Federal Green Building: Federal Efforts and Third-Party Certification Help Agencies Implement Key Requirements, but Challenges Remain
Published: 2015-07-23T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: As the nation's largest energy consumer, the federal government spent about $7 billion in fiscal year 2014 to provide energy to over 275,000 federally owned or leased buildings. Federal law and policies for improving sustainability across the federal government include “green building” provisions—construction and maintenance practices designed to make efficient use of resources and reduce environmental impacts, among other benefits. A March 2015 executive order required CEQ to revise key green building requirements and extended the time frames for implementation in existing buildings. Third-party certification systems are used to assess how well green building elements are incorporated into a building's design and operation.
GAO was asked to review federal green building efforts and agencies' use of third-party certification systems. This report examines (1) federal efforts to support agencies' implementation of key green building requirements, (2) select agencies' use of third-party certification systems, and (3) challenges select agencies face in implementing requirements. GAO reviewed federal requirements; agency policies and guidance; and interviewed officials from agencies with supporting roles and agencies with experience implementing the requirements and using different certification systems. GAO also reviewed documentation and interviewed representatives from third-party certification organizations.
GAO is not making recommendations. CEQ, DOD, DOE, EPA, GSA, OMB, and VA reviewed a draft report and most provided technical comments that GAO incorporated, as appropriate.
section_title: What GAO Found
paragraphs: The Council on Environmental Quality (CEQ), Department of Energy (DOE), Environmental Protection Agency (EPA), General Services Administration (GSA), and Office of Management and Budget (OMB) provide guidance, oversight, training, and other support to agencies implementing key federal green building requirements. For example, DOE offers training on measuring and reporting on the implementation of requirements, among other things. Also, EPA's Energy Star Portfolio Manager is a web-based tool agencies and other entities can use to measure and track buildings' energy and water use. According to officials, some federal support efforts will need to be updated when the revised requirements are issued, as called for in the March 2015 executive order.
All of the select agencies GAO reviewed—Department of Defense (DOD), DOE, EPA, GSA, and the Department of Veterans Affairs (VA)—use third-party certification systems to help implement key federal green building requirements for new construction and major renovation projects. While certification does not ensure that a building meets all requirements, agencies have developed tools to ensure that any remaining federal requirements are implemented at their buildings, and officials noted that there are additional benefits to using these systems. For example, officials stated that certification provides a well-established framework for documenting and ensuring compliance; serves as a tool to communicate with contractors and the public; and reduces the need for additional staff to verify that a building meets requirements. Of the select agencies GAO reviewed, none require third-party certification for existing buildings, but three have developed their own systems for assessing the implementation of key requirements for existing buildings. Several agencies stated that they are not certain how they will use third-party certification systems in the future after the revisions to key green building requirements are issued. For example, EPA and VA officials stated that they may reevaluate their requirement to certify specific projects after the revised green building requirements are issued.
Regardless of whether they use certification systems, the agencies GAO reviewed identified a variety of challenges in implementing current green building requirements, including challenges related to their building inventories, missions, and the criteria for evaluating compliance. For example, DOD officials said that the sheer number of buildings in their inventory proves challenging. In addition, according to officials from several agencies, their building inventories include certain building types, such as laboratories, hospitals, and industrial buildings for which some requirements are difficult to implement. VA cited mission concerns, including new safety requirements and extended hours to address patient backlogs, as a challenge to implementing energy and water conservation requirements. Also, some agency officials said that the criteria for evaluating compliance with the requirements can be a disincentive to implementing some requirements because no credit is received unless all of the requirements are implemented. Forthcoming revisions to key green building requirements may address some of these challenges. CEQ officials said that they were aware of the challenges and want to ensure that they are not providing any disincentives for agencies to meet some of the requirements even if they cannot meet all.

section_title: Letter
paragraphs: The federal government is the nation’s largest energy consumer,  spending about $7 billion in fiscal year 2014 to provide energy to its  facilities, including over 275,000 federally owned or leased buildings.  These buildings affect our environment, economy, and the productivity  and health of the workers and visitors who use them. Numerous federal  policies aim to improve federal energy and environmental management  and take advantage of the opportunity that the size and scope of the  government’s operations present to implement sustainable practices on a  large scale, lower costs, and reduce the environmental impact of federal  buildings. Federal law, executive orders, and policies include provisions  specifically related to “green building.” Green building generally refers to  designing, constructing, operating, and maintaining buildings to use  resources efficiently, reduce environmental impacts, and provide long- term financial and health benefits, including through lower annual  operating costs and better indoor air quality. Specifically, green building  includes the use of strategies to support objectives that include the  following:  integrated design–use collaborative planning and design processes  that involve a variety of stakeholders in decision making for all stages  of a building’s life cycle, including planning, building, and operation; energy conservation or efficiency–reduce energy consumption or use  renewable sources of energy; water conservation or efficiency–reduce water consumption inside  and outside the building;  indoor environmental quality–enhance indoor environmental quality  through ventilation, controlling pollution sources, and using low  pollution-emitting materials; environmental impact of materials–reduce the environmental impact  of materials by minimizing waste and using products with high  recycled content, among other things; and  sustainable siting or location measures–use of certain strategies when  deciding on building location, including discouraging development on  previously undeveloped land and minimizing a building’s impact on  the nearby ecosystem, among other things.
Federal law and policies direct agencies to implement green building  requirements in federally owned and leased buildings. The Guiding  Principles for Federal Leadership in High Performance and Sustainable  Building (Guiding Principles)—originally a 2006 memorandum of  understanding among 19 federal agencies to commit to the design,  construction, and operation of green buildings—were updated in 2008  and incorporated relevant requirements in federal law. In this report, we  refer to the 2008 Guiding Principles and the statutory requirements  referenced within them as the key federal green building requirements.  The Guiding Principles include one set of requirements for new  construction and major renovations and a separate set for existing  buildings, and we refer to these together as the Guiding Principles.  Agencies are operating under the goal of ensuring that all new  construction and major renovation and 15 percent of existing buildings  and leases over 5,000 gross square feet comply with the Guiding  Principles by fiscal year 2015 as required by the recently revoked  Executive Order 13514 (Federal Leadership in Environmental, Energy,   In March 2015, a new executive order— and Economic Performance).
Executive Order 13693 (Planning for Federal Sustainability in the Next  Decade)—called for the Council on Environmental Quality (CEQ) to  revise the Guiding Principles by August 16, 2015. Further, it called for  agencies to identify a percentage of at least 15 percent of the agency’s  existing buildings above 5,000 gross square feet that will, by fiscal year  2025, comply with the revised Guiding Principles. The 2008 Guiding  Principles called for a review every 2 years, at a minimum, to keep pace  with evolving sustainable building practices and new regulations and  legislation. Over the past several years, working groups were established  to provide input to inform revisions to the Guiding Principles and these  groups made recommendations accordingly. The Guiding Principles have  not been revised since 2008, but CEQ officials told us that they have  been working on the revisions. These officials said that there have been  advancements in policy and technology since 2008, and the need to  reflect those advancements in the Guiding Principles is one reason for the  revision. Executive Order 13693 established a deadline for CEQ to  prepare and issue revised Guiding Principles for both new and existing  federal buildings including consideration of climate change resilience and  employee and visitor wellness, which were areas not included in the 2008  Guiding Principles.
Private industry and federal agencies use green building certification  systems developed by third-party entities to assess how green building  elements are incorporated into the design and operation of a building.  The third-party entity conducts an assessment that rates a building by  awarding points in different categories, such as water and energy  consumption. A building may achieve different rating levels within a  certification system depending on how many points it achieves. Federal  agencies are not required to use a third-party certification system but, if  an agency chooses to use a system, the Energy Independence and  Security Act of 2007 (EISA) requires that the system meet certain criteria  outlined in the Department of Energy’s (DOE) regulation on the use of  these systems.
You asked us to review federal green building efforts and the use of third- party certification systems to help implement federal green building  requirements. This report examines (1) federal efforts that support  agencies’ implementation of key federal green building requirements; (2)  select agencies’ use of third-party green building certification systems to  help implement key federal green building requirements; and (3) the  challenges, if any, select agencies face implementing key federal green  building requirements.
