UPDATE - October 11, 2011
On September 22, BOMA International filed comments with the U.S. Department of Energy (DOE) in response to a Notice of Request for Information on DOE’s plans to develop a voluntary National Asset Rating Program for Commercial Buildings (AR Program). The AR Program would establish an asset rating system for commercial buildings based on a national standard and would evaluate physical characteristics and as–built energy efficiency of these buildings. DOE plans to have an initial program design available soon and will launch a pilot program in early 2012, though they have promised that there will be future opportunities for stakeholders to provide input.
BOMA International outlined several concerns in its comments about this type of program. First and foremost, BOMA questioned the need for the AR Program, when there are already several programs, certifications and tools available in the marketplace. In addition, though DOE calls it a "voluntary" program, we have concerns that states and cities may mandate it as they move forward on benchmarking and disclosure laws. With that in mind, it is critical that DOE gets this right and BOMA will continue to participate in the ongoing dialogue.
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Recently, the Department of Energy (DOE) published a Notice of Request for Information (RFI) on their plans to develop a voluntary National Asset Rating Program for Commercial Buildings (AR Program). The AR Program would establish an Asset Rating system for commercial buildings based on a national standard and would evaluate physical characteristics and as-built energy efficiency of these buildings.
DOE is seeking comments on or before September 22, 2011. DOE plans to have an initial program design available by the end of September. Obviously, for them to have a program designed by the end of September, just eight days after comments are due, implies that this program is well underway. Nevertheless, BOMA International plans to provide comments, and we encourage you all to as well.
Please review the RFI and submit your comments before the deadline. If you submit the information to DOE, we would love to receive a copy of your comments.
Also, Karen Penafiel (kpenafiel@boma.org), Vice President of Advocacy at BOMA International, is asking for BOMA members to provide any comments or thoughts to help BOMA International draft a response. Karen will need all industry comments no later than September 9 to give her time to draft our response.
BOMA has several concerns regarding this type of program. First and foremost, though DOE calls it a “voluntary” program, it will likely be adopted by states/cities as they move forward on benchmarking and disclosure laws. With that in mind, it’s critical that DOE gets this right. It is also very unclear how the AR Program will fit in and coordinate with the existing Operational Rating system, ENERGY STAR Portfolio Manager.
The DOE RFI can be accessed at http://www.gpo.gov/fdsys/pkg/FR-2011-08-08/pdf/2011-20014.pdf
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