Commercial Building Asset Rating Program, 48152-48158 [2011-20014]
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48152
Federal Register / Vol. 76, No. 152 / Monday, August 8, 2011 / Notices
TABLE 5.1—TEST LOAD SIZES—Continued
Container volume
cu. ft.
≥<
Maximum load
Average load
liter
≥<
Minimum load
4.80–4.90
4.90–5.00
5.00–5.10
5.10–5.20
5.20–5.30
5.30–5.40
5.40–5.50
5.50–5.60
5.60–5.70
5.70–5.80
5.80–5.90
5.90–6.00
lb
135.9–138.8
138.8–141.6
141.6–144.4
144.4–147.2
147.2–150.1
150.1–152.9
152.9–155.7
155.7–158.6
158.6–161.4
161.4–164.2
164.2–167.1
167.1–169.9
kg
3.00
3.00
3.00
3.00
3.00
3.00
3.00
3.00
3.00
3.00
3.00
3.00
lb
1.36
1.36
1.36
1.36
1.36
1.36
1.36
1.36
1.36
1.36
1.36
1.36
kg
19.90
20.30
20.70
21.10
21.50
21.90
22.30
22.80
23.20
23.60
24.00
24.40
lb
9.02
9.20
9.39
9.58
9.76
9.95
10.13
10.32
10.51
10.69
10.88
11.06
kg
11.45
11.65
11.85
12.05
12.25
12.45
12.65
12.90
13.10
13.30
13.50
13.70
5.19
5.28
5.38
5.47
5.56
5.65
5.75
5.84
5.93
6.03
6.12
6.21
Notes: (1) All test load weights are bone dry weights.
(2) Allowable tolerance on the test load weights are ±0.10 lbs (0.05 kg).
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IV. Summary and Request for
Comments
Through today’s notice, DOE
announces receipt of Samsung’s petition
for waiver from certain parts of the test
procedure that apply to clothes washers
and grants an interim waiver to
Samsung. DOE is publishing Samsung’s
petition for waiver in its entirety
pursuant to 10 CFR 430.27(b)(1)(iv). The
petition contains no confidential
information. The petition includes a
suggested alternate test procedure to
measure the energy consumption of
clothes washers with capacities larger
than the 3.8 cubic feet specified in the
current DOE test procedure. DOE is
interested in receiving comments from
interested parties on all aspects of the
petition, including the suggested
alternate test procedure and any other
alternate test procedure.
Pursuant to 10 CFR 430.27(b)(1)(iv),
any person submitting written
comments to DOE must also send a copy
to the petitioner, whose contact
information is included in the
ADDRESSES section above.
Issued in Washington, DC, on August 2,
2011.
Kathleen Hogan,
Deputy Assistant Secretary for Energy
Efficiency, Office of Technology
Development, Energy Efficiency and
Renewable Energy.
June 20, 2011
Dr. Henry Kelly, Energy Efficiency and
Renewable Energy Department of Energy,
1000 Independence Avenue, SW.,
Washington, DC 20585.
Re: Petition for Waiver and Application for
Interim Waiver, Clothes Washers
Capacity Greater than 3.8 Cubic Feet
Dear Assistant Secretary Kelly: Samsung
Electronics America, Inc., a subsidiary of
Samsung Electronics Co., Ltd. (Samsung),
respectfully submits this Petition for Waiver
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and Application for Interim Waiver to the
Department of Energy (DOE) for the testing of
clothes washers with capacity greater than
3.8 cubic feet.
The 10 CFR Part 430.27(a)(1) allows a
person to submit a petition to waive for a
particular basic model any requirements of
§ 430.23 upon the grounds that the basic
model contains one or more design
characteristics which either prevent testing of
the basic model according to the prescribed
test procedures, or the prescribed test
procedures may evaluate the basic model in
a manner so unrepresentative of its true
energy consumption characteristics as to
provide materially inaccurate comparative
data. Additionally, 10 CFR Part 430.27(b)(2)
allows an applicant to request an Interim
Waiver if economic hardship and/or
competitive disadvantage is likely to result
absent a favorable determination on the
Application for Interim Waiver.
Reasoning
In order to meet current market demands,
Samsung designed and will be marketing
clothes washers with capacities greater than
3.8 cubic feet. Samsung expects that the
majority of Samsung clothes washers will be
greater than 3.8 cubic feet in capacity. The
current test procedure, Appendix J1 to
Subpart B of Part 430, Table 5.1, does not
contain load sizes for capacities greater than
3.8 cubic feet, preventing Samsung from
appropriately testing clothes washer models
with capacity greater than 3.8 cubic feet. The
Department recognized this test method
deficiency in the Interim Waivers granted to
Electrolux (76 FR 11440), LG (76 FR 11233),
Whirlpool (75 FR 69653), General Electric (75
FR 76968), and Samsung (76 FR 21881).
The nature of this Application for Interim
Waiver and Petition for Waiver does not
differ from Samsung’s original Application
for Interim Waiver and Petition for Waiver as
published in 75 FR 57937.
Conclusion
Samsung requests that DOE expeditiously
grants the requested waiver for our Samsung
clothes washer, model WF501***. This
request is based upon the grounds that:
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1. Current test methods for clothes washers
do not allow testing of clothes washers with
greater than 3.8 cubic feet capacity.
2. DOE has already granted Samsung an
Interim Waiver in 75 FR 57937, per Table 5.1,
for similar models.
Affected Persons
Primarily affected persons in the clothes
washers category include Alliance Laundry
Systems, LLC., BSH Home Appliances Corp.,
Electrolux Home Products, Fisher & Paykel
Appliances, Inc., GE Appliances, Haier
America Trading, L.L.C., LG Electronics Inc.,
Miele Appliances, Inc., and Whirlpool
Corporation. Samsung will notify all these
entities as required by the Department’s rules
and provide them with a version of this
Petition. A copy was also provided to the
Association of Home Appliance
Manufacturers (AHAM).
Sincerely,
Michael Moss,
Director of Corporate Environmental Affairs.
[FR Doc. 2011–20015 Filed 8–5–11; 8:45 am]
BILLING CODE 6450–01–P
DEPARTMENT OF ENERGY
Office of Energy Efficiency and
Renewable Energy
[Docket Number EERE–2011–BT–NOA–
0049]
Commercial Building Asset Rating
Program
Office of Energy Efficiency and
Renewable Energy, Department of
Energy.
ACTION: Notice of request for
information (RFI).
AGENCY:
The U.S. Department of
Energy (DOE or the Department) seeks
to develop a voluntary National Asset
Rating Program for Commercial
Buildings (AR Program). The AR
Program would establish an Asset
SUMMARY:
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Rating system for commercial buildings
based on a national standard and would
evaluate the physical characteristics and
as-built energy efficiency of these
buildings. It would also identify
potential energy efficiency
improvements. The goal is to facilitate
cost-effective investment in energy
efficiency and reduce energy use in the
commercial building sector. DOE seeks
comments and information related to
the development of the AR Program.
DATES: Written comments and
information are requested on or before
September 22, 2011.
ADDRESSES: Interested persons may
submit comments, identified by docket
number EERE–2011–BT–NOA–0049, by
any of the following methods. Your
response should be limited to 3 pages.
• E-mail: to AssetRatingRFI–2011–
NOA–0049@ee.doe.gov. Include EERE–
2011–BT–NOA–0049 in the subject line
of the message.
• Mail: Ms. Brenda Edwards, U.S.
Department of Energy, Building
Technologies Program, Mailstop EE–2J,
Revisions to Energy Efficiency
Enforcement Regulations, EERE–2011–
BT–NOA–0049, 1000 Independence
Avenue, SW., Washington, DC 20585–
0121. Phone: (202) 586–2945. Please
submit one signed paper original.
• Hand Delivery/Courier: Ms. Brenda
Edwards, U.S. Department of Energy,
Building Technologies Program, 6th
Floor, 950 L’Enfant Plaza, SW.,
Washington, DC 20024. Phone: (202)
586–2945. Please submit one signed
paper original.
Instructions: All submissions received
must include the agency name and
docket number.
FOR FURTHER INFORMATION CONTACT:
Direct requests for additional
information may be sent to Mr. Cody
Taylor, U.S. Department of Energy,
Office of Energy Efficiency and
Renewable Energy, Building
Technologies Program, EE–2J, 1000
Independence Avenue, SW.,
Washington, DC 20585–0121.
Telephone: 202–287–5842. E-mail:
Cody.Taylor@ee.doe.gov.
SUPPLEMENTARY INFORMATION:
Background
The Department seeks to develop a
voluntary AR Program. The AR Program
would establish an Asset Rating system
for commercial buildings based on a
national standard and would evaluate
the physical characteristics and as-built
energy efficiency of these buildings. It
would also identify potential energy
efficiency improvements. The goal is to
facilitate cost-effective investment in
energy efficiency and reduce energy use
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in the commercial building sector. The
Asset Rating is intended to complement
other building rating and benchmarking
tools in the market, DOE’s Better
Building Challenge (in which partners
will commit to an energy savings
pledge, assess the improvement
opportunities across their portfolio,
undertake a showcase building retrofit,
and share their progress), and DOE’s
partnership with the Appraisal
Foundation (which would enable
investors, building owners and
operators, and others to accurately
assess the value of energy efficiency as
part of the overall building appraisal).
