1

2010

Winona Varnon, Senior Sustainability Officer

U.S. Department of Education

6/8/2010

U.S. 

Department 

of Education 

Strategic 

Sustainability 

Performance 

Plan
U.S. Department of Education Strategic Sustainability Performance Plan

June 8, 2010 

2

Table of Contents

Section 1 – Agency Policy and Strategy..................................................................................................3

Section 1 – Item 1: Agency Policy Statement...................................................................................3

Agency Policy..................................................................................................................................3

Highlights of Significant Successes and Challenges........................................................................3

Section 1 – Item 2: Sustainability and the Agency Mission.............................................................4

Section 1 – Item 3: Greenhouse Gas Reduction Goals.....................................................................5

Section 1 – Item 4: Plan Implementation.........................................................................................6

Section 1 – Item 5: Evaluating Return on Investment.....................................................................8

Section 1 – Item 6: Transparency .....................................................................................................9

Section 2 – Performance Review and Annual Update............................................................................9

Section 2 – Item 1: Summary of Accomplishments.........................................................................9

Section 2 – Item II: Goal Performance Review...............................................................................10

GOAL 1: Scope 1 and 2 Greenhouse Gas Reduction ..................................................................10

GOAL 2: Scope 3 Greenhouse Gas Reduction ............................................................................11

GOAL 3: Develop and Maintain Agency Comprehensive Greenhouse Gas Inventory .............13

GOAL 4: High-Performance Sustainable Design/Green Buildings.............................................14

GOAL 5: Regional and Local Planning.........................................................................................18

GOAL 6: Water Use Efficiency and Management ......................................................................18

GOAL 7: Pollution Prevention and Waste Elimination ..............................................................19

GOAL 8: Sustainable Acquisition ................................................................................................21

GOAL 9: Electronic Stewardship and Data Centers....................................................................22

GOAL 10: Agency Innovation......................................................................................................24

Section 3 – Agency Self-Evaluation ......................................................................................................25

Appendix 1: Acronyms and Abbreviations...........................................................................................30

List of Attachments

1. Sustainable Buildings Implementation Plan

2. Green Purchasing Plan

3. Electronic Stewardship Plan 
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Section 1 – Agency Policy and Strategy

Section 1 – Item 1: Agency Policy Statement

Agency Policy

It is the U.S. Department of Education’s (ED) policy to integrate sustainability1

• Comply fully with all relevant Federal, State, and local energy and environmental laws and 

regulations, including Executive Orders.

into our operations, 

facilities, and overall mission in such a manner to: 

• Consider environmental impacts when making planning, purchasing, and operating decisions.

• Work continuously to improve our environmental performance.

• Provide training to educate our employees and others working in ED office space to be 

environmentally responsible on the job.

• Establish environmental objectives and targets for performance, and conduct regular internal 

evaluations to determine progress. 

• Adhere to the waste management hierarchy (in order of preference): source reduction and

reuse, recycle/composting, energy recovery, treatment, and disposal.

• Work cooperatively with all of our stakeholders to further common environmental objectives.

Highlights of Significant Successes and Challenges

Over the past several years, ED has focused increased attention on its environmental impacts and 

has taken steps to address them through initiatives such as establishment of a green purchasing

program, development and implementation of an electronic stewardship plan ensuring procurement of 

Electronic Product Environmental Assessment Tool (EPEAT)-certified computers and monitors, and 

installation of energy efficient lighting and water efficient equipment. 

Because ED is a tenant in all of the buildings it occupies, and energy, water, and waste management 

services are all included in our leases and thus paid by the General Services Administration (GSA), we are 

not intimately involved in monitoring our energy, water, and waste services nor do we currently have 

major influence in affecting change in these areas. This relationship represents our greatest challenge in 

reducing energy use and associated GHG emissions, reducing water use, minimizing waste generation 

and increasing recycling. Our goal for the future is to work closely with GSA to monitor and affect 

change in these service areas.

ED has a number of projects in progress that further exemplify our commitment to incorporating 

sustainability in our activities, services, and mission:

 1 Executive Order 13514 (Federal Leadership in Environmental, Energy, and Economic Performance, October 5, 

2009) defines “sustainability” and “sustainable” as follows: to create and maintain conditions, under which 

humans and nature can exist in productive harmony, that permit fulfilling the social, economic, and other 

requirements of present and future generations.
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• While not required for ED, we are in the process of developing an environmental management 

system (EMS) that will serve to consolidate our environmental programs and procedures in one 

place and to help us proactively address our environmental footprint associated with our 

activities, products, and services. This sustainability plan will function in conjunction with and 

be driven by the EMS.

• ED is applying its Sustainable Buildings Implementation Plan to ensure that the use, 

maintenance, leasing, construction, and renovation of facilities are done in such a way as to save 

energy and reduce environmental impact. This is exemplified in several projects being 

conducted this year, including the renovation of the Mary E. Switzer Federal Building and the 

renovation of the cafeteria at the LBJ Federal Building.

• ED will host a Summit on Education for a Green Economy during calendar year 2010. The 

central question that the Summit seeks to address is what role does Education, particularly 

Higher Education, have to play in the transition to a Green Economy. The Summit will bring 

together leaders from higher education, business and industry, labor, government, and 

nongovernmental organizations (NGOs) to build shared visions and strategies for education’s 

role in creating a sustainable and green economy.

• For the first time, Environmental Literacy is included in the President’s Budget. Environmental 

Literacy is included in the “A Well-Rounded Education” component of the $1.0 billion fund for 

“Effective Teaching and Learning for a Complete Education.” A Well-Rounded Education is a $265 

million program, an increase of $38.9 million, or 17 percent, to consolidate seven current authorities 

and expand support for the subjects important to a complete curriculum, including history, the arts, 

foreign languages, environmental literacy, and economic and financial literacy.

Section 1 – Item 2: Sustainability and the Agency Mission

The overall mission of ED is to promote student achievement and preparation for global 

competitiveness by fostering educational excellence and ensuring equal access. In particular, ED seeks 

to: 

• Strengthen the Federal commitment to assuring access to equal educational opportunity for 

every individual;

• Supplement and complement the efforts of states, the local school systems and other 

instrumentalities of the states, the private sector, public and private nonprofit educational 

research institutions, community-based organizations, parents, and students to improve the 

quality of education;

• Encourage the increased involvement of the public, parents, and students in Federal education 

programs;

• Promote improvements in the quality and usefulness of education through Federally supported 

research, evaluation, and sharing of information;

• Improve the coordination of Federal education programs;

• Improve the management of Federal education activities; and

• Increase the accountability of Federal education programs to the President, the Congress, and 

the public.
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ED has identified a number of potential opportunities for integrating sustainability into its mission. For 

example, as part of our effort to assure equal access to education for all individuals, the Federal Direct 

Student Loan program will primarily be administered electronically, avoiding paper use and energy 

needed to physically transport applications. Additionally, ED foresees the need to hire up to 500 new 

FTE to accomplish its programmatic goals. Rather than build-out new office spaces for all of these 

additional employees, ED will explore alternative work environments such as telecommuting and use of 

satellite offices.

In an effort to improve scores for all students, distance learning opportunities will be considered so that 

students in remote areas do not need to travel great distances (and thus expend energy) to get a quality 

education. ED also commits to exploring other potential opportunities for integrating sustainability into 

our mission, including incorporation of provisions for sustainable building design in grants and loans 

targeted for infrastructure improvements at academic institutions and prioritizing grants to vocational 

schools and community colleges that offer curricula in “green” education programs.

Through the use of email and other communication means (described later in this document), ED 

employees are advised about opportunities to improve their environmental footprint both at work and 

home. Recent examples include a cell phone recycling campaign where during a two-week period ED 

employees contributed nearly 70 pounds of cell phones and accessories for recycling/reuse; distribution 

of SunWise bracelet-making kits (where the bracelet beads turn purple when exposed to the sun to 

remind kids to apply sunscreen) to employee children during “Take Your Son/Daughter-To-Work Day; 

and distribution of desk-side paper recycling boxes to further encourage individual employees to recycle 

waste paper. ED will continue to engage employees in similar efforts designed to further integrate 

sustainability in carrying out our mission. 

In developing our environmental management system (EMS), our initial plan will focus on four buildings 

in the Washington, DC metropolitan area that house the majority of ED employees – LBJ Federal 

Building, Union Center Plaza (UCP), Potomac Center Plaza (PCP), and Mary E. Switzer (MES) Federal 

Building (currently under renovation). In the future, our intent is to expand the scope of the EMS to 

include other Washington, DC offices, regional and field offices. Because ED leases all buildings from 

GSA, we are limited in our ability to define ED’s baseline and set goals for future improvements in critical 

areas such as water, energy, building design and construction, waste water management, and waste 

management. However, our strategy is to partner with GSA to gain the baseline data on ED’s 

environmental footprint as it relates to the buildings we occupy. 

Beyond working with GSA, the only other limitation that could inhibit or challenge our ability to increase 

sustainability would be existing federal requirements that could limit our ability to set conditions on 

grants and loans to ensure sustainable approaches are taken by grant/loan recipients. 

