T&E Item 3
November 2,2015
Worksession
MEMORANDUM
October 29,2015
TO:
FROM:
SUBJECT:
Transportation, Infrastructure, Energy and Environment Committee
Amanda Mihill, Legislative
AttorneycSl1~'4
Worksession:
Bill 35-15, Environmental Sustainability -
Amendments
Benchmarking -
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 ©27).
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 for Committee Discussion - 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 financial hardship, but would be
required to use a no-cost or low-cost verification option if available.
Bill35-15.
Bi1l35-15 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.
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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:
1. 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 (©30-31).
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.
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;
(3) selfStorage; or
(4) a use classified as manufacturing and industrial or transportation, communication,
and utilities.
Council staff supports this amendment.
2
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This packet contains:
Bill 35-15
Legislative Request Report
Executive memorandum
Fiscal and Economic Impact Statements
Benchmarking Work Group report
Testimony/Written Correspondence
Executive
AOBA
DEP Comments
Circle #
1
6
7
8
12
27
28
58
F:\LA
W\B
ILLS\1535 Environmental Sustainability-Benchmarking-Amendments\T&E Memo.Docx
3
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Bill No.
35-15
Concerning: Environmental Sustainability
- Benchmarking - Amendments
Revised:
813/2015
Draft No._1_
Introduced:
September 15, 2015
Enacted:
March 15,2017
Executive: _ _ _ _
~
_ _ _ __
Effective:
_~
_ _ _ _ _ _ __
Sunset Date:
_N:..:.o=n~e~--=
_ _ __
Ch. _ _, Laws of Mont. Co. _ __
COUNTY COUNCIL
FOR MONTGOMERY COUNTY, MARYLAND
__.__.____
By: COWlcil President at the Request ofthe COWlty Executive
AN
ACT to:
(1)
(2)
(3)
(4)
(5)
add an intent section ofthe law;
amend certain defmitions;
provide·for certain alternative paths to verification;
alter the private sector building group deadlines; and
generally amend CoWlty law regarding energy efficiency and environmental
sustainability.
By amending
Montgomery COWlty Code
Chapter 18A, Environmental Sustainability
Sections 18A-38, 18A-39, 18A-40, and 18A-42
By adding
Chapter 18A, Environmental Sustainability
Section 18A-3 8A
Boldface
Underlining
[Single boldface brackets]
Double underlinigg
[[Double boldface bracketsD
* *
*
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 unqffocted by bill.
The County Council for Montgomery County, Maryland approves the following Act:
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BILL
No.
35-15
1
2
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.
3
4
The intent ofthis Article is to:
5
6
7
Utl
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;
8
9
10
.Gil
engage the commercial building sector with building energy
information crucial to adopting energy conservation and efficiency
opportunities;
11
12
13
14
15
16
(£l
spur market transformation
Qy
making building performance
transparent for the building and tenant market, allowing more accurate
evaluation ofenergy costs and creating
~
competitive market for energy
efficient buildings;
17
18
19
20
@
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
W
recognize building owners that have made investments to improve their
building energy performance and expand in-house capacity for energy
management.
21
22
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
number, that equals or exceeds 50,000 in total building square footage [square
feet gross floor area, as identified by the Director].
28
29
*
*
*
30
31
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].
32
33
34
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].
35
36
37
38
39
40
*
*
*
[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
41
42
43
44
45
46
47
*
*
*
[Gross floor area] Total building square/ootage
means the sum of the gross
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]
48
49
50
51
52
Total building square/ootage
does not include any:
(1)
basement or attic area with a headroom less than 7 feet 6 inches;
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BILL
No. 35-15
53
54
55
(2)
area devoted to unenclosed mechanical, heating, air conditioning, or
ventilating equipment;
(3)
(4)
parking structure; or
accessory structure to a residential building.
Energy use benchmarking.
56
57
58
59
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,
60
61
62
63
64
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
65
66
67
information to the Department [no later than January 1 each year].
(c)
Group
2
covered buildings.
No later than [December] June 1, 2017,
68
69
70
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
71
information to the Department [no later than January 1 each year].
72
73
74
75
76
77
78
79
*
18A-40.
(a)
Data Verification.
*
*
Verification required.
