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4 Issues As the task group developed its framework for acquiring sustainable federal facilities, it identified a number of issues related to implementation of the framework. These issues are summarized below. FIRST COSTS, LIFE-CYCLE COSTS, AND SUSTAINABLE DEVELOPMENT A fundamental conflict exists between federal acquisition policies and the federal budget process that will limit the benefits of sustainable development. Executive Order 13123 and other federal guidance related to facilities acquisition require life-cycle costing. Life-cycle costing implicitly recognizes that, in some circumstances, additional money invested in the design and construction of a facility can yield significant cost savings over the life of the facility, particularly during operation and maintenance. The federal budget process, in contrast, is structured to look at design and construction costs, the so-called first costs of facilities, not life-cycle costs. The NRC report Stewardship of Federal Facilities: A Proactive Strategy for Managing the Natior''s Public Assets (NRC, 1998), found that the "full life-cycle costs of new facilities are not considered in the current federal budget process. Instead, only the projected design and construction costs annear as a separate line item for con~re.~innn1 cons~aerat~on. - AS a result, oust percent of the total cost of the life cycle cost of a facility are not scrutinized as extensively as the first costs. Agencies can, and have, been able to acquire facilities with sustainable development features at the same first cost as "traditional" facilities. On a case-by-case basis, agencies can present information to Congress and the Office of Management and Budget justifying higher first costs to achieve lower life-cycle costs. However, unless the federal budget process is modified to take into account life-cycle costs as a standard procedure, it will be difficult for agencies to realize the filet range of benefits and cost savings possible from sustainable development. MASTER SPECIFICATIONS AND GUIDEBOOKS Although some federal agencies are shifting to commercial specifications for design and construction, others maintain master specifications and guide books. In both cases, it is likely that some existing specifications will be in conflict with or will not fully support sustainable development objectives simply because the specifications were based 49
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so Sustainable Federal Facilities on experience with traditional building standards, guidelines, and criteria. The General Services Administration, the State Department, and the Army have contracted with private-sector firms to review existing specifications and to suggest modifications to support sustainable development. As experience with sustainable development is gained, the master specifications will need to be reviewed and updated. Some agencies, including the Naval Facilities Engineering Command, are moving away from technical specifications towards performance-based specifications and in the process are incorporating sustainable development principles in the desired performance of a facility. PERFORMANCE STANDARDS FOR SUSTAINABLE FACILITIES Another issue that agencies must resolve is the performance standards against which sustainable facilities will be measured. The requirement for performance standards is established by Executive Order 13148, which states, "Within 18 months of the date of this order [signed April 21, 2000], each agency shall conduct an agency-level environmental management system self assessment based on the Code of Environmental Management Principles for Federal Agencies developed by the EPA (61 Fed. Reg. 54062) and/or another appropriate environmental management system framework." The Code of Environmental Management Principles requires agencies to make a management commitment to environmental programs through policy documents, conduct compliance assurance and pollution prevention assessments, and institute enabling systems to ensure performance and accountability through measurement. The only standard set in executive orders is in Executive Order 13123 which states "Agencies shall strive to meet the Energy Star (Registered Trademark) building criteria for energy performance and indoor environmental quality in their eligible facilities to the maximum extent practicable by the end of 2002." Energy Star™, however, has limited use as a measurement for overall sustainable facility performance in that it addresses only the energy-related principles of sustainable development. The only nationally recognized sustainable facility performance standard is the U.S. Green Building Council's Leadership in Energy and Environmental Design (LEED™), a rating system that also rates siting, materials, water, indoor environmental quality, and operations and maintenance. Under the LEED™ system, facilities can achieve a Certified, Certified Silver, Certified Gold, or Certified Platinum rating based on the use of sustainable design techniques and components. Credits are awarded in five categories: sustainable siting; water efficiency; energy and atmosphere; materials and resources; and indoor environmental quality. For sustainable siting, prerequisites include erosion and sedimentation control. Site selection points are based on avoidance of prime agricultural land, flood plains, and wetlands, habitat for threatened or endangered species, and public parkland. Points are also awarded for urban redevelopment; use of brownfields sites; provisions for alternative transportation facilities, reduced site disturbance of greenfields, storm water management, landscaping, and exterior design to reduce heat islands and light pollution. For water efficiency, points are awarded for water-use reduction measures including efficient landscaping and innovative technologies to reduce the amount of potable water required to convey sewage. For energy and atmosphere, prerequisites
