Disclosing Building Performance
ENERGY STAR for commercial buildings and industrial plants has become increasingly prominent as more cities are requiring that owners/operators disclose the energy efficiency of their properties as indicated by ENERGY STAR scores.
In the buildings program, the EPA provides an online Portfolio Manager to facilitate the benchmarking of building energy performance. The Portfolio Manager evaluates and communicates the energy performance of a building, relative to similar buildings in the United States, based on physical and operating characteristics, such as size, number of workers, operating hours per week, number of PCs, etc.
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To qualify for the ENERGY STAR label, commercial buildings (e.g., banks, offices, supermarkets, hospitals) must score at least 75 on the Agency’s 1 to 100 energy performance scale, a score that compares a building to similar buildings rated in a national survey conducted by the Department of Energy’s Energy Information Administration. Manufacturing plants in specific sectors (including pulp and paper plants, cement plants, and petroleum refineries) must score at least 75 compared to plants performing the same operations.
Two Requirements
In the program, the EPA requires that a licensed professional (PE or registered architect; see “Architects and manufacturing plants” below) validates each Statement of Energy Performance (SEP) used to apply for the ENERGY STAR label. The Agency’s Licensed Professional’s Guide lists two tasks for licensed professionals:
- They must verify that the data entered about the building are accurate. This includes verifying the building’s physical characteristics, operating characteristics, and energy consumption. All building characteristics are provided in entirety on the data checklist and must be verified through a site visit by the licensed professional.
- During the site visit, the licensed professional must also verify that the building complies with current industry standards for indoor environmental quality, including thermal comfort, illumination, outside air ventilation, and control of indoor air pollutants. These standards are meant to ensure that an ENERGY STAR label is not pursued at the expense of a comfortable and healthy work environment. The licensed professional must use his/her expert judgment to determine whether the building as a whole provides a suitable work environment for its occupants.
Degree of Control
In follow-up guidance, the EPA stated that it is common engineering practice for PEs to use nonlicensed individuals to complete certain work related to projects that ultimately bear the PE’s seal and signature. The Agency supports this position by referring to the Code of Ethics for Professional Engineerspublished by the National Society of Professional Engineers (NSPE) as well as the requirements of many state licensing boards. In general, the Agency states that these bodies require that the PE exercise some level of control over the non-professional conducting the site visit either through physical presence or the use of communication devices. For example, the Texas Engineering Practice Act and Rules states, “The degree of control should be such that the engineer personally makes engineering decisions or personally reviews and approves proposed decisions prior to their implementation.”
Based on its research, the EPA guidance provides the following clarification:
“For purposes of verifying the information contained in the application for the ENERGY STAR label for commercial buildings, the PE may engage a representative to conduct all or part of the site visit while under his or her direction and control. However, the SEP and the corresponding Data Checklist required must still bear the seal and signature of the licensed PE, who remains responsible for all work performed by others under his or her direction.”
The EPA emphasizes that to validate the SEP, a PE must possess a current license and be in good standing.
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Architects and Manufacturing Plants
The guidance does not specify that a site visit to a manufacturing plant may be conducted by a nonprofessional under a PE’s supervision. Also, in 2010, ENERGY STAR for buildings allowed registered architects, in addition to PEs, to certify SEPs. However, the guidance does not indicate that nonprofessionals under a registered architect’s direction may conduct the commercial building site visit. Building and plant owners/operators should contact ENERGY STAR to clarify these items.