Section 1 – Item 3: Greenhouse Gas Reduction Goals

Draft V2 of the Federal Greenhouse Gas Accounting and Reporting Guidance (March 3, 2010) 

states that "[i]f an agency leases space from GSA or a private landlord and does not directly pay utilities, 

GSA is responsible for reporting the emissions associated with those utilities. If all agency space is leased 

in this manner, and the agency does not pay any energy surcharges, the agency is not required to report 

any related emissions.” At the time that ED submitted Scope 1 and 2 greenhouse gas reduction targets 

(in January 2010), we were paying utilities in two buildings and thus showed CO2 emissions for our 
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baseline and our 2020 target. At present, ED no longer occupies these buildings and will no longer 

include them in our inventory. 

In addition, while our January 2010 Scope 1 and 2 submission indicated emissions and targets for fleet 

vehicles, we have since concluded that we are exempt from these requirements because the majority of 

our fleet is considered law enforcement vehicles and the number of non-exempt vehicles is under the 

reporting threshold amount of twenty vehicles. Thus, our 2020 Scope 1 and 2 GHG emissions target 

becomes zero, which we’ve now already met by virtue of vacating the two aforementioned buildings

and being exempt from the fleet vehicle requirements. Nevertheless, as previously discussed, ED plans 

to work closely with GSA to understand baseline and set goals for reducing solid waste generation, 

energy, and water use in buildings where we are the primary tenant. We also plan to continue tracking 

fleet vehicle use of alternative fuels and reduction in use of petroleum. 

ED’s Scope 3 greenhouse gas emissions and targets are currently limited to employee commuting,

employee business air travel, contracted wastewater treatment, and operation of our shuttle bus 

system in the Washington, DC metropolitan area. Because transmission and distribution losses are tied 

to GSA-purchased energy and solid waste management services are contracted through GSA, GSA will 

account for any associated Scope 3 emissions in their targets. Our estimated total Scope 3 emissions 

equal approximately 5,808 mtCO2e. We are proposing a three percent reduction or 174 mtCO2e by 

2020. ED intends to achieve the Scope 3 reduction targets through a combination of increasing use of 

flexiplace and/or alternative work schedule (where appropriate) and encouraging the use of audio, 

video and web conferencing for certain meetings.

Section 1 – Item 4: Plan Implementation

The Department of Education will employ a variety of means to ensure that the Sustainability 

Plan is effectively implemented. First, ED will develop a Departmental Directive that will formalize the 

Sustainability Plan as Agency policy and will be communicated to all ED employees. The Directive will 

include at least the following sections as they relate to the implementation of the Sustainability Plan: 

applicability, definitions, responsibilities, procedures, and requirements. Second, ED is developing an 

environmental management system that will overlay the Sustainability Plan thereby helping to ensure

that the Sustainability Plan and its associated goals are appropriately planned, conducted, checked and 

revised accordingly. The specifics of plan implementation are described below:

a) Internal Coordination and Communication will be achieved through a combination of the 

following: Senior Officer meetings, Executive Officer meetings, periodic progress reports, staff 

meetings, ED newsletters, and connectED (Education’s intranet homepage), bulletin board 

postings, lobby displays (where ED is the major building tenant), and messages on closed-circuit 

television.

b) Coordination and Dissemination of Plan to the Field will be achieved primarily through means 

identified in (a) above. The majority of regional and field offices house primarily employees 

working for Federal Student Aid (FSA), Office for Civil Rights (OCR), and the Office of Inspector 

General (OIG). These employees will be reached through their senior management located in 

Washington, DC. The Sustainability Plan will be integrated into all existing ED Policy Directives, 

where appropriate, to ensure that the goals and tenants of the plan are implemented both at 

HQ and in the field.
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c) Leadership and Accountability will be incentivized by including appropriate measures in the 

performance standards for relevant Department staff, including the Senior Sustainability Officer

(SSO), environmental/energy manager, fleet manager, real property manager, facility manager, 

contracting officers, contracting officer representatives, and procurement officers.

d) Agency Policy and Planning Integration will be assured through the Department’s Office of 

Planning, Evaluation, and Policy Development (OPEPD). OPEPD’s key responsibilities are to 

develop and review ED policies, perform measurement and evaluation, and develop budget 

processes and proposals. In so doing, OPEPD coordinates the review of Department-wide 

policies to ensure consistency with the Secretary’s guidance and the Administration’s goals.

e) Agency Budget Integration also will be performed by OPEPD and the budget office housed 

therein. 

f) Methods for Evaluation of Progress will be developed by the Senior Sustainability Officer (SSO) 

in conjunction with OPEPD. Generally, metrics will be established for baseline and targets and 

tracked to measure progress. Measurement will be possible only where data are available and 

this may be complicated where GSA “owns” the data associated with ED as building tenants. 

Data will be reported as actual and “normalized” to account for eco-efficiencies. 

Table 1: Critical Planning Coordination

The purpose of this table is to illustrate the relationship between the Sustainability Plan and 

other planning and reporting efforts across the agency. This table illustrates opportunities for 

integrating sustainability requirements into existing planning documents and vice versa. ED is using this 

table to illustrate how sustainability programs are supported in the appropriate agency planning 

processes. A response of ‘yes, ‘no’, or ‘n/a’ in a box indicates whether the Executive Order (EO) goal is 

relevant to and has been integrated into listed report/plan. ‘Yes’ implies it has been integrated, ‘no’ for 

not yet integrated, and ‘n/a’ for not applicable.
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Originating Report / Plan

Scope 1 & 2 GHG 

Reduction

Scope 3 GHG 

Reduction

Develop and Maintain 

Agency 

Comprehensive GHG 

Inventory

High-Performance 

Sustainable Design / 

Green Buildings

Regional and Local 

Planning

Water Use Efficiency 

and Management

Pollution Prevention 

and Waste Elimination

Sustainable 

Acquisition

Electronic 

Stewardship and Data 

Centers

Agency Specific 

Innovation

GPRA Strategic Plan n/a n/a n/a n/a n/a n/a n/a n/a n/a n/a

Agency Capital Plan Yes Yes n/a Yes n/a n/a n/a n/a Yes n/a

Circular A-11 Exhibit 300’s n/a n/a n/a n/a n/a n/a n/a n/a Yes n/a

Annual Energy Data Report

[Annual Report on Federal Government Energy 

Management submitted to the Federal Energy 

Management Program (FEMP)]

n/a n/a n/a n/a n/a n/a n/a n/a n/a n/a

EISA Section 432 Facility Evaluations/Project 

Reporting

[Energy Independence and Security Act of 2007]

n/a n/a n/a n/a n/a n/a n/a n/a n/a n/a

Budget Yes Yes n/a Yes n/a n/a n/a Yes n/a

Asset Management Plan / 3 Year Timeline n/a n/a n/a n/a n/a n/a n/a n/a Yes n/a

Circular A-11 Exhibit 53’s n/a n/a n/a n/a n/a n/a n/a n/a n/a n/a

OMB Scorecards Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes

DOE's Annual Federal Fleet Report to Congress and 

the President n/a n/a n/a n/a n/a n/a n/a n/a n/a n/a

Data Center Consolidation Plan n/a n/a n/a n/a n/a n/a n/a n/a Yes n/a

Environmental Management System No No No No No No No No No No

Other (reports, policies, plans, etc.) Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes

Section 1 – Item 5: Evaluating Return on Investment

Projects, initiatives and efforts should be prioritized based on the lifecycle return on investment to 

the agency while taking into account economic, environmental, social, and mission related costs and 

benefits. This section describes how ED takes into account both monetary and non-monetary factors 

when prioritizing projects and initiatives. As directed by the Office of the Federal Environmental 

Executive (OFEE), this section includes, where applicable, a discussion on various cost and benefit 

analyses including:

a. Economic Lifecycle Cost / Return on Investment (ROI)

b. Social Costs & Benefits

c. Environmental Costs & Benefits

d. Mission-Specific Costs & Benefits

e. Operations & Maintenance and Deferred Investments

f. Climate Change Risk and Vulnerability

g. Other, as defined by agency (e.g., security, societal benefit, and deferred maintenance)

Economic lifecycle cost/return on investment analysis is usually considered by GSA when improvements 

are made to ED-occupied buildings since GSA is the lessor responsible for building construction, 

renovation, and upgrades. ED discusses these investments with GSA and expresses preferences for 
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projects. While ED does not conduct formal cost-benefit analyses, ED does consider factors beyond ROI. 

For example, ED is currently working with GSA to make American Recovery and Reinvestment Act 

(ARRA)-funded upgrades to the LBJ Federal Building, mostly addressing energy savings. ED is interested 

in certain projects that GSA had originally discarded due to a relatively high ROI (generally greater than 

10 years). One project, “daylight harvesting,” will automatically adjust light fixtures when daylight is 

available to light a room. The estimated cost-savings is over $50,000 per year, but the ROI is 14 years 

and GSA considered this too long a payback. ED is interested in pursuing this project because in addition 

to saving money and energy, it also provides a tangible example of energy efficiency in action (compared 

to upgrades to the building automation system which employees would never notice because it’s 

“behind the scenes”). 