To address these objectives, we reviewed federal law, other federal green  building requirements, and related policies and guidance; interviewed  agency officials; and reviewed documentation and interviewed officials  from third-party certification systems. To identify the key federal green  building requirements that federal agencies must implement at their  buildings, we reviewed our prior work on green buildings, and identified  and reviewed the primary sources of green building requirements in  federal law, executive orders, and policies aimed at achieving  sustainability goals across the federal government. We determined that  the Guiding Principles, including their references to existing statute,  reflect the most relevant and detailed source of federal green building  requirements, and for the purpose of this review, the Guiding Principles  and the statutory requirements referenced within them comprise the key  federal green building requirements. Appendix I lists the requirements in  the Guiding Principles. We interviewed officials from agencies that either  had roles in supporting the implementation of federal green building  requirements—DOE; the Environmental Protection Agency (EPA); the  General Services Administration (GSA); CEQ, including the Office of  Federal Sustainability; and the Office of Management and Budget  (OMB)—which we refer to as supporting agencies, or agencies with  experience implementing the requirements—the Department of Defense  (DOD) including the Air Force, Army, Navy, and the Office of the  Assistant Secretary of Defense for Energy, Installations, and Environment  (OASD EI&E); DOE; EPA; GSA; and the Department of Veterans Affairs  (VA)—which we refer to as select agencies. We identified DOE, EPA,  GSA, CEQ, and OMB as supporting agencies because they have been  assigned responsibilities for supporting federal green building efforts,  such as developing guidance or chairing working groups, or have  assumed such responsibilities. We included DOD, DOE, EPA, GSA, and  VA as select agencies with experience implementing the requirements  based on the size of their building inventories, energy use, and  experience with the use of different third-party certification systems. We  included DOE, EPA, and GSA as both supporting and select agencies to  obtain information related to their supporting roles and experience  implementing green building requirements. In addition, for the five select  agencies we obtained responses to a standard set of questions and  interviewed headquarters and building-level officials. The information  obtained from these agencies is not generalizable across the federal  government, but together the select agencies own or lease a significant  portion of federal buildings (about 63 percent of buildings and 84 percent  of square footage) and account for approximately 77 percent of the  energy consumed by federal buildings and facilities.
To examine federal efforts that support agencies’ implementation of key  federal green building requirements, we reviewed prior GAO reports and  agency documentation and interviewed officials from supporting and  select agencies. To examine select agencies’ use of third-party green  building certification systems to help implement key federal green building  requirements, we reviewed policy documents, such as DOD’s Unified  Facilities Criteria, and we interviewed headquarters and building-level  officials from select agencies. We reviewed federal reports on the use of  third-party certification by federal agencies, such as Pacific Northwest  National Laboratory’s 2012 Green Building Certification System Review.  We also reviewed documentation and interviewed representatives of the  U.S. Green Building Council, the Green Building Initiative, Green  Business Certification Inc., and the International Living Future Institute.  To examine the challenges, if any, select agencies face implementing key  federal green building requirements, we reviewed agency documents,  such as Strategic Sustainability Performance Plans, and interviewed  officials from select agencies. To get information about government-wide  challenges agencies face in implementing key green building  requirements, we interviewed supporting agency officials and attended  and reviewed Interagency Sustainability Working Group presentations.
We conducted this performance audit from October 2014 to July 2015 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: Federal policy aimed at promoting sustainability in federal facilities sets  goals for reducing greenhouse gas emissions and implementing key  green building requirements, among other areas. Green building goals  established by executive order in 2009 built on previous efforts to  establish federal green building policy. Figure 1 shows the timeline of  sources of key green building requirements from 2005 through June  2015. In March 2015, the third executive order to require compliance with  the Guiding Principles—Executive Order 13693—revoked two prior  executive orders and certain other green building policies and extended  the time frames for agencies’ existing buildings to comply with the  Guiding Principles from 2015 to 2025.
Key federal green building requirements include dozens of specific  requirements related to five Guiding Principles: employ integrated design  principles, optimize energy performance, protect and conserve water,  enhance indoor environmental quality, and reduce the environmental  impact of materials. The requirements range from requirements to reduce  water consumption to others aimed at improving indoor environmental  quality, including tobacco smoke control and daylighting requirements.  See appendix I for the specific requirements included in the Guiding  Principles which are currently undergoing revision. CEQ officials said that  the revisions will include consideration of climate change resilience and  employee and visitor wellness as called for in Executive Order 13693.  The current criteria for determining whether a building complies with the  Guiding Principles include either (1) demonstrating a building was  compliant with each of the five Guiding Principles or (2) documenting that  a commitment to third-party certification for a building was made prior to  October 1, 2008, and that the building obtained the certification. In  addition, for leased buildings, a building is considered compliant if either  (1) the building was third-party certified at any time or (2) the agency  demonstrated compliance with the appropriate set of Guiding Principles  (those for new construction and major renovations or existing buildings).  As of June 12, 2015, the revised Guiding Principles were not complete,  but CEQ officials told us that they are working toward meeting the August  16, 2015, deadline to complete the revision.
OMB’s sustainability and energy scorecard assesses federal agency  performance in meeting federal sustainability goals.building is based on the extent to which agencies meet intermediate goals  toward the 2015 goal of implementing the Guiding Principles for all new  construction and major renovation and at least 15 percent of existing  buildings and leases over 5,000 square feet. In fiscal year 2013, 10 of the  16 agencies that received green buildings scores had not met  intermediate goals, or could not demonstrate compliance with the Guiding  Principles for new construction, major renovations, or leases, and   The goal for green  received a red score on the scorecard.reviewed, 2 received a red score—DOD and DOE—and 3 received a  green score—EPA, GSA, and VA.
Of the 5 select agencies we  Federal agencies have been using third-party green building certification  systems since the late 1990s. The third-party certification systems most  commonly used in the United States and by federal agencies are the U.S.  Green Building Council’s Leadership in Energy and Environmental Design  (LEED) and the Green Building Initiative’s Green Globes. achieve different rating levels within the certification systems depending  on how many points are earned. LEED’s rating levels include Certified,  Silver, Gold, and Platinum; and Green Globes’ rating levels include one,  two, three, or four Green Globes. These systems have certifications for  the design and construction of new buildings and the operations and  maintenance of existing buildings, among others.
The Living Building Challenge is another third-party certification system that was  reviewed by Pacific Northwest National Laboratory in 2012. However, representatives of  the International Living Future Institute, which administers the system, told us the system  has not been used by federal agencies. See appendix III for more information on LEED,  Green Globes, and the Living Building Challenge. within the building industry.renovations, EISA requires the Secretary of Energy, in consultation with  GSA and DOD, to identify a certification system and level that the  Secretary determines to be the most likely to encourage a comprehensive  and environmentally-sound approach to certifying green buildings. GSA is  required to evaluate and compare third-party green building certification  systems at least once every 5 years to support DOE’s recommendation.  In 2013, GSA recommended that federal agencies obtain at least a LEED  Silver rating or, if using Green Globes, at least two Green Globes for new  construction and major renovations.
With respect to new construction and major  As part of GSA’s evaluation of certification systems, it recommended in  2013 that federal agencies continue to use these systems. In addition, in  2013, the National Research Council issued a report that recommended  that DOD continue to require new buildings and major renovations use  LEED Silver or an equivalent system. information on federal reviews of third-party green building certification  systems.
Section 2830 of the National Defense Authorization Act for Fiscal Year 2012, Pub. L.  No. 112-81, 125 Stat. 1298, 1695 (Dec. 31, 2011), required the Secretary of Defense to  submit a report to the congressional defense committees with a cost-benefit analysis,  return on investment, and long-term payback of specific energy-efficiency and  sustainability standards used by DOD for military construction and renovation. DOD  requested the National Research Council establish a committee of experts to conduct an  evaluation to inform its report to Congress.
The National Research Council’s study states that the additional incremental costs to  design and construct green buildings are relatively small when compared to the total costs  over a building’s life cycle. Specifically, the study found that research studies indicate that  the incremental costs to design and construct green buildings typically range from 0 to 8  percent higher than the costs to design and construct conventional buildings, depending  on the methodology used in the study and the type of building analyzed. None of the  studies focused on the long-term cost-effectiveness attributable to the use of green  building certification systems.
Summary  DOE identified the criteria that a certification system must meet as required in the  Energy Independence and Security Act of 2007. Specifically, the system under  which the building is certified must: (1) allow assessors and auditors to  independently verify the criteria and measurement metrics of the system; (2) be  developed by a certification organization that: (i) provides an opportunity for public  comment on the system; and (ii) provides an opportunity for development and  revision of the system through a consensus-based process; (3) be nationally  recognized within the building industry; (4) be subject to periodic evaluation and  assessment of the environmental and energy benefits that result under the rating  system; and (5) include a verification system for postoccupancy assessment of the  rated buildings to demonstrate continued energy and water savings at least every 4  years after initial occupancy. The building must be certified to a level that promotes  the guidelines referenced in Executive Order 13423 and Executive Order 13514.
