Congress has an ongoing interest in ensuring that the 500,000 buildings and other structures owned and operated by the Department of Defense (DOD) are operated effectively in terms of cost and resource use. Section 2830 of the National Defense Authorization Act for fiscal year (FY) 2012 (NDAA 2012) requires the Secretary of Defense to submit a report to the congressional defense committees on the energy-efficiency and sustainability standards used by DOD for military construction and major renovations of buildings. DOD’s report must include a cost-benefit analysis, return on investment, and long-term payback for the building standards and green building certification systems identified below:
(A) American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) Standard 189.1-2011 for the Design of High-Performance, Green Buildings Except Low-Rise Residential.
(B) ASHRAE Energy Standard 90.1-2010 for Buildings Except Low-Rise Residential.
(C) Leadership in Energy and Environmental Design (LEED) Silver, Gold, and Platinum certification for green buildings, as well as the LEED Volume certification.
(D) Other American National Standards Institute (ANSI)-accredited standards.
DOD’s report to the congressional defense committees must also include a copy of DOD policy prescribing a comprehensive strategy for the pursuit of design and building standards across the department that include specific energy-efficiency standards and sustainable design attributes for military construction based on the cost-benefit analysis, return on investment, and demonstrated payback required for the aforementioned building standards and green building certification systems.
THE COMMITTEE’S TASK
To obtain independent, objective advice in developing its response to Section 2830 of NDAA 2012, the Deputy Undersecretary of Defense for Installations and Environment asked the National Research Council (NRC) to establish an ad hoc committee of experts to undertake three related tasks:
- Conduct a literature review that synthesizes the state-of-the-knowledge about the costs and benefits, return on investment, and long-term payback of specified design standards related to sustainable buildings.
- Evaluate a consultant-generated methodology and analysis of the cost-benefit, return on investment, and long-term payback for specified building design standards and evaluate the consultant’s application of the methodology using empirical data from DOD buildings.
- Identify potential factors and approaches that the DOD should consider in developing a comprehensive strategy for its entire portfolio of facilities that includes standards for energy efficiency and sustainable design.
The specified design standards to be evaluated are ASHRAE Energy Standard 90.1-2010 for Buildings Except Low-Rise Residential; ASHRAE Standard 189.1-2011 for High-Performance Green Buildings Except Low-Rise Residential; LEED Silver, Gold, Platinum, and Volume certifications; and other ANSI-accredited standards such as Green Globes.
It became evident at the first committee meeting that the wording of task 2 was not clear in regard to the relationship between the NRC, DOD, and the consultant, or the work being undertaken by the consultant. For purposes of clarity, the committee notes that the consultant was hired directly by DOD under a separate contract and the consultant’s report is contained in its entirety in Appendix C.
The DOD consultant’s report developed an analytical approach that included a traditional benefit-cost analysis to calculate long-term benefits and costs, adjusted rate of return on investment, and payback of ASHRAE Standards 90.1-2010 and 189.1-2011 and of the LEED and Green Globes green building certification systems; sensitivity analyses using a range of scenarios that represented uncertainty in future conditions; and a test of the analytical approach using data from DOD buildings to identify issues that might arise if the approach were to be applied in the DOD operating environment.
The committee evaluated the cost-benefit and sensitivity analyses as outlined in task 2. Regarding the consultant’s application of the methodology using empirical data from DOD buildings, it is important to note that the consultant’s purpose was not to conduct a cost-benefit analysis for a sample of DOD buildings but to identify issues that might arise if the proposed analytical approach were to be used by DOD. Thus, the committee evaluated the potential application of the consultant’s analytical approach to the DOD operating environment.
A clearer description of task 2 would read as follows:
Evaluate a report developed under a separate contract by a DOD consultant that focuses on a methodology and analysis of the cost-benefit, return on investment, and long-term payback for specified building design standards and evaluate the potential application of the consultant’s analytical approach to the DOD operating environment.
HIGH-PERFORMANCE OR GREEN BUILDINGS
The Energy Independence and Security Act of 2007 (EISA 2007) defines the attributes of high-performance buildings, which include reductions of energy, water, material, and fossil fuel use, improved indoor environmental quality for occupants, improved worker productivity, and lower life-cycle costs when compared to baselines for building performance. The terms “green” and “sustainable” are often used interchangeably with high-performance buildings, but there are no standard definitions for those terms. In this report, high performance refers to buildings that are specifically called out as meeting the EISA standard. Green is a more inclusive term used to indicate buildings that are designed to be highly
energy efficient, to meet green building certification systems, or to be otherwise regarded as sustainable. Buildings that are not described as high-performance or green are referred to as conventional buildings.