Before the first benchmarking deadline required
by Section 18A-39, and before each third benchmarking deadline
thereafter, the owner ofeach covered building must assure that reported
benchmarking information for that year is verified bya [licensed
professional] recognized data verifier. The verification must be a
[stamped and] signed statement by a [licensed professional] recognized
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BILL No. 35-15
80
81
82
83
data verifier attesting to the accuracy of the 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)
[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 §
months of the year being benchmarked.
84
85
86
87
88
89
90
91
18A-42.
Annual report; disclosure of benchmarking information.
*
(c)
*
*
92
93
94
95
96
97
Exceptions to disclosure.
To the extent allowable under state law, the
Director must not make the following readily available to the public:
(1 )
any individually-attributable reported benchmarking information
from the first calendar year that a covered building is required to
benchmark; and
(2)
any individually-attributable reported benchmarking information
relating to a covered building that contains a data center, or
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
98
99
100
101
102
103
104
105
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.
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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 ofthe 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 COWlty 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.
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 ofthe law, and the recommendations
provided seek to mitigate these issues.
This bill is designed to address a variety ofissues 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
PROBLEM:
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
WTI'HlN
MUNICIPALITIES:
PENALTIES:
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OFFICE OF THE COUNTY EXECUTIVE
ROCKVILLE. MARYLAND 20850
Isiah
Leggett
County Executive
MEMORANDUM
August
3,
2015
TO:
FROM:
SUBJECT:
George Leventhal, President, Montgomery
Co~
Isiah
Leggett,
Counly Executlve
-=.R
~..,Q.----
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 ofa broad set of stakeholders, to (1) review the
County's benchmarking process leading up to their June
1,2015
deadline, and
(2)
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.
The Department ofEnvironmental Protection (DEP) convened a Work Group from a broad
set of stakeholders, including an initial list ofover
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 of the Law. Each set of
amendments is introduced with a summary, justification, and textual annotations.
• Based on this Report, DEP has drafted a new bilI
(XX
-15
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
biII 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 deadlines.
If you have any questions, please contact Lisa Feldt in the Department of Environmental
Protection at
240-777-7730
or Iisa.feldt@montgomerycountymd.gov.
IL:kdm
Attachment
(s)
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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:
I) 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 souree 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 (IT)
systems, including Enterprise Resource Planning (ERP) systems.
Bill XX-I 5 would have no impact on the County's IT systems.
6. Later actions that may affect future revenue and expenditures
if
the bill 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 case.
Bill
XX-IS
amends definitions and administmtive 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
ofManagement and Budget
Michelle Vigen, Department of Environmental Protection
J
i!i!ii:~
. Hu es, Di
ce ofManagement and Budget
.
er
Date
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Economic Impact Statement
Bill ##-15, Environmental Sustainability - Benchmarking - Amendments
Background:
This legislation would amend sections ofChapter
18A
of the County Code as follows:
• Add an intent section ofthe law,
• Amend
certain
definitions,
• Provide for certain alternative paths to verification, and
• Alter the private-sector building group deadlines.
Bill ##-15 essentiatly 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 definition 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
STARcertification 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
#1#-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 fonowing contributed to or concurred with this
analysis:
David
Platt, Mary
Casciotti, and Rob Hagedoorn, Finance; Michelle Vigen, Department of
Environmental Protection.
Date
Department of Finance
I
Page2of2
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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
En~
SUMMAR.Y.....•..••••••••••..•.•.••••.•••••••.•..••.••.•.••••..•..•••••••........••.•......•.•..• 2
BACKGR.OUND ...................................................................................................... 3
RECOMMENDED
LEGISL.ATIVE .AMENDMENTS .................................................... 5
RECOMMENDATION 1: ADD INTENT OF THE LA
W ...............................................................
5
RECOMMENDATION
2:
RENAME
TERM.
"GROSS FLOOR AREA"
WITHIN THE LAW ................. 7
RECOMMENDATION
3:
REMOVE"AS DETERMINED
BY THE
DIRECfOR" LANGUAGE.............
9
RECOMMENDATION
4:
REVISE
AND
CLARIFY VERIFICATION ............................................
10
RECOMMENDATION
5: CoUNTY
COVERED BUILDlNGS
AND
DEADLINES...........................