The AR Program will inform building
owners about the energy efficiency of
their buildings, enabling comparison of
the energy performance between
buildings while controlling for
differences in building operations and
occupant behavior. The AR Program
will also identify opportunities for costeffective improvements in the building
systems to increase energy efficiency.
Voluntary green building rating
systems and ENERGY STAR Portfolio
Manager have been used to varying
degrees in the building industry to
demonstrate building sustainability and
energy performance. For existing
buildings, measured energy
performance based on utility bill history
has been the dominant way to rate
building energy performance. However,
when a complete and continuous utility
history is missing (for example, a vacant
or partly empty building or a multitenanted building), it becomes difficult
to evaluate building energy
performance. Moreover, building
stakeholders don’t have a consistent
basis for determining whether the
energy use differences between two
similar buildings are associated
primarily with installed building
systems or with operational choices.
This information is important for
building owners and investors when
making decisions about efficiency
improvement; it also informs
prospective buyers and tenants who
may want to compare among existing,
new, and renovated buildings.
Therefore, a national program would
enable building stakeholders to directly
compare as-built energy performance of
building systems among similar
buildings, regardless of occupant
behavior and building operation.
Recent regional Asset Rating
initiatives, such as California’s AB 758
and the Massachusetts Commercial
Asset Labeling Program, indicate a
growing interest in a national Asset
Rating system. The AR Program would
facilitate the evaluation of energyrelated building characteristics, which
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include building envelope, HVAC
systems, lighting systems, and other
major building service related
equipment. The program would identify
opportunities for energy efficiency
improvements and estimate their likely
savings. If communicated to potential
buyers, lessees, and lenders, the Asset
Rating would provide information
necessary for the real estate market to
value building energy efficiency
measures.
The Department has aggressive goals
for facilitating cost-effective energy
savings in commercial buildings, most
recently stated in the Better Building
Initiative as a goal of 20% savings by
2020. Through the AR Program, the
Department intends to establish a
building Asset Rating system that can be
broadly applied to both new and
existing commercial buildings, and
provide affordable and reliable
information to building stakeholders.
The Department intends the Asset
Rating system to work with and
complement the Portfolio Manager
Operational Rating system, once the
Asset Rating system is sufficiently
demonstrated. Both of these systems
could be expected to evolve over time,
providing opportunities for increasing
integration. An integrated Asset and
Operational Rating together would
provide a feedback loop and
accountability for building owners and
operators to ensure that their building is
performing as intended and meeting its
potential. An integrated system would
also help building operators track the
results of upgrades and identify
potential operation and maintenance
problems. The Asset Rating and
Operational Rating would together
comprise a national building rating
system that effectively combines the asbuilt building efficiency with a gauge of
operational success.
This Request for Information (RFI)
calls on stakeholders to review the
considered approaches and provide
information to assist the Department in
the development and implementation of
this program. DOE intends to adopt or
develop standardized approaches to
evaluate the potential energy efficiency
of commercial buildings, provide
strategies to help building owners
improve building energy efficiency, and
establish a framework to convey the
information to audiences at various
levels. This RFI presents the following
aspects of the AR Program:
• Market needs and opportunities.
• Guiding principles for the program.
• Options and approaches for key
elements of the program.
• Pros and cons of various
approaches.
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• Initial proposed approach.
• Additional work that the
Department is considering.
The RFI is structured as follows:
(1) Program Overview.
(2) Market Needs and Guiding
Principles.
(3) Target Audience and Building
Types.
(4) Basic Metrics.
(5) Rating Methods.
(6) Rating Scales.
(7) Recommendations for
Improvements.
(8) National Commercial Building
Energy Database.
(9) Quality Assurance.
(10) Potential for Additional
Supported Options.
(11) Glossary of Key Terms.
(12) References.
The Department will consider all
input it receives and plans to have an
initial program design available by the
end of September 2011. Based on that
program design, the Department expects
to pilot the program in partnership with
interested parties and ongoing
commercial energy efficiency programs,
beginning in January 2012. The
Department welcomes input on issues
or logistical concerns that could extend
this timeframe.
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Program Overview
Limited information on the expected
efficiency of a building based on as-built
building systems and opportunities for
cost-effective energy efficiency
improvements are identified barriers to
energy efficiency investments. The
Department seeks to address these
barriers by establishing a standardized
approach for assessing the energy
performance of commercial building
assets and developing an easy-to-use
tool to help building owners and
stakeholders identify opportunities for
improvement. Accordingly, the AR
Program, as considered, has three
components:
• A rating system to compute
building energy efficiency and convey
energy performance information, taking
into account the building envelope,
mechanical and electrical systems, and
other major energy-using equipment.
The Department intends to seek ways
for the Asset Rating to be used in
coordination with the Portfolio Manager
Operational Rating to help building
owners understand the opportunities for
both capital and operational
improvements in their buildings.
• A Web application, included as part
of a free Asset Rating online software
tool (AR Tool), to maintain building
data entered by building owners or
operators and to analyze building
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energy use, accounting for envelope,
mechanical and electrical systems, and
other major energy-using equipment.
This tool would provide an energy
rating and enable owners and operators
to benchmark their building efficiency.
It would be used to provide an Asset
Rating Report.
• A second facet of the AR Tool,
designed to help building owners and
operators identify and implement
strategies to improve efficiency of their
buildings. In addition to receiving an
Asset Rating, building owners and
investors would be able to use the tool
to analyze the potential for capital
improvements to increase energy
efficiency. The potential to improve and
the potential energy savings would be
included in the Asset Rating Report.
DOE intends to support continuous
improvement of energy efficiency by
allowing buildings to be re-rated
following a retrofit.
Market Needs and Guiding Principles
The AR Program is intended to enable
building stakeholders to directly
compare expected as-built energy
performance among similar buildings
and to analyze the potential for capital
improvements to increase energy
efficiency cost-effectively. It would give
building stakeholders insight into a
property’s long-term energy cost, thus
informing their valuation of that
building. The AR Tool would provide
an as-built rating, identify potential
energy efficiency improvements, and
provide the anticipated rating resulting
from those improvements, illustrating
for stakeholders the impact of potential
capital improvements. Research
(McCabe, 2011; McKinsey, 2009) shows
a need to communicate energy and cost
savings to owners, investors, financiers,
and others to overcome market barriers
and motivate capital investment in
building energy efficiency.
The AR Program is intended to
complement and coordinate with the
existing Operational Rating system,
ENERGY STAR Portfolio Manager. The
Department is aware of other rating
systems and standards that exist or are
under development. These include but
are not limited to ASHRAE Building EQ,
LEED, Green Globes, ASTM Building
Energy Performance Assessment,
COMNET Commercial Buildings Energy
Modeling Guidelines and Procedures.
The Department will consider
developments in these rating systems
and standards as it creates a national
Asset Rating system.
The primary goal of the AR Program
is to spur commercial building energy
improvements in construction and/or
retrofits, so the principles that guide the
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program are based on market needs.
These guiding principles, which drive
the key program elements, are as
follows.
• Information must be credible,
reliable, and replicable.
• Information must be transparent
and easy to understand.
• Collecting information and
generating a rating must be affordable.
• Opportunities identified must be
relevant and practical.
• Program must include effective
quality assurance.
• Rating must recognize building
energy performance across the full range
of building efficiency.
The Department welcomes
stakeholder comments on these guiding
principles as the framework for the
development of the program.
Target Audience and Building Types
The AR Program is aimed at a variety
of building stakeholders—owners,
operators, investors, tenants, appraisers,
and designers. It may also inform
lenders, local government, utilities, and
green building rating systems.
Considering the variety of audiences,
the AR Program would provide an easyto-understand rating that can convey
building energy efficiency information
to those in the general public who have
no knowledge of building efficiency.
The AR Tool would also provide
technical information and identify
opportunities for improvements to
building professionals who would be
implementing the recommendations.
The Department seeks to develop an
affordable system that provides a useful
rating with minimal data collection. The
Department is considering a two-tiered
program. The first tier would yield a
preliminary rating and identified
opportunities for building
improvements, as well as an estimate of
the savings from the improvements. The
preliminary rating of building efficiency
would be based on minimum building
information. The second tier would
provide a certified rating after a
qualified professional has validated the
building information (see Quality
Assurance section). The preliminary
rating would give users rapid feedback
on building efficiency and improvement
opportunities; the second tier rating
would be appropriate for the
communicating the performance of the
building to others.
The AR Tool is not intended to
replace any engineering analysis needed
for building retrofits, but to provide
building owners and operators with a
quick, easy, affordable tool based on a
national standard. The AR Tool would
be designed for users who have basic
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knowledge of building systems, such as
building engineers, facility managers, or
contractors. Assistance from
credentialed or third party AR certifiers
would only be needed to receive a
certified rating. The Department intends
to work with interested parties,
including state and local governments,
utilities, and energy service companies,
to develop ways to use the AR Program
to promote market transformation.
Because of the different levels of
complexity due to building type and
size, the AR Tool development will first
focus on building types that generally
have simpler building systems and have
adequate information sources to
establish a reliable rating system. These
building types include office, school,
retail, warehouse, and assembly. In
time, other building types will be
added, including data center, laboratory,
refrigerated warehouse, health care,
lodging, food sale, food service, and
mixed use buildings.