Building standards and green building certification systems have been developed by nonprofit organizations to provide a framework for the design and operation of high-performance and green buildings. Building standards typically establish minimum requirements for the design of one aspect of a building’s performance (for example, energy). Green building certification systems, in contrast, take a “whole building” approach to design by accounting for the interrelationships among building design, materials, mechanical systems, technologies, and operating practices.
LEED, developed by the U.S. Green Building Council (USGBC), and Green Globes, licensed by the Green Building Initiative (GBI), are the green building certification systems most commonly used in the United States. EISA 2007 requires federal agencies to use a green building certification system for new construction and major renovations of buildings.
ECONOMIC PERFORMANCE METHODS AND MEASURES
Several closely related methods and measures are used for determining the economic performance of buildings, building systems, and components. There are salient differences among the methods and measures that bear on their correct application and interpretation for evaluating the cost-effectiveness of DOD construction and renovation projects.
Benefit-cost analysis (BCA) is most often used to determine if a government program or investment can be justified on economic grounds. It entails assigning monetary values to societal benefits from the program/investment, as well as to assessing direct program/investment costs, all over a specified time horizon (e.g., 20 years), and finding the difference between benefits and costs as net present value (NPV) benefits. A positive NPV means that total benefits exceed total costs, and the program or other investment is cost-effective. BCA can also be used to make mutually exclusive choices among building design, systems, and components. The choice with the highest NPV benefits is preferred on economic grounds. Related additional economic performance measures—benefit-cost ratios, internal rates of return on investment, adjusted internal rates of return on investment—can be computed from the time-denominated cash flows of benefits and costs of BCA.
Payback refers to the time period at which initial investment is recovered. Payback measures do not include future savings that may occur after the initial investment is recovered. For that reason, payback measures are not appropriate for comparing the long-term economic effectiveness of buildings or projects, because the alternative with the shortest payback period may not be the alternative with the greatest NPV benefits or the greatest return on investment.
COMPLEXITY OF THE TASK
The committee’s completion of its three related tasks was complicated by the following factors:
• Difficulty of measuring building performance objectively. The research on high-performance or green buildings inherently incorporates some level of subjectivity because of the unique nature of buildings, diversity in baselines for comparison studies, and the lack of a standard protocol for research on this topic.
All buildings differ in terms of location, materials, design, size, function, technologies, operational practices, and other factors, which influence overall building performance. The diversity in building
design and the multitude of factors that contribute to any building’s performance make it difficult to isolate the specific factors that contribute to energy use, water use, or other performance measures.
There are no national baselines from which to measure the performance of multiple factors associated with high-performance or green buildings. Instead, some baselines have been developed to measure individual factors such as energy.
The Commercial Buildings Energy Consumption Survey (CBECS) is the only national data source for detailed characteristics and energy use of U.S. commercial buildings. EISA 2007 establishes the CBECS as a baseline within the definition of high-performance buildings. However, there are well-documented deficiencies in the CBECS database, as detailed in Chapter 3. There are no national databases for water use, operations and maintenance, indoor environmental quality, or worker productivity as it relates to buildings. Baselines for comparing those factors are typically developed differently for individual studies.
There is no standard protocol for conducting research on high-performance or green buildings, although some studies do use similar methodologies or evaluation methods. Together all of these factors hinder objective comparisons across studies and preclude definitive, fully documented findings. The subjectivity inherent in making comparisons across research studies instead requires judgments based on a “preponderance” of evidence.
• Recent release of ASHRAE Standards 189.1-2011 and 90.1-2010 and the LEED Volume certification program. Few, if any buildings have been built to the latest versions of the ASHRAE standards. The only information available about the expected performance of buildings constructed to those standards was based on the same design models used in their development. The LEED Volume certification is also a new program for which there is little documented experience thus far.