ED may employ use of triple bottom line (economic, social, and environmental) cost benefit analysis for 

other projects occurring in the near future. For example, ED is pursuing opportunities for integrating 

solar and wind power in the Mary E. Switzer Federal Building renovation not because of the renewable 

energy they can provide (which is limited in the Washington DC area), but because they offer examples 

for educating employees and visitors about how renewable energy can be a part of an array of energy 

options for use in building operations. In this analysis, consideration of social and environmental 

benefits will be addressed in light of the high cost of wind/solar projects. 

Section 1 – Item 6: Transparency

The Department of Education will communicate Sustainability Plan progress and results both within 

the Agency and to the general public. Internally, ED will rely primarily on our intranet website, 

connectED. Additionally, we will post information in the weekly ED Notebook (for all of ED), the weekly 

ED Update (for HQ only), and the monthly Inside ED newsletter. We will also use closed-circuit 

monitors at strategic locations in our buildings (e.g., the cafeteria at LBJ Headquarters Building) to 

display information. ED will also use e-mails to alert employees of specific events or achievements 

related to the Sustainability Plan. With respect to the general public, ED will rely on our internet 

website (www.ed.gov) for communicating progress on the Sustainability Plan. To the extent possible, 

metrics will be displayed graphically for ease in reading and interpreting.

Section 2 – Performance Review and Annual Update

Section 2 – Item 1: Summary of Accomplishments

This item is intended to summarize accomplishments from the previous fiscal year; next year’s 

Sustainability Plan will summarize accomplishments from FY ’10. For this current version of the 

Sustainability Plan, ED summarizes below accomplishments over the past year as well as on-going 

efforts:

• ED obtained for the first time a green rating for both Current Status and Progress on the January 

2010 Environmental Scorecard.

• ED began developing an Environmental Management System (EMS), even though we are not 

required to have one. 

• ED developed its first Electronic Stewardship Plan. In FY2009, ED purchased 100% EPEAT 

monitors and EPEAT PCs/laptops. Power management has been enabled on 100% of eligible 
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computers and monitors. In November 2009, ED became an Agency Partner and Facility 

Partner of the Federal Electronics Challenge (FEC).

• In April 2010, OFEE and the U.S. Environmental Protection Agency (EPA) announced the 

recipients of the 2010 Federal Electronics Challenge (FEC) Awards and ED will receive the 2010 

Bronze Level FEC Award for its FY2009 activities. 

• ED developed a Sustainable Buildings Implementation Plan in June 2009. Green/Sustainable 

approaches are being employed in upgrades to the cafeteria at the LBJ Federal Building as well 

as in the renovation of the Mary E. Switzer Federal Building, where GSA is seeking a Platinum 

rating under the U.S. Green Building Council’s Leadership in Energy and Environmental Design 

(LEED) program.

• ED has helped plan and will host the first “Education for a Green Economy” Summit in 

September 2010.

• ED signed a Memorandum of Understanding with the Departments of Energy and Labor on 

clean energy jobs.

• Environmental literacy was included in the President’s proposal for the FY11 budget for the first 

time.

• ED worked with GSA to reduce negative environmental impact from LBJ’s cafeteria (Edible’s 

Café) by replacing all foam and plastic items with biodegradable products as well as replacing

some of the cafeteria’s current equipment with Energy-Star rated equipment.

Section 2 – Item II: Goal Performance Review

GOAL 1: Scope 1 and 2 Greenhouse Gas Reduction

a. Goal Description. ED established a goal of reducing Scope 1 and 2 GHG emissions by 29% from 

a 2003 baseline of 3,535 mtCO2e to 2,505 mtCO2e in 2020. For goal-subject buildings alone, 

GHG emissions were projected to be reduced by 30%, from 3,317 to 2,322 mtCO2e. For covered 

federal fleet consumption, GHG emissions were expected to be reduced by 16% from 218 to 183 

mtCO2e.

b. Agency Lead for Goal. ED’s Office of Management will be responsible for target development, 

implementation, and oversight.

c. Implementation Methods. When ED submitted its Scope 1 and 2 GHG emissions baseline, 

utilities were included in rent payments to GSA for all but two buildings – one datacenter and 

one warehouse. ED has achieved the reduction in goal-subject buildings by eliminating both of 

these buildings from its inventory in early 2010. Because GSA is responsible for payment of 

utilities in all remaining buildings in ED’s inventory, the OFEE has determined that further 

reductions in Scope I and 2 GHG emissions will be executed and measured by GSA. Where 

possible, Education will continue to cooperate with GSA to find additional opportunities to 

lower energy use in ED-occupied buildings. 

With respect to fleet vehicles, as of the end of calendar year 2009, ED leases a total of 53 

vehicles from GSA, 45 of which are used by the Office of Inspector General (OIG). Because OIG 

vehicles are considered law enforcement vehicles, they are exempt from the GHG reduction 

target. That leaves a total of eight non-waivered fleet vehicles, which is below the 20 vehicle 

threshold for reporting. Nevertheless, the Department’s non-OIG components will adhere to 
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the Energy Independence and Security Act (EISA 2007) requirement that any new fleet vehicles 

purchased will be low-GHG-emitting. Additionally, we will continue to work with the OIG to 

reduce petroleum use in their vehicles by opting for alternative fuels where and when available.

d. Positions. Given the fact that this goal is not applicable at this point, ED has adequate FTE 

coverage for this goal.

e. Planning Table [ED entries in BOLD]. 

Table 2. Scope 1 & 2 GHG Targets

SCOPE 1&2 GHG TARGET Unit FY 10 FY 11 FY 12 FY 13 FY 14 FY 15 FY 16 ... FY 20

Buildings

Energy Intensity Reduction Goals

(BTU/SF reduced from FY03 base year) % 15% 18% 21% 24% 27% 30% hold ... hold

Planned Energy Intensity Reduction 

(BTU/SF reduced from FY03 base year) % N/A N/A N/A N/A N/A N/A N/A N/A N/A

Renewable Electricity Goals

(Percent of electricity from renewable 

sources)

% 5% 5% 5% 7.5% hold hold hold hold hold

Planned Renewable Electricity Use

(Percent of electricity from renewable 

sources)

% N/A N/A N/A N/A N/A N/A N/A N/A N/A

Fleet

Petroleum Use Reduction Targets

(Percent reduction from FY05 base 

year)1

% 10% 12% 14% 16% 18% 20% 22% ... 30%

Planned Petroleum Use Reduction

(Percent reduction from FY05 base 

year)

% N/A N/A N/A N/A N/A N/A N/A N/A N/A

Alternative Fuel Use in Fleet AFV Target

(Percent increase from FY05 base 

year)1

% 61% 77% 95% 114% 136% 159% hold ... Hold

Planned Alternative Fuel Use in Fleet 

AFV

(Percent increase from FY05 base year)

% N/A N/A N/A N/A N/A N/A N/A N/A N/A

Other, as defined by agency

All acquired fleet vehicles must be 

low-GHG-emitting.

% 100% Hold Hold Hold Hold Hold Hold Hold Hold

Scope 1 & 2 - Reduction Target 

(reduced from FY08 base year) % 100% Hold Hold Hold Hold Hold Hold Hold Hold

f. Agency Status. Through removal of the two facilities for which ED was paying utilities, and due 

to the fact that ED’s vehicle fleet is exempt from the fleet requirements, ED has effectively met 

its Scope 1 and 2 GHG emission reduction goal. ED will work with GSA and OIG, respectively, to 

address GHG emission reductions from ED-occupied buildings and ED fleet vehicles. 

GOAL 2: Scope 3 Greenhouse Gas Reduction

a. Goal Description. ED has established a goal of reducing Scope 3 GHG emissions by 3% from a 

2010 baseline of 5,808 mtCO2e to 5,635 mtCO2e in 2020 for a total reduction of 174 mtCO2e. 

b. Agency Lead for Goal. ED’s Office of Management will be responsible for target development, 

implementation, and oversight.
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c. Implementation Methods. For the purposes of ED’s first Scope 3 GHG emissions and reduction 

calculations, only those from federal employee commuting (including the ED shuttle bus service 

in the Washington, DC metropolitan area), business air travel, and contracted wastewater 

treatment are considered. At present, emissions associated with employee business ground 

travel (e.g., rental cars and privately owned vehicles) will be excluded due to difficulty in 

attaining the data. Emissions related to contracted solid waste disposal as well as transmission 

and distribution losses from purchased energy are not applicable to ED because both waste 

disposal and energy are paid for by GSA in all ED locations. ED used data from parking permits 

and transit subsidies to determine Scope 3 emissions from employee commuting in the 

Washington, DC metropolitan area. Transit subsidy data was used to calculate non-vehicular

emissions from ED employees outside of the Washington, DC commuting area. Vehicle use 

outside of the DC metro area is difficult to determine (we do not have parking permit data), so 

in the future, ED may use a survey to collect commuting information for all staff, particularly to 

capture employees in the regional offices. Contracted wastewater treatment is based on a 

current ED employee count of 4,300.