The objective of the review was to determine the alignment between federal high- performance green building requirements and three LEED v4 systems—the current  version of LEED at the time of the review. GSA found that these systems did not  fully align with all of the federal requirements.
GSA recommended that agencies, among other items, continue using third-party  certification systems; select one system at the agency or bureau level–either LEED  or Green Globes; and use system credits that align with federal requirements.
The National Defense Authorization Act of 2012 required DOD to submit a report to  Congress on the impact of specific energy efficiency and sustainability standards  used by DOD for military construction and repair. The National Research Council  conducted the study on DOD’s behalf and recommended that DOD continue to  require new buildings or major renovations be designed to achieve a LEED-Silver or  equivalent rating. It also found that the incremental costs to design and construct  high-performance or green-certified buildings is relatively small compared to the  total costs over a building’s life cycle.
The review analyzed three systems—LEED, Green Globes, and the Living Building  Challenge—against multiple criteria. The review found that none of the systems  completely aligned with all of the federal requirements.
section_title: Federal Efforts to Support Implementation of Key Green Building Requirements Include Oversight, Training, and Other Tools Provided by Several Agencies
paragraphs: Several agencies—CEQ, DOE, EPA, GSA, and OMB—provide oversight,  training, and other tools to support agencies’ implementation of key  federal green building requirements. Officials from these supporting  agencies told us that when the Guiding Principles are revised later this  year, they will need to update some of their efforts. Below are examples  of federal efforts to support agencies’ implementation of key green  building requirements. A more detailed list of federal efforts to support  agencies is included in appendix II.
OMB and CEQ provide guidance and oversight of agencies’  implementation of key green building requirements. CEQ evaluates  and OMB approves agency Strategic Sustainability Performance  Plans—annual documents that describe an agency’s strategy and  plans for, and progress toward achieving green building and other  sustainability goals. CEQ provides agencies with a template each  year that includes guidance on how to report agency progress toward  implementing the Guiding Principles for its buildings, along with other  sustainability goals such as agency-wide greenhouse gas reductions  and water use efficiency and management. CEQ is required to review  and evaluate the plans, and OMB is required to review and approve  the plans. According to OMB staff, the review ensures agencies have  addressed all relevant sustainability goals, including green building.
As discussed above, OMB’s annual sustainability and energy  scorecards score agencies on whether they make progress toward  sustainability goals, including the goal for green buildings— implementing the Guiding Principles for all new construction and  major renovations and for at least 15 percent of existing buildings over  5,000 square feet. OMB staff told us fiscal year 2015 scorecards will  continue to evaluate progress toward the 2015 goal outlined in  Executive Order 13514, but it will need to update the metric for fiscal  year 2016 to reflect the revised Guiding Principles and revised agency  goals as outlined in Executive Order 13693.
DOE provides training, benchmarking, and other tools to support  agencies’ implementation of key green building requirements. Officials  from DOE’s Federal Energy Management Program (FEMP) described  the program as being on the front line of providing assistance to other  agencies regarding sustainability issues. It provides education,  training, guidance, and technical assistance for agencies  implementing key green building requirements. Specifically, FEMP  provides both web-based and in-person training on implementing the  Guiding Principles and also offers web-based training on related  topics, such as best practices in operations and maintenance. Several  of the agencies we spoke with told us their staff has participated in  FEMP training on the Guiding Principles. The web-based, on-demand  training provides an overview of each of the five Guiding Principles  and covers best practices for measuring and reporting on  implementation. FEMP officials told us this training will have to be  updated to reflect the revised Guiding Principles. FEMP had not  planned to update the training this year since the timing of the  revisions was unknown until Executive Order 13693 set a deadline for  completion of the revision, and officials told us updating the training  may require a reallocation of FEMP’s current budget. FEMP also  offers customized training for agencies. For example, GSA worked  with FEMP to develop training sessions that provided customized  information on GSA’s approach to documenting compliance with the  Guiding Principles.
DOE is also a resource for information for agencies with questions  about key green building requirements. For example, a Navy official  told us the Navy obtained assistance from FEMP subject matter  experts about energy conservation measures and found the  assistance it received very helpful. An official from DOE’s  Sustainability Performance Office—its internal office that oversees  departmental sustainability efforts—told us the official has reached out  to DOE’s Pacific Northwest National Laboratory for assistance on  technical matters, such as benchmarking water use and energy  modeling.
In addition, DOE provides support to agencies implementing  requirements for buildings to benchmark energy use through its  Labs21 energy benchmarking tool. Labs21 is a benchmarking tool  designed specifically for laboratories, which are more energy intensive  than other building types and, therefore, cannot be compared directly  to other building types, such as office buildings. According to DOE,  Labs21 enables agencies to compare the performance of their  laboratories to similar facilities and thereby help identify potential  energy cost savings opportunities.
DOE also co-chairs—along with GSA—the Interagency Sustainability  Working Group. According to FEMP officials, the working group  provides officials from federal agencies a forum for information  exchange and collaboration on sustainability issues. Bimonthly  meetings include an opportunity for staff from each agency to highlight  agency progress in green building, view presentations on a variety of  sustainability issues, and network with staff from other federal  agencies. According to FEMP officials, the working group is also a  place for FEMP and GSA to get real-time feedback on agency needs,  which they can then share with the Office of Federal Sustainability— formerly the Office of the Federal Environmental Executive—and  OMB.
EPA provides benchmarking and other tools to support agencies’  implementation of key green building requirements. EPA’s ENERGY  STAR Portfolio Manager is a web-based system for federal agencies  and other entities to measure and track data on buildings, such as  energy and water use. Portfolio Manager has an energy  benchmarking feature that agencies can use to implement the  benchmarking requirement in the Guiding Principles. Specifically, the  feature compares a building’s energy use to that of other, similar  buildings and gives the building a score on a scale from 1 to 100—a  score of 50 represents median energy performance, while a score of  75 or better indicates the building is a top performer. The Guiding  Principles state a preference for agencies to use Portfolio Manager for  energy benchmarking, and DOE guidance designates Portfolio  Manager as the benchmarking system for federal buildings.  According to an EPA official, it is unlikely that the benchmarking  feature of Portfolio Manager will need to be substantially updated in  response to the revised Guiding Principles.
ENERGY STAR Portfolio Manager also includes a Sustainable  Buildings Checklist that is designed specifically to assist agencies with  assessing their existing buildings against the Guiding Principles. The  checklist includes all five Guiding Principles and asks users to check  whether the action has been completed, to identify the responsible  team member, and to upload relevant supporting documentation. For  example, to document compliance with the commissioning  requirement in the Guiding Principles, a user can upload a  commissioning report, or to document compliance with the energy  efficiency requirement, a user can upload an ENERGY STAR  certification.across their building portfolio. The Sustainable Buildings Checklist  may need to be revised when the Guiding Principles are revised, but  an EPA official that manages ENERGY STAR could not comment on  what resources may be needed to update the system without seeing  the revisions.
Agencies can track progress for individual buildings and
GSA provides educational tools and green leasing language to help  agencies implement key green building requirements. GSA’s Office of  Federal High-Performance Green Buildings provides technical and  best practice advice to federal agencies. For example, it developed  the Sustainable Facilities Tool (SFTool), a web-based tool for facility  managers, leasing specialists, and project managers that provides  education on sustainability issues. SFTool allows users to explore a  virtual building—including spaces such as a cafeteria, conference  room, or reception area—to identify opportunities to incorporate the  Guiding Principles and other sustainability requirements into a  building project. SFTool also includes an annotated copy of Executive  Order 13693 with hotlinks that define key terms or provide links to  more detailed information or tools. Officials stated they will revise  SFTool when the Guiding Principles are revised, but they do not  expect to make major changes.
GSA also has green lease policies and procedures and has  developed green lease clauses that agency officials told us can be  used to ensure a lease aligns with the Guiding Principles. According  to GSA officials, they have developed more than 30 green lease  clauses that may be appropriate for leases of different sizes and  complexity. GSA officials said they do not know how much time or  effort will be required to update green leasing language in response to  the revised Guiding Principles without knowing what the content of the  revisions will be. However, officials said it could take 6 months or  more to undergo the necessary reviews.
section_title: Agencies Use Third- Party Certification to Help Implement Key Federal Green Building Requirements
paragraphs: All five select agencies use third-party certification systems to help  implement key federal green building requirements for new construction  and major renovation projects. While third-party certification does not  ensure that a building meets all of the key requirements, agencies we  reviewed have developed various tools to ensure that any remaining  federal requirements are implemented at their buildings after third-party  certification and noted that there are additional benefits to using these  systems beyond helping to implement key requirements. Of the select  agencies we reviewed, none require third-party certification for existing  buildings, but three of the agencies have developed their own systems for  assessing the implementation of key requirements for existing buildings.  Table 2 shows the third-party certification requirements for new  construction and major renovation projects for each of the five select  agencies, including the DOD military services.