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Basic Metrics
A building’s expected energy
performance can be described in a
variety of ways, including (1) Energy
use; (2) energy cost; or (3) greenhouse
gas emissions associated with the
building’s energy use. The Department
is considering several options for
representing building energy
performance, as described below.
Energy Metric—Source or Site Energy
Use
An energy metric is the most
straightforward way to represent
building energy performance. Three
building energy metrics to be
considered are site energy use, net
onsite energy use, and source energy
use. Site energy use can be directly
calculated using the sum of electricity
natural gas and any other fuels used. If
renewable energy is generated onsite,
the expected energy generation and net
energy use can also be calculated. Using
a source energy metric requires the use
of a conversion factor to convert site
electricity use to a source equivalent,
which would allow consumers to more
equitably consider all fuel types and the
environmental consequences of
electricity generation. Although site
energy is most closely related to the
values that customers see on their
energy bills for each fuel type, using
source energy as a metric more closely
reflect the cost tradeoffs among different
fuels and the long-term cost
implications of different energy choices.
Regional source-to-site conversion
factors vary and the offsite generation
mix is generally not controlled by the
consumer. Although regional source
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conversion factors more accurately
represent actual energy use, a national
conversion factor allows comparison
across the nation and ensures that a
building does not receive a relatively
low rating just because of its location.
The Department plans to use source
energy with a national source-to-site
conversion factor as the basic metric
because source energy can most
accurately represent total energy use of
a building and the related
environmental impacts. Also, using
source energy makes the Asset Rating
system compatible with ENERGY STAR
Portfolio Manager, which adopted
source energy as its basic metric. Source
energy use is familiar to building
owners and operators who have been
using Portfolio Manager or other
building rating systems relying on
Portfolio Manager. The Department
welcomes stakeholder comments on the
energy metric for Asset Rating.
Cost Metric
Consumers are generally more
familiar with cost metrics. However,
energy costs for commercial buildings
vary considerably in different parts of
the country and change over time,
including over the course of the day.
Without much more specific
information about a building’s
operations and its time-dependent perunit energy prices, energy cost does not
provide a durable, comparable metric
upon which to base a rating. A cost
metric alone cannot directly be used to
judge building energy performance or
guide building owners’ investment
decisions.
For the above reasons, the Department
does not intend to choose cost
information as the primary metric for
the program. However, the Department
is exploring how to use cost information
to assess opportunities to improve
building energy efficiency and describe
the likely cost savings associated with
these improvements. Though the actual
Asset Rating would not be affected by
energy or equipment costs, both of these
costs may be used to perform a life cycle
cost analysis, the results of which could
be used to propose opportunities for
cost-effective energy savings.
Greenhouse Gas Metric
Energy use significantly contributes to
greenhouse gas emissions, and the AR
Program would provide an opportunity
to educate consumers and help them
reduce their emissions. Using a
greenhouse gas metric as the primary
program metric would most closely link
the Asset Rating to associated
environmental impact. However, the
primary focus of the AR program is cost-
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effective energy efficiency
improvements, which is not perfectly
aligned with a greenhouse gas metric.
As noted by the Northeast Energy
Efficiency Partnerships using a
greenhouse gas metric can ‘‘confuse the
existence of non-carbon power
sources—including large hydropower
and nuclear power—with actual energy
savings.’’ (Dunsky, et al, 2009).
Therefore, the Department does not
intend to choose greenhouse gas
information as the primary metric for
the program. However, the Department
is exploring ways to support greenhouse
gas information as an optional element
of the program based on a partner’s
interest.
Initial Approach: The Department
intends to use source energy use
intensity as the primary performance
metric. Onsite renewable energy
generation may be recognized, but
separately from the rating calculation.
The Department welcomes stakeholder
comments on the above metrics.
Rating Methods
Various rating methods are possible.
All methods share some characteristics,
such as:
• A data collection phase in which
the user defines key building
characteristics.
• An energy use prediction phase.
• A comparison/rating phase.
For the data collection phase, the user
would enter the characteristics of the
building being examined; these values
would then be used in conjunction with
a set of default building characteristics
to develop the required inputs for the
energy use prediction phase. The user
inputs would fall into six broad
categories:
• General characteristics (use type,
location, age, available fuels, etc.).
• Design characteristics (geometry,
orientation, window to wall ratio,
structure type, etc.).
• Envelope elements (window types,
wall constructions, roof constructions,
etc.).
• HVAC system characteristics
(technology used, fuel type, efficiency,
etc.).
• Lighting system characteristics
(lamp type, numbers of lights, sensors
and controls, etc.).
• Service hot water (fuel type,
efficiency, storage capacity, etc.).
In addition to the above user inputs,
a set of internal values would be used
in the analysis. The internal values are
based purely on a building’s use type
and would be held constant across all
models of buildings with similar
functions. This set of inputs primarily
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consists of the occupancy and operation
parameters, such as:
• Occupancy schedule.
• HVAC system operation.
• Hot water use.
Both the user-entered and the
internally defined, fixed building
characteristics would be combined to
develop the inputs for a building energy
use prediction tool.
Several potential methods for
predicting a building’s energy use are
being considered, including:
• Pre-simulating large numbers of
buildings and using interpolation to
customize the results to an individual
case.
• Detailed energy simulation.
• Simplified energy simulation.
Each of the above methods has unique
strengths and potential issues. Selecting
the correct method will require tradeoffs
between flexibility, accuracy, and the
end-user’s time investment in data
collection.
In the case of a pre-simulation
methodology, the benefits are relative
ease of use and a level of complexity
that can be highly tailored to the needs
of the asset rating methodology. Once
deployed, this approach is less flexible
than approaches that use real time
modeling because each possible
combination of building attributes must
be predicted and modeled beforehand.
For each additional building input
characteristic that the end-user can
control, the number of required models
is greatly increased. Depending on the
level of effort required per model, it
could be challenging to implement this
approach with enough granularity to
provide useful results.
There is a wide range of building
energy modeling tools, each with
different strengths and weaknesses,
including differing levels of input and
output detail, required development
time, and expected user expertise. Most
one-off energy models are highly
detailed to allow the inclusion of all of
a building’s unique characteristics.
Using a detailed modeling approach to
formulate an asset rating would most
likely provide the greatest flexibility
and accuracy. Such a tool would,
however, require a substantial amount
of development time and would still
likely require a professional building
energy modeler to use properly—though
with greater development time some of
the expertise requirements could be
overcome.
Simplified analysis models use many
simplifications and assumptions that
allow an inexperienced user to quickly
develop robust energy models. In
general, these modeling tools allow
fewer input combinations than a
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detailed model and will reduce
opportunities for error. The primary
drawback of a purpose-built simplified
simulation model would be user
concern about the accuracy of the
results.
Whichever rating calculation method
is selected, the required outputs would
be the same. The Department intends to
select one or more metrics (see Basic
Metrics section) to be the primary
output of modeling. The metric(s)
would allow for both the placement of
the subject building onto a rating scale
(as defined in Rating Scales section) and
the comparison of the building with
similar buildings.
The Department welcomes
stakeholder comments on the rating
calculation methods.
Rating Scales
There are several ways to deliver
building energy performance
information to consumers. Various types
of scales have been used in the existing
building rating systems. The following
is a discussion of the different methods
and their applicability to the Asset
Rating system.
Numeric Scale Reflecting Physical Units
This scale method represents a certain
type of physical unit. For example, the
EnergyGuide label found on household
appliances uses a physical scale
(supplemented with cost information),
such as kilowatt hours per year in the
case of refrigerators supplemented with
the expected annual cost of the
particular refrigerator. The miles-pergallon (MPG) rating displayed on new
vehicles is another example of using
non-converted physical units to convey
information. The physical units can
transparently deliver the technical
information to the consumers; however,
consumers may be unable to judge if
they are unfamiliar with the units.
Unlike cost or MPG rating for vehicles,
energy units such as kBtu/ft 2 do not
convey enough information to most
audiences without engineering or
energy knowledge. The Asset Rating
aims to promote market transformation
and educate consumers, and an absolute
energy scale could be challenging for
the general public to interpret. In
addition, an unprocessed numeric scale
does not offer a comparison between a
building and its peers, which is a
desirable comparison because
consumers are often motivated by how
they compare to others.
Numeric Scale Converting Physical
Units into Score System
This rating method converts a metric
from physical units into a score or
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index, which may be more easily
understood by consumers. ENERGY
STAR Portfolio Manager, for example,
converts energy use in commercial
buildings into a score on a 100-point
scale. The Home Energy Rating System
(HERS) scale, used primarily for new
homes, also converts energy units into
an index, where 100 represents a home
built to 2006 International Energy
Conservation Code standards.
The scores can be calculated using
either a percentile rank method or an
interval method. ENERGY STAR
Portfolio Manager uses a 100 point
percentile rank scale based on
supporting databases, which provide
statistical representation of a given
building type. This approach is not
appropriate for the Asset Rating because
there is no reliable database recording
the efficiency of existing buildings. In
addition, the AR Program is intended to
provide information on expected energy
use (and energy costs) and effective
energy efficiency strategies across all
buildings. A percentile rank scale does
not accomplish this objective
throughout the entire range of the scale.
