Agenda Item 7A
November 17,2015
Action
MEMORANDUM
November 13,2015
TO:
FROM:
SUBJECT:
County Council
Amanda Mihill, Legislative
AttorneycA~~
Action:
Bill 35-15, Environmental Sustainability - Benchmarking - Amendments
Transportation, Infrastructure, Energy and Environment Committee recommendation
(2-0):
enact Bill 35-15 with a technical amendment to the definition of covered building.
Bill 35-15, Environmental Sustainability - Benchmarking - Amendments, sponsored by Lead
Sponsor Council President at the request of the County Executive, was introduced on September
15. A public hearing was held on October 6 at which a representative of the Executive supported
the bill (see ©28). A Transportation, Infrastructure, Energy and Environment Committee
worksession was held on November 2.
Bill 35-15 would add an intent section to the Building Energy Use Benchmarking law, amend
certain definitions, provide for alternative paths to verification, and change the private sector
building group deadlines from December 1, 2016 to June 1,2016 for Group 1 buildings (buildings
greater than 250,000 square feet) and from December 1,2017 to June 1,2017 for Group 2 buildings
(buildings between 50,000 and 250,000 square feet). Bill 35-15 is the result of a report issued by
the Benchmarking Work Group - a group made of a broad set of stakeholders charged with
reviewing the Building Energy Use Benchmarking law and make recommendations regarding the
law's implementation.
Issue/Committee Recommendation - Data Verification
Current law.
The benchmarking law requires the owner of a covered building to assure that the
reported benchmarking information for that year is verified by a licensed professional before the
first benchmarking deadline and each third deadline afterwards. Current law also includes a waiver
process if the owner shows that compliance will cause undue fmancial hardship, but would be
required to use a no-cost or low-cost verification option if available.
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Bill
35-15. Bill 35-15 would change the licensed professional to "recognized data verifier", which
the bill defines as "a Professional Engineer or a Registered Architect, or another trained individual
whose professional license or building energy training program credential is recognized by the
Director. Bill 35-15 changes the waiver provision to allow the Director to waive the verification
requirement ifthe owner demonstrates that the building achieved ENERGYSTAR certification for
at least 6 months in the year being benchmarked.
Issues.
The Apartment and Office Building Association of Metropolitan Washington (AOBA)
opposes the requirement to retain the verification requirement in the law. AOBA projects that the
County will not experience the same level of challenges experienced in other jurisdictions because
of differences in laws. AOBA urged the following amendments:
I. Repeal or delay the effective date of the data verification provision until after the first
reporting deadline to allow the County to determine if data verification is necessary;
2. Require benchmarking results and supporting records be retained for 3 years and allow
DEP to review the records; and
3. Allow people with 10 years or more experience managing energy for a building owner or
manager to be a recognized data verifier (©31-32).
In
response to AOBA's concerns, DEP submitted the comments on ©58-60. To the general issue
regarding verification, DEP staff argue that verification has been a central part of Montgomery
County's benchmarking and transparency law from its introduction. Its inclusion is based upon the
best practice of other benchmarking and transparency laws in the country. Data quality is an inherit
issue. DEP identified several data quality issues throughout the Early Bird benchmarking dataset
and found that there was only one submission without issues - that being the one that completed
verification (voluntarily).
To the specific amendments proposed by AOBA, DEP does not support those amendments and
argues:
1. Verification the first year allows the building owner to have the value of a knowledgeable
resource and second pair of eyes as they establish their processes and procedures that will
then carry them through each compliance year.
2. The availability of records on-file does not constitute a data verification program. To
consider recordkeeping a verification program, DEP would need to collect even more
information than is already set to be reported (DEP would need to seek the monthly annual
energy data from each building owner, not just the annual data) and devote enormous staff
resources to individually check individual Portfolio Manager accounts for proper inputs.
3.
It
would be difficult for DEP to review individual cases and make a fair judgment on what
counts as energy management experience. Relying on 3rd party credentials is the fairer and
more effective policy.
Committee recommendation (2-0, Councilmember Floreen absent): The Committee did not
support the suggested amendments by AOBA. Committee members were convinced from the
Department of Environmental Protection staff that data verification was a critical element of the
benchmarking program.
2
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Technical Amendment
For clarity in the law, DEP staff recommend the following technical amendment:
Covered building
means any County building, Group 1 covered building, or Group 2 covered
building.
Covered building
does not include any building with more than 10% [occupancy] of
total building square footage which is used for:
(1)
public assembly
in
a building without walls;
(2)
warehousing;
self storage; or
(3)
(4)
a use classified as manufacturing and industrial or transportation, communication,
and utilities.
Committee recommendation
(2-0, Councilmember Floreen absent): adopt this amendment (©3,
lines 29-37).
1bis packet contains:
Committee Bill 35-15
Legislative Request Report
Executive memorandum
Fiscal and Economic Impact Statement
Benchmarking Work Group report
Testimony/Written Correspondence
Executive
AOBA
DEP Comments
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Bill No.
35-15
Concerning: Environmental Sustainabilitv
- Benchmarking - Amendments
Draft No._2_
Revised:
11/9/2015
Introduced:
September 15. 2015
Expires:
March 15. 2017
Enacted: _ _ _ _ _ _ _ _ __
Executive: _ _ _ _ _ _ _ __
Effective:
_~:---
_ _ _ _ _ __
Sunset Date: --'-"N=on=eO-.-_ _ _ _ __
Ch. _ _• Laws of Mont. Co. _ __
COUNTY COUNCIL
FOR MONTGOMERY COUNTY, MARYLAND
Lead Sponsor: Council President at the Request ofthe County Executive
AN
ACT to:
(1)
add an intent section of the law;
(2)
amend certain defInitions;
(3)
provide for certain alternative paths to verifIcation;
(4)
alter the private sector building group deadlines; and
(5)
generally amend County law regarding energy efficiency and environmental
sustainability.
By amending
Montgomery County Code
Chapter 18A, Environmental Sustainability
Sections 18A-38, 18A-39, 18A-40, and 18A-42
By adding
Chapter 18A, Environmental Sustainability
Section 18A-38A
Boldface
Underlining
[Single boldface brackets]
Double underlining
[[Double boldface bracketsn
* * *
Heading or defined term.
Added to existing law by original bill.
Deletedfrom existing law by original bill.
Added by amendment.
Deletedfrom existing law or the bill by amendment.
Existing law unaffected by bill.
The County Council for Montgomery County, Maryland approves the following Act:
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BILL
No.
35-15
1
2
3
Sec.
1.
Chapter 18A is amended
by
amending Sections 18A-38, 18A-39,
18A-40, and 18A-42 and adding Section 18A-38A as follows:
18A-38A.
Intent.
4
5
The intent of this Article is to:
W
implement recommendations of the 2009 Climate Protection Plan
(EEC-2), 2013 Commercial Building Energy Efficiency study (Chapter
3.2), and support efforts of the Office of Sustainability to increase
energy efficiency and reduce greenhouse gas emissions in the private
sector and County buildings;
6
7
8
9
10
11
(hl
engage the commercial building sector with building energy
information crucial to adopting energy conservation and efficiency
opportunities;
12
13
14
W
spur market transformation
Qy
making building performance
transparent for the building and tenant market, allowing more accurate
evaluation of energy costs and creating
!!
competitive market for energy
efficient buildings;
15
16
17
18
@
strengthen the local economy
Qy
encouraging more efficient business
operations and providing new opportunities for local businesses that
provide energy conservation and efficiency services; and
19
20
21
22
W
recognize building owners that have made investments to improve their
building energy performance and expand in-house capacity for energy
management.
23
24
18A-38B.
Definitions.
*
*
*
25
26
County building
means any building owned by the County, or any group of
buildings owned by the County that have the same property identification
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BILL
No. 35-15
27
28
number, that equals or exceeds 50,000 in total building square footage [square
feet gross floor area, as identified by the Director].