Officials from all five select agencies (DOE, EPA, GSA, VA, Air Force,  and Army) told us that third-party certification helps ensure compliance  with key green building requirements by holding contractors and agency  project teams accountable for incorporating the requirements. EPA and  GSA officials stated that requiring contractors to achieve third-party  certification holds them accountable for incorporating sustainable  elements into the design of a building. EPA officials also said that the  third party verifies that a contractor is completing the necessary  documentation for certification, which can also be used by the agency to  demonstrate compliance with key requirements. In addition, we heard  from EPA, VA, Air Force, and Army officials that third-party certification  can provide assurance that project teams are helping the agency to meet  key requirements. Army officials stated that certification drives  accountability for project teams. GSA headquarters and building-level  officials told us that certification provided external validation that their  projects accomplished what the project teams intended.
Select agency officials noted that using third-party certification systems  does not ensure that all of the key federal green building requirements  are met. Pacific Northwest National Laboratory’s review of third-party  certification systems found that, of the three systems reviewed, none  fulfilled all federal green building requirements. Pacific Northwest  National Laboratory evaluated the new construction categories for Green  Globes, LEED, and the Living Building Challenge against 27 federal  green building requirements and found that 10 of the 27 requirements  were fully met using Green Globes, 11 using LEED, and 11 using the  Living Building Challenge. Several select agencies (Air Force, Army,  EPA, GSA, and VA) have developed crosswalks that align specific credit  categories in third-party certification systems with key federal green  building requirements. Officials at the National Renewable Energy  Laboratory (NREL) stated that they used crosswalks developed by GSA  and the Department of the Interior while designing its Research Support  Facility, which obtained a LEED Platinum rating and, according to NREL’s  2014 Site Sustainability Management Plan, complies with the Guiding  Principles.
Officials from GSA’s Office of Federal High Performance Green Buildings  stated that once the Guiding Principles are revised, GSA may develop a  new crosswalk between the Guiding Principles and third-party certification  systems that agencies can use.EPA, VA, and Air Force) said that such a document would be helpful. VA  and Air Force officials noted that while a general crosswalk would be a  good starting point, they would need to customize it based on their  specific needs. For example, VA officials stated that they use the health  care facilities-specific certification for medical centers, which is not very   Officials from several agencies (DOE,  common across the federal government, and they would have to make  sure that a general crosswalk made sense for those buildings. Air Force  officials stated that the DOD policy and its crosswalk will be updated  when the Guiding Principles are revised; in the past when updating DOD  policy they used GSA guidance and customized it through the “DOD  lens.”
Officials from agencies we spoke with said that their agencies use  different tools to ensure that remaining federal requirements are  implemented at their buildings after third-party certification. Several  agencies developed guidance for project managers. For example,  according to VA officials, its Sustainable Design Manual was developed  to be a one-stop shop for new construction and major renovations,  including guidance on how to meet requirements that are not covered by  obtaining third-party certification. Several agencies (EPA, VA, Navy, Air  Force, and Army) have developed a checklist that project managers must  submit. The checklists provide guidance on what is needed to meet the  requirements through third-party certification and by other means. The  Army and Air Force checklists provide the text of the requirement, the  statutory or executive source, and specific design elements that can be  included to meet the requirement. Several agencies we spoke with (DOE,  EPA, GSA, and VA) require specific language in contracts to ensure that  contractors comply with all requirements, even those that did not align  with the third-party certification system.
In addition to helping agencies implement key federal green building  requirements, agency officials and building energy managers (DOE, EPA,  GSA, Army, Air Force, Navy, OASD EI&E, and VA) that we spoke with  mentioned other benefits of using third-party certification, including the  following:  Provides a well-established framework. Some third-party certification  systems are recognized industry standards and familiar to contractors. An  interagency group co-chaired by DOD, DOE, and GSA found that the  main benefit of using third-party certification systems is that they have a  robust infrastructure that is able to keep up with an evolving  marketplace. Furthermore, Pacific Northwest National Laboratory  reported that some federal agencies found the systems to be useful tools  for documenting and tracking a building’s progress toward meeting  requirements in its review of third-party certification systems. In addition,  these systems offer frameworks for reducing energy and water use in  buildings, compared with design approaches and practices used for  conventional buildings, according to the National Research Council’s  review. The National Research Council’s review also found that these  systems can help establish explicit and traceable objectives for future  building performance and a feedback loop to determine if the objectives  were met. VA building-level officials stated that, because of the strict  documentation requirements, they use a third-party certification system  as a guide even when they do not pursue formal certification.
Reduces need for additional staff. DOD officials (Air Force, Army, and  Navy) stated that using third-party certification reduces the need for  additional staff to conduct certain activities. Specifically, current staff  would have an increased workload or agencies would need additional  personnel if they used their own system to validate a building’s  compliance with the key requirements. Air Force headquarters and  building-level officials stated they do not have sufficient personnel to  implement their own system and that using a third-party eliminates the  need to rely on staff to ensure a building complies with key requirements.  A Navy official stated that third-party certification provides a level of  subject matter expertise that their staff currently do not have. Army  officials also stated that third-party certifiers already have the subject  matter expertise and for the government to gain that level of expertise  would require significant time and effort.
Serves as a communication tool. Officials from some agencies (Army,  EPA, and OASD EI&E) and GSA building-level officials said that  certification can be used as a tool to communicate the agencies’  sustainability efforts with its own staff, the public, and contractors.  According to Army and OASD EI&E officials, third-party certification  provides a common language across industry and government to  evaluate and measure sustainability features. GSA building-level officials  told us that obtaining certification was an important method for them to  communicate GSA’s sustainability efforts to the public. Specifically, third- party certification provided a recognizable label to show the public the  agency’s use of sustainable practices in the recent renovation of a large  federal office building. EPA officials we spoke with stated that because a  third-party system is a trusted brand it is like a building received a seal of  approval.
According to some agency headquarters and building-level officials (Air  Force, Army, EPA, and Navy), although third-party certification can  reduce the need for additional staff resources, certification is a resource- intense process. Some agency headquarters and building-level officials  (Air Force, Army, Navy, and EPA) stated that the current process to  complete certification involves some costs. The monetary costs for  certification vary project-to-project, according to several agency officials  (Air Force, EPA, and VA). GSA and DOE building-level officials said that  it was difficult to isolate the cost of certifying their buildings because  certification fees were paid for by the contractors designing and  constructing the building, so these costs are included as part of the  overall contract award. Officials from GSA stated that the cost of certifying  a new construction or major renovation project is, on average, 0.012  percent of the total project budget. A study completed in 2004 for GSA  estimated that the documentation costs associated with obtaining LEED  certification ranged from about $22,000 to about $34,000 per project,  although GSA officials told us that since 2004 these costs have  decreased as the market has changed. According to Green Building  Initiative representatives, the typical total agency costs for Green Globes  certification are about $12,000 to $30,000 per project. In addition to  certification fees, some agencies also allocate staff resources for  administrative purposes, such as reviewing the documentation submitted  by contractors. Representatives of one third-party certification system  stated that, in working with federal agencies, they have found that the  biggest element of the cost of certification for the agencies is the agency  staff time. A Navy official stated that the time needed to complete all of  the documentation was a limitation because staff have other higher- priority responsibilities. According to Army officials, documentation to  support certification also could be particularly challenging for less  experienced project teams or for small contractors. Despite the current  staff resources needed to oversee third-party certification, Army officials  stated that it is still less expensive to use a third-party system than to  develop, execute, and oversee their own. The costs for the Army to obtain  third-party certification are negligible relative to the costs of the design  elements needed to meet key requirements, according to these officials.
Officials from several agencies we spoke with are not certain how they  will use third-party certification systems in the future. Air Force officials  stated that they are currently updating the implementing guidance for its  sustainability policy. As part of DOD’s process, OASD EI&E and Air Force  officials are determining how the use of third-party certification for new  construction projects will be most valuable to help ensure and  demonstrate compliance with federal requirements, which could include  the use of certification systems aimed specifically at assessing  compliance with the Guiding Principles. According to EPA and VA  officials, the agencies may reevaluate the use of third-party certification  depending on the new version of the Guiding Principles. A DOE official  said that it will continue to allow the use of third-party certification but may  not require it anymore.