In particular, the high efficiency—on an
absolute basis—of the most efficient
buildings is not fully reflected.
An alternative is a 100-point interval
scale. Use of a 100 point scale would
have some consistency with ENERGY
STAR Portfolio Manager. An advantage
of a 100-point interval scale is that the
rating system can recognize building
efficiency and building efficiency
improvements in a similar manner at all
efficiency levels. DOE is also
considering a simpler numeric scale,
similar to the 10-point scale used by the
Home Energy Score (https://
www1.eere.energy.gov/buildings/
homeenergyscore/). A 10-point scale
does not imply the same degree of
precision as a 100-point scale. In this
sense, a 10-point system, although a
numeric score, functions as a bin
system, which is discussed in the next
section.
Categorical Scale Assigning Physical
Units Into Bins
The physical units can also be
converted into a category system, which
could be presented in letters, numbers,
stars, or other symbols. It has been
shown that categorical scales, compared
with continuous numeric scales, lead to
better comprehension because
‘‘categorical ratings are easy to use and
quick to decipher’’ (Thorne and Egan,
2002a). Viewers can more easily gauge
a building’s performance relative to
other buildings or a reference point.
Categorical ratings using letter grades
have been used in multiple building
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rating systems such as ASHRAE
Building Energy Quotient and the UK
Display Energy Certificate. A rating
system based on letter grading is also a
common format for several countries in
the European Union, although the
meaning of each grade could be very
different across regions. A series of
studies on the EnergyGuide label has
demonstrated that consumers favor a
stars-based format because it is familiar
and intuitive, while check marks or
letter grades are more confusing (Thorne
and Egan, 2002b).
While stars and grades simplify things
for consumers, a binned system also has
drawbacks. Using a binned system can
appear qualitative. Including a reference
value can help alleviate this weakness.
The number of bins is also important.
Too many bins may complicate the
system, while too few bins can make it
hard for a building to improve from one
bin to the next, and not be appropriately
reflective of the investments made and
the savings being achieved.
With a well-defined bin range, a
categorical system would allow easy
distinction between the categories and
allow quick comparison between
buildings as well as changes within a
building category as improvements are
made. Star ratings are visually
appealing, motivating, and quickly draw
attention. Thorne and Egan’s (2002b)
research also suggested ‘‘consumers
found the stars rating system
complementary with the ENERGY STAR
label and certification.’’ The
shortcoming of a stars-based format is
that the number of stars needs to be
limited. More than six stars may make
it difficult for viewers to recognize the
value quickly. In this case, a numeric
format (10-point scale) becomes
advantageous.
Initial Approach: For the Asset Rating
system, the Department is considering
using a scale using physical units,
possibly accompanied by a numeric
interval scale. A 100-point interval scale
would complement Portfolio Manager’s
100-point range. The Department
welcomes stakeholder comments on
rating scales.
The Department is considering
including the following basic building
information on the Asset Rating Report
to ensure that similar buildings are used
for comparison:
• Building name.
• Year built.
• Climate zone.
• Building type.
• Year rating is issued.
• Report serial number (for tracking
purposes).
Analysis results would be clearly
displayed and formatted for easy
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reading and understanding, and would
include:
• Calculated energy use.
• Building Asset Rating based on
calculated energy use.
• Asset Rating that can be achieved
with energy efficiency upgrades.
• Energy and cost savings associated
with the higher achieved rating.
Additional information may also be
provided in the future, such as:
• A reference point to help users
understand how their building score
compares to a chosen energy code.
• Indication of whether the building
has systems to provide a certain amount
of energy from onsite renewables.
• Greenhouse gas emissions.
The Department is also considering
working with interested partners to
include local benchmark information on
the Asset Rating Report for comparison.
For example, a state might wish to
include information pertaining to
average asset ratings for a particular
building type within the state. The
Department welcomes stakeholder
comments on the information included
on the Asset Rating Report.
Identified Opportunities for Energy
Efficiency Improvements
Based on the building information,
the AR Tool would identify potential
opportunities for energy efficiency
upgrades that could cost-effectively
improve a building’s asset rating.
The AR Tool would identify
improvement opportunities in areas
such as heating, cooling, and ventilation
equipment; envelope; glazing; service
hot water; lighting; and electric motors.
The AR Tool is not intended to
replace energy audits or any engineering
analysis required for building retrofits.
It is intended to provide an affordable
way for building owners and operators
to determine which building systems
are good candidates for an efficiency
upgrade. The tool may be a gateway for
building owners who have limited
internal resources to engage with service
providers who can provide building
rating with the AR tool and offer
products and services that can improve
energy performance.
Initial Approach: The Department is
considering computing cost savings
estimates for energy efficiency measures
based on regional energy costs,
acknowledging that local conditions
will vary. The AR Tool will not display
return on investment given that
equipment and labor costs are likely to
vary considerably. The Department
welcomes public comments on the best
way to assess opportunities for energy
efficiency improvement.
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48157
National Building Asset Rating
Database
The Department intends to establish a
national building Asset Rating database
to track Asset Ratings and ensure the
legitimacy of ratings. The Department is
aware of potential privacy issues related
to maintaining this information and the
desire for some jurisdictions to require
disclosure of energy Asset Ratings.
Public comments are welcome regarding
structure and use of the Asset Rating
database.
Quality Assurance
The ability to generate accurate and
consistent information is important to
maintain user confidence. The
Department intends to include quality
assurance requirements for the
following:
Asset Rating Tool
The user would receive a warning
when automated checks suggest that
data entered may be incorrect or
incomplete.
Professional Requirements for Asset
Rating Application
Building owners would be able to use
the free Web application to enter the
required energy and building
information, generate a preliminary
building Asset Rating, and receive
recommendations. The Department is
considering requiring a professional
with specific approved qualifications to
validate building information inputs for
a building to be eligible for a certified
Asset Rating. The Department intends to
develop a guideline to specify the
credentials that a professional must
hold in order to generate a certified
rating.
Third-Party Verification
Third-party verification can be an
effective way to ensure program quality.
Some jurisdictions may want to require
third-party verification of the accuracy
of data used to acquire a certified rating.
The third party may require building
owners to submit supplemental building
information and/or perform an onsite
audit. The Department is evaluating
options for implementing this type of
requirement, including establishing
verification standards and approving
qualified third-party organizations.
Verification data and reports may be
integrated into the Asset Rating
database, software tool, and reports.
Technical Support
Full documentation of the rating
methodology would be available online
for public review. A user manual,
guidelines and eligibility requirements
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for the qualified professionals, data
checklists, and FAQs would be available
to owners and operators to applying for
certified Asset Ratings. In addition, help
for users would be available before,
during, and after the application
process. A user feedback survey may be
implemented to help gauge program
satisfaction and to gather suggestions for
improvement.
Initial Approach: The Department is
considering ensuring the quality of the
Asset Rating by providing a free Webbased application to guide standard data
collection, calculate energy use, and
generate ratings; requiring professionals
to review final submissions; enabling
third-party verification; and providing
necessary technical support. Public
comments on the quality assurance
methods are welcome.
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Potential for Additional Supported
Options
While a national performance metric
and rating system would help ensure
consistency across the country, the
Department recognizes that state and
local governments and other program
implementers may be interested in
providing information that goes beyond
the national metric and rating.
To that end, the Department intends
to partner with state and local
governments to support the sharing of
additional information as part of this
effort. For example, while greenhouse
gas information is unlikely to be a
standard metric for the AR Program, the
Department could provide conversion
factors to states and other partners that
are interested in providing such
information.
This document describes the major
design questions that the Department is
considering in developing a voluntary
AR Program. DOE is seeking comments
on the issues discussed above. However,
stakeholders are welcome to raise other
relevant issues that the Department may
have overlooked in this design process.
Glossary of Key Terms
Asset Rating—An assessment of
building energy performance that is
based solely on a building’s physical
assets, excluding the impacts of
building operation characteristics.
Asset Rating Report—A short form
document showing only key outcomes
for a building that has undergone the
Asset Rating process.
Baseline—The amount of energy that
is consumed annually before
implementation of energy efficiency
measures based on historical metered
data, engineering calculations,
submetering of buildings or energyconsuming systems, building load
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simulation models, statistical regression
analysis, or some combination of these
methods.
Benchmark—The building profile
used as a reference point for comparing
energy use and other performance
characteristics.
ENERGY STAR Portfolio Manager—A
Web-based, portfolio-wide energy and
water tracking system that tracks many
metrics of energy use- including total
site energy, source energy, weather
normalized energy use index,
greenhouse gas emissions, indoor and
outdoor water usage, and (for some
building types) the ENERGY STAR
score.
ENERGY STAR energy performance
scale—A 1–100 percentile rank score
that indicates how a building performs
relative to similar buildings nationwide.
The scores are adjusted using
standardized methods to account for
differences in building attributes,
operating characteristics, and weather
variables. Buildings performing better
than 75% of similar buildings can be
certified to ENERGY STAR.
Energy Efficiency Measure—A design,
operation, or technology change for the
purpose of reducing energy
consumption.1
Net Onsite Energy Use—The sum of
all energies that are consumed in a
building minus any energy that is
generated on site.