Covered building
means any County building, Group 1 covered building, or
Group 2 covered building.
Covered building
does not include any building
with more than 10% [occupancy] of total building square footage which is
used for:
(1)
(2)
(3)
(4)
public assembly in a building without walls;
warehousing;
self storage; or
a use classified as manufacturing and industrial or transportation,
communication, and utilities.
29
30
31
32
33
34
35
36
37
38
39
40
41
*
*
*
Group 1 covered building
means any nonresidential building, or any group of
nonresidential buildings that have the same property identification number,
not owned by the County that equals or exceeds 250,000 in total building
square footage [square feet gross floor area, as identified by the Director].
Group
2
covered building
means any nonresidential building, or any group of
nonresidential buildings that have the same property identification number,
not owned by the County that equals or exceeds 50,000 square feet gross floor
area but is less than 250,000 in total building square footage [square feet gross
floor area, as identified by the Director].
42
43
44
45
46
47
48
*
*
*
49
50
51
52
53
[Licensed professional] Recognized data verifier
means a [professional
engineer] Professional Engineer or a [registered architect] Registered
Architect [licensed in the State], or another trained individual whose
professional license or building energy training program credential
recognized
Qy
the Director [as defined in applicable County regulations],
IS
Q)
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BILL
No. 35-15
54
55
*
*
*
[Gross floor area] Total building square footage
means the sum of the gross
56
57
58
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horizontal area of the several floors of a building or structure measured from
the exterior faces of the exterior walls or from the center line of party walls.
In a covered but unenclosed area, such as a set of gasoline pumps or a drive­
through area, gross floor area means the covered area.
[Gross floor area]
Total building square footage
does not include any:
60
61
(1)
(2)
basement or attic area with a headroom less than 7 feet 6 inches;
area devoted to unenclosed mechanical, heating, air conditioning, or
ventilating equipment;
62
63
64
(3)
(4)
parking structure; or
accessory structure to a residential building.
Energy use benchmarking.
65
66
67
68
69
70
71
18A-39.
(a)
County buildings.
No later than June 1, 2015, and every June 1
thereafter, the County must benchmark [all buildings owned by the]
County buildings for the previous calendar year and report the
benchmarking information to the Department.
(b)
Group
1
covered buildings.
No later than [December] June 1, 2016,
72
and every [December] June 1 thereafter, the owner of any Group 1
covered building must benchmark the building for the previous
calendar year[.
The owner must] and report the benchmarking
73
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77
information to the Department [no later than January 1 each year].
(c)
Group
2
covered buildings.
No later than [December] June 1, 2017,
and every [December] June 1 thereafter, the owner of any Group 1
covered building must benchmark the building for the previous
calendar year[.
The owner must] and report the benchmarking
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80
information to the Department [no later than January 1 each year].
CD
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BILL No. 35-15
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*
18A-40.
(a)
Data Verification.
*
*
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Verification required.
Before the first benchmarking deadline required
by Section 18A-39, and before each third benchmarking deadline
thereafter, the owner of each covered building must assure that reported
benchmarking information for that year is verified by a [licensed
professional] recognized data verifier.
The verification must be a
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[stamped and] signed statement by a [licensed professional] recognized
data verifier attesting to the accuracy ofthe information. Ifthe Director
requests, the owner of a covered building must produce the statement
available for the most recent year in which verification was required.
(b)
92
93
[Waiver] Alternative Verification Path.
The Director may waive the
verification requirement [of] under this Section ifthe owner [shows that
compliance with this Section will cause undue financial hardship. If a
no-cost or low-cost verification option is available, the Director may
require the owner to use the alternative option] can demonstrate that the
building has achieved ENERGY STAR Certification for at least
Q
months of the year being benchmarked.
94
95
96
97
98
99
100
18A-42.
(c)
Annual report; disclosure of benchmarking information.
*
*
*
101
102
Exceptions to disclosure.
To the extent allowable under state law, the
Director must not make the following readily available to the public:
103
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105
(1)
any individually-attributable reported benchmarking information
from the first calendar year that a covered building is required to
benchmark; and
106
107
(2)
any individually-attributable reported benchmarking information
relating to a covered building that contains a data center, or
ill
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BILL
No. 35-15
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television studio [, or trading floor] that together exceeds 10% of
the [gross square footage] total building square footage of the
individual
building until
the
Director
finds
that
the
benchmarking tool can make adequate adjustments for these
facilities. When the Director finds that the benchmarking tool
can make adequate adjustments, the Director must report this
data in the annual report.
Approved:
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George Leventhal, President, County Council
Date
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120
121
122
Approved:
.l...N1":'''-,",U..
County Executive
Date
123
124
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126
This is a correct copy o/Council action.
Linda M. Lauer, Clerk ofthe Council
Date
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LEGISLATIVE REQUEST REPORT
Bill xx-1S
Energy Benchmarking Amendments
DESCRIPTION:
The Commercial Energy Benchmarking Law, adopted
May
2014, required
the County Executive
to
convene a Benchmarking Work Group
to
provide
recommendations regarding the implementation of the bill within the
private sector, including any recommended legislative amendments. The
Benchmarking Work Group is required
to
submit a report
to
the County
Executive and County Council by September 2015.
This
bill
would
amend the adopted Commercial Energy Benchmarking Law, which
requires certain building owners to benchmark their energy use and
report
it
to the County for public disclosure. These amendments are
proposed by the Benchmarking Work Group with the intent to
improve implementation of the law and its purpose.
PROBLEM:
The Benchmarking Work Group's examination ofthe law and its
implementation with County facilities and within other jurisdictions
raised concerns around specific issues, from the deadlines to
verification requirements, inconsistent application between public
and private facilities, and unclear defInitions. These issues would
directly impact implementation of the law, and the recommendations
provided seek to mitigate these issues.
This bill is designed to address a variety of issues identifIed by the
Benchmarking Work Group by adding an intent section ofthe law;
amending certain defInitions; providing for certain alternative paths
to verification; altering the private sector building group deadlines;
and generally amending County law regarding energy efficiency and
environmental sustainability.
Department of Environmental Protection
GOALS AND
OBJECTIVES:
COORDINATION:
FISCAL IMPACT:
ECONOMIC
IMPACT:
EVALUATION:
EXPERIENCE
ELSEWHERE:
SOURCE OF
INFORMATION:
Michelle Vigen, Senior Energy Planner, Division ofEnvironmental
Policy and Compliance, Department of Environmental Protection (7­
7749)
This bill applies to all municipalities that accept or adopt the County
Environmental Sustainability Law, Chapter 18A.
APPLICATION
WITHIN
MUNICIPALITIES:
PENALTIES:
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OFFICE OF THE COUNTY EXECUTIVE
ROCKVILLF.. MARYLAND 20850
Isiah Leggett
County Executive
MEMORANDUM
August 3, 2015
TO:
FROM:
SUBJECT:
George Leventhal, President, Montgomery
Co~
I.lab
Leggett,
COUDIy Executive
cR
~..A:"---~-
Introduction of
XX~
15 Benchmarking Amendments
It
is my pleasure
to
transmit the attached Benchmarking Amendments Bill and accompanying
Benchmarking Work Group Report.
The Commercial Energy Benchmarking Law, adopted May 2014, required the County
Executive
to
convene a Benchmarking Work Group, made up of a broad set of stakeholders,
to
(l)
review the
County's benchmarking process leading up
to
their June 1,2015 deadline, and (2) provide recommendations
regardmg the implementation ofthe bill within the private sector, including any recommended legislative
amendments. The Benchmarkmg Work Group is required to submit a report to the County Executive and
County Council by September 2015.
.