With respect to business air travel, ED is choosing not to use the GSA TRAX system to provide 

emissions data because of concerns associated with releasing personally identifiable 

information (PII) data (this decision was made in consultation with OFEE). Instead, we will use 

the methodology referenced in Climate Leaders GHG Inventory Protocol Core Module Guidance: 

Optional Emissions from Commuting, Business Travel and Product Transport (EPA430-R-08-006,

May, 2008), by using actual FY 2008 airline mileage to complete the equation:

E = PMT * (EFCO2 + EFCH4 * 0.021 + EFN2O * 0.310) 

where

E = Total CO2-equivalent Emissions 

:

PMT = Passenger Miles Traveled 

EFCO2 =CO2 Emission Factor 

EFCH4 =CH4 Emission Factor 

EFN2O =N2

O Emission Factor 

0.021 = Conversion Factor 

0.310 = Conversion Factor

To achieve a stated reduction target of three percent, ED proposes to investigate the following 

options for commuting: increasing use of telework and/or use of alternative work schedules; 

encouraging and facilitating ridesharing/carpooling; and/or reducing parking fees for carpools. 

As referenced earlier in the discussion under Section 1-Item 1, ED intends to evaluate enhanced 

use of teleworking for the additional 500 new FTE that are anticipated to be hired. Finally, with 

respect to the ED shuttle bus service, we will investigate opportunities for partnering with other 

federal agencies in order to optimize shuttle bus operations (e.g., have multiple agencies share 

shuttle buses where routes are similar or overlap).

With regard to business air travel, ED will investigate the use of video/teleconferencing for a 

yet-to-be-established set of regularly (physically) convened meetings and/or training classes.

Nearly all regional offices currently have video/teleconferencing capability, so the infrastructure 

is largely in place. We will likely need to purchase some additional equipment to 
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upgrade/augment existing equipment in several of our buildings to enable the successful use of 

video/teleconferencing technology. To encourage increased use of this technology, ED will 

determine if the regional offices have any barriers to using the equipment (e.g., discomfort with 

conducting distance meetings or unfamiliar with how to operate the equipment) and will work 

to address the root cause of these barriers (e.g., develop an on-line training course on how to 

use the equipment). Finally, ED will consider developing a Department-wide “green meetings” 

policy/directive that will consider opportunities for reducing attendee GHG emissions, including 

those related to travel.

Lastly, with respect to GHG emissions from contracted wastewater treatment, ED does not plan 

to take actions to reduce emissions in this category since the options available to reduce 

emissions in this area would mean either reductions in FTE or minimizing employee use of 

bathroom facilities, neither of which is a practical solution. In fact, as mentioned above, ED 

intends to add an additional 500 new FTE that will likely result in an increase in emissions in this 

category.

d. Positions. ED currently has a full-time FTE on detail from U.S. EPA to assist in the development 

of the Sustainability Plan. In addition to the EPA detail, ED has one employee who is working on 

the plan as collateral duty as well as fractions of other employees who are contributing to the 

plan development. ED will ensure that it has the resources to implement the Sustainability Plan 

once approved by OMB.

e. Planning Table [ED entries in BOLD]. 

Table 3. Scope 3 GHG Targets

SCOPE 3 GHG TARGET Units FY 10 FY 11 FY 12 FY 13 FY 14 .... FY 20

Overall Agency Scope 3 Reduction Target (reduced 

from FY08 base year) % 0 0 0 0.5 0.5 2.0 3

Sub-Target for Federal Employee Travel % 0 0 0 0.5 0.5 2.0 3

Sub-Target for Contracted Waste Disposal % N/A N/A N/A N/A N/A N/A N/A

Sub-Target for Transmission and Distribution Losses 

from Purchased Energy % N/A N/A N/A N/A N/A N/A N/A

f. Agency Status. ED has established its Scope 3 GHG emission reduction targets using the 

methodology discussed above. ED is in the process of determining next steps for meeting 

targets.

GOAL 3: Develop and Maintain Agency Comprehensive Greenhouse Gas Inventory 

a. Goal Description. The Department of Education is committed to the goal of conducting a 

comprehensive greenhouse gas inventory by January 31, 2011.

b. Agency Lead for Goal. ED’s Office of Management will be responsible for conducting the 

greenhouse gas inventory. 

c. Implementation Methods. ED will first establish organizational and operational boundaries for 

determining what will be included in the inventory. Because ED currently leases all facilities 
U.S. Department of Education Strategic Sustainability Performance Plan

June 8, 2010 

14

from GSA, ED-related Scope 1 and 2 emissions will be zero unless we can coordinate with GSA in 

terms of monitoring/measuring our energy use. If we do coordinate with GSA, OFEE will need 

to ensure that from the standpoint of a national roll-up of GHG emissions, they are not doublecounting (i.e., GSA and ED are counting the same emissions). Implementation methods for 

determining Scope 1 and 2 emissions and Scope 3 emissions are discussed under Goals 1 and 2, 

respectively. 

f. Positions. ED currently has a full-time FTE on detail from U.S. EPA to assist in the development 

of the Sustainability Plan. In addition to the EPA detail, ED has one employee who is working on 

the plan as collateral duty as well as fractions of other employees who are contributing to the 

plan development. ED will ensure that it has the resources to implement the Sustainability Plan 

once approved by OMB.

d. Planning Table. Not applicable for this goal. Again, we are committed to submitting our 

inventory by January 31, 2011.

e. Agency Status. ED has determined that Scope 1 and 2 GHG emissions will go to zero now that 

ED leases all buildings from GSA. Scope 3 emissions have been calculated and reduction targets 

set; however, this will be refined in future years to account for regional employee vehicular 

commuting and business ground travel. 

GOAL 4: High-Performance Sustainable Design/Green Buildings

a. Goal Description. All ED buildings are currently leased from GSA, where GSA is either the 

lessor or sublessor. A list of current ED-occupied buildings is provided in Table 4. Table 5 is a 

list of ED-vacated buildings since 2003. ED commits to work with GSA to achieve compliance 

with the “Guiding Principles for Federal Leadership in High Performance and Sustainable 

Buildings (Guiding Principles)” for 100% of major renovation, repair, or alteration of federal 

buildings in which ED is the main tenant. ED also commits to meet, by 2015, the guiding 

principles in 15% of building leases where ED occupies at least 5,000 GSF2

. With the 

cooperation of GSA, ED will demonstrate use of cost-effective, innovative building strategies 

to minimize energy, water and materials consumption so as to achieve a net reduction in 

agency deferred maintenance costs. As changes to its building inventory warrant, ED, in 

cooperation with GSA, will seek to optimize its real property portfolio by examining 

opportunities to decrease environmental impact through consolidation, reuse, and disposal of 

existing assets before deciding to add new assets. Finally, ED will work with GSA to ensure use 

of best practices and technology in rehabilitation of historic Federal properties.

 2 Gross square feet (GSF) is not normally tracked by ED for the purposes of its leased property. Our 

nomenclature is typically rentable square feet (RSF), which we will use as a surrogate for determining whether ED 

exceeds the 15% threshold for meeting the Guiding Principles.
U.S. Department of Education Strategic Sustainability Performance Plan

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15

Table 4. List of ED-Occupied Buildings in the U.S. 

 3 ED space in all listed buildings exceeds 5,000 rentable square feet (RSF) except where indicated.

4 Projected occupancy in 2012; ED will consolidate staff at 1990 K St, Capitol Place, and 800 No. Capitol St. 

Building Name Building Location

Building 

Number Notes3

Lyndon Baines Johnson 

Department of Education FB

400 Maryland Ave SW, Washington DC 20024 DC0010ZZ

Mary E. Switzer Memorial FB4 330 C Street SW, Washington DC 20024 DC0033ZZ Seeking LEED 

NC 2.1 Platinum

Capitol Place 555 New Jersey Ave NW, Washington, DC 20208 DC0326ZZ

LDC01289

1990 K Street 1990 K Street NW, Washington, DC 20006 DC0345ZZ LEED CS 2.0 

Certified

L'Enfant Plaza L'Enfant Plaza, 2100 Corridor, Washington, DC 20024 DC0376ZZ

Union Center Plaza 830 First Street NE, Washington, DC 20002 DC0564ZZ 

Potomac Center 550 12th Street SW. Washington, DC 20024 DC0569ZZ 

800 North Capitol Street 800 North Capitol Street NW, Washington, DC 20002

1775 Eye Street 1775 I Street NW, Washington, DC 20006 LDC80611

John W. McCormack FB 5 Post Office Square, Boston, MA 02109 MA0013 Seeking LEED 

NC Silver/Gold

Financial Square Building 32 Old Slip, New York, NY 10005 NY7363 LEED EB O&M 

Certified

Parque Las Americas 235 Federico Costa St, San Juan, PR 00918 APR02241 < 5,000 RSF

American University of PR K.14.4 Carr #2 Hato Tejas, Bayamon, San Juan, PR 00960 PR0059689 < 5,000 RSF

The Wanamaker Building 100 Penn Square East, Philadelphia, PA 19107 PA0549

William S. Moorhead 1000 Liberty Ave, Pittsburgh, PA 15219 PA0233 Seeking 

LEED NC

<5,000 RSF

Sam Nunn Atlanta Fed. 