13
RECOMMENDATION
6:
MOVE PRIVATE BUILDING DEADLlNES
TO JUNE
1 ......................... 14
APPENDIX A:
RECOGNIZED 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 bftl 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, nonproflts 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. Rename "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 nlicensed 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
Each set of amendments provided
with
a summary, justification, and textual annotations. A
version of the legislation. with a/l the amendments marked, is included at the end
of
this
document.
2
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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 non profits
• Early 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. Addition
of
Intent
2. Renaming "Gross square footage" to "Total square footage"
3. Removing aAs identified by the Director" in identifying covered b,ulldings
4. 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 information, 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 June 10, 2015. Comments from this
process have been incorporated into this final draft.
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RECOMMENDED 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
Iutent
of
the 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 cQnservation 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 ofthe'aw
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',
.'
'. BuildirigEni:!rgy Efficiency study (Chapter, 3
~
2,),
"support efforts of the Office of Sustainability
('Bii16-14J to increase energx efficiency
hand
reduce, greenhouse gas emissions in
,tlle
2t:iiate "
. ,
•sect.or and County buildings.
• Engage:
the
commercial building sect;o:r:
with
. building energy informationcruc,ial' toP adopting
energx conservatibnand efficiency.."
.
. opportuniti.es .
'. '
.,
• Spur market traqsformationby
m~kingpuilding
. performance transparent fo.r the building and·
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RECOMMENDATION 2: Rename teon, "gross floor area" within
the
law
Overview
The legislation determines applicability to buildings based on gross floor area. The law covers
bui/dings 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
summary of differences
is
In the GUIDANCE: GlOSS 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
"Gross sqfJare .
footage".
tennin()logy
Recommended Amendment
RenaiT:1,e"gross square footage"
to
"totaf building square footage"
Remove
·<trad~ floors~
from the
list.
of~$mpted
buildings - there,are no trade
floors in the County
.
Sec. 18A-38.
Def.in.it.iona.:
county building
means ariy building owned by·the County,
or any group· of buildings. owned by the County...that have
the same property identification number,' th?"t equals or
exceeds 50,000 scJ1:1are feet '!fross fleer are"" in total
bu:,i..ldirig square
footage~,
as identified
~bythe
DiEeeter.
.
..
.
:
'
Group
1
coveredb!1ildlngmeans any nonre.sidential
building, or any group.of nonresidential bui1<iings that
have the same property
.~dentification
number; n()t owned
by the County that equals or exceeds
250~OOO,oquare
feet
gross floor area, ln total building square
footage.~
identified
by
~he
Director.
Group 2 covered
building
means anynonrc.sidential
building, or any group of nonresidential buildings that
have the same property ident;ificatioJ;l
humbc'r,
not owned
by the
cOUn:ty
that equals or exceeds SO, '000 8.ql:lurefeet
~rElss.fl:ciol'!'area
in'total·bUildingsqu.;;s.re· footage but is.
l.ess .than 250,'OOOsEtuare feet
g:F~~B
.HOOF
area in total
bUildinQ square footage.
I
as i:dcfit:ified
by
'the DixeetoE;
GEe(38 fleer area
Total.building·sguare footage
means the
sum of the grQsshorizontal area of the several floors of
a building or structure measured from the exterior· faces
of the exterior walls or from.,the center l;i.ne of p'arty
walls. In a covered' but unenclosed area, such asa set
of gasoline pumps or a.drivecthrough area, gross floor
area means the covered
area~
..
GrOD8 fleer
aEed
Total'
building
squarefootagedo'es
~6t
include any: .. -.,-­
(1)
basement ,oratti,c C!.rea with a headroom less
than'
'7
feet 6 inches;. . .
(2) '.
are~devoted
to unenclosed meChimical,
heating, aircopd1
ti~n:ing
, or ventil a tin..9 equipment;
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RECOMMENDATION 3: Remove "as determined
by
the Director" langoage
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.
Justification
• 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"AS
identifle(i
the
Dh'ector" in
determining .
Covered. '.
Recommended Amendments
bv.
BUf:ldf"QS
lBA.:-3B. Def.i.n.i.t;:.i.ons.
county huilding mE!ans artyhuilding owpeq., by the
r
cotihty
I
or any group.
,p
f _buildings
pwn¢d,QY
the County
tnat hCiv!':'l thei same property identific;at;i.o,n I).umber,
.tl1ate.qUcils
Qr
exceeds' 50,000 sqUare
'f~et
.
g:t"OSS' floor
area,ae
idetiEifie:dpy
thQ
9ireoto~.
