately counter-productive in meeting the goal. It is worth
noting that "percentage price preference" language was struck from HB 629 mentioned above.
Bill 2-14. Environmental Sustainability - Buildings - Benchmarking
To the extent that buildings are a critical piece of the climate puzzle, it is important to understand
energy usage and work to conserve where we can. That being said, we encourage the Council to
look to federal regulations as many tenants in the county are federal offices or contract with the
federal government. Therefore, any new requirements for owners and/or tenants should conform
to federal standards.
Second, we firmly believe that if the county requires benchmarking of private property owners,
the county must be able to participate in the program as well. Taxpayers should know the
efficiency of the buildings they are paying to operate. Last, for those older buildings that will be
among the least efficient, the program must provide some process to help with mitigation,
whether it be providing priority for county programs or other education and
in~entives
to address
problems.
'
Bill 5-14, Environmental Sustainability - Social Cost of Carbon Assessments
It is unclear, based on our reading of this bill, how the EPA method that was developed for
regulations/legislation would be applied to Capital Improvement Projects or energy efficiency
improvements in generaL It is also unclear how information gleaned from the calculation would
be used to reach any conclusion on the viability of a project.
Gigi Godwin, President and CEO
Montgomery County Chamber of Commerce
51 Monroe Street, Suite 1800 Rockville, MD 20850
301-738-0015
ww\v.montgomerycountychamber.com
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Bill 6-14, Environmental Sustainability - Office of
Sustainability
-
Established
Based on the bill as written, this new office would record and manage the county's greenhouse gas
emissions. We see Montgomery County's position as a leader in sustainability as a driver of
economic development. We therefore believe that this effort should include an economic
development component as well as clear coordination with the extensive land use and
transportation work that happens throughout the county government and with Park and
Planning. In addition to producing an annual report, there should be some demonstrable gain to
county taxpayers to justify the creation of a new office, which will require additional staffing and
new responsibilities.
With regard to the remaining bills that are part of this package, we would encourage Council
Members to be mindful of hidden costs and unintended consequences that may arise from the
adoption of some of these bills: We hope that the fiscal impact statement will speak to some of
these and that the committee work sessions will be constructive and produce useful information.
As mentioned at the outset, we see green as part of a larger economic development strategy for
the county. We look forward to working with you to make sure this package is able to realize the
stated intention of addressing climate change at the local level to the greatest extent possible.
Gigi Godwin, President and CEO
Montgomery County Chamber of Commerce
51 Monroe Street, Suite 1800 Rock-ville, MD 20850
301-738-0015
wwvv.montgomerycountychamber.com
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Washington Gas
Energy Services
A Washington Gas Affiliated Company
Comments of Washington Gas Energy Services, Inc.
on
Bill No. 7-14 - Contracts and Procurement - Certified Green Business Program
Montgomery County Council, February 11, 2014
Washington Gas Energy Services, Inc., (WGES) is grateful for the opportunity to submit these comments on
Bill No. 7-14 - Contracts and Procurement - Certified Green Business Program.
WGES is one of the largest competitive providers of electricity and natural gas in the mid-Atlantic regionand
supplies nearly 350,000 residential, commercial, and governmental customers in Maryland, Virginia, Delaware,
the District of Columbia and Pennsylvania. WGES has a strong commitment to the environment. In addition
to the variety of wind energy products that we offer under our CleanSteps® WindPower brand) and the options
we offer with our CleanSteps® Carbon Offsets
2,
WGES and its sister company, Washington Gas Energy
Systems, have partnered with local companies to develop numerous solar projects in Maryland.
WGES was named by the US Department of Energy as the Green Power Supplier of the Year in the non-utility
category in 2011, and in 2013 WGES won the District of Columbia Mayor's Sustainability Award. In 2007,
County Executive Leggett recognized WGES for our involvement in the Montgomery County Clean Energy
Rewards Program. Internally, WGES is focused on reducing its environmental impact with initiatives such as
sustainable printing, telecommuting, volunteering for and supporting tree plantings, and obtaining LEED
certification for its headquarters.
WGES appreciates and supports the important public policy goal of encouraging businesses to adopt
sustainability practices. However, WGES has some concerns about this bill as introduced. As an initial matter,
WGES is concerned about creating a percentage price preference as the chosen means for encouraging
businesses to "go green." Creating a procurement set-aside of"this type requires careful thought, as it creates a
procurement preference based on one set of criteria ("green"), while potentially downpJaying other important
criteria (general qualifications, experience, financial integrity, etc.). Further, WGES asks for clarification that
the legislation would not exclude businesses not located in Montgomery County from becoming certified as a
green business. Additionally, WGES is concerned that any certification requirements not be so onerous as to
impose burdensome costs on companies that seek certification.
Thank you for the opportunity to share our perspective on Bill No. 7-14.
Melanie Santiago-Mosier
Director, Regulatory
&
Legislative Affairs
Washington Gas Energy Services, Inc.
13865 Sunrise Valley Dr., Suite 200
Herndon, VA 20171
703-793-7565
mmosier(Q)wges.com
All WGES residential customers receive 5% of their electricity generated from regionally located wind power, while all
WGES commercial customers receive 3.5% of their electricity from regionally located wind power, amounts that are above
and beyond Maryland's RPS requirements. Additionally, customers may choose to add more wind power to the electricity
that is supplied to them by WGES.
2
All standard natural gas offers include a baseline 5% carbon offsets match. Customers may choose natural gas matched
with 100% WGES CleanSteps® Carbon Offsets. Through our partnership with the Chesapeake Bay Foundation, WGES
CleanSteps® Carbon Offsets support new and existing local projects that help reduce the emission of harmful greenhouse
gases
in
the environment.
1
13865 Sunrise Valley Drive, Suite 200, Herndon. VA 20171 Tel: 703-793-7500 Fax: 703-793-7301
@