The Department of Environmental Protection (DEP) convened a Work Group from a broad
set of stakeholders, including an initial list of over 70 stakeholders representing utilities, building owners,
nonprofits and associations, and energy service companies. The Work Group met as a whole and in
committees approximately twenty times between September 2014 and June 2015. This transmittal includes
both their Report and a new bill reflecting their recommendations:
• A final Report outlines the work ofthe Benchmarking Work Group and proposes several
recommended legislative amendments to improve the implementation ofthe Law. Each set of
amendments is introduced with a summary, justification, and textual annotations.
• Based on this Report, DEP
has
drafted a new bill (XX-] 5 Benchmarking Amendments)
to
reflect the amendments proposed within this report. This bill would amend the adopted
Commercial Energy Benchmarking Law, which requires certain building owners to
benchmark their energy use and report it
to
the County for public disclosure. Specifically, this
bill would add an intent section of the law; amend certain definitions; provide for certain
alternative
paths
to verification; and alter the private sector building group deadlmes.
If you have any questions, please contact Lisa Feldt in the Department of Environmental
Protection at 240-777-7730 or Iisa.feldt@montgometycountymd.gov.
IL:kdm
Attachment (s)
montgomerycountymcl.gov/311
..
.
t';.
240-773-355& TTY
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Fiscal Impact Statement
County Executive Bill XX-IS - Environmental Sustainability - Benchmarking ­
Amendments
1. Legislative Summary.
This bill would amend Bill 2-14 - Environmental Sustainability - Buildings ­
Benchmarking to:
1) add an intent section to the law;
2) amend certain definitions; .
3) provide for certain alternative paths to verification;
4) alter the private sector building group deadlines; and
5) generally amend County law regarding energy efficiency and environmental
sustainability.
2. An estimate of changes
in
County revenues and expenditures regardless of whether
the revenues or expenditures are assumed in the recommended or approved budget.
Includes source of information, assumptions, and methodologies used.
The amendments proposed in Bill XX-I5 would have no impact on County revenues and
expenditures.
3. Revenue and expenditure estimates covering at least the next 6 fIscal years.
Bill XX-I5 would create no revenue or expenditures over the next 6 fiscal years.
4. An actuarial analysis through the entire amortization period for each bill thatwould
affect retiree pension or group insurance costs.
Not Applicable.
5. An estimate of expenditures related to County's information technology
(11)
systems, including Enterprise Resource Planning (ERP) systems.
Bill XX-IS would have no impact on the County's IT systems ..
6. Later actions that may affect future revenue and expenditures
if
the bil1 authorizes
future spending.
Bill XX-IS does not authorize future spending and will have no impact on
futur~
revenues or expenditures.
7. An estimate of the staff time needed to implement the bill.
Staff time
will
not be needed to implement the changes in Bill XX-IS.
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8.
An
explanation of how the addition of new staff responsibilities would affect other
duties.
There are no new staff responsibilities as a result of Bill
XX-IS
and the bill would not
affect other duties
in
the Department of Environmental Protection.
9.
An
estimate of costs when an additional appropriation is needed.
No additional appropriation is needed as a result ofBill
XX-IS.
10. A description of any variable that could affect revenue and cost estimates.
Not Applicable.
11. Ranges of revenue or expenditures that are uncertain or difficult to project.
Not Applicable.
12.
If
a bill is likely to have no fiscal impact, why that is the ease.
Bill
XX-IS
amends definitions and administrative procedures related to the previously
adopted Bill 2-14. These amendments to Bill 2-14 do not have
a
budgetary impact
on
county operations.
.
13. Other fiscal impacts or comments.
Not Applicable.
14. The following contributed to and concurred with this analysis:
Matt Schaeffer, Office of Management and Budget
Michelle Vigen, Department of Environmental Protection
J
. HugheS;Dire
ce ofManagement and Budget
.
er
7/2tJ/C!)
Date
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Economic Impact Statement
Bill ##-15, Environmental Sustainability - Benchmarking - Amendments
Background:
This legislation would amend sections of Chapter 18A of the County Code as follows:
• Add an intent section of the law.
• Amend certain definitions.
• Provide for certain alternative paths to verification, and
• Alter the private-sector building group deadlines.
Bill ##-15 essentiaI1y provides technical amendments to Chapter 18A. The. amendments
change the terminology of "gross floor area" to "total building square footage" and
expand eligibility to complete the verification requirements to a group of "recognized
data
verifiers." The terminology change from "gross floor area"
to
"total building square
footage" is to differentiate it from the term
used
in
the software
used
by building owners
to comply with the law and does not
affect
the defmition or scope ofthe law.
The change to the current law
pertaining
to certain alternative paths to verification is to
permit those building owners with
buildings
that have voluntarily achieved ENERGY
STAR-certification for at least six months ofthe year being benchmarked to not have to
undertake a separate and redundant verification. This change
will
enable certain building
owners who have achieved ENERGY STAR certification on any buildings to avoid
additional costs for verification ofthose buildings.
1.
The sources of information, assumptions, and methodologies used.
Sources of information include the Department of Environmental Protection (DEP).
The economic impact statement is based on information provided by DEP. and
Finance has not made any assumptions or provided methodologies in preparing the
economic impact statement.
Z.
A description of any variable that could affect the economic impact estimates.
There are no variables that could affect the economic impact estimates. The change
in
the verification procedure would result in cost savings to any building owners who
have achieved ENERGY STAR verification on any buildings.
3. The Bill's positive or negative effect,
if
any on employment, spending, savings,
investment, incomes, and property values in the County.
Bill
##-15 provides an alternative path to verification and. as
such.
would provide a
cost savings to any building owners who have achieved ENERGY STAR certification
on any buildings. Without specific company
data.
it is uncertain as to the specific
amount of cost savings attributed to the proposed change
in
certain alternative paths
to verification.
Page
1
of2
®
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Economic Impact Statement
Bill ##-15, Environmental Sustainability - Benchmarking - Amendments
4.
If
a Bill is likely to have no economic impact, why
is
that the case?
Please see paragraph #3.
5. The following contributed to or concurred with this analysis:
David
Platt, Mary
Casciotti, and Rob Hagedoom, Finance; Michelle Vigen, Department of
Environmental Protection.
Date
Department of Finance
f
I
Page 2 of2
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.•. 1
:::' •.•. : ..
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Report
by
the Benchmarking Work Group·
Providing Recommendations for Legislative Amendments to
Adopted Bill 2-14 (Energy Benchmarking)
June
10, 2015
Table
of
Contents
EXECUTIVE SUMMllY .................................................................."
.•...•••••••.•.••••••••... 2
BACKGR.OU'ND ...................................................................................................... 3
RECOMMENDED LEGISLATIVE AMENDMENTS .................................................... 5
RECOMMENDATION 1: ADD INTENT OF THE LAw ............................................................... 5
RECOMMENDATION 2: RENAME TERM, "GROSS FLOOR AREA" WITHIN THE
LAW .................
7
RECOMMENDATION 3: REMOVE "AS DETERMINED
BY
mE
DIRECIOR" LANGUAGE............. 9
RECOMMENDATION 4: REVISE AND CLARIFY VERIFICATION ............................................ 10
RECOMMENDATION 5: COUNTY COVERED BUILDINGS AND DEADLINES........................... 13
RECOMMENDATION 6: MOVE PRIVATE BUILDINGDEADLINES TO JUNE 1 ......................... 14
.APPENDIX:
.A::
RECOGN'IZED CREDENTIALS .•••••••.••••••••••.••••.•••••••..•••••••••••••••••••.•.. 15
1
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EXECUTIVE SUMMARY
In May 2014, Montgomery County became the first county in the nation to adopt a
benchmarking and transparency law. Section 2 of the adopted bill provided for the convening of
a Benchmarking Work Group, made up of a broad set of stakeholders, to review the County's
benchmarking process leading up to their June 1, 2015 deadline, and provide recommendations
regarding the implementation of the bill within the private sector, inCluding any recommended
legislative amendments.