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Issues 51 include fundamental building commissioning, minimum energy performance based upon the American Society of Heating, Refrigerating and Air Conditioning Engineers and Illuminating Engineering Society of North America's Standard (ASHRAE/IESNA) 90-~- 1999 for energy consumption, and CFC reduction. Points are awarded for optimizing energy performance beyond the prerequisite level, employing renewable energy, providing additional building commissioning, elimination of CFCs and haloes, measurement and verification using the Department of Energy's International Performance Measurement and Verification Protocol and~the use of green power. For materials and resources, prerequisites include storage and collection of recyclable materials. Points are awarded for building reuse, construction waste management, resource reuse, recycled content, use of local and regional materials, and rapidly renewable materials and certified wood. For indoor environmental quality, prerequisites include minimum indoor air quality performance as defined by ASHRAE 62-1999 with no smoking in the building. Points are awarded for carbon dioxide monitoring, increased ventilation effectiveness based on ASHRAE 129-1997, a construction indoor air quality management plan, low- emitting materials, indoor air and pollutant source control, controllability of systems, thermal comfort, daylighting and views. Additional points are awarded for innovation leading to exceptional performance and the use of services by a LEED™-accredited professional. A number of federal agencies, including the Department of State, the General Services Administration, and the Naval Facilities Engineering Command, have committed to using LEED™ as their performance measure for sustainable development. Additional information on Energy Star™ and the LEED™ rating system is contained in Chapter 5. INDENTIFYING ENVIRONMENTALLY PREFERABLE PRODUCTS The use of non-federal, third-party certifiers is encouraged by Executive Order 13101 "Greening the Government Through Waste Prevention, Recycling and Federal Acquisition," which states, "Agencies are encouraged to use all of the options available to them to determine the environmentally preferable attributes of products and services in their pilot and demonstration projects, including the use of technical expertise of non- governmental entities such as labeling, certification, or standards-developing organizations, as well as using the expertise of the National Institute of Standards and Technology." The Executive Order directs the Environmental Protection Agency (EPA) to "develop guidance within 90 days from the date of this order to address environmentally preferable purchasing". In response, the EPA issued the Final Guidance on Environmentally Preferable Purchasing for Federal Agencies in August 1999, which states: Section 12~) of the National Technology Transfer and Advancement Act of 1995 (NTTAA) (Pub. L. 104-~13, §12(d), 15 U.S.C. 272 note) and OMB Circular A- ~ 19 (63 FR8546, February 19, 1998) direct Federal agencies to use both domestic and international voluntary consensus standards in lieu of government-unique
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52 Sustainable Federal Facilities standards in their procurement and regulatory activities, except where it would be inconsistent with applicable law or otherwise impractical. The Act's purpose is to reduce the cost of procurement and regulation by requiring a Federal agency to draw upon any suitable technical standard already used in commerce or industry rather than inventing a new standard. Some of those standards might relate to evaluating environmental performance and measilrin~ the Pn`7irmnm~nta1 attributes of products or services. In establishing Environmental Preferable Purchasing pilot projects or planning other environmentally sensitive activities, agencies should first determine whether there is an applicable voluntary consensus standard that would meet its needs. LESSONS LEARNED ~ a,= ~~_ _~^ ~ ~~ V~~1~11~01 Designing, constructing, operating, and maintaining sustainable facilities is a new initiative for federal agencies. Because of the government-wide nature of this initiative, it is important to capture lessons learned about experience and to share experiences, both good and bad, within and among agencies. Such experiences can be related to the use of various project delivery systems, establishing objectives, the use of performance measures, and so forth. Lessons learned can be shared through computerized data bases; publications; presentations at conferences, workshops, and other events; networking; and participation in professional societies. Several of the resources listed in Chapter 5 incorporate case studies and lessons learned for sustainable development. 7 REFERENCE NRC (National Research Council). 1 998. Stewardship of Federal Facilities: A Proactive Strategy for Managing the Nation's Public Assets. Washington, D.C.: National Academy Press.
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