.......
.
s.o~
-.'.
-.
:
-.
Group
1,
covered' building meatus any' nonresidential
bui1c;iihSI ()r.any. gro),1.pof
ri<>.nres;i~~~tla.l blii~ding~
tbatha:vE) tlte saine propertyl(;ientificjltipn ntmil?erc, not
ol-medbytheCounty
that
equals dr"eiceeds
~5q,OOo.
square feet •
gross
floor a.real
as'
idcntlfieq.
aythe
Direet.e~...
"
.
.,
~
'. ,Gr9UP'
2:c~vered b~l1difigrti~ari~'ihy 'n6n.r~Md~i{tl.iill
group of nonre'sidentiiil tiUl'ldings
thathi;>ve·the same
propertyidenliflc:adbn.n:uriilier,
not
awned by
the county' t.hat e'I'uals·8r
eX-ceed-s";/5:0;
Obd
sqciciref'eetgtossfl.oor
areabufis less than
250.
1
0.0.0
. s-qti,ate
'-feet gross floor 'a'rea,...
a$
ideHtifie~ll9y
the
Di~eeteF
.
."
"
.,
bundingi .' or any
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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 TJpnsformation, 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 workforce development and local jobs - The verification piece was also
defended as a workforce development and local job opportunity. In-house 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.
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- Vtlhich 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
crede'ntials 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 inform 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 determine 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 law 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
Recommended Amendments and Guidance
Scope
of
who can
Strl.ke
uLicenSed professional" and replace with "Recognized data verifier"
complete the
requIred· ..
Definitions
t;i,eeasea prefosoioaal Recognized d..a ta verifier
nr~.;iiis
a
verification
.. Professional Engineer or. a Registered Architect or
a
trained individual whose professional License or .
btiildingeiiergy training prQgram credential
is
...
recognized:by the Direqt9r ,•. Professioaal Heelil.se.
re:t!ers
tQu
profeBflioaal; cagiaeer or a l!'c§istql!'cd
arehite.ef lieeased ia theStatq; or anothertr(3;iaed
inEifvit;iualas
·defined
applicable County
fegulat:iE)as. ,
.
is
Data
ve~ifioaticn
VCf·ifi.!;;a,t,ion requi:r;ed.
B~fQr,e
,:th.e first ben.chmii,rkint;1 , .
ooadl,ine·
required
by'
Section '1'81\-39,
and before
each
thi:rd· benqhmarking deadline thcieafter>;the6wper
of
each'e:0:Ver~d
bpilding.must· assure that: repoited
·benchl:ni~king
inforn\atitmfor that year is verified by
*:,ie~sed.f!ifJ$jeeslt\iiiai':1¢~co@ized :dataverifi~r,
The
verif;i;ci?i3ionmust be·
a:
·st:aa!l!eEi' 3:9:Ei
s~:gned, st~tement
by
a lieEfflseEl
bas~!Iiles~4e~cilrecognized
data .
verIfier
att!!i'st:i.rig to' 'theacdu:i:acy of the . information·.
:a
Guidance on
Recognized data
verifier
In Guidance, DEP should include the following information:
In-house or Third-party 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 number); 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 qualified 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 verifier in Portfolio Manager notes
(~ich
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.
-
.
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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RECO:M:MENDATION 5: County Covered Buildings
and.
Deadlines
Overview
Under the benchmarking legislation section for County buildings, the language does not use the
defined term "County Buildings" but instead refers to Hall 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
Amendtf}e
Recommended Amendment
Amend.the·Co.untybuildi'ngs benchmarking langiJageto refer
to .the
defined
term,
aGountybuildmgs",
al'ld.
to
add.
reporting Obllgati·on
consisteMtwithprlvatebullcUngscoverl'Jd unQsrthe:taw... :; ; .. _
18A-39 .Bnergyuse bencblnarki.ng.
..
(a).:.
county buildings,
.
No later than
June ...
l, 2015,
OO.ty::·
l;>ufldiftgs: .
b8nehmarkJng ..
language
.'