Center

61 Forsyth Street SW, Atlanta, GA 30303 GA1007

Pembroke Pines Center 9050 Pines Blvd, Pembroke Pines, FL 33024 FL3035 < 5,000 RSF

Fifth Third Center 600 Superior Ave, Cleveland, OH 44114 OH2091

CitiCorp Center 500 West Madison Ave, Chicago, IL 60661 IL2233 LEED CI Gold

Federal Bldg 8930 Ward Pkwy, Kansas City, MO 64114 MO0134

Harwood Center 1999 Bryant Street, Dallas, TX 75201 TX 2233

Cesar E. Chavez Memorial 

Building

1244 Speer Blvd, Denver, CO 80204 Seeking LEED 

Silver

One World Trade Center 1 World Trade Center, Long Beach, CA 90831 CA6415

50 Beale Street 50 Beale Street, San Francisco, CA 94105 CA7738ZZ LEED EB O&M 

Certified

Robert T. Matsui Courthouse 501 I St, Sacramento, CA 95814 CA0306

Park Place Building 1200 Sixth Ave, Seattle, WA 98101 WA7321 LEED EB 2.0 

Platinum

<5,000 RSF
U.S. Department of Education Strategic Sustainability Performance Plan

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Table 5. List of ED-Vacated Buildings in the U.S (since 2003).

b. Agency Lead for Goal. ED’s Office of Management will be responsible for sustainable building 

target development, implementation, and oversight.

c. Implementation Methods. ED’s Sustainable Buildings Implementation Plan (SBIP), signed

June 15, 2009, is incorporated here by reference (see Attachment 1) and will be updated to 

include the requirements of E.O. 13514 and the objectives of the Sustainability Plan. ED has 

included in the SBIP its commitment to ensure that, on its behalf, GSA performs new

construction and renovation projects that incorporate sustainable practices in the Guiding 

Principles. ED will ensure that either employees are trained in sustainable building principles 

 5 ED consolidated staff to Potomac Center (550 12th Street SW). 6 ED consolidated staff to Potomac Center (550 12th Street SW). 7 Former location of primary data center; moved to Potomac Crossing (Oxon Hill, MD) in 2004.

8 ED staff moved to current LEED Gold location at 500 Madison Ave, Chicago, IL. 9 ED staff moved to current LEED Platinum location at 50 Beale Street, San Francisco, CA.

10 Space was no longer necessary to store GFE upon migration to contractor-owned IT infrastructure. 11 Former location of primary data center; moved to contractor-owned facility (Plano, TX) in 2009. 12 Former location of backup data center; moved to contractor-owned facility (Florence, KY). 13 ED returned to John W. McCormack Federal Bldg (Boston, MA). 14 ED consolidated staff at other existing Washington, DC locations (Potomac Center and LBJ). 15 ED consolidated facilities at Cesar E. Chavez Memorial Federal Building (1244 Speer Blvd, Denver, CO).

Henry M. Jackson FB 915 Second Ave, Seattle, WA 98104 WA0101

Columbia Center 701 Fifth Ave, Seattle, WA 98104 WA7594 LEED EB O&M

1000 Second Avenue 1000 Second Ave, Seattle, WA 98104 WA7584

Building Name Building Location

Building 

Number Notes

400 Virginia Avenue 400 Virginia Ave SW, Washington, DC 20024 ED left in 20035

525 School Street 525 School Street SW, Washington, DC 20024 ED left in 20036

GSA Regional Office Bldg 3 301 Seventh Street SW, Washington, DC 20024 ED left in 20047

Chicago Regional Office 111 N. Canal Street, Chicago, IL 60606 ED left in 20078

San Francisco Regional Office 50 United Nations Plaza, San Francisco, CA 94102 ED left in 20079

Warehouse 7100 Old Landover Rd, Landover, MD 20785 MD0803 ED left in 

201010

Potomac Crossing 6710 Oxon Hill Rd, Oxon Hill, MD 20745 MD0276 ED left in 

201011

Chastain Center 200 Chastain Blvd, Kennesaw, GA 30144 GA2240 ED left in 

200912

Arch Street Tower 33 Arch St, Boston, MA 02110 MA5888 ED left in 

200913

Old Post Office 1100 Pennsylvania Ave NW, Washington, DC 20004 DC0029ZZ ED left in 

200914

1391 Speer Boulevard 1391 Speer Blvd, Denver, CO 80204 ED left in 

200915
U.S. Department of Education Strategic Sustainability Performance Plan

June 8, 2010 

17

or contractors (e.g., LEED AP certified) are available to provide guidance. ED plans to 

schedule meetings with regional GSA representatives and perform internal reviews of facilities 

and operations to ensure sustainable practices are being employed. ED also intends to create 

a “change management” procedure whereby ED facility project leads must complete a form 

before proceeding with changes to current buildings or relocation to new buildings. The form 

will include a series of questions regarding potential environmental impacts of any building 

change requests (e.g., new furniture purchase must be a “green” purchase, new light fixtures 

must be Energy Star-rated) and how impacts will be mitigated. This will help assure that all 

project leads are addressing sustainable practices in ED-occupied buildings. Finally, where an 

existing ED-occupied building lease is up for renewal, we will work with GSA to require, as a 

key criterion for selecting a new building, that the building meet the Guiding Principles and/or 

be LEED-certified. 

Two of ED’s major HQ buildings in Washington, DC are undergoing renovation and include the 

following sustainable building measures: LBJ Federal Building – (1) renovations to the 

cafeteria will include installation of Energy Star-rated fixtures and equipment plus a 

composter that will divert all food/organic waste from garbage destined for landfilling; (2) 

ARRA projects to include a number of measures to enhance building sustainability, including 

installation of cooling tower variable frequency drives, installation of demand control 

ventilation and dampers on each air handling unit, upgrade of the existing building 

automation system to direct digital system, replacement of existing constant volume exhaust 

and supply fans serving the parking garage with variable speed drives connected to CO 

sensors, installation of an air-to-air energy recovery system, installation of occupancy sensors, 

and possibly a daylight harvesting system (ED has requested that GSA consider this despite a 

longer ROI); and (3) investigating installation of a green or reflective roof on all or part of 

LBJ. Mary E. Switzer Federal Building – major renovation/modernization of this building with 

the intent of acquiring LEED platinum certification.

d. Positions. ED currently has a full-time FTE on detail from U.S. EPA to assist in the development 

of the Sustainability Plan. In addition to the EPA detail, ED has one employee who is working on the 

plan as collateral duty as well as fractions of other employees who are contributing to the plan 

development. ED will ensure that it has the resources to implement the Sustainability Plan once 

approved by OMB.

e. Planning Table [ED entries in BOLD].

Table 6. Sustainable High Performance Building Targets

SUSTAINABLE HIGH PERFORMANCE 

BUILDINGS

(Buildings Meeting Guiding Principles)

Units FY 10 FY 11 FY 12 FY 13 FY 14 FY 15

Owned Facilities Targets % N/A N/A N/A N/A N/A N/A

Leased Facilities Targets16 % 0 0 15% Hold Hold Hold

 16 Based on data presented in Table 2, ED appears to currently meet the target of 15% leased buildings 

meeting the Guiding Principles, assuming that LEED certified buildings also meet the Guiding Principles. ED 

indicates zero percentage in both FY 10 and 11 to allow time for completion of on-going LEED building projects and 

also to allow time for understanding whether LEED certification qualifies a building as meeting the Guiding 

Principles.
U.S. Department of Education Strategic Sustainability Performance Plan

June 8, 2010 

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Total Facility Targets % 0 0 15% Hold Hold Hold

Other, as defined by agency N/A N/A N/A N/A N/A N/A N/A

GOAL 5: Regional and Local Planning

a. Goal Description. ED does not have an internal directive governing regional and local planning; 

however, planning policies will be included in the EMS that ED is currently developing. The 

policies shall commit ED (where appropriate given the number of ED employees in a given area)

to participation in regional transportation planning (recognition and use of existing community 

transportation infrastructure), ensure effectiveness of local energy planning, and incorporate 

sustainable building location into policy and planning for new leases. In addition, ED will work 

with GSA (with GSA in the lead as lessor) to ensure that all Environmental Impact Statements 

and Environmental Assessments required under the National Environmental Policy Act (NEPA) 

for proposed new or expanded Federal facilities identify and analyze impacts associated with 

energy usage and alternative energy sources. ED will work with GSA to ensure coordination and 

(as appropriate) consultation with Federal, State, Tribal and local management authorities 

regarding impacts to local ecosystems, watersheds and environmental management associated 

with proposed new or expanded Federal facilities. ED will incorporate by reference guidance 

issued in relation to Section 10 of E.O. 13514 (recommendations for sustainable locations for 

federal facilities) and Section 11 of E.O. 13514 (recommendations for federal local 

transportation logistics).

b. Agency Lead for Goal. ED’s Office of Management will be responsible for the regional and local 

planning target development, implementation, and oversight.

c. Implementation Methods. In addition to inclusion in the EMS of polices and guidance 

associated with regional and local planning, ED will consider the following opportunities for 

addressing local ecosystems: organizing employee volunteers to conduct watershed monitoring 

and/or cleanups, planting of trees, and creation of a “peoples’ garden.” In addition, ED is 

currently performing site analysis for leasing new property in Phoenix, AZ and is including access 

to public transportation as a major criterion for building selection. ED intends to map each 

facility it occupies across the country to determine relationship to regional and local planning 

concerns. ED is also working with GSA on the Mary E. Switzer Federal Building modernization to 

ensure compliance with the regional and local planning requirements of the Executive Order. 

