BOMA International—Building Owners and Managers Association International

BOMA Position

BOMA International supports voluntary benchmarking and encourages its members to benchmark their buildings at least annually using EPA’s ENERGY STAR Portfolio Manager platform or other similar programs. BOMA International opposes mandates for energy benchmarking, disclosure and labeling.

BOMA International recognizes that many states and municipalities are implementing mandatory benchmarking and disclosure requirements. In recognition of such, BOMA supports the creation of a national model building energy performance program, based on the EPA ENERGY STAR Portfolio Manager platform, in order to avoid a patchwork of differing regulations from location to location. BOMA supports the creation of a user-friendly model that is easy to use and easy to understand and promotes knowledge of building energy performance without hindering real estate transactions. As part of any such program, utilities must be required to provide whole building benchmarking data to building owners and managers, with disclosure limited to parties directly involved in a sale, lease or financing transaction.

BOMA also supports increased funding for the Energy Information Administration (EIA) to enhance their research and depth of data in the Commercial Buildings Energy Consumption Survey (CBECS) and for EPA ENERGY STAR. With increased federal funding, EPA ENERGY STAR may be able to provide more robust data to expand its 1 to 100 rating system to all commercial property types.

Background

More and more jurisdictions are looking to establish building labeling programs that require buildings to make available a statement of energy performance for all real estate transactions, including sale, lease, and financing. California, Washington, Philadelphia, Seattle, Austin, Washington, DC and New York, among others, are leading the way in requiring more transparent energy efficiency data to be made public.

During the 111th Congress, legislation was introduced to establish a program to develop procedures to label buildings for their energy performance characteristics, using building type and consumption data to be developed by the Energy Information Administration. This program would serve as a model, and states would be encouraged (through funding incentives) to adopt the model. The legislation did not pass. BOMA believes that this approach goes well beyond creating a national model program for consistency across the country and compels states to implement such a program; therefore BOMA opposed the provision.

In 2011, DOE announced it was developing a voluntary asset rating program. The asset rating program is intended to complement ENERGY STAR, with ENERGY STAR providing the operational rating and the new program providing a “score” on the building’s asset rating by examining the building systems. DOE launched a pilot program in the spring of 2012 and is now working to fine-tune the program.

DOE has also launched the Buildings Performance Database (Beta v1.1). The BPD now has data from over 50,000 buildings - sufficient data to conduct analyses of more than 15 common retrofit measures, including commercial building retrofits to HVAC controls, lighting, economizers, and windows. BOMA continues to support the development of these types of voluntary programs and tools, but continues to fight against mandating their use.