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

Letter

Background

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.

Federal Efforts to Support Implementation of Key Green Building Requirements Include Oversight, Training, and Other Tools Provided by Several Agencies

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.

Agencies Use Third- Party Certification to Help Implement Key Federal Green Building Requirements

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.

Agencies Face Challenges Implementing Key Requirements Based on Their Building Inventories, Missions, and Competing Priorities

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.

Characteristics of Building Inventories

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.

Age, Number, and Other Characteristics of Existing Buildings

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.

Special-Use Buildings (Laboratories, Hospitals, and Industrial Spaces)

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.

Leased Space

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.

Historic Preservation Status

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.

Mission-Related Concerns

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.

Competing Priorities

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.

Criteria for Evaluating Compliance

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.

Agency Comments

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.

Appendix I: 2008 Guiding Principles for Sustainable New Construction, Major Renovations, and Existing Buildings

New construction and major renovations

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.

II. Optimize energy performance Increase energy efficiency

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.

IV. Enhance indoor environmental quality Ventilation/thermal comfort

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.

Appendix II: Select Federal Efforts to Support Implementation of Key Federal Green Building Requirements

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.

General Services Administration (GSA) Sustainable Facilities Tool (SFTool)

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.

Appendix III: Third-Party Certification Systems Reviewed or Required by Select Federal Agencies

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.

Appendix IV: Comments from the Department of Energy

Appendix V: Comments from the Department of Veterans Affairs

Appendix VI: GAO Contacts and Staff Acknowledgments

GAO Contacts

Staff Acknowledgments

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.