Starting in the fall of 2014, the Department of Environmental Protection (DEP) solicited
participation from a broad swatH of stakeholders, including an initial list of over 70 stakeholders
representing, utility, building owners, nonprofits and associations, and energy service
companies.
This report outlines the work of the Legislative Committee of the Benchmarking Work Group,
specifically several recommended legislative amendments to improve the implementation of the
Law.
Recommended Legislative Amendments:
1. Add Intent of the Law
2. R.ename -Gross square footage" within the law
3. Remove "As identified by the Director-language
4. Verification: Expand credentials, revise exemption, and other guidance
a. Expanding the "licensed professiolJa'- to a "Recognized data verifier- including
criteria for accepting credentials
b. Modification of Verification Hardship
5. Making requirements of County Buildings consistent with private Covered Buildings
6. Moving private Covered Buildings deadlines to al/gn with reporting requirements
Each set of amendments provided with a summary, justification, and textual annotations. A
version of the legislation, with all the amendments marked,
is
included at the end of this
document.
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BACKGROUND
In May 2014, Montgomery County became the first county in the nation to adopt a
benchmarking and transparency law. This law requires certain building owners
to
report their
building energy use to the County for disclosure on an annual basis.
.
Section 2 of the adopted bill provided for the convening of a Benchmarking Work Group, made
up of a broad set of stakeholders, to review the County's benchmarking process leading up to
their June 1, 2015 deadline, and provide recommendations regarding the implementation of the
bill within the private sector, including any recommended legislative amendments.
Work Group Convening
The Department of Environmental Protection (DEP) solicited participation from a broad swath of
stakeholders, including an initial list of over 70 stakeholders representing, utility, building
owners, nonprofrts and associations, and energy service companies.
This initial group was invited to an introductory meeting September 2014, where several
speakers provided context for the law, including DEP. DGS, JBG Companies, AOBA, and
Pepco. The Work Group opted to break into three committees to address three distinct areas of
the law's implementation:
1. Outreach
2. Technical Assistance
3. Legislative
The Outreach and Technical Assistance committees have provided valuable guidance and
advice on DEP's benchmarking programming thus far, including: .
• Connections and contact information for important outreach partners, such as industry
organizations, media groups, and nonprofits
• Ear1y Bird program design, goals, and recognition
• Benchmarking Ambassadors programming
• Communication strategies for complex aspects of the law
• Review of the Benchmarking Website layout, organization, and content
• Outreach and Technical Assistance objectives, in general
These two groups have since combined into a single group that continues to provide guidance
on Benchamarking programming.
The legislative committee took a deep dive into the legislation, starting with an initial review
by DEP of areas in the County's law that, compared to other jurisdictions' legislation, might
benefit from discussion or clarification by the Legislative committee.
The committee worked through a list of these areas, and through discussion, solicitation of
ideas from building owners aided via AOBA, and research via DEP, provided guidance to DEP
to clarify points of the legislation in guidance (on the Benchmarking Website).
The committee's work also resulted in several recommended legislative amendments, which
this report outlines and details.
Recommended Legislative Amendments
1.
2.
3.
4.
Addition of Intent
Renaming "Gross square footage" to "Total square footage"
Removing "As identified by the Director" in identifying covered b,uildings
Verification Amendments
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a. Expanding the "licensed professional" to a "Recognized data verifier" including
criteria for accepting credentials
b. Modification of Verification Hardship
5. Making requirements
of
County Buildings consistent with private Covered Buildings
6. Moving private Covered Buildings deadlines to align with reporting requirements
Review Process
The Legislative Committee developed these recommendations through a series of eight
meetings over the course of six months. Meeting times and infonnation, agendas, and notes
were distributed through the Benchmarking Working Group email list, which is administered by
DEP.
This spring, the Legislative Committee solicited comments from the Work Group as a whole,
leading up to and at a Full Work Group meeting on ;,lune 10, 2015. Comments from this
process have been incorporated into this final draft.
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RECOlVlMENDED LEGISLATIVE AMENDMENTS
Each set of amendments is detailed below, with a summary, justification, and textual
annotations. A version of the legislation. with all the amendments marked, is included at the
end of this document.
RECOMMENDATION 1: Add
Intent ofthe
Law
Overview
Conversations within the Benchmarking Work Group Legislative Committee have often revolved
around the importance of building owners acting on the information provided through the
benchmarking process and reaping the multiple benefits of energy conservation and energy
efficiency. The Working Group has noted that this intent is presented in the Law, and that it is
important to clarify the purpose and value of the legislation ·for those that must comply with it.
Justification
• Recognize the foundational actions that led to this law - The 2009 Climate Action
Protection Plan and 2013 Commercial Building Energy Efficiency study both pointed to
working with the commercial sector to reduce energy use and emissions. The latter
study specifically identified benchmarking legislation as a sound strategy to help the
County meet its emission reduction goals.
• Educate stakeholders and the broader community about the impact that building
energy use has on the County's greenhouse gas emissions
(1/3
commercial buildings,
113
residential) and reduction goal of 80%
by
2050.
• State clearly the energy conservation goals - These goals were inherent in the initial
drafts of the legislation within the energy audit and retrocommissioning requirements.
Since those were removed, the energy-saving intent
of
the law is no longer clear.
• Identify benefits beyond energy consumption and cost savings - The law can and
will provide benefits beyond the energy savings results seen from other jurisdictions with
benchmarking laws.
Issue
Intent
ofth~law
Recommended Amendment
Add to
the
following language in the appropriate section
or
in an.
additional section: .
. ..
.
The intent of this legislation is to:
• Implement recommendations of the 2009 Climate
Protection Plan (EEC-2), 2013 Commercial
Building Energy .Efficiency study (Chapter. 3; 2.),
support efforts of the Office of Sustainability
IEiiIG-H}
to increase energy efficii:mcyand
reduce.
greenhous~
gas emissions in "the
p~iv:ate
.
sector and County buildings.
.
• Eri$!age:
the
commercial building sector wi.th
'buIlding energy information crucial to a-dopting
energy conservatibnand efficiency' ..
~.
opportunities.
.
• Spur market transformation by
m~k.ing
DuHdin$!
performance transparent fox the building and
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RECOMMENDATION 2: Rename term, "gross floor area" within the law
Overview
The legislation determines applicability to buildings based on gross floor area. The law covers
buildings that have a gross floor area of 50,000 square feet or greater. The tool to complete the
benchmarking, ENERGY STAR Portfolio Manager, also uses this term, but differently.
A
summaI}'
of
differences is in the GUIDANCE:
Gross
Floor
Area
Definitions.
Justification
• This recommendation is to remove any confusion that may
be
caused by having the
same term used
in
the Law and in Portfolio Manager. but with different definitions.
• The group has reviewed that the definitions for their respective purposes are
appropriate, and a re-naming of the term within the Law may be beneficial.
Issue
Recommended Amendment
"Gross sqJ,lare
'Renait:!e'Mgross square footage
footag."
'"
tenninolosy. ,', ,
.,Remove
·trad~
floors" from the list.of exempted buildings,
~ there~are
no trade
floors in the County
,'
Sec. l8A-38. Definitions
~~
,
to
"totaf building square footageS
" ,
B
,
,',
County building
means ariy building owned by,the County,
or any group of build.:Lng::; , owned by the comltythat have
the same property identification number, th,at' equals or
exceeds 50,000 sCjUare feet grese
f~eer
area in total
building square footage':
I
as identified
:bythe
Direetor.
Group
1 coveredblliiding
means any nonre,s!dential
building, or any group:>,bf nonresidential buildings that
have the
samepropertyid~ntification
number; not owned
by the County thatequais or exceeds
250~
00'0, equaFe feet
gress flOOF
area~in
total building square footage .
