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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.
Representative terms from entire chapter:
environmental quality
