Friday, September 30, 2011

BOMA Responds to DOE's Planned Asset Rating Program for Commercial Buildings

On August 8, 2011, DOE published in the Federal Register (Vol. 76, No. 152, 48152-48158) its plan to develop a National Asset Rating Program for Commercial Buildings. As envisioned by DOE, the Rating Program would evaluate energy efficiency from a building's "as-built" characteristics and identify potential energy savings opportunities. Thus far, measured energy performance based upon utility bill history has been the dominant way to rate building energy performance. DOE believes their initiative would fill a hole created when utility bill history is missing or incomplete. DOE also believes there is a need to be able to distinguish whether energy use differences between similar buildings are associated with installed ("as-built") building systems or with operational choices. The Rating Program would enable building owners and others to directly compare the "as-built" energy performance of building systems among similar buildings, regardless of occupant behavior and building operation.

The Rating Program would have three components: (1) an asset rating system to compute building energy efficiency taking into account building characteristics including its design, envelope elements, HVAC system, lighting system, and service hot water system; (2) a web application (which would be included as a free on-line software tool) that would provide an energy rating to facilitate benchmarking; and (3) a tool in the software to assist building owners in identifying and analyzing potential energy savings opportunities.

DOE believes their Asset Rating initiative would be complementary to EPA's Energy Star Portfolio Manager, which provides only an operational rating. They expect to launch a pilot program beginning in 2012.

The DOE announcement specifically asked for industry input on their plan. On September 22, 2011, BOMA responded with a number of comments and recommendations. One of these, and one that I consider most relevant, was BOMA's questioning the real need for DOE's Asset Rating Program. In my view, this is the most salient point made by BOMA. We already have Massachussetts developing a program that includes an asset rating ("MPG Rating for Commercial Buildings: Establishing a Building Energy Asset Labeling Program in Massachussets"), along with California (under AB 758, for development of a "Building Energy Asset Rating System"). In addition, we have ASHRAE's BuildingEQ program that includes an asset rating. How many asset rating programs does the industry need? BOMA believes and I concur that the private sector voluntary marketplace is already meeting the commercial real estate industry's need for diagnostic tools to evaluate building energy efficiency and that serve as a market driver for identifying and implementing retrofitting opportunities. In these times of limited financial resources and the Solyndra fiasco, does DOE really believe this Asset Rating Program to be of critical importance to the industry? If DOE still insists on spending money, then I suggest they seriously consider spending it on bringing back the Commercial Buildings Energy Consumption Survey (CBECS) and expanding it to include many more buildings. This would be of much greater value to the commercial real estate industry and the many existing building energy performance rating systems that rely on CBECS data!

1 comment:

peter cashman said...

DOE appears to be so flush with taxpayer provided cash they can apparently afford to squander it on a mission already been accomplished by industry professionals? Makes one want to seriously consider joining the Tea Party..