This includes agreeing to a reduction in surface parking to allow for an improvement in 

pedestrian safety, circulation, and aesthetics. Finally, ED will explore the possibility of adding 

requirements for ED grant recipients that any new construction or major renovations consider 

regional and local planning aspects.

d. Positions. ED currently has a full-time FTE on detail from U.S. EPA to assist in the development 

of the Sustainability Plan. In addition to the EPA detail, ED has one employee who is working on 

the plan as collateral duty as well as fractions of other employees who are contributing to the 

plan development. ED will ensure that it has the resources to implement the Sustainability Plan 

once approved by OMB.

GOAL 6: Water Use Efficiency and Management
U.S. Department of Education Strategic Sustainability Performance Plan

June 8, 2010 

19

a. Goal Description. Because ED leases all building space, ED does not have purview over 

water use efficiency and management; rather, GSA is lead as the lessor. ED does not have an 

existing Water Conservation Directive or Plan; however, policies and procedures will be added 

to the EMS that ED is currently developing. These policies and procedures will commit ED to 

work with GSA to: reduce potable water use intensity by at least 26% by FY 2020, reduce 

landscaping water use by at least 20% by FY 2020, identify and implement water reuse 

strategies, and achieve objectives established by EPA in Technical Guidance on Implementing 

the Stormwater Runoff Requirements for Federal Projects under Section 438 of the Energy 

Independence and Security Act.17

b. Agency Lead for Goal. ED’s Office of Management will be responsible for the water use 

efficiency and management target development, implementation, and oversight.

c. Implementation Methods. In addition to inclusion of policies and procedures in the 

EMS, ED is working with GSA on the Mary E. Switzer Federal Building renovation/

modernization to ensure that stormwater is managed in manner such that runoff will be 

largely controlled through collection and reuse. GSA also intends to outfit the building with 

low flow/dual flush toilets and automatic shut-offs for sinks.

d. Positions. ED currently has a full-time FTE on detail from U.S. EPA to assist in the 

development of the Sustainability Plan. In addition to the EPA detail, ED has one employee 

who is working on the plan as collateral duty as well as fractions of other employees who are 

contributing to the plan development. ED will ensure that it has the resources to implement 

the Sustainability Plan once approved by OMB.

e. Planning Table [ED entries in BOLD].

Table 8. Water Use Efficiency and Management Targets

WATER USE EFFICIENCY & MGMT Units FY 10 FY 11 FY 12 FY 13 FY 14 FY 15 .... FY 20

Potable Water Reduction Targets (gal/SF 

reduced from FY07 base year) % 6% 8% 10% 12% 14% 16% .... 26%

Planned Potable Water Reduction (gal/SF 

reduced from FY07 base year) % N/A N/A N/A N/A N/A N/A N/A N/A

Industrial, Landscaping, and Agricultural Water 

Reduction Targets (gal reduced from FY10 base 

year)

% - 2% 4% 6% 8% 10% .... 20%

Planned Industrial, Landscaping, and 

Agricultural Water Reduction (gal reduced from 

FY10 base year)

% N/A N/A N/A N/A N/A N/A N/A N/A

Other, as defined by agency ?

GOAL 7: Pollution Prevention and Waste Elimination

 17 Section 438 applies to the “sponsor of any development or redevelopment project involving a Federal 

facility...”The “sponsor” should generally be regarded as the federal department or agency that owns, operates, 

occupies or is the primary user of the facility and has initiated the development or redevelopment project.” For 

most if not all ED-occupied buildings, the sponsor would likely be GSA as the lessor.
U.S. Department of Education Strategic Sustainability Performance Plan

June 8, 2010 

20

a. Goal Description. ED does not have a Chemical Reduction/Pollution Prevention Plan or 

Directive in place, but will include related policies and procedures in the EMS currently under 

development. 

In the EMS, ED will commit to work with GSA as appropriate to achieve the following goals: 

increase source reduction of pollutants and waste; divert at least 50% non-hazardous solid 

waste by FY 2015, excluding (construction and demolition (C&D) debris); divert at least 50% 

C&D materials and debris by FY 2015; reduce printing paper use; increase use of uncoated 

printing and writing paper containing at least 30% postconsumer fiber; reduce and minimize 

the acquisition, use, and disposal of hazardous chemicals and materials; increase diversion of 

compostable and organic materials from the waste stream; implement integrated pest 

management (IPM) and landscape management practices to reduce and eliminate the use of 

toxic and hazardous chemicals and materials; increase agency use of acceptable alternative 

chemicals and processes; and, to the extent it applies, decrease use of chemicals to assist in 

achieving FY 2020 GHG reduction targets [See Section II - 1 and 2 above] and report (as 

applicable) in accordance with Sections (301-313) of the Emergency Planning and Community 

Right-to-Know Act (EPCRA) of 1986.

b. Agency Lead for Goal. ED’s Office of Management will be responsible for the pollution 

prevention and waste elimination target development, implementation, and oversight.

c. Implementation Methods. In addition to including policies and procedures in the EMS, ED 

plans to work with GSA to research waste management and recycling methods and metrics for 

each building where it is a major tenant to determine baseline waste generation and then 

implement appropriate steps to reduce/eliminate waste generation where possible (note that 

if ED is a minor tenant in an office building, it may not be possible to develop metrics to 

understand the success of pollution prevention and elimination actions). ED will begin to 

manage paper use by tracking purchasing and inventory in all locations. ED currently uses 

30% post-consumer recycled paper in all locations, but will explore the possibility (depending 

on cost and availability) of increasing the percentage of recycled content in office paper. ED 

intends to institute defaults for duplex printing and double-sided copying. ED will work with 

GSA to implement integrated pest management (IPM) where/when appropriate, divert C & D 

debris generated during building renovations (currently being done in conjunction with the 

Mary E. Switzer Federal Building renovation), and ensure custodial services use “green” 

cleaning supplies. For the LBJ cafeteria renovation, ED is working with GSA to procure a 

composter (included as a leveraged investment in Table 6) to increase diversion of 

compostable and organic materials from the waste stream. In addition to EMS general 

awareness training, ED will provide training for employees to better understand waste 

management and recycling programs at each location and how they can help increase 

recycling rates/diversion from landfills.

d. Positions. ED currently has a full-time FTE on detail from U.S. EPA to assist in the 

development of the Sustainability Plan. In addition to the EPA detail, ED has one employee 

who is working on the plan as collateral duty as well as fractions of other employees who are 

contributing to the plan development. ED will ensure that it has the resources to implement 

the Sustainability Plan once approved by OMB.
U.S. Department of Education Strategic Sustainability Performance Plan

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e. Planning Table [ED entries in BOLD].

Table 9. Pollution Prevention and Waste Elimination Table

POLLUTION PREVENTION & WASTE ELIMINATION Units FY 10 FY 11 FY 12 FY 13 FY 14 FY 15

Non-Hazardous Solid Waste Diversion Targets (non C&D)

[applies only where data are available and enable us to 

determine only the waste diverted by ED] %

Establish 

baseline TBD* TBD TBD TBD

50%

C&D Material & Debris Diversion Targets

[will only apply in rare situations where ED is the lead in 

renovation; otherwise, GSA will be responsible] %

Establish

baseline TBD TBD TBD TBD

50%

Other, as defined by agency ? N/A N/A N/A N/A N/A N/A

*TBD – to be determined after establishment of baseline.