Operational Rating—An assessment
of building performance that is
developed to reflect the energy
performance of a building, accounting
for its physical assets and its specific
operational characteristics.
Site Energy Use—The amount of
energy consumed at a building location
or other end-use site, as reflected in the
utility bills. Includes electricity
generated by onsite renewable energy
systems.
Source Energy Use—The total energy
used at a site, including upstream losses
in distribution, storage, and dispensing
of primary fuels, or power generation,
transmission, and distribution of
electricity.
Percentile Rank Scale—A percentile
scale that is defined solely in relation to
a sample population; the scale itself
contains no information in absence of
information regarding the specific
sample population. The primary
purpose of a percentile rank scale is
comparison between peer buildings.
Interval Scale—A scale for which
each location along its span relates
directly to some metric or measurement.
1 Source: ConstructionDictionary.com, https://
www.construction-dictionary.com/definition/
energy-efficiency-measure-EEM.html.
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References
ASHRAE. 2009. Building Energy Quotient:
Promoting the Value of Energy Efficiency in
the Real Estate Market. Atlanta, GA.
American Society of Heating, Refrigerating
and Air-Conditioning Engineers. https://
www.sustain-rhythm.com/
HPB%20Exchange/files/
Energy_ABELFinal.pdf.
Dunsky, P., Lindberg, J., Piyale-Sheard, E.,
and Raesy, R. 2009 Evaluating Building
Energy Efficiency Through Disclosure and
Upgrade Policies, A Roadmap for the
Northeast U.S. Lexington, KY. Northeast
Energy Efficiency Partnerships, Dunsky
Energy Consulting.
Massachusetts Department of Energy
Resources. 2010. An MPG Rating for
Commercial Buildings: Establishing a
Building Energy Asset Labeling Program in
Massachusetts. Boston, MA. https://www.
mass.gov/Eoeea/docs/doer/Energy_
Efficiency/Asset_Rating_White_Paper.pdf.
McCabe, M.J. 2011 High-Performance
Buildings—Value, Messaging, Financial and
Policy Mechanisms. Richland, WA. Pacific
Northwest National Laboratory.
McKinsey & Company. 2009. Unlocking
Energy Efficiency in the U.S. Economy. New
York, NY. McKinsey & Company, Inc. https://
www.mckinsey.com/en/Client_Service/
Electric_Power_and_Natural_Gas/Latest_
thinking/Unlocking_energy_efficiency_in_
the_US_economy.aspx.
Thorne, J., and Egan, C. 2002a. An
Evaluation of the Federal Trade
Commission’s EnergyGuide Appliance Label:
Final Report and Recommendations.
Washington, DC: American Council for an
Energy-Efficient Economy.
Thorne, J., and Egan, C. 2002b. The
EnergyGuide Label: Evaluation and
Recommendations for an Improved Design.
Proceedings of the ACEEE Summer Study on
Buildings, Panel 8: 357.
Disclaimer and Important Notes
This is an RFI issued solely for
information and program planning
purposes; this RFI does not constitute a
formal solicitation for proposals or
abstracts. Your response to this notice
will be treated as information only. DOE
will not provide reimbursement for
costs incurred in responding to this RFI.
Respondents are advised that DOE is
under no obligation to acknowledge
receipt of the information received or
provide feedback to respondents with
respect to any information submitted
under this RFI. Responses to this RFI do
not bind DOE to any further actions
related to this topic.
Issued in Washington, DC, on August 2,
2011.
Kathleen B. Hogan,
Deputy Assistant Secretary for Energy
Efficiency, Office of Technology
Development, Energy Efficiency and
Renewable Energy.
[FR Doc. 2011–20014 Filed 8–5–11; 8:45 am]
BILLING CODE 6450–01–P
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Agencies
[Federal Register Volume 76, Number 152 (Monday, August 8, 2011)]
[Notices]
[Pages 48152-48158]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2011-20014]
-----------------------------------------------------------------------
DEPARTMENT OF ENERGY
Office of Energy Efficiency and Renewable Energy
[Docket Number EERE-2011-BT-NOA-0049]
Commercial Building Asset Rating Program
AGENCY: Office of Energy Efficiency and Renewable Energy, Department of
Energy.
ACTION: Notice of request for information (RFI).
-----------------------------------------------------------------------
SUMMARY: The U.S. Department of Energy (DOE or the Department) seeks to
develop a voluntary National Asset Rating Program for Commercial
Buildings (AR Program). The AR Program would establish an Asset
[[Page 48153]]
Rating system for commercial buildings based on a national standard and
would evaluate the physical characteristics and as-built energy
efficiency of these buildings. It would also identify potential energy
efficiency improvements. The goal is to facilitate cost-effective
investment in energy efficiency and reduce energy use in the commercial
building sector. DOE seeks comments and information related to the
development of the AR Program.
DATES: Written comments and information are requested on or before
September 22, 2011.
ADDRESSES: Interested persons may submit comments, identified by docket
number EERE-2011-BT-NOA-0049, by any of the following methods. Your
response should be limited to 3 pages.
E-mail: to AssetRatingRFI-2011-NOA-0049@ee.doe.gov.
Include EERE-2011-BT-NOA-0049 in the subject line of the message.
Mail: Ms. Brenda Edwards, U.S. Department of Energy,
Building Technologies Program, Mailstop EE-2J, Revisions to Energy
Efficiency Enforcement Regulations, EERE-2011-BT-NOA-0049, 1000
Independence Avenue, SW., Washington, DC 20585- 0121. Phone: (202) 586-
2945. Please submit one signed paper original.
Hand Delivery/Courier: Ms. Brenda Edwards, U.S. Department
of Energy, Building Technologies Program, 6th Floor, 950 L'Enfant
Plaza, SW., Washington, DC 20024. Phone: (202) 586-2945. Please submit
one signed paper original.
Instructions: All submissions received must include the agency name
and docket number.
FOR FURTHER INFORMATION CONTACT: Direct requests for additional
information may be sent to Mr. Cody Taylor, U.S. Department of Energy,
Office of Energy Efficiency and Renewable Energy, Building Technologies
Program, EE-2J, 1000 Independence Avenue, SW., Washington, DC 20585-
0121. Telephone: 202-287-5842. E-mail: Cody.Taylor@ee.doe.gov.
SUPPLEMENTARY INFORMATION:
Background
The Department seeks to develop a voluntary AR Program. The AR
Program would establish an Asset Rating system for commercial buildings
based on a national standard and would evaluate the physical
characteristics and as-built energy efficiency of these buildings. It
would also identify potential energy efficiency improvements. The goal
is to facilitate cost-effective investment in energy efficiency and
reduce energy use in the commercial building sector. The Asset Rating
is intended to complement other building rating and benchmarking tools
in the market, DOE's Better Building Challenge (in which partners will
commit to an energy savings pledge, assess the improvement
opportunities across their portfolio, undertake a showcase building
retrofit, and share their progress), and DOE's partnership with the
Appraisal Foundation (which would enable investors, building owners and
operators, and others to accurately assess the value of energy
efficiency as part of the overall building appraisal).
The AR Program will inform building owners about the energy
efficiency of their buildings, enabling comparison of the energy
performance between buildings while controlling for differences in
building operations and occupant behavior. The AR Program will also
identify opportunities for cost-effective improvements in the building
systems to increase energy efficiency.
Voluntary green building rating systems and ENERGY STAR Portfolio
Manager have been used to varying degrees in the building industry to
demonstrate building sustainability and energy performance. For
existing buildings, measured energy performance based on utility bill
history has been the dominant way to rate building energy performance.
However, when a complete and continuous utility history is missing (for
example, a vacant or partly empty building or a multi-tenanted
building), it becomes difficult to evaluate building energy
performance. Moreover, building stakeholders don't have a consistent
basis for determining whether the energy use differences between two
similar buildings are associated primarily with installed building
systems or with operational choices. This information is important for
building owners and investors when making decisions about efficiency
improvement; it also informs prospective buyers and tenants who may
want to compare among existing, new, and renovated buildings.
Therefore, a national program would enable building stakeholders to
directly compare as-built energy performance of building systems among
similar buildings, regardless of occupant behavior and building
operation.
Recent regional Asset Rating initiatives, such as California's AB
758 and the Massachusetts Commercial Asset Labeling Program, indicate a
growing interest in a national Asset Rating system. The AR Program
would facilitate the evaluation of energy-related building
characteristics, which include building envelope, HVAC systems,
lighting systems, and other major building service related equipment.
The program would identify opportunities for energy efficiency
improvements and estimate their likely savings. If communicated to
potential buyers, lessees, and lenders, the Asset Rating would provide
information necessary for the real estate market to value building
energy efficiency measures.
The Department has aggressive goals for facilitating cost-effective
energy savings in commercial buildings, most recently stated in the
Better Building Initiative as a goal of 20% savings by 2020. Through
the AR Program, the Department intends to establish a building Asset
Rating system that can be broadly applied to both new and existing
commercial buildings, and provide affordable and reliable information
to building stakeholders. The Department intends the Asset Rating
system to work with and complement the Portfolio Manager Operational
Rating system, once the Asset Rating system is sufficiently
demonstrated. Both of these systems could be expected to evolve over
time, providing opportunities for increasing integration. An integrated
Asset and Operational Rating together would provide a feedback loop and
accountability for building owners and operators to ensure that their
building is performing as intended and meeting its potential. An
integrated system would also help building operators track the results
of upgrades and identify potential operation and maintenance problems.
