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The AIA Corporate Architects and Facility Management (CAFM) Knowledge Community consist of architects working within and for businesses and corporations. Our mission is to share expertise in the strategic, tactical, and operational activities of real property and facilities management in order to deliver value to the owners we represent. 

AIA response to DOE RFI on commercial building energy asset score

  • 1.  AIA response to DOE RFI on commercial building energy asset score

    Posted 03-12-2013 04:51 PM
    This message has been cross posted to the following Discussion Forums: Committee of Corporate Architects and Facility Management and Regional and Urban Design Committee .
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    All, this week, the AIA sent comments with regard to the US Department of Energy's request for information concerning commercial building energy asset scores. Given the advent of several high performance building and energy codes (Cal Green, IgCC, etc.), local building energy performance regulations, and voluntary programs (LEED, Energy Star), not to mention the fate of the latest CBECS during the Sequester and beyond, measuring building energ use data and accessibility to such data, are becoming increasingly important. Following the AIA comments is the DOE's original request for information:


     

    March 11, 2013

    Mr. Roland Risser

    Building Technologies Program (BTP)

    U.S. Department of Energy

    Mail Stop EE-2J 1000 Independence Ave, SW Washington, DC 20585

    Re: Commercial Building Asset Score RFI Response

    Dear Mr. Risser:

    Thank you for the opportunity to respond to this request for information (RFI) on the commercial building asset score tool. The American Institute of Architects commends the Department of Energy for its continued commitment to the design of sustainable, high performance facilities and for being a leader in the development of tools that make the design of these buildings more commonplace.

    AIA architects have long led the effort to design, build and renovate commercial buildings that are not only energy efficient and sustainable, but also provide the best possible value to their owners. More recently, the development of sustainable rating systems, performance tracking, and universal codes and standards have made possible even larger strides in energy efficient design and construction..

    The AIA supports the development of this asset score tool and believes that it can be a useful driver of energy efficiency in commercial buildings. As the DOE continues to develop this tool to measure building performance, the AIA has highlighted a few areas that should be examined before the tool is placed into the market. Specifically, DOE should consider current industry efforts that aim to consolidate common metrics for high performance design; the tool's interaction with codes and standards; building types and occupancy factors; and the role that design teams play in the creation and maintenance of high performance buildings.

    High Performance Universal Metrics

    The AIA is aligned with other industry partners in its belief that there needs to be more consistency across the industry in the use of ratings and metrics. Although industry-wide development of new technologies and systems is necessary and exciting, the variety and number of these efforts highlight the need for defining a set of universal metrics. Page 2

    The National Institute of Building Sciences is working with many industry partners, including DOE, to define universal high performance metrics. The AIA urges DOE to continue this work to ensure that there is a universal understanding of "high performance" standards and metrics. The AIA believes that there needs to be more consistency across the industry in the use of ratings and metrics, and that DOE has an opportunity in this tool to start encouraging greater uniformity.

    Alignment with Codes and Standards

    Generally, the commercial building asset score reflects many of the factors that AIA believes are necessary to properly score a building's performance. However, it is unclear how this tool intends to interact with advanced building codes, including energy codes, and the International Green Construction Code (IGCC). As more jurisdictions adopt such codes, and in some cases "stretch codes," the need for clear alignment will become greater.

    For example, the current asset score energy scale does not align with the IGCC. The IGCC rates energy efficiency in the exact opposite way of this scale, with 0 equaling net zero (maximum efficiency) and 100 equaling the energy efficiency level of the 2000 IECC (minimally efficient). The discrepancy between scales could become confusing as architects and other building professionals work with both scales.

    In addition, it appears this tool will use Portfolio Manager to identify the national conversion factors for site-to-source power. The metric conversion data used in the IGCC, however, is E-Grid, not Portfolio Manager. The AIA would suggest that a useful next step would be to evaluate and potentially align the Portfolio Manager figures with those in the IGCC.

    Building Type and Use

    It is important to take a holistic approach to buildings' varying design and use when creating a score based on such a large cross-section of the built environment. Healthcare facilities and laboratories will be scored very differently than a typical office building. Similarly, if the score does not take into account external factors like siting and landscaping, buildings designed to take advantage of these factors will be disadvantaged. Occupancy and operational factors also should remain a factor to consider as score formulations are finalized.

    Additionally, although the current reference to building types in the score report is acceptable, the AIA would suggest including as additional categories building construction type; the building code under which the building was constructed; and the occupancy types related to the building code. Page 3

    Role of Design Professionals It is important that building owners and managers rely on the assistance of licensed design professionals when they make building retrofit decisions. Often, a design-centered, holistic approach to a retrofit, led by an architect who considers all the interactions in a building's systems, can yield substantially higher energy savings than a system-by-system approach. The architect's deep understanding of the building envelope, as well as its programming and use, can lead to substantial load reductions that may allow the building owner to downsize mechanical equipment.

    Additionally, deep energy retrofits usually require a high degree of collaboration between members of the project team. This requires a team leader who can direct the design and construction process and facilitate communications between the design and construction professionals and the owner. Architects are well-suited to fill this role, by having experience coordinating the work of an array of professionals to ensure that their work conforms to the overall design and performance goals of the project. Architects also are well practiced in translating the owner's project goals into specific programming and design plans, and have experience expressing technical ideas back to the owner. This is an especially important skill overseeing deep energy retrofits, because only the most sophisticated building owners will have a strong understanding of energy performance.

    Architects include construction administration services as a basic service in their practices and are familiar with coordinating and overseeing the implementation of system upgrades and replacement. As this asset score tool is further developed, the AIA is happy to serve as a resource to building owners and encourages DOE to develop a pathway to connect building owners interested in pursuing a retrofit to architects who are experts in this field.

    Conclusion

    In conclusion, the AIA applauds DOE on the development of this tool and

    appreciates the opportunity to provide our perspectives. The AIA will continue to evaluate the commercial building asset score tool and provide feedback from its members regularly. The AIA looks forward to continued work with the DOE and all stakeholders to advance policies that make the built environment more sustainable, resilient and vibrant.

    Sincerely,

    Andrew Goldberg, Assoc. AIA

    Managing Director, Government Relations





    Background on the Asset Score and RFI:

     The score provides information regarding the efficiency of a building's major energy consuming systems and is intended to enable greater understanding of building performance and potential savings.  Through the use of a free, on-line scoring tool, building owners and operators will be able to generate a score along with recommendations for how to improve the efficiency of their buildings.  The scoring tool applies standard assumptions about a building's operations (based on building type) in order to calculate a score that reflects the building's energy efficiency, not the behavior of its occupants. More detailed information concerning the scoring methodology and other program features are outlined in a document entitled "Commercial Building Energy Asset Score: Program Overview and Technical Protocol Version 1.0."  This Protocol document can be found at http://www1.eere.energy.gov/buildings/commercial_initiative/pdfs/energy_asset_score_technical_protocol_phase1.pdf.

     

    The RFI seeks input on the following specific program components:

    1. Data collection and validation;

    2. The asset score report (see sample score report attached to this

     email); and
     
    3. Score durability.

     

    The RFI provides an overview of the three program components. Additional detail on each of the three topics is provided in the Protocol document noted above.

     

    Pilot Test #2 in Late Spring 2013:

    DOE plans to continue to work with commercial building owners and operators to pilot test the score in 2013, as a follow-on to pilot testing done in 2012. During this testing period, DOE will continue to refine the program as well as conduct additional analysis to inform future program development.


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    Brett Rosenberg
    Director, Sustainable Practice
    The American Institute of Architects
    Washington DC
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