• Continuous improvement of building standards and green building certification systems and related factors. Building standards and green building certification systems are regularly updated to take into account new objectives, techniques, knowledge, and technologies for buildings. As a result, multiple versions of each exist. With a few exceptions, research studies do not identify the specific versions of the standards and certification systems under which the buildings studied were constructed. Instead, the research typically compares a sample of buildings that are defined as green to a sample of conventional buildings. Studies related to LEED-certified buildings typically include buildings constructed under different versions of LEED that meet a range of certification levels, so even these have great variability. All of those factors and the incorporation by reference of building standards such as ASHRAE 90.1 into green building certification systems create confounding factors for research studies, which hinder the attribution of specific benefits and costs to specific standards or certification systems.
• Quantity and quality of the literature. Although there are hundreds of publications related to high-performance or green buildings, relatively few are well-designed empirical studies. Of these, several focused specifically on LEED-certified buildings; none focused on Green Globes-certified buildings. The only data available on the actual performance of Green Globes-certified buildings were individual case studies.
Other factors that made the task more complex included issues related to qualitative and quantitative measurements of building performance, measured data versus modeled data for energy and water use, and the inclusion of a mix of building types in most empirical studies.
THE COMMITTEE’S APPROACH
The committee focused on the main purposes of the statement of task but did not have time to conduct extensive additional investigations. Thus, the committee’s report does not evaluate building standards or
certification systems that were not specified, describe the various debates about the use of green building certification systems, or acknowledge the full array of initiatives that are underway at DOD. Such initiatives include approaches for reducing greenhouse gas emissions, and for net-zero-energy buildings.
For its evaluation of the research literature, the committee determined it would focus on studies that met the following criteria:
• Time frame. The committee relied on studies published in 2004 or later because the first studies evaluating the incremental costs of LEED-certified buildings were published in 2004. The first evaluations of a sample of at least six high-performance or green buildings in the United States were published in 2006.
• Robustness. The committee focused on studies with clearly stated objectives, a clearly defined methodology, findings based on empirical data, and a sample size of at least six buildings. Individual case studies were not evaluated because of the prevalence of bias, error, and chance.
• Relevancy to the DOD operating environment. DOD typically owns and operates buildings for 30 years or longer. Although the committee identified a number of robust, timely studies related to the market value, rental rates, vacancy rates, and appraised value of green buildings compared to conventional buildings, the committee did not evaluate those studies in detail because market factors typically are not relevant to the DOD operating environment.
In regard to the DOD consultant’s report, the committee discussed the proposed methodology with the DOD consultant and representatives of ASHRAE, the USGBC, and GBI on June 28-29, 2012. The committee suggested changes to the methodology for the consultant’s consideration. In September 2012, the committee received the consultant’s final report, Cost-Effectiveness Study of Various Sustainable Building Standards in Response to NDAA 2012 Section 2830 Requirements for an in-depth evaluation (Slaughter, 2012; see Chapter 3 and Appendix C).
The committee’s findings are based on the literature review, the evaluation of the DOD consultant’s study, and the experience and expertise of its members. The findings are presented below with a brief explanation of the committee’s rationale. Chapter 5 contains more detailed explanations of the rationale for the committee’s findings and recommended approaches.
Finding 1: The committee did not identify any research studies that conducted a traditional benefit-cost analysis to determine the long-term net present value savings, return on investment, or long-term payback related to the use of ASHRAE Standard 90.1-2010, ASHRAE Standard 189.1-2011, and the LEED or Green Globes green building certification systems.
Of the 25 studies that met the committee’s criteria for time frame, robustness, and relevancy to the DOD operating environment, only two (Turner, 2006; Kats, 2010) provided some analyses of NPV benefits, return on investment, or payback associated with high-performance or green buildings. Those studies, however, did not evaluate the cost-effectiveness of the specific building standards or green building certification systems. Instead they looked at the cost-effectiveness of green buildings compared to conventional buildings.
Finding 2: There is some limited evidence to indicate that provisions within ASHRAE Standard 189.1-2011 may need to be selectively adopted if use of this standard is to be cost-effective in the DOD operating environment.
ASHRAE Standard 189.1-2011 contains mandatory requirements that limit the ability of DOD to adapt the standard to its operating environment. The foreword to ASHRAE 189.1-2011 states that “new provisions within the standard were not uniformly subjected to economic assessment” and that cost-benefit assessment was not a necessary criterion for acceptance of any given proposed change to the standard from the 2009 version. The study Incremental Costs of Meeting ASHRAE Standard 189.1 at Air Force Facilities: An Evaluation of Four AF MILCON Projects (LMI, 2011) and the committee’s review of ASHRAE Standard 189.1-2011 identified some mandatory requirements that may not be cost effective or feasible in the DOD operating environment.