The Asset Rating and Operational Rating would together comprise a
national building rating system that effectively combines the as-built
building efficiency with a gauge of operational success.
This Request for Information (RFI) calls on stakeholders to review
the considered approaches and provide information to assist the
Department in the development and implementation of this program. DOE
intends to adopt or develop standardized approaches to evaluate the
potential energy efficiency of commercial buildings, provide strategies
to help building owners improve building energy efficiency, and
establish a framework to convey the information to audiences at various
levels. This RFI presents the following aspects of the AR Program:
Market needs and opportunities.
Guiding principles for the program.
Options and approaches for key elements of the program.
Pros and cons of various approaches.
[[Page 48154]]
Initial proposed approach.
Additional work that the Department is considering.
The RFI is structured as follows:
(1) Program Overview.
(2) Market Needs and Guiding Principles.
(3) Target Audience and Building Types.
(4) Basic Metrics.
(5) Rating Methods.
(6) Rating Scales.
(7) Recommendations for Improvements.
(8) National Commercial Building Energy Database.
(9) Quality Assurance.
(10) Potential for Additional Supported Options.
(11) Glossary of Key Terms.
(12) References.
The Department will consider all input it receives and plans to
have an initial program design available by the end of September 2011.
Based on that program design, the Department expects to pilot the
program in partnership with interested parties and ongoing commercial
energy efficiency programs, beginning in January 2012. The Department
welcomes input on issues or logistical concerns that could extend this
timeframe.
Program Overview
Limited information on the expected efficiency of a building based
on as-built building systems and opportunities for cost-effective
energy efficiency improvements are identified barriers to energy
efficiency investments. The Department seeks to address these barriers
by establishing a standardized approach for assessing the energy
performance of commercial building assets and developing an easy-to-use
tool to help building owners and stakeholders identify opportunities
for improvement. Accordingly, the AR Program, as considered, has three
components:
A rating system to compute building energy efficiency and
convey energy performance information, taking into account the building
envelope, mechanical and electrical systems, and other major energy-
using equipment. The Department intends to seek ways for the Asset
Rating to be used in coordination with the Portfolio Manager
Operational Rating to help building owners understand the opportunities
for both capital and operational improvements in their buildings.
A Web application, included as part of a free Asset Rating
online software tool (AR Tool), to maintain building data entered by
building owners or operators and to analyze building energy use,
accounting for envelope, mechanical and electrical systems, and other
major energy-using equipment. This tool would provide an energy rating
and enable owners and operators to benchmark their building efficiency.
It would be used to provide an Asset Rating Report.
A second facet of the AR Tool, designed to help building
owners and operators identify and implement strategies to improve
efficiency of their buildings. In addition to receiving an Asset
Rating, building owners and investors would be able to use the tool to
analyze the potential for capital improvements to increase energy
efficiency. The potential to improve and the potential energy savings
would be included in the Asset Rating Report. DOE intends to support
continuous improvement of energy efficiency by allowing buildings to be
re-rated following a retrofit.
Market Needs and Guiding Principles
The AR Program is intended to enable building stakeholders to
directly compare expected as-built energy performance among similar
buildings and to analyze the potential for capital improvements to
increase energy efficiency cost-effectively. It would give building
stakeholders insight into a property's long-term energy cost, thus
informing their valuation of that building. The AR Tool would provide
an as-built rating, identify potential energy efficiency improvements,
and provide the anticipated rating resulting from those improvements,
illustrating for stakeholders the impact of potential capital
improvements. Research (McCabe, 2011; McKinsey, 2009) shows a need to
communicate energy and cost savings to owners, investors, financiers,
and others to overcome market barriers and motivate capital investment
in building energy efficiency.
The AR Program is intended to complement and coordinate with the
existing Operational Rating system, ENERGY STAR Portfolio Manager. The
Department is aware of other rating systems and standards that exist or
are under development. These include but are not limited to ASHRAE
Building EQ, LEED, Green Globes, ASTM Building Energy Performance
Assessment, COMNET Commercial Buildings Energy Modeling Guidelines and
Procedures. The Department will consider developments in these rating
systems and standards as it creates a national Asset Rating system.
The primary goal of the AR Program is to spur commercial building
energy improvements in construction and/or retrofits, so the principles
that guide the program are based on market needs. These guiding
principles, which drive the key program elements, are as follows.
Information must be credible, reliable, and replicable.
Information must be transparent and easy to understand.
Collecting information and generating a rating must be
affordable.
Opportunities identified must be relevant and practical.
Program must include effective quality assurance.
Rating must recognize building energy performance across
the full range of building efficiency.
The Department welcomes stakeholder comments on these guiding
principles as the framework for the development of the program.
Target Audience and Building Types
The AR Program is aimed at a variety of building stakeholders--
owners, operators, investors, tenants, appraisers, and designers. It
may also inform lenders, local government, utilities, and green
building rating systems. Considering the variety of audiences, the AR
Program would provide an easy-to-understand rating that can convey
building energy efficiency information to those in the general public
who have no knowledge of building efficiency. The AR Tool would also
provide technical information and identify opportunities for
improvements to building professionals who would be implementing the
recommendations. The Department seeks to develop an affordable system
that provides a useful rating with minimal data collection. The
Department is considering a two-tiered program. The first tier would
yield a preliminary rating and identified opportunities for building
improvements, as well as an estimate of the savings from the
improvements. The preliminary rating of building efficiency would be
based on minimum building information. The second tier would provide a
certified rating after a qualified professional has validated the
building information (see Quality Assurance section). The preliminary
rating would give users rapid feedback on building efficiency and
improvement opportunities; the second tier rating would be appropriate
for the communicating the performance of the building to others.
The AR Tool is not intended to replace any engineering analysis
needed for building retrofits, but to provide building owners and
operators with a quick, easy, affordable tool based on a national
standard. The AR Tool would be designed for users who have basic
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knowledge of building systems, such as building engineers, facility
managers, or contractors. Assistance from credentialed or third party
AR certifiers would only be needed to receive a certified rating. The
Department intends to work with interested parties, including state and
local governments, utilities, and energy service companies, to develop
ways to use the AR Program to promote market transformation.
Because of the different levels of complexity due to building type
and size, the AR Tool development will first focus on building types
that generally have simpler building systems and have adequate
information sources to establish a reliable rating system. These
building types include office, school, retail, warehouse, and assembly.
In time, other building types will be added, including data center,
laboratory, refrigerated warehouse, health care, lodging, food sale,
food service, and mixed use buildings.
Basic Metrics
A building's expected energy performance can be described in a
variety of ways, including (1) Energy use; (2) energy cost; or (3)
greenhouse gas emissions associated with the building's energy use. The
Department is considering several options for representing building
energy performance, as described below.
Energy Metric--Source or Site Energy Use
An energy metric is the most straightforward way to represent
building energy performance. Three building energy metrics to be
considered are site energy use, net onsite energy use, and source
energy use. Site energy use can be directly calculated using the sum of
electricity natural gas and any other fuels used. If renewable energy
is generated onsite, the expected energy generation and net energy use
can also be calculated. Using a source energy metric requires the use
of a conversion factor to convert site electricity use to a source
equivalent, which would allow consumers to more equitably consider all
fuel types and the environmental consequences of electricity
generation. Although site energy is most closely related to the values
that customers see on their energy bills for each fuel type, using
source energy as a metric more closely reflect the cost tradeoffs among
different fuels and the long-term cost implications of different energy
choices. Regional source-to-site conversion factors vary and the
offsite generation mix is generally not controlled by the consumer.
Although regional source conversion factors more accurately represent
actual energy use, a national conversion factor allows comparison
across the nation and ensures that a building does not receive a
relatively low rating just because of its location.
The Department plans to use source energy with a national source-
to-site conversion factor as the basic metric because source energy can
most accurately represent total energy use of a building and the
related environmental impacts. Also, using source energy makes the
Asset Rating system compatible with ENERGY STAR Portfolio Manager,
which adopted source energy as its basic metric. Source energy use is
familiar to building owners and operators who have been using Portfolio
Manager or other building rating systems relying on Portfolio Manager.
The Department welcomes stakeholder comments on the energy metric for
Asset Rating.
Cost Metric
Consumers are generally more familiar with cost metrics. However,
energy costs for commercial buildings vary considerably in different
parts of the country and change over time, including over the course of
the day. Without much more specific information about a building's
operations and its time-dependent per-unit energy prices, energy cost
does not provide a durable, comparable metric upon which to base a
rating. A cost metric alone cannot directly be used to judge building
energy performance or guide building owners' investment decisions.
For the above reasons, the Department does not intend to choose
cost information as the primary metric for the program. However, the
Department is exploring how to use cost information to assess
opportunities to improve building energy efficiency and describe the
likely cost savings associated with these improvements. Though the
actual Asset Rating would not be affected by energy or equipment costs,
both of these costs may be used to perform a life cycle cost analysis,
the results of which could be used to propose opportunities for cost-
effective energy savings.
