Building  Owners  and  Managers  Association  International

Building Owners and Managers Association International

Energy Efficiency and Green Building Codes

BOMA POSITION

BOMA International supports the development and promulgation of national model energy efficiency building codes - the International Code Council’s (ICC) International Energy Conservation Code (IECC) and the American Society of Heating, Refrigerating and Air-Conditioning Engineers ASHRAE/IESNA Standard 90.1 Energy Standard for Buildings Except Low-Rise Residential Buildings – that meet the needs of city, state and federal code adopting authorities as well as the commercial real estate industry by the inclusion of only those provisions that are technically feasible, cost-effective, and enforceable to establish minimum efficiency requirements that apply to all newly constructed buildings, and to tenant finish-out, additions and major renovations to existing buildings.

BOMA International also supports the development and promulgation of national model green/sustainable building codes – the ASHRAE/USGBC/IES Standard 189.1 Standard for the Design of High-Performance Green Buildings Except Low-Rise Residential Buildings, ICC’s International Green Construction Code (IGCC) and the ICC/NAHB Standard 700 National Green Building Standard for residential buildings - that provide for greater energy efficiency and sustainability than the model energy codes but that also preserve building owners’ options in selecting the systems or components that best meet their needs. 

BOMA International supports the adoption and implementation of the IECC and ASHRAE/IES 90.1 to apply to all newly constructed buildings, and to tenant finish-out, additions and major renovations to existing buildings by city, state or federal code adopting authorities consistent with this BOMA policy and the respective municipal, state or federal building code adoption processes. 

BOMA International also supports the adoption and implementation of ASHRAE/USGBC/IES 189.1, IGCC and ICC/NAHB 700 to apply only to those buildings or construction projects designated as “green” by adopting authorities, those participating in voluntary green building programs, or those where the building owners and/or management have determined that compliance with these green/sustainable building codes is advantageous. BOMA International does not support the adoption and implementation of green/sustainable building codes intended to apply to all newly constructed buildings, or to all tenant finish-out, additions and major renovations to existing buildings except as outlined above. 

Background

BOMA International continues to be directly and aggressively involved in the development of national model energy codes.  BOMA holds an organizational voting member seat on the ASHRAE 90.1 Standing Standards Project Committee and is also a critical voice for commercial real estate industry in the ongoing development of the IECC.  BOMA is directly involved in the implementation of these codes at the city, state and federal level.  Both of these national model energy codes are well established in the marketplace and constitute a far-reaching series of energy efficiency requirements that can be utilized for every type and size of building and are applicable for all 50 states. Each code is intended as a minimum requirement applying to all newly constructed buildings, and to tenant finish-out, additions and major renovations to existing buildings within the jurisdiction of the adopting authority.  BOMA has continuously advocated that for any energy code to be acceptable to commercial real estate, basic business investment principles must be observed in the cost justification for any provisions included in the codes.  BOMA has also steadfastly held that as buildings and their systems differ considerably in age, size, location, and climate, a “one size fits all” approach to minimum energy efficiency requirements is neither feasible nor cost-effective.  BOMA International believes that energy codes applying to existing buildings should not include the same energy efficiency levels that can be designed into newly constructed buildings, and also seeks to preserve flexibility for building owners and their design teams.

BOMA International has also been directly involved in the development of green building codes for both residential and commercial buildings.  BOMA holds an organizational voting member seat on the Standard 189.1 Standing Standards Project Committee.  This green building code, first released in 2010, contains provisions that go far beyond minimum requirements of either Standard 90.1 or the IECC and therefore is not intended as the minimum code applying to all newly constructed buildings, nor for existing building tenant finish-out, additions or major renovations.  BOMA International was also a voting member of the committee that developed the green residential code - ICC/NAHB Standard 700, National Green Building Standard – which was released in 2008 and covers single family residences, multi-residential apartment buildings, and multi-residential units within commercial buildings.  BOMA has also played a significant role in the development of the first (2012) edition of ICC’s International Green Construction Code, and has set a high priority on ensuring these three green codes are as coordinated as possible, thus eliminating the possibility of confusion and disparate code interpretation and enforcement.

BOMA believes any requirement to comply with the provisions of Standard 189.1, Standard 700, or the IGCC should apply only to those buildings and projects designated as “green” by voluntary green building programs, or as required by the code adoption authority such as buildings owned by the city or state government or buildings seeking to be certified as green by governmental authorities, or projects voluntarily seeking recognition as more efficient than buildings meeting the minimum energy code requirement. 

BOMA International has taken the lead in encouraging real estate owners and managers to take an active role in implementing responsible consumption practices that are environmentally and economically sustainable utilizing proven technologies and procedures.  Building owners and managers have a social responsibility to utilize “green” technologies where proven to increase building efficiency and that provide a positive return on investment (ROI).  However, it is critical that building regulations applying to green technologies, including much higher energy efficiency levels than that resulting from compliance with minimum energy code requirements, are not implemented as a substitute for those same minimum energy code requirements.​​