Finding 3. Research studies indicate that the incremental costs to design and construct high-performance or green buildings typically range from 0 to 8 percent higher than the costs to design and construct conventional buildings, depending on the methodology used in the study and the type of building analyzed. The additional incremental costs to design and construct high-performance or green buildings are relatively small when compared to total life-cycle costs.
Several studies focused on the incremental costs to design and construct high-performance or green buildings when compared to conventional buildings. Those studies used different methodologies to calculate the additional costs of design and construction and applied them to different types of buildings. The studies indicated that the additional first costs for high-performance or green buildings would typically range from 0 to 8 percent higher than the costs to design and construct conventional buildings, although the costs ranged up to 18 percent higher in a few instances. The study with the largest sample size indicated that, on average, the incremental first costs of green buildings were within 2 percent of the costs of conventional buildings,
Over the life cycle of a building, design and construction costs typically range from 5 to 10 percent of total costs, while operations and maintenance costs account for 60 to 80 percent of total costs. Thus, the additional incremental costs to design and construct high-performance or green buildings are relatively small when considered as part of total life-cycle costs.
Finding 4: The analytical approach proposed by the DOD consultant has merit as a decision support tool in the DOD operating environment if appropriate and verifiable data are available for conducting benefit-cost and sensitivity analyses.
The DOD consultant conducted a traditional benefit-cost analysis to calculate NPV benefits and adjusted rate of return on investment to determine the cost-effectiveness of the two ASHRAE Standards and the two green building certification systems. The consultant also conducted a payback analysis as required by NDAA 2012. The consultant’s proposed analytical approach expanded on the traditional BCA to incorporate factors related to geographic location, climate conditions, and local factors for utility costs. Sensitivity analyses were also incorporated to test a range of scenarios that represented uncertain future conditions related to discount rates, water prices, and energy prices. To the committee’s knowledge, those factors are not required by DOD or by other federal regulations. The committee believes that the consultant’s analytical approach has merit as one of an array of decision support tools to be used by DOD for evaluating investments in new construction or major renovations.
However, the committee has significant concerns about the sources of data available and the application of those data in the consultant’s analysis, including estimates of the incremental costs to design and construct high-performance or green buildings; those concerns are detailed in Chapters 3 and 5. As a consequence, the committee cannot support the consultant’s findings related to the absolute NPV benefits calculated for the ASHRAE standards, LEED, or Green Globes.
Finding 5: The evidence from the literature search indicates that high-performance or green buildings can result in significant reductions in energy use and water use. The cost savings associated with the reductions in energy and water use will vary by geographic region, by climate zone, and by building type.
Thirteen of the 25 studies evaluated by the committee focused on measured actual energy use in buildings based on utility bills. All thirteen found that high-performance or green buildings, on average (i.e., over a group of buildings), used 5 to 30 percent less site energy than similar conventional buildings.
The six studies that provided some evaluation of water use found that high-performance or green buildings on average used 8 to 11 percent less water than conventional buildings.
Seven studies provided some analysis of the performance of buildings certified at different levels of LEED. They indicated that the majority of LEED-Silver and LEED-Gold and Platinum buildings studied used significantly less energy and less water than conventional buildings.
The long-term cost savings that can be achieved through reductions in energy and water use over the life cycle of buildings will depend, in part, on local utility prices and on heating and cooling loads related to climate zones. During the 30 or more years a DOD building is in use, those differences could be significant. Across a portfolio of facilities, local price factors may be an important consideration for DOD in determining which investments in military construction or major renovations will be the most cost-effective over the long term.
Finding 6: Not every individual high-performance or green building achieved energy or water savings when compared to similar conventional buildings.
Although high-performance or green buildings saved energy and water, on average, within a sample of green buildings, some individual buildings had significantly greater reductions than the average, and some did not perform as well as conventional buildings. Similarly, there were LEED-Silver and LEED-Gold-certified buildings that used more energy and more water than conventional buildings. The research studies speculated about reasons why this was so, but they did not provide sufficient evidence to draw generalizations regarding why some high-performance or green buildings significantly outperformed conventional buildings and why others did not, although building type was clearly a factor.