While none of the five select agencies require third-party certification of  existing buildings, three agencies (EPA, GSA, and VA) developed their  own systems for assessing the implementation of key requirements at  existing buildings. GSA developed a methodology using a third-party  certification system–LEED Volume Program for Operations and  Maintenance–as a framework to identify the type of documentation  needed to achieve certification, as well as compliance with key federal  requirements. GSA mapped each of the Guiding Principles, federal  regulations, and mandates, and the agency’s operational policies against  one or more LEED for Existing Buildings credit categories. It found that, in  some cases, GSA’s policies were more restrictive than LEED’s and, in  other cases, LEED’s requirements were more restrictive. The  methodology GSA developed requires a building to meet the most  restrictive category, whether it is based on the third-party certification  system or GSA policy. According to GSA, project teams can meet  approximately 80 percent of key requirements by obtaining LEED- Certified for Existing Buildings Operations and Maintenance. In addition,  on an annual basis, GSA officials said that they use the LEED Volume  Program for Operations and Maintenance to pursue certification for  approximately one existing building in each of its 11 regions.
section_title: Agencies Face Challenges Implementing Key Requirements Based on Their Building Inventories, Missions, and Competing Priorities
paragraphs: Select agencies face challenges implementing key federal green building  requirements because of the characteristics of their building inventories,  mission-related concerns, competing priorities, and the criteria used to  evaluate compliance with the Guiding Principles, which can be a  disincentive to implementing some requirements. Forthcoming revisions  to the Guiding Principles may address some of these challenges, and we  discuss them under the appropriate challenge. CEQ officials told us they  are aware of and plan to consider these challenges as they complete the  revisions.
subsections: section_title: Characteristics of Building Inventories
paragraphs: The characteristics of building inventories that present a challenge to  agencies as they implement key federal green building requirements  include the age, number, and other characteristics of existing buildings;  special-use buildings (e.g., laboratories, hospitals, and industrial spaces);  leased space; and historic preservation status.
subsections: section_title: Age, Number, and Other Characteristics of Existing Buildings
paragraphs: Officials from several agencies (DOD, DOE, EPA, and VA) told us that  implementing requirements at existing buildings is more challenging than  for new construction or major renovations. According to officials from  DOD (Navy and OASD EI&E), this is because many of their buildings are  old. Air Force officials told us that the majority of the existing building  inventory incorporated the building standards in place at the time they  were constructed and, as a result, have mechanical or other systems that  do not incorporate current requirements. In addition, VA officials said that  existing buildings are more difficult than new construction because certain  design features that could help implement requirements such as passive  solar—a building design that uses structural elements of a building to  heat and cool it without the use of mechanical equipment—in many cases  can only be incorporated when constructing a new building, or with  greatly increased technical difficulty and cost in existing buildings. These  officials said that retrofitting an existing building is also challenging if the  building is occupied because occupants may require relocation, which  entails moving and other costs. In addition, according to OASD EI&E  officials, in some cases, existing buildings may have been inadequately  maintained as a result of funding shortfalls. In January 2003, we  designated federal real property as a high-risk area, in part, due to the  deteriorating condition of some government facilities. We previously  reported that the deteriorated conditions were due, in part, to the age of  many federal facilities (often over 50 years old) and other factors that  resulted in agencies deferring some maintenance and repair of their  facilities. We reported that delaying or deferring routine maintenance  and repairs can, in the short term, diminish the performance of these  systems and, in the long term, shorten service life. In addition, we have  previously reported on opportunities to concurrently address deferred  maintenance and repair backlogs and reduce energy consumption. For  example, in January 2009, we concluded that agencies can replace old  systems—such as heating and air conditioning, electrical, and plumbing— with new, more efficient systems that would lead to energy savings and  reduce or eliminate deferred maintenance and repair associated with the  systems.
DOD officials (Army and OASD EI&E) said that the sheer number of  existing buildings in their portfolios is a challenge. According to DOD’s  2014 Strategic Sustainability Performance Plan, significantly increasing  the percentage of DOD buildings that comply with the Guiding Principles  is a challenge given the tens of thousands of older, existing buildings.  According to Army officials, about 90,000 of the 150,000 existing  buildings in the Army’s inventory meet the threshold requiring  compliance—buildings greater than 5,000 square feet—with the Guiding  Principles. Officials from the Air Force noted that improving existing  buildings involves a process including building assessment, determining  the work needed to elevate the buildings into compliance, identifying  funding, and executing the projects, among other steps. According to  these officials, obtaining the funding and executing the project could take  multiple fiscal years to accomplish.
In addition, according to DOD’s 2014 Strategic Sustainability  Performance Plan, part of the challenge posed by DOD’s existing  buildings is that a large fraction of them do not have meters in place to  track electricity use, and making investment decisions related to retrofits  requires accurate consumption data. Also, according to DOD and DOE  officials, federal buildings are often configured and managed as  campuses and, although the Guiding Principles are building-specific,  DOD officials said that they are more successful implementing certain  requirements, such as on-site renewable energy, at the campus level.
section_title: Special-Use Buildings (Laboratories, Hospitals, and Industrial Spaces)
paragraphs: According to officials from several agencies (DOD, DOE, EPA, and VA)  their building inventories include certain building types, such as  laboratories, hospitals, and industrial buildings for which some  requirements are difficult to implement. For example, according to DOE’s  2014 Strategic Sustainability Performance Plan, DOE’s building inventory  consists of special-use facilities—scientific laboratories, accelerators, light  sources, supercomputers and data centers, and industrial facilities—and,  as a result of these factors, DOE is challenged with integrating  sustainability into aging infrastructure and energy-intensive processes.
Hospitals have much higher energy intensities compared with offices and  other types of buildings and also have fewer opportunities for reducing  energy use, according to VA’s 2014 Strategic Sustainability Performance  Plan.hospitals will be challenging because of strict medical standards, energy- intensive medical equipment, and the increasing number of patient visits.  In addition, VA officials said that its hospitals are already more energy   According to VA’s plan, future reductions in energy use at VA  efficient than the average U.S. hospital; it has already implemented the  most cost-effective measures for improving energy efficiency; and  additional measures would be more costly. Similarly, laboratories use  significantly more energy and present greater environmental challenges  than offices, according to EPA’s 2014 Strategic Sustainability  Performance Plan. EPA officials told us that laboratories have resource- intensive equipment and mechanical systems. For example, EPA’s  laboratory designs include single-pass air cooling systems that use more  resources than other systems. However, EPA officials told us that they  plan to classify laboratories according to risk and identify those where  they can adjust the number of air flows accordingly to conserve  resources.
Several DOD officials (Air Force, Army, and Navy) told us that many of  the buildings in their inventory are industrial, which creates challenges for  implementing certain key requirements. For example, the Air Force’s  inventory includes aircraft maintenance facilities, ground vehicle  maintenance facilities, hangars, and storage warehouses, and  implementing certain requirements such as daylighting in these spaces  can be challenging. Army officials noted that DOD’s industrial buildings’  energy use differs from more traditional energy use that most energy  conservation measures are geared to address.
According to officials from several agencies (DOD, DOE, and VA), it is  difficult to apply the Guiding Principles to certain buildings or spaces. The  Guiding Principles were written for more typical commercial buildings and  applying them to different building types can be challenging, according to  DOD officials. According to one DOE official, it would be helpful if the  revisions provided some flexibility based on building type because DOE  has diverse property types including office space, laboratories, and  highly-secure industrial facilities such as nuclear sites. Similarly,  according to VA officials, ideally the new Guiding Principles would allow  specialized buildings such as medical centers a path to compliance that  acknowledges their unique mission-based characteristics.
section_title: Leased Space
paragraphs: Officials from several agencies (DOD, GSA, and VA) identified challenges  implementing requirements for leased space. For example, according to  GSA officials, leases are often in buildings where the government only  has a partial presence and certain requirements—such as overall water  consumption reduction—cannot be met without steps being taken for the  whole building. Challenges implementing the requirements for leased  space may be affected by the new Executive Order and revisions to the  Guiding Principles. Executive Order 13693 differs from Executive Order  13514 with regard to leases. Specifically, Executive Order 13514 required  that agencies ensure that at least 15 percent of the agency’s existing  buildings (above 5,000 gross square feet) and building leases (above  5,000 gross square feet) meet the Guiding Principles. However,  Executive Order 13693 does not call for leased space to meet the  Guiding Principles, but rather requires that agencies ensure that all new  agency lease solicitations over 10,000 rentable square feet include,  among other specifications, (1) criteria for energy efficiency either as a  required performance specification or as a source selection evaluation  factor and (2) requirements for building lessor disclosure of carbon  emission or energy consumption data for that portion of the building  occupied by the agency that may be provided by the lessor through  submetering or estimation from prorated occupancy data, whichever is  more cost-effective.
section_title: Historic Preservation Status
paragraphs: Officials from several agencies (DOD, GSA, and VA) said that  implementing key requirements at historic buildings is a challenge  because historic preservation requirements limit what can be done to  retrofit these buildings. For example, according to Army and Navy  officials, implementing new technologies to reduce energy use may be  difficult because the exterior appearance or interior features of a building  may need to be maintained or replacement of windows may not be  allowed. Air Force officials noted that meeting both green building and  historic preservation requirements often leads to less conventional design  and construction solutions, which can significantly impact both cost and  the ability to complete the project. According to GSA officials, renovating  an historic building to implement key requirements is generally deemed  more expensive than moving into a leased building that does not have the  same stringent historic preservation requirements.