."...-a&
identified
by
~he
Direeter.
'
Group 2 covered
building
means any nonre,sidential
building, or any group of nonresidential buildings that
have the same property identification humber, not owned
by the C()'imty.that equals or' exceeds 50, '000 sE;Jl::llucfect:;'
greee,fleers:'f'ca in'total'bi.lildingsquare footage but is,
lessthan250;OOOs~are
feet
g!E'i3~9
,fles!' aFea in total
bUilding square footage.
I
as identifieei
19y
tae DireetE)r.
Cress flee*!
area Total, buildingsguare footage
means the,
sum of the grQSS horizontal area of the several floors of
a building or
structure,measi.lr~d
from the exterior 'faces
of the exterior walls or from the centerline of, pC/.rty
walls. In a co'V'ered'but unenclosE:!d area, such asa'set.
of gasoline pumps or a drivcC'tnrough area, 'gross floor"
area means the covered a;rea.
'CresB
floor
aRea
Total
building square, footage
does no.t include
any:,
(1)
baseinentorattic area with a headroom less
than'
'7
feet 6 inches
r: " , "
(2)-'
area 'devoted to unenclosed
meCh~mical,
heating,aircopd,.:l.tioning, or ventilating ,equipment;
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RECOMMENDATION 3: Remove "as determined
by
the Director" language
Overview
In the definition of Group 1 and 2 and County Covered Buildings, the definition lays out which
buildings are covered and ends with ... "as identified by the Director." This language places the
onus upon DEP staff to identify each individual building that needs to be benchmarked, versus
the law applying evenly to all buildings that meet the definition.
Justfflcatlon
• Regulation standard practice places the onus on the resident/business owner to
comply
if
applicable, versus the local government Identifying those Individually
responsible· This language and resulting responsibility placed upon staff is not
standard practice for regulation in general, and especially amongst other benchmarking
jurisdictions. other jurisdictions make an effort to identify and notify buildings that are
covered by the law, but buildings owners that know their buildings qualify are still
required to benchmark, even if not identified. Such an approach matches other
regulations which apply to businesses whether or not they are identified by the
administering agency.
• Imperfect data
will
result in an unreliable list
of
covered buildings and responsible
building owners· The proposed approach is particularly important in the current
situation where there is not good data available to county staff to identify covered
buildings. Staff has parcel-based data and rentable square footage per building data,
but not building square footage.
Staff
is not able to confidently identify all the buildings
that will need to comply.
.
• DEP will stili attempt to Identify and notify covered buildings - This change would
simply mean that a building owner with a building covered by the law must benchmark,
even if DEP
is
not able to identify from their data sources, that they are covered.
Issue
Removing
If
AS
identifle~
by tl:lE!
DirE!ctol" in .
determining .
. Cov.ered
euHdln$s
Recommended Amendments
Soo-. 19A:-39. Defini
t:ions.. '. .•
. ..
'..
.
; county building means. artYbuilding.owIlet;i by the
f
Co4nty
I
or any group ,pf .buildings owned,.
py
the County
that .'. have the samep.ropeJ;ty identificat;;iqn I'lumber
I
ti1atequals
exceedS'
50,000
sqUare'f~et
gross floor
area;aa
idefttifi~Et:l9y
tffG 9ireotoZ:.
.... . . .
.
or
. Group!' covered' bliUdiil<j
~earts
any'noriresidential
. builc;iih9' .
Dr .
any gr0!lpof
n9nres~!i~ntia.l bUi'~i;Un9:;;
tbi:l.ttiave tQc same property:igentificfition numger, nqt
o\.med
by
the CoUntytha.t
equals
cir-e~ceeds ~ 5q:,~OO
square feet gross fl.o6r a.rea,
as'
idcfitiflJeEf eytae
riir~¢t:6;:
..'
.
.. :.
.
,j
~,:.'
..
. ,Group
2'c~v¢ired i)l.dldiflgineans;ahynorir~~id~nt;i.ai
'building, •.
Dr any
group
.of
'noIll~eslderitial
rnifldirtgs
th~th9.vethe
same Property'
id:~lit:iflca'Hbnn:uriiber,
h.ot
owned by
the County
tM.t
equa:Ls,6r
exceoo'S:;5;O,t>00
sqcici.tef"eet
gibBS floor area
but;
is
lesS
'th2ul2'50,
000
gqlJ,~t!e
'feet
gross
floor
'a~rea/a.tiI
iaentifie'E!i
l
l9y
the
DiiJgoeitle:t..
:.
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RECOMMENDATION 4: Revise
and
Clarify Verification
Overview
Benchmarking provides valuable data on building energy use, and collecting the data and
benchmarking requires time and effort on the part of building owners and managers; some may
even opt to contract this work out to an energy service provider. Verification is increasingly
becoming part of benchmarking and disclosure laws for many reasons. There can be a cost to
verification, which the Work Group sought to address. The group discussed Chicago's
approach (the only other jurisdiction currently implementing with a verification reqUirement),
consulted the Institute for Market Trpnsformation, and EPA ENERGY STAR in their work.
The Work Group has provided several different recommendations below
to
be
considered In-whole together
to
improve the value of benchmarking and lower the
potentIal cost of verification.
Justification
• Data Quality· Due to
the
data quality issueS being reported from other jurisdictions with
benchmarking laws, a verification process is considered a best practice and an important
component of the benchmarking process, both for the public institutions administering
the programs, but also for the building owners and industry as a whole.
• Reliability and Value of Data Transparency A verification process contributes to an,
even playing field in which businesses can feel confident in the data set as a whole, and
that their competitors are held to a similar standard for accuracy.
• Policy Decision-making. In order for the County to consider benefits or incentives to
aid building improvements, an accurate representation of the building stock and
performance levels are necessary to identify cost-effective use of resources and target
,support.
• Knowledge and capacity building - The discussion that wil.llikely occur in the process
of verification between a knowledgeable verifier
and
the building owner or manager
could provide valuable information towards taking actions to reduce energy use within
the building.
.
• Promote wQrkforce development and local jobs - The verification piece was also
defended as a workforce development and local job opportunity. In-holJse verification is
allowed and would encourage building owners to have their existing staff trained in
energy management and Portfolio Manager. Verification will also drive local training
programs and new leads for energy conservation projects.
w
Key Changes
• Expanded the legislated definition of Licensed Professional- The cost associated
with this part of the law is tied to the requirement of a "licensed professional- which often
means Professional Engineer or Registered Architect The group looked at the intent of
verification and Chicago's model, and expanded the scope to include less costly
credentials, redefining
the
-licensed professional- term to be "recognized data verifier".
• Provided guidance on type of credential accepted to do verification - Criteria were
also established (within their Guidance) on how DEP would evaluate additional
credentials that want to qualify.
• PrOVided guidance on the scope of verification - Based on conversations with EPA
ENERGY STAR and Chicago, the group decided that verification should follow the
applicable sections of the Portfolio Manager Verification Checklist. Guidance documents
should further infonn that verification can
be
done without an on-site visit. .
• Provided guidance on how verification should be documented - Again, the group
followed EPA ENERGY STAR and Chicago's
best
practices to detennine how
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verification should be documented and reported; this will be clarified in Guidance
documents.
• Removed hardship exemption for this section of the legislation - The group
determined that the hardship exemption for the Jaw as a whole was sufficient, and that
the lower cost of verification proposed should not warrant a second level of exemption
from this part of the law.
Issue
Scope·
of
who can
com
plete
the
requir~d·
..
verlfiCatlQn
Recommended Amendments and Guidance
StrI.ke
"LicenSed professional" and
replace
with
"Recognized data verifier"
Darini
U()ns ..
.