Finding 7: In general, the quantities of energy and water used by a building once it is in operation are greater than the quantities of energy and water predicted by building design models, if these models are specifically created for compliance with LEED, Green Globes, or ASHRAE standards.
All building standards and green building certification systems require that a building design meet or surpass an energy efficiency standard. In the case of LEED, Green Globes, and ASHRAE 189.1, this standard is ASHRAE/Illuminating Engineering Society of North America (IESNA) 90.1. An energy model created to be compared with the ASHRAE/IESNA 90.1 standard necessarily underestimates the
energy use and the energy cost of the building once constructed and in operation. This is because (1) such models assume perfection in manufacturing, installation, and operation of buildings and their systems; and (2) such models do not include certain heat losses because they are too difficult to calculate.
Energy and water use should be predicted with an “actual use” model that takes into account factors not considered by the LEED, GBI, or ASHRAE design models. An “actual use” model starts with the model created for compliance with LEED, Green Globes, or with ASHRAE 189.1, and then incorporates real-life assumptions of manufacturing, installation, and operation. It also incorporates the three-dimensional heat losses.
An “actual use” model created during design can be significantly improved in its predictive value if it is updated with as-built/as-operated conditions. Imperfections during construction can be observed and incorporated in the model, change orders can be modeled as well, and variations in occupancy captured (e.g., different plug loads). An “actual use/as-built model” is best suited for use as a benchmark to assess whether the building performs as it should and to correct deficiencies in operation.
The difference between modeled energy or water use and actual energy or water use is important for facilities managers and other decision makers when communicating with other stakeholders. Using data from LEED, GBI, or ASHRAE design models in decision making or in communications can set unrealistically high expectations that cannot be met. Using data from an as-built model will provide more realistic performance data. However, conveying information based on measured energy or water use will provide the most realistic data for decision-making and will improve the credibility of facilities managers and decision makers with other stakeholders.
Finding 8. DOD has the opportunity to continue to take a leadership role in improving the knowledge base about high-performance buildings, improving decision-support tools, and improving building models by collecting data on measured energy, water, and other resource use for its portfolio of buildings and by collaborating with others.
The data currently available to support decision-making about investments in military construction and major renovation projects is inadequate. Under the Energy Performance Act of 2005, all federal buildings are required to be metered by FY 2012. Metered data for energy and water use can be used to improve decision support tools and processes, to establish baselines for conventional buildings, and to measure the performance of high-performance or green buildings against those baselines. DOD could work with the Department of Energy and others to improve the available knowledge and databases related to high-performance buildings, to the benefit of the federal government and society.
Finding 9. Effective operation of high-performance buildings requires well-trained facilities managers.
High-performance or green buildings incorporate new building design processes, new technologies, and new materials. Effective operation of high-performance buildings requires well-trained facilities managers who understand the interrelationships among building technologies, occupant behavior, and overall building performance, as recognized through the enactment of the Federal Buildings Personnel Training Act of 2010.
RECOMMENDED APPROACHES FOR DOD’S CONSIDERATION
Decisions about investments related to new construction and major renovations of buildings at DOD installations are not reducible to a single decision rule (such as benefit-cost maximization), nor are facilities managers responsible to a single stakeholder. In fact, facilities managers must assess the relative merits of facilities improvement projects against performance with respect to multiple decision criteria and justify recommendations to stakeholder groups and governing bodies that hold different and sometimes conflicting priorities. Trade-offs are required for most building projects, including design and construction costs (i.e., first costs) versus operating and maintenance and deconstruction costs, resilience and flexibility factors versus worker productivity, and so forth.
Based on its findings and on its own expertise and experience with building standards and green building certification systems, the committee recommends that DOD consider the following approaches as it develops a comprehensive strategy for its entire portfolio of facilities to include standards for energy efficiency and sustainable design.
Recommended Approach 1. Continue to require that new buildings or major renovations be designed to achieve a LEED-Silver or equivalent rating in order to meet the multiple objectives embedded in laws and mandates related to high-performance buildings.