GOAL 8: Sustainable Acquisition 

a. Goal Description. ED’s Departmental Directive “Green Purchasing Plan,” revised July 23, 

2008, is incorporated here by reference (see Attachment 2) and will be updated to include the 

requirements of E.O. 13514 and the objectives of the Sustainability Plan, specifically: (1) 

ensuring 95% of new contract actions, including task and delivery orders under new contracts 

and existing contracts, require the supply or use of products and services that are energy 

efficient (Energy Star or Federal Energy Management Program (FEMP)-designated), water 

efficient, biobased, environmentally preferable (excluding EPEAT-registered products), nonozone depleting, composed of recycled content, or are non-toxic or less toxic alternatives and 

(2) to ensure that all Federally-mandated designated products and services are included in all 

relevant acquisitions.

b. Agency Lead for Goal. ED’s Office of Management will be responsible for the sustainable 

acquisition target development, implementation, and oversight.

c. Implementation Methods. In addition to revising ED’s Green Purchasing Plan to include the

requirements of E.O. 13514, ED is in the process of revising its training course “What is Green 

Purchasing Anyway?” to reflect the new E.O. ED also intends to seek funding for upgrades to 

its training tracking system to better determine who needs training. ED also plans to review 

and revise its procedure for conducting green purchasing audits. ED intends to prepare a 

template to ensure appropriate sustainability acquisition contract language is included in all 

solicitations and purchase agreements. Finally, as stated earlier, ED will prepare a “change 

management” procedure to help ensure that all purchases are made in accordance with ED’s 

Green Purchasing Plan.

d. Positions. ED currently has a full-time FTE on detail from U.S. EPA to assist in the 

development of the Sustainability Plan. In addition to the EPA detail, ED has one employee 

who is working on the plan as collateral duty as well as fractions of other employees who are 

contributing to the plan development. ED will ensure that it has the resources to implement 

the Sustainability Plan once approved by OMB.
U.S. Department of Education Strategic Sustainability Performance Plan

June 8, 2010 

22

e. Planning Table [ED entries in BOLD].

Table 10. Sustainable Acquisition Targets

SUSTAINABLE ACQUISITION Units FY 10 FY 11 FY 12 .... FY 20

New Contract Actions Meeting Sustainable Acquisition Requirements % 75% 95% Hold Hold Hold

Energy Efficient Products (Energy Star, FEMP-designated, and low 

standby power devices) % Establishbaseline TBD* TBD TBD TBD

Water Efficient Products % Establish

baseline TBD TBD TBD TBD

Biobased Products % Establish

baseline TBD TBD TBD TBD

Recycled Content Products % Establish

baseline TBD TBD TBD TBD

Environmentally Preferable Products/Services (excluding EPEAT) % Establish

baseline TBD TBD TBD TBD

SNAP/non-ozone depleting substances % Establish 

baseline TBD TBD TBD TBD

Other, as defined by agency N/A N/A N/A N/A N/A

*TBD – to be determined after establishment of baseline.

GOAL 9: Electronic Stewardship and Data Centers

a. Goal Description. 

a. Establish and implement policy and guidance to ensure use of power management, 

duplex printing, and other energy efficient or environmentally preferred options and 

features on all eligible agency electronic products.

b. Update agency policy to reflect environmentally sound practices for disposition of all 

agency excess or surplus electronic products.

c. Update agency policy to ensure implementation of best management practices for 

energy efficient management of servers and Federal data centers.

d. Goals should identify how the agency intends to meet technology energy consumption 

reduction goals in its data centers.

e. Discuss how the agency is planning on meeting the technology energy reduction goals in 

data centers. Include details on the investment plan, covered versus non-covered 

facilities, and how the agency identified the covered facilities.

f. Discuss how the agency will increase the quantity of electronic assets disposed through 

sound disposition practices. Include in the discussion how your agency is using or plans 

to use programs such as disposal through GSA Xcess, recycling through Unicor, donation 

through GSA’s Computer for Learning (CFL) or other non-profit organizations, and/or 

recycling through a private recycler certified under the Responsible Recyclers (R2) 

guidance or equivalent.
U.S. Department of Education Strategic Sustainability Performance Plan

June 8, 2010 

23

b. Agency Lead for Goal. ED’s Office of the Chief Information (OCIO) is the lead Program Office for 

this goal.

c. Implementation Methods. 

a. Sub-goals 9a, 9b, 9c and 9f

b.

. The U.S. Department of Education Electronic Stewardship 

Plan (dated 8 Jan 2010) is incorporated here by reference (see Attachment 3) and has

been updated to reflect E.O. 13514 and sub-goals 9a, 9b, 9c, and 9f. (For FY2009, the 

Department was awarded the 2010 Federal Electronics Challenge Bronze Level Award 

for its Operations & Maintenance activities.)

Sub-goals 9d and 9e. The Government-Owned-Contractor-Operated (GOCO)-based 

computer room for the Institute of Education Sciences (IES) is housed within the GSAsupported Mary E. Switzer (MES) Building. GSA holds the responsibility for GHG 

emissions and associated metering. The Department does intend to increase the IES 

Computer Room’s activity implemented via virtualization technology, which in turn, 

should improve average CPU utilization of the remaining physical servers. Each of ED’s 

three primary data centers is located in non-covered contractor-owned, contractoroperated (COCO) facilities. ED does intend to maximize the use of virtualization 

technology at its contractor facilities to improve operations while supporting the 

environment; however, ED does not intend to establish separate electrical metering for 

its outsourced managed services contracts, which are very closely aligned with cloud 

computing goals and efficiencies. 

d. Positions. The Department is adequately manned for supporting the goals of electronic 

stewardship and data centers. 
U.S. Department of Education Strategic Sustainability Performance Plan

June 8, 2010 

24

e. Planning Table [ED entries in BOLD]. The Department plans on meeting or exceeding the 

following:

Table 11. Electronic Stewardship and Data Centers Targets

ELECTRONIC STEWARDSHIP and DATA CENTERS Units FY 10 FY 11 FY 12 FY13

% of device types covered by current Energy Star specifications that 

must be Energy-Star qualified18 % 90% 90% 95% hold

% of electronic assets covered by sound disposition practices19 % 95% hold hold hold

% of cloud activity hosted in a data center % 0% hold hold hold

% of agency data centers independently metered or advanced metered 

and monitored on a weekly basis % 0% hold hold hold

Reduction in the number of agency data centers % 0% hold hold hold

% of agency, eligible electronic products with power management and 

other energy-environmentally preferable features (duplexing) actively 

implemented and in use

% 50% 67% 95% hold

% of agency data centers operating with an average CPU utilization of 

60%-70% % 0% 40% 60% 75%

% of agency data centers operating at a PUE range of 1.3 – 1.6 % 0% hold hold hold

% of covered electronic production acquisitions that are EPEATregistered % 99% hold hold hold

% of agency data center activity implemented via virtualization % 20% 40% 60% 65%

Other, as defined by agency N/A N/A N/A N/A N/A

Agency Defined N/A N/A N/A N/A N/A

GOAL 10: Agency Innovation 

a. Goal Description. ED will explore several opportunities to innovate outside the requirements of 

the Sustainability Plan. Examples are listed below.

(1) Leverage ED resources to influence environmental improvements by our customers by 

including, sustainability requirements (where permissible) in ED-issued loans/grants. For 

example, where ED issues grants/loans for construction of new facilities or renovation of 

existing facilities, ED could include as a grant requirement that decisions about retaining existing 

schools and where to locate new schools consider the needs of the surrounding communities to 

take advantage of existing resources/infrastructure (e.g., roads and sewers) and to allow 

students and families to walk or bike to school to reduce GHG emissions. 

(2) Investigate the possibility of including sustainability requirements (beyond what is currently 

required in terms of environmental due diligence and clean-up) in deeds where federal real 

property is transferred to another entity. 

 18 This count should include the percentage of products that met energy star standards at the time of 

purchasing. 19 Some examples of sound disposition practices include, but are not limited to, GSA Xcess, recycling through 

Unicor, donation through GSA’s Computer for Learning (CFL) or other non-profit organizations, and/or recycling 

through a private recycler certified under the Responsible Recyclers (R2) guidance or equivalent.
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(3) Continue to work with our computer contractor to collect, refurbish, and distribute 

computers, printer, and monitors to school districts in need.

(4) Collaborate with EPA to develop/promote green education curriculum (one example would 

be the SunWise Program that teaches children about the dangers of ultraviolet radiation and 

how to protect themselves). 

(5)Partner with OFEE and other federal agencies to help “green” the supply chain. 

b. Agency Lead for Goal. ED’s Office of Management will be responsible for target development, 

implementation and oversight.

c. Implementation Methods. ED’s Office of Management will lead these efforts out of HQ’s 

central office and will work with other ED offices and federal agencies as necessary to achieve 

the goals. ED may establish an intra-office sustainability challenge whereby each Executive 

Office in ED sets a sustainability goal of their choice and tries to achieve it over a three-year 

period. Those offices that achieve established goals would receive an award/incentive for their 

achievements. This effort may help to achieve buy-in across ED rather than focusing most of the 

efforts within ED’s Office of Management.

d. Positions. ED currently has a full-time FTE on detail from U.S. EPA to assist in the development 

of the Sustainability Plan. In addition to the EPA detail, ED has one employee who is working on

the plan as collateral duty as well as fractions of other employees who are contributing to the 

plan development. ED will ensure that it has the resources to implement the Sustainability Plan 

once approved by OMB.

e. Planning Table [ED entries in BOLD]. 

