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This post is the first in a series on the federal government’s use of green building certifications. Part 2: Sustainable Federal Buildings: What's the Law?
Special-interest groups have been fighting the LEED rating systems on multiple fronts ever since LEED got a foothold in government policymaking. These groups (primarily chemical manufacturers and timber interests) are making headway.
Despite these pressures, along with LEED’s weakness as a policymaking tool (like all voluntary rating systems, it really doesn’t work as a mandate unless the government is explicit about credits and energy performance targets that must be achieved), a recent report recommended that the Department of Defense should continue with its current certification policy: LEED Silver or equivalent.
DoD’s updated Unified Facilities Criteria (UFC), hot off the press, has stood by that recommendation for new construction:
In accordance with OUSD AT&L Memorandum, “Department of Defense Sustainable Buildings Policy”, DoD Components will design and build all new construction and major renovations projects: 1) in compliance with the Guiding Principles, 2) third-party certified to the US Green Building Council (USGBC) Leadership in Energy and Environmental Design (LEED) Silver level (or approved equivalent rating), and 3) achieve no fewer than 40% of the certification points related to energy and water conservation. In addition, all repair and renovations projects must conform to the Guiding Principles where they apply. [emphasis added]
How important is it for the military to keep using LEED? For the sake of public perception, it’s extremely important: if DoD thinks LEED is the best way to ensure green building design and construction quality, then a lot of other people will too.
On the other hand, LEED does not—and was never meant to—meet all of the military’s building needs. They’ve got a lot of other things going on, from carbon requirements to energy performance reporting to enhanced security needs, and their UFC documents are a great demonstration of the difference between building codes or standards (like the IgCC and ASHRAE 189.1—both of which USGBC helped develop) and building rating systems (like LEED).
After paging through the National Research Council’s report—whose main conclusion seemed to be that there wasn’t enough data to make a data-based decision—I still had some questions: what’s “equivalent,” for one. So I spoke with Maureen Sullivan, director of environment, safety, and occupational health at DoD, and Lt. Col. Keith Welch, environment, safety, and occupational health officer.
Here are four key points I got from Sullivan and Welch.
DoD sets policy for all the services and the Department of Veterans Affairs, but it doesn’t micromanage or do much enforcement. When I asked Sullivan what the equivalent of LEED Silver might be, she replied, “We assign that responsibility to the military departments”—and for some departments or individual installations, that may include the Green Globes rating system developed by the Green Building Initiative (GBI).
“We didn’t want to lock ourselves into one particular green rating system,” Welch adds. “We offered the services and installations the opportunity to use other systems if they chose to.”
The Department of Veterans Affairs (VA) is best known for its use of Green Globes—and even that certification is becoming more rare now that GBI has developed its Federal Guiding Principles Compliance Program, apparently tailored for the VA. (It’s unclear whether DoD will deem this an acceptable third-party rating system, however: “We’re not in the mode of trying to check blocks and chase a metric,” said Welch of the program. “We want to use every construction dollar we have to greatest effect.)
The Army and Air Force both certify with LEED Silver or better, and the Navy’s standard is LEED Gold.
Congress called a halt to LEED spending on Gold or Platinum certification in late 2011, pending a DoD report about the costs and benefits of various LEED systems and the ASHRAE standards. The National Research Council’s report to DoD should not be confused with DoD’s report to Congress, which is still being written.
In fact, the military just completed a massive revamp of its whole policy anyway (see more on the UFC below)—and that will affect what DoD says to Congress in the next few weeks.
For now, the military still isn’t allowed to pay extra for LEED Gold or Platinum, though we already know the Army is moving forward with its certification plans, saying it doesn’t actually cost more to certify at higher levels.
Congressmen might have called for this cost report because of lobbying, but Sullivan implied that DoD can’t be bothered with the political side of things.
“Our discussions with the Hill are focused on our goal to make the most effective use of every dollar that comes to the Department of Defense,” she said. “At the end of the day, we want the military departments to use the best tools available to reduce their life-cycle energy and water usage and to reduce the cost of maintaining and operating a facility.” LEED is just one of those tools, she said, along with the ASHRAE 189.1 standard.
That might sound like Beltway babble, but DoD’s focus on revising the UFC gives it credence: LEED is fine for what it is, says Sullivan, but DoD’s massive overhaul of its green building policies and practices is where the rubber really meets the road with the military and green building.
“We’ve gone through a pretty elaborate process to take [ASHRAE] 189 and say which parts make the most economic sense for us,” Sullivan said. “This is one document that unifies the facility criteria that will feed into how we design.”
“This raises the floor for all our buildings,” notes Welch. “Instead of relying on a third-party rating system, we’ve given construction agents language to put straight into construction documents to require that certain things be done. We wanted to use the UFC to take out the variability and give us some ability to standardize the outcome.”
The UFC, in other words, will function like a building code for the military. It requires many things that are optional in LEED or aren’t addressed at all.
My conversation took place before the new UFC was released—and at that point, whether to keep third-party certifications at all hadn’t even been decided. The way Sullivan and Welch talked about it, I actually thought LEED was going to get the boot. So why did they keep it?
“The NRC report that just came out on February 15 validated our current policy as cost-effective,” wrote Welch in an email. “One of their recommendations was to keep it that way.”
Although DoD decided to keep LEED for now, it’s clear the leadership is questioning the importance of certifying. Welch adds, “Now that the NRC study is in and the UFC is published, we have an opportunity to re-evaluate our policy.”
This doesn’t seem to be the case with the U.S. General Services Administration (GSA), which makes interagency recommendations about green building and will be releasing its review later this year: they’ve been quite clear that third-party certifications are a crucial part of saving money with green building.
What do you think? If the military has its own extensive building standard, does it need LEED, Green Globes, or any other rating system? Share your thoughts in the comments.
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