The preponderance of available evidence indicates that green building certification systems and their referenced building standards offer frameworks for reducing energy and water use in buildings, compared to design approaches and practices used for conventional buildings. They may also result in improved indoor environmental quality, improved worker productivity, and lower operations and maintenance costs, although the evidence is very limited. Green building certification systems can also help to establish explicit and traceable objectives for future building performance and a feedback loop to determine if the objectives were met.
The incremental costs to design and construct high-performance or green-certified buildings compared to conventional buildings is minimal compared to the total costs of a building over its life cycle. Over the 30 years or more that high-performance or green buildings are in use, the cost savings attributable to reduced energy use and reduced water use may be significantly greater than the incremental first costs of design and construction.
The limited evidence available indicates that the majority of LEED-Silver-certified buildings studied used significantly less energy and water than conventional buildings, although some LEED-Silver-certified buildings did not outperform conventional buildings. Based on the evidence and committee members’ own experience with green building certification systems, the committee believes the most prudent course for DOD is to continue its current policy. At the same time, DOD should establish practices to evaluate the performance of its high-performance or green buildings to ensure that performance objectives are being met, to continuously improve performance, and to ensure that the measures required to reduce levels of energy and water use are cost-effective.
Because DOD has developed standard designs for the types of buildings it constructs most often, using the LEED-Volume certification program may be cost-effective, although as yet there is little experience with or documented evidence about the program. DOD should consider a pilot study to determine whether volume certifications will in fact be cost-effective.
Recommended Approach 2. Retain flexibility to modify building standards and the application of green building certification systems in ways that are appropriate to the Department of Defense operating environment and mission.
ASHRAE Standard 189.1-2011 contains many mandatory provisions that have not yet been evaluated for their cost-effectiveness. The committee recommends that DOD conduct pilot studies on specific provisions of the standard to determine their cost-effectiveness and their practicality in the DOD operating environment before adopting ASHRAE 189.1-2011 in its entirety. As experience with the various provisions emerges, DOD can determine which provisions of the standard are cost-effective and support DOD’s mission and incorporate those provisions into DOD guidance documents when appropriate.
Recommended Approach 3. Put policies and resources in place to measure the actual performance of the Department of Defense’s high-performance, green, and conventional buildings to meet multiple objectives.
Not every individual high-performance or green building will have significant energy and water savings even if it is certified at a LEED-Silver or equivalent rating. The committee recommends for all new construction and major renovations that DOD measure actual performance for 3 years or longer after initial occupancy and use the resulting information and lessons learned to further modify its policies if appropriate. This can be done because DOD meters all of its buildings. Data for conventional buildings should also be gathered to establish baselines for performance measurement.
It will be necessary to continue to use building models in the design stage to support decision making among alternatives. Building models can be improved over time such that predicted results are more closely aligned with actual results, as detailed in Chapter 5. As DOD’s buildings are metered, DOD should gather data on the use of energy, water, and wastewater to establish baselines for conventional buildings and to determine how well high-performance or green buildings are performing in comparison to baselines and in comparison to predictions associated with design models.
DOD can continue to take a leadership role in improving the performance of all federal facilities, as well as all U.S. buildings, by collaborating with the Department of Energy, other federal agencies, nonprofit organizations, and others to improve national databases related to buildings and their performance and to improve the knowledge base related to the design, construction, and operation of high-performance facilities.
Recommended Approach 4. Use investment approaches that analyze the total cost of ownership, a full range of benefits and costs, and uncertain future conditions as part of the decision-making process.
The analytical approach developed by the DOD consultant could potentially be used by DOD to improve the basis for decisions about which investments will be most cost-effective across its portfolio of facilities. The proposed approach accounts for life-cycle costs, variations in geographic conditions, climate, type of building, and local cost factors. It also helps define upper and lower ranges of uncertainty for specific factors that are inherent with decision making about buildings that will be used for 30 years or longer. To use such an approach effectively, however, DOD will need to ensure that the data available for analysis are accurate and reliable.
Recommended Approach 5: Specify and fund training appropriate for facilities managers to ensure the effective operation of high-performance buildings.
Effective use of new technologies and new processes associated with high-performance buildings requires a workforce that is adequately trained to make decisions and implement them to maximum benefit. Facilities managers should have the skills and training necessary to understand the interaction of complex building systems and how to operate them effectively. Implementation of the Federal Building Personnel Training Act of 2010 should help to ensure that DOD facilities managers are certified in the required competencies and skills.