LieeaseEl ,refossional Reqog;nhed data verifier
1q~aris
a
.. Professional Engineer ora .Registered Architect or a
trainedindivldual whose professional license or
bullding energy trainfng. pr9gram credential is
recognized by the Direqtpr.. PFefessieAal
liee~ge.
re~ers
tea
prefE;3sional,cnfjiBecr or a
re~i6tifZ~cd
arehitcQt liecf'lOociin,
the
.S.tatl;:; or anothcrtl!'l;l:iHed
iHElfvielua!
as
defined in
a~~lieablc
CObmty
re§ulai:i:.9ftS ' .
.
Data
ve~ificati()n
Ve~ifip~t,ion
required.
B~fQr.e.th.e
first
beI',\c~,rkin9
deadltne' requiredhysectiori'f$A-39, ana
befol:-~·cach'
thl:rCi·
Qen~hmiu:'king
deadline
t~ereafter,:theo~ner
of
each':
c;~vered·
h).liid.ini] 'must .assure. that,
repot~ted
. ;
)Jen~J;'klng'
.
informat,,'ibn ·for· that year.
is'
'Veri:e,l.ed: by
:a
~u~seEl,fie~e6si~aa;t:+ecogni:i'e:d
:d<ilta
verifi~r
•• The
verif;i;~1:iionmlist
be'
ae4WepeEi'
aREl s,:i;.gned
st~tem~nt
by
a.
11i:;H.'~ftS~ ill:'~,g'Csf$4efliarecogniied da~a
·.v-er.i:fier '
at14s.t:irig
to' theaOcilra.:cy
of
the .
information.
;
...
;
.;,:
'.
.
;
",.'.
.'
Guidance on
Recognized data
verifier
In Guidance, DEP should include the following information:
In-house or Third-partv Verification
Recognized Data Verifiers may include in-house individuals or third-party
providers.
Criteria to Determine Recognized Data Verifier Credential
The Director will evaluate professional licenses and building energy
training program credentials to be accepted as a Recognized Data Verifier
based on the following criteria:
Demonstrates trained individuals' proficiency in building energy
benchmarking and familiarity with ENERGY STAR Portfolio
Manager;
• Demonstrates trained individuals' working knowledge of energy­
efficient operations, measures, and technology;
• . Provides opportunities for ongoing
skill
maintenance and/or re­
training as technologies, tools, and practices evolve;
• Provides means of tracking graduates or credentialed individuals
by name and with a unique identifier (such as a license,
identification, or other numbert and
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• Makes training materials and records available for review by the
Director and is found to be in compliance with preceding criteria.
Recommended Credentials for the Director to Accept
The Legislative Work Group has helped develop an initial roster of
credentials they recommend the Director recognize. A full list Is under
Appendix
A.
DEP staff will also explore ways to recognize individuals qualffied but
without an accepted credential.
Require the use of the free Portfolio Manager Verification Checklist, and
include the full name, credentials, and contact information (email or
phone) of verffier in Portfolio Manager notes (which are submitted to the
County). Verification documentation, signed not necessarily stamped
should be kept as a hard copy, to be made available upon request by the
Director, per legislation.
.
program
Like Chicago's pro bono verification program, DEP is encouraged,
particularly for the compliance period of Group 2 buildings in 2017. to
develop and implement a pro bono verification program. Such a program
would solicit energy service providers willing to volunteer time to complete
verification for building owners who cannot afford verification (e.g.
nonprofits, churches, other buildings with particular hardships). Buildings
that request pro bono verification would be published on a list (as a small
deterrence to avoid abuse of the program).
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RECOMMENDATION
5:
County Covered Buildings and Deadlines
Overview
Under the benchmarking legislation section for County buildings, the language does not use the
defined term vCounty Buildings· but instead refers to Vall buildings owned by the County" and
does not provide a date for them to report
to
DEP, only to benchmark. This change would make
the law consistently applied across County buildings and private sector buildings.
Justification
• Eliminate confusion about which buildings are to be benchmarked in the County
under the law - Using the defined term, ·County buildings" will clarify and make
consistent the intent that is within the definition
to
benchmark County buildings
50,000
square feet. and greater.
• Provide for reporting
of
data to DEP to be included in their reporting and database
- The currently language only requires benchmarking, but not reporting. To remain
Within the spirit of leading by example, County buildings should also report their data by
their June 1 deadline each year.
Note: These changes will not take effect unless adopted through legislative amendment. For
the County's first benchmarking year (June 1,2015). DGS and DEP are working together to
make sure DEP can meet their own reporting deadlines, and that DGS is meeting
its
obligations
as best understood under the law.
Issue
Amendttie' .
Recommended Amendment
Amendt1le County bulldi'ngs benchmarking langtJageto referto.the
defined:term, "Gountybuildirlgs"
I
and
t$
add·reporting ObligatioI'!
consistent WithprivatebtHldingscovered under
the
taw... : '
_
;
001:lAtY:··
l;>uUcfinga..
~
b8nchmarking
language
~.
lBA-39 Bnergyuse bent:lbniarking.
, .'
(a)
county :buildings,
. No later than
June .
.1;
2015,
and e"lif;ry
Jl'-n~
i
.thereafter., the county'must,
~
. benchmark
a~J:. M~ibe.iJil:fiJe.
&\#1tEls.
By e.oo.
county ..
buildings
f0r
t:h~p-rerlous'ea'lenda:r,y;ear
and,
·rep6~thehenchmark1ngirttormation.totlil:id
Departm~nt.
.
~
.'.
-'
~,
"
..
':
,.'­
,'"
"
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RECOMMENDATION 6: Move Private Building Deadlines to June 1
Overview
The current set of deadlines in the legislation are not clear, do not align with reporting deadlines
within the same legislation, and may cause inconvenience to major stakeholders due
to
the
proximity to holidays. The Work Group recommends moving the deadline up to June 1.
Justification
• Two deadlines are unnecessary and confusing - The legislation provides a separate
deadline for benchmarking and for reporting. The
two
deadlines are unnecessary, as
the former is unenforceable and
when
one benchmarks is irrelevant so long as
it
has'
happened before they report to the County. No other jurisdiction has two deadlines for a
pu re bill such as was adopted.
• The December 1 deadline does not align with DEP reporting requirements and
may render data disclosure Irrelevant- DEP is required
to
report to Council on the
benchmarking law each October. Current deadlines mean that DEP would be reporting
data that is nearly
two
years old. (e.g. DEP would report on and disclose CY 2015 data,
reported December
2016/January
2017 in October 2017) Such a timeline would reduce
the value and impact of the data disclosure.
• Benchmarking
will
not take 11 months to complete - Jurisdictions with benchmarking
laws have deadlines ranging from April 1 (DC) to typically June 1. Bills through the end
of the previous calendar year are usually available by March.
• The current deadlines falls during major holidays - The December 1 holiday falls
right between Thanksgiving and Christmas holidays, which can pose difficulties in terms
of staff availability, time out of the office, travel, and end-of-the-year reporting (for
building owners, utility d(!Jta access providers, and local government).
• The proposed deadline aligns but does not overlap with DC's deadline, whJch is
amenable to building owners with portfolios in both Jurisdictions and utility
staffing availability. DC's benchmarking deadline is April 1. Utilities have requested
we stagger our deadlines.
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APPENDIX A: Recommended Verification Credentials
These credentials are not part of a legislative amendment, but per legislative amendment,
credentials must be recognized by the Director in order to qualify an individual to perform
verification under the law. The following credentials are recommended by the Legislative
Committee be recognized by the DEP Director as qualifying credentials.
Credential
Professional Engineer (PE)
InstitutionlAssoc.