.'.
and
e;t~ry Jun~ ·l.thereaftei:~·;
the
must ,:'
.. '. benchmarj{..
a4::1.li\c\i3;lQ,j,~~B
. ..ei\HleEl
e:r tee
County.
bUildfrigs:tor
th~p'i:eViousca'lendar ':y~arand'
, .
rep~''t:hebenchma:i:king:
information.totlUf
Department.;'·'
county'
...
,
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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
pure 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 time line 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 dCJta access providers, and local government).
• The proposed deadline aljgns 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
Com.mittee be recognized by the DEP Director as qualifying credentials.
Credential
Professional Engineer (PE)
Institution/Assoc.
National Society of
Professional Engineers
..
. American Institute of
Registered Architect (RA)
Architects
Association of Energy
Certified Energy Manager (CEM)
I
Engineers (AEE)
ASHRAE
Building Energy Assessment Professional (BEAP)
Certified Energy Auditor (CEAl
AEE
LEED ­ Professional with specialty,in Operations + Maintenance (LEED­ US Green Building Council
(USGBC)
AP O+M)
USGBC
LEED-Fe"ow - For outstanding APs
Building Energy Modeling Professional (BEMP)
ASHRAE
Commissioning Process Management Professional Certification (CPMP) ASHRAE
ASHRAE
Operations and Performance Management Professional (OPMPl
Building Commissioning
Certified Commissioning Professional (CCP)
Association (SCA)
Associate Commissioning Professional (ACPj
SCA
I Sustainability Facility Professional (SFP)
International Facilities
!
Management Association
Certified Building Commissioning Professional (CBCP)
AEE
. Existing Building CommiSSioning Professional (EBCP)
AEE
RPAlFMA High Performance Designation (RPAlFMA-HP)
BOMI International
Systems Maintenance Technician (SMTl
BOMllnternational
BOMI International
Systems Maintenance Administrator (SMAj
Real Property Administrator (RPA) with caveat requirements
BOMllntemational
Certified Property Manager (CPM) with caveat requirements
Institute of Real Estate
Management
~
RPA 'and CPM
are
acceptable verification credentials with the following caveats noted below.
Documentation must be submitted to energv@montgomervcountmd.gov 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.bomLorg/uploadedFiles/201 0 New SiteiSite­
wide ImageslRPA%20Experience%20Reguirement-20 15.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%20Ubrarv/Membership/CPMExoerienceForms.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 of the 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. Bi1135-15 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 .nTNE 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.
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 tenn in Portfolio Manager and Montgomery County's law. AOBA supports the
proposed change.
III.
DATA VERIFICATION REQUIREMENT:
DATA VERIFICATION -ClJRRENT ANI) PROPOSED STATl'TORY CHANGES
---
---,
SEC. 18A-40 DATA VERIFICATION
~-~----
--------~--~---
.. 'STATtlTORV;
Ka) Verifi-=-tion
Before the
a) . Verification required. Before the
·n.
~hnuu"
km
.
d.
ea
dUne
'~Utre
d.'.
bY.
Sec~on
.enChm
arkin deadline, required by s.ectio.n
I
~.A
...
. ' .
.
'.·.g
.
.•...
....
.
18A-:39, and.
before.eachthlrd
ben~hmarktng
9,
and before each thud benchmarking
~Jll
fIeadUne
1ber~~~
the
ow~rOf
each 'ereaftet,
the owner of each covered
~Qi':i;
\COvered buildmg
must assure
that
ust: assure that reported .'
,
lreporteil~.Ilchmarking in:l~mudi~nt!
'n/orma.tion for that year is verified by
a
IJ!'."
~t(Il
.
.
itbat
year.
ill
vt}rif'ied
bY
a ,,,mued
'. .
rcoognized
data
verifier.. .....
jprofesslonaI.Tbev:erW.cationmust
be'
a
edfication must be a stamped aRd$igned
~~pedarid, sign~d
.$hlteine(it
by.
~
tatement.
by
a
lieeBsed pFafessiaBaI recOgnized
professiorialattesting
rothe
acCUi!f.lCyofthedata
~erifier
attesting to the accuracy of
tb
fnformation;
.~r,tne ·Oi~~l'rcq~~tbepormatioD. I~ t~e
Director requests. the
o~e:,?
:owner of "cpvete<:l
bwld1tlg
tnU$t
ptt1~a
covered bUlldmg must produce the . " .....
~he
statemelltavaiIable
for the tUo$(
t:ecent~vai1abte
for the most recent year in'
whic
!WI'
-'
,,-._~_~.