Table 12. Agency Innovation Targets

AGENCY INNOVATION Units FY 

10 FY 11 FY 13 .... FY 20

Other, as defined by agency

-By end of first quarter FY 11, complete research to determine 

the potential for implementing (a) 1 – 5 above

N/A - Research 

complete TBD* TBD TBD

*TBD – to be determined after completion of research.

Section 3 – Agency Self-Evaluation 

I. Please answer ‘yes’ or ‘no’ to the following questions. If the answer is ‘no’, provide an 

explanation below [ED responses in BOLD].

Does your plan provide/consider overarching strategies and approaches for achieving long-term 

sustainability goals? 

We believe this, the first ED Sustainability Plan, does consider overarching strategies for 

Y
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achieving long-term sustainability with both the physical and programmatic aspects of the 

Department. Nevertheless, we anticipate that fine-tuning of the plan in future versions will 

help solidify our approach. Also, we believe that completion and implementation of an EMS 

will provide an important tool for achieving the approaches envisioned in the plan.

Does your plan identify milestones and resources needed for implementation? 

Generally, yes, the plan does identify milestones and resources; however, in some areas we 

have research and baseline data collection to conduct before we can be more specific.

Y 

Does your plan align with your agency’s 2011 budget submission?

Yes, ED is seeking to leverage funding in FY ’11 to finance some of the efforts identified in the 

plan.

Y

Is your plan consistent with your agency’s FY 2011 budget and appropriately aligned to reflect 

your agency’s planned FY 2012 budget submission?

Yes, ED intends to leverage FY ’11 and ’12 budgets to achieve some of the plan activities.

Y

Does your plan integrate existing EO and statutory requirements into a single framework and 

align with other existing mission and management related goals to make the best use of 

available resources? 

Yes. The sustainability plan template was useful in that it consolidated many of the E.O. 

requirements into a single framework. ED’s EMS will help to further identify and align all 

applicable E.O.’s, statutes, regulations, and internal directives.

Y

Does your plan provide methods for obtaining data needed to measure progress, evaluate 

results, and improve performance?

In general, yes; however, we will need more time to understand the details for data collection 

and analysis, particularly where we will need to work with GSA and other third parties (e.g., 

contractors) to obtain data.

Y

II. What is your agency’s planned actions for the following year (in 6-month increments, July-Dec 

2010 & Jan-June 2011) to achieve the sustainability and energy standards for success on the OMB 

Scorecard? Please use short, descriptive, and action-oriented bullets for key milestones and 

associated target dates. Agencies may highlight text within its Sustainability Plan to emphasize these 

key actions and milestones. 

Please see Table 13.
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Table 13. Department of Education Key Actions to Achieve Scorecard Standards for Success

Scorecard

Standard

Number

Scorecard Standard for 

Success

Corresponding 

Goal in 

Sustainability 

Plan

Applicable 

to ED? 

(Y/N)

ED Key Actions July-Dec 2010 ED Key Actions Jan-June 2011

1 On track to achieve Scope 

1 & 2 GHG reduction 

target for 2020

1 N Continue to work with GSA to support ARRA 

energy efficiency upgrades in LBJ and energy 

efficiency efforts associated with the MES

renovation/ modernization.

Continue to work with GSA in support of 

energy efficiency efforts in the MES

renovation/ modernization.

2 On track to achieve Scope 

3 GHG reduction target 

for 2020

2 Y Begin evaluation of opportunities to 

increase use of teleworking, alternative 

work schedules, carpooling, and transit 

subsidies.

Begin evaluation of Department travel to 

determine opportunities for replacing some 

travel with video/teleconferencing.

Complete evaluations and begin to 

implement findings.

Leverage funds for purchase of additional 

video/ teleconferencing equipment.

Determine feasibility of developing “green 

meetings” directive for ED.

Investigate opportunities to coordinate with 

other federal agencies on shuttle bus use.

Collect data on vehicular commuting in the 

Regions.

Evaluate practicality of calculating Scope 3 

emissions from employee ground business 

travel.

3 Reduction in energy 

intensity in goal-subject 

facilities compared with 

2003

1 N See actions for standard #1. See actions for standard #1.
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Scorecard

Standard

Number

Scorecard Standard for 

Success

Corresponding 

Goal in 

Sustainability 

Plan

Applicable 

to ED? 

(Y/N)

ED Key Actions July-Dec 2010 ED Key Actions Jan-June 2011

4 Use of renewable energy 

as a percent of facility 

electricity use

1 N Continue to work with GSA on integrating 

renewable energy opportunities in the MES

renovation/ modernization.

Continue to work with GSA on integrating 

renewable energy opportunities in the MES

renovation/ modernization.

5 Reduction in potable 

water intensity compared 

with 2007

6 N Continue to work with GSA to ensure 

inclusion of water use reduction/ 

management features in the MES

renovation/ modernization.

Continue to work with GSA to ensure 

inclusion of water use reduction/ 

management features in the MES renovation/ 

modernization.

6 Annual reduction in fleet 

petroleum use compared 

to 2005

1 N Continue to ensure 100% of ED leased 

vehicles are low-GHG-emitting.

Work with OIG to reduce petroleum 

use/increase use of alternative fuels.

Replace current leased AFVs for Secretary 

and Deputy Secretary with hybrid vehicles.

Continue to ensure 100% of ED leased 

vehicles are low-GHG-emitting.

Work with OIG to reduce petroleum 

use/increase use of alternative fuels.

Replace two expiring vehicles with 

hybrid/electric vehicles.
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Scorecard

Standard

Number

Scorecard Standard for 

Success

Corresponding 

Goal in 

Sustainability 

Plan

Applicable 

to ED? 

(Y/N)

ED Key Actions July-Dec 2010 ED Key Actions Jan-June 2011

7 Sustainable Green 

Buildings

4 Y Update ED’s Sustainable Building 

Implementation Plan.

Continue to work with GSA to ensure ARRA 

upgrades are made to LBJ.

Continue to work with GSA to “green” the 

LBJ cafeteria.

Continue to work with GSA to ensure LEED 

certification of MES Building.

Continue to ensure ARRA upgrades are made 

to LBJ.

Purchase and install composter for LBJ 

cafeteria.

Continue to work with GSA to ensure LEED 

certification of MES Building.

Develop change management procedure to 

assure all project leads are considering 

sustainable approaches in building moves and 

renovations.

Work with GSA to determine which EDoccupied buildings meet the “Guiding 

Principles.” Determine schedule of expiring 

building leases to ensure new leases are for 

buildings that meet “Guiding Principles” 

where practicable.

Develop/procure and provide training in high 

performance sustainable design/green 

building.

8 Cross-Cutting (addresses 

all above standards)

All of the above. N Complete development of EMS and begin 

implementation.

Fully implement EMS.
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Appendix 1: Acronyms and Abbreviations

ACS Administrative Communication System

AFV Alternative Fuel Vehicle

ARRA American Recovery and Reinvestment Act of 2009

BTU or Btu British Thermal Unit

C&D Construction and Demolition

CEQ Council on Environmental Quality

CFL Computer for Learning

CIO Chief Information Officer

CPU Central Processing Unit

DOE U.S. Department of Energy

ED U.S. Department of Education

EISA Energy Independence and Security Act

EMS Environmental Management System

EO Executive Order

EPA Environmental Protection Agency

EPAct Energy Policy Act

EPCRA Emergency Planning and Community Right-to-Know Act

EPEAT Electronic Product Environmental Assessment Tool

EPP Environmentally Preferable Purchasing

ESPC Energy Services Performance Contract

EUL Enhanced Use Lease

FEC Federal Electronics Challenge

FEMP Federal Energy Management Program

FSA Federal Student Aid

FTC Florence (KY) Technology Center

FTE Full Time Employee

FY Fiscal Year

gal gallon

GHG Greenhouse Gas

GPRA Government Performance and Results Act

GSA General Services Administration

GSF Gross Square Feet

IES Institute of Education Sciences

IT Information Technology

LBJ Lyndon Baines Johnson Department of Education 

Federal Building

MES Mary E. Switzer Memorial Federal Building

mtCO2e Metric tons of Carbon Dioxide Equivalent

NEPA National Environmental Policy Act

O&M Operations and Maintenance

OCIO ED Office of the Chief Information Officer

OCR ED Office for Civil Rights
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OFEE Office of the Federal Environmental Executive

OIG ED Office of Inspector General

OM ED Office of Management

OMB Office of Management and Budget

OPEPD ED Office of Planning, Evaluation & Policy Development

PCP Potomac Center Plaza

PO ED Principal Office

PPA Power Purchase Agreement

PTC Plano (TX) Technology Center

PUE Power Usage Efficiency

R2 Responsible Recyclers

RIA Regulatory Impact Analysis

ROI Return on Investment

SBIP Sustainable Buildings Implementation Plan

SF Square Feet or Square Footage

SNAP Significant New Alternatives Policy

SRPO Senior Real Property Officer

SSO Senior Sustainability Officer

TRI Toxics Release Inventory

UCP Union Center Plaza

USC United States Code

UESC Utility Energy Services Contract