National Society of
Professional Engineers
. American Institute of
Registered Architect (RA)
Architects
Association of Energy
Certified Energy Manager (CEM)
EnQineers (AEE)
. Building Energy Assessment Professional (BEAP)
ASHRAE
AEE
Certified Energy Auditor tCE'll
• LEED ­ Professional with specialty-in Operations + Maintenance (LEED­ US Green Building Council
AP O+M)
(USGBC)
USGBC
LEED-Fellow - For outstanding APs
Building Energy Modeling Professional (BEMP)
ASHRAE
Commissioning Process Management Professional Certification (CPMP) ASHRAE
. Operations and Performance Management Professional (OPMPl
ASHRAE
Certified Commissioning Professional (CCP)
Building Commissioning
Association (BCA)
Associate Commissioning Professional (ACPJ
BCA
Sustainability Facility Professional (SFP)
International Facilities
Management Association
Certified Building Commissioning Professional (CBCP)
AEE
Existing Building Commissioning Professional (EBCPl
AEE
RPAlFMA High Performance Designation (RPAlFMA-HP)
BOMI International
Systems Maintenance Technician (SMn
BOMllnternational
Systems Maintenance Administrator (SM1\}
BOMI International
Real Property Administrator (RPA) with caveat requirements
BOMllntemational
Certified Property Manager (CPM) with caveat requirements
Institute of Real Estate
Manqgement
RPA and CPM are acceptable verification ctBdentia/s wfth the following caveats noted below.
Documentation must
be
submitted to enemy@montqomervcountmd.qov by the verifier each
year they complete verification under the benchmarking law.
RPA caveat: RPA must have been achieved with the elective course, Asset Management
OR achieved with completion of at least 3 of the 5 Sustainability/High Performance
Experience Criteria (http://www.bomi.org/uploadedFiles/2010 New SiteiSite­
wide ImageslRPA%20Experience%20Reguirement-2015.pdf).
CPM caveat: CPM must have been achieved with the following three functions selected and
illustrated in the Experience Form
(https:llwww.irem.org/File%20Library/Membership/CPMExperienceForms.pdf): #3, #30, and
#33.
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Testimony on Behalf of County Executive Isiah Leggett on
Bill 35-15
Environmental Sustainability - Benchmarking - Amendments
October 6, 2015
Good afternoon. My name is Stan Edwards, Chief ofthe Division of Environmental
Policy
&
Compliance in the Department of Environmental Protection. Thank you for the
opportunity to testify on behalf of County Executive Leggett regarding Bill 35-15, which would
amend the County's Commercial Benchmarking Law.
The Benchmarking Law, adopted in May 2014, required the County Executive to
convene a Benchmarking Work Group, made up of a broad set of stakeholders, to (1) review the
County's benchmarking process leading up to the June 2015 deadline to benchmark County
buildings, and (2) provide recommendations regarding the implementation of the law within the
private sector, including any recommended legislative amendments. The Benchmarking Work
Group submitted a report to the County Executive and County Council in September 2015 on the
results of their work. Bill 35-15 reflects the recommendations of the Work Group. Specifically,
this bill would add an intent section to the law; amend certain definitions; provide for certain
alternative paths to verification; and alter the private sector building group deadlines.
The County Executive would like to recognize the many individuals that participated in
the Work Group process. Participants included representatives from building owners, property
managers, industry associations, energy service companies, and nonprofit energy and
environmental organizations. The Work Group email list included over 350 subscribers, and
approximately 50 members participated actively throughout the process. The Work Group met
as a whole and in committees approximately twenty times between September 2014 and June
2015.. The Work Group continues to meet periodically to help ensure smooth implementation of
the law heading into the first reporting period next year. The Work Group process provides an
excellent example of cooperation among government, business, and environmental interests for
the benefit of all parties.
The County Executive appreciates the opportunity to comment on the proposed bilL I
would be happy to address any questions the Council may have.
@
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WRITTEN STATEMENT OF THE APARTMENT AND OFFICE BUILDING
ASSOCIATION OF METROPOLITAN WASHINGTON ON
BILL 35-15-THE ENVIRONMENTAL SUSTAINABILITY ­
BENCHMARKING - AMENDMENTS
The Apartment and Office Building Association of Metropolitan Washington (AOBA) is a non­
profit trade association representing more
than
more than
112,000
apartment units and over
30
million square feet of office space in suburban Maryland, the majority of which, including
57,204
apartment units and
24,809,066
square feet of commercial office space, is in
Montgomery County. AOBA is pleased to submit this statement on Bill
35-15 -
The
Environmental Sustainability Benchmarking - Amendments. The legislation proposes several
amendments to the County's existing benchmarking law, three of which AOBA submits
comments on below.
I.
PROPOSAL FOR NEW
JUNE
1 REPORTING DEADLINE
The legislation proposes to move the annual reporting deadline for private non-residential
buildings from December 1
to
June
1.
AOBA supports the proposed change.
Group
1
Non-Residential
Group
2
Non-Residential
50,000
sq. ft. up -
250,000
sq. ft.
2016
June
1,2017
II.
DELETE "GROSS FLOOR AREA" DEFINITION
The legislation proposes to substitute ''total building square footage" for the phrase "gross floor
area" currently referenced in the statute. The change is necessary to address differences in the
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meaning of the
teon
in Portfolio Manager and Montgomery County's law.
AOBA
supports
the
proposed
change.
III.
DATA VERIFICATION REQUIREMENT:
DATA
VERIFICATION
-CllRRENT AND
PROPOSED
STATVTORY CHANGES
!----':=~!'!:::"l'.':!!!'"~~=~~~:__~~r__:~~-~~~~~=~==~~~~
Ct1q.E~.S'f:&mQRV,
i
.
:_Q~"
SEC. 18A-40 DATA VERIFICATION
-
~~.,,'"----
-
,.~
.
PRQP,Q~.EJj~~S
.
. ......
._l'
_._._."'-._~_~_,
'.' ....•...• •
.• •.......• ' "
..._ .
1·. ________
.._.,,"-"_.,;...
~---.,;..;.;~~~.....:....
.........
~~...;l
......_.
rhows that compliance with this Section
will
at
under
this
Section
if
the owner.:
.'
;cause undue financial hardship. If a no-costf' . • '. . .
~""
~r
low-cost verification option is available,l·
II
'~BeI
__
-B8tm1&BtjIh-:H-"""_~Sf-eP--IQ1w-i1!Q5tl
~he Dir~tor ~ay
require the owner to use:tbe'I·.'
:tfell'ifieIN:it»it-ef)tie&-is-~tMlllbIler.HJm~H'l
ialtematlVe optlOn.
fl'
tM~K'RllfA!rUle-iM¥lt1ef:'-ter-U!;e-'la.e'""9lteFoat~
OP*'OB
eun demonstrate
that
the' buildin ha.
!
achieed
ENERGY STAR Certification for a
least 6 montbs of the
ear
beiu .
benchmarked.
j-'~--sic. 18A:3i'DiFiNITIONS---~'T' "--SEC~18A-38B
DEFINITIONS' ­
_
.-
- '.
.,-..
""''' __
.v>._,."..,,"'______ ,
... ...
...
=,>Oc=-.''"'',''''.;"'..,''
r'Lieensed
professional" means professional
I
"biee&seEi pf'eHssi9Dll1"
"Recognized
data
:engineel'Qr
registeredarcbitect
.ij~fftlS«i
in
verifier"
means a Professional Engineer or
Jtbe
State,
Gt
anotbertnlincd
individuat!!'
Registered Architect lieeBsed
ill
tlte 8tateo
!defined
in
applicable
County
regulations.
another
trained
individual
whose
rofessional
license
or
buildi .
cne
trainin
recognized
by
the Director
~:5~;r~i~Ei~~~\!!~~~-thel'ii:f~i;;~~;'V~~IiO~pa~h.Th
.
~
. .e....
lrements of thIS SectIon If theowner
,
DIrector may waIve the ven.ficatlOn :reqUltemen
q
u.
la)
Verifi~tion
Required: Before
thefirs~a)
Verification .required.