While agencies identified buildings with historic preservation status as  posing a challenge to their ability to implement requirements, GSA’s  renovation of two historic buildings—50 United Nations Plaza Federal  Office Building in San Francisco, California, and the Wayne N. Aspinall  Federal Building and U.S. Courthouse in Grand Junction, Colorado—both  incorporated green building requirements and received LEED Platinum  certification.
The renovations to the 50 United Nations Plaza Federal Office Building  included new mechanical, electrical, lighting, and plumbing systems; roof  replacement and refurbishment of existing historic wood windows; and  restoration of the historically significant interiors and central courtyard, as  well as redesign of office interiors. GSA estimated that the building at 50  United Nations Plaza would achieve annual energy savings of about 59  percent compared with a comparable building and projected annual  energy savings for this project of about $393,958. In addition, according  to GSA officials, although GSA could not include a photovoltaic solar  array on the roof of the Wayne Aspinall Federal Building in the manner  that it originally planned because historic preservation officers said it  would violate the integrity of the building, GSA worked with the engineers  on the project to come up with an alternative strategy to incorporate a  smaller solar array on-site.
section_title: Mission-Related Concerns
paragraphs: Officials from all five select agencies (DOD, DOE, EPA, GSA, and VA)  told us that mission-related concerns can make implementing certain key  requirements challenging. For example, VA must implement new safety  requirements in its hospitals and other buildings with overnight stays to  help prevent and control health-care associated Legionella disease  (Legionnaires’ disease) and implementing these requirements will  increasingly impact the agency’s ability to implement energy and water  conservation requirements, according to VA officials. Specifically, the new  safety requirements will increase water and energy demand because they  require, among other activities, (1) increased flushing of hot and cold  water at outlets and (2) maintaining specific water temperature ranges— cold water should be kept at or below 67 degrees to the greatest extent  practicable, and hot water should be kept no lower than 124 degrees.  Cooling water below 67 degrees in hot environments where cold water is  commonly warmer than 67 degrees requires additional energy, and  flushing water systems increases water use, according to VA officials. VA  officials also said that the goals of reducing energy use and wait times for  veterans are in conflict; specifically, VA is extending medical center hours  to address a backlog of patients, which will increase its energy use. In  addition, Air Force and VA officials told us that implementing daylighting  requirements—which call for a minimum amount of daylight exposure in a  certain amount of the space—is challenging due to mission-specific   Specifically, Air Force officials also told us that daylighting  requirements.may be contrary to what the space is used for or potentially detrimental to  the mission. For example, daylighting may not be possible because of  security concerns in spaces, such as a Sensitive Compartmented  Information Facility—an enclosed area within a building that does not  have windows and is used to process sensitive information—or it is not  practical in a space, such as a command control center where daylight  could disrupt the ability to view screens.
section_title: Competing Priorities
paragraphs: Officials from all five select agencies (DOD, DOE, EPA, GSA, and VA)  told us that they face challenges because they have multiple priorities that  compete for limited resources. In addition, DOD and DOE officials said  that there are limited incentives to implement requirements that do not  have any economic benefit. Specifically, according to DOD officials, the  use of limited resources to implement certain key requirements—such as  those that aim to improve indoor air quality—can be difficult to justify  because they may not also reduce energy use or operating costs. Also,  DOD officials said that green buildings can increase occupant productivity  and morale, but there is no way to include these intangible benefits in a  life-cycle cost analysis. According to VA officials and its 2014 Strategic  Sustainability Performance Plan, retaining green building features in  already-designed new construction projects is challenging due to budget  constraints and the need to address higher priority, mission-based needs.  Officials told us that ensuring green building elements are retained and  not removed at the end of the project to reduce costs if the project looks  like it will go over budget is challenging. According to EPA’s 2014  Strategic Sustainability Performance Plan, its laboratory mechanical  system upgrades are complex and frequently take several years to  design, complete, and commission, and finding ways to fund projects in a  time of reduced resources, including sustainable building improvement  projects, is challenging.
section_title: Criteria for Evaluating Compliance
paragraphs: Officials from DOD and DOE told us that the criteria used to evaluate  compliance with the Guiding Principles—which require a building to meet  all of the dozens of requirements included in the Guiding Principles—can  be a disincentive to implementing some requirements at an individual  building because they receive no credit for implementing one requirement  if they do not implement all the requirements. Air Force officials said that  the current criteria encourage agencies to focus on investing in high- performing buildings for which a relatively small investment results in  compliance. These officials said that this is in conflict with an approach  focused on addressing the worst performing buildings and systems first  and, as a result, pursuing compliance in isolation would be in conflict with  the agency-wide energy and water strategies. Revisions to the Guiding  Principles could affect this challenge if, as Air Force officials stated, the  criteria used to evaluate implementation is adjusted to allow buildings to  demonstrate progress as opposed to being an all or nothing standard.
CEQ officials could not comment on whether the all or nothing approach  would be reconsidered as part of the revision, but officials said that they  were aware of that issue and want to ensure that they are not providing  any disincentives for agencies to meet some of the requirements even if  they cannot meet all.
section_title: Agency Comments
paragraphs: We provided CEQ, DOD, DOE, EPA, GSA, OMB, and VA with a draft of  this report for their review and comment. DOE and VA provided written  comments, reproduced in appendix IV and V, respectively, and also  provided technical comments that were incorporated, as appropriate.  CEQ, DOD, EPA, GSA, and OMB either had no comments or provided  technical comments that were incorporated, as appropriate.
We are sending copies of this report to the appropriate congressional  committees; the Chairman of the Council on Environmental Quality; the  Administrators of the General Services Administration and the  Environmental Protection Agency; the Director of the Office of  Management and Budget; and the Secretaries of Defense, Energy, and  Veterans Affairs. In addition, the report is available at no charge on the  GAO website at http://www.gao.gov.
If you or your staff members have any questions about this report, please  contact Frank Rusco at (202) 512-3841 or ruscof@gao.gov, Brian J.  Lepore at (202) 512-4523 or leporeb@gao.gov, or David J. Wise at (202)  512-2834 or wised@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. GAO staff members who made major contributions to this  report are listed in appendix VI.
section_title: Appendix I: 2008 Guiding Principles for Sustainable New Construction, Major Renovations, and Existing Buildings
subsections: section_title: New construction and major renovations
paragraphs: Use an integrated team to develop and  implement policy regarding sustainable  operations and maintenance. establishes and maintains an integrated project  team as described on the Whole Building  Design Guide  <http://www.wbdg.org/design/engage_process. php> in all stages of a project’s planning and  delivery;  integrates the use of the Office of Management  and Budget’s A-11, Section 7, Exhibit 300:  Capital Asset Plan and Business Case  Summary;  establishes performance goals for siting,  energy, water, materials, and indoor  environmental quality along with other  comprehensive design goals and ensures  incorporation of these goals throughout the  design and lifecycle of the building; and  considers all stages of the building’s lifecycle,  including deconstruction.
Incorporate sustainable operations and  maintenance practices within the  appropriate Environmental Management  System.  Assess existing condition and operational  procedures of the building and major  building systems and identify areas for  improvement.  Establish operational performance goals for  energy, water, material use and recycling,  and indoor environmental quality, and  ensure incorporation of these goals  throughout the remaining lifecycle of the  building.  Incorporate a building management plan to  ensure that operating decisions and tenant  education are carried out with regard to  integrated, sustainable building operations  and maintenance.  Augment building operations and  maintenance as needed using occupant  feedback on work space satisfaction.
Employ commissioning practices tailored to the size  and complexity of the building and its system  components in order to verify performance of  building components and systems and help ensure  that design requirements are met. This should  include an experienced commissioning provider,  inclusion of commissioning requirements in  construction documents, a commissioning plan,  verification of the installation and performance of  systems to be commissioned, and a commissioning  report.