Greenhouse Gas Metric
Energy use significantly contributes to greenhouse gas emissions,
and the AR Program would provide an opportunity to educate consumers
and help them reduce their emissions. Using a greenhouse gas metric as
the primary program metric would most closely link the Asset Rating to
associated environmental impact. However, the primary focus of the AR
program is cost-effective energy efficiency improvements, which is not
perfectly aligned with a greenhouse gas metric. As noted by the
Northeast Energy Efficiency Partnerships using a greenhouse gas metric
can ``confuse the existence of non-carbon power sources--including
large hydropower and nuclear power--with actual energy savings.''
(Dunsky, et al, 2009).
Therefore, the Department does not intend to choose greenhouse gas
information as the primary metric for the program. However, the
Department is exploring ways to support greenhouse gas information as
an optional element of the program based on a partner's interest.
Initial Approach: The Department intends to use source energy use
intensity as the primary performance metric. Onsite renewable energy
generation may be recognized, but separately from the rating
calculation. The Department welcomes stakeholder comments on the above
metrics.
Rating Methods
Various rating methods are possible. All methods share some
characteristics, such as:
A data collection phase in which the user defines key
building characteristics.
An energy use prediction phase.
A comparison/rating phase.
For the data collection phase, the user would enter the
characteristics of the building being examined; these values would then
be used in conjunction with a set of default building characteristics
to develop the required inputs for the energy use prediction phase. The
user inputs would fall into six broad categories:
General characteristics (use type, location, age,
available fuels, etc.).
Design characteristics (geometry, orientation, window to
wall ratio, structure type, etc.).
Envelope elements (window types, wall constructions, roof
constructions, etc.).
HVAC system characteristics (technology used, fuel type,
efficiency, etc.).
Lighting system characteristics (lamp type, numbers of
lights, sensors and controls, etc.).
Service hot water (fuel type, efficiency, storage
capacity, etc.).
In addition to the above user inputs, a set of internal values
would be used in the analysis. The internal values are based purely on
a building's use type and would be held constant across all models of
buildings with similar functions. This set of inputs primarily
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consists of the occupancy and operation parameters, such as:
Occupancy schedule.
HVAC system operation.
Hot water use.
Both the user-entered and the internally defined, fixed building
characteristics would be combined to develop the inputs for a building
energy use prediction tool.
Several potential methods for predicting a building's energy use
are being considered, including:
Pre-simulating large numbers of buildings and using
interpolation to customize the results to an individual case.
Detailed energy simulation.
Simplified energy simulation.
Each of the above methods has unique strengths and potential
issues. Selecting the correct method will require tradeoffs between
flexibility, accuracy, and the end-user's time investment in data
collection.
In the case of a pre-simulation methodology, the benefits are
relative ease of use and a level of complexity that can be highly
tailored to the needs of the asset rating methodology. Once deployed,
this approach is less flexible than approaches that use real time
modeling because each possible combination of building attributes must
be predicted and modeled beforehand. For each additional building input
characteristic that the end-user can control, the number of required
models is greatly increased. Depending on the level of effort required
per model, it could be challenging to implement this approach with
enough granularity to provide useful results.
There is a wide range of building energy modeling tools, each with
different strengths and weaknesses, including differing levels of input
and output detail, required development time, and expected user
expertise. Most one-off energy models are highly detailed to allow the
inclusion of all of a building's unique characteristics. Using a
detailed modeling approach to formulate an asset rating would most
likely provide the greatest flexibility and accuracy. Such a tool
would, however, require a substantial amount of development time and
would still likely require a professional building energy modeler to
use properly--though with greater development time some of the
expertise requirements could be overcome.
Simplified analysis models use many simplifications and assumptions
that allow an inexperienced user to quickly develop robust energy
models. In general, these modeling tools allow fewer input combinations
than a detailed model and will reduce opportunities for error. The
primary drawback of a purpose-built simplified simulation model would
be user concern about the accuracy of the results.
Whichever rating calculation method is selected, the required
outputs would be the same. The Department intends to select one or more
metrics (see Basic Metrics section) to be the primary output of
modeling. The metric(s) would allow for both the placement of the
subject building onto a rating scale (as defined in Rating Scales
section) and the comparison of the building with similar buildings.
The Department welcomes stakeholder comments on the rating
calculation methods.
Rating Scales
There are several ways to deliver building energy performance
information to consumers. Various types of scales have been used in the
existing building rating systems. The following is a discussion of the
different methods and their applicability to the Asset Rating system.
Numeric Scale Reflecting Physical Units
This scale method represents a certain type of physical unit. For
example, the EnergyGuide label found on household appliances uses a
physical scale (supplemented with cost information), such as kilowatt
hours per year in the case of refrigerators supplemented with the
expected annual cost of the particular refrigerator. The miles-per-
gallon (MPG) rating displayed on new vehicles is another example of
using non-converted physical units to convey information. The physical
units can transparently deliver the technical information to the
consumers; however, consumers may be unable to judge if they are
unfamiliar with the units. Unlike cost or MPG rating for vehicles,
energy units such as kBtu/ft \2\ do not convey enough information to
most audiences without engineering or energy knowledge. The Asset
Rating aims to promote market transformation and educate consumers, and
an absolute energy scale could be challenging for the general public to
interpret. In addition, an unprocessed numeric scale does not offer a
comparison between a building and its peers, which is a desirable
comparison because consumers are often motivated by how they compare to
others.
Numeric Scale Converting Physical Units into Score System
This rating method converts a metric from physical units into a
score or index, which may be more easily understood by consumers.
ENERGY STAR Portfolio Manager, for example, converts energy use in
commercial buildings into a score on a 100-point scale. The Home Energy
Rating System (HERS) scale, used primarily for new homes, also converts
energy units into an index, where 100 represents a home built to 2006
International Energy Conservation Code standards.
The scores can be calculated using either a percentile rank method
or an interval method. ENERGY STAR Portfolio Manager uses a 100 point
percentile rank scale based on supporting databases, which provide
statistical representation of a given building type. This approach is
not appropriate for the Asset Rating because there is no reliable
database recording the efficiency of existing buildings. In addition,
the AR Program is intended to provide information on expected energy
use (and energy costs) and effective energy efficiency strategies
across all buildings. A percentile rank scale does not accomplish this
objective throughout the entire range of the scale. In particular, the
high efficiency--on an absolute basis--of the most efficient buildings
is not fully reflected.
An alternative is a 100-point interval scale. Use of a 100 point
scale would have some consistency with ENERGY STAR Portfolio Manager.
An advantage of a 100-point interval scale is that the rating system
can recognize building efficiency and building efficiency improvements
in a similar manner at all efficiency levels. DOE is also considering a
simpler numeric scale, similar to the 10-point scale used by the Home
Energy Score (https://www1.eere.energy.gov/buildings/homeenergyscore/).
A 10-point scale does not imply the same degree of precision as a 100-
point scale. In this sense, a 10-point system, although a numeric
score, functions as a bin system, which is discussed in the next
section.
Categorical Scale Assigning Physical Units Into Bins
The physical units can also be converted into a category system,
which could be presented in letters, numbers, stars, or other symbols.
It has been shown that categorical scales, compared with continuous
numeric scales, lead to better comprehension because ``categorical
ratings are easy to use and quick to decipher'' (Thorne and Egan,
2002a). Viewers can more easily gauge a building's performance relative
to other buildings or a reference point. Categorical ratings using
letter grades have been used in multiple building
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rating systems such as ASHRAE Building Energy Quotient and the UK
Display Energy Certificate. A rating system based on letter grading is
also a common format for several countries in the European Union,
although the meaning of each grade could be very different across
regions. A series of studies on the EnergyGuide label has demonstrated
that consumers favor a stars-based format because it is familiar and
intuitive, while check marks or letter grades are more confusing
(Thorne and Egan, 2002b).
While stars and grades simplify things for consumers, a binned
system also has drawbacks. Using a binned system can appear
qualitative. Including a reference value can help alleviate this
weakness. The number of bins is also important. Too many bins may
complicate the system, while too few bins can make it hard for a
building to improve from one bin to the next, and not be appropriately
reflective of the investments made and the savings being achieved.
With a well-defined bin range, a categorical system would allow
easy distinction between the categories and allow quick comparison
between buildings as well as changes within a building category as
improvements are made. Star ratings are visually appealing, motivating,
and quickly draw attention. Thorne and Egan's (2002b) research also
suggested ``consumers found the stars rating system complementary with
the ENERGY STAR label and certification.'' The shortcoming of a stars-
based format is that the number of stars needs to be limited. More than
six stars may make it difficult for viewers to recognize the value
quickly. In this case, a numeric format (10-point scale) becomes
advantageous.
Initial Approach: For the Asset Rating system, the Department is
considering using a scale using physical units, possibly accompanied by
a numeric interval scale. A 100-point interval scale would complement
Portfolio Manager's 100-point range. The Department welcomes
stakeholder comments on rating scales.
The Department is considering including the following basic
building information on the Asset Rating Report to ensure that similar
buildings are used for comparison:
Building name.
Year built.
Climate zone.
Building type.
Year rating is issued.
Report serial number (for tracking purposes).
Analysis results would be clearly displayed and formatted for easy
reading and understanding, and would include:
Calculated energy use.
Building Asset Rating based on calculated energy use.
Asset Rating that can be achieved with energy efficiency
upgrades.