Before the
firs
/ixinchtriarking 9eadline
'teSluired by
SectionenchIIiarking deadline required by Section
18A.,
118A~~9,
an.d befoI1!eachtWrdbenehmarking .9, and before each third benchmarking
~.
~ead1irie the~er"
til"
()W~~rf)f ~eb
bereafter, the owner of each covered .. . ".
';covered building
must
.sure
that
ust assure that reported
benchrru:ttkin
!reported
beBeAJuar~g iIltormati~
'for irrforrna.tion
for that year is verified by a
D,
e4i
lB5eiCll
......
~bat
year.
i$...
verified
by
a
.J.i~
.... .
recognized
data
verifier... Tb
!professIonal. The .
~e.riicatlonmust
be.
a
erification must' be a stamped aRd $igne
~ped8.1id.
signed
s~!e.ment
by·a
Ii~ed s~~ment
by
a
lieeRsed prefessioBaI
reco •
jprofessional.attesting
to
the
accuracy
oithe
afa verifier
attesting to the accuracy of
~information.
If
t.he
Directorreq11eSts~.:the·
nformation. If the Director requests, the owner
pwner of a
oov~ buitdingm~
produce.
covered building must produce
thesta~
Itbe~tate~ent 1lt~lab~e
for the
m;ost
l'ecent~va.nabh;.
for the
~ost
recent year in
whi¢
l
I
I
~-'~~,..&,..,.....
"'_~"_ """"~.
'_''''~''''!'_'_'<'~'' '''ir'""-"",-~",",,,~,.<.,,.h~~~'''''<-''"-=''"-''¥
~"'_
_""'-~"""'''.-'''
_'_._______,_ _.,_ ___,,_ __
,~
_
___'_~Dlieaah!
Getmt'y
gegu:lations.
_~'-
__",_,_.,
.
2
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CURRENT LAW:
The County's current benchmarking law includes a provision requiring
building owners to have the reported benchmarking data verified by a licensed professional.
Building owners must verify the reported data after the first benchmarking deadline in
2016
and
every three years thereafter.
The proposed legislation proposes to allow building owners to
instead use a "recognized data verifier" to comply with this provision. The County's Department
of Environmental Protection (DEP) has also published guidance, included
with
the proposed
legislation., identifying the various acceptable credentials that will qualify an individual as a
recognized data verifier. The proposed list includes, for example, several designations from
institutions such as the Institute of Real, Estate Management (IREM) and BOMI. AOBA
commends DEP for proposing certifications which will allow more building owners to utilize
onsite staff and avoid the additional cost of hiring a third-party to perform this function. It is
important to note, however, that the approved list still excludes many exceptionally
knowledgeable building management staffwith relevant experience.
'pROPOSED~LEGISLATIO.N:
AOBA POSITION:
While AOBA commends the County for expanding the list of authorized
certifications, we continue to strongly oppose and question the necessity of retaining the
verification requirement in the benchmarking law. The purported reason for the proposed
language is an unsubstantiated need to assure the quality of the data yet to be submitted by
~¢rcia1 buij~~g
owners in MontgoJ)lery County,
many
ofWho.Ql
are
already very familiar
With Portfolio Martager.1 Montgomery eO\ltlty is not the Distria:OfColQillbia. We should not
expect Montgomery County to experience the same level of challenges experienced in
jurisdictions like the District of Columbia where the local law departs significantly from
Portfolio Manager guidelines. For example, District law requires owners to report water
consumption which is voluntary under Portfolio Manager. Additionally, unlike Montgomery
County, the District's law also applies to multifamily buildings. Many multifamily building
owners were unfamiliar
with
Portfolio Manager and benchmarking at the time the District's law
was adopted. Notably, while there was an energy star tracking system for multifamily buildings,
a rating system was not yet available for residential buildings. These are just a few examples of
differences which may have resulted in inaccurate data being reported in the early years of
benchmarking implementation in the District. Notably, the Montgomery County law simply
requires use of Portfolio Manager
by
nonresidential buildings,
many of whom as noted are
already familiar with Portfolio Manager and reporting building energy consumption data.
IV.
AOBA RECOMMENDATIONS
(1)
Delay implementation: AOBA recommends repealing or delaying the effective date of the
data verification provision until a period following the first reporting deadline. This would
lSee Attachment A - Energy Star Labeled commercial buildings for Maryland including Montgomery County;
Attachment B Montgomery County Benchmarking Brochure, page 2 ("Over one thousand of the nearly 4,300
commercial buildings in Montgomery County have accounts in Portfolio Manager. Of these buildings, 122 have
achieved a score of 75 and are certified as ENERGY STAR buildings"); Attachment C - List of AOBA members
recognized by Montgomery County as Early Bird Benchmarkers; and Attachment D - Existing EPA tool to allow
building owners to verifY data.
®
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provide
Ute
County with an opportunity to review actual reported data and determine at that
time, if questions about the quality of the data warrant implementing the data verification
requirement. Proceeding with the current proposal unfairly questions,
before reporting begins,
the reliability and integrity of the benchmarking data to be reported by building owners.
42.
AOBA amendment: Delete current 18A-40 and amend Sec. 18AM
Annual
report; disclosure
ofbenchrnarking information by adding anew paragraph (aMI).
Ut-llData Verification
Report.
Theanrrtijd
~spbmitted
oo,QctoMtl.
~Ot6$haIt
includ.e
.and ·analysi§ of; {D any technical errors in reporting via. Portfolio Manager; (2) need. for
additionai outreach to afi'ectedbuilding oWners; and
(3).{a) .
compliance reporting .statistics,
succe_~e~
and.
chruIeD.~es,
includiug
any
concerns,
if
an}:'.
with the accuracy, completeness and
correctness of the building energy . data beingrepprted
by
buildingsector
and type
inCluding
:but
not limited to co
Il1
mercial office buildings? .universities. hospitals, ca.n1puses
and
building
oonm1exes;
and a
(b)
'reCommendation.
based on
theCounty~sanalysis.
of
the.
data, . .
as.·.tQ
whether.Jhe County should implement
a data
verificationreguitement for
private
and
public
.buIlding
owners subject
to
this
section.
AND
(2)
Incorporate DC recordkeeping requirement which allows the government to review
records used to report consumption data. Review of the data wiD determine if a data
verification provision is necessary for subsequent reporting years.
DC
regulations:
21 DCMR 3513.13
A building owner shall comply with the following
record retention requirements: (a) Preserve benchmark results and supporting records for
a period of at least three (3) years. The records shall include:
(1
)The U.S. EPA Portfolio
Manager
confirmation
email
demonstrating
proof-of-submission
date;
(2) A copy of the building owner's energy, water, and space use attribute information
entered into Portfolio Manager; (3) Copies of applicable tenant information forms and
letters; and (4) Additional information used to support the information required by
§
3513.3(c); and
(b)
Make benchmark results and supporting records available for
inspection and audit by DDOE during normal business hours, following reasonable notice
byDDOE.
AOBA amendment: New 18A-44.
A
buildingowp,ef sh@ll comply with the following
record
retention requirements:
(al
Preserve bencbmarkresultsand supporting records for aperiQd of
at
least
three (3) years. The records. shalL include:
en
The U.S. EPA Portif'01io Manager
conftrplatiQn
email demonstrating proof..:of-submission date;
(2)
A
copy
of the building owner's
enemrandspace
use attribute information entered. into .Portfolio Manager;(3) Copies of
ap.pUcable
tenant
infognation
forms
and
letters;
and (blMakebencrunark
results
andsu:gQQrting
~ds
available for
inspection artd
audit by
the .
Director during nonnal
busillesS
hours,
'01.12.
reasonable notice by the Director.'
.
(3) Approved Credentials for recognized data verifier: The approved list should be
expanded to include persons with 10 years or more managing energy for a building owner or
manager.
4
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ATTACHMENT A
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