Employ recommissioning, tailored to the size  and complexity of the building and its system  components in order to optimize and verify  performance of fundamental building systems. Commissioning must be performed by an  experienced commissioning provider.  When building commissioning has been  performed, the commissioning report, summary  of actions taken, and schedule for  recommissioning must be documented. In  addition, meet the requirements of Energy  Independence and Security Act of 2007 (EISA),  Section 432 and associated Federal Energy  Management Program (FEMP) guidance.  Building recommissioning must have been  performed within 4 years prior to reporting a  building as meeting the Guiding Principles.
section_title: II. Optimize energy performance Increase energy efficiency
paragraphs: New construction and major renovations  design to earn the ENERGY STAR® targets for new  construction and major renovation where applicable.  For new construction, reduce energy use by 30%  compared to the baseline building performance rating  per the American National Standards  Institute/American Society of Heating, Refrigerating  and Air-Conditioning Engineers, Inc.,  (ASHRAE)/Illuminating Engineering Society of North  America Standard 90.1-2007, Energy Standard for  Buildings Except Low-Rise Residential. For major  renovations, reduce the energy use by 20 percent  below prerenovations 2003 baseline. Laboratory  spaces may use the Labs21 Laboratory Modeling  Guidelines. rating of 75 or higher or an equivalent  Labs21 Benchmarking Tool score for  laboratory buildings.
Option 2: Reduce measured building  energy use by 20% compared to building  energy use in 2003 or a year thereafter  with quality energy use data.
Option 3: Reduce energy use by 20%  compared to the ASHRAE 90.1-2007  baseline building design if design  information is available.
Use energy efficient products   Use ENERGY STAR® and FEMP-designated energy  efficient products, where available.
Use ENERGY STAR® and FEMP-designated  energy efficient products, where available.
Measurement and verification  Per the Energy Policy Act of 2005 Section 103, install  building level electricity meters to track and  continuously optimize performance. Per EISA Section  434, include equivalent meters for natural gas and  steam, where natural gas and steam are used.
Per the Energy Policy Act of 2005 Section 103,  install building level electricity meters to track  and continuously optimize performance. Per  EISA Section 434, include equivalent meters  for natural gas and steam, where natural gas  and steam are used.
Compare actual performance data from the first year  of operation with the energy design target, preferably  by using ENERGY STAR® Portfolio Manager for  building and space types covered by ENERGY  STAR®. Verify that the building performance meets  or exceeds the design target, or that actual energy  use is within 10% of the design energy budget for all  other building types. For other building and space  types, use an equivalent benchmarking tool such as  the Labs21 benchmarking tool for laboratory  buildings.
Compare annual performance data with  previous years’ performance data, preferably  by entering annual performance data into the  ENERGY STAR® Portfolio Manager. For  building and space types not available in  ENERGY STAR®, use an equivalent  benchmarking tool, such as the Labs21  benchmarking tool for laboratory buildings.
Per Executive Order 13423, implement renewable  energy generation projects on agency property for  agency use, when lifecycle cost-effective.
Per Executive Order 13423, implement  renewable energy generation projects on  agency property for agency use, when life  cycle cost-effective.
Per the Energy Independence and Security Act  (EISA) Section 523, meet at least 30% of the hot  water demand through the installation of solar hot  water heaters, when life cycle cost-effective.
New construction and major renovations  use of harvested rainwater, treated wastewater,  and air conditioner condensate should also be  considered and used where feasible for  nonpotable use and potable use where allowed. water baseline for plumbing fixtures older than  1994 is 160% of the Uniform Plumbing Codes  2006 or the International Plumbing Codes  2006 fixture performance requirements, or
Option 2: Reduce building measured potable  water use by 20% compared to building water  use in 2003, or a year thereafter with quality  water data.
Outdoor Water. Use water efficient landscape and  irrigation strategies, such as water reuse,  recycling, and the use of harvested rainwater, to  reduce outdoor potable water consumption by a  minimum of 50% over that consumed by  conventional means. The installation of water  meters for locations with significant outdoor water  use is encouraged.
Outdoor Water. Three options can be used to  measure outdoor potable water use performance:
Option 1: Reduce potable irrigation water use  by 50% compared to conventional methods.
Option 2: Reduce building related potable  irrigation water use by 50 percent compared  to measured irrigation water use in 2003 or a  year thereafter with quality water data.
Option 3: Use no potable irrigation water.
Employ design and construction strategies that  reduce storm water runoff and discharges of  polluted water off-site. Per EISA Section 438, to  the maximum extent technically feasible, maintain  or restore the predevelopment hydrology of the  site with regard to temperature, rate, volume, and  duration of flow using site planning, design,  construction, and maintenance strategies.
Employ strategies that reduce storm water runoff  and discharges of polluted water off-site. Per EISA  Section 438, where redevelopment affects site  hydrology, use site planning, design, construction,  and maintenance strategies to maintain hydrologic  conditions during development, or to restore  hydrologic conditions following development, to  the maximum extent that is technically feasible.
Install water meters for building sites with  significant indoor and outdoor water use is  encouraged. If only one meter is installed, reduce  potable water use (indoor and outdoor combined)  by at least 20% compared to building water use in  2003, or a year thereafter with quality water data.
Per the Energy Policy Act of 2005 Section 109,  when potable water is used to improve a  building’s energy efficiency, deploy life cycle cost- effective water conservation measures.
Per the Energy Policy Act of 2005 Section 109,  when potable water is used to improve a building’s  energy efficiency, deploy life cycle cost-effective  water conservation measures.
Specify the Environmental Protection Agency’s  (EPA) WaterSense-labeled products or other  water conserving products, where available.  Choose irrigation contractors who are certified  through a WaterSense labeled program.
Specify EPA’s WaterSense-labeled products or  other water conserving products, where available.  Choose irrigation contractors who are certified  through a WaterSense labeled program.
section_title: IV. Enhance indoor environmental quality Ventilation/thermal comfort
paragraphs: Meet ASHRAE Standard 55-2004, Thermal  Environmental Conditions for Human Occupancy,  including continuous humidity control within  established ranges per climate zone, and  ASHRAE Standard 62.1-2007, Ventilation for  Acceptable Indoor Air Quality.
Meet ASHRAE Standard 55-2004, Thermal  Environmental Conditions for Human Occupancy  and ASHRAE Standard 62.1-2007, Ventilation for  Acceptable Indoor Air Quality.
New construction and major renovations  condensation to prevent building damage,  minimize mold contamination, and reduce health  risks related to moisture. building damage, minimize mold contamination,  and reduce health risks related to moisture. For  façade renovations, Dew Point analysis and a plan  for cleanup or infiltration of moisture into building  materials are required.
Achieve a minimum daylight factor of 2%  (excluding all direct sunlight penetration) in 75%  of all space occupied for critical visual tasks.  Provide automatic dimming controls or accessible  manual lighting controls, and appropriate glare  control.
Automated lighting controls (occupancy/vacancy  sensors with manual-off capability) are provided  for appropriate spaces including restrooms,  conference and meeting rooms, employee lunch  and break rooms, training classrooms, and offices.  Two options can be used to meet additional  daylighting and lighting controls performance  expectations:
Option 1: Achieve a minimum daylight factor  of 2% (excluding all direct sunlight  penetration) in 50% of all space occupied for  critical visual tasks, or
Option 2: Provide occupant controlled lighting,  allowing adjustments to suit individual task  needs, for 50% of regularly occupied spaces.
Specify materials and products with low pollutant  emissions, including composite wood products,  adhesives, sealants, interior paints and finishes,  carpet systems, and furnishings.
Use low emitting materials for building  modifications, maintenance, and cleaning. In  particular, specify the following materials and  products to have low pollutant emissions:  composite wood products, adhesives, sealants,  interior paints and finishes, solvents, carpet  systems, janitorial supplies, and furnishings.
Implement a policy and post signage indicating  that smoking is prohibited within the building and  within 25 feet of all building entrances, operable  windows, and building ventilation intakes during  building occupancy.
Prohibit smoking within the building and within 25  feet of all building entrances, operable windows,  and building ventilation intakes.
Use integrated pest management techniques as  appropriate to minimize pesticide usage. Use  EPA-registered pesticides only when needed.
Follow the recommended approach of the Sheet  Metal and Air Conditioning Contractor’s National  Association Indoor Air Quality Guidelines for  Occupied Buildings under Construction, 2007.  After construction and prior to occupancy,  conduct a minimum 72-hour flush-out with  maximum outdoor air consistent with achieving  relative humidity no greater than 60%. After  occupancy, continue flush-out as necessary to  minimize exposure to contaminants from new  building materials.