'.. .
Required:
'liE'Mlllf,r
...
"f '.
·PR.OJ»()SED~GES
__J-...
~-.~~~-:----'l
first
firs
s
i ..
.
. ,'". ", '[
H'
r~~~~6t~~(m~9o\;'f~-ibe~?~:;':1.~VerificaliO~
tequtremen
Pa!i'.Th
.}·equlrements
of this Section if theoWllet! Director may waive the verification
~hQWS
that compliance with this Section
will,
efl.mder this Section if
the
owner ,
fl'
..
•.
..,
..
~
..
(cause undue
financial
hardship.
If
a no-cost
l · . "
Io:v-cost verificati?n option is available,/
~f$f:Pr*
....
_-t!D$f-*..m'~~
~b.e
DIrector
may
reqUIre the owner to
useth~; ~rifi~~H.pfi.-ig.-m~~le;-i6Hlm-eIi
!alternative
o p t i o n . l
_~HEfQiJ~HM~miHt-'._~le-l~Rati¥.e!
1
apil8R can demQnstrate that the buildin ba,
'
1
achieved
ENERGY STAR·CertificanoQ·fo a
1
!
I e '
_"'-_'_,,:_._.'__
_.'_.__
..
I
SEC.
18A-38
DEFINITI()N~.
.... .
..i ...." . . . '.
SEC. 18A-38B DEFINITIONS
;9f
lQft"__....
~_''''''''_~.~~l<_.
._'_:~"":_.
"'_'_"/"""'~""_:~_'''-"",,,
F'Li~e;:sed·~proressionat,;,i1{eatiS·prof~;ionail"l:.ie;;;;eJ'·" p;e&5;f;;j"-'~Rec;g;;j;'C~d~"'data
~ngineet
Qf
rutered
arCbit~
lic.ensed
In.
verifier" means a Professional Engineer or .
license or buildin .
ene'
trainin
recognized
by
the Director
r
\the
State. GtBno.thertrail'led
individual
as Registered Architect lieeBsed in the State 0
~efined'
in
applicable
CQuntyrml!tiols. -
another trained individual whose
rofessiona
,
t
l
¥
!mftlie$le
Getmt~atkms...,~_,
___
.~.
2
29
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elJR.R.ENTLAW:
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 BOM!. 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 staff with relevant experience.
PRQPDSEnLEGISLATlOl~::
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
~eroial
buij4ij:lg owners in
Montg~
County,
many
ofwhQm.~<6b:eady
very familiar
with
Portfolio Maftager.
1
Montgomery Cdunty is not
~']}istribtof
C()ItllllQia. 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 the County with an opportunity to review actual reported data and detennine 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.
AOBA
amendment: Delete current 18A-40 and amend Sec. I8A-42. Annual report; disclosure
of benchmarking information by adding a new paragraph (a-I).
(fl:..
l).,Pata Verification
~rt
Theannmu
re.xgmIYbmiI:ted
ontjeWlXth
2016$h@lmcJyde
and
analysi§
of; (It
any .
teclmical
euors
.in
reDQrting
via
Portfoli~
¥awwer;
(2)
qSJ,eed . fW;
.additional outreach to
m~builgmg.~t
··.ind
(3)(a)· compliancefejNmng.
§,taiistics.
successes ansi
ch@en~st.S.includiqg,anycol1~,
if anX,with the
ac~uracy.
completeness and
correctness of the buiidfng
.elU~teaa.ta:beingreported
by building sector
and
type
1neluding~b:ut
not . limited to. cOInmercial office buildings, univmities, hospitals. campuses and buildhlg
cgm.w1¥Xet; and
I
O>l~ti,gn..
.
based
on
the~ynty~sana1ysis.
of
the
data,asfO
;WjietU!!:ilie· County should
tmpment
a
d8t!VenficationNquirement for
private
and
public·
.'builditt!p\mS,tS §!!biect to thiSseciion.
AND
(2)
Incorporate
DC
recordkeeping requirement which allows the government to review
records used to report consumption data. Review of the data will determine
if
8
data
verification provision is necessary for subsequent reporting years.
DC
regulations:
11 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: (l)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 OOOE during normal business hours, following reasonable notice
byDDOE.
(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
j
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ATTACHMENT A
32
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