Energy and cost savings associated with the higher
achieved rating.
Additional information may also be provided in the future, such as:
A reference point to help users understand how their
building score compares to a chosen energy code.
Indication of whether the building has systems to provide
a certain amount of energy from onsite renewables.
Greenhouse gas emissions.
The Department is also considering working with interested partners
to include local benchmark information on the Asset Rating Report for
comparison. For example, a state might wish to include information
pertaining to average asset ratings for a particular building type
within the state. The Department welcomes stakeholder comments on the
information included on the Asset Rating Report.
Identified Opportunities for Energy Efficiency Improvements
Based on the building information, the AR Tool would identify
potential opportunities for energy efficiency upgrades that could cost-
effectively improve a building's asset rating.
The AR Tool would identify improvement opportunities in areas such
as heating, cooling, and ventilation equipment; envelope; glazing;
service hot water; lighting; and electric motors.
The AR Tool is not intended to replace energy audits or any
engineering analysis required for building retrofits. It is intended to
provide an affordable way for building owners and operators to
determine which building systems are good candidates for an efficiency
upgrade. The tool may be a gateway for building owners who have limited
internal resources to engage with service providers who can provide
building rating with the AR tool and offer products and services that
can improve energy performance.
Initial Approach: The Department is considering computing cost
savings estimates for energy efficiency measures based on regional
energy costs, acknowledging that local conditions will vary. The AR
Tool will not display return on investment given that equipment and
labor costs are likely to vary considerably. The Department welcomes
public comments on the best way to assess opportunities for energy
efficiency improvement.
National Building Asset Rating Database
The Department intends to establish a national building Asset
Rating database to track Asset Ratings and ensure the legitimacy of
ratings. The Department is aware of potential privacy issues related to
maintaining this information and the desire for some jurisdictions to
require disclosure of energy Asset Ratings. Public comments are welcome
regarding structure and use of the Asset Rating database.
Quality Assurance
The ability to generate accurate and consistent information is
important to maintain user confidence. The Department intends to
include quality assurance requirements for the following:
Asset Rating Tool
The user would receive a warning when automated checks suggest that
data entered may be incorrect or incomplete.
Professional Requirements for Asset Rating Application
Building owners would be able to use the free Web application to
enter the required energy and building information, generate a
preliminary building Asset Rating, and receive recommendations. The
Department is considering requiring a professional with specific
approved qualifications to validate building information inputs for a
building to be eligible for a certified Asset Rating. The Department
intends to develop a guideline to specify the credentials that a
professional must hold in order to generate a certified rating.
Third-Party Verification
Third-party verification can be an effective way to ensure program
quality. Some jurisdictions may want to require third-party
verification of the accuracy of data used to acquire a certified
rating. The third party may require building owners to submit
supplemental building information and/or perform an onsite audit. The
Department is evaluating options for implementing this type of
requirement, including establishing verification standards and
approving qualified third-party organizations. Verification data and
reports may be integrated into the Asset Rating database, software
tool, and reports.
Technical Support
Full documentation of the rating methodology would be available
online for public review. A user manual, guidelines and eligibility
requirements
[[Page 48158]]
for the qualified professionals, data checklists, and FAQs would be
available to owners and operators to applying for certified Asset
Ratings. In addition, help for users would be available before, during,
and after the application process. A user feedback survey may be
implemented to help gauge program satisfaction and to gather
suggestions for improvement.
Initial Approach: The Department is considering ensuring the
quality of the Asset Rating by providing a free Web-based application
to guide standard data collection, calculate energy use, and generate
ratings; requiring professionals to review final submissions; enabling
third-party verification; and providing necessary technical support.
Public comments on the quality assurance methods are welcome.
Potential for Additional Supported Options
While a national performance metric and rating system would help
ensure consistency across the country, the Department recognizes that
state and local governments and other program implementers may be
interested in providing information that goes beyond the national
metric and rating.
To that end, the Department intends to partner with state and local
governments to support the sharing of additional information as part of
this effort. For example, while greenhouse gas information is unlikely
to be a standard metric for the AR Program, the Department could
provide conversion factors to states and other partners that are
interested in providing such information.
This document describes the major design questions that the
Department is considering in developing a voluntary AR Program. DOE is
seeking comments on the issues discussed above. However, stakeholders
are welcome to raise other relevant issues that the Department may have
overlooked in this design process.
Glossary of Key Terms
Asset Rating--An assessment of building energy performance that is
based solely on a building's physical assets, excluding the impacts of
building operation characteristics.
Asset Rating Report--A short form document showing only key
outcomes for a building that has undergone the Asset Rating process.
Baseline--The amount of energy that is consumed annually before
implementation of energy efficiency measures based on historical
metered data, engineering calculations, submetering of buildings or
energy-consuming systems, building load simulation models, statistical
regression analysis, or some combination of these methods.
Benchmark--The building profile used as a reference point for
comparing energy use and other performance characteristics.
ENERGY STAR Portfolio Manager--A Web-based, portfolio-wide energy
and water tracking system that tracks many metrics of energy use-
including total site energy, source energy, weather normalized energy
use index, greenhouse gas emissions, indoor and outdoor water usage,
and (for some building types) the ENERGY STAR score.
ENERGY STAR energy performance scale--A 1-100 percentile rank score
that indicates how a building performs relative to similar buildings
nationwide. The scores are adjusted using standardized methods to
account for differences in building attributes, operating
characteristics, and weather variables. Buildings performing better
than 75% of similar buildings can be certified to ENERGY STAR.
Energy Efficiency Measure--A design, operation, or technology
change for the purpose of reducing energy consumption.\1\
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\1\ Source: ConstructionDictionary.com, https://www.construction-dictionary.com/definition/energy-efficiency-measure-EEM.html.
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Net Onsite Energy Use--The sum of all energies that are consumed in
a building minus any energy that is generated on site.
Operational Rating--An assessment of building performance that is
developed to reflect the energy performance of a building, accounting
for its physical assets and its specific operational characteristics.
Site Energy Use--The amount of energy consumed at a building
location or other end-use site, as reflected in the utility bills.
Includes electricity generated by onsite renewable energy systems.
Source Energy Use--The total energy used at a site, including
upstream losses in distribution, storage, and dispensing of primary
fuels, or power generation, transmission, and distribution of
electricity.
Percentile Rank Scale--A percentile scale that is defined solely in
relation to a sample population; the scale itself contains no
information in absence of information regarding the specific sample
population. The primary purpose of a percentile rank scale is
comparison between peer buildings.
Interval Scale--A scale for which each location along its span
relates directly to some metric or measurement.
References
ASHRAE. 2009. Building Energy Quotient: Promoting the Value of
Energy Efficiency in the Real Estate Market. Atlanta, GA. American
Society of Heating, Refrigerating and Air-Conditioning Engineers.
https://www.sustain-rhythm.com/HPB%20Exchange/files/Energy_ABELFinal.pdf.
Dunsky, P., Lindberg, J., Piyale-Sheard, E., and Raesy, R. 2009
Evaluating Building Energy Efficiency Through Disclosure and Upgrade
Policies, A Roadmap for the Northeast U.S. Lexington, KY. Northeast
Energy Efficiency Partnerships, Dunsky Energy Consulting.
Massachusetts Department of Energy Resources. 2010. An MPG
Rating for Commercial Buildings: Establishing a Building Energy
Asset Labeling Program in Massachusetts. Boston, MA. https://www.mass.gov/Eoeea/docs/doer/Energy_Efficiency/Asset_Rating_White_Paper.pdf.
McCabe, M.J. 2011 High-Performance Buildings--Value, Messaging,
Financial and Policy Mechanisms. Richland, WA. Pacific Northwest
National Laboratory.
McKinsey & Company. 2009. Unlocking Energy Efficiency in the
U.S. Economy. New York, NY. McKinsey & Company, Inc. https://www.mckinsey.com/en/Client_Service/Electric_Power_and_Natural_Gas/Latest_thinking/Unlocking_energy_efficiency_in_the_US_economy.aspx.
Thorne, J., and Egan, C. 2002a. An Evaluation of the Federal
Trade Commission's EnergyGuide Appliance Label: Final Report and
Recommendations. Washington, DC: American Council for an Energy-
Efficient Economy.
Thorne, J., and Egan, C. 2002b. The EnergyGuide Label:
Evaluation and Recommendations for an Improved Design. Proceedings
of the ACEEE Summer Study on Buildings, Panel 8: 357.
Disclaimer and Important Notes
This is an RFI issued solely for information and program planning
purposes; this RFI does not constitute a formal solicitation for
proposals or abstracts. Your response to this notice will be treated as
information only. DOE will not provide reimbursement for costs incurred
in responding to this RFI. Respondents are advised that DOE is under no
obligation to acknowledge receipt of the information received or
provide feedback to respondents with respect to any information
submitted under this RFI. Responses to this RFI do not bind DOE to any
further actions related to this topic.
Issued in Washington, DC, on August 2, 2011.
Kathleen B. Hogan,
Deputy Assistant Secretary for Energy Efficiency, Office of Technology
Development, Energy Efficiency and Renewable Energy.
[FR Doc. 2011-20014 Filed 8-5-11; 8:45 am]
BILLING CODE 6450-01-P