New construction and major renovations  meeting or exceeding EPA’s recycled content  recommendations. For other products, specify  materials with recycled content when practicable.  If EPA-designated products meet performance  requirements and are available at a reasonable  cost, a preference for purchasing them shall be  included in all solicitations relevant to  construction, operation, maintenance of, or use in  the building. EPA’s recycled content product  designations and recycled content  recommendations are available on EPA’s  Comprehensive Procurement Guideline website  at <www.epa.gov/cpg>. or exceeding EPA’s recycled content  recommendations [for building modifications,  maintenance, and cleaning]. For other products,  use materials with recycled content such that the  sum of postconsumer recycled content plus one- half of the preconsumer content constitutes at  least 10% (based on cost or weight) of the total  value of the materials in the project. If EPA- designated products meet performance  requirements and are available at a reasonable  cost, a preference for purchasing them shall be  included in all solicitations relevant to construction,  operation, maintenance of, or use in the building.  EPA’s recycled content product designations and  recycled content recommendations are available  on EPA’s Comprehensive Procurement Guideline  website at <www.epa.gov/cpg>.
Biobased content. Per Section 9002 of the Farm  Security and Rural Investment Act, for USDA- designated products, specify products with the  highest content level per USDA’s biobased  content recommendations. For other products,  specify biobased products made from rapidly  renewable resources and certified sustainable  wood products. If these designated products meet  performance requirements and are available at a  reasonable cost, a preference for purchasing  them shall be included in all solicitations relevant  to construction, operation, maintenance of, or use  in the building. USDA’s biobased product  designations and biobased content  recommendations are available on USDA’s  BioPreferred web site at  <www.usda.gov/biopreferred>.
Biobased content. Per Section 9002 of the Farm  Security and Rural Investment Act, for USDA- designated products, use products with the  highest content level per USDA’s biobased  content recommendations. For other products, use  biobased products made from rapidly renewable  resources and certified sustainable wood  products. If these designated products meet  performance requirements and are available at a  reasonable cost, a preference for purchasing them  shall be included in all solicitations relevant to  construction, operation, maintenance of, or use in  the building. USDA’s biobased product  designations and biobased content  recommendations are available on USDA’s  BioPreferred website at  <www.usda.gov/biopreferred>.
Environmentally preferable products. Use  products that have a lesser or reduced effect on  human health and the environment over their  lifecycle when compared with competing products  or services that serve the same purpose. A  number of standards and ecolabels are available  in the marketplace to assist specifiers in making  environmentally preferable decisions. For  recommendations, consult the Federal Green  Construction Guide for Specifiers at  <www.wbdg.org/design/greenspec.php>.
Environmentally preferable products. Use products  that have a lesser or reduced effect on human  health and the environment over their lifecycle  when compared with competing products or  services that serve the same purpose. A number  of standards and ecolabels are available in the  marketplace to assist specifiers in making  environmentally preferable decisions. For  recommendations, consult the Federal Green  Construction Guide for Specifiers at  <www.wbdg.org/design/greenspec.php>.
New construction and major renovations  construction, demolition and land clearing  materials, excluding soil, where markets or on-site  recycling opportunities exist. Provide salvage,  reuse and recycling services for waste generated  from major renovations, where markets or on-site  recycling opportunities exist. beverage containers and paper from building  occupants, batteries, toner cartridges, outdated  computers from an equipment update, and  construction materials from a minor renovation.
Eliminate the use of ozone depleting compounds  during and after construction where alternative  environmentally preferable products are available,  consistent with either the Montreal Protocol and  Title VI of the Clean Air Act Amendments of 1990,  or equivalent overall air quality benefits that take  into account lifecycle impacts.
Eliminate the use of ozone depleting compounds  where alternative environmentally preferable  products are available, consistent with either the  Montreal Protocol and Title VI of the Clean Air Act  Amendments of 1990, or equivalent overall air  quality benefits that take into account lifecycle  impacts.
section_title: Appendix II: Select Federal Efforts to Support Implementation of Key Federal Green Building Requirements
paragraphs: Provides instructions to federal agencies on designing, constructing, maintaining,  and operating buildings in sustainable locations, as called for in Executive Order  13514, Federal Leadership in Environmental, Energy, and Economic Performance.
Provides instructions to federal agencies on implementation of water use efficiency  and management goals in Executive Order 13514, Federal Leadership in  Environmental, Energy, and Economic Performance.
Web-based and in-person training on the Guiding Principles, including training  customized to an agency’s needs.
Establishes guidelines for agencies to meter their buildings for energy (electricity,  natural gas, and steam) and water. Among other guidance, defines which buildings  are appropriate to meter and provides metering prioritization recommendations for  those agencies with limited resources.
Designates ENERGY STAR Portfolio Manager as the building energy use  benchmarking system to use for federal facilities. Describes minimum data inputs  and public disclosure requirements, among other things.
Training and educational tools that describe types of building commissioning— including recommissioning and continuous commissioning—and when and where  each might best be used to ensure that a facility performs according to its design  and the needs of its owners and occupants.
Training and education on applying lifecycle cost analysis to evaluate the cost- effectiveness of energy and water efficiency investments, with assistance provided  by the National Institute of Standards and Technology.
Identifies products that are in the upper 25% of their class in energy efficiency.  FEMP sets efficiency levels for product categories that have the potential to  generate significant federal energy savings.
Allows laboratory owners to compare the performance of their laboratories to similar  facilities and thereby help identify potential energy cost savings opportunities.
Online tool for tracking and assessing energy and water use. Certain property types  can receive a 1-100 ENERGY STAR score, which compares a building’s energy  performance to similar buildings nationwide.
Designed to assist agencies in assessing their existing buildings against the Guiding  Principles, including serving as a repository for compliance documents.
Offers guidance and tools for purchasing products or services that have a lesser or  reduced effect on human health and the environment when compared with  competing products or services that serve the same purpose.
Gives agencies a framework to help them reduce storm water runoff from  development projects and protect water resources.
Purpose/description  Aims to provide consumers with easy ways to save water, as both a label for  products—such as toilets and sinks—and an information resource to help people  use water more efficiently.
subsections: section_title: General Services Administration (GSA) Sustainable Facilities Tool (SFTool)
paragraphs: Web-based tool intended for facility managers, leasing specialists, and project  managers that provides education on sustainability issues, including on the Guiding  Principles.
Developed leasing clauses that can be used to demonstrate the lease complies with  the Guiding Principles.
DOE and GSA  Interagency Sustainability Working Group  Provides sustainability officials from federal agencies a forum for information  exchange and feedback on sustainability issues.
Describes preaward and postaward procurement actions to verify compliance with a  contract’s sustainable requirements, and provides resources for confirming a  contractor has provided acceptable documentation to show compliance with  sustainable requirements.
Score agencies on whether they are meeting intermediate goals for compliance with  sustainability goals, including for the Guiding Principles.
section_title: Appendix III: Third-Party Certification Systems Reviewed or Required by Select Federal Agencies
paragraphs: Summary   Projects attain a rating  through the achievement  of all prerequisites and  points in different  categories related to the  eight areas of focus. The  total possible points vary  based on the version of  LEED that is used. LEED is a web-based  system and all  documentation is  submitted online.  Green Business  Certification Inc. provides  the third-party certification  service by reviewing the  submitted documentation.
Projects attain a rating  through the achievement  of points in different  categories related to  seven areas of focus. A  project can attain a total of  1,000 points.  Complete an initial web- based survey, and  subsequent  documentation is  submitted to the third- party assessor or can be  submitted online.  An on-site assessment is  required for certification.  The third-party assessor is  contracted by the Green  Building Initiative.
Summary   Projects attain ‘Living’  status by completing all  the imperatives, or  categories, related to  seven petals, or areas of  focus. ‘Living’ status  means that a building is  regenerative, not just  green.  A building can receive  Petal Certification if it  meets the requirements of  three or more petals,  including water, energy, or  materials.  A project can complete  petals in three typologies,  or certification types.  A project can attain Net  Zero Energy certification  by demonstrating through  actual performance data  that it produces more  energy than it consumes.
Rating levels  Living Building  Challenge  Award and  Certificate  Petal  Recognition  Net Zero  Energy  Certification  This is not a comprehensive list of categories and subcategories for LEED certification. Examples of  other categories include retail, schools, and hospitality.
section_title: Appendix IV: Comments from the Department of Energy
section_title: Appendix V: Comments from the Department of Veterans Affairs
section_title: Appendix VI: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contacts
section_title: Staff Acknowledgments
paragraphs: In addition to the individuals named above, Karla Springer (Assistant  Director), Harold Reich (Assistant Director), Sara Vermillion (Assistant  Director), Janice Ceperich, John Delicath, Swati Deo, Debra Draper,  Philip Farah, Cindy Gilbert, Geoffrey Hamilton, Armetha Liles, Marietta  Mayfield Revesz, and Barbara Timmerman made key contributions to this  report.